Summary of Contaminant Assessment and Reduction Project (CARP) Final Report
The Hudson River flows from the eastern Adirondacks through power dams, and into the long lower estuary before reaching New York Harbor and the sea. As it moves, it passes through different social and economic settings where it picks up and transports residuals of those settings. By the time it reaches New York Harbor the river is carrying traces from all the places it has passed. This is an attempt to quantify those traces and to gain an understanding of how the deleterious ones might be reduced.
DEVELOPMENT OF CARP
In the spring of 1996, a few New York Sate Department of Environmental Conservation (NYSDEC) staffers took the train down from Albany to the Hudson River Foundation on W 20th St. in Manhattan to sit in on a meeting that Dennis Suszkowski, HRF's science director, had organized. The Hudson River Foundation was created to accept money levied from a court settlement against paper mills and power generators using Hudson River water. HRF distributes the money as grants for research on the Hudson. It also hosts meetings, arranges seminars, and generally serves as a meeting site for academics, consultants, people from the Environmental Protection Agency, the Army Corps of Engineers, the Port Authority of New York/New Jersey, the New York City Department of Environmental Protection, the New Jersey Harbor Discharges Group, citizens groups like the Bay Keeper and Friends of Jamaica Bay, and people from the New Jersey and New York state conservation departments.
HRF had awarded a grant to Robert Thomann and Kevin Farley, both professors at Manhattan College in the Bronx. In the 1970s, Thomann had developed a mathematical model for PCBs in the Hudson. HRF's grant was to update the model and to include more chemicals, particularly dioxins, pesticides, and a class of substances produced by combustion called polynuclear aromatic hydrocarbons, or PAHs for short.
Mathematical modeling is a scientific rather than simply descriptive approach to environmental studies. It begins with a general framework of boxes with lines between them. Each box represents a compartment such as "fish" or "water" or "sediment" and the lines are rates of movement of a substance between the boxes. The model looks at the study area as a grid and calculates the rates of movement of chemicals, water, suspended solids, and so forth, both within and between the grid segments over some length of time. Models organize information and help understand what is important and what isn't. If the modelers really understand the relevant rates and have information about the concentrations of the chemicals in the various compartments and at the systems boundaries, they can predict the consequences of changing inputs or chemical loading. A loading is a rate at which some chemical enters the system. Regulatory programs or changes in the uses of chemical should be capable of reducing these loadings and the model could predict how long it would take before reduced concentrations are seen in fish or the water.
After two meetings at HRF a sampling strategy was sketched out calling for sediment and biota (birds, fish, shellfish, benthos, zooplankton), and water sampling. The water component called for samples from sewage treatment plant discharges, sewage treatment plant sludges, combined sewer overflows, storm sewer overflows, landfill leachates, industrial effluents, and tributaries. Loads (mass per time such as kilograms of a chemical/year) would then be calculated. In order to tie the loads together, the strategy also requested ambient seasonal sampling at 19 sites throughout the area including the Hudson, Passaic, and Hackensack Rivers, the Arthur Kill, Raritan Bay, Upper and Lower Bays, Jamaica Bay, East River, Long Island Sound, and New York Bight.
The logic of this modeling approach is sound but the execution is extremely difficult. Tidal systems like New York Harbor are physically complicated. There was almost no information on chemical concentrations in the water and the extensive data from landfills, sewage treatment plants, and tributaries were usually inadequate or incomplete.
Harbor Estuary Program(HEP)
Much of the focus for the attention on water quality in New York Harbor comes from the 1996 Comprehensive Conservation and Management Plan (CCMP). This document is a product of the Harbor Estuary Program, itself stemming from 1987 amendments to the Clean Water Act. The CCMP is, as implied, comprehensive, and deals with floating debris, pathogenic bacteria, nutrients, habitat, storm discharges, dredging, and toxic chemicals. Toxic impacts are noted in sediments of the harbor and some areas in the Bight and in ambient harbor waters to sensitive organisms in laboratory tests. Reproductive impairments to fish-eating birds have been attributed to DDT. Some birds nesting in the Kills may have suffered from decreased reproductive success and some fish have exhibited fin rot (winter flounder) and liver tumors (tomcod), developmental abnormalities, behavioral impairments, and altered life histories (mummichogs) attributable to chemical pollution.
Body burdens of some chemicals exceed levels believed safe for human consumption. The CCMP identifies 15 chemicals ("chemicals of concern") as either exceeding enforceable standards (mercury, PCBs, dioxin, PAHs, chlordane), exceeding unenforceable criteria (arsenic, cadmium, DDT and metabolites, dieldrin, heptachlor, heptachlor epoxide, hexachlorobenzene, and gamma-hexachlorocyclohexane (g-HCH), or predicted by modeling to exceed enforceable criteria (copper).
HEP calls for 13 specific actions to reduce continuing inputs of toxic chemicals to the harbor. These are:
- Reduce municipal discharges of chemicals of concern.
- Reduce industrial discharges of chemicals of concern.
- Minimize the discharge of toxic chemicals from CSOs, storm water, and non-point sources.
- Reduce air emissions of chemicals of concern.
- Remediate identified solid and hazardous waste sites.
- Trackdown and clean-up of other sources of chemicals of concern.
- Improve chemical/oil spill response and prevention.
- Focus pollution prevention activities on chemicals of concern.
- Identify and remediate selected contaminated sediments.
- Establish consistent methodology to assess risks and improve communication of fish advisories.
- Review and develop criteria for copper and other priority chemicals.
- Assess ambient levels, loadings, and effects of chemicals.
- Develop mass balances for metals and organic chemicals.
Mud Dump Site/HARS/Dredging
Besides HEP's CCMP, other actions directly related to navigational dredging deal with toxic chemicals. The Port of NY/NJ is the largest on the eastern seaboard. Parts of it are naturally very shallow necessitating navigational dredging. Historically, dredge spoils were deposited in the bay and later just beyond the Rockaway/Sandy Hook line. Ocean dumping of dredge spoil is regulated by the 1972 Marine Protection, Research and Sanctuaries Act (MPRSA). In 1982, USEPA Region 2 designated a Mud Dump Site six miles east of Sandy Hook, NJ and eleven miles south of Rockaway, New York. By 1984, the New York District of the USACOE and USEPA Region 2 published a regional guidance manual to implement the national manual (revised also in 1984) in New York Harbor. The local guidance established three categories of dredge spoil:
Category I which is suitable for unrestricted ocean disposal,
Category II sediments may be ocean disposed if capped with Category I material, and
- Category II materials have total DDT (sum of DDT, DDE, and DDD) greater than 40 ppb, cadmium greater than 0.3 ppm, or mercury greater than 0.2 ppm in either clams or worms. PCBs are greater than 100 ppb in clams and, as of September 2000, greater than 113 ppb in worms (formerly 400 ppb in worms). Also, if 2,3,7,8-TCDD is greater than 1 ppt and less than 10 ppt or if total TEQ (minus 2,3,7,8-TCDD) exceeds 4.5. And finally, Category II is not toxic to clams or worms.
Category III sediments are not suitable for ocean disposal.
- Category III material is toxic to laboratory organisms or has dioxin TEQ exceeding 10 ppt.
Under the original 1984 protocols, 95% of the dredged material was Category I and a little less than 5% was Category II. Thus, more than 99% of the harbor dredge spoil could be ocean dumped at a cost of $5-$10 per cubic yard. However, growing public pressure for a clean environment forced the federal agencies in 1992 to reevaluate the criteria. The revised criteria resulted in 66% of the dredge spoil being classified Category III (not suitable for ocean disposal) and 9% became Category II (suitable only if promptly covered by Category I). This change in categorization greatly increases dredging costs perhaps to the point of threatening the continued economic viability of the port.
Furthermore, continued ocean disposal of Category II material was halted by executive order in 1996 and in 2000 the criteria for categorization were yet again revisited and made more stringent.
New York/New Jersey Harbor is estimated to have 124,000 directly related jobs with a combined payroll of $16.5 billion.
With this economic background, the need to get a better understanding of toxics in the harbor became apparent to the governors of both New York and New Jersey and to the Port Authority of New York/New Jersey. The Port Authority articulated a coherent vision of an alliance between the states, the relevant federal agencies, major dischargers, citizen environmental groups, and the Port Authority. The Port Authority also brought $130 million to the table. The Army Corps of Engineers offered to fund a data management contractor. Thus was born CARP.
Contaminant Assessment and Reduction Project (CARP)
CARP is a cooperative effort of the States of New York and New Jersey, with assistance from EPA and the Army Corps of Engineers, as well as academic and private scientists and engineers, to understand and to reduce contaminants in the harbor (www.carpweb.org).
The principal issues requiring address are:
- To what extent is chemical contamination of harbor sediments and biota historical versus ongoing?
- If a significant portion of harbor chemical contamination is ongoing, what can be done to reduce that load?
- How long will it take before harbor sediments and biota attain certain qualities following cessation or diminution of new inputs?
The target chemicals, to be discussed in greater detail below, are PCBs, dioxins, DDTs and chlordane, mercury, and cadmium. A major impediment to open ocean disposal of dredge material is toxicity. While the above listed chemicals are toxic, they are of interest for their bioaccumulation and carcinogenicity. They are not expected to be at concentrations responsible for the toxicity seen in short exposure laboratory tests. Some existing data points to polynuclear aromatic hydrocarbons (PAHs) as potential short-term toxicants to harbor test organisms.
The 1996 strategy set the sampling sites and chemical list. The other parts of the project were settling the chemical analytical methods, the logistics of getting people and supplies to where they need to go, deciding what to do in the field, and setting up a data management process.
Some of the People Who Made CARP Possible
The NYSDEC workplans were extensively discussed during many meetings held at the Hudson River Foundation in 1997 and 1998. Active participants in the process were Dennis Suszkowski (HRF), Tom Wakeman (Port Authority, NY/NJ), Seth Ausable (the EPA Harbor Estuary Plan coordinator), Bruce Brownawell (SUNY Stony Brook), Carleton Hunt (Battelle Ocean Sciences), Richard Bopp (RPI), Dominic DiToro (Hydroqual), John St. John (Hydroqual), Mick DeGraeve (Great Lakes Environmental Center), George Korfiatias (Stevens Institute), Mike Bruno (Stevens Institute), Phil Heckler (NYCDEP), Alan Stubin (NYCDEP), Fred Grassle (Rutgars University), Steve Eisenreich (Rutgars University), Greg Durell (Battelle Ocean Sciences), Eric Evenson (USGS, New Jersey), and Pat Phillips (USGS, New York).
The project leaders from the NYSDEC were Paul Gallay (Special Assistant to the Commissioner) and Jeff Sama (Director, Division of Regulatory Affairs). The supervisor of the NYSDEC sampling operation was Italo Carcich, Chief of the Bureau of Watershed Assessment and Research. Sharon Hotaling helped with the proof-reading.
The labor involved in just accomplishing the water part of the program was substantial. Most of the ambient samples were taken with boats large enough to have internal labs and AC power. Steve Cluett of SUNY Stony Brook helped with the 50 foot Onrust based in Port Jefferson on Long Island. Through the assistance of Dore LaPosta and Doug Pabst we were able to get sea time on EPA's Anderson. We also spent a considerable amount of time on EPA's smaller 55 foot Cleanwaters with the assistance of Randy Braun and Steve Hale. The City of New York generously provided the Marine Science's harbor vessel Osprey and field assistance from Jordan Adelson and Mike Cacioppo under the direction of Alan Stubin and Beau Ranheim.
Tributary sampling was performed by Pat Phillips and Gary Wall of the USGS out of Rensselaer, New York.
Wastewater treatment plants in New York City were sampled with the help of Max Obra and his crew at Wards Island. Additional help in ambient and WPCF sampling came from the NYSDEC Region 2 staff, particularly Annetta Vitale, Selvin Southwell, and particularly the Dredge Team members George Hyde and Dare Adelugba. Jimmy Pyn graciously put up with a great many unannounced visits to the Newtown Creek WPCF. Landfill sampling in New York was done with help from Susan Pepitone of NYCDEP (Pelham Bay), and Ted Nabavi of NYCDOS (Fresh Kills). NYSDEC's Dan Walsh provided much of the basic concepts of landfill sampling. In New Jersey, we were helped by Tom Maturano of the New Jersey Meadowlands Commission.
The design of CSO sampling was worked out by Tom Newman, then of Hydroqual, and accomplished by Iris Martin and Al Torres of Staunton-Chow, a contractor to Hydroqual. SWO sampling was done by a NYCDEP team under the direction of Jerry Volgende and Carol Neptune.
Lily Lee and Ronald Lochan, in addition to Gerry Volgende's staff designed and assisted in the trackdown work in New York City.
The chemists at the labs, particularly Brian Fowler, Coreen Hamilton, Georgina Brooks, Dale Hoover, and Laurie Phillips at Axys Analytical, provided an enormous amount of advice, insight, quantitative data, and encouragement.
Much of the logistics, that is keeping track of supplies and equipment, was handled by Mike Dauphinais here at NYSDEC. NYSDEC rented space at the USACOE facility at Caven Point in Jersey City, NJ to keep sampling equipment for the ambient sampling cruises. In this endeavor we were assisted by Alan Dorfman at the USACOE and by our attorney, Jennifer Hairie.
Larry Bailey and his staff, particularly Gail Dieter and Sue Barbuto, provided a great deal of assistance with lab contracts and in assisting with the interpretation of lab QC procedures.
Particular thanks go to John Donlon at NYSDEC. John built and maintained the TOPS, participated in a great many sampling surveys, assembled equipment and supplies, shipped samples to the labs, entered data, created all the maps, and organized the massive amount of paper and other reporting media returned by the labs.
Over the life of the project people have changed jobs and I'm sure there are many others whose important contributions I've left out. I thank them all.