Table of Contents
Fox River Clean-up Proposed
Concerns about the proposal
Public Hearings on the Fox River and Green Bay Cleanup ProposalRiver-Bay Rescue RallyNew Website! Fox River Watch at www.foxriverwatch.com
Good & Bad News
Fox River Clean-up Proposed
For extensive coverage of the proposed Fox Rvier Clean-up visit www.FoxRiverWatch.com
Thirty years after the DNR first started studying the toxic PCB
contamination in the Fox River (in 1971), they're finally proposing
a
clean-up.
Unfortunately, the plan contains several serious weaknesses.
The Plan in a Nutshell
The DNR and EPA propose to clean certain sections of the river to a
level
of 1 part per million (ppm) PCBs.
For comparison purposes, fish with over .05 ppm PCBs in their bodies
are
included in consumption warnings for anglers, due to the toxicity of
PCBs.
- Little Lake Butte des Morts: dredge hotspots, with off-site
- From Appleton to Little Rapids (about 20 miles): no action, just monitoring
- From Little Rapids to De Pere: dredge hotspots, with off-site disposal.
- From De Pere to Green Bay: dredge, with off-site disposal.
- The Bay of Green Bay: no action, just monitoring
disposal.
- Meet the human health and wildlife health PCB water quality standards
- Meet the sport fish consumption advisory standard (this still allows a
- Protect ecological values, like healthy invertebrates, birds, fish and
- Reduce longterm transport of PCBs from the river into Green Bay and Lake
- Minimize downstream movement of PCBs during dredging.
1-in-10,000 cancer risk)
mammals, especially those which eat fish.
Michigan.
Includes the removal of sediment having PCB concentrations greater
than 1 ppm using a hydraulic or mechanical dredge, dewatering the sediment
either passively (in settling lagoons) or mechanically (with presses),
treating the water before discharging it back to the river, and then
disposing of the sediment in a landfill, either transporting it by
truck or
by pipeline. Different combinations of these techniques
may be used in
different sections of the river. Specific landfill disposal sites
have not
been selected.
Timeline
- Start work in the summer of 2003.
- Complete in 7 years.
- Little Lake Butte des Morts: 14 years before high-intake human
- From Little Rapids to De Pere: 42 years before high-intake human
- From De Pere to Green Bay: 59 years before high-intake human fish-eaters
- The Bay of Green Bay: more than 100 years before sport fish consumption
fish-eaters are protected (to a 1-in-100,000 cancer risk). 29 years before
fish-eating mammals are protected.
fish-eaters are protected. 43 years before fish-eating mammals are
protected.
are protected. 45 years before fish-eating mammals are protected.
warnings are lifted.
$258.1 million for dredging and landfilling. $49.5 million for monitoring. Will be paid by seven paper companies who dumped PCBs in the Fox River from 1954 to about 1990.
The proposal includes several weaknesses. Unfortunately, the plan
documents occupy about a foot of shelf space and will take a few weeks
to
analyze in detail.
Using an EPA Technical Assistance Grant (TAG) we've hired 2
independent experts to help us with this analysis. Their conclusions
will
be presented soon on our FoxRiverWatch website (their resumes already
are).
We will also have MUCH more detail in our next newsletter. A
few initial
concerns follow: (more to come later)
- Protects the Polluters Before Protecting Public Health
- No Action on the Bay
- NOT Evenly Distributed
- Weakened Standard
- Unrealistic Consumption
- Questionable Application of the Standard
The agencies claim the plan is driven by health concerns, but it's
clear
the plan is written first and foremost to keep costs down.
The public faces enormous health risks, primarily in lower Green
Bay and the river downstream from the DePere Dam. But this plan
allows 59
years to pass in this river section before "high-intake" fish-eaters
are
protected. The high-risk Bay fish-eaters won't be protected for
more than
100 years.
This is simply unacceptable.
The plan leaves behind several areas of significant PCB contamination.
In particular, the plan includes no remediation in the bay of Green Bay.
The plan's sediment dredging stops at an imaginary line at the
mouth of the river, even though significant PCB contamination can be
found
in sediments just beyond the mouth and around the corner along the
East
Shore, such as near the Kidney Island toxic dredging dump by Bay Beach
Amusement Park..
Just a preliminary review of the documents shows that an additional
4 million cubic yards of sediments in certain Bay hotspots with greater
than 5 ppm PCBs could be removed from the Bay for an additional $124
million, which is very affordable. This could remove
approximately 28,000 to 40,000 lbs of PCBs from the Bay (and perhaps
more),
compared with the rest of the plan where DNR and EPA support removing
just
64,350 lbs of PCBs from the Fox River at a cost of $258.1 million.
Removal of the lower bay hotspots could greatly speed the recovery
in the Fox River below the De Pere Dam as well as in the lower Bay.
If
the lower bay isn't addressed, the bay PCB sediments will wash back
up the
Fox River with storm surges and seiches (tide-like sloshing in the
bay.)
The fish in this river section also move freely between the river
and bay, raising questions about the plan's claim that it will take
only 59
years for the river fish to be safe to eat, but over 100 years for
the bay
fish.
Contrary to agency statements, PCBs are NOT uniformly distributed
in the sediments of the Bay. Distinct hotspots (like Bay Beach) have
been located, including a serious one offshore from Dykesville, along the
East Shore. We need estimates of the cost of removing just those
hotspots, not lumped with the general background sediments. We'll
be scrutinizing the documents for this information.
The 1 ppm PCB sediment cleanup standard is 4 times weaker than the
initial government proposal 2 years ago (which was also weaker than
a
previous standard 5 years ago.) The DNR claims the federal Bush
Administration made them do this. The weakening represents a
major retreat
from health protection.
The agencies used a fish consumption rate that is only half the
rate identified in scientific literature for highly exposed populations
(subsistence consumers and minorities.)
In addition, they used a "reduction factor" which assumes that
cooking and cleaning reduces contaminants, but, in fact, this does
not
protect individuals who don't cook and clean following state guidelines
(Hmong populations, some native American groups.)
The 1 ppm standard is misleading because it isn't being applied
to known PCB hotspots which are well-over 1 ppm in the Bay.
Furthermore, the Fox River Coalition, which met from 1992 to 1997
on this issue, frequently discussed 11 million cubic yards in the Fox
River
with concentrations higher than 2.5 ppm PCBs. Now, this plan
says only
7.25 million cubic yards will be removed to a cleanup standard of 1
ppm.
Something doesn't seem right. This is another area we'll be examining.
The agencies appear to be averaging the PCB levels in the sediment
in order to achieve the 1 ppm.
These are just preliminary observations. We'll provide much moreChemical Risks Only
The ecological risk assessment only looks at toxic chemical effects. But the wildlife are more vulnerable to toxic effects when also stressed by habitat modification, thermal stress, exotic species, and disease. (All factors present here.) This means a better PCB cleanup standard is needed.
Hydraulic vs. Mechanical
The plan should specify hydraulic (vacuum)
dredging methods only. No messy clamshell dredges or other mechanical
dredging methods should be allowed, because they could stir up the PCB
sediments while trying to remove them.
Better Landfills Needed
The landfills need to be stricter than normal, to prevent PCB volatilization into the air and to treat wastewater, not to send it through regular sewage treatment plants. We need to prevent the contamination of our sewage processes.
No Detoxification Required
The sediments with higher PCB concentrations should be pre-treated before landfilling, to detoxify the PCBs, using a process which will not make matters worse by creating dioxins. Incineration of PCBs can be dangerous, so other non-burning methods would be preferred.
"Natural Recovery"
The plan relies heavily on the industry's favorite cleanup method: do nothing but allow fresh sediment to cover the old, or let the PCBs disperse to become someone else's problem. They omit the natural processes of erosion, wave action, turnover of larger slower bodies of water, biologic processes, and human activities that counteract this "recovery."
Rushed Public Process
The public hearings are coming too soon for the public to have time to discuss and digest the details of the proposal. Many groups already mailed their newsletters for the month of October by the time of the Oct. 2 announcement. Their newsletters won't mention the
public hearings on Oct. 29 and 30.
The agencies have also been far too slow to provide the documents.
The proposal takes up about a foot of shelf space. It takes time to read.
One of our experts (Dr. Foran) received a hardcopy on Oct. 11th.
Our office and our geologist still haven't gotten one (as of Oct. 16).
But under the TAG grant we're supposed to read and understand this massive
document in time to share our analysis with the public in time for the
first public hearing on Oct. 29. Keep in mind, it takes 2 weeks to write,
print and mail our newsletters to reach your home reasonably before the
hearings.
Dr. Foran , as our TAG expert, is supposed to analyze all the
documents in time to give his presentations on Oct. 23 and 24.
The EPA and DNR knew our schedules and plans under the TAG
grant, yet they have crippled our efforts. We've waited years for the
opportunity to comment on this plan, but now it's being rushed to prevent
citizen review of the details before the hearings.
analysis soon!
Public Hearings on the Fox River and Green Bay Cleanup Proposal
Monday, October 29, 6:30 pm
Holiday Inn Select, 150 Nicolet Road
(US 41 & College Ave.), Appleton
Tuesday, October 30, 6:30 p.m.
Oneida Radisson Convention Center, 2040 Airport Road
(Hwy. 172, across from Austin Straubel Airport), Green Bay
We've waited 30 years for this.
Don't miss your chance to make a real difference!
NOW is the time to be involved in this important issue!
Please prepare to attend the public hearings, even if you'd
rather not speak. Bring your friends, family and co-workers,
and show your support for a clean Fox River and Bay!
This is IT! Please Attend!
Come show your support for a strong cleanup!
Join us for a public rally at each of the two
public hearings. Make a sign and bring friends!
Let's show some ENERGY on this issue!
Meet at the front entrance at 5:30 p.m. at each of the
hearing sites listed on the front. Let's have some fun
and make a difference at the same time!
New Website! Fox River Watch at www.foxriverwatch.com
Please visit our new website, for detailed information and timely
updates
on the river and bay cleanup. We've organized hundreds of pages
of
material to make it easy to find information on:
- PCB health effects -- thousands of studies and links
- PCB sources, chemistry, history, and locations
- How you can protect yourself and your family from PCBs
- Fox River and Bay statistics, geology and history
- Cleanup technologies and dredging information
- Descriptions of the 7 PCB polluting companies
- Government proposals to clean up the PCBs
- Political shenanigans surrounding this issue
- An archive of Fox River, Bay and PCB news articles
- Links to hundreds of other websites on related topics
- Action alerts and public notices, explaining how you can help
Imagine
A CLEAN FOX RIVER
The time to Act is NOW
Contact us: 920-437-7304 or cwac@execpc.com
Tell DNR what you think of their plan. Letters must be postmarked
by December 7. Mail to:
Ed Lynch, PE-RR/3, WDNR
Fox River Proposed Plan
101 South Webster St.,
P.O. Box 7921,
Madison, WI 53707-7921
E-mail comment letters to: FOXRIFS@dnr.state.wi.us (same deadline)
DNR's website -- http://www.dnr.state.wi.us/org/water/wm/lowerfox/index.html
Public Libraries -- Appleton, Brown County, Door County, Oneida and Oshkosh
Fox River Watch website -- http://www.foxriverwatch.com
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