U.S. Seeks Court Approval on Dredging Agreement with GE

The Department of Justice and EPA asked the U.S. District Court in Albany, New York to approve the October 2005 consent decree with the General Electric Company for the river dredging called for in EPA's 2002 Record of Decision for the Hudson River PCBs Superfund site.

• Plantiff's Submission Requesting Entry of Consent Decree
• Plaintiff's Memorandum In Support of Submission Requesting Entry of Consent Decree
• Exhibit 1 - Comment of U.S. Rep. Sue W. Kelly
• Exhibit 2 - Comment of U.S. Reps. Nita Lowey and Maurice D. Hinchey
• Exhibit 3 - Comment of Eliot Spitzer. Attorney General of the State of New York
• Exhibit 4 - Comment of Denise M. Sheehan, Commissioner, State of New York Department of Environmental Conservation
• Exhibit 5 - Comment of Town of Fort Edward (and associated entities)
• Exhibit 6 - Comment of Friends of a Clean Hudson
• Exhibit 7 - Comment of Scenic Hudson, Inc.
• Exhibit 8 - Representative samples of letter Comments
• Exhibit 9 - Executive Summary, Facility Siting Report (December, 2004)
• Exhibit 10 - ROD White Paper - Socioeconomics
• Exhibit 11 - The Times Union (Albany, NY) (February 15, 2006)
• Certificate of Service
• Appendix A Technical Responses to Comments
• Exhibit 1 Pages 5-8 of Responsiveness Summary, Book 2 of 3, White Paper: Relationship Between Tri+ and Total PCBs
• Exhibit 2 Map illustrating the three Hudson River Sections
• Exhibit 3 EPA Memorandum to the File (October 21, 2005)
• Exhibit 4 - Mulligan, John B., P.E., “Response to NOAA Comment Letter of October 18, 2005" (“Mulligan Memo”).
• Exhibit 5 - Comments of EPA on the Intermediate Design Report (“IDR”) (November 1, 2005)
• Exhibit 6-1 - GE’s Response to EPA comments on the IDR (December 26, 2005)
• Exhibit 6-2 - GE’s Response to EPA comments on the IDR (December 26, 2005)
• Exhibit 7 - Trends in Upper Hudson River Sediment PCB Contamination Toward the Shoreline” (December 2005) (“GE Trends Report”)
• Exhibit 8 Figure 2-3 (Residual Evaluation Flow Chart) and Table 2-5 (Summary of the Residuals Standard) of the Residuals Standard (EPS Volume 1)
• Exhibit 9 March 10, 2006 Letter from GE to EPA
• Exhibit 10 Pages 9-10 - 9-11; 9-37 - 9-38 of EPA’s Responsiveness Summary
• Exhibit 11 December 5, 2000 National Remedy Review Board Recommendations for the Hudson River PCBs Superfund Site
• Exhibit 12 Excerpt from GE’s Habitat Assessment Report for Candidate Phase 1 Areas (November 2005)
• Exhibit 13 January 18, 2001 EPA Region 2 Memorandum Re: National Remedy Review Board Recommendations for the Hudson River PCBs Site
• Exhibit 14 EPA Information Sheet
• Exhibit 15-1 - GE’s March 21, 2006 draft Remedial Action Community Health and Safety Plan (“CHASP”)
• Exhibit 15-2 - GE’s March 21, 2006 draft Remedial Action Community Health and Safety Plan (“CHASP”)
• Exhibit 16 Pages 6-46 - 6-47 of Quality of Life Performance Standards
• Exhibit 17 Section 3.5 of Engineering Performance Standards, Volume 3: Technical Basis and Implementation of the Residuals Standard
• Exhibit 18 April 20, 2006 Correspondence from GE to EPA
• Exhibit 19 Excerpt from Seelye, Elwyn E., Data Book For Civil Engineers, Design, p. 9-08 (3rd ed. 1960)
• Exhibit 20 Memorandum Re: Response to Questions on Shoreline Slope, PCB mass for Removal in River Section 1, and Shoreline Total PCB Inventory Remaining
• Exhibit 21 Memorandum Re: Comparison of Removal Areas and Volumes for Phase 1 Areas
• Exhibit 22 Photic Zone Backfill Table