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BROWN COUNTY
GREEN BAY
Congressional District # 6, 8
FOX RIVER NRDA/PCB RELEASES
EPA ID# WI0001954841Last Updated: November, 2009
Site Description
The Lower Fox River and Green Bay Site includes a 39-mile stretch of the Lower Fox River as well as the bay of Green Bay. The river portion of the site extends from the outlet of Lake Winnebago and continues downstream to the mouth of the river at Green Bay, Wisconsin. The bay portion of the site includes all of Green Bay from the city of Green Bay to the point where Green Bay enters Lake Michigan. The site has been divided into five discrete operable units (OUs) by the Wisconsin Department of Natural Resources (WDNR) and the United States Environmental Protection Agency (EPA). An OU is a geographical area designated for the purpose of analyzing and implementing remedial actions and is defined on the basis of similar features and characteristics (e.g., physical and geographic properties). The river and the bay operable units are:
• OU 1 – Little Lake Butte des Morts
• OU 2 – Appleton to Little Rapids
• OU 3 – Little Rapids to De Pere
• OU 4 – De Pere to Green Bay
• OU 5 – Green Bay
Site Responsibility
The site is being addressed through federal, state and potentially responsible parties' actions.Threats and Contaminants
The site is contaminated with polychlorinated biphenyls (PCBs), a hazardous substance and probable human carcinogen. It has been estimated that the 14 million cubic yards of contaminated river sediments contain more than 65,000 pounds of PCBs, and at least several hundred million cubic yards of sediments in Green Bay are contaminated with as much as 150,000 pounds of PCBs. Because fish and wildlife are contaminated with PCBs, people who eat contaminated fish or waterfowl may suffer adverse health effects. Fish consumption advisories for the site were first issued in 1976 and 1977 by WDNR and the state of Michigan, respectively. The advisories are still in effect. Adverse impacts to wildlife have also been documented.
Cleanup Progress
In 1989/90, EPA and WDNR began sediment and water sampling in the Lower Fox River and Green Bay for use in the Green Bay Mass Balance Study (GBMBS). The GBMBS was a pilot project to test the feasibility of using a mass balance approach for assessing the sources and fates of toxic pollutants, spreading throughout the food chain. Key subsequent evaluations were the remedial investigation and feasibility study, conducted by WDNR with funding by EPA. Based on these evaluations, a proposed plan for site cleanup was issued by EPA and WDNR on October 5, 2001.
In addition to site investigations, two dredging demonstration projects were conducted on the Fox River.
- In 1998 and 1999, WDNR and EPA sponsored a project to remove PCB-contaminated sediment from Deposits N and O located in OU 1, in the Lower Fox River about 31 miles upstream from Green Bay. This project successfully demonstrated that dredging of PCB-contaminated sediment could be performed in an environmentally-safe and cost-effective manner. The project also provided for the opportunity for public outreach and education of environmental dredging as well as removal of PCBs from the river. Approximately 8,200 cy of PCB-contaminated sediment, containing 112 pounds of PCBs, was removed from the river.
- In 1999 and 2000, a dredging project at SMU 56/57 also removed 80,000 cubic yards of PCB-contaminated sediments, containing 3,400 pounds of PCBs. This deposit is located in OU 4 about 3 miles upstream from the mouth of the Fox River. This project began in 1999 by the Fox River Group as a demonstration project. The project was completed in 2000 by Fort James Corporation with EPA oversight. Similar to Deposit N, this project demonstrated that dredging could effectively remove PCB- contaminated sediments at the Fox River in an environmentally-sensitive and cost-effective manner.
After consideration of public comments on the proposed plan, two Records of Decision (RODs) for the Fox River and Green Bay were finalized by EPA and WDNR in December 2002 and July 2003. These decisions were as follows:
• OU 1 (at the upstream/southerly end of the Lower Fox River): dredging and disposal of approximately 800,000 cubic yards of PCB-contaminated sediments with concentrations above 1 ppm.
• OU 2: monitored natural recovery.
• OU 3 and 4 (the most downstream / northerly end of the Lower Fox River): dredging and disposal of approximately 6.5 million cubic yards of PCB-contaminated sediment with concentrations above 1 ppm.
• OU 5 (Green Bay): limited dredging and monitored natural recovery.
• Total costs were estimated to be $400 million.
Both RODs contained a contingent remedy for the capping of contaminated sediment subject to approval by EPA and WDNR and only under certain circumstances. In addition to issuing the two RODs for the site, EPA negotiated or issued remediation-related legal agreements or orders as summarized in the following table:
| Legal vehicle | Date of Entry or Signature | Settlers or Respondents | Scope |
| Administrative Order on Consent | May 26, 2000 | Ft. James Corporation and Fort James Operating Company | SMU 56/57 remediation |
| Judicial Consent Decree | December 10, 2001 | Appleton Papers Inc. (API) and NCR Corp. | Funding of $41,500,000 for past costs and Fox River Projects |
| Administrative Order on Consent | July 1, 2003 | WTM I Company (formerly Wisconsin Tissue) | OU 1 Design |
| Judicial Consent Decree | April 12, 2004 | P.H. Glatfelter Co.and WTM I Company | OU 1 remediation |
| Administrative Order on Consent | March 5, 2004 | Fort James Operating Company and NCR Corporation |
OU 2 - 5 Design |
| Judicial Consent Decree | November 3, 2006 | NCR Corporation and Sonoco-U.S. Mills, Inc. | "Phase 1" remediation |
| Unilateral Administrative Order | November 13, 2007 | Appleton Papers, Inc., CBC Coating Inc., Georgia Pacific Consumer Products, LP, Menasha Corp., P.H. Glatfelter Co., U.S. Paper Mills Corp., WTMI | OU 2 - 5 remediation |
Implementation of these agreements resulted in design planning beginning July 1, 2003, for OU 1 and March 3, 2004, for OU 2-5.
Dredging and disposal of contaminated sediments in OU1 began in September 2004. Dredging in OU1 was completed on June 25, 2008, and final capping and sand covering work was concluded on May 19, 2009. Approximately 370,000 cubic yards of PCB-contaminated sediments (and about 1900 pounds of PCBs) were removed from OU1 and disposed off-site, and about 215 acres were capped or covered.
During 2007, approximately 130,000 cubic yards of PCB-contaminated sediment were dredged from a newly-identified hotspot just downstream of the DePere Dam and disposed at an off-site landfill. This initial phase of the cleanup for PCB contamination in OU 2 - 5 removed contaminated sediments with PCB concentrations as high as 3000 ppm. Final remedial activities for this area will be completed by 2011, once the rest of site cleanup activities have progressed downstream to this area.
On June 26, 2007, EPA issued a ROD Amendment that modified the original decision for OU 2 - 5 from dredging 7.1 million cubic yards and capping 500,000 cubic yards, to dredging 3.5 million cubic yards and placing an engineered cap or sand cover over 3.7 million cubic yards of PCB-contaminated sediment. This modified approach is comparably protective to the original decision, but will be completed sooner and at less cost. The current cost estimate for the revised remedy is $650 million (in 2008 dollars).
On June 12, 2008, EPA issued a final ROD Amendment that modified the original decision for OU 1 remediation from an all-dredging remedy to a combination of dredging, capping and covering. Similar to the decision for the OU 2 - 5 remedy, this modified approach for OU 1 is comparably protective and resulted in the OU1 remedy being completed sooner and at less cost than that required for an all-dredging remedy. Costs were just under $100 million for the revised remedy versus $144 million estimated for the previously planned remedy.
Full-scale cleanup work in OU 2 - 5 began on April 28, 2009. During 2009, more than 500,000 cubic yards of PCB-contaminated sediment were dredged and disposed at off-site landfills, about 15% more than original 2009 removal goals. Additionally, capping and covering work began in August 2009, with about 50 acres capped or covered. Weather permitting, capping, covering and dredging operations will resume on April 5, 2010. OU 2- 5 cleanup operations are expected to be completed by 2017, and except for long-term monitoring, will finalize all site cleanup activities.
EPA completed a five-year review for the site on July 17, 2009, to evaluate the protectiveness of the remedy. The review concluded that the remedial actions being implemented at the site are expected to be protective after they are completed (anticipated by 2017), but that it may take some additional time after completion of the remedy for fish tissue concentrations to decrease. Another five-year review will be completed by July 2014.
Success Story
This project is the largest environmental sediment cleanup ever undertaken. To date, this project has removed (i.e., dredged) more than 1 million cubic yards, and capped or covered about 265 acres. Site cleanup is expected to be completed by 2017, and will remove or contain a total of 8 million cubic yards of PCB-contaminated sediments, with about half of the sediments dredged and half capped or covered. This cleanup has been a collaborative effort, with WDNR and EPA working cooperatively with the companies conducting the cleanup in reducing risks from the PCB contamination in a protective and cost effective manner.
Contacts
Remedial Project Manager, U.S. EPAjames hahnenberg (hahnenberg.james@epa.gov)
(312) 353-4213
Community Involvement Coordinator, U.S. EPA
susan pastor
(312) 353-1325
Aliases
FOX RIVER NRDAFOX RIVER/LOWER GREENBAY 39 STREM MILES
/PCB RELEASES