Link to Owner Dr. Robert B. Pamplin Jr.



Priorities must be set and met for remediation of Portland Harbor Superfund site

There is no doubt that the cleanup of Lower Willamette River sediments that pose risks to human health and the environment is important and necessary. After nearly 160 years of industrial discharges and urban use, there is contamination that needs to be addressed.

With information from 14 years of scientific study, the U.S. Environmental Protection Agency and the Lower Willamette Group have done a lot of work to characterize environmental conditions at the Portland Harbor Superfund site. The LWG has spent more than $110 million on technical studies, government and tribal oversight costs, and public involvement to support EPA’s selection and development of a proposed cleanup plan in 2016.

The LWG’s goal is to work cooperatively with EPA to move forward with a cleanup proposal that is protective of human health and the environment, achievable and consistent with federal and state laws and EPA guidance.

The cleanup should be focused on those areas that have the highest levels of toxic and persistent contaminants because it will have the most impact on reducing risks. The primary risks to humans are from long-term consumption of resident fish, such as bass and carp, not from recreational use of the river or the consumption of salmon.

Superfund’s goal is to reduce risks to human health and the environment. No level of sediment cleanup in Portland Harbor can eliminate all risks. In particular, it’s important to note that sediment cleanup in this farthest downstream portion of the Willamette River cannot remove fish advisories currently in place for the entire 160-mile main stem of the Willamette River (e.g., for mercury levels) or result in attainment of state water-quality standards for the Willamette River watershed. Some of the EPA’s proposed sediment cleanup goals for this site fall below background conditions, and therefore could never be attained.

The LWG has several priorities for the Portland Harbor Superfund site.

n Cleanup goals should be achievable — it would be impossible to clean up the harbor sediments to levels that are below background conditions from upstream.

n The remedy should be consistent with national Superfund laws and guidance.

n The cleanup should use a combination of proven technologies (dredging, capping, monitored and enhanced natural recovery) and keep the door open for new, innovative technologies. Mass removal of contaminated sediment by dredging should not be presumed to be the most effective cleanup option.

n More investigation and studies will be needed in the design phase before construction begins. The remedy proposed by EPA should explicitly allow flexibility for refinement and adjustment of technologies and process options when there is new information.

n The site study area is 11 miles long and should be divided into sections (known as operable units) to better focus the use of cleanup technologies for each area of the river.

n The preferred remedial alternative should be cost-effective. Its total cost should be proportional to its effectiveness in reducing risk. In addition, EPA’s cost assumptions must be transparent in order to support future agreements with potentially responsible parties to implement EPA’s selected remedy.

The process to allocate costs among potentially responsible parties already is underway and separate from both EPA’s remedy selection process and the LWG’s work, and is designed to ensure each potentially responsible party pays their fair share.

The overarching objective of an allocation process at a Superfund site is to identify fair shares of investigation, cleanup, long-term and oversight costs that should be paid by current and historical parties associated with the site.

This complex river system can be efficiently cleaned up by focusing active remedies on areas of the Portland Harbor site where contaminant levels present the most potential risk to humans, fish, wildlife and invertebrates.

Barbara J. Smith is the spokesperson for The Lower Willamette Group. The LWG is composed of the 10 parties who signed an agreement with the U.S. Environmental Protection Agency to conduct the Remedial Investigation and Feasibility Study (RI/FS) of the Portland Harbor Superfund Site and four other parties who have contributed financially to the project. The members are: Arkema Inc., Bayer CropScience Inc., BNSF Railway Co., Chevron U.S.A. Inc., City of Portland, EVRAZ, Gunderson LLC, Kinder Morgan Liquids Terminals, NW Natural, Phillips 66 Company, Port of Portland, Siltronic Corp., TOC Holdings Co., and Union Pacific Railroad Co. LWG website:

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