Portland Harbor Superfund - PUBLIC COMMENT NOW OPEN! MAKE YOUR VOICE HEARD by September 6th! See details below
Willamette Riverkeeper (WR) has been, and remains, the lead advocate for the cleanup of the Portland Harbor Superfund site. Superfund (CERCLA) is a federal law that requires those who have liability for polluting our river to clean it up in order to reduce health risks to people and wildlife.
WR advocates for a robust cleanup, works to educate the general public about this issue, and gets people on the river in this area on a regular basis.
The US EPA released the Draft Cleanup Plan for Portland Harbor on June 8th. From now to 5pm on September 6th, you can write the EPA to let them know what you think of their plan, and to make recommendations to them directly. Whether you write 2 sentences, or 20 pages, your input is officially counted!
Q: Why does pollution in the river matter?
A: Pollutants such as PCBs, DDT, and oil-based contaminants were released into the Willamette River for decades, and collected in the river bottom across a 10 mile stretch of river. The pollutants are also found in riverside lands. These and other pollutants can increase the risk of cancer for people who eat resident fish on a regular basis. The pollutants can also have negative impacts on a range of wildlife, from fish and baby river otters, to shorebirds and Osprey. Much of it is very toxic, and needs to be removed from the river!
Those who have liability for the pollution in our river are required to clean it up under the federal Superfund law, or they must pay to clean it up. There are over 100 different entities who hold liability in relation to Portland Harbor.
WR recommends the following points to include in your comments to the US EPA (See Contact info below for the EPA email and web page):
- Adopt Alternative G with enhancements to improve the long-term effectiveness of the cleanup.
- Select disposal options that do not include a Confined Disposal Facility and that do include treatment of dredged sediment to breakdown or bind contaminants.
- Because Institutional Controls (IC) are not effective, especially in the long term, EPA needs to reduce the need for ICs, and include in the ROD provisions for PRPs covering the costs of ICs, and provisions for evaluating the IC effectiveness with regular program modifications.
- Monitored Natural Recovery (MNR), with or without enhancement has not been shown to be effective and therefore EPA needs to reduce the use of MNR, enhance the monitoring to annually, and include provisions in the R.O.D. for contingency actions if monitoring data indicate unsatisfactory performance results.
- Accept the new technology options that will reduce costs and improve long term effectiveness. These may be conducted as pilot projects.
- Include atmospheric transport in analysis of exposures. This inclusion will indicate the extent to which remaining contamination will expose humans in the community to unacceptable risks.
- Require the state of Oregon to continue upland sources control via legally enforceable means; the current text indicates that this approach “May” be taken.
- EPA needs to require installation of environmental and quality of life monitoring during the construction phase, with the PRP’s covering the cost. This provision needs to be a required element and clearly stated.
- The Community needs regular opportunities for input during the construction phase of the cleanup.
- The general goals and design characteristics/requirements of the fish tissue monitoring need to be specifically listed in the R.O.D.
- Habitat restoration following remedy construction needs to be a required element in the R.O.D. Aquatic habitat that is disturbed by the remedy must be restored and the full cost paid by the PRPs. When nearshore and intertidal habitat has to be removed, it must be replaced and replanted with SAV that thrives.
- This remedy will have features that must be maintained in perpetuity and thus analyses need to account for a longer time frame in estimating costs and benefits.
- The community expects the final remedy to comply with state environmental quality, especially the water quality criteria for the PTW contaminants. PCBs, dioxins and DDTs in water and fish must meet state water quality standards.
- When the data are obtained for the remedial design, these must be shared with the community.
- This site presents characteristics of an Environmental Justice community, yet EPA has not addressed this issue. EPA needs to assess the EJ aspects of this site and take appropriate action to enhance protective and remedial measures.
- The final result of the cleanup should be the lifting of the Fish Consumption Advisory related to PCBs for the Portland Harbor area by a specific date.
- The US EPA should lead the cleanup effort after the ROD, not the State of Oregon.
- Sediment should be removed from the Swan Island area rather than implementing a massive input of carbon as a treatment.
As part of any comment you send to the US EPA make sure to remind them that this is YOUR river!
You can submit your comments directly to the US EPA, Region 10 office by:
- Email: firstname.lastname@example.org
- Web: EPAs on-line comment form (scroll to bottom of page)
- Traditional mail: Attn: Harbor Comments, U.S. EPA, 805 SW Broadway, Suite 500, Portland, OR 97205
Send in your comments to the US EPA today! See below for more details about this stretch of the Willamette River and the Superfund process.
The Portland Harbor Superfund site is a highly contaminated stretch of the Willamette River that extends approximately 10 miles, near the confluence with the Columbia River to the Fremont Bridge. In 2000 this area was designated a Federal Superfund Site under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). This means the federal government has recognized this portion of the Willamette among the most polluted sites in the nation. Clean and healthy rivers are part of the Public Trust that holds that our rivers are held “in common, and belong to all.” Our river should be clean and healthy, to benefit all of us.
Check out this interactive map to learn more about the area: www.heywillamette.org
Those who hold liability for the cleanup are legally called Potentially Responsible Parties (PRP).
The Cleanup Timeline to Date:
- Remedial Investigation: Identified the extent and type of contamination. (Completed.)
- Feasibility Study: Proposed Cleanup options, and evaluation of options. (Released by PRPs in March 2012 but finalized by the EPA in 2016.)
- Proposed Draft Cleanup Plan: (Released by the US EPA June 8, 2016) Outlines the specific approach to the cleanup. Official public comment period opens, enabling the EPA to receive feedback from the general public. (June 8 through August 8)
- Record of Decision: The final plan that directs the Cleanup process. ( LATE 2016.)
- Cleanup Actions and restoration. (2017 and beyond.)
There are a variety of pollutants in Portland Harbor, including polychlorinated biphenyls (PCBs), metals (cadmium, lead, zinc), dioxins, furans, polycyclicaromatic hydrocarbons (PAHs), arsenic, DDT and mercury. Some of these are also found in riverside “upland” areas.
Many of these pollutants are byproducts of past industrial activities. An example of this are PCBs, used decades ago, which now comprise one of the most widespread pollutants found in the river. Once released into the environment, many pollutants like PCBs take decades to breakdown and remain in the river with the potential to harm the health of fish, wildlife and people. These pollutants may react together in the environment to create even more toxic compounds.
Here are the top three ways these contaminants can harm the people and wildlife in our community:
- Consumption of resident fish and shellfish taken from the Portland Harbor.
- Infant consumption of breast milk from mothers who are exposed to contaminants.
- Bioaccumulation: Contaminated sediment is eaten by plankton, which are eaten by bottom-feeders, which are eaten by fish, which are eaten by humans, birds and mammals thus harming all life forms along this line.
PCBS, DIOXINS/FURANS, DDT, AND PAHS WERE DETECTED IN MOST SAMPLES OF VARIOUS FISH AND INVERTEBRATE SPECIES COLLECTED. CONCENTRATIONS OF THESE POLLUTANTS VARIED GREATLY WITHIN AND BETWEEN SPECIES, WITH FISH TISSUE CONCENTRATIONS GENERALLY GREATER THAN THOSE IN INVERTEBRATES.
Who is responsible for the Cleanup?
The Environmental Protection Agency (EPA) is responsible for overseeing the Superfund process on behalf of the public and is taking the lead with the in-water portion of the Cleanup. The Oregon Department of Environmental Quality is taking the lead on uplands next to the river to ensure more contamination does not make its way to the river. The EPA oversees DEQ’s work.
Over 100 companies along the river have some responsibility for the pollution. The City of Portland and the Port of Portland also share some liability. Based on the Polluter Pays Principle, these Potentially Responsible Parties (PRP) that either directly caused the pollution or purchased contaminated property, are responsible for the cost and cleanup the pollution. The federal government expects purchasers of industrial lands to do their due diligence before acquiring property and the costs of cleanup are factored into the decision to purchase the property. In 2000 a subset of the PRPs called the Lower Willamette Group signed an agreement with the US EPA to lead the research of the contaminants, then formulate cleanup options in a document called the Feasibility Study (FS). Today the US EPA is taking leadership for finishing the FS and creating the draft Cleanup Plan expected in 2016.
HOW WILL THE POLLUTANTS BE CLEANED UP?
There are several options for cleaning up our river. These options include:
- Removal of Sediment from the river environment and placing it in a landfill.
- Capping leaves pollutants in place and actively covers them with clean material (often including layers of clay, rock, and sand). This method includes many years of monitoring, and may provide less certainty in relation to human, fish and wildlife health.
- Alternative Treatments can include biochar, carbon enhancements and other emerging approaches that treat sediment both in the river, and once it is removed. These are still in their experimental stages and are unlikely to be the primary strategy.
- Natural Recovery simply leaves pollutants in place and relies on the river’s natural sediments to cover up the pollution over time. This is the least protective for the river.
None of the Cleanup options are perfect. Given that there are miles of contaminated sediment, the impact of the decision of whether to remove sediments, cap them, or leave them untreated, is significant. The final solution must adequately protect people and wildlife.
Estimates for cleaning up the Superfund site range from $300 million up to over $2 billion. These companies have profited over the decades from the river, and now it is time for them to invest in the Willamette’s health and restoration. This is our opportunity to ensure that the Willamette River will be clean and healthy for future generations
Clean and Healthy Rivers are linked to a healthy and robust economy. A clean and healthy river is a community right - one that residents of the city of Portland are being denied today. This ten mile reach is contaminated with a high degree of pollution such as PCBs, heavy metals, oil based products (known as PAHs), and DDT which all need to be removed.
Since its listing under Federal law as a Superfund site in December of 2000, significant progress has been made determining the nature and extent of this pollution. The Superfund process is now in its final phase, which will determine how the river will be restored to health. Simply put, in 2016 it will be time for the community to make sure the pollutants are removed properly and adequately for the health of our community, wildlife and economy. The public must provide feedback to the US EPA NOW!
WR believes that the more public comment we have on this issue, the better. Please consider making formal comment to the EPA.
To date, here are some key notions that must be part of this cleanup.
- We must remove as much contaminated sediment as possible from this area, beyond what is required in Alternative G of the Feasibility Study.
- We must limit the amount of Monitored Natural Recovery throughout the site.
- We must have fish that are safe to consume, without raising cancer risk for people, when the cleanup is complete.
- We must utilize capping technology, where clean materials are put over contaminated sediments to hold them in place only where it is technically feasible, and where it will never impede navigation. We must also realize that capping has costs for the long-term with perpetual monitoring that adds to the cost of such measures.
- We must ensure that when sediment is removed from the river in this area, that it is disposed of safely.
- We must also ensure that polluters pay for their full share of the Cleanup.