LEE— The town’s assessment of General Electric’s final design plan for the PCB landfill slated for Woodland Road is that it’s not nearly as final as it needs to be.
In a detailed 19-page comment letter submitted to the U.S. Environmental Protection Agency, the town questioned the lack of detail on how water treatment would be handled at the site, and whether the groundwater calculations on which the landfill’s approval hinges account for a likely wetter future.
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The town is also seeking “a comprehensive risk analysis on the possible failure of the liner and leachate system.”
Monday was the last day for public comments on the final design plan. It details how GE intends to build a landfill, known as the upland disposal facility, for as much as 1.3 million cubic yards of lower-level PCB-contaminated sediment from the Housatonic River and its floodplains as part of the Rest of River cleanup.
While those lower-level sediments are to average 50 parts per million or less, the town noted the plan doesn't require routine testing to assure that standard. Sediments of 50 ppm and above are to be transported out of the region to a licensed facility.
The comments were produced by the town’s PCB Advisory Committee with the assistance of its technical consultant, Kleinfelder, and SKEO, the EPA’s contractor for technical assistance to communities. It was written and submitted by Town Administrator Christopher Brittain.
GROUNDWATER
The 2020 cleanup permit, which replaced a 2016 permit in which all contaminated sediment was to be trucked out of the area, stipulates that the bottom of the landfill sit 15 feet above the seasonal groundwater level.
So the town of Lee took issue with a statement in the final design asserting that climate change-related changes are “uncertain,” but likely to result in lower-than-average groundwater levels.
“This statement requires substantiation, given that groundwater levels are a driving design criterion for the UDF,” the town said. It noted that climate models all predict more precipitation in the near-term and long-term, and that groundwater studies conducted for the site took place in a relatively dry year.
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Assuming that groundwater won't be affected is "weak at best," the letter said. “The statement ... that climate change will 'likely' not raise groundwater appears to be an undefended assumption with, it seems, no attendant consideration of risk for maintaining the minimum 15 feet between the consolidation area liner and ground water levels.”
The town also questioned the 33 percent slope of the landfill’s side berm, and whether it would hold during a worst-case storm.
In other groundwater-related concerns, the town asked that test wells presently expected to be abandoned in place be maintained instead, and used to monitor groundwater levels and test for contaminants.
The landfill site sits in a former gravel quarry over a large groundwater aquifer.
LEACHATE
GE’s final design plan also contemplates building a water treatment facility at the site. It would remove PCBs and other contaminants from water collected from river sediments, as well as leachate — stormwater collected as it percolates through the landfill.
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Until such a facility is built, that water would be trucked off-site for treatment— likely to GE’s water treatment facility at the former power transformer campus in Pittsfield, the source of PCBs, a probable cause of cancer, in the Housatonic.
The town of Lee wants more detail on that plan. “It is not clear how the current designs accommodate the placement of an on-site treatment facility, or any associated features necessary to manage the leachate to be treated,” the town said.
In a separate section, the town challenged GE’s assumptions of how much precipitation would fall on the landfill during a major weather event— and therefore how much capacity the leachate recovery system will require. The town pointed to September 2023, when it saw 7 inches of rain over a week, as a recent worst-case example.
“Bottom line, there is a great deal more water falling from the sky than appears to be modeled [in the design plan],” the town said.
The town also wants to know if the water treatment facility will remain in operation once the landfill is capped.
LANDFILL MANAGEMENT
The town also noted a lack of detail on how materials would be managed and stored at the site, and how spills or releases of PCB-contaminated materials would be handled.
While the comments focus on improving and explaining the landfill plan, they also ask once more that GE forgo the landfill and haul all of the sediment away, as directed under the 2016 cleanup permit, or treat the PCBs while still in the river.
"We feel that these methods offer the only long-term safety for the people of Lee,” the town said.
