The EPA is considering to significantly reduce the cleanup plan of the PCB's in the Acushnet River. They are proposing to bury them in the harbor instead of continuing to haul them away. (See Overview below).
| ALERT: | This could be the most important 'local' environmental concern of our lifetime. Don't let Greater New Bedford (gNB) get shorted, write your comments to the EPA. (do it now while it's on your mind). |
DEADLINE: Sept 10, 2010 to the public comment period. |
Videos Related to similar plight on West Coast
PCB's deadly effects on Whales in WA
Cousteau on PCB's, Whales and Humans.
Successful Public action w/ EPA @ Duwamish in WA
The EPA wants to bury 300,000 cubic yards (over 8,100,000 cubic feet) of sediment: 15,000 lbs of PCBs!!
A 650-foot square CAD cell excavated 47 ft below the riverbed is what is proposed. This is about the size of over a dozen NB City Halls.
This would only hasten project work time by about 15% under current funding levels; reducing the project time to 40 years (instead of 46) and sweeping 15,000 lbs of PCBs under the rug instead of removing them (delivering a disadvantaged result) .
YOUR VOICE CAN INFLUENCE THIS. The EPA 's ongoing evaluation of CAD cells for potential use is subject to public acceptance. Speak now our forever hold your piece.
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If you don't know what to say or don't have time now you can use this as a start:
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In 1982, the EPA concluded there had been such a legacy of pollution in greater New Bedford that the Acushnet River was declared a Superfund site, one of the largest Superfund sites in the country (6 miles, 270 acres; 18,000 acres of closed fisheries) and the highest priority in Massachusetts.
The EPA investigation subsequently ordered THAT THE HARMFUL PCB CONTAMINATED SEDIMENT WOULD BE TAKEN OFF SITE. Currently, the sediments are being shipped away to a Toxic Substances Control Act (TSCA) licensed facility in Michigan.
This will end if the NEW proposal (presently up for public comment) is approved!
Now, we are being sold down the river; literally and figuratively. They are NOW pitching us an alternative plan that will deprive us of the previously ordered full cleanup. To cut corners, they want to put some of the PCBs down the river, under the river beds; essentially, sweeping it under the rug
The proposal is to bury 1/3 of the 900,000 cubic yards of PCB contaminated sediment in submerged Confined Aquatic Disposal ("CAD") cells in the river bed (location TBA: most likely 500-600 yards north of Popes Island) instead of removing them completely out of the New Bedford, Acushnet, and Fairhaven tidal estuary.The argument is that it will be faster and cheaper but it is only going to save a few years and it won't, ultimately, be cleaned up and removed. It seems lack of money is the underlying basis that prompts putting forward such costly to create plans, because funding has been metered out at a pace that they expect it to take 46 years to do. But there's plenty of money in our federal budget; it's the prioritizing of funding to less environmentally concerned interests (i.e., bank bailouts, tax cuts to Raytheon and Fidelity, etc.... for example) that needs to be accessed and reduced; not the cleanup of dangerous PCBs that restores a necessary clean environment. And besides the new proposal only reduces the time by about 15%: from 46 to 40 years at current rates of funding.
This problem is, primarily, the result of the disposal of toxic corporate effluent that includes products for government contracts to support the war effort during WWII (and beyond), and by the continued production of such products that were consumed by those beyond the Greater New Bedford (gNB) area. Thus the cleanup of New Bedford's PCB problems is, justly, the responsibility of a larger sphere of responsible parties (Aerovox, Cornel Dublier, etc.), the national consumers of said products, and the federal government who shared involvement in the activities that created or authorized the mess. As such, the cost to restore gNB to environmental equity is a shared FEDERAL responsibility that should know no limits to facilitate that end. An abbreviated effort at this time is not acceptable. This is something that gNB certainly can not afford to do alone so if we don't insist they remove them now we will be stuck with them forever. And the responsible corporate deep pockets may be off the hook, leaving us with an insurmountable hurdle to overcome later. .
So, it is up to greater New Bedford commenters to hold the EPA's feet to the fire to ensure Federal efforts come to bear the weight of enforcing a full cleanup. Please, do it now.
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Miles away from the New Bedford hurricane dike signs warn of PCB contaminated fish at the opening to Buzzards Bay.
For years gNB suffered with an estuary that stank to high heaven from a miserable outflow that contaminated our environment, our great maritime heritage, and our livelihood. This writer clearly remembers walking across the Coggeshall St. bridge one August morning in the late '70's and almost passing out from the odoriferous vapors (presumably VOCs from the dead organisms, methane and hydrocarbons) rising from the river. It took years of campaigning with much effort by local activists before the EPA assumed responsibility and finally began the cleanup; then things finally began going in the right direction when the EPA decided to "remove" the contaminants.
New Bedford, a city that for years has suffered a whole host of inequities at the hands of the local, state, and federal government is now about to be shortchanged again. The good results of those past efforts and decisions regarding the PCB contamination are now being assaulted. If this new proposal is followed, that prior decision will have been circumvented, reduced and our course will again be moving in the wrong direction. Promises that were made by the EPA to those past campaigners (some who have passed on) will be broken and their vision of leaving future generations an environment closer to the original natural one will be damaged.
Although EPA says that they will be cleaning the river up faster and cheaper, neither end will ultimately be the case.
If they do not remove the contaminants once and for all, then, in fact, they wlll not have cleaned up what remains at all; just swept it under the rug.. If it's still here it's not cleaned up. Without removing the contaminants completely, the threat will not be removed. Burying them deeper in the river would, clearly, be moving things in the wrong direction (deeper in, NOT out).
"They blinded me with science."
I had heard that at one if the harbor cleanup meetings the public was told that if they understood science that they'd know it would work.
Ironically, I more recently asked our area's most prominent oncologist what he thought about burying 15,000 lbs of PCB's in the harbor. He is a scientist and presumably one who knows about the affect of carcinogens and his reply was,"They got to go somewhere but they are not going there!"
Despite the many turbidity tests, predictions, computer modeling, etc. that the EPA shows in the proposal, there is no actual real longitudinal evidence that these ideas will be successful.
This is simple... they are either going to put poison in a hole in the river (15,000 lbs) OR their going to ship it away.Your comment is necessary to influence the outcome.
Cad Cell techniques have only been utilized for a short period of time; in fact, there has only been one case of PCB's being contained in the US. That was just in 2000 (see this Pg 18, Table 11 ) so there is no long term data available (also see: Page 4 Limitations of CAD). It was placed at a Naval facility in Puget sound; concurrently, PCBs are being attributed to the diminishing whale population there; Puget sound Orca's are now considered an endangerd species. Orcas are the top of the food chain in their environment as humans are in theirs. Cousteau, The Center for Whale Research, NOAA, and Canada's Department of Fisheries and Oceans are all concerned that what is true for them is also true for humans (See this and the related videos below).
On Page 14, item 2 of the present proposal , it says:
"2. CAD cells are a proven technology for sequestering contaminated sediments, although the levels of PCBs within the Superfund sediments to be disposed of are higher than other sites where CAD cells have been used."
Isn't it nice that New Bedford is about to be the test site for this experimental solution; PCB's have never been approved anywhere other than the Puget Naval facility (federal ownership was listed as an import factor of approval on lessons learned: Pg 18, Table 11).
On Page 8, Par 2, the present proposal mentions possibly adding activated carbon to the 3 ft sand cap:
"EPA will also investigate whether adding activated carbon or other supplements to the CAD cell would further limit the mobility of the contaminants within it.."
So, they admit the possibility of contaminant migration. On Page 11, Para 1 , it goes on to say:
"...the model predicted that 50 years after being capped, the cap would contain 7 ng/kg (parts per trillion) PCB and 100 ng/1 copper -..."
In theory... theory and practice are the same; in practice they are not. Beyond that, 50 years is not 7 generations out. How about those forthcoming generations? The children of greater New Bedford should not be forsaken for the sake of time and/or money.
How can the CAD cell designers know of the unknown, unknowns like the effects of the worst hurricanes of 200 years , the effects of worms or vegetation penetrating the 3 ft sand cap over time, or that of long overdue earthquakes, etc. They are claiming that a cap layer of 3 ft of sand will protect us for 1800 years (page 10, last para). Besides the Sphinx and Pyramids, is there anything man made that has lasted 1800 yrs? Any one who has seen the effects of Hurricane Carol of 1954, Diane and Connie of 1955, or the Hurricane of 38 most certainly must have doubts to this. In the latter, at Dune Deck, Bayside, NY the storm tore an inlet 400 ft wide and 20 ft deep.
Models make predictions within the confines and limitations of a programmers program ; but, we know that meteorological modeling can't even get it right 10 days out. How much of a leap of faith is it to expect a 3 ft layer of sand to protect us for 1800 years?
The only way to be sure that contaminants can not do any more harm is to remove them.
This newly proposed plan will spend millions of dollars on keeping the pollutants here, it will NOT remove the contaminants. Instead, it spends (wastes) the funding to bury them which will make it much harder and more expensive to get to them later when future knowledge and technology improves such that neutralization may become possible. If they do not want to ship them it would make more sense to store them above ground where they would be more accessible for later processing than to bury them under a riverbed.
At present levels of funding it will only mean that the time will be reduced from 46 to 40 years away; isn't it worth 6 more years (15% longer) to have this 15,000 lbs of PCBs completely removed off site.
How can the children of New Bedford, Acushnet, and Fairhaven (and surrounding towns) be forsaken for money (or time): at what price is it alright to gamble on the health of the children and perpetuate the contamination of the fisheries. Again, PCBs are being attributed to the diminishing Orca population in Puget sound (see this): local species are contaminated too.
The time to stand up for wise spending and a complete cleanup is now.
This blue image/table below is taken directly from page 24 of the EPA presentation materials:
http://epa.gov/ne/nbh/pdfs/presentations/299754.pdf
Faster? Maybe to reach an end to the project; but how can it be faster if the PCBs are still here?
The change will stop the work and shut down the federal and corporate purses 15% earlier ; but it won't really be truly done? The PCBs will still be here.
Less costly? Is it really worth saving just about 15% in money or time and still have the PCBs in the harbor when they could have been removed completely. What will be the continued environmental costs? And what point will perpetual monitoring costs overtake the apparent savings. And what inevitable financial costs may come later (i.e.; subsequent to another hurricane or similar unforeseen catastrophic event).
The table below illustrates the apparent savings. (I stress"apparent").
| Funding | Time in Years | Financial Costs | |||||||
| per year | |||||||||
| Current | ESD | Difference | % savings | Current | ESD | Difference | % | ||
| | | ||||||||
| $15,000,000 | 46 | 40 | 6 | 13.04% | 1.7 billion | 1.2 billion | 500M | 29.41% | |
| $30,000,000 | 40 | 26 | 14 | 35.00% | 1.2 billion | 767 million | 433M | 36.08% | |
| $80,000,000 | 7 | 6 | 1 | 14.29% | | ||||
Not completely removing PCBs and shipping them away to the TSCA licensed Michigan facility is NOT cleaning up the river, it is just sweeping it under the rug; it will still be here to resurface and rear it's ugly head and it will still be here to further contaminate the estuary eco-system.
New Bedford's pollution was one of the worst in the country. One study on Liver Disease in Winter Flounder was conducted to look at the patterns of liver disease in winter flounder in New England, including flounder from New Bedford Harbor. Of nine sites studied, flounder from New Bedford Harbor had the highest incidence, 26 %, of liver neoplasms (cancer). Fifty-seven percent of all flounder collected from New Bedford Harbor had some liver disease. See: http://www.epa.gov/nbh/html/studies.html. This is an old study but, presently, not having a well loved sentinel species like Orcas to keep our attention drawn to it in this area, it is indicative that as humans at the top of the food chain we are affected similarly here and should be just as concerned.
Of further concern winter flounder (lemon sole) are migratory. "Adult winter flounder migrations consist of two phases; an autumn estuarine immigration prior to spawning, and a late spring/summer movement to either deeper, cooler portions of estuaries or to offshore areas after spawning." (Src: Wikipedia)
So winter flounder that feed in the Acushent River in one season may be harvested off shore the next and land on your dinner table as lemon sole and in chowders and other seafood by products.
Subsequent to these tests, there have been advancements in the right direction. Remediation by removal has been on going and the level of contamination has been diminishing as contaminants were being taken away. But now they want to end the removal and bury what is left, purportedly, forever.
Is that what you what them to do?
Furthermore, this new proposal flies in the face of the recent statement by the EPA Administrator:
"EPA has an answer to these challenging economic times.", said EPA Administrator Lisa P. Jackson. "Under the Recovery Act, we're getting harmful pollutants and dangerous chemicals out of these communities and putting jobs and investment back in."
"This funding will provide a tremendous boost to the cleanup of New Bedford Harbor that could more than triple the amount of PCB-contaminated sediment removed compared to recent years. The progress anticipated this year will significantly expedite the timetable to return a clean harbor back to the community."
Contrarily, the CAD cell proposal will not be "getting harmful pollutants and dangerous chemicals out of these communities" or "triple the amount of PCB-contaminated sediment removed" as she said.
It will bury them, Is that what you what EPA to do?
PLEASE send your comments to the address below ASAP; do not let the EPA turn their efforts in the wrong direction. Be uncompromising and insure that they keep up the good work; not take a less effective shortcut.
Mail written comments to:
David Dickerson
USEPA, OSRR07-4
5 Post Office Square - Suite 100
Boston, MA 02109-3912
Afterthought: Keep the priorities straight: at stake is our resulting environment for all time (and the environment is the foundation of all business and culture).
Don't be swayed by sales pitches by self serving aspiring political rock stars looking to expedite their ascension; those who extol mis-perceived results of some short sighted vision of an acceleration of some short term cultural or economic growth because of this plan that will ultimately yield a poisoned fruit. It may benefit the political advantage of the speaker(s circle) short term on the running up, but it will sacrifice the lasting benefits of a legacy of inter-generational equity of better health and prosperity to the inhabitants for the longer term.
PCB contaminated Whales are dying off : listen to related info by experts from the Center of Whale research:
More video in this topic from Cousteau.
Below is video demonstrating how public action changed the course that the EPA chose at a sister river (the Duwamish) in Washington state. The Duwamish feeds into Puget Sound (just as the Acushnet feeds into Buzzards Bay). Killer whales are dying from PCB contamination in the sound. We must be uncompromising, just as these activists were, in order to get the Acushnet cleaned properly.
These video excerpts are taken from PBS's Frontline production: "Poisoned Waters"; you owe it to yourself to see the entire production. You can watch the whole thing on line now (the DVD is available at the New Bedford Main Library) ..
For further viewing see: Call of the Killer Whales- PBS/ Jean-Michel Cousteau Ocean Adventures
See the work of our peers at the Duwamish River in WA
