Jim McKenna
Superfund Project Manager
Port of Portland
121 NW Everett
Portland, OR 97209
Dear Mr. McKenna:
The Oregon Center for Environmental Health appreciates the opportunity to respond to the Lower Willamette Group’s Round 2A Field Sampling Plan. In general we share the EPA’s criticism that the number of sampling sites, (68 sediment surface chemistry and 27 bioassays) is scientifically indefensible and would leave the clean up process and the community with little understanding of the contamination levels or the threat to public health and the environment. We support the EPA’s recommendation for 535 sediment surface chemistry samples and 200 bioassays.
The Center also has concerns about intentions for subsurface sediment sampling. In a meeting on December 5, 2003 with members of the Community Advisory Group, the LWG highlighted their commitment to the site investigation by complying with EPA’s recommendations for surface sediment sampling and bioassays, but neglected to tell the group about their disagreements with EPA over subsurface sediment sampling. It was only when members of the group asked about borings and fate and transport issues, did the subject get addressed.
The LWG Workplan proposed Round 2B subsurface sediment sampling based on historical areas of channel scouring and the results of Round 2A surface sediment sampling which could result in no subsurface sampling at all. EPA has recommended 276 subsurface sediment locations at a depth of at least 20 feet. Our experts recommend sampling at this depth and greater to be sure that we are looking at areas of historic contamination that would not be revealed with shallower sampling. It is also possible that toxics at these levels may be covered for now but released later through erosion. Sampling should be done until depths are reached that are clean in order for the public to be assured that the clean up is adequate. For these reasons, determining the nature and extent of contamination in sediments at depth should be the focus of field chemistry sampling prior to the selection of the RI/FS and clean up process.
The Oregon Center for Environmental Health would like to see the LWG move forward with this effort by producing work plans and sampling plans that are integrated, thorough, and show a serious intent to clean up the harbor. We want to stress that it is not EPA’s role to tell the group how to put together the clean up program. Rather the onus is on the polluting companies to create the plan through the use of consultants and review of past efforts of a similar nature in other parts of the country. This failure has caused delays and frustration for everyone involved and we will look for final work plan and sampling plan that addresses all of EPA’s concerns, the Willamette Riverkeepers comments, the CAG comments as well as the Center’s concerns.
We are also aware that the Port of Portland, which is taking a leadership role in the clean up process, has not scraped channel deepening plans and we will be monitoring the development of the final work plan to ensure that the Record of Decision is not driven by those needs over the interest of the public and the environment.
Sincerely,
Executive Director Board of Directors