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The National Research Council recently issued a report saying, "Sediment dredging has fallen short of achieving cleanup goals at many contaminated sites."   Many local news media interpreted this report as supporting the EPA and DNR proposal to cap PCB hotspots in the Fox River.  As usual, they've gotten it wrong.

In their news release, the NRC cited 8 basic conclusions:

1. "It has not been demonstrated that dredging has reduced the long-term risks the sediments pose to people and wildlife."

This is an amazing blanket statement until you realize the NRC is talking about MEASURED results AFTER a cleanup is done.  Most of the major sediment cleanups are still underway and only partially complete, so of course the agencies couldn't have demonstrated long-term risk reduction.  We're still in the short-term.   It would be impossible to detect any effect on the Fox River yet. 

No kidding.  River sediment clean-ups are difficult and time-consuming.  Also, dredging is bound to leave some residue that must have time to be buried or disperse.  Short-term results should not be expected. 

Also, the cleanup standards being used for many of these cleanups were DESIGNED to be too weak to protect public health and wildlife, even after the clean-up is done.  On the Fox River, the initial risk assessment determined that .25 ppm (parts-per-million) PCBs was the maximum concentration that should be left behind in sediment, to leave an EVENTUAL, AVERAGE, OVERALL concentration in the low parts-per-billion range (around .001 ppm or 1 ppb), which is the true level necessary to protect public health.  But the government caved in to corporate pressure and weakened the Fox River standard to 1 ppm, which equals 1,000 ppb.   This means a large mass of PCBs is being left behind in dredged areas.  OF COURSE this would hamper short-term and long-term goals for reducing pollution levels.

Monitoring is important, both before and long after.  But it's important to not put too much emphasis on interim monitoring during the cleanup process or on short-term results.  Long-term results are far more important.  Also, if monitoring data is lacking, how can the NRC say "sediment dredging has fallen short of achieving cleanup goals at many contaminated sites?"  It sounds like the NRC is stretching to make significant statements based on very little data.  The NRC seems to have a hidden agenda here.

Of course.

The "residual" issue is highly overblown as a risk, unless the initial cleanup standard deliberately left a large mass of residual contamination behind.  It's important to make a distinction between a light dusting of drifted residuals just on the sediment surface and a thick layer of 6" or 3 feet of 1 ppm PCB sediment left behind deliberately.  If long-term goals aren't being met, it's probably because the original dredging program was too limited.  More contaminated sediment should have been removed in the first place.

The bottom line is that if the MASS of PCBs has been removed, it's gone forever, period.  The long-term risks should be negligible, if the dredging program is aggressive enough.

This NRC report also muddies the water.  There are 2 kinds of caps proposed for the Fox River cleanup, but the NRC news release didn't make a distinction between them.  The first kind of capping lays a 6 inch sand layer over areas which have been dredged.   The sand is used as a dilution layer and everyone expects the sand will erode from many of these so-called "capping" sites over time.  The second kind of cap is proposed for sites on the Fox River which will NOT be dredged at all, or will be only partially dredged, and the caps will be thicker and designed to be semi-permanent (perhaps to 100 year storm standards).  This means the cap is not simply covering up "residue," it is covering ALL of the PCB hotspot.

Of course there will be a small amount of pollution released during dredging, but the use of a hydraulic, vacuum-style dredge, or closed environmental dredge, minimizes this release.  The NRC is also ignoring the fact that the laying of caps will also cause a significant release of contaminants.  The capping process could be just as messy as dredging.

Keep in mind that the Fox River sediments are now releasing hundreds of pounds of PCBs each year, with no dredging at all.  If dredging elevates that release slightly in the short-term, it must be balanced against the HUGE drop in releases a few years after dredging is done.   Once the PCB mass is gone, the fix will be permanent.  With capping, we would have to worry permanently about future leaks, recontamination, and health risks due to cap failure.

Seems obvious.  It appears the NRC is saying that dredging should be used on the Fox River to prevent contaminated sediments from being dislodged by storms, floods or ice erosion, but the wording is vague enough that the DNR and EPA would undoubtedly interpret it differently.

This is problematic.  While we're unhappy with the performance of the Wisconsin DNR on this issue, we're equally unimpressed with the EPA's performance.  And while we agree that national standards are needed and would be preferable, this is only true if they are HIGH standards, not the lame leadership we've seen to date from the federal government.  We would not want to see a federal program which is only the lowest common denominator of all the weak state programs in this country.  We would also hate to see all the responsibility placed under the political control of rabidly anti-environmental politicians like George Bush and Dick Cheney.

In their news release, the National Research Council raised many concerns about dredging, but they failed to acknowledge that THEY HAVE NO DATA on the longterm effectiveness of the alternative sediment remediation method, the so-called "permanent caps" proposed for the Fox River over large PCB deposits.  There have been no comparable caps placed anywhere in the world in a large flowing river at a northern latitude like ours, exposed to annual freeze-thaw pressures and ice scouring.  The NRC seems to be favoring capping instead of dredging, without any comparable data requirements or analysis of capping effectiveness.

The National Research Council report is not new information, not well summarized, clearly one-sided, and seems to be politically timed to serve the polluters' interests, not the public's interests. 

This is a political report.

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