Susan Svirsky
EPA Rest of River Project Manager

I am not an engineer, biologist, or expert in river remediation. I have, though, been reading and analyzing GE’s studies for more than twenty years.

In my opinion, GE’s revised Corrective Measures Study for the Rest of the River minimizes the many problems of PCB contamination in the Housatonic, and emphasizes the cost and difficulty of solving those problems. It is more propaganda than science.

GE’s failure to provide a responsible corrective measures study begins with its claim that “even the highest historic levels of PCB contamination have not destroyed or degraded the ecology of the Rest of River; PCBs have been present for more than 70 years and yet the indigenous flora and fauna have flourished.”

GE states this despite knowing that since 1982 the Massachusetts Department of Public Health (MADPH) has issued a fish advisory due to the high levels of PCBs in fish tissue. MADPH later extended this order to frogs and turtles and most recently to ducks.

EPA’s peer-reviewed Ecological Risk Assessment found significant risk to species ranging from the microscopic aquatic invertebrates to the threatened bald eagle.

EPA’s Human Health Risk Assessment found there were risks to humans from direct contact with soil and sediment; eating fish, frogs, turtle or waterfowl; and eating agricultural products grown in the floodplain.

Despite an ever-increasing body of scientific knowledge about PCBs and endocrine disruption, neurological and motor control problems, including lowered IQ in the children of women who consumed fish with high levels of PCBs, GE maintains: “PCBs have not been shown to cause cancer in humans or to cause adverse noncancer effects in humans at environmental levels.”

We already know that fish can swim and birds can fly while exhibiting and passing on multiple symptoms of disease. Just like most of us already know our friends and family can endure while suffering through a variety of cancers. The issue here is finding a comprehensive treatment, and hopefully a cure for a river poisoned with PCBs.

Allow me an additional concern. The EPA, in its July, 2003 Fact Sheet on Ecological Risks, states: “Animals are exposed to contaminants through breathing (inhalation) … ” Yet the EPA neglects this critical pathway when it comes to assessing human health risks. Recent work by Dr. David Carpenter of the School of Public Health at State University of New York, Albany suggests a strong link between inhalation of PCBs and human health risks.

Dr. Carpenter notes: “We found that living next to the Hudson River … suggests the chance of having a heart attack is 39 fold greater than if you live in a zip code that doesn’t abut a hazardous waste site. This is the highest risk ratio we have ever found for any disease.” His Hudson River data also found a 36 fold elevated risk of diabetes.

Dr. Carpenter adds: “the levels you have in air in most of the sites where it has been measured are not terribly high. But I think our results suggest that you don’t need high levels in order to have adverse health effects.”

In GE’s world, PCBs are fine and the fish are fine and the river would be fine if only the finicky government regulators would let it be. So it is not surprising then that GE’s favored course of action is inaction: “Therefore, GE believes that the least intrusive approach – “Monitored Natural Recovery” – is best here.”

GE, whose callous, irresponsible use of PCBs and immoral dumping practices destroyed the Housatonic River in the first place, ironically now argues that forcing them to undo their damage will destroy it.

This is nonsense. Vernal pools have been successfully cleaned and restored. River banks and river sediments can be remediated. Yes, it is complicated and yes it will take time. But the river system will never be whole until it is clean. Humans who use the river or live beside it will be never be safe until it is clean. The extraordinary variety of plants, insects, fish, birds, and animals who make the river either a permanent or temporary home will never be healthy until the river is clean. This is not “destroying a river to clean it.” This is cleaning a river to clean it.

When the Housatonic River Initiative agreed to drop its legal challenge to the EPA/GE Consent Decree, EPA Administrator Mindy Lubber pledged the EPA would investigate the feasibility of using alternative remediation methods to clean the river. Now is the time for such pilot studies. Technologies like thermal desorption and possible in place remedial methods reduce the need for landfilling. And there are already off-site approved landfills. There is absolutely no need for GE’s proposed PCB dumps in the Rest of River system.

While GE is doing its best to convince people the river will be forever destroyed if they are forced to clean it, I am confident that the EPA can oversee an effective cleanup and scrupulously avoid unnecessary damage to the river system. I am confident that the EPA can insist upon a comprehensive river restoration program.

Only the EPA can give us back our fishable, swimmable river.

The Berkshire Record, December 16, 2010. © Mickey Friedman