Source Control Along the Willamette River Portland Harbor Superfund Site

1. Source Control Along the Willamette River Portland Harbor Superfund Site Dawn Sanders City of Portland Bureau of Environmental Services October 30, 2009

2. City of Portland Superfund Program • City’s Source Control objectives, approach, and watershed context • Portland Harbor characteristics • City program components • Source tracing for PCBs • Findings, successes, and challenges • Watershed planning and actions

3. Overall program objective: Identify and control sources to City conveyance systems to prevent recontamination Approach: Significant sources addressed at property Low-level sources addressed through state and local programs City Portland HarborSource Control Program

4. Portland Watershed Management Plan • Provides a scientific foundation and sets our future course • Integrates regulatory drivers with action-oriented strategies • Monitors progress • Integrated Management of: • Stream flow and hydrology • Physical habitat • Water quality • Biological communities • www.portlandonline.com/bes/watershed

5. Portland Harbor Drainage • Total Stormwater acreage ~ 12,000 • ~ 50% drained by City system • CSOs addressed by City CSO program

6. Portland Harbor Land Use • 57% Parks & Open Space • 33% Industrial • 10% Residential, Commercial, and Major Transportation (highways/freeways)

7. Stormwater Regulatory Coverage DEQ Cleanup Sites NPDES Permitted Sites

8. City Portland Harbor Program Components • Coordination with DEQ • Identification of sources • Bringing it back to the Watershed level -- Coordination on source control with other City and State programs

9. City/State Source Control Partnership • City partnering with DEQ, which is actively evaluating over 70 sites in PH • New sites traced to high contaminants  DEQ Cleanup • Coordination and review of site work • City administration of DEQ’s general stormwater permits • Evaluation of upstream sources • Source investigation and sediment sampling to assess whether additional source control is needed before Portland Harbor remediation

10. City Source Tracing Efforts • Broad spectrum of COIs being evaluated • Variety of solids and water sampling used to trace sources • Inline conveyance system data represent inputs from all sources upstream; patterns can tell us where significant sources are discharging to the pipe

11. Source Tracing Sampling Methods Inline Sediment Sampling • Grab samples • Sediment traps Water Sampling • Stormwater

12. Storm Main Can help identify key areas to focus further tracing efforts Lack of high concentrations may mean: No sources Non-representative sample Intermittent/seasonal source 98,000 µg/kg Use of Inline Data 6,770 µg/kg 1,242 µg/kg <50 µg/kg

13. How Ubiquitous are PCBs? • PCBs found at every land use • Concentrations reflect findings from traditional stormwater monitoring of metals and PAHs • Highest concentrations associated with current or historical industrial areas (48-9,900 µg/kg) • Lowest concentrations associated with open space (4 µg/kg) Example: Storm Sediment Traps

14. Finding High PCB Sources Sites with high PCBs identified through inline samples • Inline data within 13 industrial basins (some onsite data also shown for Metal Scrapper) • Inline concentration > 1,000 ppb indicates significant source (site data typically >>higher) • PCB sources from: • Current activities • Legacy activities • Unknown (site investigation needed) Drum Reconditioning Metal Scrapping Transformer Reconditioning Transformer Substation Former Automobile Shredding

15. Are PCBs Really An Intractable Problem? • Invested over five years of time and effort in source tracing and stormwater evaluation • What have we learned? • You can find low-level PCBs everywhere • In Portland Harbor, most high solid concentrations above 1,000 ppb within a conveyance system appear to be traceable to specific sites (Onsite data >> 1000 ppb) • Although PCBs are a legacy contaminant, they sometimes are associated with current activities • Finding and controlling the larger sources gives more bang for the buck • Sites without significant PCB sources generally <100 µg/kg

16. 7 PCB sites (+ 1 non-PCB site) entered DEQ VCP based on City source tracing work Additional sites identified for further DEQ or City action Changes in existing City and State programs to address sources Stormwater pathway now being evaluated at Cleanup sites Coordination between DEQ Cleanup and City Industrial Stormwater groups City Code changes – e.g., redevelopment and enforcement Successes in Source Control

17. Source identification and control efforts take resources and detective work Low-level contributions are harder to trace in-line; on-site data are needed Timing and adequacy of upland site stormwater characterization Long-term controls need to be resolved General stormwater permits don’t monitor for many Portland Harbor risk drivers Permits are associated with operator SIC, not with the site Challenges to Source Control

18. Prioritizing Source Control Activities • Start in areas with highest sediment contamination • Focus on source tracing/identification of largest sources • Manage stormwater as close to the source as possible • Control largest contributors under DEQ’s Cleanup Program • Use other State and City programs to address low-level contributors • Potentially adjust existing or create new programs to address long-term control of stormwater

19. CSO Tunnel Linking back to City Programs to address Watershed issues Many programs affect water quality • CSO Separation/Stormwater Controls • MS4 Permit Program • Industrial Permit Oversight and Assistance • Illicit Discharge Elimination Program • Spill Prevention and Response • Redevelopment • Watershed plans

20. City of Portland Development Standards – Stormwater Management Manual Manage stormwater as close to the source as possible to reduce or eliminate the volume of water and pollutants leaving the site. Chapter 4 provides guidance for known or suspected contaminated sites: • Requires additional review and assessment to prevent movement of contaminants offsite • Site contaminant data are required before approval • May require special handling of soils, collected groundwater and surface drainage

21. Spill Prevention and Response • City maintains a 24-hour complaint line • Incidences at contaminated sites may require heightened response and additional sampling • Coordination of response with DEQ site managers

22. Willamette Watershed Plan Watershed Health Goals and Objectives

23. Bringing it back to the Watershed Scale Willamette Subwatershed Planning • Characterization of each subwatershed to identify assets and problems • Identification of strategies and projects to address problems and protect assets • Ranking of actions based on predicted measurable improvements • Public involvement For more info: www.portlandonline.com/bes/subwatersheds

24. How can the City address Portland Harbor stormwater issues? • Only about half of Portland Harbor drains though a City conveyance system • Many City programs address only those areas within the City MS4 drainage area • New connection requirements • Storm pipe O&M • But many have broader application • Public education • Willamette Subwatershed plans • Need strong State support to address areas without local authority or to provide equity across landscape