[0] A Summary of GE's Comments to EPA on Its Massive Hudson River Dredging Plan.

Business Editors

FAIRFIELD, Conn.--(BUSINESS WIRE)--April 17, 2001

I.  Source Control will Achieve the Same Level of Reductions of PCBs
    in Fish as Dredging with None of Dredging's Harmful Impacts

    When assumptions about resuspension (based on studies by the
University of Wisconsin and the U.S. Geological Survey) and project
schedule (based on experience at other dredging sites) are used,
dredging provides no benefit compared to source control, but causes
severe, potentially irreversible damage to the environment.

    --  Without effective source control, EPA will never achieve any
        of its targets for PCB levels in fish in the Thompson Island
        Pool, where most dredging will occur.

    --  Dredging in the first two sections of the river will resuspend
        PCBs, increasing PCB levels in fish in the rest of the Upper
        Hudson. As a result, in the 29 miles from Northumberland to
        Troy, dredging would delay by 10 years the time when the
        average angler could eat the fish.

    --  EPA's dredging project will increase - not decrease - the
        amount of PCBs transported to the lower river by 1,500 pounds
        over the period measured by EPA.

    --  Source control achieves lower risks to human health (both
        cancer and non-cancer) than dredging in 34 of the 40 miles of
        the site.

    --  The benefit EPA claims will result from dredging is that
        people in the upper river will be able to consume one fish
        meal every month 35 years after dredging is completed.
        Unrestricted fishing is never achieved in the 67-year modeling
        period.

II. PCB Levels in Upper Hudson Fish are Declining and Sediment
    Deposits are Stable.

    --  PCB levels in Upper Hudson water and fish have declined 60%
        since 1984, and between 1991 and 1998 levels dropped at a rate
        of about 7% per year. The National Academy of Sciences also
        found declines in PCB levels over an extended period of time.

    --  EPA ignored the full impact of this information, instead using
        a selective subset of data to reach erroneous conclusions
        about trends of PCB levels in fish, water and sediment. EPA
        ignored the fact that PCB sources near Hudson Falls have
        caused interruptions in the declines.

    --  Both EPA's and GE's models predict that, with source control,
        PCB levels will decline another 50% in the next 10 years.

    --  The models also show that fish throughout the upper river will
        meet the FDA safety standard of 2 parts per million by 2015,
        before any dredging project can be completed.

    --  EPA ignores its own model which shows declines in PCB levels
        are a result of source control and natural recovery, not
        dredging.

    --  GE's source-control clean-up work has reduced the amount of
        PCBs entering the Hudson from five pounds a day to three
        ounces per day. GE recently submitted to New York State a
        proposal for an under-the-river collection system to promptly
        capture the remaining three ounces per day. This work and the
        river's natural recovery have been, and will continue to be,
        the most powerful factors in reducing PCB levels in fish.

    --  Sediment cores from the Thompson Island Pool show that the
        vast majority of PCBs remain buried and are not available to
        fish. Further, mass balance analyses show that more than 95%
        of the PCB inventory will remain stable in the sediments for
        the foreseeable future.

III. EPA has Vastly and Incorrectly Overstated the Risk from PCBs in
     the Upper Hudson.

    --  EPA found the Hudson is safe for all swimming, boating and
        other recreational activities and for use as a source of
        drinking water.

    --  The only significant risk EPA identified in the river is
        consuming large amounts of fish (i.e., a cancer risk derived
        from eating a half-ton of fish over a 40-year period.)

    --  EPA's assessment did not take into account that for 25 years
        it has been illegal to possess fish from the Upper Hudson.

    --  EPA ignored NYSDEC records and a NYSDOH survey which confirm
        that the consumption bans and advisories are understood,
        effective and obeyed. The National Academy of Sciences found
        that the Upper Hudson communities were "very accepting of
        fishing bans and fish consumption advisories as a long-term
        solution for PCB contamination."

    --  EPA has not identified individuals who consistently eat Hudson
        River fish at a rate that would result in unacceptable risks.
        Instead, EPA assumes a hypothetical rate that is high by a
        factor of four, based on the weight of evidence from studies
        EPA chose to ignore.

    --  No environmental dredging project has been shown to result in
        the removal of fish consumption restrictions.

    --  EPA's proposal does nothing to change the risk it claims
        exists from people eating fish in the upper river during and
        after dredging.

IV. EPA Failed to Consider the Risks to Communities, Workers and the
    Ecosystem from the Implementation of this Project, as Required by
    Law.

    --  EPA has not evaluated the risk to workers or people who live
        along the river from the implementation of its dredging
        proposal or the siting of two hazardous waste treatment
        facilities which are part of its plan.

    --  EPA's proposal will destroy 170 acres of fish and wildlife
        habitat. EPA has presented no evidence that it can restore
        this environmental damage after dredging is completed.

    --  Federal law requires EPA to provide the public with a full
        evaluation of the adverse effects of its dredging proposal on
        people and the environment. EPA's failure to provide this
        impact analysis deprived the public of critical information
        necessary to provide meaningful comments.

V.  EPA has not Demonstrated that this Massive Dredging Project can be
    Implemented and Cannot Answer Basic Questions about it.

    --  EPA has not identified a disposal site for the eight billion
        pounds of dredged material.

    --  EPA has not identified the type of dredging technology it will
        use or the methods it will employ to control resuspension.

    --  EPA has not identified a viable means of transporting dredged
        material away from the site. EPA envisions the use of 1,300
        rail cars, but offers no plan on where so many rail cars can
        be obtained or how they will be managed over the long distance
        between the Hudson and the final disposal site.

    --  EPA has not identified a viable means of transporting two
        billion pounds of sand and gravel that would be dumped into
        the river after dredging. EPA failed to identify a source for
        this material.

    --  EPA has not identified sites for two hazardous waste
        processing and treatment facilities it must build to implement
        the project.

    --  EPA has not evaluated the risks and logistical difficulties of
        maintaining 50 boats and barges in the river full-time during
        the project.

    --  EPA has not explained how this project can be completed in
        five years when other projects that were 10 times smaller took
        nearly that long to complete.

    --  EPA failed to evaluate the risks posed to the river and to
        local communities from the construction of a 10-mile
        underwater pipeline to carry PCBs and mud throughout the upper
        river.

    --  EPA failed to evaluate the disruption caused to local
        communities during dredging, including noise, smell, lighting
        and transportation impacts.

    GE's formal submission to EPA covers nearly 250 pages and includes
more than 25 technical appendices. The full GE submission, including
an executive summary, can be read at www.hudsonvoice.com. Copies of
the document are available by calling GE at 1-877-9HUDSON.