Portland Harbor Superfund Site
Region 10 – January 2017

Record of Decision Community Summary

The United States Environmental Protection Agency has issued
the Record of Decision (ROD) that selects the remedy for the
cleanup of the Portland Harbor Superfund Site. EPA’s Proposed
Cleanup Plan for the Portland Harbor Superfund Site was
released for public comment on June 8, 2016. The proposed
plan was the result of many years of work to investigate the
site’s contamination and develop potential cleanup alternatives.
This proposed plan outlined these different cleanup alternatives
and presented a preferred alternative (Alternative I) to address
risks to people and the environment from contamination in the
lower Willamette River and its river banks.

Map sources: Esri, DeLorme, AND, Tele Atlas,
First American, UNEP-WCMC, USGS, DigitalGlobe,
GeoEye, i-cubed, USDA, AEX, Getmapping, Aerogrid,
IGN, IGP and the GIS User Community.

During the 90-day comment period, the public asked for
changes to the preferred alternative. Based on the public
comments, EPA modified Alternative F and selected it as the
final remedy. Alternative F Modified addresses many of the
public concerns and is still cost-effective.
The following information is provided in this
community summary:
  The site and its risks.
  Description of the selected remedy.
  Why the EPA chose another alternative.
  Comments about the cleanup.
  Outcomes of the selected remedy.
  EPA’s commitment to flexibility and cooperation.
  Next steps in the Superfund process.
For more detail, please refer to the ROD or attend one of the community information sessions that are currently planned
for March 2017 (see last page).

The Site and Its Risks
The selected remedy covers an approximate 10-mile stretch of the lower Willamette River in Portland, Oregon (see
map). It is a major industrial port area that was contaminated over the twentieth century by commercial and industrial
activities. EPA is working with the Oregon Department of Environmental Quality (DEQ), tribal governments, and other
federal and state agencies to address unacceptable levels of contamination in the river.
The Lower Willamette Group (a subset of parties potentially responsible for the contamination) conducted a remedial
investigation of the nature and extent of site contamination, evaluated the risks to people and ecological receptors
from the contaminants and summarized the information in a remedial investigation report that was revised by EPA in
February 2016. EPA determined the greatest health risk to people is from eating resident fish (like carp, bass and catfish)
from Portland Harbor and particularly to infants that are breast-fed by mothers who eat resident fish from the river.
Direct contact with in-river sediment and surface water may also pose an unacceptable risk. Of the contaminants that
pose the most risk to people’s health, polychlorinated biphenyls (PCBs-now banned) and dioxins/furans are the most
widespread. The most widespread contaminants for ecological risk are PCBs, polycyclic aromatic hydrocarbons (PAHs),
dioxins and furans, and the pesticide DDT (now banned). These ecological contaminants pose risks to mammals, birds
and benthic invertebrates (such as crayfish and worms).

 Portland Harbor Superfund Site – Record of Decision Community Summary

Description of the Selected Remedy - Alternative F Modified

The selected remedy addresses all areas where contaminant concentrations exceed cleanup levels through a combination of
dredging, capping, in-situ treatment (or treatment ‘in place’), enhanced natural recovery, monitored natural recovery (MNR)
and institutional controls (such as fish advisories and land use restrictions).
  Areas to be capped or dredged will be defined by remedial action levels (RALs), which are sediment cleanup

concentrations for a focused group of contaminants that pose the greatest risk.

  The remedy will include a total constructed area of 394 acres of sediment and 23,305 lineal feet of river bank, and will

allow 1,774 acres of sediment to naturally recover.

  The remedy includes 365.4 acres of capped and dredged contaminated sediment and 28.2 acres of enhanced natural

recovery. About 247.6 acres of sediment will be dredged to varying depths. The 23,305 lineal feet of river bank
excavation will be covered with a cap using beach mix or vegetation. Approximately 133 acres of sediment will be treated
‘in place’ (or in situ treatment).

  Dredged material (about 3 million cubic yards) will be removed from the site primarily by rail or barge, and less than 10

percent of the dredged sediment and river bank soil may require treatment prior to disposal.

  Work in the navigation channel generally will not begin until work in the adjacent areas managed under EPA authority

has been completed. This approach addresses source areas that continue to contaminate the channel and allows for new
information regarding the channel dynamics to be used to design the channel cleanup.

  The Oregon Department of Environmental Quality (DEQ) may also undertake action at some river banks that are

the subject of this ROD to expedite source control of contaminated upland areas, as necessary. Most of the known
contaminated groundwater plumes will be addressed by DEQ’s upland source control actions. EPA’s selected remedy
will address the portion of those plumes that extend into the river or continue to discharge contaminants to the river to
prevent further impacts to the river.

  Final selection of the remedial technologies will be included in the remedial design after collecting additional data

in all areas and segments of the river and using the criteria in the ROD. The in-river construction is expected to take
about 13 years, with no additional time required to complete dredged material processing (dewatering and sampling
before disposal).

Why The EPA Chose This Alternative

The EPA understands that public involvement is very beneficial
throughout the Portland Harbor Superfund process and that
community input was critical during the proposed plan phase
to ensure a better final decision. Additionally, the Superfund
statute and regulations require EPA to consider comments
from the state, tribes and the public, including the potentially
responsible parties, as well as any other new or significant
information developed or received during the public comment
period. Based on these considerations, EPA may alter or
change the preferred remedy while making its final decision.
Input was received from over 5,300 commenters during the
90-day public comment period. The responsiveness summary
(included in the Record of Decision) presents the comments
received and provides EPA’s responses. Comments seen most
frequently are shown in the box to the right. The vast majority
of commenters stated that Alternative I did not go far enough
to address contamination in the river.
Based on the comments received, EPA had to decide whether
to select the preferred alternative (Alternative I), select
another alternative presented in the proposed plan, modify
Alternative I, or modify another alternative presented in
the proposed plan. Ultimately, EPA evaluated modifications
to Alternative F under the nine regulatory decision criteria
and selected Alternative F Modified as the final remedy.
Alternative F Modified addresses many of the public concerns,
is protective of public health and the environment and is
cost-effective. The benefits of this alternative are presented
on the next page.

Comments About the Cleanup
The 10 most frequently seen comments were:
  The preferred alternative for cleanup does not

remove enough contaminated sediment.

  The remedy should ensure that unlimited fish

consumption was safe for all groups.

  Dredged material should not be placed in a

confined disposal facility in the river.

  Consider an alternative other than Alternative I.
  Ensure that those who caused the contamination

pay for cleanup.

  Ensure source areas are controlled.
  Improve insufficient environmental justice

response.

  Provide timelines and metrics for success.
  Ensure instream monitoring before, during, and

after remediation.

  Move quickly and don’t delay cleanup.

Please see the responsiveness summary in the final
Record of Decision for a complete overview of all the
comments received and the EPA’s responses. This is
available at http://go.usa.gov/3Wf2B.

 Portland Harbor Superfund Site – Record of Decision Community Summary

Outcomes of the Selected Remedy

The primary outcomes of selecting Alternative F Modified rather than Alternative I are:
  Increased Use of Active Remediation: Public concern was that Alternative I was too passive and that a larger
percentage of the river needed to be dredged. Alternative F Modified increases the area of active remediation
(dredging, capping and enhanced natural recovery). Additionally, to control migration of contaminants, 133 acres of
sediment will be treated ‘in place’ (or in-situ treatment). Dredging may increase from 150 to 248 acres and capping
may increase from 81 to 150 acres (not including 25 riverbank acres). Therefore, the area left for monitored natural
recovery is reduced. Thus, more of the persistent contaminants are removed from the river and from the food chain.
This will achieve greater risk reduction sooner.
  Protective of Human Health: Removal of more contaminants makes it safe for all but the most sensitive populations
(such as breastfeeding infants whose mothers eat resident fish) and subsistence fishers to eat more fish from the river
more often. Concentrations of mercury from sources outside the river will always require limits on fish-consumption.
Additionally, the final cleanup plan reduces the potential for direct contact with contaminants in the sediment.
  Protective of the Environment: Removal of more contaminants is also protective of wildlife (both resident and
migratory fish and birds).
  Simplified Use of Remedial Action Levels: RALs (sediment cleanup concentrations for a focused group of
contaminants used to define where to cap or dredge) will now be consistent throughout the majority of the site
(except in the navigation channel). Within the navigation channel, other RALs will be consistently used (please refer to
Section 14.2.1 of the ROD for more information about RALs in the navigation channel).
  Reduced Impacts Downstream: Less contamination will flow into the Columbia River and Multnomah Channel from
the site due to more contamination being removed.
  More Permanent: The cleanup will rely less on institutional controls (such as fish advisories and land use restrictions)
since it removes more of the contamination from the river.
  No In-River Disposal: There will be no confined disposal facility for dredged sediments in Terminal 4. On-site disposal
was unpopular with the community and the owner of the property also withdrew sponsorship of the location. All
dredged wastes will be disposed of off-site.
  Cost: The costs of cleanup will increase to approximately $1.05 billion. The cost is commensurate with the scope and
scale of contamination and with similar sites across the country.
  Economic Benefits: This final remedy will create jobs during active cleanup and will make riverfront properties
available for future re-development.

The EPA’s Commitment to Flexibility and Cooperation

Input received during the comment period emphasized the importance of EPA remaining flexible in implementing the
remedy at the site and the need for cooperation and communication among all parties. As a result, the EPA has included the
following in the ROD:
  Additional data collected for remedial design (see “Next Steps” on the last page) will be used to establish baseline
conditions and guide the design. The ROD provided for and specifies flexibility in the application of appropriate cleanup
technologies, based on criteria. Areas that are anticipated to require remediation may be modified or adjusted based on
new data and information. If contaminant levels in an area are below the remedial action levels (RALs) or other feasibility
study assumptions no longer represent current conditions, then the remedy will be adjusted in accordance with the ROD
and consistent with statutory requirements.
  During remedial design, if the reasonably anticipated land use designation is different from what was known in the
feasibility study, EPA may potentially adjust the remedy as needed. Changes will be made in accordance with the criteria
identified in the ROD. Any changes to the remedy that are not provided for in the ROD will be documented in a future
decision document, consistent with statutory requirements. Remedy changes may result in lower costs to the overall
remedy.
  The EPA will continue working with the state and (based on data collection results) may identify areas or sub-sites for
early action where the state and EPA may jointly oversee the cleanup actions.
  The EPA is also committed to developing a larger watershed approach because contamination issues exist in the
Willamette and Columbia river watersheds that are beyond the scope of this selected remedy. As a result, in this final
cleanup plan EPA and the Oregon Department of Environmental Quality have committed to working on a watershed
strategy that will enhance the remedy by reducing background levels of contaminants coming into the site.
The EPA will also continue its public outreach efforts throughout remedial design and remedial action. This includes continuing support and outreach to communities with environmental justice concerns that are disproportionately impacted by the
site, continuing to distribute information and gathering community input. EPA welcomes public input constructive to the
process, including ways to improve how fish consumption advisories and other institutional controls may be implemented.

 Next Steps - Remedial Design Sampling and Evaluation
The next step in the Superfund process is remedial design, which is where the technical details of the cleanup are
developed. Prior to and during design, additional sampling data will be collected to update baseline conditions and
support the design process. Data collection and other evaluations will be conducted in order to do the following
(among other things):
  Determine boundaries for the areas that will be dredged, capped, or have enhanced natural recovery (ENR) applied.
  Refine the delineation of contamination.
  Design remedial technologies, based on criteria in the ROD, and construction methods.
  Develop projections of natural recovery.
  Clarify treatment and disposal requirements.
  Clarify protection measures for aquatic and listed species during construction.
  Refine compensatory mitigation requirements.
  Update reasonably anticipated land and water uses, particularly related to maintenance or navigation dredging.
  Verify and consider area-specific conditions, such as the presence of active docks or other structures, caps and other

remedial activities already in place and river uses.

  Verify the future maintenance dredge areas.
  Determine where groundwater plumes are discharging and impacting the biologically-active areas or surface water.
  Identify which groundwater plumes will need to be addressed in the river by EPA (versus on land by DEQ).
  Determine the effectiveness of the upland source control measures in achieving the remedial action objectives and

cleanup levels in the ROD.

  Determine appropriate disposal of the dredged materials based on regulations or facility requirements. If the material

could go to a municipal landfill or similar landfill that is closer to the site, disposal costs could be lower than estimated.

Join Us at a Community Information Session
At the request of community groups and stakeholders, the EPA is planning to host community information sessions
to present the details of the final remedy in March 2017. Please visit the EPA’s website (http://go.usa.gov/3Wf2B)
for the most up-to-date details about these information sessions as schedules may be subject to change.

EPA Contacts, Information Repositories and Website
  Sean Sheldrake, Project Manager, 206-553-1220, sheldrake.sean@epa.gov
  Laura Knudsen, Community Involvement Coordinator, 206-553-1838, knudsen.laura@epa.gov

Site documents (including the full Record of Decision, Remedial Investigation, Feasibility Study, Proposed Plan and
various fact sheets, community summaries and other materials) are available on EPA’s website at
(http://go.usa.gov/3Wf2B) and at the three local information repositories listed below:
  Multnomah County Central Library, 801 SW 10th Avenue, Portland OR 97205
  St. Johns Library, 7510 N Charleston Avenue, Portland OR 97203
  Kenton Library, 8226 N Denver Avenue, Portland OR 97217