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Point/Counterpoint

Setting the Record Straight on the Lower Fox River

Point: PCBs do not pose a serious human or ecological health threat.

Counterpoint:

Five separate studies, two involving consumption of Great Lakes fish, have demonstrated that maternal exposures to PCBs have been linked with neurological impairments (i.e. mental acuity/IQ, short-term and long-term memory, impaired responsiveness) in infants and children. Studies on monkeys exposed to PCBs have found similar neurological results as well as adverse reproductive effects.

Increased cancer mortality (i.e., liver) have been reported in workers exposed to PCBs. In the general population, one study found that the chances of getting cancer (Non-Hodgkin’s lymphoma) significantly increased with PCB exposure, which occurs primarily through the diet. PCBs are known animal carcinogens. EPA and the World Health Organization have classified PCBs as probable human carcinogens.

Changes to the immune system have also been reported from PCB dietary exposures.

In the Great Lakes environment (i.e., Green Bay), PCBs are associated with reproductive impacts (i.e., reduced fertility) and birth defects in fish-eating birds and other wildlife.

Point: PCB levels in the Lower Fox River and Green Bay are not hazardous and are rapidly declining.

Counterpoint:

Due to PCB contamination and human health concerns, fish consumption advisories have been in-place for the Lower Fox River and Green Bay since 1976. Some species and sizes of fish (i.e., large walleye, crappie, small mouth bass, and channel catfish) are not to be consumed at all or only a few meals per year. Unfortunately, not all residents fishing the Lower Fox or Green Bay follow the fish advisories.

PCB levels in Lower Fox River and Green Bay fish are declining very slowly or not at all. PCB levels may be dropping by 50% in some fish every 10-30 years. At these rates of decline, which are very optimistic, it would take from 50 to more than 100 years for fish to be eaten without restrictions.

Very recent evaluations of some Great Lakes’ fish show that PCB levels may no longer be declining.

PCB water levels at the mouth of the Lower Fox River have not declined from 1989 to 1995 and are from 100 to 10,000 times greater than safe levels set by the State to protect human and ecological health.

Point: Superfund designation will halt all cooperative clean-up efforts, harm the Fox Valley’s image, and have calamitous implications for the economy of the Fox River Valley.

Counterpoint:

More than five years of cooperative efforts have not led to the removal of any PCBs from the river and the governments still have no commitment from responsible parties to prepare or undertake a comprehensive clean-up plan.

The governmental parties remain open to any serious proposals for a negotiated resolution, and Superfund designation does not create a bar to further negotiations.

PCB contamination in the Lower Fox has been widely recognized by the public for decades. Superfund designation would not alter the public’s recognition of this already well-known problem.

EPA has created certain policies to relieve situations in which a party’s potential Superfund liability exceeds that party’s means and to specifically avoid business closures.

Point: An expensive clean-up remedy, such as dredging, will have detrimental impacts on the local economy -- lost jobs, mill closings, reluctance of new industry to move in, etc.

Counterpoint:

The flip side -- a clean, fishable, river -- would be a great boost to the local economy by supporting more fishing, boating, and recreation.

Examples exist under the Superfund program where the clean-up action itself created local economic benefits above and beyond those associated with the restoration of the natural resource. A good example is the Bayou Fon Fouca Superfund site in Louisiana, where 80% of the personnel employed were hired locally.

Reports of $3 billion for remedies such as dredging with incineration are greatly inflated. Moreover, the intergovernmental partners have not determined that dredging is necessarily the best clean-up alternative.

Point: One possible clean-up technology, dredging, will result in the resuspension of PCBs, allowing fish to be in greater contact with the chemicals than they would have been if PCBs were allowed to remain in sediment.

Counterpoint:

Navigational dredging, which typically causes large quantities of sediments to be released, should not be confused with environmental dredging used for removing PCBs in sediment.

New technologies for environmental dredging have greatly improved upon the dredging of years past, particularly with respect to pump design, and if necessary, containment of the dredging area.

Other environmental dredging projects have shown that resuspension during dredging is minimal. For example, at the Manistique River/Harbor and Ford Monroe projects, monitoring during dredging demonstrate minimal release of contamination. Other sediment removal projects (i.e., Waukegan Harbor, Illinois) have shown that PCB levels in fish and wildlife decreased five fold a year after dredging.

Point: EPA proposes to hold the Lower Fox River to a higher standard of cleanup than other PCB sites -- areas of the Lower Fox slated for cleanup currently have concentrations of PCBs lower than levels left after cleanup at other midwest sites.

Counterpoint:

Every site is evaluated on its potential for risks to human health and the environment. Many variables are considered in determining a clean-up level for any particular site.

No clean-up level has yet been determined for the Lower Fox River. This will be part of the evaluation now underway by Wisconsin DNR and EPA.

Nevertheless, contamination of PCBs in the Lower Fox is so widespread that the average concentration of PCBs over the length of the river is unacceptably high relative to other PCB clean-up sites and PCBs, even in low concentrations, remain available to be absorbed by fish. This may mean that a more restrictive clean-up level may be necessary than at some other sediment sites.

Point: EPA is applying a "double standard" to the Lower Fox; i.e., while EPA has made a decision to delay release of a report that calls for dredging on New York’s Hudson River pending scientific peer review, EPA plans to move forward with "a massive dredging project" on the Lower Fox River.

Counterpoint:

The Hudson River and Lower Fox River are very different rivers and the clean-up projects are at very different stages.

EPA was nearing a decision on a remedy to address Hudson River contamination when it paused to allow peer review, whereas EPA and the State of Wisconsin are just beginning a process to systematically identify and evaluate the universe of alternatives (including dredging) appropriate for the clean-up of the Lower Fox.

The decision to conduct additional scientific review is unique to the Hudson River. The Lower Fox River is one of the most studied rivers in North America. EPA and the State of Wisconsin have spent 20 million dollars conducting a state-of-the-art PCB study which identified the Lower Fox River as an immediate threat to Green Bay and Lake Michigan by the release of 600 pounds per year of PCBs.

EPA has not determined what the best approach to cleanup will be for the Lower Fox River, or whether and to what extent the approach will involve dredging.

Point: EPA has implemented other remedies at other sites because of fears of large contaminant releases during dredging.

Counterpoint:

EPA has implemented different alternatives for different sites. EPA does not use a "one size fits all" approach to addressing contamination.

EPA does not generally fear large releases of contaminants during dredging projects. With proper design and competent implementation, EPA clean-up experiences makes it clear that dredging can be implemented with minimal short-term adverse impacts.

Reports that EPA officials will use clay-coated pellets to cover PCB-contaminated sediment in the Ottawa River, Ohio, instead of dredging are incorrect -- while EPA has some involvement in a sediment remediation project on the Ottawa River involving dry excavation (a type of dredging), EPA is not involved in the demonstration project on that river employing the clay-pellets. The use of clay-pellets is an experimental sediment remediation technique which has not had wide application or long-term test results.

In March, 1998, USX Corporation (formally U.S. Steel Corp.), with support of EPA, proposed to remove and contain 687,000 cubic yards of contaminated sediments from five miles of the Grand Calumet River in Gary, Indiana. These sediments, contaminated with PCBs, oils and metals, will be removed using hydraulic (suction) dredging.


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