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The Clean Water Action Council expressed both relief and concern over today’s announcement of an interim $50 million settlement with P.H. Glatfelter’s Company and Wisconsin Tissue Mills to pay for PCB-contaminated sediment cleanup in Little Lake Butte des Morts, at the head of the Lower Fox River in Northeast Wisconsin.
 

“We’re relieved that funds are being provided without a legal battle, and that the Lake cleanup may be more rapid than previously thought,” stated Rebecca Katers, Executive Director of Clean Water Action Council. The project on Little Lake Butte des Morts may require only 2-3 years (to start next summer), rather than the 7 years originally projected. “On the other hand, we’re very concerned that the cleanup standard is too weak and will not provide even minimal public health and wildlife protection downstream,” added Katers.  The Lake project would require the companies to dredge down only to a 1 ppm PCB cleanup target, when the U.S. Environmental Protection Agency and Wisconsin Dept. of Natural Resources both have acknowledged that 0.25 ppm PCB target is the “most cost-effective PCB action level that meets protective thresholds.”  Local fish will still be unsafe to eat, even after the “cleanup.”   If they were to dig just a little deeper and wider in each hotspot, the fish consumption warnings could be lifted decades earlier.   Removal of more PCBs would also prevent PCBs from escaping downstream in the future to continually contaminate the lower river and Green Bay.

Little Lake Butte des Morts in 1970, with Neenah at the  bottom (south) and Appleton at the top (north).  The pollution from P.H. Glatfelter (Bergstrom Paper at  the time) is clearly visible originating in the lower  right-hand corner, and the Wisconsin Tissue Mills  discharge is visible in the middle right-hand area  of the flowage. (Photo from the Carl Guell Slide  Collection at the Geography Dept.,UW- Oshkosh.)

The agencies are misleading the public when they claim their project will achieve a 0.25 ppm AVERAGE concentration of PCBs on the surface of the sediment. 

This means hotspots of 10 ppm or more could be left behind, as long as statistical averages over the entire lake can be achieved.   And that 10 ppm could extend several feet deep (including hundreds of pounds of PCBs) without affecting the Lake's average SURFACE concentration. 

“This is the wrong way to measure the cleanup’s effectiveness.  The cleanup should eliminate the MASS of PCBs, not focus on a temporary surface concentration.  That surface could erode downstream tomorrow.  What matters is the total amount of PCBs remaining in sediment pockets which will continue to erode downstream for years into the future.  The cleanup should remove each entire PCB pocket (even 10 feet deep), to eliminate potential for future erosion and recontamination downstream.  This means dredging down to remove all sediments with concentrations higher than 0.25, not just achieving a 0.25 ppm “average.”) 

“Keep in mind that our recommended 0.25 ppm PCB cleanup target is already a compromise that does not achieve full public health protection - but at least it would allow fish consumption advisories to be lifted, at a minimum,” added Katers.  (The governments' so-called "safe" level of fish consumption still allows considerable health risks.)

Another serious concern is the governments’ approval to cap PCB contaminated sediments in place with sand and gravel, if it is deemed less expensive during the design phase. 

“A cap would be just a temporary fix, leaving the PCBs for our grandchildren to clean up in the future.  It would set a terrible precedent,” concluded Katers.  “Wisconsin rivers should not be used as permanent toxic dumps by private corporations.”

• EPA, WDNR and Two Paper Mills Sign Agreement for $60 Million Cleanup at Fox River Site - Oct 1, 2003 US Newswire
• Paper companies to cleanup PCBs - Oct 1, 2003 PC

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