In Pittsfield, GE has worked for 17 years
under supervision by EPA and the states of Massachusetts and
Connecticut to clean up PCBs on its
former plant site, along the Housatonic River, and at residential properties,
schools and a city park. GE has complied
with all regulatory requirements. EPA, which has exercised de facto
oversight there, confirmed in a June
1997 letter: "GE is currently in compliance with its (federal cleanup
program) permit."
This year, GE established a voluntary
goal of cleaning up 62 properties in Pittsfield. So far, we have completed
17 properties and removed 18,000 tons
of contaminated soil. Our work continues on schedule and at an
aggressive pace.
GE also has been a full participant in
months of negotiation among representatives of the City of Pittsfield,
EPA
and the states over future PCB cleanup
and economic issues. In May, Pittsfield city leaders and GE reached
agreement on an environmental and economic
plan valued at more than $145 million that calls for GE to
conduct extensive and prompt additional
PCB cleanup and provide economic help for the future of the city and
the Berkshires. Thus far, EPA has chosen
not to join this agreement.
Resolve Differences Through Science
Even as we have pursued these aggressive
clean-up programs, GE and EPA continue to have serious technical
differences, particularly on issues
related to PCBs and human health and the appropriateness and effectiveness
of large-scale dredging. We believe
these differences should be resolved on the basis of a full and rigorous
analysis of the best available science,
not on political considerations.
On the Hudson River, there has never
been a scientific consensus in favor of dredging, and EPA has never
ordered dredging. In fact, in its standing
decision on the issue, EPA in 1984 rejected dredging because of the
risks of dredging and the potential
for serious environmental damage. Since then, the volumes of data on
Hudson River conditions show clearly
that dredging old, buried PCB deposits would not achieve the common
goal of reducing PCB levels in fish
any faster than GE's ongoing and successful program of preventing PCBs
from reaching the Hudson. Our approach,
which is working, involves cutting off sources of PCBs to the river in
the area of our Hudson Falls plant site.
GE believes that if EPA fairly evaluates all of the scientific data on
the
Hudson it will reach the same conclusion
we have reached: Dredging is wrong; source-control is right.
On the Housatonic, GE has proposed to
EPA that the government agencies and the company jointly conduct a
full scientific evaluation of the risks,
harms and likely outcome of a massive Housatonic dredging project before
beginning what could be a catastrophic
assault on the river's ecology and nearby private properties.
Moreover, EPA's regulation of PCBs still
does not take full account of the growing body of independent
scientific research -- more than 20
human health studies conducted over the last 20 years -- that shows that
PCBs do not cause cancer or other serious
illnesses in people. Regarding allegations that PCBs cause other
adverse effects such as endocrine disruption,
EPA has said there is too little information to make such a
determination. We agree more study is
necessary.
Stop-and-Go Process
Despite these differences, GE has aggressively
pursued PCB clean-up projects, with excellent results in both
states. State and federal environmental
laws create a stop-and-go process in which companies investigate
potential environmental problems and
propose solutions but must wait for government approval to proceed at
every step. Long government approval
cycles cause long delays.
When EPA began its Hudson River Reassessment
in 1990, it predicted completion within two years and may
have underestimated the complexity of
the task and need to collect and analyze large amounts of data. As a
result, EPA has had to extend its schedule
on numerous occasions. GE has never sought extensions or
proposed delays. To the contrary, GE
has cooperated fully with EPA and improved the overall quality of its
Reassessment by providing volumes of
river data, analysis and PCB research and working with EPA
contractors to develop computer models
to predict future river conditions.
In a hearing before Assemblyman Brodsky's
Environmental Conservation Committee in March 1997, EPA's
William McCabe said: " ... EPA has spent
significant time addressing issues raised by the team of scientists
working on the project for General Electric.
While many people are critical of the expenditure of time in this
manner, EPA believes that a number of
concerns that General Electric has raised have been valid, and that by
understanding such concerns and addressing
them as appropriate, the Reassessment will benefit."
Recently, in response to demands from
elected officials and citizens upset over a landfill-siting report the
agency
kept secret, EPA agreed to subject its
Hudson River science to independent peer review and to open its
process to more public involvement.
GE supported both decisions.
On the Housatonic, GE met all regulatory
commitments on time every time. By contrast, EPA failed to meet its
own 90-day target for reviewing GE submissions
on 25 of 33 occasions. EPA has had GE's technical paper on
the Housatonic River for two years and
has not uttered one word about it.
In our work on both the Hudson and the
Housatonic rivers, GE has followed two guiding principles: our full
compliance with the law and insistence
on a sound scientific basis for all regulatory decisions. We will continue
to do so.