The Rest of the River meeting held October 26
Below is a report on the GE/EPA goals meeting, followed by contact information and a list of talking points. Here is your chance to have a say in how the "clean up" of the river moves forward!
Report on the Rest of the River - October 26 Citizens Coordinating Council Meeting
General Electric Company (GE) presented their ideas for the Interim Media Protection Goals (IMPGs or preliminary cleanup goals -  404 pages - 11.07mb) for the Rest of River. The Rest of the River, refers to the part of the Housatonic
River that has not yet been remediated. This stretch begins where the east and west branches meet in Pittsfield and continues south through Connecticut. The US Environmental Protection Agency (EPA) is seeking feedback. (See below for whom to send your comments to.) The full proposal of IMPGs submitted to EPA by GE can be viewed at the EPA's website. Click on Rest of River, and the IMPG proposal is in the section called GE Reports and Documents, towards the bottom of the page.
Jane Winn attended the meeting for BEAT and what follows is her summary and opinions of the meeting.
The IMPGs are the goals that will be set for the river remediation. How non-toxic do we want our water, soil, and sediment to be? How non-toxic do we want our potential food - fish, cow's milk, eggs, beef, chicken
to be? And how nontoxic do we want our wildlife - fish, invertebrates, frogs, osprey, eagles, mink and otters to be? BEAT agrees with the Housatonic River Initiative that the goal should be a fishable, swimable river. Once these goals are set - the next question will be to identify remediation techniques will allow us to meet those goals? How do we accomplish the "clean up"?
The permit for setting these goals states that the goals must take into account the results of the Human Health and Ecological Risk Assessments. GE did take these results into account, but then presented an "alternative" approach that does not take these assessment results into account. They did this they say, because they disagree with the Risk Assessments. They think the peer reviewed Risk Assessments are too conservative. All GE's "alternative" goals leave more PCBs in the soil, food, and wildlife. One shocking example of GE's goals - it would be permissible to leave fish for human consumption with 55 parts per million (ppm) PCBs. US Food & Drug Administration sets a PCB limit of 2 ppm in fish (see Federal Register May 22, 1984 - 49FR21514). GE has to remediate the soil on residential properties to 2 ppm average. Why would they be allowed to leave enough PCBs in the river to have fish with 55 ppm in their muscle?
BEAT disagrees with the Risk Assessments, too - but in the other direction. The Risk Assessments did not take into account synergistic effects of PCBs and other chemicals - such as pesticides - even though it looked at exposure of grounds keepers and farmers to PCBs.
BEAT strongly urges EPA to be very conservative in setting these IMPG goals. Here our some of our thoughts:
The citizens deserve a river that provides fish that are safe to eat and water that is safe to swim in.
Remediation goals should be based on the very lowest numbers from the results of the Risk Assessments, should assume the highest exposure level that could be taking place, and should assume the most sensitive
receptors. (Fetal exposure, nursing infants, people with compromised immune systems) Remember that the Risk Assessments did not take into consideration the synergistic effects of PCBs with other chemicals. There are many other chemicals in our watershed - from pesticides, to pharmaceutical that get flushed down the toilet and are not broken down by sewage treatment plants. People really do eat the fish they catch from this river - signs or no signs. Some of these people are "sensitive receptors", living with mental health problems or possibly compromised immune systems. Mink eat fish and other animals in and around the river. To have our mink population recover we need a thorough "clean up". Please, use the 0.98 ppm figure or less to safeguard our mink.
Send you comments to: Susan Svirsky at svirsky.susan@epamail.epa.gov
or mail to:
Susan Svirsky
10 Lyman St., Suite 2,
Pittsfield, MA 01201
All comments must be received by November 15, 2005.
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