Doug Tomchuck
U.S. Environmental Protection Agency
Superfund Division
C/O Hudson River PCB Site
290 Broadway 19th Floor
New York, New York 10007


Dear Mr. Tomchuck:

Federated Conservationists of Westchester County, Inc. strongly supports the Environmental Protection Agency's findings on a proposed remediation plan for the Hudson River pursuant to its reassessment under the Superfund law. Much work has been done to restore the Hudson River over the past decades. Unfortunately, the dumping of over one million pounds of PCB's directly into the river by General Electric has made the Hudson the country's largest toxic waste site. It is time for the PCB's to be removed and for General Electric to help clean up this unique American treasure.

· The Hudson River is not "cleaning itself" of PCBs. Scientific studies have shown that less than 10% of PCB mass has been reduced by dechlorination over the last 20 years and that PCB's are most often in the top nine inches of sediment. Five hundred pounds of PCB's flow over the Federal Dam at Troy and disperse in the Lower Hudson annually. Without active remediation, the PCB"s will remain in the river.

· PCBs remain an unacceptable health risk for residents and wildlife in the Hudson Valley. PCB's are designated as probable carcinogens and are know to cause neurological, reproductive, and endocrine problems, including dampened intelligence and attention deficit disorders. Along the entire length of the river, recreational and subsistence fishermen and their families continue to eat their catch, despite health advisories, with consequent health risks.

· EPA's proposed cleanup would dramatically improve the health of the river. By removing 100,00 pounds of PCB's from the areas where they are most concentrated, the risk to human health and fish would be reduced.

· EPA's preferred remedy is removal (targeted dredging) of 2.65 million cubic yards of contaminated sediment containing over 100,000 pounds of PCBs from "hotspots" in the Upper Hudson River using dredging techniques which minimize adverse environmental impacts. We support active environmental dredging and urge the EPA to employ suction dredging insofar as possible. We also urge the EPA that prior to commencement of PCB dredging the final design plan provide that techniques be used that minimize resuspension of the PCB's, that the PCB's be covered when transported, and that safe disposal techniques and facilities be utilized.

We, in Westchester County, are entitled to have the Hudson river restored. We are entitled to have a pollution free river that is safe for all recreational and commercial uses. We urge the EPA to complete the Hudson River Reassessment as expeditiously as possible and issue a Record of Decision.

Respectfully submitted

Edna Sussman
Executive Director