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Perspective: The Emperor's New Clothes and the USEPA's Decision to Dredge Hudson River PCBs

Authors:
  • RAM TRAC Corporation - Schenectady, New York

Abstract

For decades, the United States Environmental Protection Agency (USEPA) has considered dredging the Hudson River to remove polychlorinated biphenyls (PCBs). The cost would be hundreds of millions of dollars initially, and over a billion dollars cumulatively, for limited PCB "hotspot" dredging. The USEPA now has postponed dredging to 2007, allowing time to consider whether dredging constitutes the best use of funds. For example, would greater health benefits be obtained more inexpensively by presenting each household along the Hudson with a treadmill? Would greater per capita benefits be obtained by establishing a research institute addressing local epidemiological issues?
PERSPECTIVE
The Emperors New Clothes
and the USEPA’s Decision to
Dredge Hudson River PCBs
Robert A. Michaels
Once lived an emperor who thought so
much of new clothes that he spent all his
money to obtain them. When swindlers
presented the emperor with an imagi-
nary new suit, his cour tiers admired it.
No one wished to let others know that he
saw nothing. “But he has nothing on at
all,” said a little child at last . . . “But he
has nothing on at all,” cried the whole
people at last.—Hans Christian Ander-
sen, Aesops Fables, The Emperor’s New
Suit,” 1837.
For decades, the United States Environ-
mental Protection A gency ~USEPA! has con-
sidered dredging the Hudson River to
remove polychlorinated biphenyls ~PCBs!.
The cost would be hundreds of millions of
dollars initially, and over a billion dollars
cumulatively, for limited PCB “hotspot”
dredging. The USEPA now has postponed
dredging to 2007, allowing time to con-
sider whether dredging constitutes the best
use of funds. For example, would greater
health benefits be obtained more inexpen-
sively by presenting each household along
the Hudson with a treadmill? Would great er
per capita benefits be obtained by estab-
lishing a research institute addressing local
epidemiological issues?
The reward for doing river restoration is
that a river becomes in some sense “fixed.”
Although this reward would have to be
especially large for the Hudson to justify
the enormous price of “fixing” it, the re-
ality seems different. Whereas we should
be rewarded with clean sediments and water,
only PCB hotspots will be dredged, leaving
PCBs in sediments, biota, and water else-
where in the river and also leaving virtu-
ally all non-PCB contaminants in sediments,
biota, and water.
Whereas we should be rewarded w ith an
uncontaminated sport fishery and safe-to-
consume fish, in fact, fish advisories lim-
iting consumption of Hudson River fish
cannot possibly be rescinded, because all
other Hudson River pollutants will survive
PCB hotspot dredging. Whereas we should
be rewarded with only de minimis air pol-
lution arising from river water, in fact mo-
bilization of PCBs by dredging will increase
PCB release to the air for many years, and
other pollutants also will become airborne
after dredging. Indeed, USEPA recently ac-
knowledged underestimation of PCB mo-
bilization by d redg ing. Whereas we should
be rewarded with only a vanishingly low
incidence of adv e rse health effects that seem
to be caused by airborne PCBs, in fact
such health effects ~if really caused by PCBs!
would increase for many years before
decreasing.
Some people see light at the end of the
tunnel, when dredging really will reduce
PCBs in sediment, biota, water, and air
and really will eradicate PCB-associated
human disease. Others see the same light
at the end of a different, longer tunnel,
when continued natural burial of sediment-
borne PCBs by sediment loading from run-
off into the river will work toward doing
the same job. Continued natur al dechlori-
nation of buried PCBs, along with their
further degradation by physical, chemical,
and biological processes acting beneath the
sediments, will finish the job even if we do
not dredge.
Science is relevant to some aspects of choos-
ing the better route to a clean Hudson
River. Most notably, science can—but has
not—determined whether PCBs are harm-
ing health and/or whether the effects are
sufficiently serious, and risks sufficiently
high, to justify urgent action. Recall that
Love Canal was urgently evacuated, whereas
such precipitous action would be deemed
inappropriate today. Indeed, that over-
reaction spawned the modern Superfund
Act, and Love Canal became its first site.
If sediment-borne PCBs indeed are the
source of PCBs in air and/or biota, and if
such PCBs are harming people’s health now,
will dredging exacerbate their effects by
further mobilizing sediment-borne PCBs?
If PCB-mediated health effects are deemed
unacceptable now, their prolonged exacer-
bation due to dredging would be deemed
unacceptable squared. Additional mea-
sures to protect populations clearly would
have to be contemplated, presumably short
of evacuation but, also presumably, expen-
sive. Conversely, if PCB health risks are
acceptable today, what would motivate the
decision to dredge PCBs when natural pro-
cesses eventually will remove them anyway?
My scientific interest in dredging is fo-
cused primarily upon its health impacts
and primarily because USEPAs environ-
mental impact statement
1
systematically un-
derstates the amount of PCBs that will
enter the atmosphere from river water and,
therefore, understates the public health con-
sequences. The USEPA:
excludes dissolved and colloidal PCBs,
and also monochlorinated and dichlo-
rinated PCBs, from the inventory of
PCBs in river water;
overestimates the rate at which clay par-
ticles would remove adsorbed PCBs from
river water via precipitation; and
underestimates PCB concentrations in
surface water, the rate at which PCBs at
a given concentration on the surface
would enter the atmosphere, and the
temperature contribution to PCB vola-
tilization, especially in cooling towers
along the densely populated shores of
the river, because water in cooling tow-
ers is typically 1008 F ~388 C! hotter than
in the river.
Without credible scientific resolution of the
issues raised above, I conclude that the
dredging decision lacks scientific merit. The
emperor who loves new clothes, in fact,
has no clothes.
Notes
1. United States Environmental Protection
Agency, 1999 ~revised November 2000!, “HRA,
Mid- and Upper Hudson River, Phase 2
Report—Further Site Characterization and
Analysis,” Volume 2F—A Human Health Risk
Assessment for the Mid-Hudson River, Hudson
River PCBs Reassessment FS, TAMS Consul-
tants, Bloomfield, NJ, 30 pp. plus appendices.
Address correspondence to Robert A.
Michaels, President, RAM TRAC Corpora-
tion, 3100 Rosendale Road, Schenectady,
NY 12309; (e-mail) ram@ramtrac.com;
(Web site) www.ramtrac.com.
POINTS OF VIEW
DOI: 10.10170S1466046605050283 Points of View 139
ResearchGate has not been able to resolve any citations for this publication.
HRA, Mid-and Upper Hudson River, Phase 2 Report-Further Site Characterization and Analysis
United States Environmental Protection Agency, 1999~revised November 2000!, "HRA, Mid-and Upper Hudson River, Phase 2 Report-Further Site Characterization and Analysis," Volume 2F-A Human Health Risk Assessment for the Mid-Hudson River, Hudson River PCBs Reassessment FS, TAMS Consultants, Bloomfield, NJ, 30 pp. plus appendices.