|
REMEDIAL ACTION PLAN SCIENCE & TECHNICAL ADVISORY COMMITTEE c/o DNR, P.O. Box 10448, Green Bay, WI 54307-0448 March 15, 2000 Mr. Greg Hill, WR/2
RE: Site 56/57 Lower Fox River Demonstration Project Dear Mr. Hill: As you are aware, the Science & Technical Advisory Committee (STAC) of the Lower Fox River And Green Bay Remedial Action Plan (RAP) has been actively involved with assessment and planning of remediation activities on the Lower Fox River for more than a decade. We have watched closely the planning process for the Site 56/57 demonstration project as proposed by the Fox River Group (FRG). We have previously submitted comments to Mr. Robert Paulson of the Department of Natural Resources (DNR) concerning the monitoring plan for the project. Based on the information available, we supported moving forward with the demonstration project, though we expressed a number of concerns regarding how the data generated by the project would be interpreted. The STAC met yesterday to review information currently available regarding the Site 56/57 demonstration project. In the interest of brevity and timeliness, we wish to submit the following comments.
"We find it completely unacceptable for the demonstration project to remain unfinished. Completion of the project represents the only environmentally sound and ethically appropriate solution to the problem." - STAC  1.) In spite of the importance of this project, and the extensive planning effort involved, we find it difficult to believe that only 30,000 of the originally identified 80,000 cubic yards sediment were removed during the dredging project prior to ceasing activities for the winter. The original project time frame, as identified by the FRG, called for completion of dredging and processing of all sediment by the end of November. 2.) We are very concerned that the reported PCB concentrations remaining at the surface of the sediment management units that were only partially dredged are extremely high, up to 280 ppm. If our information is correct, this area now exhibits the highest concentration of surficial sediments in the entire river system. These concentrations, if left in the river, represent a substantial increase in the potential environmental risk to the biota of the lower Fox River and Green Bay. Expected spring river flows, even in a dry year such as this, can be expected to resuspend these bottom sediments into the water column, making them available for accumulation by algae and other organisms in the food chain, and ultimately in humans. This is not the case where dredging was conducted to the planned depth; only where dredging was left incomplete. 3.) Based on available data, we concur with the DNR’s conclusion that, where properly performed to the necessary sediment depth, dredging has been demonstrated at Site 56/57 to be a viable option for removal of PCB contaminated sediments. If the project had been completed as originally designed, all data currently available indicate that the previously identified mass of PCBs would have been safely removed, and the residual sediment surface concentrations would be within acceptable levels. 4.) The STAC strongly recommends that the demonstration project be completed as quickly as possible. To leave the site in its current condition invites an unacceptable level of environmental risk. We strongly encourage the appropriate parties to focus their joint resources on remediating this significant problem. 5.) Should a voluntary agreement for project completion not be forthcoming, we would then recommend that legal proceedings be initiated, either by the DNR or the EPA, to ensure completion of the project as quickly as possible. 6.) Finally, we recommend that environmental monitoring be initiated immediately, to document the downstream transport of PCBs from this area of high PCB contamination. In summary, we find it completely unacceptable for the demonstration project to remain unfinished. Completion of the project represents the only environmentally sound and ethically appropriate solution to the problem. Swift action by the FRG to resolve this situation would undoubtedly have a positive impact on public credibility. We may submit additional comments after we receive and review additional project summary data. We felt it necessary to voice our concerns immediately, so that they may be included as negotiations between the DNR and the FRG proceed. Thank you for the opportunity to provide these comments. Please don’t hesitate to contact myself or any STAC member if you have any questions or require additional information. Sincerely, John Kennedy
cc: George Meyer, DNR Maureen Katz, USDOJ
|