LSI 2010 NRD Santa Fe final conference binder 072110.pdf

Sheri L. Moreno of General Electric Company Speaker 15: 2
Hudson River Dredging Project – An Example
• 1947-1976 - PCBs were discharged from two GE manufacturing facilities in the Upper
Hudson River
• 1976 – GE settled all claims with New York State for PCB discharges to the Hudson River
• 1983 – Hudson River PCBs Superfund Site was listed on the NPL
• 1984 – EPA ROD – no dredging
• 1989-2000 – EPA Reassessment RI/FS
• 1990 – Consent Decree to remediate remnant deposits
• 1997 – NRDA Preassessment Screen
• 2002 – EPA ROD selects dredging of PCBcontaining
sediments in Upper Hudson River
• 2002 – NRDA Plan Issued
• 2003-2005 – 3 GE/EPA Agreements
• 2009 – Phase 1 Dredging
• 2010 – Phase 1 Peer Review/Phase 2 Election
2
Remediation and Restoration Don’t Always “Fit” –
Especially at Megasites
• EPA/Trustees - different standards and considerations
• Trustees have consistently advocated for significantly bigger
more complex remedy
• Trustees have taken positions that have presented many
challenges for GE to reach agreement with EPA – and that
continues
• Resolution of both remediation and restoration at the same time
isn’t always possible – megasites more difficult
• Stakes are bigger
• Questionable liability
Law Seminars International | Natural Resource Damages | 07/15/10 in Santa Fe, NM