Delaware Audubon Society


The Delaware Audubon Society is a statewide citizen organization whose mission is to promote an appreciation and understanding of nature; to preserve and protect our environment; and to affirm the necessity for clean air and water and the stewardship of our natural resources. We submit herewith, our concerns, comments and questions for the public hearing due to modifications of the existing plans to the Delaware River Main Channel Deepening Project.

We continue to contend that the deepening of the Delaware River Main Channel to a depth of 45 feet from the current 40 foot depth posses a long term health risk to humans. The act of dredging in and of itself stirs up sediment and reintroduces contaminates into the water which have previously settled into the sediment. These reintroduced contaminates are then taken up into the food chain by plants, animals, fish and other aquatic life. The Delaware River and its coastal zone areas have been and continue to be used for industrial transportation and production. The waters of the Delaware River and its sediment have been exposed to a large number and volume of heavy metals and chemical compounds, including PCB's.

The Army Corp of Engineers sampled all reaches for detection of 13 heavy metals, 22 pesticides, 7 PCB's, 29 volatile organic compounds, 12 acid extractable organic compounds, and 45 base neutral organic compounds. That totals 128 different contaminates possibly present in the river sediment in varying amounts.

The Army Corp of Engineers asserts that their sample testing shows none of the dredged sediment would contain harmful levels of contamination therefore, posing no threat to human health. Delaware Audubon disagrees. P.4-19, section4.1. To evaluate potential human health impacts associated with disposal of channel sediments, bulk data were compared to New Jersey Department of Environmental Protection (NJDEP) Residential, Non-Residential, and Impact to Groundwater Soil Cleanup Criteria. These criteria were established to provide a technical basis for evaluating levels of chemical contamination, and the associated risks to human health. Depending on the contaminant, the human health criteria are based on an additional lifetime cancer risk of 1 of 1,000,000 or 1 of 100,000. Delaware Audubon asks the question: If each of the above 128 contaminants pose an additional lifetime risk of cancer, what is the sum total of additional cancer risk to humans based on the levels of contaminants found throughout the project area? It is a well known medical fact that Delaware has one of the highest incidents of cancer nationwide.

P.4-5, section4.1. To summarize the large volume of data, samples collected within each reach were grouped and the mean concentration of each chemical parameter was calculated. P.4-6-4-31. Tables 4-2 through 4-8 shows the mean concentration of each contaminate in Reaches A through E as well as the detection range. By calculating the mean concentration and then using that calculation against the NJDEP standards gives a false appearance of falling within these standards. A more accurate method would be to compare each sample taken directly against the NJDEP standards. Upon examination of Tables 4-2 through 4-8 (Summaries of Bulk Sediment Sample Analyses giving detection ranges) against Tables 4-9 through 4-19 (Worst Case Mean Concentrations with NJDEP Residential Standards), we found that the detection range of the samples offered a better indicator of contaminate levels within each reach. For example, in Reach B where the Corp has only indicated two contaminates (thallium and cadmium) as being over NJDEP residential standards, the detection range shows that 6 of the 128 contaminates falls outside these standards.

Reach B: Forty-nine samples were taken.

Antimony was detected in 24 of the 49 samples with a detection range of 1.7-32.0ppm. The NJDEP standard for antimony is 14ppm. At least one sample exceeds the standard by 18ppm.

Beryllium was detected in 38 of the 49 samples with a detection range of 0.31-1.5ppm. The NJDEP standard for beryllium is 1.0ppm. At least one sample exceeds the standard by .5ppm.

Cadmium was detected in 19 of the 49 samples with a detection range of 0.11-4.0ppm. The NJDEP standard for cadmium is 1.0ppm. At least one sample exceeds the standard by 3ppm.

Lead was detected in 44 of the 49 samples with a detection range of 4.7-120ppm. The NJDEP standard for lead is 100ppm. At least one sample exceeds the standard by 20ppm.

Selenium was detected in 28 of the 49 samples with a detection range of 0.21-119ppm. The NJDEP standard for selenium is 63ppm. At least one sample exceeds the standard by 56ppm.

Thallium was detected in 13 of the 49 samples with a detection range of 0.17-9.0ppm. The NJDEP standard for thallium is 2ppm. At least one sample exceeds the standard by 7ppm. All concentrations presented in parts per million (mg/kg), dry weight.

We also found this to be true with samples of PCB-1254 and PCB-1248. Examination of Table 4-12 gives the appearance that all samples fell within acceptable standards by using the mean concentrations. However, when the NJDEP standard of .49ppm from Table 4-12 is compared to the PCB Data Summary of Bulk Sediment Sample Analyses (Table 4-4) the two before mentioned PCB's exceed the standards.

PCB-1254 was detected once at a level of 1.19ppm in Reach B. That exceeds the .49ppm standard by .7ppm. Likewise, PCB-1248 was detected once at a level of .53ppm in Reach B. That exceeds the .49ppm standard by .04ppm. On P.4-5 of section 4.1 the Army Corp of Engineers acknowledges that PCB's were detected in two samples at the concentrations given above. However, the Corp does not mention that these exceed the NJDEP standards.

The Army Corp of Engineers addresses water quality due to "stirring up" by the dredging process on pages 4-36-4-39, section 4.2 (Elutriate Sediment Analyses). Their data is inconclusive since they do not present the standards that they must meet. On page 4-39 that data is summarized in the following way. The few [contaminates] that were encountered were detected on a very limited basis. All concentrations were considered to be relatively low. The metals arsenic, copper, lead and zinc were the only contaminants detected in greater than 20% of the samples. Elevated concentrations of contaminants in Delaware River water resulting from dredging or dredged material disposal operations would be lower than the elutriate analysis results, as a result of mixing and dilution with the large volume of water in the river. We say this is faulty logic since not only will the volume of water increase so will the volume of sediment and the amounts of contaminants "stirred up".

The Delaware Audubon Society doubts the Army Corp of Engineers' assertion that dredging the Delaware River to a depth of 45 feet poses no health risk to humans. We have no way of verifying the data from elutriate sediment analyses however we do feel that the Corp's method of presenting data gives a false appearance of compliance.

We strongly believe our health concerns are justified. It is proven that the quality of the water does have an impact on the health of the plants, animals, fish and other aquatic life. It is also proven that contaminates from the water enter the food chain and can eventually have a negative impact on human health. For example, In Delaware, there is currently a health advisory in place for fish consumption due to extremely high levels of PCB's found in fish. One of the areas under this health advisory is the Delaware River from the C&D Canal north. Any stirring up of sediment would only reintroduce additional toxins back into the water thus aggravating an already existing problem.

In conclusion, the Delaware Audubon Society opposes the Delaware River Main Deepening Channel Project.

Leslie G. Savage
Vice President
Board of Directors
Delaware Audubon Society

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