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Susan Pastor, Community Involvement Coordinator
U.S. EPA, P-19J
77 W. Jackson Blvd.
Chicago, IL 60604

Dear Ms. Pastor

The Clean Water Action Council is submitting this letter and attached CD disk and ring binder as evidence that Renard Isle remediation should become part of the amended Record of Decision (ROD) for the Lower Fox River and Green Bay.   In summary, we believe Renard Isle should be added for these 5 basic reasons:

1. Renard Isle is a PCB contamination site clearly linked to Fox River PCB discharges.

2. It warrants serious PCB cleanup attention in its own right, even without the river contamination.

3. Funds are desperately needed to protect public health and wildlife from risks at Renard Isle. 

4. Success of the Fox River and Bay PCB clean-up could hinge on whether Renard Isle is properly addressed. Continued island leakage or a storm breach at Renard Isle could counteract any improvements in the Bay produced by the ROD.

5. The Fox River paper industries must be held accountable and cover a large share of the costs of Renard Isle remediation, repair and long term maintenance. This toxic dump was created because the paper industry polluted the Fox River and Bay sediments.  It exists only because of the contamination.  If the sediments were clean, no disposal site would have been necessary and these sediments could have been used as fill material or for landspreading on farmland over the years. 

Renard Isle is a 55 acre artificial island constructed off shore from Bay Beach Amusement Park as a Confined Disposal Facility (CDF) in 1978.  It sits at the extreme southern end of the Bay, just to the east of the mouth of the Fox River.  It was filled from 1979 to 1996 with contaminated dredged sediments from the Brown County shipping channel (Port of Green Bay). 

The island contains sediments dredged during some of the most intense historical PCB discharge periods and from the most heavily contaminated areas in the last 5 miles of the Fox River, including a final loading from the notorious Fort Howard Turning Basin near site 56/57.  According to rough estimates made by the Wisconsin Dept. of Natural Resources in the 1980s, the island contains about 30,000 pounds of PCBs, and high concentrations of mercury, arsenic, lead and a host of other toxic contaminants. 

When compared to the 60,000-70,000 pounds of PCBs in the river, Renard Isle is an enormous unaddressed toxic PCB hotspot.

Major Concerns

1.  Large Continuing PCB Source Unaddressed --- The BODR claims that new inputs of PCBs to the Fox River and Green Bay are minimal, but the BODR never addresses the long-term PCB leakage from Renard Isle, which could easily be significant.   Similarly, the island has caused a large accumulation of many acres of contaminated sediments between the island and shore, which have also been ignored and unstudied.  This is a major blind spot in the amended ROD.  The liability assignment issues are a side issue at this stage; the most important need is to apply Superfund and state standards to investigate and remediate this site for the sake of public health and wildlife.

2.  Lack of Studies --- Detailed, systematic core sampling has never been done on the island to determine the true distribution and extent of toxic contaminants.  Only a handful of cores have been sampled over the years, enough to show a wide range of contaminant concentrations, some near TOSCA levels.  Only 5 sampling wells were used by the County recently to make broad claims regarding all 55 acres of the island.   In addition, during the 5 well sampling, the wells were sheathed and filtered, because (as the samplers Foth & Van Dyke said) the "mud would flow into the sampling wells."  By filtering out a large percentage of the particulates and solids, and analyzing only the pore water, the PCB and other toxic samples were badly skewed to hide the true nature of the toxic flows from the island.  (Many contaminants stick to particulates.) The DNR has required that 5 new wells be placed and sampled this year, but this still is not the comprehensive site characterization that is needed.  The sediment was laid over many years, from many different areas of the river, with uneven placement on different segments of the island.  At least 110 cores are needed, or 2 cores per acre.

3.  Uncapped and Exposed --- Since the last sediment additions in 1996, the island has remained uncapped and exposed to the elements, resulting in run-off, volatilization and blowing dust.  Large populations of woodchucks, ground squirrels, rabbits, fox, raccoons, waterfowl, terrestrial birds and even deer have been noted on the island, often burrowing through the contaminated sediments, causing further toxic uptake or distribution.  Cottonwoods and willows are growing in large numbers on the island, and their falling leaves undoubtedly carry more contaminants offsite.  The site needs a properly sloped, thick impervious clay and barrier cap, with thick vegetated topsoil, just as required at any upland PCB sediment landfill.  (The Corps and County are pressuring the DNR to give them permission to simply cap the island with sand dredged from the northern end of the shipping channel.  This would be grossly inadeqaute.)

4.  Leaking Dike --- The perimeter dike is not sealed and has little ability to filter contaminants from water flowing in and out of the island on a daily basis.  The dike wall consists of only one layer of interlocked sheet metal held in place by large rocks.  There is no sand, clay or fabric filter core in the walls.  In fact, the Corps once told us verbally that they built the walls with gaps at the bottom to facilitate dewatering of the sediments.  The perimeter is over a mile long, creating a large leakage area from highly contaminated sediments within, like a huge toxic tea bag soaking in the Bay.  Army Corps' dye-tracer studies at other similar, but less contaminated, disposal islands in Wisconsin showed over 90% of the water flow was directly through the walls to the outside, not through designated filters.  The Corps has repeatedly refused to conduct a dye-tracer study at Renard Isle.  The County and Corps have provided no relevant data to support their claims that the leakage effects are minimal.   The island needs to be sealed to prevent further escape of toxins.  Capping alone is not enough.

5. Dysfunctional Filters --- The island was built with two weir structures at one end which were supposed to serve as sand-filtered outfall cells for the island (on the assumption that the walls would "seal themselves.")  The County and Foth & Van Dyke have acknowledged that the weirs are non-functional and NOT filtering wastewater leaving the island.  In fact, DNR documents from 1987 state that the sand weirs were already completely plugged and in dire need of maintenance.  That was 20 years ago. 

6. High Vulnerability to Storms --- The dikes were built to withstand only weak storms with an intensity expected statistically every 20 years, but a 50, 100, or 300 year storm could hit any day, breaching the dikes and spilling contaminated sediments into the bay.  The walls must be reinforced to withstand major storms. 

7. Short Lifespan --- The Corps built the island with only a 50 year design life which will end soon.  In roughly 20 years, the sheet metal walls will need replacement, which will be extremely expensive and logistically difficult to do without serious leakage of toxic contaminants.  Planning must begin now to properly design new  walls and identify the source of funding.  Perhaps the plan should be to excavate and remove the island materials to a safer upland site.

8.  Lack of Planning   --- Currently, we have only a vague promise that the Corps will repair the island in the event of storm damage, and the County has set aside roughly $250,000 for the task, but one storm at the similar Saginaw Bay CDF in Michigan caused a serious breach and cost more than $1 million to repair.  We are very worried that any response in Green Bay will be slow and inadequate.  A detailed contingency plan must be prepared that identifies the specific personnel and chain of command needed for rapid remedial actions starting immediately after island storm damage.  The plan should also secure guaranteed ready equipment, and ensure adequate and immediate sources of repair materials.  All necessary funding sources should also be identified and secured in advance, so repairs will be uninterrupted by funding shortfalls.

9. Lack of Law Enforcement --- For more than 2 decades, the state has refused to enforce the terms of wastewater discharge permits or apply water quality criteria to discharges from the island, despite several documented permit violations and a DNR staff recommendation in 1987 that an enforcement action was warranted.

The ring binder attachments with this letter provide documentation for the claims made above.  A PowerPoint presentation is also included as visual evidence and background, though it was originally prepared for the Wisconsin Dept. of Natural Resources. 

Sincerely, 

Rebecca Katers, Executive Director
Clean Water Action Council of N.E. Wisconsin
1270 Main Street, Suite 120
Green Bay, WI 54311

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