Boyd: Dredge or not, the problem won't go away

Daily Gazette, The (Schenectady, NY)

January 14, 2001
Section: Opinion
Edition: Schenectady Albany; Final
Page: F-01

Dredge or not, the problem won't go away
GORDON BOYD For The Sunday Gazette
"Clean up the Hudson River. For our Families, For our Future." So urges the message on the signs, visible from many a roadway in our region. A simple message. A simple hope, but a vain one.

The cost: dredging and hauling millions of yards of PCB-contaminated sediment to landfills from Niagara Falls to Alabama, strip mining a million or more tons of sand and gravel from local pits to replace the river sediment, conversion of 20 miles of natural riverscape into an industrial waterfront, removing hundreds of acres of soil and vegetation alongside and below the water line.
The missing benefit: safe fish. The dredging project will fail to reduce PCBs in Upper Hudson fish to safe levels for the foreseeable future. EPA's own report says so at Table 7-5 in Volume 2 of its six-volume plan.
Yes, PCB concentrations in Upper Hudson fish are projected by EPA to decline after the dredging. But not enough in much of the river to meet the agency's own health safety threshold for at least 60 years, and maybe never. That would be at or beyond the time this year's high school graduates enter nursing homes.
Until 2070, and probably longer, average concentrations of PCBs in Upper Hudson fish will make them unsafe for unrestricted human consumption. By then, the fishing and consumption restrictions will have been in place for nearly a century.
In short, the "benefit" of dredging the Hudson is this: no foreseeable change in the fishing rules for the lifetimes of most people alive today.
The only way
And to be at risk from PCBs you MUST eat the fish; there is no other way. EPA says none of the other ways people could be exposed to the PCBs pose a risk, whether drinking river water, coming in contact with sediments or breathing the air nearby. Only from eating fish, a voluntary activity, easily avoided.
If you invested the $460 million that the dredging and habitat removal is estimated to cost, you could take the interest income and buy a five-ounce serving of fish for each and every one of the million or so residents of the Capital Region every week forever. We'd never have to bother the Hudson River fish again.
EPA and the dredging advocates want to involuntarily protect us from a voluntary risk, and to do so at great cost to the river, the surrounding countryside and its residents.
So just what is the risk from eating fish that contain concentrations of PCBs in the levels of a few parts per 10 million, the risk that EPA can't make go away?
EPA's risk analysis concludes that if a hypothetical adult angler eats 31.9 grams of such fish every day for 40 years, he will elevate his cancer risk by one in a thousand, an increase that exceeds EPA's standard of one-to-10 in a million (for involuntary risks).
EPA appears to apply the same cancer-increase-rate criteria to avoidable, voluntary fish eating as it does to risks we can't possibly avoid, such as air pollution. Why? If a risk is avoidable, subject to informed choice, or is taken only by volunteers, why do we need EPA's $460 million protection plan?
Eating fish from the Hudson is a risk that nearly everyone avoids simply by observing common sense and the current regulations. The remedy EPA offers is one that will inflict unavoidable economic and possibly environmental harm to people and communities up and down the river, all of whom are safe from the PCBs if only they avoid eating fish. For me, not eating Upper Hudson fish is a lot easier than remembering to wear sun block.
And if the government is going to go to such lengths to protect us from voluntary risks, then why is tobacco not a banned substance, carrying a lifetime risk of 252,000 deaths per million?
Risk will remain
Finally, by EPA's own analysis, the dredging plan will fail to eliminate the supposed risk anyway.
Upon this house of card-like assumptions and speculations EPA's dredging order is built.
The recommendation here is to leave the PCBs in place unless and until conclusive evidence shows a meaningful health benefit from their removal and a less destructive removal technique is developed. Meanwhile, allow General Electric Co. to pursue its plans for eliminating further migration of PCBs from onshore and bedrock sources into the river, a step that will lead to reduced fish concentrations, albeit a few years later than from dredging.
The current situation is anything but a public health emergency. The river will be no worse off for waiting another decade or so. The people and communities of the Upper Hudson will definitely suffer for years if the dredging goes forward, and few of us will live to see the only benefit that would make such a grandiose disruption worth the cost: safe fish.
P.S.: By the way, if you're looking in EPA's six-volume study for schematic drawings of the Northern and Southern Transfer Facilities planned for sites near Schuylerville and Hudson Falls, let me know if you find them. They're listed in the Table of Contents for Volume 2, Figures 6-1 and 6-2, but those pages are something else entirely, at least in the volumes on reserve at the Saratoga Springs Public Library. Could it be they were removed from the EPA study at the last minute because of their political sensitivity, or is this a dumb mistake by the engineering consultants and a proof-reading breakdown at EPA?
Gordon Boyd lives in Saratoga Springs and is a regular contributor to the Sunday Opinion section.

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