Dr. P.L. defur, technical advisor ESC, LLC estewards.com

Transcription

1 Dr. P.L. defur, technical advisor ESC, LLC estewards.com May 29 notes current FINAL S 1 - Title Slide- Thank you and I am here as an independent technical advisor for the community, a role that my firm serves for communities around the country. I have worked under contract to Duwamish River Cleanup Coalition Technical Advisory Group for more than 10 years to provide analysis and comments throughout the process. I have reviewed the Proposed Plan for the cleanup of the Lower Duwamish River and present some of my comments to you tonight. S2 - the list of issues- The Proposed Plan, including the Feasibility Study, presents alternatives that could be improved in several ways and there are several important points that must be addressed before the whole process is completed- all are listed here. S3 - Exposure pathways- I recognize that EPA considers the greatest health threat is from fish consumption, which I don t think anyone disputes. Yet full protection of human health from contaminants in seafood from the Duwamish River is not achieved, and protecting people from contaminants in the river in other ways, beach play, recreational activities, etc., may be marginal. 1

2 S4 -Remedy methods- Throughout t the country there are limited options for cleaning up contaminated sediments, --although I have to note for the record that other sites are piloting new methods this year- - and what we know is that removing the contamination is the most certain and permanent solution. I doubt that Natural Recovery will work for PCBs and dioxins. In this case of PCBs, arsenic, dioxins and furans, Natural Recovery is burial with new sediment deposition coming down the Green River. Institutional Controls are not a remedy, they are an attempt to control your behavior and keep you from or reduce exposure to the contaminants. S5- pie chart proportion of dredging etc- The greatest part of the acreage of the Duwamish will be left alone to sediment over-- more removal is needed. MNR should be changed to ENR or better. S6 - Sedimentation- "natural recovery"- the Plan has an overly heavy reliance on the river sedimentation process doing the work under circumstances that are not sufficiently understood or certain. Experience with MNR applied to chemicals such as PCBs, dioxins and arsenic is limited and has not been as successful as hoped over longer period of time. S7 - - Fish consumption sign- IC's are not reliable and are not a remedy- they are an attempt to control human behavior S8 - Cancer rate projections- 2

3 The models used in estimating results from implementing the Proposed Plan indicate decreases in PCBs in fish tissues, but not enough to reach MTCA criteria for safely consuming seafood at a rate that is usual for a Tribal child. S9 - Non-cancer effects projections- A Tribal child will face excess risks from non-cancer health consequences unless consumption of seafood from the Duwamish is cut to less than about once every other week! S10- Table of methods and achieving the endpoints This table from the Proposed Plan indicates that there is little difference in how long it will take to reach the endpoints given above for three f the options, but that the certainty and permanence of removal make a substantial difference. S11- EJ 1-Disproportionality 90% of the risks are being reduced for the WHOLE population BUT the VULNERABLE population who is UNFAIRLY exposed to risks from multiple locations need MORE risk reduction to OFFSET the cumulative risks. S12 - EJ Analysis recommendations 2- Recommendations for voluntary actions that have little or no specifics need more serious and active features with legally binding elements. S13 EJ 3- did not find this statement in the EJ Analysis 3

4 S14 - EPA figure of remedy, certainty, permanence- Insure It Works Permanence and certainty are greatest with removal. The greater use of MNR will reduce certainty and permanence. S15 - Remove more- Remove, instead of cap or cover, all highly contaminated sediments to ensure a successful, final and permanent cleanup. ENR applied for low level contaminated sediments- ENR needs to be used instead of MNR. S16- Dredging and MNR Dredging methods and equipment have improved and continue to improve, as seen on the Hudson R, Newark Bay, Delaware River, and other waters around the country. The monitoring data for dredging on the Hudson River and in Newark Bay indicate that dredging can be done properly without making a mess. These operations have been closely monitored. In contrast, MNR is uncertain, leaves contamination as a liability that does not break down- remember, the PCBs and dioxins do not degrade. And whatever is left behind requires long term monitoring. S17 - source control figure model- The Source Control work that ecology described is more than just a good effort. The source control effort is yielding result and results o 4

5 in the form of reduced pollution, lower levels of PCBs, arsenic, dioxins/furans and PAHs. We need the final Record of Decision to account for what happens when the present Ecology staff retire and move on. Ecology and King Co seem to be doing more- much more than is written, and that is good, because EPA indicated in the Plan that remedy actions will not begin until source control is sufficient. S18 - flowing out of pipe- EPA needs to insure that the source control is completed and in the watershed above the turning basin, where the Greens meet the Duwamish. S 19 Health Equity Because Seattle deserves A River For All! Our vision for the cleanup will create a healthy, thriving river that benefits all who are affected by its health. This includes: YOU residents of the area subsistence fishermen Tribes recreational uses Fish other wildlife Businesses industries and workers of the Duwamish Valley. 5

6 S 20-- monitoring pictures- Start monitoring fish PCB, dioxin and arsenic levels during remediation and measure young of the year and sport fish to assess short term and long term trends. Now is the time to collect data on the levels of contaminants in fish and shellfish as a baseline, as in some other site cleanup operations. During the remediation, measure conditions in the vicinity of the dredging and report on a web site daily, weekly, so that modification to the processes can improve the processes- look what was done and improved in Early Actions here and in the ongoing Hudson River with monitoring. S-21- Pollution Prevention Mitigate impacts on Tribes, fishing families, and residents by establishing a community health and revitalization fund (funded by the responsible parties). There is precedent in other parts of the country that have worked quite well. S 22- Health Equity Address the needs and health concerns of those who are on the river and depend on fishing S- 23-Create Jobs for the local community S-24- Deadline for Comments S- 25--Questions 6

7 - figure of certainty V permanence- EPAs own analysis admits in the Proposed Plan that the certainty and permanence are greatest with removal - Green River map- Source control is sufficiently important that it MUST be legally binding - in order to give ALL parties on the river some sense of certainty. At present, the source control is an appendix without legal enforceability. The final ROD has to have a way to make the source control enforceable so that when the present team of people is retired, the work will go on at least as aggressively if not more so with the foundation prepared today. Now, the other feature of source control that has to be counted in the overall effort is that the controls on PCBs and dioxins will include sediment controls, thus reducing the sediment headed downstream. 7