Alison Hess/Doug Tomchuk
Hudson River PCBs Public Comment
US Environmental Protection Agency
290 Broadway, 19th floor
New York, NY  10007-1866

Dear Ms. Hess and Mr. Tomchuk,

Please introduce yourself here:

Support for Proposed Remedy:
	I strongly support EPA's proposed plan to remove PCB-contaminated sediment from targeted 'hotspots' in the Upper Hudson River, as outlined in Alternative #4 of the Proposed Plan for the Hudson River Superfund Site. This alternative removes PCBs using environmental dredging techniques in conjunction with source control at the GE Hudson Falls plant.
OR
	I strongly support removing PCB-contaminated sediment from targeted 'hotspots' in the Upper Hudson River. While I support the EPA's Proposed Plan, I would prefer the more comprehensive option outlined in Alternative #5 of the Proposed Plan for the Hudson River Superfund Site. This more rigorous approach removes the largest amount of PCBs, using environmental dredging techniques in conjunction with source control at the GE Hudson Falls plant.
Human Health Effects and Environmental Impacts:
	PCBs remain an unacceptable health risk for residents and wildlife in the Hudson Valley. PCBs are designated as probable carcinogens and are known to cause neurological, reproductive, and endocrine disorders. Other long-term health effects of PCBs include reduced ability to fight infections, low birth weights, and learning problems. Despite health advisories, subsistence fishermen and their families along the entire length of the river continue to eat their catch.
	Regular consumers of fish face an estimated increased risk of one additional case of cancer per 1,000 persons exposed. This excess cancer risk is 1,000 times higher than the EPA's goal of protection and ten times higher than the highest risk allowed under Superfund law. For non-cancer health effects, regular consumers of fish face an exposure over a hundred times higher than acceptable EPA standards.
	Recent research also links PCBs to diabetes and heart disease. Dr. David Carpenter (School of Public Health, University at Albany) and other scientists offer compelling evidence that PCBs can cause learning disorders and dampening of intelligence.
	Birds and mammals that eat PCB-contaminated fish from the Hudson River, such as the bald eagle, belted kingfisher, great blue heron, mink, and river otter, are at risk. PCB's may adversely affect the survival, growth, and reproduction of these species. Piscivorous fish, such as the largemouth bass and striped bass, in the Hudson River are at risk at the individual level.
Dredging:
	GE claims the river is 'cleaning itself' of PCBs. However, scientific studies have shown that less than 10% of the PCB mass has been reduced by dechlorination over the past twenty years. These less chlorinated PCBs are still toxic and are more mobile. Studies have also found that PCBs are not being universally buried and often remain in the top nine inches of sediment.
	Five hundred pounds of PCBs flow over the Federal Dam in Troy each year and disperse down river. Without remediation, these PCBs will continue to move throughout our environment. Chemical 'fingerprinting' of PCBs shows that Hudson Valley PCBs have spread as far away as the Canadian Arctic.
	Environmental dredging, particularly hydraulic dredging (removal by vacuum suction), must be clearly distinguished from the less contained methods used for navigation and construction. Modern environmental dredging equipment, like the cutterhead dredge and the eddy pump, is designed to prevent resuspension of contaminated sediments.
	Because suction removal is the most efficient and cost-effective technology for preventing resuspension of contaminants, EPA should specify hydraulic dredging. Sealed clam-shell dredges should be avoided wherever possible.
	While I have great confidence in hydraulic dredging, EPA must ensure adequate contingency planning for towns that take their drinking water from the river, including Waterford, Rhinebeck, Port Ewen, Poughkeepsie, Highland, and the Chelsea intake to NYC's supplemental water supply.
Disposal vs. treatment options
	I support dewatering, stabilization, and transport by rail to existing hazardous waste landfills. I support the EPA's decision not to landfill removed sediment in Hudson Valley or use any farmland for disposal or processing.
	I request that the final remediation process utilize a fully enclosed system for dredging, storage, treatment and transportation of PCBs. This will contain any PCBs that may evaporate and prevent atmospheric transport.
	I request that EPA further evaluate treatment technologies, with the goal of detoxifying or destroying PCB contamination rather than landfilling them in communities outside the Hudson Valley.
	I support EPA's plan to backfill dredged areas and support extensive biological restoration to minimize ecological effects in remediated areas.
Economic impacts
	The estimated $460 million dollar remediation will significantly enhance the local economy. Ultimately, commercial and recreational fisheries will be restored. Once the PCBs have been removed from the upper layers of sediment, the river will be safe to dredge for navigational purposes. Both commerce and tourism will be enhanced.
	NY State has numerous examples of successful dredging projects, such as those in Plattsburgh and Croton-on-Hudson. These areas now enjoy a cleaner environment and health risks have been significantly reduced.
	Unfortunately, in its fight to avoid dredging, GE is missing an important economic opportunity. If it developed its own dredging capability, it could provide cost-effective service to the Upper Hudson and to many of the 75 other Superfund sites for which it is responsible. This infrastructure and expertise could then be exported to remediate toxic sediments from hazardous waste sites around the globe.
Remediation Schedule
	EPA should keep to its revised schedule and release its final Record of Decision in August 2001, so that remediation can proceed without any further delays.

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