Highlights

General Comments

Comments on the 
Draft Feasibility
Study (FS)

Comments on the 
Draft Remedial
Investigation (RI)

References

Complete Report
for easy printing

About Donna Boreck

Donna Boreck's 
Resume (PDF)

Technical Assistance
Grant (TAG)

For immediate release 
Wednesday, Jan. 16, 2002

(Green Bay, WI)  A geologist has identified several shortcomings in the Wisconsin DNR’s proposed PCB cleanup plan for the Fox River and Green Bay. Donna Boreck was 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. The grant program was created by Congress to allow local citizens to hire outside experts for a "second opinion" to help them review and comment on the highly technical documents produced by the government and the polluting industries.

"The cleanup plan depends heavily on computer models, rather than actual data, particularly in the bay," concluded Boreck, a geologist with many years of experience with hazardous waste sites. "Each model has limitations. The farther the model is projected into the future, the more inaccurate it becomes. It is not appropriate to leave the PCBs in the river and bay based on imprecise computer models, when we know through actual data that public health risks will remain high without cleanup."

The Wisconsin DNR and U.S. EPA have proposed to leave 20 miles of the river and the entire bay to "natural recovery" due to flawed computer model projections. For example, very few sample points from Zone 2 of the Bay (the extreme southern end) were factored into the model, which would skew the model results from cleaning that area. In addition, the agencies imply that natural recovery will occur on the bay in 100 years, when this is based on a computer model which stops at 100 years. Actual recovery may take 200 or 500 years without cleanup.

The agencies also place an "all or nothing" emphasis on the model results. They concluded bay cleanup would not be worthwhile based on their assumption that it could be more than 100 years before fish-advisories could be lifted. This ignores the fact that a bay cleanup would greatly reduce risks in the meantime.

"The plan assumes PCBs will be buried or diluted by natural processes over time, yet the DNR’s own documents show this will not be protective in a reasonable time frame," added Boreck. "This is a significant contradiction."

"The river and large sections of the bay are not quiet waters. The higher energy environments do not allow for efficient burial and isolation of PCB-bearing sediments. Erosion of PCB deposits, storm waves, ice action, bioturbation (bottom wildlife activity) and human disturbance will continue to keep PCBs in active circulation and available to the foodchain for a long time, unless the PCBs are permanently removed."

Boreck was critical of the plan’s priorities. "The cleanup levels seem focused more on minimizing costs and less on protecting human health," concluded Boreck. "The method used to determine the 1 ppm PCB extraction level is not appropriate for a contaminant like PCB. The DNR’s consultant used methods similar to those used to determine the most cost-effective quantity of ore to extract in a mining operation, where the resulting health risk would not be a factor."

Boreck also challenged the notion of capping PCB deposits in the river, due to her concerns about erosion potential from excessive currents in the river, and the potential for increased currents following major storms and flooding. She noted, "The proposed capping 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. Large scale cleanup requires the best available proven technology, which would be dredging and removal of PCBs in this case."

Boreck recommended a more stringent clean-up target of no more than .25 ppm PCBs in the remaining sediments. Even with the extensive averaging used in the plan, she found that the proposed, higher 1 ppm target level could not achieve the averages necessary to meet the public health protection objectives stated in the plan.

View details of Donna Boreck's review

• Highlights
• General Comments
• Comments on the Draft Feasibility Study (FS)
• Comments on the Draft Remedial Investigation (RI)
• References

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