pirn it inter-office correspondence · 2020. 6. 12. · i. history of the problem^251 the village...

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< PIRN It 7c: . yCiliN q, .FIENNINGSCN. From: . vV"??T H . A -. .P? D . A . R P. 62 INTER-OFFICE CORRESPONDENCE Gate:.... ..7/7/8.2. Suciect: . ADDITIONAL SUPPORT INFOF.MATIC". WAUKEGAN HARBOR LITIGATION This memorandum, in response to your request of 7/2/82, presents a brief history of the Upper Hudson River PCS problem and project descriptions, key design criteria and cost/benefit analysis for the following PCB-related projects: o The Fort Edward Terminal Channel Excavation and Remnant Pool Depos.it Mitigation completed by the NYSDEC in 1978. o Tha Hudson River PC3 Reclamation Project In addition, dredging production rates are presented for the alternative dredging schemes developed as part of the Hudson River PC5 Reclamation Project. ; DEPOSITION i , EXHIBIT rjR H-1S -1-

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Page 1: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

< PIRN It7c: . yCi l iN q, .FIENNINGSCN.

From: . vV"??TH .A-. .P?D.A.RP.

62

INTER-OFFICE CORRESPONDENCE

Gate:.... ..7/7/8.2.

Suciect:. ADDITIONAL SUPPORT INFOF.MATIC". WAUKEGAN HARBOR LITIGATION

This memorandum, in response to your request of 7/2/82,presents a brief history of the Upper Hudson River PCS problemand project descriptions, key design criteria and cost/benefitanalysis for the following PCB-related projects:

o The Fort Edward Terminal Channel Excavation andRemnant Pool Depos.it Mitigation completed by theNYSDEC in 1978.

o Tha Hudson River PC3 Reclamation Project

In addition, dredging production rates are presented forthe alternative dredging schemes developed as part of theHudson River PC5 Reclamation Project.

; DEPOSITIONi , EXHIBITrjR

H-1S

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Page 2: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

I. HISTORY OF THE PROBLEM^25

The Village of Fort Edward is located in WashingtonCounty, New York,, approximately 45 miles north of Albany(F:gure 1). Recent activities in the upper Hudson River atthis point began in the spring of 1974 after the removal of a20-ft high timer crib Jam, which was in poor structural condi-tion and presented a hazard to the population living down-stream.

After the dam was removed, some 850,000 cu yd of debrisand sediment which had accumulated behind the dam for over 100years was scoured from the deposits above the dam and depositedin the river channel within a distance of about one mile down-scream. Various remedial measures, including removal of.debris, were undertaken during 1974-75 by the State of MewYork. All these efforts, however, were carried out with noknewledge of PCS contamination.

In late 1975-76, field investigations were under takr-i. todetermine the extent of PC3 contamination in the river system.The presence of this substance had resulted from discharge ofPCB-contaminated wastes over many years at two locations in theformer pool of Fort Edward dam. Sampling indicated thatremnant deposits on the western bank of the river had PCBlevels of approximately 10 ug/g, whereas those on the easternside (where the PCB outfall points were located) has PCB levelson the order of 100 to 5,600 ug/g. High levels of Cd and Pbwere also present.

In April 1976 a flood with an approximate recurrence of100 years occurred. This event caused the scour of an addi-tional 250,000 cu yd from unprotected areas of the former pool.Deposits in the Fort Edward Terminal Channel as a result of theApril 1976 flood averaged 20 ug/g PCB, a relatively low levelbecause the material has been scoured primarily from the lesscontaminated western bank.

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Page 3: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

I. HISTORY OF THE PROBLEM^251

The Village of Fort Edward is located in WashingtonCounty, New York, approximately 45 miles'north of Albany(Figure 1). Recent activities in the upper Hudson River atthis point began in the spring of 1974 after the removal of a20-ft high timer crib dam, which was in poor̂ structural condi-tion and presented a hazard to the population living down-stream.

After the dam was removed, some 850,000 cu yd of debrisand sediment which had accumulated behind the dam for over 100years was scoured from the deposits above the dam and depositedin the river channel within a distance of about one mile down-stream. Various remedial measures, including removal of'debris, were undertaken during 1974-75 by the State of MewYork. All these efforts, however, were carried out with noknowledge of PCB contamination.

In late 1975-76, field investigations were undertaken todetermine the extent of PC3 contamination in the river system.The presence of this substance had resulted from discharge ofPCB-contaminated wastes over many years at two locations in theformer pool of Fort Edward dam. Sampling indicated thatremnant deposits on the western bank of the river had PCBlevels of approximately 10 ug/g, whereas those on the easternside (where the PC3 outfall points were located) has PCB levelson the order of 100 to 5,500 ug/g. High levels of Cd and Pbwere also present.

In April 1976 a flood with an approximate recurrence of100 years occurred. This event caused the scour of an addi-tional 250,000 cu yd from unprotected areas of the former pool.Deposits in the Fort Edward Terminal Channel as a result of theApril 1976 flood averaged 20 ug/g PCB, a relatively low levelbecause the material has beer scoured primarily from the lesscontaminated western bank.

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Page 4: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

PCRME3POOL

AREA 3A

TERMINAL .' 'CHANNEU :''l.

2OCO iCCO

D R E D G I N G AND DISPOSAL AREAS

Page 5: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

The need to remove this new material blocking the naviga-tion channel presented an opportunity to demonstrate certainaspects of removal and containner._ of river debris which,although not classified as hazardous, could be disposed of in asite which essentially met chemical landfill requirements. 1

The project generated valuable information on severalimportant aspects of contaminated material handling and dis-posal. These findings are being used in preparing final designand dredging administration procedures for the proposed HudsonRiver PCS Reclamation Project in the 40-mile river reachbetween P̂ '-t Edward and Albany, where bed and bank sedimentsare contaminated by some 400,OCC Ib of PC3. In addition,approximately 700,000 Ib of PCB is located in or adjacent tothe study area in numerous landfills, dumps, and dredge spoilareas.

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Page 6: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

II. THE FORT EDWARD TERMINAL CHANNEL EXCAVATIONAND REMNANT DEPOSIT MITIGATION (1978)PROJECT DESCRIPTION________

Koreau PC3 Encapsulation SiteThe disposal area occupies some ten acres in the Town of

Moreau, Saratoga County, New York. The site was owned by theState and war; originally an unused hydraulic dredge spoil site.

The western one-third of the site is underlain by ten to40 ft of glacial lake clays, and the remainder by brown siltyfine sand. Hydraulic conductivities of the underlying mater-ials are on the order o." 10~ to 10~ cm/sec.

Because of the variety of subsurface deposits, it wasdetermined to cover the entire bottom with an 18-inch thickLayer of compacted clay, which has a hydraulic conductivity (k)or. tne order to 1 x 10~ cr.i/sec. Before the liner was placed,Lhc- sit-.cr surface was drained of perched water areas, organicmaterial vas removed, and a four-ft hiyh interior clay dike- war.constructed along the southerly and easterly perimeters. Thenortherly and westerly perimeters of the site were establishedon existing debris from previous channel dredging programs

The c]ay liner was extended up the existing slope toprovide a barrier to migration from the existing deposits, andan exterior trench drain of crushed stone and perforated pipewrapped in filter cloth was installed to intercept groundwaterflow. The side slopes of the disposal site had a maximumhorizontal .-vertical slope of 4:1 (Figure 2), A system of pavedsurface drains was provided to intercept surface runoff and an18-inch thick clay cover was placed over the deposited debris.The final slope dressing consisted of 12 inches of materialsuitable for turf establishment (silty sand), followed byseeding ar.d mulching. The permeability of the compacted clayliner was determined by infiltrometer.

The native clays utilized for the liner and cover wereexcavated from a borrow pit a few hundred yards from the site.

Figure 3 presents two photographs of the complete Moreaubj te.

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Page 7: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

100 FT. 200 FT. 300 FT.

N A T U R A L SCALE

E L . I S O

I2~ TOP DRESSING •

II" CLAY COVER-

20

V E R T SCALE 2 i H O R I Z . SCALE

SITE CROSS SECTIONS

Page 8: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

PCB encapsulation site. Town of Horeau, M«w York, July 1979.View Looking eastward at completed site eight months after final seedingwith mixed grasses and clover. Side slopes of fill are one vertical onfour horizontal. Paved drains for surface run off and groundwater arevisible (right and foreground). Site is a joint project of DOT and DEC

PCB encapsulation site, Town of Moreau, New York, June 1980.View looking eastward with completed site in lower half of photograph.Hudson River at top. Paved drains are visible around the perimeter ofthe site. DOT Moreau spoil site is at left of photograph, previouslyused borrow area at right. River Road crosses lower right hand cornerof photograph.

Page 9: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Dredging OperationsApproximately 180,000 cu yds of debris and sediment

containing 6,400 pounds of PCB were removed from the FortEdward Terminal Channel during two periods: September-December1977 and April-June 1978. During October 1978, an additional14,000 cu yds of material containing approximately 25,000pounds of PCB were removed from Remnant Deposit Area 3A.

Tho terminal channel deposits averaged 20 ug/g PCBfwhereas deposits from Area 3A had an average PCB concentrationof 1,000 ug/g, and thus required a more careful handlingoperation. The general excavation procedure consisted ofremoval of material by dragline trom the terminal channel anddeposit in a windrow to allow for drainage and storage ofmaterials. After a few hours the material became well drainedand was easily handled.

During removal of Ihe Fort Edward Terminal Channel materi-al, the agitation of the bed deposits by the dragline exca-vation cjenerated ai- oily floating scum which drifted away fromthe area being excavated. To resolve this problem a conven-tional oil boom was deployed, trapping the scum, which wasremoved manually, along with wood debris. PCB levels in the *floating srum reached as high as 4,000 ug/g dry weight, which

. ̂cessitated some care in handling.The Area 3A deposits, located above normal water level,

were removed with conventional power shovels and generally jloaded directly into trucks, although some stockpiling was _... _ idone. Special care was taken to clean loose material fromtrucks, and loads were covered to prevent contaminated materialfrom being tracked onto highways. At the Moreau site, thedredged material was placed on lifts on the order of one tothree ft to a total depth of approximately 15 ft.

Site ProblemsBecause of heavy fall rains and the onslaught of an early

winter, the site was not covered with clay within the time

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Page 10: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

frame originally intended. As originally designed, dredgingand covering operations were to be completed by December 1977.The material from Area 3A were added to the project because thesite was still open thru the summer of 1978.

During the period when the site was exposed (August1977-Novemfaer 1978) precipitation in the vicinity was measuredat 66.5 inches. This value is about 30 percent greater thanaverage for the same period. Measurements made through theinstallation of temporary observation wells/ as well as severalbaekhoe test pits indicated that some 12 feet of saturatedmaterial existad at the site prior to start-up of the dewater-Lng operations.

In May of 1978, wet spots were noticed in two areas of thenewly clay covered south and east slopes. A few weeks afterthe covering of the clay surface with 12 inches of turf estab-lishment material the areas in which the wet spots were noticedexperienced tension cracks followed by surface slumping.Slumping alonq the south slope occurred over an area of about50 feet, and slumps over .in area of about 100 feet, long oc-curred on the east slope. _

Dewatering the SiteThe site was originally designed under the assumption that

material would be spoiled and covered during the same season. :An internal clay perimeter dike was constructed three to four '<feet above the bottom of the liner. In addition, one permanentfour-inch monitoring well/drain (DOT) was installed in a lowpart of the disposal site. It was anticipated that six toseven inches of precipitation might percolate through the claycover per year. Thii would have resulted in an accumulation ofabout 1.9 x 10 gallons per year, exclusive of leakage throughthe bottom and drainage out the four-inch monitoring well anddrain. The drain was designed to accept a flow of three tofive gpm (15 in. of 30 slot screen), or 1.6 x 106 to 2.6 x 10

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Page 11: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

gallons per year. At this rate (and with some bottom leakage)it was expected that water accumulation would be minimal, andthat the interior dike would provide storage capacity for atleast a few years accumulation. The in-situ hydraulicconductivity of the material was much less than anticipated,with the drain yielding only about 0.5 to 1 gpm.

In July o£ 1978, various alternatives for dewatering ofi:he site were evaluated for cost and time requirements. •

[•: was determined that a wellpoint dewatering systemrunning parallel to the east and south slopes would be the onlytimely means of dewatering for slope repairs. It was alsodecided to install a permanent trench drain system in thevicinity of the two slope slippages. The length of the trenchdrain would be determined by the ease of installation encoun-tered in the field.

WelLpoint. InstallationNine hundred feet of header and 82 points were insta J.led,

during the period September 25-29, 1978.The operation of the wellpoint system allowed for an

almost immediate repair of the failed slope areas, althoughpumping rates were much less than expected. The repairsconsisted of removing the 12 inches of turf establishmentmaterial and the 18 inches of clay about and adjacent to thefailed areas. All slumping occurred at the clay-dredge spoilinterface. Approximately .1,800 square yards of slope wereremoved and repaired during October of 1978. In addition an- -interior trench drain 400 ft long by 4.5 wide was installedadjacent to and between the two failure areas.

Analysis of Dewatering OperationsThnurrh December 1978 it is estimated that approximately 1

x 10 gallons were removed from the Moreau site through

Page 12: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

wellpoint pumping, siphon operation and gravity drainage (DOTwell) .

Siphon operations have continued sporatically (no winteroperations) to the present time. Trom December 1978 to March1980, it is estimated that an additonal 820,000 gallons havebeen removed. This number is based on a siphon operation for130 days at 3.5 gpm (655,000 gal) and a gravity drainage ofabout 0.25 gpm continuous since December 1978 (165,000 gal).The PCB concentration of this water is monitored periodicallysince it is discharged back into the Hudson River. As ofMarch, 1980 site water levels were on the order of 141.50 ft adrop of 2.7 ft since December 1978. Based on the theoreticalporosity area drawdown relationship 785,000 gallons (2.7 x290,000) would have been removed. This number correlatesnicely with the estimated actual withdrawal.

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Page 13: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

III. HUDSON RIVER PC3 RECLAMATION PROJECT DESCRIPTION

A. Projecc DescriptionThe Hudson River PC3 Reclamation Project as presented in

the Scoping Report (March 1981) includes four componentsdirected toward reducing the impact of PCB on the Hudson River,its biota, and the surrounding Hudson River Valley. Thesecomponent.s art*:

o Dredging of approximately 27 hot spot^ ' areas in theriver bed with containment in a secure upland site.

o Design and construction of a secure upland contain-ment site caoable of long-term isolation of contami-nated material.

o The dressing and fencing of remnant deposit areas 3and 5, located above the former Fort Edward Dam site.

o Destruction of the recovered PCB at such time as atechnically and economically feasible procedurebecomes available.

B. Containment SiteThe containment site, referred to as Site 10 in earlier

reports, is situated on a 250 acre parcel of land locatedapproximately 2.5 miles south of the Village of Fort Edward, inthe Town of Fort Edward, in Washington County, New York. (SeeFigure 4).

The site's major components include:o Containment Areao Roughing and Storage Pondo Surge Pondo Water Treatment Planto Leachate Collection Systemo Storr.i Water Drainage Systemo Chemical Feed System

Ul Hot spots have been defined as areas of PC3 contaminationequal to or greater than 50 yg per g.

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Page 14: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

CONTAINMENT AREA

ROUGHING ANDSTORAGE POND

RESCOPED

MALCOLM P1RN1E INC

Page 15: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

F I G U R E

75 150 225 METERS

NMENT S I T E

Page 16: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Containment Area - The containment area is an earthenbasin bisected by a cross dike. It occupies approximately 40acres at its maximum water surf*'-0 and its total containmentvolume of approximately 1,100,000 cu yds. This volume issufficient to hold all of the 27 hot spots.

The containment area is designed for long term encapsula-tion of PCB-contaminated materials.

Roughing and Storage Pond - The roughing and storage pond(3&SP) is an earthen basin with a maximum water surface area ofapproximately 12 acres.

After the slurried dredge material is pumped into thecontainment area, weir overflow is transported via pipeline tothe R&SP. The primary purpose of this basin is to ensureefficient sedimentation near the end of each dredging season as;:he effective overflow rate in the concainment area decreases.The T&S? also provides protection Cor the subsequent treatment..mils froii! ^ny upsets in Uhe containment ar<?a whioh might leadt-o transit?nt escape of dredged material.

A small portable dredge will be operated to recyclesettled dredged material back into the containment area.

The R&SP is not a permanent containment unit. At the endof the dredging program, all of the contaminated material inthe R&SP will be relocated to the containment area and the pondwill be filled in and regraded.

Surge Pond - The surge pond is an earthen basin with amaximum water surface area of 2.4 acres. This pond receives -weir overflow from the R&SP. Its purpose is to buffer thetreatment plant units from surges in the dredging process andto provide a convenient, sediment-free point for treatment feedand recycle supply pump suctions if a recycle dredging proce-dure is implemented. A detailed discussion of dredging optionsis presented in the Containment Site Design Report.

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Page 17: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Water Treatment Plant - The water treatment plant consistsof two earthen basins, the flocculation basin and the settlingbasin, with maximum water surface areas of 0.1 and 1.0 acres,respectively. The plant has a capacity of 13 million gallonsper day (mgd) and consists of coagulation, flocculation andsedimentation units. The purpose of the water treatment plantis to reduce PCS concentration in the dredge return flow beforedischarge to the rivec.

Th« water treatment plant, is expected tea achieve effluentsuspended solids less than 4 milligrams per liter and turbidityless than 10 NTU with procev chemical doses. The average PC3concentration in the discharge is axpected to be in the 10-20microgram per liter range.

Leachate Collection Syscam - The leachate collectionsystem is a network cf perforated drainage piping laid ingravel-filled, filter-cloth-lined collection trenches at thebase of the containment *rea. The bottom of the containmentar-.i* is sloped to transmit flow towards the trenches.

The leachate collection system will be utilized in twophases: short-term dewatering and long-term percolation.

A piping system connects the drainage system to a leachatestorage tank and subsequently to a discharge point at theHudson River.

In addition valves, collection and sampling wells, and aflow metering and monitoring manhole are provided to determinethe quantity and concentration of PCS in the leachate. Dis-charge to the Hudson River will only be permitted if theobserved leachate quantities and concentrations will have noadverse impact on the River. If river discharge proves unac-ceptable, the leachate will be stored in-place and periodicallycollected and treacad from cha leachate storage tank.

Storr.watar Drainage Systeav - The stormwater drainagesystem will intercept and convey stornrwater runoff that wouldhave directly affected the containment site. Precipitation

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Page 18: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

falling on the containment site, and on the watershed north ofthe containment site, will be transported by the drainagesystem to the Hudson River.

The components of the drainage system include a combina-tion of swales, open channels, and closed conduits.

Chemical Feed System - Pumps, piping, tanks and dilutionwater will be provided for two optional treatment processes -polymer only and a alum, caustic and polymer combination. Therequired equipment will be housed in a chemical feed building.

Other Site Components - Other site components include pumpslation, access road, electrical services, fencing, seeding,clearing ar^ grubbing and monitoring wells.

C. Hot Sect DredgingThompson Island Pool - The Thompson Island Pool is located

between the Thompson Island Dsm and Rogers Island. The areasto be dreoged are.the 20 identified hot spots (including fourabove Lock. 7) with a volume of approximately 645,500 cu yds and105,800 Ibs of PCD (see Table 1).

Lower Pools - Based on a range of costs per cubic yard fordredging, transport and treatment, between 160,000 and265,000 cu yds of material could be dredged in the lower poolswithin the budget constraints of the rescoped project.

Using the MPI estimates of contaminated volumes and PCBmasses listed in Table I, and applying the criteria describedpreviously in the Rescoping Report, to each of the lower pools,resulted in the following dredging program for the lower pools.Using the lower range value of 160,000 cu yds (high estimate ofunit cost), only lower pool hot spots 29-34 in the Lock 5 Poolwill be dredged. Using the higher range value'of 265,000 cuyds (lew estimate of unit cost), both lower pool hot spots 929-34 in the Lock 5 Pool and approximately 80 percent of hotspot 37 in the Lock 3 Pool will be dredged. Table 2 detailsthe hot spots to be dredged under the rescoped program.

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Page 19: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Table 1

Hudson River ?C3 Reclamation Project Areas to be Dredged

Contaminated and Removal Volumes and PCB Quantities7

PCS2'3"*Quantity(Ibs)

340140140320900

3,7109,270560

18,830590

1,940290420320

35,3303,34022,0602,7702,460450

2,030104,900

220690

8,150170950

12,35022 ,500~

Hot Spot1Area No.

I2J4

Subtotal

5b•7

391C111213JL-1151617181920

Subtotal

293031323334

Subtotal

Total UsingHigh Esti-mate ofUnit Cost8

Area(sq ft)

66,60021,20038,30078,800204,900

460,4001,033,700110,600

1,462,700113,500191, 2CC57,100•J5,70028,000974,200286,600446,50083,200201,70042,00062,700

5,604,800

32,70054,400194,30041,200119,400955,300

1,397,800

7,207,500

Contaminated'1'Volume(cu yd)

3,1001,0001,7503,6509,300

34,10076,5508,200

108,3508,83014,1504,2503,4002,05072,15021,25013,0506,15014,9503,1004,650

415,150

1,5002,5009,0001,9005,55044,250"62,700

487,400

Mean2'3FCB Cone.(ug/g)

63814650b57

6269399938783971892791033802569483249144

811555165198159205

150

Removal5Volume(cu yd)

7,4002,3504,2508,75022,750

51,150114,85012,300162,50013,15021,2506,3505,1003,100

108,25031,85049,6009,2bO22,4004,6506,950

622,700

3,6506,05021,6004,600

13,2=50106,200155,150

128,300 800,300

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Page 20: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Table 2

Rescoped Program

Hot Spot OreI3l.-.gHigh Estimate of Unit Cost

Pool

Thompson Island

Lock '»

Hot Spots

J thru 20

29 thru 34

Contaminated Materialvol, cu yd PC3 Mass, Ib

645,500 105,800

1S5,350 22,330

800,350 123,330

Hoc Spot DredgingLow Estimate of Unit Cost

i?cpJL

Thc.npsou Island

LocX 5

Lock 3(1)

Ho_c_ Spots

1 f.hru 20

29 thru 34

37 partial

Contaminated Material_vol, cu yd PC3 Mass, Ib

645,500 105,800

155,350 22,530

109,650 9,310

910,500 137,640

(1) Partial removal will recover approximately 80 percent of in-place PC3in Hot Spot 37.

Note: All values based upon MPI estimates as presented in Draft EIS,N.Y. S.ite Envircnnencal Quality Review, September 1980.

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Page 21: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Under the rescoped dredging program between 37 and 40percent of the 347,200 pounds of PC3 in the hot and cold spotsin the Upper Hudson river bed will be dredged. The PCS massesused in calculating these percentages are the total masses ofPC3 associated with the volumes of material expected to bedredged. These percentages therefore do not reflect quan-tities of PCS missed in the dredging process, lost to thewater column or returned to the river in treatment planteffluent. Earlier studies have shown that the losses in thes«»t-.hrae areas total in the range of 6 to 9 percent-..

C. Other Program ElementsRemnant Deposits - The remnant deposits are

PCa-contaminated areas adjacent to the Hudson River upstreamof th^ former Fort Edward Dam. These areas are the remains of150 y^urs of deposition behind the dam, exposed as dry landfollowing dam removal in 1973. Much of the deposited materialha:- r/ashed downstream; those areas which remain havt? beendesignated remnant deposits.

Under the rescoped project remnant deposit areas 3 and 5will be top dressed and perimeter fencing will be installed asrequired.

Monitoring Program - A brief description of the proposedprogram for monitoring the effectiveness of the dredgingprogram follows. The program will include two overlappingcntegori.es of monitoring, environmental and operations.

Environmental monitoring will involve atmospheric,aquatic and terrestrial sampling before, during and after thecompletion of dredging activities. Samples will be taken atleast daily during dredging and more intensively during earlyphases of the project to provide supplemental operationscontrol data. Dredged material will be regularly sampled toassure that the dredging operation is recovering contaminatedmaterial. .

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Page 22: PIRN It INTER-OFFICE CORRESPONDENCE · 2020. 6. 12. · I. HISTORY OF THE PROBLEM^251 The Village of Fort Edward is located in Washington County, New York, approximately 45 miles'north

Environmental monitoring after the completion of dredgingwill record the more immediate effects- of the PC3 dredgingprogram on PCB levels in the air and water; and, later, anyresidues on land, foliage and in animal tissues.

The following studies will be included under the environ-mental monitoring program:

o Sediment Transport Monitoringo Hudson River Fish Flesh PCB Analysiso Sediment PCB Dcsocption Studyo Biological (Macroinvertebrate) PCB Uptake Studyo Foliar Contamination by PCB in Washington County

Forage Cropso Air-Plant PCB Relationshipso Agricultural Inplace Studies.o Site 10, ground water monitoring.Operations control includes both monitoring and dredge

control. The dredge phase losses, bucket losses, losses tothe water column and air, and the loss of PCB in ths trea-^cntplant effluent will all be monitored. The purpose of themonitoring is not simply to record the effectiveness of therelated processes, but to provide "real time" data that canincrease and maintain the best attainable dredging efficiency.

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IV. SUMMARY OF PC3 ENCAPSULATION SITE DESIGN CRITERIA

A summary of the design criteria for the Moreau PCBEncapsulation Site and the proposed Site 10 Containnent Siteis presented in the following Table.

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Capacity (volume)cu yds

factor

L'ner

Cip

!.2 1th* ti

Table 3

Kev Oesion Criteria

Moreau Site .-Proposed Site 10

19* ,000 eu yds180,000 cu yds 9 *vg.1<»,000 cu yds 9 avg.

PCS cone, of 20 pp*PCS cone, of 1000 pp«

None

1£" of imported clayk * 1 X 10" (specified)k = 1 X 10 (measured)

12" top dressing18" clay cover

Wollpoint oyster »nd trench drainrunning parallel to the interioreast, and south slopes of thecontainment site. Discharge pipingis connected to perimeter asphaltdrainage channel.

1,100,000 cu yds

1.1 (Thomson Island Pooland above Lock 7)

1.3 (Loner Pools)

in situ clays, depth of10 feet* _7

k - 2.6 X10* (mean value)

10" top dressing8" gravel18" clay cover

o Sloped bottoia of con-tainment areas.

o Network of gravel J i l l o i fcollection trench'swrapped with f< H*rfabric

o Perforated drainagepiping in collectiontrench (8" P.E. pipe)

o Collection and samplingurells on containmentarea perimeter, con-nected to drainagepiping.

o Piping system connectingdrainage system toleachate storage tank

o Valved piping system con-necting leachate stor-age tank to dischargepoint at Hudson River.

0 Flow aetering and monitor-Ing system.

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Cable 3(continued)

Key Design Criteria

Moreau Site

LeachateTreatment

No leachate treatment required.

SlurryTreatment

Ho slurry, PCB contaminated uuterlaltrucked to site.

Proposed Site 10

If required, leachate willbe pumped out of leachatestorage tank and treatedeither off-site, or at atreatment facility on-site.

System set up for eitherpolymer or alum, polymercaustic combination.

Water TreatmentPlant EffluentDischarge

Not applicable. Average PCS concentration10 to 20 us/1.

Maxlnua PCS concentration100 ug/1

Mininun PCS concentration* ug/i

Suspended Solids <4 Tig/1Turbidity <,10 NTu"

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V. COST/BENEFIT ANALYSIS

Cost/benefit analyses are presented with respect to twocriteria. First the cost per pound of PCB removed was de-termined, and secondly, the cost per pound of reducing the PCBload over the Federal Dam at Troy and into the Hudson RiverEstuary was estimated.

H. Cost Per Pound of PCB RemovedThe cost per pound of PCB removal for the Moreau Project

vas determined by using actual costs, actual yardages removedand measured pounds of PCB contained in the site. These costsare prasentad as actual costs at the time of performance andagain as estimated 1982 costs. The 1982 costs were estimatedby using an average annual inflation rate of 8.3 percent overthe period 1977 to 1982. This inflation rate was developedfrot.i .increases in t-.hi-: F.NB Cndexus for construct Ion costs andmaterial costs over the period.

The cost pet pound of PCB removal for the proposed Site 10project was determined based upon cost estimates presented Inthe Scoping Report of March 1981. In accordance with thefigures developed in this report, a ten percent inflation ratewas assumed to adjust 1981 costs up to the 1982 base and 1983cost down to the 1982 base.

Table 4 presents the results of the cost/benefit analysisbased upon cost per pound of PCB removed. Costs have beenestimated in three categories - removal and treatment; contain-ment, site work and material handling; and treatment (chemicalcosts only).

The cost per pound of PCB removed in the Moreau project is$82 per pound. The cost per pound of PC3 removed in the Site10, Hudson River PCS Reclamation Project is $192-206 per pound.

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Table 4

Cost/Benefit Analyst*Cost Per 3oun<j of PCB Reaoved

Moreau Sit*

Yardage Removed(cu yds)

"enoved

Cos', of PCS

3eir.=v«1 and' Tr »nscorr.

Fort Edward Terminal Channel 180,000Remnant Deposit Area 3A 1»,000

190,000 cu yds

r'ort Edward Terminal Channel 6,*CQ !bs (measured)Approximately 75,000 Ibs (estimated)

32,000 Ibs (estimated)

Proposed 5< te 10

EstimatedRange: 800,950

to910,500

EitioateoRange: 128,300 Ibs

to1J7.6MJ Ibs

Fort Edwaro Terminal Channel Remnant Deposit Area 3A Estimated 1982(1977 SI (Est. 1S82 5) (1978 S) (Est. 1982 S) Dollars

605,000(1) 901,COO(2> M)3,OSC(S) (2) 11,150,000

(6)

i.'o la: ncer.t, S t *.'.c, Material•>Ulir.g

Treatirient(Chemical CostsOnly)

Uewatering Costs(Estimated)

Hudson RiverProbing andSampling

Subtotal

Engineering Design,Fir'd Engineering,Construction Ad-ministration, andLegal and Ad-mini strafive Costs

Total

Cost per poundof PCS Removea(1982 Dollars)

?5G,000V

105,000

968,000

(3)

,(«'

1,210,000

,000(2)

1,<*29,000

359.0001,787,000

flb,'»00 (5 '

122,000'1*89,000

Fort £i>»ra Terminal Channel i279/1bCooOtned Terminal CK*nn«l

i Site 3A

672,000

168,000340,000

7,310,000

7*0,000

(monitoring)1,^20,000

650.00021,270,000

5,218,00026,*88,000

$192-I06/lb

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Table *(continued)

Cost/BenefitCost Per Pound of PC8 Removed

Hi Cost* frora O.A. Collin* Construction Co. Inc. Bid Letting, July U, 1977

(7! Cost, escalated at an annual inflation rote if 8.3V

("5; Costs from August 29, 1973 letter of cost of work to Mr. V. Griffin of NYSDOT fromHarold V. Clark of James H. Kaloy, Inc.

{*) Cost taken from R.F. Thomas .-nemo to File 26S-U-2 dated 7/H/78.

(5) Breakdown of costs was estimated using a ratio of removal and transportcost to total cost as developed in the Engineer's Estimate included in"Reswva! and Stabilization of Recnant deposits Fort Edward FloodControl Project Report on Design «nd fstifJte", Malcolm Plrnie, Inc.,Kay 197?.

'/jj Cost eitim«Lec di 25* of cost for removal, transport, containment,lit.c .tork, moterial rehAnc1! ing, treatment chemical costs and dewateHng.

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B. Cost per Pound of PCS Reduction Over the Federal Dam atTroy_________________________The transport of PC3 in the Upper Hudson has been modeled

by Lawler, Matusky & Skelly Engi.—ars (1978, 1979). Theirmodel is based on a historical flow cycle of the Hudson Riverof 20 years (1958-1977). The 20 year cycle was selected as aresult of a multiple periodic regression analysis of 47 yearsr>C flow records at Spier Falls.

The study makes use of the sediment transport mcdoi(HtC-6) , developed at the Hydrologic Engineering Center of cheiJ.S. Corps of Engineers. Using mean daily flew records, crossjftctior. -" geometry, downstream rating curves and grain sizedistribution of the river bed .-aterial, the program computesflow dep.th, velocity, physical capacity of the river to trans-port sediments, and the scour or deposition rates of sedimentsin the river.

A PCB Inventory Model developed by LMS compliments th«rit.C-6 by dcci-untinc tor the incorainy and outgoing PCB for eachreach, and for the PCB exchange between the water column andthe river bed based on the computed scour and deposition. Theoutput from this model is a relationship of PCB concentrationversus flow for the downstream boundary condition of eachmodeling reach. The integration of the PCB concentration toflow relationship with the 20 year flow data provides thecumulative mass of PCB transported in each reach over the pro-jected period. The model projections consider the incomingconcentrations at Rogers Island as the upstream boundarycondition and simulate the movement of PCB to the Federal Uainat Troy in 20 year cycles.

The PCB concentrations monitored at Rogers Island deserveparticular attention, for while the PCB transport from RogersIsland to the Troy Dam was simulated, the input load of PCB atRogers Island is the measured upstream boundary condition ofthe model. Two conditions are identified and tested by LMS intheir model: an upper limit identified as present conditions

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(post-1978) which gives an average loading of 2900 pounds of *PC3/year, and a -lower limit that gives 1300 pounds of PCB/year.The lower limit is an estimate of the reduced loading thatwould occur if the upstream influent PCB (from Glens Falls toRogers Island) could be reduced in the future by remedialaction, washout or some other method. The report identifiesremnant deposits 3 and 5, which have the highest concentrationol' PCB in the area, as the major contributor of upstream PCB.However, these two areas have been stabilized and are outsidethe normal scouring path of the Hudson River. Several studies(MPI March 1978, DEC March 1980) consider their contribution ofPCB to be negligible.

USGS data collected sinca the remnant pool mitigatingmeasures of 1978 fall within the limits of 1300 to 2900 poundsper year. Pending additional data collection by USGS, espe-cially at high flew conditions, these figures will be regarded !>*» the upp«?T *nd lowec limits of PCB loadings at Rogers Island.

Based on th«se conditions, the model estimates the- t.rans-port of PCS over the Troy Dam and to the estuary. The higherestimate projects 7200 pounds/year of PCB discharge, while, thelower estimate predicts 5600 pounds/year. These loadings areaveraged over a 20-year period based on historical flow res-cords, and do not reflect the yearly fluctuations of riverdischarges and variations of the PCB mass transported.

LMS projects average annual transport of 7200 pounds PCBover the dam at Troy for a 56 year period, after which theUppar Hudson source would be exhausted. The transport of PCBis limited by the supply of available PCB. Therefore, if noremedial action is undertaken, the supply of PCB would diminishover time by the quantities transported. The following tableadapted from LMS (1979) summarizes this transport.

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PC3 TRANSPORT, NO-REMEDIAL-ACTION ALTEPNATIVE

Supply No. of YearsPC3 Transport of Available to Exhaust

Location counds/year PCS pounds Supply

At Lock 7

Lock / to Troy

l Dam cil Troy 7200

: LMS (1979)DEC (1980)Estimates for Draft EIS NYSEQR report, HP I (September 1930)

2900 - 1300

4300

50,000

284,000

38 - 19

66

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In addition, LMS (1978, 1979) estimated the average annualPCB load at Troy for the pre-1978 period before either theRemnant Deposit Area 3A Mitigation or the Fort Edward TerminalChannel Excavation occurred. The 1978 LMS study estimates theaverage annual PCB load (including a low flow correction basedon a field data for flows less than 20,000 cfs) assuming nomitigation (pre-1978) as 8,000 pounds per year.

LMS (1979) utilized the same mathematical model developedfor Lhe "Ko Action" alternative to evaluate several "Action"llternatives, Of: interest here is the Thompson Island Pool andabove Lock 7 dredging scenario. LMS (1979) estimates thereduction in PC3 load over the da... at Troy as a result ofdredging hot spot areas 1-20 as 500 Ibs per year. Dredging theThompson Island Pool and above Lock 7 would therefore reduce'thn current PCS load over the darr. at Troy from 7,200 pounds peryaar to 6,700 Ibs per year.

Using these Lhrer data points •- pr?-l978 loading of a,000Ibs/year; post Remnant Deposit Arei 3A and Fort Edward TerminalChannel Excavation (post-1978) loading of 7,200 Ibs; and, anestimate of the post Thompson Island dredging loading of 6,700Ibs - a cost per pound of PCB reduction over the Federal Dam atTroy was estimated. Table 5 presents the cost/benefit analysisusing this data.

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Table 5Reduction of PCS Over the Troy Dan

"No Action" Alternative

Cost% Re- of Removal,

Incremental ductlon with Transport & CostAverage Annual Reduction In with Regard Treatment per PoundPCS Load at PCS Load at to No Action 1982 Reduction

Troy (Ibs/yr) Troy (Ibs/yr) Alternative (Dollar?) at Troy

8,000 . . . .

Moreau Site

1978 Remnant uepositsRemedial Actions (IncludesCast Channel of RogersIsland Dredging)

Proposed Si te 10

Oredcing Lock 7 tofho-npson Island Pool

',200 300

6,/CO 500

10\ S 2,100,000 $ 2,600No treatment

required

16% $16,000,000 $32,000(rough esti-

mate)

(1) Source: LMS (1979)

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VI. PRODUCTION RATES FOR DREDGING SYSTEMS DEVELOPED UNDER THEHUDSON RIVER PC3 RECLAMATION PROJECT

A. Production rates for the following dredging systems aretaken from DREDGING REPORT PROGRAM REPORT NO. 2, PCS HotSpot Dredging Program, Upper Hudson River, September,1980.

1. Hydraulic Dredging and Transport:

a) Typical equipment list would include:

1) One 16-inch hydraulic cutterhead dredge2) Two 16-inch booster pump units3) One 300 hp tender tug4) One .1*0 hp supply tug5) One derrick bargeS) One fuel barge7) Work-deck barge8) Pipeline and miscellaneous equipment9) Two bulldozers.

b) The average production rate estimated for one .16-inch hydraulic cutterhead dredge in Hot Spots1 through 20 (refered to as the Thompson Islandpool and areas above Lock 7) is 341 cu yds perhour. Estimated operating time is 17 hours perday or 500 hours per month.

2. Clamshell dredging with mechanical unloading (truckor conveyor transport).

a) Typical equipment list would include:

1) Two five-cu yd clamshell dredges2) Five 1000 cu yd hopper scows3) One work-deck barge4) One 800 hp towing tug5) Two 200 hp tender tugs6) Two six-cu yd clamshell cranes for unload-

ing7) Two five-cu yd front-end loaders8) Twelve 20-cu yd dump trucks9) One work-deck barge

b) The average production rate estimated for onefive-cu yd clamshell dredge is 200 cu yds perhour. Estimated operating time is 600 hrs. permonth for a monthly production rate of 120,000cu yds. (Note: Under this alternative, twofive-cu yd dredges will be required to dredge

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the Thompson Island Pool and areas above Lock 7in one dredging season.)

3. Clamshell Dredging and Hydraulic Pumpout Transportwith or without Recycling of Water:

a) Typical equipment list would include:

1) Two five-cu yd clamshell dredges2) Five 1000 cu yd hopper scows3) One work-deck barge4) One 800 hp towing tuy5) Two 200 hp tender tugs6) One 16-inch pumpout plant7) One tie-up barge8) Shoreline pipeline and miscellaneous equip-

ment9) Two bulldozers

b) The average production rate estimated for onefive-cu yd clamshell dredge is 200 cu yds perhour. Estimated operating time is 600 hrs permonth for a monthly production rate of 120,000cu yds. (Note: Cinder this alternative, twofive-cu yd dredges will be required to dredgethe Thompson Island pool and areas above Lock 7is on<? dredging season.)

3. Production rates for the Mud Cat dredges are taken fromliterature received by Mr. Peter Kuniholm, MPI from MudCat Division National Car Rental Systems, Inc., and dated9/80 and 11/80. The cover letter is dated May 29, 1981.

4. Mud Cat dredges

Model D-24-1 Model D-30

Main Pump: Thomas 8-inch intake Thomas 10-inch intake8-inch discharge 8-inch discharge24-inch impeller(closed) 30-inch impeller (closed)

Operating Depth: 15 ft (standard) 25 ft. (standard)

Pump Speed: 900 r.p.m. 675-700 r.p.jn.

Detroit Diesel: 6-71; 203 hp 81900 r.p.m. 8V-71; 225 hp

Total Head: 105 3 83 p.s.i. 8 14' 155 % 75 p.s.i. 9 17'/recat 1000' — 40' liftCapacity: 90-140 cu yds/hr. 110-200 cu yds/hr.

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Sand & Gravel: LOO cu yds/hr. 140 cu yds/hr.

Sand: 115 cu/yds/hr. 155 cu yds/hr.

Light sand & silt: 140 cu yi_.'hr. 200 cu yds/hr.

2500 gallons/min. 2700 gallons/min.

Other models offer greater operating depths with similarcapacities.

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Bibliography

Hydroscience , Inc., "Analysis of the Fate of PCB's in theEcosystem of the Hudson Estuary", Prepared for the Stateof New York Department of Environmental Conservation,October 1979.

Lawler Matusky & Skelly Engineers, "Upper Hudson River PCBNO ACTION ALTERNATIVE STUDY, Final Report", March 1978.

.1 . Lawler Matusky £ Skelly Engineers, "Upper Hudson RivecTransport Modeling Study, Final Report", December 1979,

•1 Malcolm Virnio, Inc., "Investigation of Conditions Assuci-at.&d with the Removal or Fort Edward Dam," February 1975.

j. Malcolm Pirnie, j.uc., "Preliminary Appraisal SedimentTransport Relations Upper Hudson River, " June 1976.

1 Malcolm Pirnie, Cnc. , "Maintenance Dredging, ChamplainCanal, Fort Edward Terminal Channel, Fort Edward, NewYork," April 1977.

V Malcolm Pirnie, Inc., Environmental Assessment, Mainte-nance Dredging, Champlain Canal, Fort Edward TerminalChannel, Fort Edward, New York, April 1977.

'•! Malcolm Pirnie, Inc., bupplement No. 1, Environment^Assessment, Maintenance Dredging, Fort Edward TerminalChannel, May 20, 1977.

9. Malcolm Pirnie, Inc., "Investigation of Conditions Associ-ated with the Removal of Fort Edward Dam, Review of 1975Report", August 1977.

10. Malcolm Pirnie, Inc., "Revised Interim Report, Data Base,"October 1977.

11. Malcolm Piruie, Inc., Feasibility Report, "Dredging otPCB-Contaminated River Bed Materials, Upper Hudson River,New York," January 1978, Three Volumes.

12. Malcolm Pirnie, Inc., "Environmental Assessment, RemedialMeasures, Remnant Deposits, Former Fort Edward Pool, FortEdward, New York", March 1978.

13. Malcolm Pirnie, Inc., "Report on Design and Estimate,Removal and Stabilization of Remnant Deposits, Fort EdwardFlood Control Project", May 1978.

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f

<

14. Malcolm Pirnie, Inc., Letter Report, Dewatering MoreauDisposal Area, July 25, 1978.

15. Malcolm Pirnie, Inc., "Report of Design and Estimate,Dewatering of Moreau Disposal Site, Fort'Edward FloodControl Project", August 1978.

16. Malcolm Pirnie, Inc., Phase I Engineering Report "Dredgingof PCB-Contaminated River Bed Materials Upper HudsonRiver, New York", December 1978.

\i . Malcolm Pirnie, Inc., "Project Rtport, Dewatering of theMoreau Deposits Site. Fort Edward Flood Control Project",December 1978.

L3. Malcolm Pirnie, Inc "Containment Site Investigations,Program Report No. 1," May 1980.

19. Malcolm Pirnie, Inc., "Analysis of Dredging Systems,Program Report No. 2, September 1980.

20. Malcolm Pirnie, Inc., "Draft, Environmental Impact State-ment, New York State Environmental Quality Review, PCS HotSpot Dredging Program, Upper Hudson River", September1980.

•?l. Malcolm Pirnie, Inc., "Design Report, PCB Hot Spot Dvedg-ing Program, Containment Site", September 1980.

22. Malcolm Pirnie, Inc., "Hudson River PCB ReclamationProject Scoping Report", March 1981.

23. Malcolm Pirnie, Inc., "Hudson River PCB ReclamationProject Response to Concerns Raised in NEPA-EIS", June1981.

24. Malcolm Pirnie, Inc., "Hudson River PCB ReclamationProject Technical and Management Control Binders", TwoVolumes, 1981.

25. Maslansky, Steven P., Malcolm Pirnic, Inc., (currently o^Geoenvironmental Consultants, Inc.), "Moreau DisposalSite, A Case History", April 1980.

26. Maslansky, S.P., R. F. Thomas, R.F. Bonner, and P.L.Busch, "Selection and Design Criteria of Secure LandfillFacilities for the Containment of PCB Contaminated RiverDebris". In: Proceedings of the First Annual Conferenceof Applied Research and Practice on Municipal andIndustrial Waste, Kadison, WI, pp. 635-644, September1973.

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r «

27. NYSDEC, "PCS in Sediments and Water, and Their Transport",March 1980.

28. Thomas, Richard R., Russell C. Mt Pleasant (NYSDEC) andSteven P. Maslansky, "1979 Removal and Desposal of PCS-Contaminated River Bed Materials", In: Proceedings ofthe First Annual National Conference on Hazardous MaterialRisk Assessment, Disposal and Management, Miami Beach, FL,pp 167-172, April 1979.

29. USEPA, "Environmental Impact Statement on the Hudson RiverPCS Reclamation- Demonstration Project, Draft", May 1981.

30. USEPA, "Environmental impact Statement on the Hudson RiverPC3 Reclamation Demonstration Project, SupplementalDraft", August 1931.

31. Roy F. Weston, "Interim Report, Rogers Island and MoreauSites", April 6, 1977.

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