|Engineer Questions Lack of Bay Cleanup|
Lack of Bay Cleanup
|Citizens hire William G. Acker to analyze
News release --- Thursday, Nov. 15, 2001
(Green Bay, WI) An engineer has discovered serious flaws in the governments’ proposed PCB cleanup plan for the Fox River and Green Bay. He concludes that lower Bay cleanup is both cost-effective and feasible, contrary to government claims.
William G. Acker, a civil engineer with 27 years of experience with the paper industry and other businesses in Northeast Wisconsin, was recently hired by the Clean Water Action Council on behalf of a citizen coalition funded with a Superfund Technical Assistance Grant by the U.S. Environmental Protection Agency. (See resume and synopsis.)
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.
William Acker is a Bay shoreline resident himself, and understands the toxicity and economic concerns of local citizens examining the cleanup proposal.
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.
2. 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,
5. If Zone 2 is included in the proposed cleanup plan (to 1.0
ppm), we remove an additional
6. In the WDNR Proposed Plan, they admit that nearly one-half of the
total quantity of PCBs
7. On page 13 of 35, the Proposed Plan says: “In general, areas with
the greatest risk are
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
10. In the WDNR Proposed Plan, Zone 2 (from the mouth of the river to
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.
CONTENT BY: Rebecca Leighton Katers
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