A not-so-super cost estimate

Oct 10, 2016

At $746 million, the EPA’s lowball price tag for cleaning up the Portland Harbor Superfund site is ‘wishful thinking,’ according to one important critic.

By Richard Massey Managing Editor

The Environmental Protection Agency recently released its feasibility study for the remediation of one of the nation’s most complex superfund sites, the harbor along the Lower Willamette River in Portland, Oregon, and was roundly criticized for botching the cost estimate.

The 10-mile stretch of waterway, contaminated by PCBs, PAHs, DDT, and heavy metals, has been an ongoing source of conflict and environmental planning since at least 2000, when the site was designated as a superfund. But the EPA, in announcing its preferred $746-million remediation plan – limited dredging and capping, and a predominance of monitored natural recovery – only raised more questions.

The biggest of which, based on comments from interested parties, seems to be this: How did you come up with your numbers?

The City of Portland, the Port of Portland, and the Lower Willamette Group, a consortium of businesses potentially liable for the river’s pollution, all said the cost estimate is way too low. Since those entities could end up paying the lion’s share of the cleanup costs, the price tag for them is a key point of emphasis. And the EPA, they say, got it wrong.

“The City believes the proposed plan underestimates the actual cost of the Alternative I by as much as 50 percent to 100 percent,” says the city in response to the EPA’s plan.

Taking the city’s estimate into account, the cleanup cost would look more like $1.1 billion to $1.5 billion. So where, according to the city of Portland, did the EPA go wrong?

“The City is concerned about the accuracy of the EPA’s proposed plan cost estimates, particularly the assumptions about construction parameters such as sediment management area footprints, continuous dredging, volumes dredged and thickness, and/or types of capped layers,” the city says.

While Portland ultimately called the plan a “reasonable starting point to move forward with the cleanup,” the city also acknowledged that “the cost evaluation presents a misleading estimate of the total remedy cost to the public, and could impact the willingness of performing parties to step forward and lead the larger cleanup effort.”

Annie Von Burg, a senior program manager with Portland’s Bureau of Environmental Services, says that while the city’s comments are strong, they are meant to improve the overall plan, not impugn the EPA.

“We recognize there are a lot of uncertainties around cost at these early stages,” Von Burg says. “This is one of the most complicated sites in the country. We’re confident EPA can adjust those numbers to be more accurate.”

Referencing the undergirding sentiment in Portland, a city known for its environmental awareness, Von Burg says, “In general, there’s been a wide array of comments, from ‘This plan is not enough,’ to ‘This is too much,’ and everything in between.”

More than 140 potentially responsible parties have been identified by the EPA as polluters. And at some point, the cost for the cleanup will have to be divvied up among those found to be liable. As that scenario unfolds, the Lower Willamette Group will remain on center stage. Composed in part by important companies like Arkema Inc., Bayer CropScience, BNSF Railway, Chevron USA, and Union Pacific Railroad Co. – companies that could bear the brunt of the cleanup cost – the Lower Willamette Group, or LWG, has already spent in excess of $100 million doing its own assessments of the superfund site.

And the group is not happy with the conclusions arrived at by the EPA.

In its request for a dispute resolution regarding the EPA’s feasibility study – a dispute resolution that does not include the city of Portland or the Port of Portland – seven members of LWG had this to say: “EPA’s estimated costs for performing each of the alternatives continue to omit significant cost elements and dramatically understate other cost elements on the basis of unrealistic and in some cases impossible assumptions about dredge production rates and volumes, remediation waste processing, engineering design, construction management, best management practices EPA intends to require, and the present value of money.”

The Zweig Letter was unable to reach the EPA for a statement.

The agency is under pressure to address the comments from Portland stakeholders and produce a record of decision by the end of the year. Adding to the urgency surrounding the Portland Harbor Superfund, Von Burg says, is the looming presidential election between Hillary Clinton and Donald Trump. Regardless of who wins, the new president, among many other obligations, must appoint an EPA administrator, a move that could potentially stall the Portland project for years if the record of decision is not in place before the new administration moves into the White House.

“This is one of the largest economic and environmental issues facing Portland,” Von Burg says. “The stakes are high.”

Once the record of decision is in place, the engineers and planners can move in and begin designing and implementing the plan.

“That’s the next phase of this whole thing,” Von Burg says.

Other mega waterway sites being overseen by the EPA include the Hudson River in New York, the Lower Passaic in New Jersey, and the Lower Duwamish in Washington State.

The Lower Willamette River in Portland has been an industrial waterway for over a century, and has been redirected, straightened, filled, and deepened, and its shores have been raised, filled, stabilized, engineered, and armored to accommodate commercial activity. A working harbor that handled 8.3 million in total tonnage last year, the Port of Portland supports thousands of jobs and generates millions in state and local taxes. Major tenants include Schnitzer Steel, Georgia-Pacific, and Del Monte Fresh Produce. With so much to gain, and perhaps to even lose, with a site-wide cleanup, it’s not surprising that the port chimed in on – and criticized – the EPA’s plan.

In particular, the port objected to a CDF, or confined disposal facility, at Terminal 4, a 262-acre area with seven berths.

“We are not interested in taking on long-term management of a facility that our neighbors adamantly oppose, and one with uncertain economics and risks,” the port says in a September 6 press release.

LWG, which sponsored a 950-page report on the superfund – a report researched and authored by Windward Environmental, Kennedy/Jenks Consultants, Integral Consulting, and Anchor QEA – seemed perturbed that the EPA allegedly deviated from an agreed upon, collaborative process to reach its own conclusions.

“EPA’s preferred alternative is the product of illusory goals for cleanup and wishful thinking related to time and costs and is not a sensible, reliable solution,” says LWG.

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