The GE facility is comprised of 250 acres with five million square feet of building space.
 Part of the facility lies within the 100 year flood plain of both the Housatonic River and the
 Unkamet Brook, a tributary of the Housatonic which flows through the GE plant.  At the facility's
 southern border the ground surface slopes towards the Housatonic River. For many years an
 underground lake of PCB-contaminated oil has infiltrated the river system, and the neighborhood
 bordering the facility. GE began to manufacture electrical capacitors and transformers at the
 Pittsfield plant beginning in 1903.  According to research compiled by  David Schalk of
 Bloomington, Indiana, PCBs, "polychlorinated biphenyls" are  a group of distinct chemical
 compounds, none of which occur naturally. They were produced commercially by Swann
 Chemical Company beginning in 1929.  During the 1930s and 1940s, PCBs were often combined
 with "chlorinated napthalenes" manufactured by the Halowax Company.  Swann was purchased in
 1935 by the Monsanto Industrial Chemical Company.  Monsanto produced PCBs at plants in
 Sauget, Illinois and Anniston, Alabama until 1978.  PCBs were used in capacitors, transformers,
 hydraulic fluids, lubricants, carbonless copy paper, inks, pesticide extenders, sealants and flame
 retardants.
          In the following pages you will several names that describe different trademarked names for
 PCBs.  Westinghouse called its product Inerteen.  Monsanto used the trademark Aroclor while
 GE used the tradename Pyranol to denote its version of Monsanto-produced PCBs.  The
 Transformer Manufacturing Division of GE manufactured large and medium-sized AC and DC
 power transformers.  Pyranol was used by GE beginning in 1932 and until 1977 when they
 stopped due to the Environmental Protection Agency's (EPA) proposed regulations banning the
 manufacture of PCBs."
          According to the August 1988 RCRA Facility Assessment prepared for  the US EPA: "Prior
 to 1977, synthetic oil containing PCBs were used as the electrical insulating medium in
 transformers.   Before shipment, transformers were filled, pressurized, and tested under load.
 ...After testing, the oil was drained.  Both new and used oil had to be stored and piped to various
 areas of the plant, mainly between storage tanks and transformer assembly/testing areas.  Four
 major oil storage centers existed in the PCB use areas of the facility: Buildings 3C, 12-F, 12-G and
 29A." (Pg III-11)
          "Historically, GE disposed of wastes on-site and off-site.  On-site disposal occurred in
 landfills and a surface impoundment.  The three surface water bodies on three sides of the GE
 facility, the Housatonic River to the south, the Unkamet Brook to the east, and Silver Lake to the
 southwest, received permitted and unpermitted wastewater discharges throughout GE's occupancy
 of the property.
          "Off-site areas receiving wastes generated by GE include the Superfund Rose Site in
 Lanesboro, Massachusetts, and the Pittsfield Sanitary Landfill.  Disposal also occurred in oxbow
 areas ... and the Newell Street - GE Parking site ... along the Housatonic River both on and off the
 facility property.  "As a result of transformer and associated product manufacturing operations,
 various oils, including PCBs, have been released to soil, surface water, and groundwater from
 leaking tanks, pipes, and spills. ... Extensive ground water and soil contamination from the PCBs is
 well documented for this facility.
          "Investigations conducted under the 1981 Consent Order indicated that the ground water
 around the perimeter of the East Plant Area contained contaminants such as chlorobenzene,
 benzene, trichloroethylene and methyl chloride, as well as metals.  The ground water plume of
 benzene and chlorobenzene extends to the Housatonic River.  The sediments and water of the
 Housatonic River, Unkamet Brook, and Silver Lake are contaminated with PCBs."  (EPA I.D.
 NO. MAD 002084093 pp 6-8)
 The EPA report continues: "In December 1982, the Housatonic River study, performed by
 Stewart Laboratories for GE, documented  that approximately 40,000 pounds of PCBs were
 contained in the river sediments in Massachusetts, comprising more than 250,000 cubic yards of
 contaminated sediment." (Pg. III-29)
          The estimate of 40,000 pounds of PCB contamination has been used in statements and
 documents by both the Massachusetts Department of Environmental Protection and the US EPA.
          But according to an 1990 interview with Ed Bates and Charles Fessenden, there is reason to
 believe that far greater contamination has  spread from the GE facility to the river system and
 surrounding neighborhood.
          Ed Bates was the former Manager of Tests at Power Transformer at GE in Pittsfield, and
 Charles Fessenden was the Supervisor of Calculations. According to Ed Bates: "People don't
 realize that Pyranol is twice as heavy as water.  If you put a gallon of Pyranol in water and it sinks
 right  to the bottom.  Within that twelve and a half pounds of Pyranol weighs, seven pounds of
 every gallon is PCBs.  We used to use an average of 20,000 gallons of Pyranol a week and this is
 if you do simple mathematics, this is one hundred and forty thousand pounds of ... PCBs a week
 that we were handling.  And we had a loss rate: spillage, overfilling, of about 3% so this says that
 every week we would lose between four and five thousand
  pounds of PCBs that would go down into the drain and into the river. ...About a million and a half
 pounds of PCBs have been plowed into that river.  I imagine a good 30% is left."
     It is fair to say that up until the last few years, Berkshire County residents were less than
 impressed with the efforts of state and  federal environmental regulators.  For reasons no one is
 sure of, the jurisdiction for the Pittsfield contamination fell under federal Resource  Conservation
 and Recovery Act (RCRA) legislation, rather than the more powerful Superfund (CERCLA)
 legislation.  Seemingly fearful that GE would  exercise its legal option under RCRA to litigate, it
 seemed to us that the timetable and scope of remediation was shaped more by GE than the
 pressing environmental and public health needs of the community.
          For example, most of the initial testing of the river, floodplain, and the bordering residential
 and business properties were done  by GE consultants.  Because the agencies didn't have a budget
 for extensive testing they were constantly forced to make a case for why GE should engage  in
 additional testing.  And it is precisely because of this inadequate testing that in recent days we are
 discovering dangerously high levels of PCB contamination in  areas believed to be free
 ofcontamination.
          Early state and federal efforts required collection wells to drain  the underground oil plume
 south of East Street, to prevent even more PCBs  from reaching the river.  These are the wells
 former Mayor Remo DelGallo speaks of in section entitled "The Allendale Neighborhood.".  The
 wells continue to pump significant quantities of PCB contaminated oil.
          Unfortunately, to deal with these large quantities, the EPA  licensed GE to operate a thermal
 oxidizer on site, and adjacent to the Newell Street neighborhood.  And GE imported PCB
 contaminated oil from  other PCB  sites.  HRI worked hard to close the facility in 1996.
          In the last three years, spurred by growing pressure from HRI and State Representative
 Chris Hodgkins, staff from the Massachusetts DEP and EPA have begun to apply coordinated
 pressure to speed up cleanup efforts.  Recent discoveries of alarmingly high levels of PCBs in
 residential areas and the flood plain have triggered "imminent hazard" conditions and required
 immediate cleanup.  Each day brings new word of additional contamination - often the result of
 off-site burial of PCB contaminated fill.  In the last two years over 150 residences have been tested
 positive with levels of PCB contamination higher than the 2 parts per million level recommended for
 residential use.  One homesite had levels of 44,000 parts per million.
           An August 7, 1997 meeting hosted by the DEP, EPA and GE drew a standing-room only
 crowd of 150 anxious and angry Pittsfield residents. And the front page headline of the Boston
 Sunday Globe of August 10, 1997 read "GE knew of Pittsfield 'liability' for years."
          As we investigated the history of PCB use and GE's continued pattern of delay and
 deception, we kept hearing the persistent question "Why?"  "Why didn't GE stop its use of
 PCBs?"  "Why don't they just clean it all up now?"  It's important to remember just how much
 money was at stake, and how much money is still at stake.  David Shalk puts some of the  science
 and economy of PCB production and use in perspective:
          "The U.S. government interdepartmental task force estimated that PCB impregnated
 capacitors are 1/6 the size, 1/5 the weight, and 1/4 the cost of comparable oil impregnated
 capacitors, providing the advantages of reliability, long life and compactness."
          And an expert on PCB remediation and removal for Westinghouse estimated that a complete
 clean-up of the Housatonic River and its flood plain could cost as much as one billion dollars.
 Each and every day GE delays its cleanup, saves them an extraordinary amount of money.  Every
 decision means money: How clean should a clean-up be?  Which properties should be cleaned?
 How much of the river should be cleaned, and to what levels?  Since the EPA mandate of 1977,
 GE's tactics of delay and study, study and delay, its unwillingness to accept responsibility for a
 thorough cleanup, and its possible criminal obstruction of the state and federal agencies
 investigation of the extent of the contamination has worked for twenty years now.  They have
 successfully stalled long enough so that  statute of limitations issues prevent former workers from
 suing, and may possibly keep flood plain property owners from suing for the contamination of their
 land.
          As you think about PCB contamination and investigate this problem, the issue of money vs.
 safety, money vs. human health, and money vs. the environment will always be with you.  And the
 issue for all of us is: how much is a human life worth?  A city neighborhood?  A playground?  A
 river system?
 

 HEALTH CONCERNS

          As we have discovered, the issues of public health and PCBs are very complicated.  It
 involves the rare and arcane science of risk assessment, the complicated issues of health studies,
 and death records and the attributable cause of death, and the relationship of human exposure to
 the exposure of animals in the laboratory.  While we are by no means experts in this field, we have
 by necessity learned something about these issues.
          The story of human health and PCBs begins with the men and women who worked in the GE
 buildings, handling the PCBs.  There is very good reason to believe that these people were
 needlessly and recklessly exposed to PCBs.  While the EPA mandate about PCBs was issued in
 1977, public health officials and the companies involved in the manufacture and use of PCBs were
 discussing its obvious dangers as early as 1936.
          A 1936 article written by Louis Schwartz, M.D., Senior Surgeon, U.S. Public Health
 Service, New York, N.Y. entitled "Dermatitis from Synthetic Resins and Waxes" was published in
 26 American Journal of Public Health 586 (June, 1936).  Schwartz writes:
          "In addition to these skins lesions, symptoms of systemic poisoning have occurred among
 workers inhaling these fumes.  Those working with the chloro diphenyls (PCBs) have complained
 of digestive disturbances, burning of the eyes, impotence and hematuria.  The latter symptom
 developed among a number of men making amino diphenyl, which is used in the manufacture of a
 rubber antioxidant.  Causes of death from yellow atrophy of the liver have been reported among
 workers exposed to the fumes of the chloro naphthalenes.
          "Patch tests performed with Halowax and with the chloro diphenyls (PCBs) have yielded
 negative results.  The skin lesions probably result from the mechanical plugging up of the follicles of
 the skin with the waxes as the fumes solidify on the skin.*  The chlorine present in the waxes may
 have an irritating effect on the plugged follicles and cause suppuration.

 PREVENTION
          "1.  The protection of the workers from the irritating chemicals that compose the resins and
 waxes from the resins and waxes themselves.  To do this, the process should be totally enclosed.
 If this is not possible, hoods with suction exhaust should be placed over open processes that dust
 and fumes are pulled away from the worker and out of the room.
          "2.  The workrooms themselves should be ventilated by intake and exhaust fans to remove
 dust and fumes.
          "3.  The floors, walls, and ceilings should be washed down at frequent intervals to keep them
 free of dust.
          "4.  Two lockers should be furnished to each worker.  One for his street clothes and one for
 his work clothes.  The lockers for street clothes and work clothes should be in separate rooms,
 with the shower baths between the locker rooms.  The worker coming to work enters the locker
 room for street clothes, takes them off, and puts them in the locker and goes into the locker where
 his clothes are kept and dons them.  From this room he goes to the workrooms through a
 connecting door.  At the end of his shift, he goes through this door to the work clothes locker
 room, takes off his work clothes and leaves them on the floor or bench to be washed and then
 goes to the shower baths and bathes and dries.  Then he goes to the street clothes locker room,
 puts on his clothes and goes out of the door leading to the street.  It has been estimated at one
 point that 6 cents a day per worker will take care of furnishing clean clothes each day.
          "* I have recently seen the wife and child of a worker who had developed comedones and
 pustules from contact with his work clothes which were saturated with halowax and which he was
 accustomed to wear at home.
  ...
          "7.  There should be periodic medical examination of workers to detect cases of dermatitis
 and workers in chlorinated napthalenes and diphenyls (PCBs) should be periodically examined for
 symptoms of systemic poisoning.
          "8.  Laws should be passed making it compulsory for factories where there are skin hazards
 to adopt these measures."(pp. 591-592)
          And in a second article "Skin Hazards in American Industry Part  II": No. 229 Public Health
 Bulletin, U.S. Treasury Department, Public Health Service (September, 1936), Schwartz states:
 "Workers in chlorinated naphthalenes and diphenyls (PCBs) should be periodically examined for
 symptoms of systematic poisoning." (p. 10)
          Our friends at the Hudson River Sloop Clearwater, www.clearwater.org, have been working
 for years to get GE to clean up its massive PCB contamination of the Hudson.  They found a
 revealing article by Cecil K. Drinker and others: "The Problem of Possible Systemic Effects From
 Certain Chlorinated Hydrocarbons" from The Journal of Industrial Hygiene And Toxicology Vol.
 19 (September, 1937).

          Drinker reports on a one-day meeting held by the Harvard School of Public Health on the
 problems of "systemic effects" of chlorinated hydrocarbons including "chlorinated diphenyl" and
 attended by representatives of Monsanto, GE, the Halowax Corporation and The U.S. Public
 Health Service.  Halowax use of chlorinated napthelenes to coat electric wire preceded the Swan
 Chemical company's manufacture of PCBs.  GE began using Halowax's products.  Sandford
 Brown, the president of Halowax stated, according to Drinker, that they hadn't seen any problems
 with their workers until "the past 4 or 5 years.  ... Then ... combined with chlorinated diphenyl and
 other products, and suddenly this problem is presented to us."  By the mid 1930s some of
 Halowax's workers, as well as workers at GE and other customers, were breaking out with
 chloracne.  In 1936 three Halowax workers died.  Halowax hired researchers from Harvard
 University to study the problem.  They made "a number of estimates of chlorinated hydrocarbons in
 the air of different factories" then exposed rats to similar levels.  Their report declared "the
 chlorinated diphenyl is certainly capable of doing harm in very low concentrations and is probably
 the most dangerous ...  These experiments leave no doubt as to the possibility of systemic effects
 from the chlorinated napthalenes and chlorinated diphenyls."
          F.R. Kraimer, an assistant manager at GE's Wireworks in York, Pennsylvania stated: "It is
 only 1 1/2 years ago that we had in the  neighborhood of 50 to 60 men afflicted with various
 degrees of this acne which you all know.  Eight or ten of them were very seriously afflicted -
 horrible specimens as far as their skin conditions was concerned.  One man died and the diagnosis
 may have attributed his death to halowax vapors, but we are not sure of that ...  The first reaction
 that several of our executives had was to throw it out - get it out of our plant.  They didn't want
 anything like that for treating wire.  But that was easily said but  not so easily done.  We might just
 as well have thrown our business to the four winds and said, 'We'll close up,' because there was no
 substitute and there is none today in spite of all the efforts we have made through our own research
 laboratories to find one."
          GE's medical director, Dr. B.L. Vosburgh of Schenectady, New York was present and
 stated: "About the time we were having so much trouble at our York factory some of our
 customers began complaining.  We thought we were having a hysteria of halowax mania throughout
 the country."
    Monsanto was represented by Dr. R. Emmet Kelly who said "I can't contribute anything to the
 laboratory studies, but there has been quite a little human experimentation in the last several years,
 especially at our plants where we have been manufacturing this chlorinated diphenyl ...  A more or
 less extensive series of skin eruptions which we were never able to attribute as to cause, whether it
 was impurity in the benzene we were using or to the chlorinated diphenyl." (The Journal of
 Industrial Hygiene and Toxicology Vol. 19 (September 1937), pp. 283-311)
          David S. McCrea of McCrea & McCrea of Bloomington, IN has compiled a series of
 documents regarding PCBs.  A report of March 28, 1938 written by W.P. von Oettingen,
 M.D.and Director of Haskell Laboratory of Industrial Toxicology entitled "The Toxicity and
 Potential Dangers of Inerteen" seconds the warnings of Dr. Schwartz.  He writes:
          "The contact of Inerteen with the skin causes dryness of the skin, thickening and scaling, and
 it appears that sufficient quantities may be absorbed in this way to cause damage of the liver.  ...
          "For the safe handling of Inerteen it appears necessary that concentrations of its vapors in air
 are kept below 0.05 mg. per liter of air by adequate forced ventilation at the site of the production
 of such vapors.
          "Greatest personal hygiene is of paramount importance. Contamination of the skin should be
 avoided by proper protective garments such as gloves, caps and coveralls.  In case of accidents or
 with short exposure to higher concentrations, of and above 0.2 mg. per liter of air, respirators or
 open air masks should be worn.  The skin should be kept immaculately clean and ointments such
 as or Aquafor should be applied to  the skin after the washing of the hands.
          "In view of the possibility of a toxic action of this material on the liver, persons suffering from
 injuries of the liver (jaundice), syphilis, and heart diseases should be excluded from operations in
 which Inerteen is handled.
          "Workers handling Inerteen or with frequent exposure to its vapors should undergo periodic
 examinations; special attention should be paid to their nutritional condition, and the condition of the
 liver should be checked by determining the icteric index in the blood and excretion of urobilin and
 urobilinogen in the urine."

          According to interviews with Pittsfield workers, GE never provided the comprehensive
 safeguards suggested by Drs. Schwartz and von Oettingen, and some Pittsfield workers routinely
 worked up to their armpits in PCBs. Oftentimes the transformers, filled with PCBs, were put to
 pressure and PCB-laden oil spilled to the floor.  Workers walked through small pools of PCBs.
          Some workers were so sensitive to the fumes, they luckily had to be transferred to other
 operations.  On a daily basis the floor of Power Transformer was soaked with oil, and large
 amounts of "fuller's earth," a kitty-litter like product was used to soak up the fluid.  PCBs were a
 constant in the life of a GE worker at working with transformers.
          David McCrea offers a September 20, 1955 letter written by Dr. R. Emmet Kelly of
 Monsanto Chemical Company (MCC) to a Dr. J.W. Barret of London about Aroclor Toxicity:
          "MCC's position can be summarized in this fashion.  We know Aroclors are toxic but the
 actual limit has not been precisely defined.  It does not make too much difference, it seems to me,
 because our main worry is what will happen if an individual develops any type of liver disease and
 gives a history of Aroclor exposure.  I am sure the juries would not pay a great deal of attention to
 MACs."  (  MAC = maximum allowable concentrate.)
          On March 18, 1975 W.B. Papageorge, Manager of Product Acceptability, Specialty &
 Process Chemicals, Monsanto Company, St. Louis, Missouri responded to a series of questions
 from Dan A. Albert, Staff Supervisor, Personnel Relations at Westinghouse Electric Corporation in
 South Boston, Virginia about health problems possibly caused by PCBs.
  Papageorge writes:
          "Question: Does Inerteen have permanent effects on the human body? If so, what type of
 permanent damage and how long a period of time does it take for this to develop?  If not, explain
 why, if possible. "The polychlorinated biphenyls in Inerteen can have permanent effects on the
 human body.
          " ... The problem arises from repeated and prolonged exposure to atmospheric
 concentrations in excess of the accepted Threshold Limit Levels or repeated and prolonged skin
 contact.
  " ... The potential toxic effects in humans from excessive exposure to polychlorinated biphenyls
 include injury to the liver and chloracne.  In animals, the liver effect is demonstrated by increased
 liver weights and injury to cellular tissue.  Although chloracne is difficult to evaluate in animals, in
 humans, this takes the form of comedones (large blackheads with typical acne pustules) and may
 be an external symptom of over exposure preceding serious liver injury.
          "Animal data and human experience indicate that the toxic effects are similar whether
 exposure results from ingestion, inhalation of vapors, or absorption of the liquid material through
 the unbroken skin."
          "Question: Since Inerteen affects birds and other animals, if there is no real effect to human
 beings, how do you explain it to employees in such a way that they will understand why it can kill a
 bird and not a human?
          "There is a potential real effect to humans - including death - as discussed in answer to
 Question 1.
          "Question: Employees carry Inerteen home on the soles of their shoes and complain quite a
 bit about the effect Inerteen has on wearing out of their shoes.  Is this a serious problem?  Will
 Inerteen in the soles and leather of shoes, over a long period of time, have an effect on the feet and
 skin since the shoe is the only protective equipment we wear on our feet and the Inerteen
 penetrates through the leather.
          "There should not be polychlorinated biphenyl on the floor for workmen to contaminate their
 shoes to carry home.  The plasticizer or solvent action will destroy or shorten the life of the shoes.
 More importantly, the wearing of contaminated shoes could lead to absorption of the liquid through
 the soles of the feet as through any other unbroken skin surface."
          David Schalk comments: "Regulatory authorities paid little attention to PCBs prior to the late
 1960's.  Only then did the U.S. Food and Drug Administration FDA) begin the regulatory process
 by setting internal 'action levels.'  In 1970, FDA announced guidelines for fish and milk, and in
 1972 they published proposed tolerances in the Federal Register.  Nearly all FDA activity
 regarding PCBs during the past few years has focused upon fish and shell fish.
          "The Federal Insecticide, Fungicide, and Rodenticide Act canceled the registration of all
 pesticides which contained PCBs either as an active  ingredient, or as an extender to retard
 evaporation, effective November 29, 1970.
          "The U.S. EPA gathered information during the early 1970s, but did little to regulate PCBs
 before they were forced to administer the PCB phase-out mandated by Section 6(e) of the Toxic
 Substances Control Act of 1976 (TSCA).  EPA currently regulates PCBs which are still in service
 in electrical equipment or which are distributed in commerce for special uses. They also regulate
 PCB discharges into the environment, and the disposal or destruction of discarded PCBs.
          "The U.S. Department of Labor has not become very involved in PCB regulation; ...
 Workers must rely upon state regulations, their unions, and their own diligence for protection from
 PCB exposure."