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Hudson River PCBs Superfund Site

Engineering Performance Standards (EPS)

Engineering performance standards are technical requirements to help ensure that the cleanup meets the objectives for protecting people's health and the environment set forth in the ROD (Record of Decision) and does not cause adverse health or environmental impacts.

The ROD required the development of the following engineering performance standards:

  • Dredging-related resuspension
  • Dredging residuals
  • Dredging productivity

The engineering performance standards were developed to provide public accountability and assurances that the dredging will be protective of people's health and the environment. These standards are being used to measure the progress of the dredging and its effect on the river system. They will ensure that:

  • action levels established in the resuspension standard protect people's health and the river ecosystem, and reduce dredge-related resuspension,
  • PCB amounts and concentrations allowed by the resuspension standard are set at levels that do not cause significant impacts on PCB levels in fish in the river,
  • removal of PCB-contaminated sediments with an anticipated residual of approximately 1 ppm prior to backfilling is achievable on an area-wide average basis, and
  • the cleanup can be accomplished in a timely manner with minimal impacts to the community.

In May 2003, EPA released the Draft Engineering Performance Standards - Public Review Copy document to the public for review and comment. It presented the draft engineering performance standards and, for each performance standard, it discussed the major ways performance is measured, the techniques used to assess performance, the supporting analyses for the recommendations (including case studies), and some of the major interactions among the performance standards. The Draft Engineering Performance Standards - Public Review Copy document was revised based on public comment and became what is referred to as the Draft Engineering Performance Standards - Peer Review Copy document. In October 2003 EPA submitted the Draft Engineering Performance Standards – Peer Review Copy document for peer review. It contains the draft engineering performance standards that were peer reviewed by a panel of independent experts. A summary of the changes from the May 2003 Public Review Copy document can be found in the fact sheet, Summary of Changes from May 2003 EPS-Public Review Copy (released Octoer 2003).

Eastern Research Group, Inc. (ERG), an EPA contractor, established a peer review panel to independently review and ensure that the engineering performance standards for the Hudson River PCBs site cleanup are technically adequate, properly documented, and satisfy quality requirements. A peer review workshop was held on January 27 - 29, 2004 in Saratoga Springs, NY to provide a forum for the peer reviewers to discuss the proposed standards for dredging-related resuspension, dredging residuals and dredging productivity. The workshop was open to the public and the panel heard from stakeholders who participated as observers. At the end of the workshop, the peer reviewers developed a written summary of their conclusions and recommendations.

The Report on the Peer Review of the U.S. Environmental Protection Agency’s “Draft Engineering Performance Standards—Peer Review Copy” for the Hudson River PCBs Superfund Site was prepared as a general record of discussion for the January 27–29, 2004 peer review meeting in Saratoga Springs, New York. It captures the main points of scheduled presentations, highlights discussions among the peer reviewers, and documents observer comments provided at the peer review meeting.

Full Report [404 KB, 66 pp]
Appendices [1.6 MB, 162 pp]

On April 20, 2004, EPA released its Final Engineering Performance Standards. Concurrent with the release of the final standards, EPA also released its Response to Peer Review Comments. In this document, EPA either describes how the peer reviewers’ comments were incorporated or provides the technical rationale for not incorporating a comment. The Response to Peer Review Comments contains a summary of the changes made to the October 2003 draft standards.

The results from the first season of dredging (Phase 1) were used to evaluate the project’s progress compared to the assumptions in the ROD in order to determine whether any adjustments to the dredging operations or standards would be needed for the second phase.In March 2010, EPA and GE each released a detailed technical assessment of the first phase of work to a panel of independent scientific experts for their review. The panel was asked to consider certain questions relating to the engineering performance standards and the monitoring program for Phase 2 of the project. The peer review panel publicly discussed its views on the EPA and GE reports in early May 2010 and the members' individual views on the questions were compiled into a report. The Draft Hudson River Peer Review Report underwent factual review by EPA and GE and was provided to the public for informational purposes in mid-August 2010. EPA received the Final Hudson River Peer Review Report from the panel in September 2010.

During the independent peer review, EPA also sought public comments on the EPA and GE reports. EPA accepted public comment on the Phase 1 Evaluation Reports until April 26, 2010. In response to requests from the public, EPA provided additional time for the public to submit comments on the Addendum to EPA's report. Public comments on the Addendum were accepted until May 17, 2010. These comments were provided to the panel members for consideration during their evaluation.

In December 2010, EPA issued performance standards for Phase 2 dredging based on the knowledge gained during Phase 1 and input from the peer review panel.  This fact sheet summarizes the technical requirements for Phase 2.

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