Public Comments on EPA´s Preferred Remedy
for Hudson River PCB Superfund Site
Congratulations to the EPA
by Manna Jo Greene, Environmental Director
Hudson River Sloop Clearwater
On behalf of Hudson River Sloop Clearwater I want to congratulate the
EPA on its proposed plan to actively remove PCB-contaminated sediment
contained in the concentrated hotspots located in the upper Hudson
River. Clearwater, along with many other environmental groups in Hudson
Valley, supports a rigorous remediation which minimizes impacts on river
ecology and human health.
General Electric has perpetuated the misleading notion that if left
alone the Hudson River will somehow clean itself. This has not
happened in the past 50 years, nor in the last 23 since PCBs were banned
in 1977. PCBs are persistent. 1.5 to 3 pounds migrate into the river
from the concentrated sediments in the Thompson Island pool every day.
To break the toxic cycle of bioaccumulation, evaporation and atmospheric
transport, the PCBs must be carefully removed using environmental
dredging techniques, and treated, or at least safely contained.
Environmental dredging is primarily hydraulic dredging (removal by
vacuum suction). This 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. While we have great confidence in this method of PCB
removal, Clearwater also wants to be certain that there is adequate
contingency planning for towns such as Waterford and Poughkeepsie, which
take their drinking water from the river.
GE claims the river is "cleaning itself up", however the truth is that
PCBs are continuously being dispersed into the environment, moving
downriver, out to the ocean, and into the biosphere. A very small
percentage of heavily chlorinated PCB molecules are transformed by
bacterial activity slowly over time to less chlorinated forms, which are
still toxic, but are more mobile. Dilution is clearly not the solution
to pollution! Remediation is.
Tonight I would like to enter into the public record Clearwater's video,
"The Hudson River PCB Story: A Toxic Heritage," which documents
environmental and human health impacts of PCBs. In addition to PCBs
being listed as probable carcinogens, they are known to cause hormonal
disturbances and neurologic disorders. Dr. David Carpenter offers
documentation of PCBs causing learning disorders and dampening of
intelligence.
John Peterson Myers, author of Our Stolen Future, is an authority on
endocrine disruptions which are caused by PCBs. Myers offers a
compelling argument for removing PCBs and breaking the chain of toxicity
they create. He says, "I have come to believe that some of the basic
ground rules by which new chemicals and their derivative products are
developed, tested, and brought to market, need new examination if we are
really serious about creating a world in which babies can grow up toxic
free, in which babies can grow up in ways that allow them to explore
their full potential. As laws and commerce work today, too much of the
real testing of chemicals takes place in the real world. It takes place
in our bodies, in our children's bodies, and in the global ecosystem...
The scientist and the father in me argues that we should take care
of this problem now, so that our kids can focus on all those other
problems, all those other challenges, they are faced with as they grow
up."
Clearwater's Executive Director, Andy Mele notes, "It all comes down to
human potential. As long as there are PCBs in the Hudson River, and as
long as there are chemicals anywhere in the environment interfering with
our hormones and our brains, we are the losers. We may never know what
we might have been, what we might have become, what we might have
accomplished, or how our children might have fulfilled their dreams had
we lived in a world free of these chemicals."
Most people in the Hudson Valley have not been persuaded by GE's
intentionally misleading multimillion dollar advertising campaign.
Ultimately GE needs to take responsibility for the problem it created,
and dedicate its vast resources to actively cleaning up the river,
rather than trying to sway public opinion with spurious advertising, and
delaying remediation by endless lawsuits. Unfortunately, in its ardor
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 presently responsible. This
infrastructure and expertise could then be exported to remediate toxic
sediments from hazardous waste sites around the globe.
The planned remediation is a contained process. It will not change any
of the activities on the river. People will still be able to boat, swim
and fish (and to return their catch in which PCBs have bioaccumulated to
the river). Towns that take their drinking water from the river will be
able to continue to do so. 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.
We look forward to reviewing the details of this proposal and thank the
EPA for its courageous position in taking a strong stand for human
health and a clean environment. With the implementation of this plan we
will be well on our way to restoring the full integrity of the Hudson
River.
PCBs Should Be Classified As A Known Human Carcinogen
Comments to US EPA by
Gerhard Randers-Pehrson
December 14, 2000
Throughout the documentation that has been produced in preparation for
this proposed plan, there are many references to the toxicity of PCBs.
Whenever the government speaks, they carefully say that PCBs are
"probable human carcinogens." Environmentalists are more likely say
that PCBs are carcinogenic; believing that animal model proof is
sufficient. General Electric will always say something to the effect
that "there is no credible evidence that PCB exposure causes disease in
people." The lynchpin of the GE statement is the study "Mortality in
Male and Female Capacitor Workers Exposed to Polychlorinated Biphenyls"
conducted by Renate D. Kimbrough, MD and others published in March 1999.
Let me quote from the Kimbrough paper descriptions of study design: "All
hourly and salaried workers employed for at least 90 days between
January 1, 1946, and June 15, 1977, in two capacitor manufacturing
plants in upstate New York were included in the cohort." The cohort was
divided also into male and female, yielding four groups for study. The
experimenters managed to locate 98.7% of these 7076 people.
Quoting again from Kimbrough: "The purpose of this study was to further
explore previously reported excesses in cancer-specific mortality in
capacitor workers exposed to PCBs. Six a priori cancers that were
previously reported as being elevated were the primary focus of this
study (melanoma, liver, rectum, gastrointestinal tract, brain and
hematopoietic cancers)." Note that it is normal to have a particular
organ listed in two places in a study: the rectum is a possible cancer
site, but it is also part of the GI tract which groups together the
stomach, intestine and rectum.
Now given this design, I would expect to find a table of results with
four groups of workers with Standard Mortality Ratios for these six a
priori cancers. Instead, we find 26 different cancers listed in their
table 4. This is all right in one sense that five of the a priori sites
are in the table: melanoma, liver, rectum, brain and hematopoietic
cancers are listed. But instead of an entry for GI tract cancers, there
are just the three separate entries: stomach, intestine, and rectum.
Listing GI tract cancers as an a priori site requires the authors to
analyze them together as a group. Separating the individual sites out
for other analysis is allowed, but the group analysis is required.
Now it is easy enough to add up the expected and observed cancers in the
GI tract group from the individual entries. When we do this we find that
the hourly female group has a Standard Mortality Ration greater than 100
percent. In this group there were 28 cancer deaths when only 18 were
expected. This yields a Standard Mortality Ratio of 156 with a 95%
Confidence interval (103-225). These data from Kimbrough shows that PCBs
should be reclassified as a known human carcinogen.
One thing that should be done because of this finding is to reexamine
this population to screen for incidence of GI cancer, mainly to protect
the lives of the exposed individuals but to learn the dose-effect
relationship of incidence vs. body burden of PCBs.
Looking at these data in a prospective way, it is interesting to propose
that the upper part of the alimentary canal should also be examined.
When we group together the malignant neoplasms of the tongue, buccal
cavity, pharynx and esophagus, we find an elevation in both hourly
worker groups: male and female. For males, the SMR of 154 is not
significant: the 95% CI is (80-269). In the female group we find seven
deaths when only 2.8 were expected. This is a SMR of 250 with a 95% CI
of (102-514). While this is a significant elevation of cancer, we can
only use the results as a guide for future studies because we formed the
grouping ex post facto. The further study of this cohort of workers
should include screening for all digestive tract cancers.
Truth About PCBs
Betsy Garthwaite
GE has said that dredging the Hudson would be "environmentally
devastating." But, in my opinion, the only thing that is environmentally
devastating is being forced to continue to live with unsafe levels of
PCBs in our river.
The truth is that GE's dumping of PCBs into the Hudson River was not
legal. They began dumping in the 1940s. It wasn't until 1975 that GE
ever obtained a state permit to allow their discharges, and between 1975
and 1977 (the year they were forced to stop), GE exceeded their permit
on several occasions. In fact, an administrative law judge declared that
the company was guilty of violating state water quality standards. Not
only that, PCBs have continued to leech into the river from contaminated
soil on GE property.
The United States Environmental Protection Agency has recommended a plan
for targeted environmental dredging of select portions of the upper
Hudson River -- where PCB concentrations are at their highest -- in
order to protect the environment and safeguard human health. US Fish &
Wildlife supports this plan, as does Governor George Pataki and the NYS
Department of Environmental Conservation. The NYS Department of Health
has had Hudson River fish consumption advisories in place since 1975.
But in spite of the overwhelming amount of evidence to the contrary, GE
still contends the do-nothing approach is best. Who are we to believe?
I, for one, having read the EPA's assessment and having weighed the
EPA's mission (to safeguard human health and the natural environment)
against GE's (make as much money as possible) and having factored in the
company's deplorable environmental record, will side with the EPA. I
certainly can't believe anything GE has to say about it. Unfortunately,
most of our media have not done an adequate job to inform the public
about this issue, and many people have been misled by half-truths and
outright lies.
If the media won't do the homework, it means we have to. I encourage
readers to visit the websites of the EPA (www.epa.gov), Eliot Spitzer
(www.oag.state.ny.us), Scenic Hudson (www.scenichudson.org) and
Clearwater (www.clearwater.org) to better inform themselves about this
issue. Then, write the EPA and tell them you support a cleaner and
healthier Hudson through targeted and responsible dredging. Send your
written comments by Friday, Feb. 16, 2001 to:
Alison Hess/Doug Tomchuk
Hudson River PCBs Public Comment
US Environmental Protection Agency
290 Broadway, 19th Floor
New York, NY 1007-1866
Sincerely,
Betsy Garthwaite
PCBs Health Effects Include Cancer and Endocrine Disorders
by Philip J. Hopp
US EPA
Attn: Carol Browner; Jeanne Fox
Alison Hess/Doug Tomchuk
I am writing in support of the dredging of PCB'S From the Hudson River,
as long as there will not be future contamination from the dredging
process. My concerns with PCB'S, dioxin and furans have been numerous.
In the last few years, with the knowledge I have gained of the affects
of the above mentioned chemical compounds, I have become extremely
worried that a lot of the cancers that we see today, both in children
other people may be caused by these compounds. I have read the EPA's
studies on dioxin and PCB'S and I do know that all people throughout the
world have elevated body levels of these compounds (especially higher
among those who eat fish). These facts, coupled with the fact that
cancers are higher and the incidence of endocrine disorders is higher
leads me to believe, that these chemicals have some connection. Why only
recently the Veterans Administration has made dioxin exposure (from
Agent Orange), and the effects suffered from the exposures, diabetes for
one (an endocrine disease) covered for treatment under the VA'S system.
There is a lot more we have to learn about these dangerous chemicals.
In the meantime we have to eliminate these chemicals from our
environment, and if dredging them from the bottom of the Hudson River
helps in their elimination from the environment, I agree with that plan.
Philip J. Hopp
The River Will Not Clean Itself
by Douglas R. DeFeo
Ms. Alison Hess and Mr. 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:
I am writing to offer my support for the 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 General
Electric Hudson Falls plant.
My Connection to the Hudson River:
I am a resident of Suffolk County, New York, but was born and grew up in
northern Westchester County. For years, my family and I sailed up and
down the Hudson River, enjoying its scenery and the experience. We
were, however, constantly reminded of the Hudson's unfortunate
ecological circumstances and hoped that efforts would continue to
improve the ecology of this national historic and ecological treasure.
Because of the contamination, however, we avoided contact with the
water. I recall as a child thinking of it as poison, despite the
natural beauty that surrounded me. Unlike many who live along the
Hudson, we could limit our contact with the River because we lived in
the middle of northern Westchester County. For those who lived and
worked along its banks, such avoidance, and ultimately exposure to PCBs
was inevitable. For the sake of future generations, efforts must
continue to remediate the damage caused by this contamination and
hopefully to restore the river's ecological integrity.
The River Will Not Clean Itself:
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, which is often disturbed by natural forces
and human contact. In fact, the contamination continues. It has been
estimated that 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. We are, thus, not only responsible for
our own residents and wildlife, but life well beyond our state and
national boundaries.
The Dangers of PCB Contamination:
There is more than sufficient scientific data supporting the position
that PCBs remain an unacceptable health risk for residents and wildlife
in the Hudson Valley and beyond. Furthermore, the identification of
General Electric as the primary source of this toxic material in the
region appears to be well documented and indisputable. 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.
The identified and scientifically supported dangers associated with PCB
contamination can be summarized as follows:
1) 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.
2) 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.
3) 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.
Environmental Dredging:
The EPA must clearly identify the method of dredging required for the
clean up of the Hudson River. 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. As a part of the process, measures should be
taken to 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:
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 also support EPA's plan to backfill dredged areas and
support extensive biological restoration to minimize ecological effects
in remediated areas.
Finally, the EPA should keep to its proposed schedule to release its
final Record of Decision in June 2001, so that remediation can proceed
without any further delays. Thank you for your consideration.
Sincerely, Douglas R. DeFeo
cc: John Cahill
Commissioner
New York State DEC
50 Wolf Road
Albany, New York 12233
For Polar Bears and Three-Year Olds
by Donald M. Kreis
Dear Ms. Hess and Mr. Tomchuk:
Thank you for the opportunity to comment on the Environmental
Protection Agency's long-awaited proposal to employ targeted
dredging to remove 2.65 million cubic yards of contaminated
sediment, containing more than 100,000 pounds of highly toxic
polychlorinated biphenyls (PCBs), from the upper Hudson River.
There is, of course, little I am in a position to tell you about the
scientific and public policy bases for implementing the EPA's highly
laudable plan. I understand that both of you are scientists who have
devoted much of your professional lives to this problem. The main
purpose of my letter is to make sure you understand that one does
not have to live in the Hudson Valley to care deeply about this issue
and to hope fervently that the EPA has the fortitude to resist the
multi-million dollar propaganda campaign mounted by General
Electric (GE) in an effort to evade Superfund responsibility for the
disastrous Hudson River contamination that this greedy corporate
behemoth has unconscionably wrought.
I was born and raised in the Hudson Valley and visit the area
frequently. Thus I know the Hudson River, from New York Harbor to
the Adirondacks, to be one of America's greatest natural wonders
a precious resource that has provided recreational, economic and
spiritual sustenance to millions of Americans since the founding of
the Republic. It is outrageous and inexcusable that one corporation
was allowed to usurp this resource, wiping out the river's viability as
a fishery and leaving its sediments awash in bioaccumulating
carcinogens, for so long. No one person or corporation should be
allowed to appropriate and ruin a common resource in such a
fashion; the Superfund statute is designed expressly to redress
such wrongs.
Even a citizen who has never seen the Hudson River would have
good reason to care deeply about the EPA's ultimate decision in this
matter. I live near the Connecticut River and work near the
Merrimack River two great New England waterways that, like the
Hudson, have provided generations of Americans with incalculable
value, by serving as host to commercial enterprises, by being
harnessed for energy-generation purposes, and by providing
recreational opportunities. If EPA is unable to defend its scientific
principles in connection with the Hudson River, yielding to wealth
and power that GE has brought to bear on your agency, then no
American who has ever loved a river will be able to have confidence
that the federal agency charged with protecting the environment will
actually succeed in doing so.
I have learned from the web site of Hudson River Sloop Clearwater,
Inc. that 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. Reading about GE's
blithe willingness to drive these species from the Hudson River
forever reminded me of the weekly "Global Citizen" column I read on
February 3, 2001 in my local newspaper, the Valley News of West
Lebanon, N.H.. The columnist, Donella Meadows, was musing about
a report suggesting that polar bears face extinction from the effects
of global warming and bioaccumulating toxins. Here is the end of her
column:
"A friend of mine, in response to this news, did the only appropriate
thing. She burst out weeping. "What am I going to tell my three-year-
old?" she sobbed. Any of us still in contact with our hearts and souls
should be sobbing with her, especially when we consider that the
same toxins that are in the bears are in the three-year-old. And that
the three-year-old over her lifetime may witness collapsing
ecosystems, north to south, until all creatures are threatened,
especially top predators like polar bears and people.
Is there any way to end this column other than in gloom? Can I give
my friend, you, myself any honest hope that our world will not fall
apart? Does our only possible future consist of watching the
disappearance of the polar bear, the whale, the tiger, the elephant,
the redwood tree, the coral reef, while fearing for the three-year-old?
Heck, I don't know. There's only one thing I do know. If we believe
that it's effectively over, that we are fatally flawed, that the most
greedy and short-sighted among us will always be permitted to rule,
that we can never constrain our consumption and destruction, that
each of us is too small and helpless to do anything, that we should
just give up and enjoy our SUVs while they last, well, then yes, it's
over. That's the one way of believing and behaving that gives us a
guaranteed outcome.
Personally I don't believe that stuff at all. I don't see myself or the
people around me as fatally flawed. Everyone I know wants polar
bears and three-year-olds in our world. We are not helpless and
there is nothing wrong with us except the strange belief that we are
helpless and there's something wrong with us. All we need to do, for
the bear and ourselves, is to stop letting that belief paralyze our
minds, hearts, and souls."
Unfortunately, these words are likely to be the last message to be
heard from Ms. Meadows, who unexpectedly was taken seriously ill
just a few days after this column was published and died yesterday
at the age of 59. I hope that these words, and the fact that they
proved to be a valedictory statement from a distinguished
environmental thinker, might inspire you and your colleagues as you
consider what to do next, in particular as you ponder what actions to
urge on your superiors at the EPA.
Over the course of my career, which has included the fields of
journalism and law, I have had the privilege on occasion of
interacting with several EPA officials, based in your Region I office
in Boston. From these experiences I have reason to believe that
your agency is populated by many dedicated professionals whose
commitment to the agency's noble mission is stalwart and
unwavering. One can only hope that GE's propaganda campaign
will backfire; if it does, the credit will go to dedicated servants of the
common good like Alison Hess and Doug Tomchuk and others who
work alongside you.
You will therefore be in my thoughts and prayers over the coming
weeks and months. Please move forward with your courageous yet
sensible plan to remove the PCBs from the Hudson. Thank you for
considering my views.
Sincerely,
Donald M. Kreis,
Grantham, NH
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