Presentation from Dr. Peter deFur, Environmental Stewardship Concepts
Dr. Peter deFur, technical consultant providing review of the Superfund Proposed Plan for the Portland Harbor Community Advisory Group, at a public forum on Tuesday, June 21st, presented what he sees as issues for the community to pay particular attention to, in our review and for comments to the EPA. Attached is the PowerPoint presentation from Dr. deFur.
Issues of concern in the initial ESC analysis of FS and Proposed Plan, including elements from the 2015 Proposed Plan. 6-21-2016
- Atmospheric release of PCBs is not included in any part of the EPA analysis or Proposed Plan. Recent research confirms that PCBs can be released into the air, that air can be a source of human exposure, and that exposure by inhalation can cause harmful health effects in people.
- State and Community acceptance is an important component of the final plan, and the state must concur with the remedy. We have no indication that the state is satisfied with the Plan, considering that the state will play a greater role once the remedy is complete. The community has rejected the Plan as inadequate.
- Tribal consultation and coordination seems to have been mostly, if not solely nominal. There is no indication that the Proposed Plan has been modified to meet the needs of tribes.
- Emerging technologies- treatment of dredged material is more viable than ever before and needs to be given greater attention in the Plan and FS. Newer treatments are available for riverbank contamination as well.
- Control of upland and upriver sources is necessary and not complete. The Plan indicates a more pervasive influx of contaminant from the sources on land, many or all of which are uncontrolled. This problem must be remedied with source elimination in the harbor and source control upriver.
- Contaminants left in river will largely remain for the foreseeable future. PCBs, dioxins/furans, DDx, and metals will not degrade. The Plan leaves a substantial amount of contaminants in the river and we seek an estimate of the mass of chemicals remaining.
- Confined Disposal Facilities have been opposed by the community since the concept was first raised. The community does not want to have a CDF in perpetuity.
- Monitored Natural Recovery has not been shown to effectively deal with contaminant that do not degrade, including metals, PCBs and dioxins/furans, among other chemicals. MNR can work on PAHs that can be broken down by bacteria.
- Time frame for estimated costs needs to be longer, at least 100 years, recognizing that the remedy includes monitoring in perpetuity. EPA also needs to estimate the economic benefits of a clean river, fishing boating, etc.
- Compliance with all standards, including drinking water and surface water standards (Clean Water Act).
- Restoration of any lost habitat needs to be a requirement of the final remedy. The Proposed Plan refers to restoration, and this restoration must comprehensively include actions following removal actions.
- Independent air & water monitoring during the cleanup must be instituted and include baseline data collected as soon as possible.
- More detailed/site-specific data will be obtained during the design phase and the ROD must be written to require removal that accounts for the data that will be collected.
- Hire locally from the Portland community.
- Fish contamination needs to be monitored to assess the changes with time and over space, beginning with a monitoring program now to establish a clear baseline.
- Environmental Justice is given little, if any attention, with no identifiable actions to protect communities that have suffered harm as a result of background, ethnicity or race.
|Community Mtg 6-2016 Prop Plan.pdf||1.62 MB|
|Issues FS- Proposed Plan.pdf||65.53 KB|