Lower Duwamish Waterway Superfund Site Proposed Plan Comments May 29, ESC, LLC Dr. Peter defur

Transcription

1 Lower Duwamish Waterway Superfund Site Proposed Plan Comments May 29, 2013 ESC, LLC Dr. Peter defur

2 Comments on behalf of DRCC/TAG Human health not protected- equity What happened to non-cancer? Permanence and Certainty= removal Too much IC EJ needs real action Source control not enforceable Sedimentation and sources Monitoring during cleanup- website updates

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4 Institutional Controls no fishing Few options to clean up the river... Dredging: removal Capping: cover Enhanced recovery: additives Natural recovery: Let It Be

5 Preferred Alternative Remediation Elements 62% % % Dredging Capping Enhanced Natural Recovery For more comparison of alternatives see Proposed Plan, Figure 14 pg % Monitored Natural Recovery The Preferred Alternative (5C Plus) will address approx. 412 acres Not including 29 acres of cleanup in Early Action Areas (EAAS)?Institutional Controls such as fish advisories?

6 Natural recovery has problems uncertain and not permanent

7 Institutional Controls not remediation, poor effectiveness

8 Excess Cancer Risks for PCBs 1 in 1E E-03 1 in 1E-04 10,000 Excess Cancer Risks for PCBs for Tribal Child Risks at LDW baseline concentrations The shaded area indicates EPA's acceptable excess cancer risk range under CERCLA. The dotted line indicates the MTCA threshold for individual carcinogens. 1E-05 1 in 1,000,00 1E E-07 1 in 100,000,00 1E meal every other month 1 meal per month 1 meal per week 3 meals per week* Source: EPA, Hiltner, April 5, 2013

9 Non-Cancer HQs for PCBs Non-cancer hazard quotients for PCBs for Tribal child HQ at LDW baseline concentrations HQ at model-predicted steady-state concentration The dotted line indicates the CERCLA and MTCA non-cancer threshold meal every other month 1 meal per month 1 meal per week 3 meals per week* Source: EPA, Hiltner, April 5, 2013

10 Protect Health Quickly, as much as possible For the Long Term

11 EJ Analysis: Recommended offsets to reduce cumulative impacts Seafood consumption (many ideas) Reduce exposure over time (habitat restoration, source control, stormwater, etc) Green infrastructure (trees, rain gardens, etc) Jobs

12 Our concerns about EJ Analysis Cumulative Risks Source control is an EJ issue ICs are for fishing issues only but SP/GT have other concerns (beaches) Risk reduction does NOT mean that the gap in unfair contaminant distribution between general population and GT/SP goes away Beyond voluntary EJ efforts: source control, EJ concerns, jobs, health screening, more

13 Discrepancies between EJ analysis and Proposed plan Proposed Plan (page 87) says: EPA s EJ analysis determined that the preferred alternative balances the need to reduce human health risks quickly while providing certainty that the methods used in cleanup will be effective and will remain effective in the future We did not find this determination in the EJ Analysis

14 Removal Containment Natural Recovery Treatment Disposal Engineered Caps Enhanced Natural Recovery Monitored Natural Recovery $$$ High Cost and Construction Impacts Low $? Low Uncertainty High???

15 Remove all highly & moderately toxic sediments Certain Permanent Eliminates Future Costs & liability Enhance Recovery For all lowlevel Toxic sediments More protective Less uncertainty faster

16 Dredging Can be Done Right, MNR is uncertain at best Lessons from other rivers: James River Hudson Delaware Extent of experience Dredging v NR New methods/equipment

17 Source Control from many places

18 Integrate & enforce pollution source control goals More protective & cleaner

19 Protect Fishing Communities without endangering Health & Culture Promote Health Equity Environmental Justice

20 Monitoring during Cleanup

21 Create a Pollution Prevention & Mitigation Fund Until Goals are met

22 Create Jobs! Hire Locally!

23 Comment deadline: June more days!

24 Questions?????