aquifer | Rosemere Neighborhood Association

Communities’ Letter on EPA’s Final Vapor Intrusion Guidance

July 28, 2012 Author: admin
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Vapor Intrusion: image source epa

On July 26, 2012, a letter was sent to EPA’s Richard Kapuscinski from environmental organizations and citizens groups from all over the country – including Rosemere Neighborhood Association – concerned about EPA’s pending Final Vapor Intrusion Guidance.

The letter begins:

We, the undersigned are concerned that pressure from polluters, chemical producers, and property owners may weaken elements of EPA’s pending Vapor Intrusion Guidance, and we urge EPA to adopt an investigatory approach that is truly protective of Americans exposed to highly toxic vapors in their homes, schools, workplaces, and other buildings.

On July 6, 2012, Inside EPA, reported:
Industry is criticizing EPA’s approach to calculating the potential for subsurface contamination to migrate to indoor air, raising concerns over a technical document expected to be a component of the agency’s final vapor intrusion guidance and over a Region III proposal to offer government-funded mitigation for vapor intrusion at homes near a Superfund site in Pennsylvania.
Industry argues the so-called attenuation factors in the EPA documents are unnecessarily conservative and flawed because of incorrect assumptions of the rate at which contamination flows into residences.

The determination whether vapor intrusion poses a health threat at any existing building should not be based solely upon models and predictions. Models cannot account for changes in operating conditions, occupancy, building modifications, or structural changes such as adding utility lines that penetrate floors or settling that cracks slabs. One test is worth 1000 expert opinions. Decisions should be based upon multiple lines of evidence, including indoor air testing, subslab soil-gas sampling, and outdoor air monitoring.

To read the entire letter: Communities’ Letter on EPA’s Final Vapor Intrusion Guidance
CITIZENS FIGHT FOR CLEAN WATER IN CLARK COUNTY

March 17, 2012 Author: admin
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CITIZENS TAKE ON CLARK COUNTY’S FAILED ATTEMPT TO MAKE TAXPAYERS PAY FOR DEVELOPERS’ STORMWATER POLLUTION

Nationwide, stormwater is the leading source of water pollution. This is also true for the Columbia River Basin. In urban areas, rain runs across dirty pavement and roofs, picking up toxic metals, oil, grease, bacteria and other contaminants along the way.

Experts across the country agree: the cost of stormwater pollution is steep. Murky, smelly streams and rivers and fish advisories warning people not to eat otherwise healthy, locally caught fish are a stark reminder of the public costs of stormwater pollution. Yet Clark County tried to make taxpayers pay for stormwater impacts that are the responsibility of private development. Taxpayer dollars already support public stormwater infrastructure and now its time for developers to pay their share.

IGNORING COMMON SENSE

Why is Clark County Trying to Evade Protections for Safe, Swimmable Rivers and Livable Communities?

In 2010, local citizens and conservation groups successfully challenged Clark County’s sweetheart deal with Washington State regulators—a deal that made Clark County the only major county in the state to avoid critical steps to reduce stormwater pollution. Washington’s Pollution Control Hearings Board ruled that the County’s controversial development standards violated state laws to protect clean water. In 2011, a federal court judge also found that Clark County’s actions likely violate the federal Clean Water Act.

Not only is Clark County violating the law, it is ignoring the very real economic and quality of life costs associated with stormwater pollution. For example, stormwater pollution:
- Increases flooding—the Federal Emergency Management Agency (FEMA) estimates that stormwater causes or contributes to at least one quarter of economic losses due to flooding—or $1 billion per year.
- Adds costs to providing safe drinking water.
- Threatens public health.
- Impacts fishing opportunities and water recreation.
CITIZENS FIGHT FOR CLEAN WATER IN CLARK COUNTY

Many cities and counties in Washington State are working hard to clean up polluted waterways. One of the primary ways Washington State is trying to reduce stormwater pollution is by requiring new development and redevelopment to control stormwater as it leaves the property.

CONTINUED….Click here for the full document: CITIZENS FIGHT FOR CLEAN WATER IN CLARK COUNTY
PEAC Comments on Final Environmental Impact Statement for I-5 Columbia River Crossing Project

October 25, 2011 Author: admin
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I-5 Interstate Bridge Over Columbia River

Pacific Environmental Advocacy Center (“PEAC”), the Environmental Legal Clinic of Lewis & Clark Law School, has submitted comments on behalf of a coalition of environmental groups on the Columbia River Crossing Project (“CRC”) Final Environmental Impact Statement.

PEAC clients include Rosemere Neighborhood Association, Coalition for a Livable Future, the Northeast Coalition of Neighborhoods, Northwest Environmental Defense Center, Columbia Riverkeeper, the Portland Audubon Society, Oregon Public Health Institute, Upstream Public Health, and Association of Oregon Rail and Trail Advocates. PEAC also states that although it specifically represents these groups, it is “in fact representing the concerns and views of a broad and diverse coalition of groups.”

To date, CRC has established a pattern of ignoring input from these environmental and stakeholder groups concerned about the proposed bridge design impacts to our sole source aquifer, surface and groundwater resources, salmon, air quality, general public health concerns and other environmental impacts.

In this document PEAC details all these concerns and the various technical reports behind them, finding,

Overall it is remarkable how much incomplete and missing analysis is found when the public reviews this FEIS, which has already cost Oregon and Washington taxpayers more than $130 million. This would be Oregon’s largest public works project, and its taxpayers and the taxpayers of Washington are entitled to a much more thorough and complete analysis, a true comparison of all reasonable alternatives that “sharply defines the issues and provide[s] a clear basis of choice among options” (40 C.F.R. § 1502.14), and a meaningful opportunity to review and comment on all of those things in a supplemental DEIS.

While the coalition is not “anti-bridge”, it does charge CRC with the responsibility to not harm our environment, destroy our resources or our community and to be fiscally responsible.

PEAC concludes with,

For all the reasons set forth above, PEAC respectfully requests, on behalf of its clients listed below, that the responsible federal agencies and the CRC Task Force withdraw the CRC FEIS and issue a corrected Supplemental DEIS for public comment.

You can read the entire PEAC document “Comments on September 2011 Final Environmental Impact Statement for I-5 Columbia Crossing Project” here: PEAC_Comments_on_CRC_FEIS
(pdf format – please note this is a fairly large document a may take a moment to open)
EPA Testing Results at Camp Bonneville Show Contaminated Plume Growing & Moving

October 13, 2011 Author: admin
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EPA has released the initial results of its testing at Camp Bonneville, the former US Military installation in Clark County, Washington.

EPA is conducting assessment of the known and suspected release of hazardous substances at Camp Bonneville to determine whether it warrants listing under the Superfund Program following a petition from Rosemere Neighborhood Association (RNA).

The first round of samples was collected last May (2011) and EPA’s report on that testing can be found http://www.epa.gov/region10/pdf/sites/camp_bonneville/bonneville-p1-sample-results.pdf.

The second round of data was collected in August (2011) and that report is expected in January 2012. Following the secondary reports, EPA will score the site to determine Superfund status upon which a final report will be released.

RNA brought the Superfund petition in 2009 citing faulty clean-up efforts at the site where live munition drills and chemical warfare had been conducted for decades. RNA contended in its petition that contamination from buried military munitions and chemicals, including the continued rise of measured perchlorate and RDX, has leached into the soil and groundwater at the site. RNA was also concerned that the plume of toxic chemicals had become mobile threatening Lacamas Creek. Lacamas Creek feeds into Lacamas Lake and ultimately into the Columbia River.

EPA’s latest data reveal – as suspected by RNA – that the plume has traveled and has become larger, possibly entering the creek flow or infiltrating below the creek to the opposite shore. Although RNA had raised these concerns to the Washington State Department of Ecology for years, Ecology officials had maintained that topography would prevent any additional test wells from being established. Based on RNA’s petition and subsequent discussions regarding hydrologic flow, EPA successfully installed additional testing wells in suspect areas that proved the plume had moved.

The danger to surrounding groundwater and surface water would have gone undiscovered had it not been for the Superfund petition brought by RNA. Following the incomplete clean-up led by Mike Gage and BCCRT, property ownership of Camp Bonneville was to go back to Clark County over a month ago, but the transfer of ownership has been stalled due to a dispute that Gage has with the Washington State Department of Revenue. All other contractors who worked on the initial phases of clean-up at the site have paid their taxes, but Mike Gage has thus far refused to pay his taxes. Apparently clean-up will be stalled until Gage’s tax dispute is resolved.

Around $28 million has been spent on the Bonneville clean-up thus far including extensive efforts to alleviate the contaminated goundwater plume. The groundwater contamination was initially caused by munitions that had been buried in landfills. The landfills were evacuated but during that process the backhoes began to sink and they were not able to remove all of the contaminated soil. As a result, much of the contaminated soil was left behind and the remaining holes were filled with porous, loamy soil that was extremely permeable and allowed the plume to become mobile.

EPA Camp Bonneville page can be found here: http://yosemite.epa.gov/r10/cleanup.nsf/sites/CB

Direct link to the Camp Bonneville Phase 1 Sample Results Report is here: http://www.epa.gov/region10/pdf/sites/camp_bonneville/bonneville-p1-sample-results.pdf

UPDATE:

Responding to the EPA test results announcement, Clark County Department of Public Works Project Manager, Jerry Barnett, said, “The county will meet with Ecology and the EPA to determine the significance of these results. Findings include perchlorate in sediments and subsurface water adjacent to Lacamas Creek at concentrations below cleanup levels.”

However, while EPA might agree to discuss site assessment as a process, it is premature to be discussing the “significance” of the data. As explained above, EPA management will not conduct its complete review of the data until next year after all phases of testing have been completed.

The Washington Department of Ecology also announced Thursday that it is opening a period of public review and comment on an updated legal agreement for the cleanup of Camp Bonneville. Under the proposed Amended Prospective Purchaser Consent Decree between Clark County and Ecology, Clark County will take the lead role in the cleanup of Camp Bonneville. Ecology will accept comments on the proposal from Oct. 14 through Nov. 17, 2011.

For more information go to Ecology’s website here: http://www.ecy.wa.gov/news/2011/277.html

For the amended decree, click here: https://fortress.wa.gov/ecy/gsp/Sitepage.aspx?csid=11670

You can send comments to Ecology on the draft documents from Oct. 14 through Nov. 17.

Here’s how you can submit comments:

By US Mail:
Ben Forson, Site Manager
Washington Department of Ecology
Toxics Cleanup Program
P.O. Box 47600
Olympia, WA 98504-7600.

By Email to:
bfor461@ecy.wa.gov
Columbia River Crossing Project Environmental Impact Analysis

May 31, 2010 Author: admin
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I-5 Interstate Bridge Over Columbia River

In Summer 2008, a Draft Environmental Impact Statement (DEIS) was released on the Columbia River Crossing Project, and various environmental organizations, including Rosemere Neighborhood Association, submitted public comment to show that the draft document was incomplete and full of data gaps. Concerns were also raised regarding the draft’s compliance with the National Environmental Policy Act.

Since the release of the DEIS, Rosemere has met several times with Columbia River Crossing (CRC) staff and has raised concerns regarding the project’s impact on the environment, including the aquifer system that provides Clark County residents with drinking water and local streams within the construction footprint.

In 2005, Rosemere submitted a petition to EPA requesting that agency to designate the Troutdale and Unconsolidated Alluvium Aquifer System in Clark County, Washington, as a Sole Source Aquifer. The EPA defines the Sole Source Aquifer Program as a tool used to protect drinking water supplies in areas with few or no alternative sources to groundwater resources, and where such an aquifer is vulnerable to contamination. Sole Source designation requires at least a 50% dependence on an aquifer for its potable water supply. Factual analysis provided by Rosemere and its partners shows that 99.4% of the potable water used in Clark County is obtained from groundwater. In August, 2006, EPA officially granted Rosemere’s petition and designated Clark County’s Troutdale Aquifer System as a federally protected Sole Source Aquifer. One of Rosemere’s goals was to ensure adequate environmental review of the CRC project under the federal Sole Source Aquifer program. [Read More...]
Toxics at Vancouver Lake

October 25, 2009 Author: admin
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Thursday, October 22, marked the 5 year anniversary of the Vancouver Lake Watershed Partnership, created to address longstanding problems that prevent the lake from being swimmable and fishable, including toxic blue green algae.

Patty Boydon, Port of Vancouver Environmental Director, gave a presentation on the installation of an air stripping facility installed to remediate toxic groundwater plumes produced by Cadet/Swan Manufacturing. Groundwater plumes that have expanded into the Fruit Valley Neighborhood were caused by the use of industrial chemical solvents. The shallow groundwater plumes were first discovered in 1998 during road construction, marking the largest groundwater cleanup in Washington State. [Read More...]
Press Release: RNA Wins Landmark Environmental Justice Case Against EPA’s Office of Civil Rights

September 18, 2009 Author: admin
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FOR IMMEDIATE RELEASE

Contacts:

Chris Winter
CRAG Law Center

Dvija Michael Bertish
Rosemere Neighborhood Association

ROSEMERE NEIGHBORHOOD ASSOCIATION WINS LANDMARK ENVIRONMENTAL JUSTICE CASE AGAINST EPA’S OFFICE OF CIVIL RIGHTS

Ninth Circuit Court of Appeals Criticizes EPA for a “Pattern of Delay” in Implementing Title VI of the Civil Rights Act

(September 18, 2009) Rosemere Neighborhood Association (“Rosemere”) is a non-profit community organization in Clark County, Washington, dedicated to environmental protection and the pursuit of improvements to low-income environmental justice communities.

In February 2003, Rosemere first filed a Title VI administrative complaint with EPA’s Office of Civil Rights (“OCR”) alleging that the City of Vancouver, WA had discriminated in the provision of municipal services in violation of the Civil Rights Act of 1964. Rosemere alleged that Vancouver failed to use EPA funds to address fairly long-standing problems in low-income and minority neighborhoods in West Vancouver.

[Read More...]
Press Release: Sixty Day Notice of Intent to file a Citizens’ Lawsuit Against Clark County

April 27, 2009 Author: admin
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Stormwater outfall during dry weather conditions

PRESS RELEASE****PRESS RELEASE****PRESS RELEASE

Today Rosemere Neighborhood Association delivered a Sixty Day Notice of Intent to file a Citizens’ Lawsuit against Clark County, Washington, under the Clean Water Act. A copy of the Sixty Day Notice is attached to this press release. Rosemere Neighborhood Association is represented by attorneys Theda Braddock, of Steilacoom, Washington, and Paul E. Brain of Smith, Alling, Lane, PS, of Tacoma, Washington. [Read More...]
Rally Organized to Oppose the 12-Lane Columbia River Crossing – April 5, 2009

April 6, 2009 Author: admin
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#1 Senator Don Benton (WA), #2 Association of Oregon Rail & Transit Advocates, #3 Portland City Commissioner Amanda Fritz

It was the perfect day for a rally, the first nice spring day in the region. It took place at the noon at Tom McCall Waterfront Park in Portland amidst freshly sprouted lawn, trees starting to blossom, a sunny blue-sky day, and a busy promenade with bicyclists, strollers, and roller skaters. Television crews buzzed about as the stump speeches began beneath the Hawthorne Bridge. Sponsors of the rally included the Bicycle Transportation Alliance, Coalition for a Livable Future, 1000 Friends of Oregon, Upstream Public Health and Oregon League of Conservation Voters. Speakers included Washington Senator Don Benton, Portland City Commissioner Amanda Fritz, and Former Oregon Secretary of State Bill Bradbury. [Read More...]
RNA’s letter to Governor Chris Gregoire regarding stormwater and septic tank ordinances – February 16, 2009

April 6, 2009 Author: admin
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Governor Chris Gregoire

The Rosemere Neighborhood Association has sent a letter to Governor Chris Gregoire regarding legislation introduced under House Bill 1661 [Reducing the authority of the state board of health with regard to small-scale sewage systems] to remove state oversight on private septic systems. Without state standards, local jurisdictions would have the authority to revoke existing operations and maintenance requirements for on-site septic systems, and local authorities would be faced with public challenges to overturn local codes without the presence of state regulations. In short, this bill would allow failing septic systems to continue to pollute ground and surface water and spread disease. The RNA asserts that a major component of stormwater pollution may be septic tank infiltration through perforated stormwater pipes. [Read More...]