Table of Contents
Expert Opinions on the Proposed PCB Cleanup
The Toxicologist's Concerns
Human HealthThe Geologist's Concerns
Risks are Underestimated
Wildlife Health
Sediment Quality Thresholds
Feasibility
Human HealthThe Engineer's Concerns
Capping in the Lower Fox River
Modeling
Average Values
Green Bay Remediation
Some details uncovered by Mr. AckerPlease Write Your Comment Letter Today
For more information visit www.FoxRiverWatch.com
Expert Opinions on the Proposed PCB Cleanup
A few years ago, the Clean Water Action Council received a grant from the U.S. Environmental Protection Agency (EPA), on behalf of a coalition of local and regional citizen groups, under the Superfund Technical Assistance Grants (TAG) program.
The grant allowed us to hire three experts to help us evaluate at least some of the details in the huge 7 volume Remedial Investigation and Feasibility Study (RI/FS) for cleanup of PCBs from the Fox River and Green Bay system. The study was written by a consultant to the DNR, with $4 million in funding from the EPA.
(The EPA and DNR will evaluate the technical input and public comments, and the EPA will issue a "Record of Decision" (ROD), probably several months from now.)
The other groups in our coalition are; Great Lakes United (a regional organization), Door County Environmental Council, Brown County Conservation Alliance (which consists of several hunting, fishing, boating and outdoors groups), Chappee Rapids Audubon Society (in Marinette), Wisconsin's Environmental Decade, and the Northeast Wisconsin Student Environmental Coalition.
The grant also allowed us to create and maintain a major new website about the Fox River cleanup and PCBs, as an information clearinghouse and referral site to other websites. The site has already been used by thousands worldwide.
And finally, the grant allowed us to hold and advertise several public programs featuring our toxicologist.
Each of our experts produced separate evaluations of different aspects of the proposal. Their reports and resumens are online at www.FoxRiverWatch.com
A summary of our three experts' opinions are listed in this newsletter.
Dr. Jeffery Foran is a PhD toxicologist with 20 years of experience. He is an adjunct professor at the Allied School of Public Health in Milwaukee, and current President of the Society of Environmental Toxicology and Chemistry (SETAC).
Dr. Foran emphasized that "approximately 40,000 individuals in the Fox River and Green Bay region are faced with PCB cancer risks similar to smoking two to three packs of cigarettes a day. Other non-cancer health risks are extremely high. Their PCB exposure is primarily through contaminated fish and fowl consumption."
“These risks must be addressed immediately,” stated Dr. Foran.
“Unfortunately, the proposed cleanup would fail to protect public health,” concluded Dr. Jeffery Foran.
“The governments’ PCB cleanup standard must be at least 4 times stronger. Sediment PCB levels remaining after cleanup should be no more than .25 ppm (parts per million), in order to achieve reasonable health protection. Otherwise, the plan will not meet its stated objectives."
“The stronger standard would achieve rapid results, protecting public health as soon as the dredging is completed,” added Dr. Foran. “I saw no reasonable justification for the government’s weaker standard, which would force the public to wait 7, 40 or even 100 years after dredging.”
The lack of a Bay cleanup is another serious concern identified by Dr. Foran. “Without bay cleanup, extremely high health risks will continue for more than 100 years. Such high risks are clearly unacceptable under standard government policies used throughout the country.”
Dr. Foran recommends a .25 ppm cleanup standard for the lower bay, for minimum health protection. This would also greatly reduce PCB flows to the upper bay and Lake Michigan.
Highlights of Dr. Foran's report:
- The cancer rate due to PCB contaminated fish consumption is approximately equal to the cancer rate experienced by individuals who smoke 2 or 3 packs of cigarettes a day.
- This risk is 100 to 1000 times greater than cancer risks commonly determined to be “acceptable” by state and federal agencies.
- This risk is 10 times greater than cancer risks that trigger stringent regulation of pollutant sources by the U.S. EPA.
- These consumers also face a variety of non-cancer health risks at high rates.
- 14,000 recreational anglers are highly exposed to PCBs in the Fox River and Green Bay system. In addition, 12,000 low income or minority individuals are highly exposed. Assuming the recreational anglers expose one more family member to fish consumption at the same rate, this means roughly 40,000 individuals are highly exposed to PCB health effects, an enormous population at risk.
- Waterfowl hunters also face significant health risks.
- 1. The true high-end fish consumption rates for recreational
and high-intake fish consumers are more than 2 times greater than “high-end”
rates chosen in the Assessment.
2. The Assessment uses a PCB “reduction factor” of 50% based on an inaccurate assumption that individuals practice appropriate cleaning and cooking procedures.
3. The Assessment does not account for the cumulative risks for individuals who eat both fish and waterfowl, and who are also PCB exposed through recreation activities and occupation.
4. The Assessment inappropriately declares that negative epidemiological studies prove or conclude that PCBs don’t cause human cancer. Human epidemiological studies typically lack adequate power to identify adverse effects in populations at low frequencies or levels..
5. The Assessment does not address the potential for, and in some cases, evidence for synergism. (The compounding effects of 2 types of chemicals acting together.)
- Wildlife are also seriously harmed by PCBs. Significant ecological risks occur at virtually all levels of biological organization and for all assessment/measurement endpoints throughout the Fox River/Green Bay system.
- In virtually all cases (except insect-eating birds), wildlife health risks have been confirmed by field observations.
- The Assessment ignores the impact of multiple stresses (disease, temperature, habitat alteration, and many others) which can make wildlife more vulnerable to PCB toxicity.
According to the Assessment, if the PCB levels are over 1 ppb (which equals only .001 ppm) in the sediments, this could lead to fish PCB contamination which exceeds the “acceptable” cancer risk of 1-in-a-million for high-intake fish consumers.[Note: Clean Water Action Council is recommending a .25 ppm standard as a compromise level, even though it won't achieve the better 1-in-a-million risk standard. This compromise is due to the large quantity of sediments affected.]Despite this finding, the governments propose a cleanup target in the sediments of 1 ppm, which is 1,000 times higher than the level they admit could exceed the “acceptable” cancer risk.
- The plan should strengthen the stated “Remedial Action Objectives” to
- It is disturbing and inappropriate that action levels necessary to achieve even the weaker objectives were not considered in the selection of cleanup options for the Bay, apparently due to cost and technology concerns.
1. Achieve surface water quality criteria without qualification
2. Eliminate rather than reduce transport of PCBs
- Cleanup technologies may change considerably in the next few years; therefore the plan should evaluate all action levels needed to achieve objectives, even to levels as low as .125 ppm PCBs. Current cost estimates should not prevent a full cleanup evaluation.
Donna Boreck has more than 20 years experience as a research scientist focused primarily on geologic and environmental issues involved in the development of energy and mineral resources. Her training and experiences include work with hazardous and solid waste issues. She currently works for the Federal Emergency Management Agency, assessing damaged sites and determining enviornmental regulatory issues - though she initiated her work for us prior to this position and has continued to work for us as a private consultant.
Her concerns are as follows:
- The 1-ppm target level is not protective of human or ecologic health. An assumption is made that the remaining PCB concentrations will be managed by natural recovery -- an uncertain gamble.
- Capping in conjunction with natural recovery has been proposed by Appleton Paper Company as an alternative to dredging. There are a number of weaknesses in the proposal:
- 1. The Wisconsin DNR has already presented guidance on when to
cap. The guidance included capping in an area where currents are no greater
than 0.15 feet/sec. Average current velocities in all reaches of the river
vary from 0.25 to 1.23 feet/sec.
2. WDNR guidance included that capping should be done in areas where the maximum 100-year flood current is no greater than 0.7 feet/sec. Based on average current velocities for the different reaches of the river, the 100-year flood current may exceed the 0.7 feet/sec in all reaches of the river. Actual values for the 100-year flood current for each reach need to be determined.
3. The proposed capping project has been described as the …"biggest ever attempted in the U.S.". Any time an engineering design is sized larger; there are new challenges and risks associated with increasing the size and level of complexity of the design. Large scale PCB cleanup requires the best available proven technology--dredging and removal of PCBs.
4. Capping requires long-term monitoring and maintenance. It may only take less than ten years to place the cap, but the proposed capping will require centuries of time, expense and man-hours to monitor and maintain the effectiveness of the cap -- much longer than the 10 year time frame required to dredge the river and bay.
- Many conclusions in the RI/FS are based more on modeling and less on empirical results from monitoring, data gathering, etc. Each model has its limitations. Making a decision based on model results is appropriate if the limitations are taken into account in the final decision. With what is empirically known about PCB contamination in both the river and the bay, deciding not to act, based on modeling results (i.e. leaving the PCBs in the River or Bay to natural recovery) is inappropriate.
- The method used to determine the 1-ppm extraction level is not appropriate for a contaminant like PCB. The method, similar to what is done to determine in-place reserves for mineral commodities, seems to focus more on minimizing volume of sediment extracted or cost of remediation and less on what needs to be recovered to protect human health.
- Recovery of PCB contaminated sediment will not be 100%. Using the recovery factor from Deposit N (20%), recovery of the 1ppm sediment would be approximately 79%, not the 99% modeled for Zone 1.
[Note: at the Deposit 56/57 dredging demonstration, the loss was only 2%, so dredign techniques can make a large difference.]
- Quoting average values for parameters such as current velocity and wind speed gives a false sense of security in visualizing sediment transport and deposition in the river and bay. PCBs and other contaminants move in the system by events that are not 'average'.
- 1. Quoted in the RI/FS, "…Based on the seasonal variations in
PCB concentrations, it is estimated that more than 60% of the PCBs transported
over the DePere Dam occurs during 20% of the year, when discharge is at
it's greatest."
2. The average velocity for Zone 1 is 0.25 feet per second. The velocity pegged for erosion of sediments in the Lower Fox River is 0.3 feet/sec. Below that point, sediments can be deposited. Above that point, resuspension of sediments can occur. Velocities recorded at USGS Stream Gage along the Lower Fox River revealed that actual velocities can vary significantly from the 0.25 feet/sec average and the 0.3 feet/sec erosion velocity-- hourly, daily and over periods of weeks.
- Green Bay is not quiet water. It is a dynamic system where, based on the present footprint of PCB contamination, suspension and resuspension is ongoing.
- Green Bay has a diverse bottom-dwelling community that will both negatively affect burial of PCB-contaminated sediment and will continue to provide a contaminated food source to fish and other wildlife. Worm species reported in Zones 2 and 3a in Green Bay can effectively churn and expose to the water column up to 6 cm of sediment on the Bay floor.
- Green Bay is now a rich resource of PCBs and an independent source of contamination to both Lake Michigan, the surrounding land, and, via volatilization followed by deposition, to locations far from the bay area. Without remediation, Green Bay will be a source of PCBs for years. Ironically, if Green Bay is not remediated, it can help to re-pollute Zone 1 of the Lower Fox River, limiting efforts and wasting remediation dollars.
William Acker is a registered civil engineer with 27 years of experience with the paper industry and other businesses in Northeast Wisconsin. He's a Bay shoreline resident himself, and understands the toxicity and economic concerns of local citizens examining the cleanup proposal.
He concludes that lower Bay cleanup is both cost-effective and feasible, contrary to goverment claims. He examined the cost and feasibility analysis contained in the plan, with emphasis on Zone 2 of Green Bay, the extreme southern end of the Bay.
The EPA and DNR propose no cleanup in this segment, on the assumption that it would be too costly and of little benefit. Acker challenges that assumption.
“I believe the cleanup of the Fox River along with Zone 2 of the Bay is affordable by the paper industry,” Acker stated.
“The cost of removing PCBs per pound from the lower Bay is no higher than removing them from the river,” concluded Acker.“In fact, the lower Bay contains more PCBs than the entire river, in areas equally accessible to cleanup.”
The river sediments contain 65,818 pounds of PCBs, while Zone 2 of lower Green Bay contains 69,202 pounds. More PCBs are contained in the 7.5 mile stretch of the lower Bay than in the entire 39 miles of the Fox River. The rest of Bay to the north contains another 83,643 pounds, more widely dispersed. This means that almost half of the Bay’s total PCB mass is still sitting offshore from the City of Green Bay.
“The lower Bay is one of the areas with highest health risks, so it seems peculiar to clean up the river without touching the Bay,” added Acker.
“I found that 88% of the PCB mass for Zone 2 of the Bay is in the concentration range above 1.0 ppm PCBs, which is the stated cleanup target of the government’s plan,” stated Acker. “It’s misleading to have this stated goal, yet leave such a large mass of PCBs behind.”
“In addition, I found that the majority of PCBs are near the surface on the Bay, and are actively recycling, not being buried. The Sea Grant Institute has claimed that PCBs are being buried by cleaner sediments in the Bay, but this isn’t true in Zone 2, because the southern Bay is so shallow and exposed to intense wave action,” stated Acker.
A serious discrepancy has been discovered between the DNR and EPA estimates of total PCBs in the entire Bay, 69,330 kg or 152,850 lbs, and a UW Sea Grant Institute estimate of 8,500 kg or 18,700 lbs. Both amounts are used in the proposed plan documents. This must be resolved in order to have an accurate Bay cleanup planning effort.
[Note: a preliminary look throws doubt on the lower Sea Grant number, because they collected only one sample at the lower Bay (Zone 2), along the west shore, which would tend to be cleaner. This would seriously skew their total PCB numbers for the Bay. Their estimates are also little use in deciding the conditions in Zone 2. In contrast, the DNR used many more sampling points to estimate the mass of PCBs in Zone 2; therefore, Clean Water Action Council is relying on the DNR data until better information is provided.]
Some details uncovered by Mr. Acker
1. More PCBs are contained in the 7.5 mile stretch of Zone 2 than in the entire 39 miles of the Fox River. Zone 2 has 31,390 kg (69,202 lbs) of PCBs and the Fox River has 29,855 kg (65,818 lbs) of PCBs.Up to Top2. The current proposed cleanup plan is to remove only 29,259 kg (64,504 lbs) of PCBs from the Fox River which is 29% of the total PCBs lying in the Fox River and the Bay .
3. The total amount of PCBs now present in the combined Fox River and Bay is 99,185 kg (218,663 lbs) Seventy percent of these PCBs are in the Bay (69,330 kg or 152,845 lbs), and 30% are in the Fox River (29,855 kg or 65,818 lbs). Almost half of the total PCB mass in the Bay is found in Zone 2.
4. The De Pere to Green Bay Reach Zone 1, and Zone 2 of the Bay, combined, contain more than 60 percent of the total PCB mass in the system in less than 10 percent of the total contaminated sediment volume.
5. If Zone 2 is included in the proposed cleanup plan (to 1.0 ppm), we remove an additional 29,768 kg (65,627 lbs) of PCBs, which increases the proposed PCB removal from 29,259 kg (64,504 lbs) to 59,027 kg (130,131 lbs), an increase of 102%. The percentage of remaining PCBs removed increases from 29% to 60%.
6. In the WDNR Proposed Plan, they admit that nearly one-half of the total quantity of PCBs in the Bay is concentrated near the mouth of the Lower Fox River in Zone 2 (Page 10 of 35).
7. On page 13 of 35, the Proposed Plan says: “In general, areas with the greatest risk are De Pere to Green Bay (OU 4) and Green Bay’s Zone 2”.
8. The Fox River is a Recreational Angler Site. Zone 2 is a Commercial Fishing Site as well as a Recreational Angler Site.
9. The reasonable maximum exposure hazard quotients (HQs) for piscivorous mammals suggest that reproductive risk is greatest in the De Pere to Green Bay reach (OU 4) and Green Bay Zone 2 (page 15 of 35). Also total PCB HQs for benthic (bottom-dwelling) fish were greatest in the De Pere to Green Bay reach (OU 4) and Green Bay Zone 2 (Page 15 of 35).
10. In the WDNR Proposed Plan, Zone 2 (from the mouth of the river to Point Vincent) would not be cleaned up. The plan for Zone 2 is Monitored Natural Recovery. In the Proposed Plan (Page 18 of 35) the agencies say: “Natural recovery may take more than 100 years, as measured by acceptable PCB concentrations in certain fish species. During this long time frame, ongoing significant risks to public health and the environment would continue. In contrast, remedial actions greatly reduce the time of recovery”.
11. Most of the PCB mass for Zone 2 is in concentrations above 1.0 ppm. In this zone, 72 % of the total PCB mass is in concentrations ranging from 1.0 ppm to 5.0 ppm. In addition, 16% of the total PCB mass ranges from 5.00 ppm to even higher concentrations. Therefore, one can say that 88% of the PCB mass for Zone 2 is in concentrations above 1.0 ppm. In Zone 3, the percentage of PCB mass above 1.0 ppm is only 0.0046%. In Zone 4 there is no mass of PCB’s above 1.0 ppm. This does show that PCB concentrations drop off dramatically after Zone 2.
12. In Zone 3, the agencies averaged sediment data over an enormous area of the Bay, and did not include data about specific locally-concentrated PCB hotspots along the east shore north to Door County. It’s possible that such hotspots could be cleaned out, but the agencies did not include enough information in their documents to evaluate this potential.
13. The average contaminated sediment depths are much deeper in the river as compared to sediments in the bay. The four river zones are as follows, OU 1 is 21 inches, OU 2 is 7 inches, OU 3 is 34 inches, OU 4 is 49 inches. The three bay zones are, Zone 2 is 14 inches, Zone 3 is 11 inches, and there was no data on Zone 4.
14. If Zone 2 were dredged to a Sediment Quality Threshold of 1.0 ppm, the average dredge depth would only be about 8 inches as compared to a 3 foot depth for dredging in the last stretch of the river (OU 4).
15. As the concentration of PCB sediments decreases, the cost of removal tends to increase dramatically. An example is Zone 3, which has a PCB removal cost of $106,000 per lb of PCB’s removed (for a cleanup of 1.0 ppm). Zone 2 however is $12,400 per lb (for a cleanup of 1.0 ppm) which is actually less expensive than two river regions OU 1 and OU 3 $15,234 per lb and $12,616 per lb).
16. One pound of PCBs is theoretically enough to contaminate 20,000,000 pounds of fish to exceed the .05 ppm PCB human health standard for fish consumption. Even small amounts of PCBs can be dangerous. Though the cost of PCB removal may seem high, it’s important to remember the cost of future medical problems or the dollar value of fish as a free local food source. For example, Zone 2 cleanup at $12,400 per pound of PCB removed translates into only $0.001 per pound of fish protected for human consumption.
17. Zone 2 is a very shallow body of water. From the mouth of the river to Point Sable (4 miles) the bay has an average depth of less than 8 feet. From Point Sable to Point Vincent (3.5 miles) it has an average depth of less than 14 feet. Water circulation in this zone is controlled by wind speed and direction, surface water elevation changes induced by wind and barometric pressure, river discharge, upwelling of the thermocline in Lake Michigan, thermal and density gradients between the bay and Lake Michigan, ice cover and the Coriolis effect (the spinning of the earth causes the river currents to flow up the east shore of the Bay). The Draft Remedial Investigation says this: “Shallow bays and lakes, especially like the inner bay of Green Bay, respond rapidly to transient forces listed above, which tend to dominate over steady, low frequency forces for short time intervals.
18. Zone OU 4 (from the De Pere Dam to the Bay) holds 91% of the PCB mass in the river and 60% of the contaminated sediment in the river.
Please Write Your Comment
Letter Today
or send the enclosed form letter.
We've waited 30 years for this.
Don't miss your chance to make a real difference!
Tell the DNR and EPA waht you think of their plan. Letters must be postmarked by January 21. Mail to:
Ed Lynch, PE-RR/3, WDNR
Fox River Proposed Plan
101 South Webster St.
P O Box 7921
Madison, WI 53707-7921
You can also e-mail comment letters to:
FOXRIFS@dnr.state.wi.us (same deadline).
Find out more:
Copies of the proposed plan are in major Public Libraries:
Appleton, Brown County, Door County, Oneida and Oshkosh.
Please send your ready-made letter TODAY.
Copy and mail or email the folowing letter by January 21, 2002. You can also send a letter from this web address: http://eactivist.actionize.org/view.php?refid=792799&action=1035
Ed Lynch, PE-RR/3, WDNR
Fox River Proposed Plan
101 South Webster St.
P O Box 7921
Madison, WI 53707-7921
FOXRIFS@dnr.state.wi.us
Dear Mr. Lynch,
I am writing to ask that the proposed PCB cleanup plan for the Fox River be strengthened. I am very concerned that the current proposal fails to protect my health, my family or my community.
Specifically, I ask that the plan be amended to:
1. Clean the PCBs from the lower Green Bay (Zone 2) and from additional PCB hotspots which have accumulated in pockets farther north along the bay's east shore.It is disturbing that this contamination has been allowed to linger 30 years from the time that the Wisconsin DNR began Fox River PCB studies in 1971. Toxicologists tell us the cancer rate due just to PCB contaminated fish consumption is approximately equal to the cancer rate experienced by individuals who smoke 2 or 3 packs of cigarettes a day. This risk is 100 to 1000 times greater than cancer risks commonly determined to be "acceptable" by state adn federal agencies, and 10 times greater than cancer risks that trigger stringent regulation of pollutant sources by the U.S. EPA. These consumers also face a variety of non-cancer health risks at high rates. Skin contact and breathing also pose health risks.2. Strengthen the sediment cleanup standard for PCBs to .25 ppm, rather than the proposed 1 ppm. This standard should be applied to the bay as well as the Fox River. (The DNR's own plan documents admit that 1 ppm is not protective of public health or wildlife, and 2 years ago DNR proposed a .25 pm standard, now weakened..)
3. Strengthen measures to reduce the volatilization of PCBs into the air during the dredging and at the final disposal site. It is not acceptable to ignore this often significant release of PCBs.
4. Cleanup work must begin as soon as possible, with multiple dredging crews working simultaneously at several sites along the river and in the bay, to make the cleanup as speedy as physically possible.
14,000 recreational anglers are highly exposed to PCBs in the Fox River and Green Bay system. In addtion, 12,000 low income or minority individuals are highly exposed. Assuming that recreational anglers expose one more family member to fish consumption at the same rate, this means that roughly 40,000 individuals are highly exposed to PCB health effects, an enormous population at risk. Waterfowl hunters also face significant health risks. Due to several weaknesses in the governments' health risk assessment, the actual health risks are likely to be 3 to 4 times greater.
It is unacceptable to allow this risk to persist for more than 100 years into the future (possibly 200-500 years), when we have the technology to remove the problem. Though the cleanup costs are high, I believe the benefits far outweigh those costs, in terms of public health protection and fully restored economic uses of the river and bay system. Our region can't afford to leave the PCBs in place. Those who caused the contamination must be held accountable for their actions.
[You can personalize the form letter by adding your own concerns].
Sincerely,
_______________________________
Signature
Printed Name ___________________________________
Street Address ___________________________________
City, State and Zip Code ____________________________
Phone ______________________________
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