Time to Restore not Destroy
In the year 2000 the Portland Harbor was designated as a Superfund Site by the US EPA. Since then extensive studies have been completed to determine the extent and nature of pollution in this section of the river, to determine the ecological and human health risks from this pollution, and to determine how it can best be cleaned up to protect future ecological and human health. I serve as Chair of the Portland Harbor Community Advisory Group.
The US EPA is currently completing their review and revisions of the Portland Harbor Feasibility Study. This study lays out options for how the Portland Harbor will be cleaned up. The Portland Harbor is a large and complicated site, meaning that no single solution will fit all areas to be cleaned. Over the next several months the US EPA will be making decisions regarding the cleanup. The first fundamental decision will be to essentially draw a line designating what areas of the river need to have some kind of action taken. This line is determined by setting Remedial Action Levels (RALs). For the various contaminants in the river, a level is set at which action must be taken. For example, the EPA could say any area of sediment that has more than 500ppb (parts per billion) of a certain contaminant needs to be treated.
Once the line is drawn, the next decision is how to treat it. Some areas will need to be dredged, some might be appropriate for capping, other areas might have some kind of in situ treatment that would work. The draft Feasibility Study produced by the Lower Willamette Group includes heavy reliance on Monitored Natural Recovery (MNR) or Enhanced Monitored Natural Recovery.
Personally, I break Monitored Natural Recovery into three parts:
- Natural attenuation, which is the actual break down of chemical contaminants over time into other non-toxic compounds. This is what we would ideally hope to see happen over time, unfortunately the chemicals that need to be cleaned up in the Portland Harbor are persistent chemicals that take a tremendous amount of time to naturally break down. Most of these chemicals have been in the river for 50, 70, 100 years. If they were going to naturally break down in any reasonable amount of time, it would have already happened.
- What I term "Monitored Natural Removal", which is the physical process of contaminants in the Portland Harbor moving down stream to other areas of the river. This is certainly not a solution, as all it does is move contaminants from one area to another and dilute them. Many of the chemicals we are concerned about cleaning up are bio-accumulative, which means it does not matter where or how diluted they are, they still accumulate into the food chain affecting both ecological and human health.
- What I term "Monitored Natural Covering", which is the physical process of new clean sediments being deposited in the Portland Harbor burying contaminants deeper below the river bottom. While this process is helpful temporarily, it does separate the contaminants from the food chain, it is temporary. Any significant event, an earthquake, a flood, prop scouring from a turning ship, can remove the clean sediments and expose the contaminated sediments.
"Enhanced" Monitored Natural Recover is a step better since it takes an additional action to add some kind of treatment to the sediment. Most likely the form of this treatment would be to amend the sediment with activated carbon (or with Bio-Char) which will improve the binding of contaminants so that the contaminants are no longer as free to release into the food chain. This is an improvement over MNR (which could also be termed "do nothing"), but is also not a complete solution.
For material that is dredged from the river, the next decision to be made is what to do with it. Sometimes dredged material can be treated to break-down or remove the contaminants. Even if it is treated, the material is not simply returned to the river, it must be taken somewhere. If it is treated, there may be a wider variety of options for where the material can be taken for disposal or reuse. If material is too heavily contaminated, and is not treated, it will need to be taken to a disposal facility that can accept that kind of material.
One option for disposal of material that is being considered in the Portland Harbor is the creation of a "Confined Disposal Facility" (CDF) at Terminal 4 Slip 1. What are the advantages of this? It allows for lower cost disposal of material, since it does not need to be shipped (truck, train, barge) to a distant disposal facility. What are the disadvantages? Material gets stored next to the Willamette River, with the risk that it will leech back into the groundwater and river, the risk of earthquake or flood releasing material back to the river, and the destruction of additional fish habitat in the river. While engineers can work on designs to protect the river as much as possible from re-contamination, no design will make up for the loss of fish habitat.
The proposed design, as it stands now, is referred to as a "flow-through" berm. This means that the area will not be lined, and ground water will be allowed to flow through the material, with water flowing through the berm in either direction. Given this design, it is critically important that the material contained in the facility does not release contaminants back into the ground water and river.
How do you avoid re-contamination? Either require that material placed in the CDF is clean material, or ensure that contaminants in the material are bound up such that they will not be released.
If material is required to be clean before it is placed in the CDF, it must either have been clean enough when removed from the river, or it must have been treated in some way to make it clean. Material being removed from the river, is being removed because of the danger it poses by the fact that it currently releases contaminants into the river. So, if the material is such that it must be removed from the river, placing it in a CDF next to the river, with a flow-through design, would continue to allow contaminants to be released into the river, but perhaps diluted over a longer period of time.
Material dredged from the river may be treated in some way, to break down or remove contaminants, and then placed in the CDF. Treatment of material is a great choice, and would allow for the CDF to contain clean fill, relieving us of the risk of future re-contamination of the river. Unfortunately available treatment options have not been fully explored. It is often noted that the costs or the space requirements for treatment don't gain a great advantage over disposal at a waste site, since even if material is treated and considered clean, there are still limited places that will accept anything that originated from a Superfund site.
Another step that could be taken, is to line the CDF with an activated charcoal product, essentially creating a charcoal filter which will capture and bind up contaminants before they can escape. This is a very promising option as it reduces the risk of re-contamination, although it still is essentially just putting the contaminants in storage.
Regardless of what may be done in the design of a CDF to protect the river, this project still fills an off-channel area of river which serves as habitat for thousands of fish. Unfortunately there are no readily available studies of fish behavior, especially sturgeon, in this area. From speaking with people who fish in the area, and who troll through the slip with their fish finder radar, they have observed that the shallower waters of the slip are used by common resident fish (Bass, Crappie, etc) while the deeper water is used by sturgeon. Just off the end of the slip is a deep hole where sturgeon live during much of the year, and in the winter they move into the off-channel waters of slip 1 where it is warmer than in the deep hole.
My primary concern is that since we currently know so little about sturgeon behavior, and sturgeon habit requirements, I would not want to destroy an area that sturgeon are currently using. As anyone who fishes for sturgeon knows, the season for sturgeon fishing is being reduced to zero due to the already precariously low populations.
Even the Natural Resource Trustees Council proposed restoration plan has very little proposed for sturgeon restoration, simply because so little is known about what habitat will best benefit them. It seems to me that the first step in protecting sturgeon should be to avoid doing more harm to them. The lower Willamette River has already been changed substantially by human action, filling wetlands, moving channels, and destroying natural fish habitat. The river needs to be cleaned up, to stop the ongoing damage to ecological health, and efforts must be made to restore lost habitat for fish and other wildlife. We should also do this in a way that does not further destroy existing habitat.
If you agree that a CDF would be the wrong choice for disposal of material dredged from the Willamette River you may sign an online petition. This petition is addressed to the Governor of Oregon in his capacity as a member of the State Land Board. In order for the CDF to be constructed, a portion of the "submerged lands" (Willamette River) must be purchased from the State of Oregon. The Port of Portland submitted a request regarding that purchase, but it currently is on hold until the EPA makes a final decision to allow the CDF. Purchase of the land would require approval of the State Land Board, which consists of the Governor, the Secretary of State and the State Treasurer. These three statewide elected officials could end any prospect of the CDF by denying the sale of the river bottom.