The Gazette article, “Has dredging worked in the Hudson River?” (March 31) and the editorial, “Provide better answers on impact of PCB dredging” (April 3) serve to illustrate the failures of the dredge project from day one.
From the court decision that initially let the U.S. Environmental Protection Agency (EPA) and the state Department of Environmental Conservation (DEC) off the hook for conducting a rigorous environmental impact assessment of the upper Hudson River to provide a baseline, the scientific and practical credibility of the project has been in question.
As an example, one of the arguments used in the original Hudson Superfund proposal was the economic loss to the fishery industry of the lower Hudson estuary from PCB contamination.
However, the Hudson natural resource trustees have now concluded that fish of the upper Hudson will need perhaps several more decades to recover from prohibitions on consumption.
Dredging adds PCBs back into the water column by resuspension, plus direct loss; that which passes over the Waterford dam will wind up in the lower Hudson. What has been the impact there?
A lack of coordination among state and federal agencies, and differences among the parties on the interpretation and analysis of various data on the dredge project, is a built-in consequence of science by bureaucracy.
The EPA has largely depended on the hiring of “independent” consultants for its work, while the DEC has its own staff, with input from the U.S. Geological Survey and Division of Water Resources.
GE has contributed its own research data on PCB transport and degradation over time in the Hudson, epidemiological study results and other data. And the state Department of Health has provided PCB toxicity and chemical data.
However, because of the common adversarial relationship between GE and the EPA, coordination of opinion and criticism among these data sources is problematic at best in the absence of an effective peer review.
As a final salute to cynicism, the question should be asked whether the results of the project was worth its billion-dollar price tag.
Prior to 1973, the 1.3 millions pounds of PCBs targeted for dredging were impounded behind the former International Paper Co. dam at Fort Edward. In at least two reports by DEC scientists, samples from the 3-meters-deep sediment pool behind the dam are described, along with their PCB contents.
At this point, the PCB-laced sediment could have been dredged or removed at minimal cost. Yet, in an unfathomable decision, the DEC granted Niagara Mohawk Power Corp. permission to remove the dam.
Two 100-year and two 50-year flood events later, these PCBs were transported over the length of the upper Hudson.
PCB in the Hudson have long enjoyed a high environmental priority status among the EPA, various activist groups, the Natural Resource Trustees, etc.
Yet, ironically, $1 billion spent on reducing the impact of power plant emissions and acid rain on the Northeast will save far more real lives from respiratory illnesses than can ever be demonstrated for the cancer risk from consumption of Hudson River fish.
In this context, one should also ask how priority is determined for environmental clean-up projects of this scope.
In the present case, it certainly can be argued that the Hudson is neither the worst PCB-contaminated river, presents the most exposure risk or most impacts the local population.
In the vicinity of Massena, the St. Lawrence River is contaminated by PCBs derived from two aluminum plants and a General Motors plant. With a few exceptions, partial to complete remediation of PCB sources on land has been achieved or is in progress, but PCBs in the river itself largely remain.
In “Contamination Cove” of the river, adjacent to the Mohawk (Akwesasne) Indian Reservation, PCB contents (including the “worst” congener 1260) reach hundreds of parts per million.
Wildlife (frogs, turtles, fish, birds, etc.) of the area have PCB contents so high that they would be classified as toxic waste themselves. The residents have been prohibited from using these (a normal food source), with a consequent 50 times increase in the incidence of diabetes.
Where are the activities, “sloop sailors,” resource trustees and NOAA (National Oceanic and Atmospheric Administration) officials on this one?
Incidentally, this is another EPA and DEC oversight project.
On a still larger scale, the Water Resources Division of the U.S. Geological Survey and the U.S. Department of Agriculture cooperate on an ongoing survey of every significant watershed in the U.S. water and river sediment analyses and other data reveal contaminations (PCS, PAHs and other organics, metals, etc.) is ubiquitous in every urban watershed at levels exceeding regulatory limits.
Some states have also resorted to similar bans on watershed fish consumption.
The situation only emphasizes the subjective, political and biased nature of making priorities for environmental risk/remediation.
Dr. George W. Putman of Saratoga Springs was a technical witness for the Citizens Against Sludge Encapulation (CEASE) during the Adjudicatory Hearing in Ft. Edward (1987-88) on the first Hudson River Superfund proposal.