1999 GREAT LAKES WATER QUALITY FORUM
SEPTEMBER 24-26, 1999
LIGHTLY EDITED, VERBATIM TRANSCRIPT
SATURDAY MORNING, SEPTEMBER 25
QUESTIONS AND DISCUSSION
Rebecca Caters, Clean Water Action Council, Green Bay, Wisconsin
Our organization is very concerned about the definition of how clean is clean enough. We heard a lot of talk about activities, dredging contaminated sediments all throughout the Great Lakes. It's great to see something happening, but we're concerned about the end point that you are aiming for. We have been alarmed that at least two proposals we have seen for the Sheboygan River and for the Fox River in northeast Wisconsin, neither proposal proposes to fully clean up the system to be fully protective of public health and wildlife. There is an open acknowledgment by EPA at the Sheboygan site that subsistence fishers would not be protected by the clean-up standard, that it is not fully protective. On the Fox River side the state's plan still allows subsistence fishers to be at risk. In my experience over the last many years, there has been a real backslide in the standards set. It used to be a one in a million risk and a much more aggressive target, but now it slid down to maybe one in 10 thousand risk and only protecting sport fishermen, not the low-income subsistence fishers that fully depend on the Great Lakes for their food and water. In our situation we have both waterfowl contamination and fish contamination. Some people are dependent on those sources for food. We need to have clean-up plans that are fully protective. Is that going to be re-emphasized in coming years or is this partial clean-up standard going to prevail?
Let me start and I will turn it over to Frank. It's a tough question. How clean is clean? On the Fox River, we have come to the recommendation in the remedial investigation and feasibility study. I think it's 250 parts per billion is the recommended average clean-up level. You are correct. It doesn't totally remove all the fish contaminant advisories. It takes us to a level where a citizen in their lifetime could average 200 meals of walleye a year and still be able to do so within the fish contaminant advisories. It's a question of how far we can go with the amount of money. I think that we estimate that clean-up level, depending on technology, will cost between $200 million to $1.3 billion. There is a level in there, in fact, I think we are going to be faced with that in the remedial investigation and feasibility study is, comparing it to other clean-up levels and we all as governments need to make sure that we have the justifications for the variance and levels of clean-up. To my knowledge that is the one we are proposing and the Fox River is probably the most restrictive that has been proposed.
We've had active discussions with EPA in Sheboygan where there is a less restrictive proposal. These things can vary by site. There can very well be justifications for different numbers, but what we need to make sure is that we do that into account and be able to explain it to the public, of what is a rational decision in each site, so we don't want to undermine potential for other clean-ups in other areas. We are having it, and to the credit of Region 5 EPA, when we brought this issue to our attention, our concern about Sheboygan vis-à-vis impacting in the Fox River, we brought together large teams of staff from both agencies to try to resolve that issue, so we can come forward with numbers that are protective as possible for our citizens and still can be explained.
I forgot add one portion of the question. It's not simply, How clean is clean enough, but also over what timeline? We are concerned that these plans have used time as one of the treatment methods and dispersion and averaging of levels. I know on the Fox River, one of the discussions is that we are going to look for an average sediment contamination level of such and such. Well, averaged over how deep, how wide an area, how much time. We would prefer to see a much more aggressive effort taking much more of the material out so that the total loading to Green Bay is minimized, not just averaged and dispersed.
Okay, well, just to put it in context, I think we are talking about a removal of 80 or 90% of the PCBs so I think that we are not minimizing, that we are not going to get it all no matter how much money we have, but we are trying to get a great amount. I think we are going to be basing our time frame on our technologically feasible way of getting it done. We think that it will take 8 to 10 years of dredging. If we can get it done faster, and our studies shows it may happen, we'd be glad to do so. We are not limiting the time frame for clean-up based on cost. We are basing it on just being able to get the machinery in place and doing it. How many dredges we use one, two, three dredges or whatever. We are talking about a length or period of time, but surely we are not using a time factor as limiting the amount clean-up.
Can I give you a Canadian perspective on how clean is clean. Quite clearly, there are a couple of things that come to my mind. One is the Great Lakes Water Quality Agreement. The virtual elimination of those toxic substances that are bioaccumulating and are persistent, those that we have identified. The second comment I'd make is that we mention in the new CEPA, that just went through the Canadian legislation, and it identifies substances or, if substances identified through the assessment as toxic, as persistent and bioaccumulative, then it is also on a virtual elimination track. That legislation calls for action plans to move us towards that goal. So how clean is clean? It is the virtual elimination of those mega uglies.
I've been told by the IJC Commissioners that we should inform those that are in line as of right now that we will address your questions. We wouldn't accept anymore questions in this forum from anyone else joining the line after this point. We will have after this session an availability session in Room 101C for anybody who didn't get a chance to ask a question today. We'll be in Room 101C. Those who are currently standing, we will take your questions and then we will have to cut it off after that point.