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When the DNR recently released their long-awaited report,"Green Bay Sediment Results from July 2002 Survey," we were shocked to discover that the survey deliberately did not sample most of the Bay sites that citizens had expressed concerns about. 
 

This is critically important because the new PCB concentration data was needed to verify or disprove the disputed data provided by the DNR and EPA in their  Remedial Investigation and Feasibility Study (RI/FS) a year and a half ago.  As we reported last year, a major conflict arose when our engineering consultant, William Acker, discovered that the RI/FS included two different sets of data that were fundamentally incompatible, from two research groups. (See Acker's conclusions.) Clean Water Action Council issued a news release demanding better sampling. The UW-Sea Grant Institute claimed only 19,000 pounds of PCBs are found in all of Green Bay, while the DNR's consultant, Remediation Technologies (RETEC), claimed the total is 154,000 pounds (with 69,000 pounds concentrated in the extreme southern end of the Bay.)

Obviously, this throws cleanup planning into a cocked hat. 

When the discrepancy was publicized, each group insisted they were correct.  The DNR tried to downplay the dispute, because they didn't intend to clean Bay sediments anyway.   On this point, UW-Seagrant agreed.  Unfortunately, at that time, the scientists based their opinions on very few samples.  Seagrant took only one sample south of Long-tail Point, DNR took only about 6 samples, and the rest were paper industry consultant samples which we don't trust.  The U.S. Army Corps of Engineers generally sampled only in the shipping channel, so that data wasn't helpful.

Taxpayers spent $13 million for the Green Bay PCB Mass Balance Study a decade ago and another $4 million for the PCB cleanup plan by RETEC and the DNR.  It's an outrage that we don't have better, more reliable data for the Bay after all this expense. We desperately need more Bay samples taken by trustworthy researchers.

Last year, we insisted that the DNR's 69,000 pound estimate had a  ring of truth to it, because it was only logical that sediments accumulated along the Bay's eastshore would contain many of the same PCB concentrations as the nearby sediment source, the Fox River.  In fact, 90% of the PCBs remaining in the river are concentrated in the last 7 miles, between the DePere Dam and the river mouth.  It is inevitable that these sediments would have contributed significant PCBs to areas just beyond the mouth and to the east.

Mr. Acker determined that many thousands of pounds of PCBs could be cleaned up in the southern Bay as cost-effectively as the river cleanup.

We had been counting on the new Bay samples to clear up the scientific controversy and allow for informed decision-making by the agencies.  The samples should have been taken to precisely identify the locations and volumes of hotspots.  Once identified, we had argued that those PCB hotspots should be cleaned up to the extent possible. 

Now, we've been handed a highly misleading report which leaves us with many of the same concerns and questions we had last year.

The following are obvious weaknesses in the study:

1.  Channel samples inappropriate   All of the 39 core samples were clustered along the 11-mile shipping channel, down the center of the Bay (see map).   This would be the most disturbed part of the Bay, not where hotspots would be congregated.  The shipping channel is 24 feet deep while the water is less than 4 feet deep next to the Inner Bay channel.  They sampled near channel side slopes, where PCB sediments would be diluted with cleaner deep sediments or sediments from upstream.  The nearby shallow sediments are also churned by waves.

2.  Lower Bay samples needed, not northern  Only 18 of the 39 cores were taken in the lower Inner Bay where we most needed data (south of Long Tail Point and Point Au Sable) with 11 cores clustered around the mouth of the Fox River.  The river mouth samples were elevated, up to 30 ppm PCBs, as we expected.   The river flows into the Bay and currents turn east at this point, but no samples were taken to the east of this hotspot.

3.  Not deep enough   The average core sample was only 10.5 inches deep.   13 of the 18 core samples taken in the Inner Bay (south of Long Tail Point and Point Au Sable) were less than 1.5 feet deep.   While the Bay is shallow, the sediments are MUCH deeper than 1.5 feet in many key places.   Our greatest concern is for the buried PCBs disturbed only when major storms hit.  Also, on the surface, fine particles would tend to be washed, leaving a higher percentage of sand or gravel, skewing the PCB data. Surface sediments are mixed by storms. PCBs would be most diluted in these layers.

The DNR argued they were sampling near the channel to test areas where dredged sediments were side-cast back in the 1960's when open-water dumping was allowed.  This is fine, but they didn't go deep enough to locate those old deposits. 

To be useful, the researchers should have searched carefully for  pockets and thicker deposits of fine-grained sediments, because PCBs stick to fine silts, clays, and organic matter, but not to sand.  Cores should have been driven deep into these areas.

All of the Inner Bay samples were in shallow waters, less than 4 feet deep.  Samples should have been taken in the 10 feet deep waters east of the shipping channel.

4.  Money wasted   The researchers wasted precious money and time taking 21 of the 39 core samples along the shipping channel north of Long Tail Point and Point Au Sable, not in the Inner Bay where we desperately needed samples.   (Each sample costs hundreds of dollars).  We wouldn't expect to see PCB hotpots along this northern section, because it is primarily sandy and flushed regularly by freshwater currents coming down the west shore from the Upper Bay.  (PCBs are generally low in sandy sediments.) 

Frying Pan Shoal is a sand bar just below the water surface, stretching between the two Points. It forms a modest barrier to sediment movement north, and causes the water in the Inner Bay to circle counter-clockwise after leaving the river.

Five of the samples were taken in the Shoal, with 2 of them only 3 inches deep, a ridiculous waste of money.   Those could hardly be called "core samples" or more important than Inner Bay samples.

5.  Dyckesville and Door County concerns ignored   No samples were taken by Dyckesville, north along the eastshore, though everyone acknowledges the presence of a large PCB hotspot there.  The neighbors are very concerned.  Numerous past studies show that Bay currents tend to go north along the east shore to Door County, but no samples were taken along that path.

6.  Questionable companies took samples  The samples were taken by RETEC (Remediation Technologies, Inc.) and Superior Special Services, both major industry consultants, when we had specifically asked for the agencies to take the samples themselves.  Both consulting firms have direct financial ties to the paper industry in Wisconsin, and we don't trust them.   RETEC was hired to do the RI/FS by DNR, on the recommendation of the Fox River Group of paper industries. (See1998 report on RETEC.)

7.  Kidney Island accumulation ignored   The DNR separately took 2 samples from "inside the crescent" of Kidney Island and found low levels (<1 ppm PCBs).   But the  sample locations deliberately missed the huge bulk of the accumulated sediments between Kidney Island and the mainland at Bay Beach Amusement Park.   DNR took samples from an area where a narrow channel now cuts through a continuous sediment bed (dry land some years) which has formed because of Kidney Island's stagnation of current.  Samples there would not be typical of the main sediment bed.  This was not a serious effort to characterize this site.

This matters because the 1988 "Remedial Action Plan" approved by the DNR called for restoration of Bay Beach as a public swimming area, and even now, Brown County government has big plans for boosting water recreation there.   Local taxpayers should not be stuck with the future liability of cleaning up this hotspot, when this should be part of the overall River and Bay PCB cleanup.

8.  Sampling missed sediment dumping grounds   The Study narrative claims the 39 samples took place along areas where dredged sediments were historically dumped, back when open-water dredge spoil disposal was allowed.  But, it appears they deliberately missed the main dumping ground in the mid-lower Bay, to the west of the channel.  ThereÕs a gap in the sampling.

9.  What about the 69,000 lbs of PCBs?  The DNR claims the study results were not surprising, but they haven't responded to our main concern about the 69,000 pounds of PCBs (the same quantity as the entire Fox River) which the DNR last year claimed sits in the Inner Bay.   What is the PCB mass now given these results?  Given the lack of eastshore, middle-east or westshore samples, can the DNR even hazard a guess?

Furthermore, the obvious data scarcity, and the larger scientific dispute last year about overall Bay PCB levels calls into question the reliability of the computer models which were used to argue against cleaning up Bay hotspots.  The DNR and EPA claimed it would be more than 100 years before the PCBs decline to "safe" levels, so it "made no difference" to clean the Inner Bay. 

We'll need much more proof before we can believe this.  Many more samples must be taken.

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