Opposed to development of the waters over the superfund MOU at Ward Cove
By Betsey Burdett
September 14, 2019
Here are some of the things I have found out.
The EPA has oversite for the both the uplands and the MOU. There is a sand cap which covers certain areas of the cove. The July 2004 Covenant of the Record of Decision (ROD) Section IX states:
“The borough covenants and agrees that it shall not, through any activities or operations at or in the Ward Cove Area, materially damage any cap or capping materials that may be applied to sediments in the Ward Cove Area under the Ward Cove (CERLA) consent decree.”
Further, the Borough would have to immediately report any disruption to the cap. Termination of the restrictions and due diligence clauses would have to be approved by the EPA.
The mitigation that has been chosen for the MOU included the sand cap and testing of the surface layers above the sediment. The conclusion of the Sediment Remediation Project within the constraints of the study and testing was that the waters of Ward Cove had made a complete recovery. The dredging that was done was within the budget that was agreed upon. Logs remain submerged below the sediment layer in areas that are too deep or steep, not just in front of the marine sort yard.
The Alaska Ship and Supply Company purchased an impressive area of the superfund site and agreed to take on the obligations of institutional controls (ICs). In the Deed of Trust that they signed at the time of the purchase the Borough stated that they had complied with all environmental laws and the buyer agreed that they would take over the ICs, and would maintain and promptly perform all repairs on the above properties as needed.
What’s under the sediment layer? What is under those logs? Those who worked for KPC on the barges pushing logs around know that thousands of those logs sunk. Many were treated with arsenic. KPC paid a 3.1 million dollar fine for illegally dumping heavy metals into the cove from the uplands including cadmium, mercury, zinc, and polycyclic aromatic hydrocarbons (PAH), dioxins/furans. The conclusion in the report by KPC contractor Integral was that contact was unlikely due to depth and cold water. This same report recommended long term monitoring of the remedy.
Now the Alaska Ship and Supply Company is proposing a floating dock over the superfund site so that they can accommodate up to two Panamax cruise ships. These ships use an AZIPOD applied prop system. There is no way that Ward Cove could host a scour analysis test as a “failure” would be catastrophic not only to the obligations of the Borough, Alaska Ship and Supply Company, but most of all the health of the Cove and the waters outside of its 250 acres. Any simulation of the scour test would not cover the conditions of the Cove with its unique manmade and natural topography.
Should you decide to comment the reference # is POA-2019-00313 and the e mail address is email@example.com
Received September 12, 2019 - Published September 14, 2019
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