Credentialed scientist says EPA’s conclusion that PCB cleanup is on track is not supported by data
HUDSON VALLEY—The cleanup of toxic PCBs in the Hudson River will not achieve the Environmental Protection Agency’s (EPA) mandatory goal of protecting the environment and public health, as the agency claims in its draft Five-Year Review of the project. A highly credentialed expert contracted by the environmental groups Scenic Hudson and Riverkeeper finds the scientific data gathered to date about the health of the river does not support the conclusion that the goals of the cleanup will be achieved. The expert has more than 20 years’ experience with chemicals, notably PCBs, in natural and man-made environments and their remediation. The scientist’s report states that the EPA used highly variable and uncertain data and that the agency’s methodology contains a bias toward a high rate of recovery that yields conclusions that cannot be supported with any reasonable degree of confidence or scientific certainty.
Remy Hennet, Ph.D., who has a doctorate in geochemistry from Princeton University, is a principal with the firm of S.S. Papadopulos and Associates, which has expertise in contaminant studies and environmental engineering. He conducted a thorough review of the EPA’s data and conclusions in its Five-Year Review. He found it highly likely that any predicted recovery rate from PCB pollution in the Hudson River based on the available data for fish tissue is so uncertain as to be meaningless.
The EPA failed to adequately account for the large uncertainty inherent in fish tissue results. This flaw was compounded by transforming fish data from different laboratories, different analytical methods and different field studies into one combined database.
Dr. Hennet found that the EPA did not adequately consider the significant uncertainty this data transfer could create in the overall results. When Dr. Hennet made very slight changes within the customary reasonable range, the variations consistently produced average rates of recovery lower than the rate calculated using the EPA’s approach. As a result, the EPA’s approach achieves results that are consistently biased toward faster recovery rates. This demonstrates that the uncertainty introduced by the data procedures is significant. Using more realistic recovery rates leads to the inevitable conclusion that Hudson River fish will not reach targeted PCB reductions for decades longer than the EPA predicted.
Dr. Hennet also points out that different species of Hudson River fish recover from the toxic pollution at different rates. The EPA used the average recovery rate, which was biased high, to state an average recovery time for all fish species. Dr. Hennet points out that this conceals the variability in recovery rates by individual species of fish. Because the fish species that retain contamination longer will continue to create health exposures for people, the slower recovering fish rates should be given more consideration when determining if the cleanup is protecting the health of the river and people.
On Sept. 1, Riverkeeper, Scenic Hudson and partners submitted to the EPA technical comments on its Five-Year Review. Based on analysis by Dr. Hennet and other scientific authorities, the comments asked the EPA to find that the cleanup is not protective of human health and the environment.
Scenic Hudson Director of Environmental Advocacy Hayley Carlock said, “The EPA’s determination that the Hudson PCB cleanup will protect human health and the environment is arbitrary, capricious and not supported by independent scientists or scientists from federal and New York State agencies. The EPA acknowledges in its review that the cleanup currently doesn’t safeguard the health of people or the river. This should be the sole finding of the review. EPA should delete its finding that the cleanup ‘will be protective’ even in more than five decades in the future as it is forecasting. The EPA should outline a plan for more cleanup in the upper Hudson and should direct General Electric to investigate how to characterize and clean up the problem in the lower Hudson. The health of people in the region and the potential for the Hudson to serve as a catalyst for economic development will be compromised unless EPA acknowledges the cleanup to date has failed to achieve its explicit goals and lays the groundwork for a comprehensive remedy.”
Riverkeeper Legal Director Richard Webster said, “The EPA can no longer hide its head in the sand. Our comments clearly show that an impartial analysis of the data demonstrates that the EPA is missing the critical targets for the cleanup of the upper 40 miles of the Hudson and more must be done. For the lower 150 miles of the Hudson, even the EPA agrees that more investigation is needed. It must therefore order General Electric to do a remedial investigation as soon as possible.”
Riverkeeper is a member-supported watchdog organization dedicated to defending the Hudson River and its tributaries and protecting the drinking water supply of nine million New York City and Hudson Valley residents. Since its beginnings more than 50 years ago, Riverkeeper has helped to establish globally recognized standards for waterway and watershed protection and serves as the model and mentor for the growing Waterkeeper movement that includes more than 300 Keeper programs around the globe. Visit us at www.riverkeeper.org and follow us @Riverkeeper.
About Scenic Hudson
Scenic Hudson preserves land and farms and creates parks that connect people with the inspirational power of the Hudson River, while fighting threats to the river and natural resources that are the foundation of the valley’s prosperity. A crusader for the valley since 1963, we are credited with saving fabled Storm King Mountain from a destructive industrial project and launching the modern grass-roots environmental movement. Today with more than 25,000 ardent supporters, we are the largest environmental group focused on the Hudson River Valley. Our team of experts combines land acquisition, support for agriculture, citizen-based advocacy and sophisticated planning tools to create environmentally healthy communities, champion smart economic growth, open up riverfronts to the public and preserve the valley’s inspiring beauty and natural resources. To date Scenic Hudson has created or enhanced more than 65 parks, preserves and historic sites up and down the Hudson River and conserved more than 40,000 acres.