The EPA’s Region 10 is analyzing comments from approximately 5300 individuals on its “Proposed Cleanup Plan for the Portland Harbor Superfund Site” and plans to release a record of decision (ROD) by the end of the year.
Region 10 encompasses Alaska Washington Oregon and Idaho with headquarters in Seattle.
The 90-day public comment period extended from June 8 to August 8 with a 30-day extension to September 6 granted. The comments were received via emails hard copies web submittals and oral testimonies at four EPA public meetings.
The Port of Portland and the 10-member Lower Willamette Group (LWG) of which the Port is a member – have objected to elements of the proposed plan stating that it gives the responsible parties no ability to assess the most economical and environmentally effective method for each location but rather levies a rigid definition of the dredging and capping areas and dredging amounts with no leeway for applying site specific methods commonly used in cleanup projects.
Kelly Madalinski who is on the Superfund team at the Port of Portland said “(The EPA’s) plan is not affordable and we can come up with equally protective but more affordable solutions.”
The port has submitted a 25-page response with detailed feedback on each point in EPA’s plan giving better alternatives.
One concern the stakeholders have is the massive size of the site which would require unwieldy organization if implemented as one project.
“We prefer breaking the site into smaller project areas instead of one big project focusing on discrete sites as individual cleanup projects” Madalinski said. That recommendation was included in the port’s response.
“The EPA is focused on dredging only. We want to use alternative technologies and the effectiveness of natural recovery and continue to evaluate and adjust as needed versus removing an enormous amount of material” he said.
“We hope they take into consideration our comments which will result in a faster just as effective and affordable cleanup” Madalinski said.
LWG FORMED TO PROVIDE FEASIBILITY STUDY
Barbara Smith is the spokesperson for LWG and has worked on the project for 15 years under contract to the 10-member group of Potentially Responsible Parties (PRPs) who will be responsible for the cost of remediation in their portions of the site. It is a small sub-group of the 150 total PRPs she said.
The LWG consists of Arkema Inc.; Bayer CropScience Inc.; BNSF Railway Company; Chevron U.S.A. Inc.; City of Portland; Evraz Inc. NA; Gunderson LLC; Kinder Morgan Liq-uids Terminals; NW Natural; Phillips 66 Company; Port of Portland; Siltronic Corporation; TOC Holdings Co.; and Union Pacific Railroad Company all of whom have activities along the river that have contributed to the contamination either recently or in the past. The group signed an administrative order with EPA in 2001 to prepare a feasibility study for cleanup of the site. Working with Region 10 LWG sampled the water and sediments in the affected part of the river and prepared a report analyzing the human and ecological health risks. The cost of this work was $114 million paid for by the LWG members.
In its 70-page response to the EPA Plan LWG stated its support of the cleanup objectives in the plan but goes on to say that the plan will “require at least five to seven years of baseline sampling extensive design and planning and whose construction (dredging and capping) will likely take 14 years or more to complete.”
The response goes on to say that EPA’s assessment of risks makes unrealistic assumptions about exposure to contaminants and that it re-quires cleanup of areas not identified as a problem in the risk assessments.
“Based on its extensive effort to investigate the site LWG believes a more realistic cleanup plan would take a much shorter time to construct attain comparable risk reduction … and cost far less than EPA’s preferred alternative” the statement continues.
“The LWG’s work is done” Smith said. “We have provided the studies to the EPA. Actual cleanup will be negotiated with the individuals.”
SITE INCLUDES 12 MILES OF RIVER
The Port of Portland has occupied the lower 12 miles of the Willamette River since the mid-1800s and has added contaminants to the river through in-river activities and through commercial activities on the waterfront. The riverbanks water and river bottom are contaminated with polychlorinated biphenyls (PCBs) polycyclic aromatic hydrocarbons (PAHs) dioxins/furans pesticides and heavy metals.
The Lower Willamette River from the Broadway Bridge (RM 11.8) to Kelly Point Park (RM 1.9) was added to EPA’s National Priorities List and added to the Superfund program in 2000. Plans for the eventual cleanup with several interim in-water cleanup projects and a point-source pollution abatement program in effect by the City of Portland have been formulated and put into effect since then.
The proposed EPA plan relies heavily on dredging operations that will remove cap and treat contaminated sediment in situ.
The plan document describes the Remedial Action Objectives (RAOs) necessary to protect human health and the environment in five categories or “exposure pathways”: sediment biota surface water groundwater and river banks. To achieve these goals EPA plan spells out eight alternative plans including No Action as alternative A. Alternative B is EPA’s suggested final plan. A summary of this alternative is as follows:
• Dredging (different depths): 72.2 acres – 494000 to 659000 cubic yards
• Excavation: 51000 cubic yards
• Capping area: 22.8 acres
• Ex-situ treatment: 156000-208000 cubic yards sediment and 9500 cubic yards soil
• In-situ treatment: 6.7 acres
• ENR (enhanced natural recovery): 99.8 acres• MNR (monitored natural recovery) 1966 acres
• Capital costs: $352 097000
• Periodic costs: $290324000
• With DMM (dredged material management) Scenario 2: $451460000
• Construction duration: 4 years
• DMM scenario 2 includes only off-site disposal.
LWG’s draft Feasibility Study (FS) evaluating the cleanup options for contaminated areas of the Lower Willamette River was submitted to EPA in March 2012. The draft Remedial Investigation Report (RI) was submit-ted by LWG to EPA in 2009. The reports are the result of cooperative working relationships between LWG and EPA the Oregon Department of Environmental Quality and federal state and Tribal trustees. It also reflects ongoing public involvement with and outreach to the Portland community which contributed many comments all taken into consideration in the final reports.
EPA’s investigation and analysis showed that contamination found in the river sediments is associated with multiple sources in and upstream of the site. Sources include agricultural and urban development industrial activities and both past and current discharges and runoff into the river. Impacts to fish and wildlife in and near the river have been caused by physical changes and chemical contamination.
The 151-page Proposed Plan is available for download at: https://semspub. epa.gov/work/10/100020143.pdf