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| Remediation of the Fox
River Position The Wisconsin Paper Council strongly supports a cooperative approach toward remediating the Fox River. We also support conducting two pilot projects in an expeditious manner. The results of these studies, both analytical and monitoring, should be utilized by both state and federal agencies in developing a comprehensive remediation strategy. Furthermore, the Wisconsin Paper Council strongly opposes designation of the Fox River as a Superfund site.
Polychlorinated biphenyls (PCBs) are a class of chemical compounds which were first manufactured in 1929. They were widely used in electrical equipment, hydraulic fluids, carbonless copy paper production, and a wide variety of other commercial and industrial uses. The federal government banned the manufacture of PCBs in 1977 because of concerns over potential risks to human health and the environment.
PCBs have never been used in the manufacture of paper. They were, however, used as a coating in developing a type of carbonless copy paper that was manufactured in the 1950s and 1960s. Its use was voluntarily discontinued in 1971, six years before the EPA ban. Carbonless paper was a popular product used in offices throughout the country. Once discarded, the carbonless paper made its way into the waste stream...and was recycled by several paper manufacturers along the Fox River and elsewhere. During the timeframe when carbonless paper was recycled, there was no practical way to identify and separate PCB-contaminated wastepaper from the hundreds of thousands of tons of paper recycled by the mills.
From the mid-1950s to the mid-1970s, the manufacture and recycling of carbonless copy paper along the Fox River, along with the activities of municipalities and other industries, resulted in the release of PCB's to the Fox River. These wastewater discharges were legal at the time and regulatory authorities and the mills were unaware of the potential risks associated with PCBs. Estimates are that approximately 125 tons of PCBs entered the Fox River. Approximately 40 tons remain and are dispersed through 11 million cubic yards of sediment. More than 85 percent of the PCBs are buried below one foot of sediment and almost one-half are buried below more than three feet of sediment. Because of PCB contamination, advisories have been issued related to the consumption of certain species of fish and waterfowl.
Remediating the Fox River will be an extremely complex task inasmuch as PCBs are distributed over a 39-mile stretch at varying depths and concentrations. Recent studies show that in many areas concentrations are less than levels remaining after cleanup at other contaminated sites in the United States. The Environmental Protection Agency has announced its intentions to list the Fox River as a Superfund site. This announcement comes despite the fact that the Fox River Group (seven paper mills) and the DNR have agreed to undertake two pilot projects as a first step in developing a comprehensive remediation strategy. The companies have committed $10 million toward this effort. A Superfund designation is counter-productive as it is likely to result in a pro-tracted legal battle; delay cleanup of this valuable natural resource; create enormous and unnecessary financial expenditures; and deter economic development in the area. June 5, 1998
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