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At last night's meeting, the DNR and EPA attempted to answer the public's questions about the final Record of Decision (ROD) for the Fox River and Bay PCB cleanup.   Several of their answers raise important questions:
 

1. ROD Amendment Required for Incinerator, Why Not Capping? The agencies announced they would need to undergo an amendment process in order to add the Minergy Incinerator (otherwise known as "Vitrification") to the final Record of Decision.  This amendment process will open the incineration proposal to a new public comment and public participation process. This seems odd given that the agencies are NOT requiring themselves to undergo an amendment process for another radical change in the ROD - the capping (rather than removal) of hundreds of acres PCB hotspots on the bottom of the Fox River.   The public deserves an opportunity to weigh in on that proposal equally, but the agencies clearly want to the shut the public out. The agencies argue that capping was mentioned in the proposed plan a year and a half ago, but the same can be said of the incinerator.  The public was asked to comment on a plan where neither incineration nor capping were seriously considered or chosen by the agencies as part of their proposal.   In addition, we were told by the agencies verbally that capping did not look likely or desirable.  Based on this information, the public did not give much attention to the two technologies, or several other technologies which were mentioned but not proposed.  We focussed our limited time and resources on the elements which the agencies DID propose.

Flowing water is powerful and erosive.   Capping PCBs in place is only a temporary solution.

The agencies say they revised the ROD to incorporate capping after they received a great deal of technical information from Appleton Papers' "expert panel" in support of capping.  But this information was submitted long AFTER the public hearings and comment period ended, and was coupled with intensive political lobbying by the "expert panel."  The polluting corporations also organized a publicity campaign around their biased capping proposal.  Arjo Wiggins Appleton (the European owner of Appleton Paper's PCB liabilities) was also busy giving $1.5 million grants to the University of Wisconsin, in an apparent effort to buy silence and support for their capping proposal.  (see University Credibility). The public was never given an chance to respond with opposing technical information.  The public did not have the same level of access to the agencies, corrupt politicians or the University.

It certainly appears that the capping proposal was a political decision, not a technical one - or the agencies wouldn't be so afraid to open the proposal to a ROD amendment, public hearing and comment period.   If the agencies can take the time to amend the ROD for vitrification, it would be a simple matter to fold the capping proposal into the same public review process.  It's obvious that they don't want to hear the opposing technical and legal arguments.

2.  Bay Numbers Now Radically Different  Last night, the DNR announced revised estimates of the PCB quantity in the Bay of Green Bay, dropping the total from 154,000 pounds down to 32,000 pounds.   This is a 5-fold drop.   This means that roughly two thirds of the PCBs in the system are still in the Fox River, and only one third has escaped to the Bay.  (see Bay Data Debate and Samples Miss Targets)

This is significant and cancels many of the DNR and EPA arguments which were presented last year during the public hearings and comment period.   Last year, they argued that the Bay was hopeless and would take more than 100 years to recover, even if a cleanup occurred; therefore, the agencies did not seriously consider a cleanup of the lower Bay even in areas which exceeded their cleanup target of 1 ppm.   They based this decision on computer model forcasts which used the much higher 154,000 pound figure, which they now admit was wildly inaccurate.

The same argument was used to justify the 1 ppm PCB cleanup target.  The DNR and EPA argued that because there was such a large mass of PCBs circulating in the Bay (at 154,000 pounds) that their computer models showed that it made no difference whether they used the 1 ppm target or the .25 ppm target which 25 environmental and conservation organizations are on record supporting. (see detailed discussion in Letter from 25 Organizations)  Again, the agencies claimed that the situation was hopeless, so they chose a politically expedient partial cleanup target which is guaranteed to NOT protect public health.

When pressed, the DNR and EPA said they did intend to run the computer model now with the lower Bay estimate, but said it would not change their cleanup target of 1 ppm.

Once again, the public was fed grossly inaccurate information at the public hearings and during the comment period, only to find now that we were duped into hopelessness.   It seems likely now that the system could recover much more rapidly with a more aggressive cleanup target, but the public is being cheated of this.   Thousands of people will continue to be poisoned for many decades into the future, when we have the financial and technical ability to perform a much better cleanup.

3. Misleading Recovery Forecasts   Last year, the EPA and DNR said that if 1 ppm were chosen as the cleanup target it would be 45 years after cleanup before the last 7 miles of the Fox River could be removed from the fish consumption advisories.  Because the cleanup will take 10 years,  this means it will be 55 years from now.

Last night, the DNR and EPA tried to deceive the public by saying this stretch of river would recover in less than 20 years.   Their forcasts were more favorable and self-serving because they were based solely on one-year-old Walleye, which are too small to keep or eat.   Sport anglers go for the 4- to 5-year-old Walleye, which accumulate 4 to 5 times as many PCBs.   In addition, many subsistence anglers are catching and eating Catfish, Suckers, Bass and even Carp, which will also take much longer to recover. 

The agencies are deliberately misleading the public about the lingering effects of the pollution they choose to leave behind in our river and bay.   They are hiding the public health impacts of their weak cleanup standard.  The economic impacts are also substantial - the recovery of commerical fisheries for carp and other fish will be delayed by several decades.

At a minimum, the cleanup target needs to be .25 ppm PCBs (this means removing all sediments which are at or above .25 ppm).  This will lead to average sediment PCB levels sufficiently low to lift the fish consumption advisories just a short time after the cleanup is completed.   The recovery could be achieved decades earlier.

The proposed cleanup will cost $400 million, but a relatively small increase in the investment could protect health and boost the economy decades earlier.  (For the last 7 miles of the river, the incremental increase in cost is only $18 million, to dredge down to .25 ppm PCBs.)  To stop just short of the goal is a poor investment strategy.

4. Surface Concentrations vs. PCB Mass --- The DNR and EPA argued that the radically different PCB quantity (the mass of PCBs) may not affect the computer model forecasts because the model is based primarily on surface concentrations of PCBs, not the depth of contamination or total quantity of PCBs in the system.   This is a strange skew in the model, because it is clear that major 100-year or 500-year storms could stir up deeply buried PCBs to recontaminate surface layers, and conversely if the deep PCBs have been removed, the storms would stir up cleaner sediments and rapidly dilute the surface PCBs.

A more aggressive cleanup would remove any potential for storms to stir up and recontaminate the river and bay in the future.
 

5. Dishonest Words --- In a democracy, it is essential that our government be open and honest with the public.  Instead, the DNR and EPA continue to use dishonest and deliberately misleading words to describe their choices.  We have repeatedly criticized their use of the term "Natural Recovery"  (see Natural Recovery).   Another dishonesty is the use of "Vitrification" or "Melter" in place of the more accurate and descriptive term "Incinerator."  The terms vitrification and melter imply that the sediments will be melted and conserved as an entire mass - turned to stone, complete and whole.

The true process dries the sediments then burns them in a high temperature furnace.   All the organic matter and PCBs are burned off.  The residue is a melted slag, but much of the sediment mass is burned away, not conserved.   The drying and burning processes will unavoidably create new toxic air pollution in the Fox River Valley.  The public would understand this immediately if the term "Incinerator" were used, so the EPA and DNR are deliberately misleading the public with the terms "Vitrification" or "Melting" which imply something else. 

We saw the same public manipulation several years ago, when the Minergy Incinerator was built in downtown Neenah.  They called it a "glass aggregate plant," which sounded fairly innocuous to the public.  Too late, the public realized they were getting a large new air pollution source and paper sludge Incinerator.  At the beginning, the company promised to use only clean-burning Natural Gas to fire their furnaces, then three years later switched to dirty coal despite public opposition.

Minergy is the same company which now wants to build a "Melter" for Fox River sediments.  If they can't be honest in their choice of words, how can we trust them to run a clean incinerator?  (Sierra Club, are you listening?)  The news media should not allow this deception to continue.

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