v>EPA
United States
Environmental Protection
Agency
Public comment period
EPA will accept written comments
on its proposed changes to the
cleanup plan during a public
comment period from Nov. 13 to
Jan. 11,2007. This fact sheet
provides a pre-addressed form for
you to send your comments to
EPA. Comments must be
postmarked no later than Jan. 11.
There will be no comment period
extension since this is beyond the
30-day requirement.
Public meeting
EPA will hold a public meeting to
explain and answer questions about
its proposed changes to the cleanup
plan. We will also accept oral and
written comments at the meeting.
Date: Dec. 5, 2006
Time: 7p.m.
Place: Brown County Library
515 Pine St.
Green Bay
Jf you need special accommodations
in order to attend this meeting, please
contact Susan Pastor at least one
week prior to the meeting, toll-free at:
(800) 621-8431, Ext. 31325
weekdays, 9 a.m. - 4:30 p.m.
EPA Web site
This fact sheet and other related
documents can be found on the
following EPA Web site:
www.epa.gov/region5/sites/
foxriver
EPA Proposes Changes to
Current Cleanup Plan
Lower Fox River/Green Bay Site
Northeast Wisconsin
November 2006
U. S. Environmental Protection Agency and Wisconsin Department of
Natural Resources propose to modify the current cleanup plan for
sections of the Lower Fox River/Green Bay site referred to as operable
units (or OUs) 2 - 5. This includes areas of the river from Appleton to
Green Bay contaminated with PCBs. (See Lower Fox River site map
on Page 2.) In December 2002, a document called the record of
decision was finalized, which included OU 2. A second document was
approved in June 2003, which covered OUs 3-5. These documents
describe the overall cleanup plan selected for those sections of the
Lower Fox River and Green Bay. This cleanup plan primarily involved
dredging of the river and bay and is called the ROD remedy. However,
while designing the cleanup, engineers collected new information that
has led EPA and DNR to consider making changes to the current
cleanup plan. A summary of this new information can be found on Page 3.
EPA and DNR's proposed changes would combine capping with the
dredging to reduce the amount of dredging required, especially in areas
where new information found that dredging would be virtually
impossible. Aback-up option in the current cleanup plan allows for
capping in some areas. This proposed cleanup plan, called the
optimized remedy, would separate the site into much smaller areas
allowing the cleanup to be customized to meet the particular conditions
in each of those areas. The proposed plan would also allow the
cleanup to be implemented faster and would make better use of limited
landfill space. The proposed plan is detailed in a document called the
basis of design report.1 Another document called a technical
memorandum has also been prepared, which provides more details on
the proposed changes. These reports can be found in the site
information repositories listed on the back page and online at
www.epa.gov/region5/sites/foxriver.
EPA and DNR encourage the public to attend the public meeting (see
the shaded column to the left) to learn more about the proposed
changes. EPA and DNR could modify the proposed changes, choose a
new plan, or not change the cleanup decision at all based on public
comments. The approved cleanup plan will then be explained in a
document called a ROD amendment.
^Section 111 (a) of the Comprehensive Environmental Response, Compensation, and Liability Act
requires publication of a notice describing the proposed modifications to the cleanup plan.
Information supporting the decision, such as the basis of design report, must also be made
available to the public for comment. This fact sheet is a summary of information contained in the
basis of design report for the Lover Fox River site. Please consult that document, which can be
found at the locations listed on Page 7 of this fact sheet, for more detailed information.
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Current plan
The current plan involves:
• dredging 7.6 million cubic yards (new estimate
based on additional sampling) of sediment (mud)
withPCB levels greater than 1 part per million
(ppm is a form of measurement) from OUs 2-4
• pumping contaminated sediment through a
temporary pipeline to settling basins (ponds)
• letting sediment settle naturally, pumping water
from settling basins, treating the water and
returning the treated water to the river
• pumping contaminated
sediment through a pipeline to
a landfill for final disposal
• dredging PCB-contaminated
sediment in Green Bay near
the mouth of the river.
This plan allows for the use of an
engineered cap in limited areas if
that proves to be less costly than
dredging, or if dredging alone
was not sufficient.
Engineered caps are covers
placed over sediment in some
locations and could be from 13
to 33 inches thick. They would
consist of a combination of 6-15
inches of sand and 7-18 inches
of stone.
Estimated cost: $580 million
Completion time: Levels safe
enough for wildlife are expected
to be met within 20-100 years
depending on the area.
By removing the contaminated
sediment, EPA and DNR
estimate the river will have an
average PCB level well within
the cleanup goal of .25 ppm.
Cleanup goal - .25 ppm for average PCB levels in
sediment at the river's surface.
PCB action level (a concentration that identifies the
need for a cleanup) -1.0 ppm for PCB levels that
would be addressed under both plans.
Lower Fox River Site Map
OU1 Little Lake
Butte des Morts
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Proposed plan
The proposed plan is similar to the current plan, but adds
the new information collected while designing the cleanup.
The proposed plan still uses dredging to remove most of
the PCBs in the river, but now includes the use of
engineered caps and sand covers to accommodate the
limitations of dredging. The new plan also customizes the
cleanup to meet the specific conditions of much smaller
areas. The proposed plan includes:
• dredging 3.7 million cubic yards of contaminated
sediment from OUs 2-5
separating the sand from the sediment and using it on
and off the site to further reduce the amount of
material placed in a landfill
• using a combination of capping and dredging in Green
Bay near the mouth of the river
• using engineered caps in selected areas such as:
- where dredging could cause damage to riverbanks
- where contaminated sediment is deeply buried
- in the navigational channel in OU 4 as long as the
cap is at least 2 feet below the authorized level of
the bottom of the navigational channel
- near utilities when dredging in those areas could
pose a risk to those facilities
• using sand covers as an alternative to dredging in
areas where the maximum PCB level is less than or
equal to 2 ppm and where the contaminated sediment
layer is no thicker than 6 inches
• monitoring of the caps and covers to ensure that the
contamination will not be released since some of the
contamination will be left in place. If it is found that
the caps or covers are networking, additional actions
will be taken.
Estimated Cost: $390 million
Completion time: The proposed plan would result in
lower PCB concentrations after cleanup. EPA and DNR
believe that it would take less time to reach a point when
fishing advisories could be lifted and when the river and
bay would be safe for wildlife.
Common features
Both plans include:
• using sand covers for certain areas that either have
been dredged and still have levels over 1 ppm, or that
have pre-dredging conditions similar to dredged areas
• imposing institutional controls such as fish advisories
until the cleanup objectives are met
• monitoring the levels of PCBs in sediment, water and
fish tissue
• using monitored natural recovery for the remainder of
the bay.
New information
The investigation done while designing the cleanup
involved taking 10,000 sediment samples at more than
1,300 locations. Additional information showed that:
• PCB s are not uniformly spread throughout the site
but tend to be concentrated in smaller, definable
areas.
• A small deposit of sediment near the surface that i s
highly contaminated with PCBs has been identified
downstream and west of the De Pere Dam.
• Deeply buried contaminated sediment is present at
depths between 6 to 13 feet below the river
bottom in the middle stretches of OU 4 and in the
Fort Howard turning basin. Relatively cleaner
sediment lies over these areas.
Contaminated sediment was detected in several
developed shoreline areas downstream of the De
Pere Dam. In these areas, it may not be feasible
to dredge all buried contaminants because
dredging could damage riverbanks and structures
along the shoreline.
Several areas in the site have a relatively thin layer
(often only 4 inches) of sediment that just barely
exceeds 1 ppm of PCBs.
• The limitations of modern dredging equipment in
removing contaminated sediment have recently
been documented.
There is limited landfill space and no regional
landfill has enough space to accept the amount of
sediment that would be dredged under the existing
cleanup plan.
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Comparing the cleanup alternatives
EPA evaluated the cleanup alternatives against seven of
the nine evaluation criteria. (See "Explanation of the
nine evaluation criteria" on Page 7.) The state and
community acceptance criteria will be evaluated after
public comments are received by EPA. The degree to
which the cleanup alternatives meet the evaluation criteria,
as determined by EPA, is shown in the table below.
Both plans provide overall protection of human health and
the environment and comply with state and federal laws.
Though the two plans involve different mixes of
technologies, both provide comparable levels of long-
term effectiveness, permanence, and reduction of toxicity,
mobility, and volume. However, the proposed plan can
be done faster than the current plan, providing better
short-term effectiveness. The proposed plan will also
achieve a lower PCB concentration in sediment in less
time. The proposed plan is easier to do as it uses caps
and covers in areas where dredging would be extremely
difficult, relies on proven dewatering and transport
methods, and needs less landfill space. It also can be
implemented at a lower cost. Both plans are designed to
meet the goals and cleanup timeframe in the ROD and
address all sediment that exceeds 1 ppm.
Site history
Between 1954 and 1971, paper mills in the Lower Fox
River valley manufactured or recycled carbonless copy
paper containing PCBs. Until the early 1970s, the mills
discharged the PCBs into the Fox River where they
settled into river sediment or were carried into Green
Bay. Due to elevated levels of PCBs in fish tissue and a
growing knowledge that PCBs were harmful to people
and the environment, DNR issued fish consumption
advisories for the river and Green Bay in 1976. These
were followed by waterfowl consumption advisories for
the river and Green Bay in 1987. Advisories remain in
effect today.
Since the mid-1980s, a number of governmental and
other organizations have studied the contamination
problem. In 1997, six federal and state agencies and
tribal governments signed an agreement to work together
to clean up and restore the Lower Fox River.
Evaluating the cleanup alternatives
Evaluation Criteria
Overall Protection of
Human Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
and Permanence
Reduction of Toxicity,
Mobility, or Volume
through Treatment
Short-Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Current Plan
•
•
•
•
•
•
$580 million
Proposed Plan
•
•
•
•
•
•
$3 90 million
Will be evaluated after the comment period.
Will be evaluated after the comment period.
= Meets Criteria
= Does Not Meet Criteria
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Use This Space to Write Your Comments
Your input on the proposed change in the cleanup for OUs 2-5 at the Lower Fox River site is important to EPA.
Comments provided by the public are valuable in helping EPA select the final cleanup plan for the site.
You may use the space below to write your comments. You may hand this in at the Dec. 5 public meeting, or detach,
fold and mail to Susan Pastor. Comments must be postmarked no later than Jan. 11. If you have any questions, please
contact Susan at (312) 353-1325, or toll free at (800) 621-8431, weekdays 9 a.m. - 4:30 p.m. Comments may also
be faxed to (312) 353-1155 or sent via the Internetatwww.epa.gov/region5/publiccomment/foxriver-pubcomment.htm.
Name
Affiliation
Address
City State_
Zip
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Lower Fox River Site Comment Sheet
Detach, fold, stamp, and mail
Name _ „,
Address ?lace
City State -
Zip - Here
Susan Pastor
Community Involvement Coordinator
Office of Public Affairs (P-19J)
EPARegion 5
77 W.Jackson Blvd.
Chicago, IL 60604-3590
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Explanation of the nine evaluation criteria
EPA uses the following nine criteria to evaluate the cleanup alternatives. Atable comparing the alternatives against
these criteria is provided on Page 4.
1. Overall Protection of Human Health and the
Environment Evaluates whether a cleanup option
provides adequate protection and evaluates how
risks are eliminated, reduced or controlled through
treatment, engineering controls or local government
controls.
2. Compliance with Applicable or Relevant and
Appropriate Requirements Evaluates whether a
cleanup option meets federal and state
environmental laws, regulations and other
requirements orjustifies any waivers.
3. Long-Term Effectiveness and Permanence
Considers any remaining risks after a cleanup is
complete and the ability of a cleanup option to
maintain reliable protection of human health and the
environment overtime once cleanup goals are met.
4. Reduction of Toxicity, Mobility, or Volume
Through Treatment Evaluates a cleanup option's
use of treatment to reduce the harmful effects of the
contaminants, their ability to move in the
environment and the amount of contamination
present.
5. Short-Term Effectiveness Considers the time
needed to clean up a site and the risks a cleanup
option may pose to workers, the community and
the environment until the cleanup goals are met.
6. Implementability Is the technical and
administrative feasibility of implementing a cleanup
option and includes factors such as the relative
availability of goods and services.
7. Cost Includes estimated capital and annual
operations and maintenance costs as well as the
present worth cost. Present worth cost is the total
cost of an alternative overtime in terms of today's
dollar value.
8. State Acceptance Considers whether the state (in
this case Wisconsin) agrees with EPA's analyses
and recommendations as described in the basis of
design report and EPA's proposed cleanup plan.
9. Community Acceptance Considers whether the
local community agrees with EPA's analyses and
proposed cleanup plan. The comments that EPA
receives on its recommendation are an important
indicator of community acceptance.
The next step
EPA, in consultation with DNR, will evaluate public
comments received during the public comment period
before deciding whether to amend the cleanup plan for
the site. EPA encourages you to review and comment
on the cleanup options. EPA will respond to the
comments in a document called a responsiveness
summary. The responsiveness summary will be a part
of the final decision document called the ROD
amendment that describes the final cleanup plan
selected for the site. EPA will announce the final
cleanup plan in the local newspaper and will send a
copy of the amendment to the information repositories
for the site where it will be available for public review.
It will also be posted at www.epa.gov/region5/sites/
foxriver. After a final cleanup plan is chosen, it will be
designed and implemented.
Official records
Copies of the ROD amendment, basis of design report and
other documents related to the Lower Fox River cleanup
will be available in the reference sections of:
• Appleton Public Library, 225 N. Oneida St., Appleton
• Brown County Library, 515 Pine St., Green Bay
• Door County Library, 104 S. FourthAve., Sturgeon Bay
• Oneida Community Library, 201 Elm St., Oneida
• Oshkosh Public Library, 106 Washington Ave.,Oshkosh
An administrative record, which contains detailed
information upon which the selection of the cleanup plan
will be based, is available at the DNR Northeast Region
office, 2984 Shawano Ave., Green Bay, Wis.; DNR
Bureau of Watershed Management, 2nd Floor, 101 S.
Webster St., Madison, Wis.; and the EPARecords Center,
7th Floor, 77 W Jackson Blvd., Chicago, 111.
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For more information
For more information about the Lower Fox River/Green Bay site cleanup, please contact:
Susan Pastor
Community Involvement Coordinator
Office of Public Affairs (P-19J)
EPARegion 5
77 W.Jackson Blvd.
Chicago, IL 60604-3590
Phone: (312) 353-1325 or
(800) 621-8431 Ext. 31325
weekdays, 9 a.m. - 4:30 p.m.
Fax: (312)353-1155
E-mail: pastor.susan@epa.gov
James Hahnenberg
Remedial Project Manager
Superfund Division (SR-6J)
EPARegion 5
77 W.Jackson Blvd.
Chicago, IL 60604-3590
Phone: (312) 353-4213 or
(800) 621-8431 Ext. 34213
weekdays, 9 a.m. - 4:30 p.m.
Fax: (312)886-4071
E-mail: hahnenberg.james@epa.gov
Greg Hill
Proj ect Coordinator
Water Division
Wisconsin DNR(WT/2)
101 S.Webster St.
P.O. Box 7921
Madison, WI 53707-7921
Phone: (608)267-9352
Fax: (608) 267-2800
E-mail: gregory.hill@dnr.state.wi.us
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