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• Goals
• The proposed cleanup plan
• Description of dredging and off-site disposal
• Timeline
• How long will it take to reach health protection goals?
• Cost
• Who pays?
• Public comment process
• Where can I find out more?

• Concerns about the proposal.  How could it be improved?

• Meet the human health water quality standard of 0.003 ng/L (nanograms per liter) for PCBs This equals 0.003 parts per trillion (ppt) PCBs

• Meet the wildlife health water quality standard of 0.012 ng/L for PCBs.  This equals 0.012 ppt PCBs.

• Meet the sport fish consumption advisory standard of 0.05 ppm (parts per million) --- (this still allows a 1-in-10,000 cancer risk)

• Protect ecological values, like healthy invertebrates, birds, fish and mammals, especially those which eat fish.

• Reduce longterm transport of PCBs from the river into Green Bay and Lake Michigan.

• Minimize downstream movement of PCBs during dredging.

View MAP by Green Bay Press Gazette

• Unit 1 --- Little Lake Butte des Morts  --- dredge hotspots, with off-site disposal, to meet an action level of 1 ppm PCBs in the sediments

• Unit 2 --- From Appleton to Little Rapids (approximately 20 miles) --- no action except monitoring

• Unit 3 --- From Little Rapids to De Pere --- dredge hotspots, with off-site disposal, to meet an action level of 1 ppm PCBs

• Unit 4 --- From De Pere to Green Bay --- dredge, with off-site disposal, to meet an action level of 1 ppm PCBs

• Unit 5 --- The Bay of Green Bay --- no action except monitoring

This includes the removal of sediment having PCB concentrations greater than 1 ppm using a hydraulic or mechanical dredge, dewatering the sediment either passively (in settling lagoons) or mechanically (with presses), treating the water before discharging it back to the river, and then disposing of the sediment in a landfill, either transporting it by truck or by pipeline.   Different combinations of these techniques may be used in different sections of the river.  Specific landfill disposal sites have not been selected.  No detoxification methods would be used.

• Start work in the summer of 2003.
• Complete work in 7 years.

• Unit 1 --- Little Lake Butte des Morts  --- 14 years before high-intake human fish-eaters are protected (to a 1-in-100,000 cancer risk).  29 years before fish-eating mammals are protected.

• Unit 3 --- From Little Rapids to De Pere  --- 42 years before high-intake human fish-eaters are protected.  43 years before fish-eating mammals are protected.

• Unit 4 --- From De Pere to Green Bay  --- 59 years before high-intake human fish-eaters are protected.  45 years before fish-eating mammals are protected.

• Unit 5 --- The Bay of Green Bay  --- More than 100 years before sport fish consumption warnings are lifted.

$258.1 million --- for dredging and landfilling

$49.5 million --- for monitoring

Seven paper companies who dumped PCBs in the Fox River from 1954 to ~1990.

The formal public hearings have concluded (on Oct. 29 and 30, 2001).   Citizens need to write letters explaining their concerns to the DNR and EPA.   The public written comment period has been extended by another 45 days.

Letters --- must be postmarked by January 21, 2002

Mail to:

Ed Lynch, PE-RR/3
Wisconsin DNR
Fox River Proposed Plan Comments
101 South Webster St., P.O. Box 7921
Madison, WI 53707-7921

back to top

DNR's website --- http://www.dnr.state.wi.us/org/water/wm/lowerfox/index.html

At Public Libraries --- Appleton, Brown County, Door County, Oneida and Oshkosh
 

The proposal includes several weaknesses.  Unfortunately, the plan documents occupy about 18 inches of shelf space and take several weeks to analyze in detail..  Using the EPA Technical Assistance Grant, we've hired 2 independent experts (a toxicologist and geologist) to help us with this analysis.  Their conclusions will be presented soon on this website.  A few initial concerns:  (more to come later)

• Protects the Polluters Before Protecting Public Health --- The agencies claim the plan is driven by health concerns, but it's clear the plan is written first and foremost to keep costs down.   The agencies have responded to criticism by saying they can't support a $1 billion cleanup, even if it's necessary to protect public health.  The public faces enormous health risks and economic damages, primarily in lower Green Bay and the river downstream from the DePere Dam.  But this plan allows 59 years to pass in this river section before "high-intake" fish-eaters are protected.  The high-risk Bay fish-eaters won't be protected for more than 100 years.  This is simply unacceptable.  (See The Corporations Can Afford It.)

• No Action on the Bay --- The plan leaves several areas of significant PCB contamination untouched.  In particular, the plan includes no remediation in the bay of Green Bay.  The plan's sediment dredging stops at an imaginary line at the mouth of the river, even though significant PCB contamination can be found in sediments just beyond the mouth and around the corner along the East Shore.(See map by Green Bay Press Gazette)  Approximately 66,000 pounds of PCBs still sit in the Fox River, which the DNR and EPA have targeted exclusively.  Another 69,000 pounds of PCBs are just beyond the river mouth in the extreme southern end of Green Bay, mostly south of Long Tail Point and Point au Sable.  These bay sediments are accessible and the cost per pound of PCBs removed from the bay is actually the same or lower than the cost per pound in the river. This bay cleanup would make the overall cleanup cost closer to $1 billion, but would get much faster results in terms of public health protection. (See The Corporations Can Afford It and Engineer Questions Lack of Bay Cleanup) 

• River will be Re-contaminated by the Bay ---- Removal of the lower bay hotspots could greatly speed the recovery in the Fox River below the De Pere Dam as well as in the lower Bay.   If the lower bay isn't addressed, the bay PCB sediments will wash back up the Fox River with storm surges and seiches (tide-like sloshing in the bay.)   The fish in this river section also move freely between the river and bay, raising questions about the plan's claim that it will take only 59 years for the river fish to be safe to eat, but over 100 years for the bay fish.

• PCBs Are NOT Evenly Distributed --- Contrary to agency statements, PCBs are NOT uniformly distributed in the sediments of the Bay.  Distinct hotspots have been located, including a serious one offshore from Bay Beach Park and from Dykesville, along the East Shore.  We need estimates of the cost of removing just those hotspots, not lumped with the general background sediments.  We'll be scrutinizing the detailed documents for this information.

• Weakened Cleanup Standard --- The 1 ppm PCB sediment cleanup standard is 4 times weaker than the initial DNR proposal 2 years ago (which was itself weaker than a previous (.05 ppm) cleanup standard proposed 5 years ago).  The DNR claims the federal Bush Administration made them do this.  This represents a major retreat from health protection.   When comparing the 1 ppm PCB cleanup standard with the fish-eating advisories which start at only 0.05 ppm PCBs, it's easy to see that the cleanup is grossly inadequate.  Dr. Foran's preliminary analysis shows that a truth health protection cleanup standard would be approximately 1,000 times lower than proposed by the agencies.

• Unrealistic Consumption --- The agencies used a fish consumption rate that is only half the rate identified in scientific literature for highly exposed populations (subsistence consumers and minorities.)  In addition, they used a "reduction factor" which assumes that cooking and cleaning reduces contaminants, but, in fact, this does not protect individuals who don't cook and clean following state guidelines (Hmong populations, some native American groups.)

• Questionable Application of the Standard --- The 1 ppm cleanup standard is misleading because it isn't being applied to known PCB hotspots which are well-over 1 ppm in the Bay.   Furthermore, the Fox River Coalition, which met from 1992 to 1997 on this issue, frequently discussed 11 million cubic yards in the Fox River with concentrations higher than 2.5 ppm PCBs.  Now, this plan says only 7.25 million cubic yards will be removed to a cleanup standard of 1 ppm.  Something doesn't seem right.  This is another area we'll be examining.  The agencies appear to be averaging the PCB levels in the sediment in order to achieve the 1 ppm. 

• Chemical Risks Only --- The ecological risk assessment only looks at toxic chemical effects. But the wildlife are more vulnerable to toxic effects when also stressed by habitat modification, thermal stress, exotic species, and disease.  (All factors present here.)  This means a better PCB cleanup standard is needed.

• Hydraulic vs. Mechanical --- The plan should specify hydraulic (vacuum) dredging methods only.  No messy clamshell dredges or other mechanical dredging methods should be allowed, because they could stir up the PCB sediments while trying to remove them.

• Better Landfills Needed --- The landfills need to be stricter than normal, to prevent PCB volatilization into the air and to treat wastewater, not to send it through regular sewage treatment plants.  We need to prevent the contamination of our sewage processes.

• No Detoxification Required --- The sediments with higher PCB concentrations should be pre-treated before landfilling, to detoxify the PCBs, using a process which will not make matters worse by creating dioxins.  Incineration of PCBs can be dangerous, so other non-burning methods would be preferred. 

• "Natural Recovery" isn't Natural or Recovery --- The plan relies heavily on the industry's favorite cleanup proposal: do nothing but "allow fresh sediment to cover the old," or let the PCBs disperse to become someone else's problem.  They omit the natural processes of erosion, wave action, turnover of larger slower bodies of water, biologic processes, and human activities that counteract this "recovery."  The PCBs are not being buried.  They're moving and cycling throughout the system.  They don't break down and will be with us for hundreds of years if we don't act to contain and destroy them.

• Disperal Hurts Other People in Distant Regions --- It's wrong to wait for PCBs to disperse through water and wind action, because PCBs become airborne and reconcentrate in cold regions of the world where those people will suffer PCB health risks.  Also, millions of people use Lake Michigan and the Great Lakes, which are all connected to the Fox River and Bay PCB contamination.  We're affecting a wide region and need to stop.

• Rushed Public Process --- The public hearings came too soon for the public to have time to discuss and digest the details of the proposal, and make fully informed testimony at the hearings..  Many groups had already mailed their newsletters for the month of October by the time of the Oct. 2 announcement.  Their newsletters didn't mention the public hearings on Oct. 29 and 30.

Everyone familiar with the process knew that the agencies were likely to extend the written public comment period by at least another month or two, and, in fact, they announced this extension at the first hearing on Oct. 29.  The agencies should have done this upfront on Oct. 2, and allowed citizens much more time to prepare for the public hearings.  There was absolutely no reason to rush the hearings.

The agencies were also far too slow to provide the documents.  They relied primarily on the DNR website to disperse the information, but the massive pdf documents were too enormous to download and print from there, forcing everyone to try roaming through all the technical data on screen, an extremely cumbersome process, especially for older, slower computers.  Many people found that the site was disfunctional when they needed to use it.  Also, our experts found that key pages were missing and had to be requested by mail.

The agencies excused themselves by saying citizens could read the documents at one of five local libraries.  But a person would have to live at the library for weeks in order to read these documents, or in many cases, travel long distances over and over again to reach one of these libraries, an unrealistic expectation by the agencies.

The agencies should have produced a more useable document, written in terms that a lay person could understand, no more than 2 inches in width --- and required the polluters to pay the cost of printing and mailing copies to interested members of the public.

As it is, the proposal takes up about 18 inches of shelf space (without the binders).  It's an enormous 7 volume set.  It takes time to read.  One of our experts (Dr. Foran) finally received a hardcopy on Oct. 11th only 12 days before he needed to give a public program on the issue..  Our office and our geologist didn't get one until Oct.19, only 10 days before the first public hearing.  But under the TAG grant we were supposed to read and understand this massive document and share our analysis with the public in time for the first public hearing on Oct. 29. 

Keep in mind, it takes 2 weeks to write, print and mail our newsletters to reach your home reasonably before the hearings. Dr. Foran, as our TAG expert, was supposed to analyze all the documents in time to give his presentations on Oct. 23 and 24, and at the hearings on Oct. 29 and 30.   The EPA and DNR knew our schedules and plans under the TAG grant, yet they crippled our efforts. We've waited years for the opportunity to comment on this plan, but now it's been rushed to prevent citizen review of the details before the hearings.

In addition, when the agencies publicized the hearings, they insisted on calling them "meetings."   To most of the public, this would sound like just another event where the agencies do all the talking and the public has to just sit there and take it.  The public is sick of meetings on this issue, after 16 years of talk and delays.  The public has been waiting YEARS for THEIR opportunity to tell the agencies what they think, but they may not have attended the hearings because they didn't know "this was it."

We called many of our members and found they were confused by the DNR's publicity of the "meeting."  Luckily, the TAG grant included some advertising dollars, so we placed ads in numerous area newspapers to urge people to attend the hearings.  We hope this helped, but it shouldn't have been necessary if the agencies were doing their jobs correctly.

In fact, the agencies themselves had trouble getting their own mailings out within their self-imposed deadlines.  Many of us did not receive the EPA notice cards or descriptive newsletters until AFTER the public hearings were held.  They may have wasted thousands of taxdollars on these late notices.  (To be fair, some of the delays may have been due to anthrax scares and delays at the various Post Offices.  But this highlights the risks inherent when setting unrealistic short timelines for publicity.  This was too important an issue to rush.)

When the hearings were finally held, the agencies siphoned off many citizens to a side room, where they testified early then left --- which also diluted the sense of a "town hall meeting" or "hearing" where we could have a public discussion and debate over the issue.

Finally, the DNR limited citizens to only 3 minutes each for their testimony at the hearing --- on an 18" thick document on a plan costing over $300 million and impacting an enormous region of our state and the Great Lakes.  A person can't begin to testify properly in that short time on the kinds of concerns we've listed here on this page.  The DNR was not making a serious effort to truly listen.

The agencies at the hearing had the nerve to claim that they want public involvement and that they wanted to hear citizen concerns, but they manipulated these hearings in numerous ways to suppress a proper public discussion and debate of the plan details.