Retain the Record of Decision for the Portland Harbor Superfund CleanupThe Portland Harbor Community Advisory Group, Portland Harbor Community Coalition, North Willamette Watershed Council, Portland Audubon, Willamette Riverkeeper seek to retain the Record of Decision as originally issued by the EPA in December 2016. While an effort to change that plan is being pressed upon the EPA, that procedure does not conform to CERCLA law and Superfund process which says changes, additions or corrections should not occur or be adopted until the Five-Year Review. Benzo-A-Pyrene has been reevaluated by the EPA to state that while it definitely causes several types of cancer; the overall risk of cancer is lower than previously estimated This change benefits in particular two cooperating potentially responsible parties (PRPs); but it does not benefit the community at large. While we empathize with their desire to reduce overall cost of the cleanup, the Record of Decision as adopted was already a compromise that leaves contaminants in the river. To leave an additional 17 acres of PAH’s in the river to continue to affect wildlife habitat and human health is to benefit a few for the short term and not the many. Looking toward the future, health for all those affected, now and in the future still should take priority. The EPA Proposed Explanation of Significant Differences (ESD) explains a reduction in the amount of cleanup to be required in the Portland Harbor Superfund Site. EPA is accepting comments on the ESD until December 23rd. Attached here is material developed by community members for use in submitting comments. PAHinfosheet_print
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US Environmental Protection Agency
Attn: Portland Harbor Comments
805 SW Broadway, Ste. 500
Portland OR 97205
To whom it may concern,
I have several concerns in regard to EPA’s implementation of new toxic levels for benzopyrene (a) also known as BaP, on the Willamette River superfund site.
The concerns are as follows:
1) Because the chemical is concentrated in north Portland, it should be reduced to equal the rest of the urban Willamette for the sake of equity.
2) There is no information on skin contact even though Cathedral and Kelley Point beaches are affected by a hotspot. There is no assurance that beaches or swimming would be safe.
3) All activities such as swimming, boating, recreation, and fishing, should be considered in interpreting the change, not just dock work.
4) Pollutant mixtures that can be more toxic than the original pollutant. EPA has not studied mixtures and cannot give assurance that they would be safe.
5) Breakdown byproducts can be more toxic than the original pollutant. EPA has not studied break down byproducts and cannot give assurance that they would be safe.
6) Wildlife should be considered when interpreting the change. Leaving the chemical in river sediments where the chain of life begins, harms all wildlife.
Interpretation of BaP updated toxic values should help, not hinder the goal of a multi-use river as strongly expressed by the community in the Record of Decision. River access should be safe everywhere.