Comments on Proposed Rulemaking for National Priorities List

Confederated Tribes and Bands

of the Yakama Nation

November 3, 2021

U.S. Environmental Protection Agency EPA Docket Center Superfund Docket Mail Code 28221T 1200 Pennsylvania Avenue NW Washington, D.C. 20460

Established by the Treaty of June 9, 1855

RE: Bradford Island, Cascade Locks, OR (Docket ID No. EPA-HQ-OLEM-2021-0462) Comments on Proposed Rulemaking for National Priorities List

Dear Environmental Protection Agency:

With this letter, the Confederated Tribes and Bands of the Yakama Nation (Yakama Nation) is providing its attached comments to EPA on the proposed rnle published in the Federal Register on September 9, 2021 , proposing the addition of Bradford Island (Docket ID No. EPA-HQOLEM-2021-0462) on the National Priorities List pursuant to the National Contingency Plan (NCP), 40 CFR Part 300. 86 Fed. Reg. 50,515. The Yakama Nation strongly supports the proposed NPL listing of Bradford Island, which is vital to Yakama enrolled members as one of many usual and accustomed treaty fishing places in the Columbia River Basin.

The NCP at § 300.425( c )( 1) authorizes EPA to include a site on the NPL if it scores sufficiently high on the Hazard Ranking System ("HRS"), 40 CFR Part 300 Appendix A Data collected in 2011 and 2020 indicate that PCB levels in fish tissue remain elevated by orders of magnitude above human health and ecological risk based criteria. Site data collected after EPA's previous HRS ranking in 2000 indicate a significantly more alarming magnitude and extent of contamination and ongoing exposure at Bradford Island. It is our understanding that EPA has recently reevaluated the Bradford Island facility using toxicity information from more recent sampling data, resulting in an HRS score of 50 that now exceeds the threshold for NPL listing.

Aside from the HRS, Yakama Nation has previously communicated to EPA that the U.S . Army Corps of Engineers (Corps), the lead agency at the Bradford Island site, has been either unable or unwilling to plan, manage, or execute a cleanup of Bradford Island that is protective of human health and the environment. The attached comments document the current state of affairs at the site, the culmination of over two decades of Corps cleanup mismanagement that has left the Columbia River with continuing fish consumption advisories and lingering questions about the extent and gravity of hazardous contamination. As a result of these problems, Yakama Nation, the Oregon Department of Environmental Quality, and the Washington Department of Ecology jointly requested that Bradford Island be added to the NPL in October 2019. Given the current data and the potential exposure to sensitive populations, it is clear that

Post Office Box 151, Fort Road, Toppenish, WA 98948 (509) 865-5121

the contaminants of concern at the Bradford Island facility continue to pose a serious threat to human health and the environment requiring thorough investigation and expedited remediation. Yakama Nation fully supports proceeding with promulgation of a final rule that includes Bradford Island on the National Priorities List in Appendix B of the NCP, and appreciates the opportunity to comment on this very significant EPA rulemaking. Please contact Rose Longoria, Regional Superfund Projects Manager, at (509) 865-5121 x6365 if you have any questions regarding these comments.

Delano Saluskin Chairman Yakama Tribal Council

Attachments: Attachment A, Comments on Proposed NPL Rule, Bradford Island Attachment B, Figures Attachment C, Documents Cited

cc: Michelle Pirzadeh, U.S. Environmental Protection Agency Calvin Terada, U.S. Environmental Protection Agency Kevin Bryce, US Army Corps of Engineers Richard Whitman, Oregon Department of Environmental Quality Laura Watson, Washington Department of Ecology

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ATTACHMENT A CONCERNS WITH BRADFORD ISLAND CLEANUP

BRADFORD ISLAND CLEANUP Cascade Locks, Oregon

Attachment A U.S. Environmental Protection Agency

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YAKAMA NATION COMMENTS ON EPA PROPOSED NPL RULE

BRADFORD ISLAND (DOCKET ID NO. EPA-HQ-OLEM-2021-0462)

CONTAMINANTS OF CONCERN

The Bradford Island site is uniquely dangerous to both human health and the environment. Concentrations of polychlorinated biphenyls (PCBs) and mercury in resident fish and shellfish within one river mile of Bradford Island have been among the highest reported in the nation and are several orders of magnitude greater than PCB concentrations at other major PCB-driven Superfund sites, such as the Lower Duwamish Waterway (WA), Portland Harbor (OR), Fox River (WI), and Hudson River (NY). These toxins have direct exposure pathways to Tribal members and members of the public; other wildlife and biota are also directly exposed to these toxins through consumption of fish and shellfish, as well as through other pathways (Henny et al, 2004). Reported concentrations of PCBs and mercury are so high that the Oregon Health Authority and Washington Department of Health have issued a recommended total ban on consumption of resident fish taken between Bonneville Dam and Ruckel Creek, a reach of one river mile that falls directly within Yakama Nation’s usual and accustomed treaty fishing areas (Figures 1 and 2, attached).

Upland contamination on Bradford Island, including heavy metals, chlorinated solvents, pesticides, petroleum, and PCB contamination, has multiple direct migration pathways to the Columbia River, including stormwater runoff, mass wasting events, and groundwater discharge. Columbia River aquatic biota, including ESA listed species, are already under significant stress due to pressure applied from the Columbia River dam system, climate change, and other industrial pollution. Additional concentrated point-source exposure from Bradford Island (which has measurable localized impacts) further exacerbates existing problems in an already severely stressed system.

HAZARD RANKING SYSTEM

The National Contingency Plan (NCP) at § 300.425(c)(1) authorizes EPA to include a site on the National Priorities List (NPL) if it scores sufficiently high on the Hazard Ranking System (HRS), which EPA promulgated as Appendix A of the NCP. The HRS evaluates the relative potential of uncontrolled hazardous substances, pollutants or contaminants to pose a threat to human health or the environment via four pathways: ground water, surface water, soil exposure and subsurface intrusion, and air. As a matter of EPA policy, those sites that score 28.50 or greater on the HRS are eligible for listing. In 2000, using information available at the time, EPA scored the Bradford Island site below 28.50 and issued a determination of No Further Remedial Action Planned (NFRAP). However, since that time significant new information on site conditions has emerged. Taking this information into account, it is our understanding that the Bradford Island site HRS score would exceed 28.50.

TRIBAL USES, RESOURCES AND EXPOSURE

The damage to biologic resources both in the Columbia River and on the upland portion of Bradford Island directly impacts Tribal resources harvested under the Treaty of 1855. Tribal


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members’ right to perform traditional treaty fishing activities in the Bonneville Pool and elsewhere is reserved under federal law in numerous Supreme Court and U.S. District Court decisions, most recently from 1969-1989 in United States v. Oregon (D. Or. 3:68-cv-00513-MO). The Yakama Nation co-manages the Columbia River Zone 6 fishery with the states through the 2018-2027 Management Agreement, a court order in U.S. v. Oregon that also includes the United States as a signatory.

Tribal members’ exposure to contamination, including to bio-accumulative toxins such as PCBs, pesticides, and heavy metals through consumption of resident fish and shellfish from the Bradford Island site is orders of magnitude greater than the exposure risk posed to the general public. It is therefore imperative that a thorough and fully protective cleanup be performed at Bradford Island in accordance with the statutory requirements of CERCLA and the NCP, and in full consultation with Yakama Nation - whose enrolled members are exposed to significant risk associated with ceremonial and subsistence fishing in the area.

USACE ADMINISTRATION OF CLEANUP

Pursuant to Executive Order 12580, the U.S. Army Corps of Engineers (USACE or Corps) has been the lead agency for the Bradford Island facility since 1997, when the Portland District began conducting investigations at the facility in coordination with ODEQ under ODEQ’s Voluntary Cleanup Program. The facility is currently divided into two operable units (OU) for upland and river remedial actions under CERCLA Project NWP-13-0002. Response actions taken by the Corps include: removal actions in the Columbia River in 2000, 2002, and 2007; Remedial Investigation (RI) reports for both OUs in 2012; and a Feasibility Study (FS) for the Upland OU in 2017. Through a Technical Advisory Group (TAG), Yakama Nation Fisheries has been participating in the Corps’ actions leading to an expected draft FS for the River OU. The Corps has maintained in both the RI and Upland FS, as well as supplemental documents such as the Baseline Human Health and Environmental Risk Assessment (URS, 2016), that the work and or methodologies applied at Bradford Island follow CERCLA. However, Yakama Nation’s review of USACE’s work to date finds it to be both technically lacking and frequently inconsistent with even some of the broadest requirements of CERCLA.

State ARARs. First and foremost, the Corps has not incorporated State regulations as applicable or relevant and appropriate requirements (ARARs) for the site. USACE has been repeatedly informed by the EPA (2000), Yakama Nation, Washington Dept. of Ecology, and Oregon Department of Environmental Quality that State cleanup standards and rules apply directly to the site (Yakama Nation, 2017). See 42 U.S.C. § 9621(d)(2)(A); 42 U.S.C. § 9620(a)(4); 40 CFR § 300.400(g)(4). Yet, the Corps have maintained that under CERCLA these standards do not apply.

Data Gaps. Work performed at the direction of USACE frequently does not follow the basic structural requirements identified in CERCLA, such as completing site characterization as part of the RI prior to proceeding to the FS, or even directly to cleanup. See 40 CFR § 300.430(d)(2) (lead agency “shall characterize the nature of and threat posed by the hazardous substances and hazardous materials and gather data necessary to assess the extent” of them, listing seven factors to be included). Although USACE maintains that the RI for the site is complete, multiple


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substantive data gaps remain unresolved that preclude development of final protective remedies. Most obviously, a complete and comprehensive conceptual site model that identifies the source of PCBs and heavy metals in the River OU has not been produced for public review. However other supporting examples are abundant, such as the recently released Sandblast Area of Potential Concern (AOPC) Work Plan and Quality Assurance Program Plan (USACE, 2021a), which includes discussion of how lateral and vertical extents of upland contamination are not fully defined and therefore require additional sampling. And, critically, contamination in the river and aquatic biota has not been fully characterized, despite these being the most significant exposure pathways to tribal members and the public.

Tribal Risk Evaluations. In addition, the Corps must assess both actual and potential exposure pathways, especially for sensitive populations such as Yakama enrolled members who both reside and conduct subsistence fishing at the Site. 40 CFR § 300.430(d)(2)(v-vii). Yakama enrolled fishers tend to occupy treaty fishing areas for most, if not all of their lives, including residential use. These platforms and locations are handed down, generation to generation, and are fished by the entire family. Following cleanup and restoration of Bradford Island, the Yakama Nation expects its members to be able to resume occupancy of the island and surrounding shorelines and to fish the platform locations that they and their ancestors have fished since time immemorial. Without a thorough understanding of both site conditions and evaluation of risks using appropriate scenarios, the Corps will not be able to design a remedy that is protective of the Yakama Nation’s future exercise of treaty fishing rights. Nevertheless, USACE’s evaluation of exposure scenarios in the RI, remarkably, did not include an exposure scenario for Tribal members using fishing platforms on the island, which had to be added in the Baseline Human Health and Environmental Risk Assessment, Upland Unit (HHERA, URS, 2016). Similarly, fish consumption rates used in the RI for screening level calculation did not consider Tribal fish consumption rates representative of Yakama Nation members.1

Nexus between upland and river. Contamination of the Columbia River from the upland portions of Bradford Island has been occurring since as early as the 1940s. The site was first identified in 1996 when EPA requested sediment sampling of Columbia River sediments and groundwater seeps at what is now the Landfill Area of Potential Concern (URS, 2012). Since that time, USACE has on repeat occasions attempted to separate risks between the Upland and River OUs, despite all evidence to the contrary. This year, the Optimization Review Report (Hydrogeologic and USACE, 2021) commissioned by the USACE pointed out that established remedial action objectives for the Upland OU “did not address the potential for unacceptable impacts to the River OU resulting from the Upland OU.” This follows the completion of the HHERA in 2016, which was appended to the Upland FS and stated explicitly that “Upland OU to River OU pathways (i.e. potential mass wasting and soil erosion) that were evaluated in the Final RI were not addressed herein, as these possible pathways will be considered in the Upland OU FS or the River OU FS” (emphasis added). The Upland FS, as noted above, did not include a remedial action objective to address potential unacceptable impacts to the River OU, but did assert that it took the potential for erosion at the Landfill AOPC “into consideration” while intentionally ignoring erosion at the Bulb Slope AOPC even though “erosion … is assumed to

1 See Appendix J of the Remedial Investigation (URS, 2012). The specified fish consumption rate used to calculate preliminary screening levels was 142.4 grams per day, which is also less than the ODEQ default fish consumption rate of 175 grams per day.


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[also] be occurring.” USACE’s handling of stormwater transport from the Upland OU to the River OU has been similarly disjointed and illogical.2 It strains credulity to believe that USACE, an organization for which one of the primary missions is management of the nation’s navigable waterways, has consistently found that arbitrarily separating the upland portions of a steep sided island from the surrounding waterway to be an acceptable remedial approach under the requirements of CERCLA.

No further action determinations for Sandblast and Bulbslope areas. Both ODEQ and the Yakama Nation disagreed with the Corps risk assessment in the 2017 Upland RI that led to no action decisions in the Sandblast and Bulbslope areas. This decision does not comply with CERCLA or current risk assessment guidance. After much discussion, the Corps agreed to further investigations and source control actions through regional operation and maintenance (O&M) budgets. Without clear criteria and objectives or adequate budget, it has been difficult to come to agreement on a path that will be protective of human health or the resources. The framework of performing cleanup work under O&M, rather than under CERCLA, is not working.

Inconsistent application of CERCLA. Finally, while CERCLA has been invoked with some frequency by USACE at Bradford Island, their compliance with and application of the law has been inconsistent at best. Yakama Nation’s recent discussion with USACE regarding proactive removal of highly contaminated sandblast grit from the Upland OU provides only one of many examples. While USACE has previously completed in-water debris removals (2002) and vacuum dredging operations for contaminated sediment (2007) under its authority to complete a non-time critical removal action, USACE staff have maintained throughout discussions that similar actions could not be taken in the Sandblasting AOPC unless they are performed as an interim remedial action authorized through an Interim Record of Decision (ROD)(USACE, 2021b)3.

There is, in fact, nothing legally stopping USACE from performing proactive removal of the multiple tons of highly contaminated waste material that was generated through Bradford Island facility operations and maintenance activities4. Such actions do not require justification as a non-time critical removal action or interim action if they are not proposed as part of a final remedy under CERCLA. The Corps has previously proposed to Yakama Nation, ODEQ, and Ecology to perform this removal action, but without clear parameters for removal. EPA also recommended similar action to the Corps in 2006, but then went further and recommended specifically that it

2 Briefly, examples include USACE’s evaluation of stormwater transport from potentially erodible areas being eliminated on the basis that the areas were observed to be vegetated (although in at least one portion of the Sandblast AOPC also covered in erosion rills) and therefore not, in USACE’s opinion, erodible. Similarly, USACE has maintained stormwater transport does not comprise a completed pathway from the Upland OU to the River OU because catch basins on the island, which outfall directly to the river, have filter socks installed. This second position is particularly egregious given that repeat sampling of the catch basins has identified highly contaminated material that must have come from Upland sources and installation of a filter sock would not be considered a permanent remedy under any legal framework.

3 The Corps position is that a non-time critical action cannot be justified based on the current ecological risk, which does not consider impacts to the Columbia River.

4 As stated in the Upland and River Operable Units Remedial Investigation Report prepared by URS, 2012, USACE’s is funding all Remedial Investigation and Feasibility Study operations work through its operations and maintenance program.


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should consider immediate remediation of both the Pistol Range and Sandblast AOPCs by removing contaminated media rather than waiting for completion of an RI/FS or EE/CA.

Regardless of whether they are showing sufficient initiative and/or goodwill, the position adopted by the Corps is not legally defensible under the NCP, which authorizes the Corps to “take any appropriate removal action to abate, prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release” if there is found to be a threat to public health or welfare. 40 CFR § 300.415(3)(b)(1). There is little doubt at this juncture that such a threat exists, that a removal action is necessary to protect human health and the environment, and that sufficient information exists to conduct a removal action without having to issue an Interim ROD.

DEFICIENCIES IN WORK COMPLETED

While it is not the intent of these comments to provide a comprehensive listing of every mistake, omission, deficiency, or oversight by USACE and its contractors in the work performed at Bradford Island, there are numerous examples of such problems in reviewing the work completed to date. Examples of such deficiencies, which do not meet the requirements of CERCLA or the applicable standard(s) of care for a project regulated at both the State and Federal level, include but are not limited to:

• USACE’s failure to maintain a contemporaneous and widely available administrative record of all information and communications regarding Bradford Island as is available for other EPA- or DOE-managed sites.

• Lack of formal RI/FS scoping and preparation of a RI Work Plan, including an assessment of existing data, identification of State and Federal ARARs, preparation of preliminary remedial action objectives and data quality objectives.

• Failing to prepare and publicize a comprehensive cleanup plan and schedule including formal project milestones.

• Performing work out of order and in a disjointed and manner that breaks basic information dependencies which should inform each subsequent phase of work (e.g. completing a risk assessment after the remedial investigation, which defines the nature and extent of contamination using screening levels set through the risk assessment process).

• Providing inconsistent and inadequate funding for the Bradford Island cleanup has led to arbitrary schedules and project objectives. This funding approach precludes development of a comprehensive cleanup framework or project remedial action objectives.

USACE’s overall management of the cleanup process has in at least one case contributed to conditions at Bradford Island becoming measurably worse. Following the 2007 non-time critical removal action for contaminated sediment, PCB concentrations in sediment and smallmouth bass


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tissue increased by up to an order of magnitude (URS, 2012b) (Figures 3 and 4, attached)5. Recently released analytical results from additional tissue sampling performed in 2020 indicate that concentrations of total PCBs in whole-body smallmouth bass samples remain orders of magnitude above the previously established human health screening level value of 0.570 micrograms per kilogram wet weight6 (USACE, 2021d). Other proposed actions by USACE, such as performing Bulb Slope AOPC characterization as part of road construction to the Landfill AOPC rather than under CERCLA, would restrict future cleanup alternatives and foreclose completing complete characterization of the nature and extent of contamination. These actions, and the ongoing monitoring analytical results for fish, crayfish, and clam in the Columbia River further emphasize the need for Bradford Island to be listed on the NPL. Bradford Island must be addressed with the appropriate expertise and funding using progress and accountability metrics that ensure the cleanup is both timely and fully protective of all potential receptors.

PUBLIC ENGAGEMENT AND COMMUNICATIONS

While USACE has asserted its authority to manage and execute cleanup work under CERCLA at Bradford Island (URS, 2012; USACE 2017), it has made at most only a cursory attempt to fulfill requirements for public engagement and/or public acceptance for the work it has elected to perform. It has certainly not fostered productive and collaborative working relationships with either State regulators or Yakama Nation.

USACE has primarily relegated public engagement to the Technical Advisory Group, which meet monthly until September, 2021. While regional USACE staff attending TAG meetings periodically engaged with Yakama Nation and other agencies in a thoughtful and earnest manner, the overall TAG framework was badly compromised from the outset due to the constraints placed by higher levels of USACE administration. Public engagement through the TAG failed to yield meaningful results in large part because budgets, schedules, and project objectives were set by USACE in isolation and then later unveiled to the TAG members. Nearly any proposed change brought up in the TAG forum required some form of approval from higher levels of USACE authority; however, such authority was seldom (if ever) in attendance.

As of September 22, 2021 the Corps has disbanded TAG meetings entirely and announced it will reconvene the Community Advisory Group meetings as the new public forum for project updates and community engagement. The Corps acknowledged in their announcement that the change was necessary to “meet CERCLA community involvement objectives” and to comply with Federal Advisory Committee Act requirements (USACE, 2021c).” This change, particularly without the new communications forums in place, is alarming.

USACE has proposed additional technical working group meetings with tribes and agencies to be convened on an ad-hoc basis to meet their obligations as the current lead federal agency under CERCLA. Based on Yakama Nation’s experience working with the TAG and USACE’s failure

5 Consistent with other planning and CERCLA compliance failures, the Corps did not use analytical methods that achieve reporting limits that are less than their own selected screening level values in either the 2006 or 2011 sampling events, making the resulting data set of limited value for performance evaluation.

6 As previously noted, the selected screening level value does not consider potential increased levels of risk posed to tribal members associated with significantly higher levels for fish consumption than the general public.


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to follow through on previous commitments; Yakama Nation remains highly skeptical that the proposed changes will result in either meaningful or timely consultation regarding proposed future work. The recently enacted changes further emphasize the need Bradford Island to be listed on the NPL to ensure the cleanup process maintains property public accountability and is performed in full consultation with the Yakama Nation.

ATTACHMENT B FIGURES

BRADFORD ISLAND CLEANUP

Cascade Locks, Oregon

Service Layer Credits: Source: Esri, Maxar,GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID,IGN, and the GIS User Community

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FIGURE 1BRADFORD ISLAND VICINITY

BRADFORD ISLANDCASCADE LOCKS, OREGON

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FARALLON PN: 1548-004

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OregonPortland | Baker City

CaliforniaOakland | Irvine

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ATTACHMENT C DOCUMENTS CITED

BRADFORD ISLAND CLEANUP Cascade Locks, Oregon

Attachment C U.S. Environmental Protection Agency

Page 1 of 2

Documents Cited

Henny, C. J., Grove, R. A., Kaiser, J. L., & Bentley, V. R. 2004. An evaluation of osprey eggs to determine spatial residue patterns and effects of contaminants along the lower Columbia River, USA. Raptors Worldwide, WWGBP/MME, Budapest, Hungary, 369-88.

Hydrogeologic Inc. 2021. Draft Optimization Review Report, Bradford Island Upland and River Operable Units, Cascade Locks Oregon. July 16.

Oregon Health Authority. 2013. Limit consumption of some fish species near Bonneville Dam, middle Columbia River. September 23.

----------. 2021. Memorandum to Chris Budai, USACE from Mike Poulsen, Jennifer Peterson, and Bob Schwarz, Oregon Department of Environmental Quality RE: Bradford Island ECSI #2010 Comments on Sandblast AOPC Work Plan. March 24.

URS, Inc. 2012a. Upland and River Operable Units Remedial Investigation Report. Prepared for the U.S. Army Corps of Engineers. June.

URS, Inc. 2012b. Draft analytical results for sediment, clams, bass, collected from forebay September/October 2011 and bass collected from reference area August 2011, Bradford Island Pre-Feasibility Study. Prepared for the U.S. Army Corps of Engineers by URS Inc. July 2.

----------. 2016. Baseline Human Health and Ecological Risk Assessment, Upland Operable Unit, Bradford Island, Cascade Locks, Oregon. Prepared for the U.S. Army Corps of Engineers. April.

U.S. Army Corps of Engineers (USACE). 2017. Final Feasibility Study, Bradford Island Upland Operable Unit, Cascade Locks, Oregon. August 11.

----------. 2015. Memorandum For Record, Slope Stability Investigation and Analysis. Prepared by Christopher Humphrey and Jeremy Britton, U.S. Army Corps of Engineers Portland District. January 20.

----------. 2021a. Final Work Plan with Quality Assurance Project Plan for Soil Sampling at Sandblast AOPC, Bradford Island, Cascade Locks Oregon. May 14.

----------. 2021b. Memorandum for Record, Bradford Island, Upland Operable Unit Prepared by USACE Seattle and Portland Districts. July 13.

----------. 2021c. Communication from Christine M Budai to Technical Advisory Group members re: Bradford Island – Changes to TAG. September 22.

----------. 2021d. Smallmouth Bass, Crayfish and Clam Data Report. River Operable Unit, Bradford Island, Cascade Locks, Oregon. October.

U.S. Environmental Protection Agency (EPA). 2000. Use of Non-Time Critical Removal Authority in Superfund Response Actions. February 14.

Attachment C U.S. Environmental Protection Agency

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----------. 2000. Letter to Col Randall Butler, U.S. Army Corps of Engineers from Mark Adler, Site Assessment Manager. June 19.

----------. 2006. Letter to Thomas E. O’Donovan Colonel EN, U.S. Army Corps of Engineers from Lori Cohen, Associate Director Office of Environmental Cleanup. January 31.

Yakama Nation. 2017. Letter to Colonel Aaron L. Dorf from Phil Rigdon, Yakama Nation, Richard Whitman Oregon Department of Environmental Quality, and James J. Pendowski Washington State Department of Ecology regarding Bradford Island Lock and Dam Project CERCLA Project NWP-13-0002; DEQ ECSI #2010. September 21.

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