Detailed Comments on Major Project

Detailed Comments on Little Lake Butte des Morts

Comments PDF File

About Dr. deFur

Dr. deFur's CV

Technical Assistance
Grant (TAG)

The following is a summary of concerns raised by Dr. Peter deFur, a technical consultant who we hired last year with a U.S. EPA Technical Assistance Grant.

Key Issues and Recommendations

• The proposed new plan for the Fox River PCB Clean-up [the "Optimized Remedy"] represents a significant step backwards from the original plan and leaves unacceptable amounts of PCB contaminated sediment (44-48% by volume of sediment) remaining in the Fox River.

• Capping is not a viable alternative in the Fox River because environmental factors such as ice, flooding or groundwater seepage could compromise the integrity of any caps.

• The management approach taken in the plan is more focused on logistical issues than on managing and minimizing the risks posed by PCBs in the river.

• WDNR needs to develop a source control plan for new and ongoing sources of PCBs into the river.

• Investigations outlined in the "Basis of Design Report" regarding loadings of PCBs are sparse and inadequate.

• WDNR should develop a plan to achieve zero additional PCB discharges into the river.

• WDNR should remove as much of the contaminated sediment within the Fox River as physically possible. The most effective method for reducing risks from PCBs in the river is to remove them.

• PCB cleanup technologies such as sediment washing exist and should be considered as alternatives to the disposal of contaminated sediments in landfills or CDFs

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