A discussion about the fuel tanks in the Critical Energy Infrastructure (CEI) Hub in Linnton and its relations to risk management within Portland Harbor and the Willamette River. We are revisiting this topic of the CEI risk because of the importance for our community to know how it relates to the clean-up effort, risk and responsibilities, and protocols in the event of human-caused damages to the Willamette River in Portland Harbor Superfund.

CAG Board Members

Michael Pouncil, Chair

Doug Larson

Sarah Taylor

Scott Burr, Tech Advisor

Number of Participants: 47


Susheela Jayapal – Multnomah County Commissioner
district2@multco.us, 503-988-5219


Jonna Papaefthimiou- Planning, Policy, and Community Programs Manager Portland Bureau of Emergency Management
jonnap@portlandoregon.gov, 503-823-3809

Caleb Shaffer, EPA Region 10 Portland Harbor Team Lead

shaffer.caleb@epa.gov, 503-326-5015

Lauren Wirtis Oregon DEQ’s Regional Public Affairs Specialist Wirtis.Lauren@deq.state.or.us, 503-229-6488

Doug Larson

Welcomes Commissioner Jayapal and asks her to convey our best wishes to her sister in the U.S. House of Representatives.

Michael Pouncil

Welcome to guests and participants. Signatures are coming in up and down the river in support of remedial design of the Superfund Site. $1.3 billion has been designated for this cleanup and to ensure that there are mechanisms in place to protect against seismic and other events.


Sarah Taylor

The Braided River Campaign has received a grant for local artists to create portraits of people who once lived in the Lower Willamette River. Examples of representation are a village of Chinese farmers on the river and a person working on WWII industry.


Land Acknowledgement: We honor and acknowledge the peoples who lived in relationship with the river, lakes and wetlands for more than 15,000 years. We commit to the healing and restoration of this stretch of river with a deep commitment to racial healing.


A Brief History of the Area: We look at the tank farms without thinking of what was there before. Tribes were living there next to a working waterfront. Lewis and Clark spent time there. The land was stolen from the tribes and was given to people from all over the U.S. The Linnton area (CEI hub) included Scandinavian, Japanese and Chinese. There were dairy farms along what is now HWY 30. The Chinese villages were burned by the Ku Klux Klan. Portland banned tank farms but in 1929 Linnton was not part of Portland so that’s where these tank farms were installed. Additional tank farms have been installed since, declaring eminent domain to take land for commercial reasons. The town of Linnton was torn down with the promise of a river-front town, but the promised land use was diverted for additional tank farms. The 350+ tanks are an acknowledged risk, built on unstable landfill. The Lower Willamette River is shallow and is inappropriate for an international seaport.


Susheela Jayapal

Thank you to Sarah for the Land Acknowledgment and for the art project.

Multnomah County’s role – the risk, in the event of a natural disaster to the tanks, is huge. We know that spills are likely. We are charged with assessing, quantifying, and developing mechanisms to ensure that the liability of such an event rests with the owners and operators of the tanks in the hub. We’ve commissioned a study, Eco Northwest, to work on this analysis. Phase 1: Engineering analysis, looking at infrastructure, how it could fail, etc.

Phase 2: Community Engagement. taking into account the impacts on people’s daily lives. This will consist of at least 3 meetings with community participation. We will also include the tribes, who have treaty rights. We will also engage with down-river partners, all the way to Astoria.

Phase 3: Mechanisms to reduce the risks. Risk-bonding, requiring owners and operators to set aside monies in the event of a problem, with the understanding that no amount of the money is comparable to lives and property lost. Our main objective is to reduce risk, increase incentives to owners and operators to reduce underlying risks.



Jonna Papaefthimiou

My main charge is in assessing risk and in response planning – and how the city can be a strong partner with residents. The CEI hub (Linnton) – so much could go wrong. We are looking at a 25-30% likelihood of the subduction seismic event. 90% percent of the jet fuel, liquid diesel, gas in Portland are stored in the CEI hub. The City works with consultants in studies, soil-boring, bringing that information to the City. The City has control over building codes and land use, can use oversight on older, compromised structures. The City has less authority to insist on a retrofit of the pipeline. We can lobby the city for changes that will allow for more regulation. The risks we face now are unacceptable.

Q&A for Susheela Jayapal and Jonna Papaefthimiou

Q: How are the owners and operators contributing to the planning for risk now?

A: It’s at this point a city and county effort. We expect some resistance. This is not a scenario that owner/operators have been planning for.

Q: The City of Portland, before annexing Linnton, asked their tank farm to move out of Portland. In Commissioner Jayapal’s risk-bonding incentives, can owners/operators be required to simply relocate to a safer location? In Juneau Alaska a tank farm was moved from a residential area to an unpopulated area. Has there been discussion for siting a new location for the tank farm?

A: Haven’t heard that conversation. We don’t want to export the problem to another residential area, and a relocation would be redesigned to account for seismic risks. We need to move away from fossil fuels for everything, do we need to build another huge hub, or a smaller hub somewhere?


Q: How does this work on the risk bonds translate into future working with the City.

A: The City has passed fossil fuel zoning, and the tank farm can’t be expanded. What we don’t see is the future of the CEI hub, no real plan. These tanks have been there for 100 years and some probably need to be decommissioned. We don’t have this vision yet.


Q: We have the tanks built on silt sand, dangerous. Waiting for a vision beyond fossil fuel, will be too late if there’s a seismic event. Given that fact, what legally can this committee do, now, with these owners to reduce risk, now? We need a legal avenue. It’s our lives, our river. Can we get a plan with teeth, how can we do this?

A: This won’t go as fast as anyone wants but we hope to get started in that direction. We’ve not been quantitative about it. Having data can, hopefully, provoke the city to take action. Data can also empower residents to take action. This is an essential first step in order to set up regulation.


Q: Does the City have any control over requiring owners and operators to replace old, compromised pipeline?

A: The pipeline is controlled by the Federal Government. We could just retrofit it to the city limits but it needs to be bigger than the City of Portland.


Comment: I see 5 steps: study, risk assessment, bonding, retrofitting. I think those 350 tanks need to be moved. They are in the worst possible place, in the middle of population. Procrastination has to end. The tanks have to be moved. Retrofitting is unacceptable, would not make a difference in an earthquake. Move them to Eastern Oregon and truck the gas.


Comment: From Linnton – thank you to City and County for advocating for addressing these issues. The tanks should relocate because of tremendous risk. There have been many studies which were submitted to the tank farm owners last November, have not received a response.


Q: How many tanks are empty vs. how many are full? How much oil in these tanks are used by Portlanders, how much is exported?

A: Hard to know how the fuel is used, use varies at different times of year. Each is used at least a little bit, or they would be decommissioned. Most fuels in these tanks are jet fuel, diesel and gas.




Caleb Shaffer, EPA

EPA, Working with the team for the cleanup of Portland Harbor Superfund Site.

We don’t’ have the authority to move tank farms, rather we are involved in inspection with a set of regulations, written into the Clean Water Act, and Spill Control and Counter-Measure Regulations. Those plans present what a spill would look like and result in planned secondary containment of spill, maintenance records, training in the event of spills. If regulations aren’t followed there are penalties.



Lauren Wirtis, DEQ

Prevention is where attention should be focused. DEQ’s role comes into play after a spill has occurred but they’re committed to also prevent spills. We often go into inspections together with EPA. DEQ’s emergency response team would be deployed after a spill event. Committed to continue moving this forward, including getting the responsible parties (PRP’s) to fund this. DEQ does not have authority to insist on relocating tank farms but they are supportive of this work.

Q&A for Caleb Shaffer and Lauren Wirtis

Q: Can you speak frankly about what is possible for EPA to address these risks? Financial, eco-systems, dangers.

A: With a new incoming administration, we’re encouraged that we’ll have some support for these programs and increased authority. We are implementing regulations laid out by Congress.

Specifically, the Superfund Site, we have been able to move forward with 70% of the site actively planning for cleanup, a monumental task.


Q: You both commented that EPA and DEQ collaborate on tank inspections. Concern: We had a dry summer last year, 5 months without rain. Given how catastrophic a fire could be, reports are conflicting about how summer heat pushes gases out of the tanks into the atmosphere. Some tanks, but not all, have devices to remove volatile emissions. In the event of a fire, what keeps those tanks from exploding? Concern about fire, as well as earthquakes? Also how many inspections do you conduct in a year? Who is responsible for preventing an accident, rather than damage management after? The oil re-recyclers have been operating with expired permits for many years. DEQ is underfunded and understaffed – There doesn’t seem to be any contingency planning for an outside source, rather than within the tank farm.

A: Scrubbers and emission control devices are installed in tanks that release volatiles. Can’t say for sure what would happen if Forest Park caught on fire, with wind. The strategy would be to keep the fire as far away from the tanks as possible. A valid concern. You make a good point.

Oregon State Fire Marshall has a Local Emergency Planning Committee, related to hazardous storage.


Q: Does FDRC have a role in pipe-laying and tank farms?

A: Possibly DOT has a role, not sure what the details are.


Q: Who is in charge of prevention? DEQ = cleanup. Once those tanks rupture, it’s too late. The river will be destroyed. The tanks sit on unstable ground.

When there was a truck that went off of St Helens’ road, it exploded and caught fire. Fire trucks rushed over, had difficulty finding what chemicals had been released. Who is charged with knowing which chemicals they would be dealing with?

A: The State Fire Marshall has information on what is in the tanks, information is available to first responders and to a limited degree, to community members.


Q: Linnton is the most at-risk neighborhood for wildfires. Why isn’t prevention of liquification a part of the scope of prevention?

The railroad is becoming a switching yard – they go all night long, a big fire hazard adjacent to the tank farms.

A: The City struggles – much of the infrastructure at the CEI hub was there before permits were even issued. How do we force them to retrofit? Should be possible but will be expensive. But much cheaper than cleaning up after an event.


Comment: Portland Fire & Rescue has said that our biggest fire risk will come from HWY 30. The tank farms are on the east side of HYW 30.


Q: How much leakage or safety violations have been attributed to the tank farms? Has this been monitored?

A: EPA: when there’s been a release of hazardous materials, it is submitted to a database. There is an 800# than anyone can call. EPA inspected Zenith terminals in summer of 2019. There are current plans for other inspections


Q: Part of the resistance to moving the hub has been the selection of a new location. The pipelines would have to pass through tribal lands. Also, can EPA or DEQ help come up with better sources of energy?

A: DEQ – the deep-water port comes together with the rail lines, runs at full capacity. If it were moved along the Columbia River there could be ways to reroute the pipeline away from Linnton.

It would be faster to build an alternative to fossil fuels than to relocate the tanks.


Q: It’s my understanding that the remedial design plan is underway for the CEI hub? Also, that design area combines letters and numbers that is difficult to understand. Can you simply add the name Linnton to describe the area of remedial design?

A: There is contamination in the river in that area, a lot of the same contaminants (PCBs, CIHs).

And yes, we can amend the name to include the name Linnton. We’ll keep that in mind for future handouts and communications.

Along with the Local Emergency Planning Committee, there is the Northwest Ares Regional Response Team that community members can get involved with.



Michael Pouncil

Closing: Thanks to all presenters and participants. Be careful, check in on your neighbors. This is a challenging time. Look after each other and be careful.

Portland Harbor CAG

Contact: Michael Pouncil at 503.705.7224, mpouncil@comcast.net

Notes taken by Jane Terzis