PB99-964603
                              EPA541-R99-056
                              1999
EPA Superfund
      Record of Decision:
      Vancouver Water Station #4
      Contamination Site
      Vancouver, WA
      9/1/1999

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FINAL RECORD OF DECISION                                                Page iii
Vancouver Water Station 4
EPA Region 10
                                CONTENTS

Section                                                                 Page

ABBREVIATIONS AND ACRONYMS	vii

1.0  INTRODUCTION 	1

2.0  SITE NAME, LOCATION, AND DESCRIPTION	.	1

3.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES 	4
      3.1    INITIAL RESPONSE 	4
      3.2    INVESTIGATIONS	5
            3.2.1  Results of Investigations	6
            3.2.2  Sources ofPCE	6
      3.3    INSTALLATION OF THE AIR STRIPPING SYSTEM	9
      3.4    ENFORCEMENT  	9

4.0  COMMUNITY RELATIONS	10
      4.1    CITY OF VANCOUVER COMMUNITY RELATIONS EFFORTS  	10
      4.2    EPA COMMUNITY RELATIONS EFFORTS  	11

5.0  SCOPE AND ROLE OF RESPONSE ACTION	..12

6.0  SUMMARY OF SITE CHARACTERISTICS 	13
      6.1    PHYSICAL CHARACTERISTICS 	13
            6.1.1  Surface Features	13
            6.1.2  Geology	13
            6.1.3  Hydrogeology	14
      6.2    NATURE AND EXTENT OF CONTAMINATION  	16
            6.2.1  Chemicals of Potential Concern	16
            6.2.2  Acetone Detections . . .	17.
            6.2.3  PCE Concentrations	18

7.0  SUMMARY OF SITE RISKS  	  	22
      7.1    HUMAN HEALTH RISK ASSESSMENT  		22
            7.1.1  Identification of Chemicals of Potential Concern	23
            7.1.2  Exposure Assessment	23
            7.1.3  Toxicity Assessment	27
            7.1.4  Risk Characterization 	28

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                 PaSe 1V
  EPA Region 10


                          CONTENTS (Continued)

            7.1.5  Uncertainty Assessment  ...                               -,-,
      7.2   ECOLOGICAL EVALUATION  	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.	33

 8.0 REMEDIAL ACTION OBJECTIVES
                                                                     34
       8.1    NEED FOR REMEDIAL ACTION	-J
       8.2    POTENTIAL SOURCES                	 	  *
       8.3    TRANSPORT OF PCE TO WATER STATION 4 .'.'.".''.'..	35
            8.3.1  Mill Plain Release Scenario	              	36
            8.3.2  Flowpaths to WS4  	.....'...'.      	35
            8.3.3  Preferential Pathways	'. '	37
            8.3.4  Degradation of PCE in Groundwater          	-27
      8.4    CONCLUSIONS	           " "	  '
      8.5    REMEDIAL ACTION OBJECTIVES . . . . '...........'.['. .'.'."	38

 9.0 DESCRIPTION OF ALTERNATIVES 	                        3g
      9.1    THE OPERATING TREATMENT SYSTEM ALTERNATIVE	30
      9.2    THE NO-ACTION ALTERNATIVE	...'.'.'.'.'.'.'.'.'." 39

 10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES .                        39
      10.1    OVERALL PROTECTION OF HUMAN HEALTH AND THE	
           ENVIRONMENT
      10.2   COMPLIANCE WITH ARARS	  "4
      10.3   LONG-TERM EFFECTIVENESS AND PERMANENCE	49
      10.4   REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH	
           TREATMENT	                                        4?
      10.5   SHORT-TERM EFFECTIVENESS	4?
      10.6   IMPLEMENTABILITY	              	?~
      10.7   COST OF IMPLEMENTATION	" "	A
      10.8   STATE ACCEPTANCE  .             	T!
      10.9   COMMUNITY ACCEPTANCE ........ .....'.'.'.'.\\\	44

11.0 THE SELECTED REMEDY	
      11.1   AIR STRIPPING	  *
      11.2   GROUNDWATER CLEANUP  	"	^-
      11.3   GROUNDWATER MONITORING   	"	"	Al
                                     	4o
12.0 STATUTORY DETERMINATIONS
      12.1   PROTECTION OF HUMAN HEALTH AND THE' ENVIRONMENT  .'  .'   \ 47

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FINAL RECORD OF DECISION                                             pa  y
Vancouver Water Station 4
EPA Region 10


                          CONTENTS (Continued)

     .12.2  COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
           REQUIREMENTS (ARARS) AND OTHER CRITERIA AND GUIDANCE   47
           12.2.1 ARARs	47
           12.2.2 Other Criteria, Advisories, or Guidance to Be Considered (TBCs) for
                This Remedial Action 	        48
      12.3  COST-EFFECTIVENESS	 48
      12.4  USE OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
           TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO
           THE MAXIMUM EXTENT PRACTICABLE	49
      12.5  PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT  :	50

13.0 DOCUMENTATION OF SIGNIFICANT CHANGES	50
APPENDIX

A    Responsiveness Summary

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 FINAL RECORD OF DECISION                                                     p
 Vancouver Water Station 4                                                            ge x !
 EPA Region 10


 FIGURES

 2-1    Site Location Map ..... .................                                   .-,
 2-2    Site Map  ..........................                         ............ 3
 3-1    Well Locations ........... .......................     .................. 7
 6-1    Physical Conceptual Site Model  ........... ........... ..'..' ............ 15
 7-1    Human Health Conceptual Site Model ...... '. ................ .."..'. ...... 25
 9-1    Typical Air Stripper ................ •                      ...............
TABLES

6-1    Summary of PCE Detections in Groundwater (1988-1998) .............. .        20
7-1    Summary of Cancer Risks, Future User of Untreated Public Water Supply ........ .  . 29
7-2    Summary of Cancer Risks, Future Private Water Supply User .........          .  . 29
7-3    Summary of Cancer Risks, Current Private Water Supply User ....... ....... ^ ..  ^ 30
7-4    Summary of Noncancer Hazard, Future User of Untreated Public Water Supply '.'.'.'.'.'. 30
7-5    Summary of Noncancer Hazard, Future Private Water Supply User ............... 31
7-6    Summary of Noncancer Hazard, Current Private Water Supply User ............    31

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                                                FINAL
                          DECLARATION OF THE RECORD OF DECISION
 SITE NAME AND LOCATION

 Vancouver Water Station 4
 Vancouver, Washington


 STATEMENT OF PURPOSE

 This decision document presents the selected final remedial action for Vancouver Water Station 4 (WS4) in
 Vancouver. Washington, which was developed in accordance with the Comprehensive Environmental Response,
 Compensadon, and Liability Act of 1980 (CERCLA), as amended, and, to the extent practicable, the National Oil
 and Hazardous Substances Pollution Contingency Plan (NCP).  This decision is based on the Administrative
 Record for the site.

 The lead agency for this decision is the U.S. Environmental Protection Agency (EPA). The Washington State
 Department of Ecology concurs with the selected remedy.


 ASSESSMENT OF THE SITE

 Actual or threatened releases of hazardous substances from WS4, if not addressed by implementing the response
 action selected in this Record of Decision (ROD), may present imminent and substantial danger to public health.
 welfare, or the environment.


 DESCRIPTION OF THE SELECTED REMEDY

The City of Vancouver's public water supply wells at WS4 are contaminated with tetrachloroethene (PCE). No
ongoing source for the PCE in the groundwater has been identified for which cleanup acdon could be taken.
Therefore a remedy that focuses on treatment of the drinking water produced from WS4 has been determined to
 represent the maximum extent to which permanent solutions and treatment technologies can be used in a cost-
effective manner.  Even without a source control remedy, the concentration of PCE in groundwater at WS4 is
expected to eventually decrease to a level below the maximum contaminant level (MCL).

The selected remedy for cleanup of both the public water supply and groundwater at WS4 is air stripping.  Air
stripping is a treatment technology in which the water to be treated trickles down through a tower in a packed
column that breaks up the now of water to create as much surface area as possible. Large volumes of air are then
forced upward dirough the water, transferring the volatile contaminants from the surface of the water to the air
through the process of evaporation.  The air to which the contaminants have been transferred is then treated by
forcing it through carbon filters, which adsorb the contaminants. The filters are then regenerated or treated and
disposed of as a hazardous waste.

The air stripping system at WS4 has been in operation since January 1992. before the site was listed on the
National Priorities List.  Use of air stripping has consistently reduced concentrations of PCE in treated water to
below the level of detection. This acdon addresses the principal threat to human health—contamination of
drinking water widi PCE.

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      DATA CERTIFICATION CHECKLIST
             H      Chemicals of concern (COCs) and their respective concentrations (Table 6-1; Section 7. 1. 1;



             BI      Baseline risk represented by the COCs (Section 7)


             H      Cleanup levels established for the COCs and the bases for the levels (Section 8.5)
             H      Land and groundwater use that will be available at the site as a result of the selected remedy

                    a^sult iff
                                r       Operati°n and maintenance (O&M) costs (Section 10.7); total present
                    worth costs. Ascount rate, and the number of years over which the remedy cos estimates are

                                                                                     ™™™
                                               erating costs)


            H      Decisive fector(s) that led to selecting the remedy (Section 8.4)


    STATUTORY DETERMINATim*
 /^ Chuck Clarke, Regional Administrator
LsJLS. EPA Region 10

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 FINAL RECORD OF DECISION
 Vancouver Water Station 4
 EPA Region 10
Page vii
                         ABBREVIATIONS AND ACRONYMS
 ARAR       applicable or relevant and appropriate requirement
 bgs          below ground surface
 CERCLA     Comprehensive Environmental Response, Compensation, and Liability Act
 CFR         Code of Federal Regulations
 COC         chemical of concern
 COPC        chemical of potential concern
 DNAPL      dense nonaqueous-phase liquid
 EPA         U.S. Environmental Protection Agency
 HHRA       human health risk assessment
 HI           hazard index
 HQ          hazard quotient
 IRIS         Integrated Risk Information System
 kg           kilogram
 MCL         maximum contaminant level
 /"g           microgram
 mg           milligram
 MSL         mean sea level
 MTCA       Model Toxics Control Act
 NCEA        National Center for Environmental Assessment
 NCP         National Contingency Plan
 NPL         National Priorities List
 NTP         National Toxicology Program
 PCE         tetrachloroethene (also known as perchloroethylene)
 RAO         remedial action objective
 RBSC        risk-based screening concentration
 RCRA        Resource Conservation and Recovery Act
 RfD          reference dose
 RI/FS         remedial investigation/feasibility study
 RME         reasonable maximum exposure
ROD         Record of Decision
 SDWA       Safe Drinking Water Act
 SF           slope factor
TC A         1,1,1 -trichloroethane
TCE         trichloroethene
UCL95       95 percent upper confidence limit
VOC        volatile organic compound
WDOH      Washington State Department of Health

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FINAL RECORD OF DECISION
Vancouver Water Station 4                                                           ge V1"
EPA Region 10



                  ABBREVIATIONS AND ACRONYMS (Continued)


WS1         Vancouver Water Station 1
WS4         Vancouver Water Station 4

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 FINAL RECORD OF DECISION                                                       p   ,
 Vancouver Water Station 4
 EPA Region 10
                            DECISION SUMMARY
                             1.0 INTRODUCTION


 In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
 of 1980 (CERCLA), as amended, and, to the extent practicable, the National Oil and Hazardous
 Substances Pollution Contingency Plan (NCP), the U.S. Environmental Protection Agency (EPA)
 is selecting under CERCLA the existing air stripping treatment system to address environmental
 contamination at Vancouver Water Station 4 (WS4) in the city of Vancouver, Washington.  The
 selected treatment system has been constructed and is operational.

 EPA is the lead agency for overseeing the implementation of the selected remedy.  The selected
 action has the concurrence of the Washington State Department of Ecology and is responsive to
 the expressed concerns of the public. The selected action complies with applicable or relevant
 and appropriate requirements promulgated by EPA, Ecology, and other state agencies.


         2.0 SITE NAME, LOCATION, AND DESCRIPTION


 WS4, a public water supply station operated by the City of Vancouver, is located approximately
 '/2 mile north of the Columbia River at the intersection of East Fifth Street and Blandford Drive in
 the city of Vancouver, Washington (Figure 2-1). Vancouver is located in Clark County in the
 southwestern corner of Washington state, across the Columbia River from the city of Portland,
 Oregon. The site is located on a river terrace north of Lewis and Clark Highway (SR-14),
 adjacent to a commercial district and residential areas.

 The Superfimd site (CERCLIS ID No. WAD 988475158) was listed on the National Priorities
 List (NPL) in October 1992. The site is defined as the wellfield, which encompasses
 approximately '/2 acre and includes several support buildings, six production wells, two air
 stripping towers, and one capped well (Figure 2-2). Until the discovery that the groundwater was
contaminated with tetrachloroethene (also known as perchloroethylene, or PCE), WS4 provided
about 25 percent of the public water supply for the city of Vancouver. Only two of the

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                             Washington
                      vancoiiver
             Lewis and Clark Hwy
                          Columblaniver
   Figure 2-1
Site Location Map
    54-52-OJ3C
Vancouver Water Station 4
 RECORD OF DECISION

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  &EPA
  REGION 10
p   i   50-100



   SCALE IN FEET
Figure  2-2

 Site Map
     54-52-OJ3C

Vancouver Water Station 4


  RECORD OF DECISION
FILENAME  T-\voncouver\«s-«Vod\2-2 d»g

EDIT OMC- 04/19/99   AI l7-56

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4
  EPA Region 10
Page 4
  wells—the two with the lowest average concentration of contamination—have been used since
  1989.  Most drinking water for the city of Vancouver is supplied by other wellfields- WS4 is used
  primarily to meet peak demands for water, with the largest volumes pumped during the summer.

  WS4 pumps water from an alluvial zone in hydraulic communication with the Troutdale
  Formation, a deep aquifer from which several municipal wellfields and an unknown number of
  private wells draw water. Investigations into potential sources of PCE contamination at WS4
  have shown the persistent and widespread presence of PCE in this deep groundwater.  PCE is
  routinely measured in monitoring and private wells at levels near (and often above) the maximum
  contaminant  level (MCL) of 5.0 micrograms per liter (ug/L). In some cases, private wells located
  outside of, but in the vicinity of, the defined Superfiind site have been measured with much higher
 levels of PCE.  None of the private wells in the vicinity of WS4 are known to be used for
 domestic purposes. All known private wells within approximately 1 mile  of WS4 are on
 properties that are connected to city water for domestic water use. Property owners with known
 private wells in the vicinity of WS4 have been notified of the presence of PCE in groundwater
 they have been told that their private wells should not be used to supply domestic water (for
 drinking or bathing) but can be used for activities such as irrigation and washing cars. At this
 time the EPA does not intend to include the wider contamination by PCE  throughout the aquifer
 as part of the Superfund site.

 There are no  wetlands, flood plains, threatened or endangered species, or  properties on or eligible
 for the National Registry of Historic Places on this site.



      3.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES


 The wellfield  at WS4 has been owned by the City of Vancouver for over 50 years  The
 production wells at WS4 were installed during World War II to provide water for workers at the
 Vancouver Shipyards.  Water from WS4 is blended together with water from several other
 wellfields to provide drinking water to the  Vancouver region. The combined water supply system
 Provides drinking water to approximately 150,000 people throughout the Vancouver area Water '
 trom WS4 is primarily used to meet peak demand, particularly in the summer
3.1    INITIAL RESPONSE

When the federal Safe Drinking Water Act (SDWA) was amended to require suppliers of public
drinking water to monitor for volatile organic compounds (VOCs), the City of Vancouver began

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 FINAL RECORD OF DECISION                                                        page 5
 Vancouver Water Station 4
 EPA Region 10


 monitoring water from WS4 and its other wellfields.  Results of this monitoring, which began in
 March 1988, indicated a persistent presence of PCE in the water at WS4. In February 1989, in
 consultation with the Washington State Department of Health (WDOH), the City notified the
 public of the presence of PCE in the groundwater at both Water Station 1 (WSI) and WS4.
 Because PCE concentrations at WSI were much lower than those at WS4, the notice stated that
 WS1 water was being blended with WS4 water to reduce overall PCE concentrations.

 In April of 1989, the four WS4 wells with the higher PCE concentrations were taken out of
 service.  In May of 1989, EPA proposed an MCL for PCE for public drinking water systems of
 5.0 ug/L. EPA issued the final MCL for PCE (5.0 ug/L) in January 1991, with an effective date
 of July 1992 (40 CFR Part 141). Samples collected from the production wells in the spring of
 1989 showed concentrations of PCE ranging from approximately 3 to  10 ug/L,


 3.2    INVESTIGATIONS

 Several investigations into the  source or sources of PCE  at WS4 have been conducted by the City
 of Vancouver and EPA since PCE was detected at WS4 in 1988. The  investigations began in
 1989 by sampling private wells, surface water sources, and industrial sumps in the vicinity of
 WS4. Early investigations focused on dry cleaning operations on the Mill Plain plateau to the
 north (and upgradient) of WS4. PCE is commonly used as a solvent in dry cleaning, and dry
 cleaners are routinely considered in most investigations of an unknown source of PCE  in
 groundwater.

 Investigations of potential sources of PCE at WS4 included conducting soil-gas surveys, installing
 monitoring wells, and taking samples from monitoring and private wells in the vicinity of WS4.
 From 1989 through 1992 over 300 soil-gas samples were collected from hundreds of locations
within the expected capture zone of WS4.  The soil-gas results were inconclusive and although
they did not identify any specific "hotspots," they were used to locate monitoring wells.

 In 1990 the City of Vancouver installed seven monitoring wells at locations including Hamey
 School, Dubois Park, East Fifth Street, and the Park Hill  Cemetery.  In 1992 EPA installed an
additional eight monitoring wells and collected samples from the new wells and several existing
monitoring wells. (The new wells were installed at locations covering a wide area to the north
and northwest of WS4.)  Between 1993 and 1997 the City of Vancouver installed and collected

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   FINAL RECORD OF DECISION
   Vancouver Water Station 4                                                             Pa8e 6
   EPA Region 10


   samples from another eight wells on the Mill Plain plateau.  Two additional wells were installed by

  S'iSuW^    remedial inVeStigati°n " 1998' Figure 3-' Shows the ***»"• of wells in


  I-1"6 Ci,to0°/ Vanco"ver has also routinely collected samples from the production wells at WS4
  bmce  1988, more than 1,500 weekly samples have been collected and analyzed for PCE  (The
  product,on weH samples have been analyzed only for PCE, but all monitoring well samples have
  been analyzed for the full suite of VOCs.)

  3.2.1  Results of Investigations   ,

  The groundwater data clearly indicate that a pulse, or concentrated volume, of PCE passed
  through the wellfield over a period of several years beginning in 1992. PCE concentrations
  suddenly increased in 1992, peaked in about 1993, and decreased over the next several years to
  the current level (,n the range of 20 to 40 ug/L). Concentrations of PCE at WS4 have ranged
  from a low of less than 1 ug/L to a maximum of 520 ug/L. Although PCE has been measured in
   A ™l/n°    °n    '    highest average concentrations have measured in WS4-1 WS4-4B
 and WM-9. These production wells are located at the northern portion of the wellfield
 Production wells WS4-2B and WS4-5B, both on the southern portion of the wellfield have the
 lowest  average concentrations. (These are the only two wells that have been used for water
 production since 1989.) WS4-3B, located in approximately the middle of the wellfield, shows a
 concentration trend over time that is higher than the two southern wells but lower than the three
 northern wells.

 A similar pulse of PCE passed through PW-2, a private well located approximately 200 yards
 northeast (and upgradient) of the wellfield. The highest concentrations of PCE measured in this
 investigation were in PW-2 (concentrations of over 1,000 ug/L were routinely measured in PW-2
 «!l?r8,  A      1992)'  1?e City °f Vancouver PumPed PW-2 for several years (disposing of the
 water to the sewer system) m an effort to reduce the PCE entering the WS4 wellfield

 3.2.2  Sources of PCE


                                           of PCE may be present in the area.  (PCE has
                                                  co»-ntrations of PCE measured a°WS4
             to cleanup or other source control measures. Using this definition  no primary
ongomg source of the PCE in WS4 was ever identified.  Howevef, the significant reducS
or
or

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                               ge
  EPA Region 10


  PCE concentration over the last several years strongly supports the conclusion that there is not an
  ongoing source of PCE contamination in the area.
 3.3    INSTALLATION OF THE AIR STRIPPING SYSTEM

 In October 1988, the City began weekly monitoring of the water at each of the six wells at WS4.
 The City used the results to determine which wells to use for drinking water production to ensure
 that the concentration of PCE in the drinking water delivered to its customers was as low as
 possible.  In November 1989, the City removed WS4 from service.

 To regain full use of WS4, the City installed an air stripping system to remove PCE from the
 groundwater pumped by the station.  During the initial design of the air strippers, the
 concentration of PCE at WS4 was consistently in the range of 5 to 20 ug/L, so the stripper design
 was based on a maximum expected concentration of 100 ug/L. During 1991, however, the
 concentration of PCE in PW-2 rapidly increased to over 1,000 ug/L.  This upgradient well was
 being sampled weekly to provide an "early warning" of possible increasing concentrations of PCE
 at WS4. Because of this increase, the City modified the design of the treatment system to
 accommodate an input concentration  of more than 100 ug/L.  The two stripping towers,
 originally designed to run in parallel and to treat 8,000 gallons per minute (gpm), were '
 re-configured to run in series.  This design change reduced the total flow to 4,000  gpm,  but
 enabled the system to remove much higher concentrations of PCE.

 The redesigned treatment system was put into operation in January 1992, and has reduced
 concentrations of PCE in treated water to below detectable levels. Only two of the six wells at
 the water station—the two with the lowest average concentrations of PCE—have been used since
 the station resumed service in 1992.

 Following installation of the air stripping treatment system, the City changed the frequency of its
 monitoring of the untreated water from weekly to monthly.


3.4    ENFORCEMENT

Although the air stripping system was effectively removing PCE from water that the City was
distributing for drinking  water,  Vancouver WS4 was listed on  the NPL in October  1992 because
of the presence of PCE in the groundwater. The maximum detected PCE concentration reported
from a production well was 520 ug/L, reported on July 6, 1993 from WS4-9

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                             ge
  EPA Region 10


  As required under CERCLA, a preliminary health assessment was conducted by WDOH under
  cooperative agreement with the U.S. Department of Health and Human Services' Agency for
  Toxic Substances and Disease Registry. Released for public comment in April 1993, the
  preliminary health assessment evaluated only the effects of exposure to untreated PCE-
  contaminated water. The assessment identified one community health concern: the risk of cancer
  from drinking water contaminated with PCE. However, at the time that the assessment was
  prepared, the carcinogenicity of PCE was still under review by EPA and the assessment could
  state only that the likelihood of developing cancer as a result of lifetime exposure to PCE-
  contaminated water associated with WS4 could not be estimated.  The assessment also concluded
 that the site posed no apparent public health hazard to the known exposed population as a result
 of short-term exposure to elevated PCE concentrations in water.

 In September 1993, federal funding  constraints led to a decision by EPA to postpone further
 investigations of WS4, saving EPA's limited funding for sites with greater risk. (The threat to
 human health had been eliminated by the treatment system, which was fully operational in 1992.)

 In November 1997, EPA resumed work on the investigation of WS4. In March 1998, EPA
 collected samples from existing monitoring wells and private well PW-2.  In September 1998,
 EPA installed two additional monitoring wells and collected samples from monitoring and private
 wells in the vicinity of WS4.  Samples were collected using low-flow techniques and were
 analyzed for the full suite of VOCs.  PCE concentrations ranged from 1.1 to 19 9 ug/L in the
 March 1998 sampling and from 1.1 to 25.6 ug/L in the September sampling. Eighteen wells were
 sampled on both occasions; concentrations in 7 of these wells did not significantly vary from
 March to September, concentrations increased in 7 wells, and concentrations decreased in 4 wells.

 In 1999, EPA released the final remedial investigation and feasibility study (RI/FS) report for
 WS4. The results of the RI/FS report are summarized in this Record of Decision (ROD).


                      4.0 COMMUNITY RELATIONS


4.1   CITY OF VANCOUVER COMMUNITY RELATIONS EFFORTS

In February 1989 the City of Vancouver notified users of public water that PCE had been
detected in wells at WS4. The notice stated that the City was reducing the amount of water
pumped from WS4 and increasing the amount of water pumped from WS1 to reduce the
concentration of PCE in water delivered to its customers.  In November 1989, the City took WS4
out of service until a treatment system could be installed.

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 FINAL RECORD OF DECISION                                                        p   ..
 Vancouver Water Station 4                                                               S
 EPA Region 10


 In response to the water quality concerns at WS4, in 1989 the City began providing its water
 customers with an annual water quality report that it included with each customer's March billing
 statement. The contamination at WS4 was the subject of the first report.

 Also in response to the water quality concerns at WS4, in 1989 the City sponsored formation of
 the Water Quality Advisory Committee, which includes medical and legal experts, members of the
 community, state regulators, and representatives from the City's water department.  The Advisory
 Committee serves as a forum through which the City disseminates technical information to the
 public and receives input regarding the community's concerns.  The Advisory Committee issues
 recommendations to the City's Public Works Director and was instrumental in designing the
 City's policy for notifying the public about water quality incidents.


 4.2   EPA COMMUNITY RELATIONS EFFORTS

 EPA issued a fact sheet in July 1992 entitled "Vancouver Water Station #4 Contamination
 Superfund Site." This fact sheet described the startup of the air stripping system and announced
 plans to install monitoring wells in the vicinity of WS4 and to begin scoping for the remedial
 investigation.

 In October 1992, EPA issued a news release announcing that WS4 had been added to the NPL as
 a Superfund site.

 EPA's "Superfund Community Relations Plan" for the WS4 Superfund site was released to the
 public on February 1, 1993. The plan noted that 32,000 copies of the July 1992 fact sheet had
 been distributed and that EPA had met with members of the community on September 21  and 22,
 1992.  The plan also announced establishment of an information repository at  the Fort Vancouver
 Regional Library and stated that many Vancouver neighborhood associations and other local
 organizations had been placed on EPA's mailing list.

 In September 1993, EPA distributed another fact sheet entitled "Vancouver Water Station #4
 Contamination Superfund Site," announcing the postponement of the investigation of WS4 to
give funding priority to other sites with more immediate health risks and noting that monitoring
would continue while the investigation was on hold.

In September 1994, EPA released another fact sheet,  entitled "Vancouver Water Stations #1 and
#4 Contamination Sites," reiterating the postponement of the investigation at WS4 and noting that
the investigation at WS1  was also on hold.

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                            Page 12
  EPA Region 10


  The most recent fact sheet was released June 18, 1998, and provided summaries of previous
  activit.es at both WS1 and WS4.  The fact sheet noted that the Proposed Plan for WS1 was
  expected to be issued in July 1998, with the Proposed Plan for WS4 "to be developed early" in


  The RI/FS report for WS4 was released in May 1999 and made available to the public in the
  Administrative Record maintained at EPA Region 10, 1200 Sixth Avenue, Seattle  Washington
  and at the information repository maintained at the Vancouver Public Library Fort Vancouver '
  Branch, 1007 E. Mill Plain Boulevard, Vancouver, Washington. The Proposed Plan for WS4 was
  published on May 5, 1999. The notice of availability of these two documents was published in the
  Vancouver Columbian on May 5,1999.

  The public comment period was held from May 5, 1999, to June 3, 1999. Written  comments on
  the Proposed Plan and RI/FS report were received from two individuals and the City of
  Vancouver. The community had an opportunity to request  a public meeting during the public
  comment period on the Proposed Plan, but no requests for a public meeting were received.

 This decision document presents the selected remedial action for the WS4 site in Vancouver
 Washington chosen in accordance with CERCLA, as amended,  and, to the extent practicable  the
 INUF.  1 he decision for this site is based on the Administrative Record.
           5.0  SCOPE AND ROLE OF RESPONSE ACTION


 This site consists of one operable unit. The selected remedy is the final action at this site.

 The City of Vancouver and EPA conducted numerous investigations prior to the remedial
 investigation, spanning a period of 10 years, to identify the source of PCE entering WS4  but an
 ongoing source (or sources) of the PCE contamination for which cleanup action could be taken
 was never identified.  Although it appears that a pulse of higher-concentration PCE passed
 through the water station, a definitive PCE plume has not been delineated  No additional
 investigation into potential sources was conducted during the remedial investigation because
 concentrations at WS4 had decreased substantially and there was no evidence of an ongoing
 source area where cleanup action could be taken.

 The response action is therefore focused on the groundwater at the wellfield and on ensuring that
the dnnlcing water distributed by WS4 meets the standards that are protective of human health
The scope of the response action at WS4 is the following:

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                              ge
  EPA Region 10


        •      Ensuring that human health is protected by reducing the level of PCE in drinking
               water produced from WS4 to meet federal drinking water standards

        •      Reducing the concentration of PCE in the groundwater at WS4 to below the MCL
               of 5
 EPA's response action for WS4 is to select the continued treatment of drinking water produced
 from WS4 by using the air stripping treatment system that is already in operation  Continued
 operation of the air stripping treatment system at WS4 to provide clean drinking water will also
 serve as a treatment system for the contaminated groundwater at the wellfield.



            6.0  SUMMARY OF SITE CHARACTERISTICS


 6.1     PHYSICAL CHARACTERISTICS

 6.1.1   Surface Features

 The Vancouver area is situated on a series of gentle terraces rising to the north from the Columbia
 River. WS4 is located about '/2 mile north of the Columbia River, near the first terrace above the
 Columbia River flood  plain at an elevation of approximately 100 to 1 10 feet above mean sea level
 (msl).  Topography is  flat with a gentle slope to the west. South of the site, the ground surface
 slopes down to the flood plain, which is at an elevation of approximately 30 feet above msl
 North of the site, the ground surface slopes steeply upward to elevations of approximately 250 to
 300 feet above msl at the top of the second terrace north of the Columbia River  This terrace is
 located  roughly at Mill Plain Boulevard and is referred to as the Mill Plain plateau.

 Water, Station 4 is located within a fenced area in a neighborhood that also includes single and
 multifamily residences and small commercial businesses to the west, north, and east  The Lewis
 and Clark Highway is south of the site. Paved areas are typically equipped with stormwater
 drains, which are part of the city's stormwater system.

 6.1.2   Geology

 The geological setting  of the Vancouver area consists of 2,000-foot thick Cenozoic-Age basaltic
 basement rock  overlain by Miocene to Pliocene Age sedimentary bedrock units (the Lower and
Upper Members of the Troutdale Formation), topped with Pleistocene to Holocene Age
unconsohdated alluvial sediments.

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  FINAL RECORD OF DECISION                                .                        p    ,,
  Vancouver Water Station 4                                                               g
  EPA Region 10


  The sediments of the Upper Member of the Troutdale Formation contain a lower layer of coarse-
  grained sandy gravel and an upper layer of cemented gravel. A period of erosion and weathering
  followed deposition of the Troutdale Formation, resulting in a highly weathered zone at the top of
  the Troutdale Formation and a thin soil horizon. The Pleistocene alluvium of the Orchards Gravel
  overlies the Troutdale Formation.  The Orchards Gravel is composed  of coarse-grained sand and
  gravel in the area of the Columbia River flood plain with finer-grained sands present as lenses
  and/or stringers within the coarse-grained material in the terraced areas.

 Lithology in the wider vicinity around WS4 is dependent upon location.  Boring logs for wells in
 the Mill Plain plateau describe sand with variable amounts of silt and gravel (Orchards Gravel) to
 depths ranging from approximately 130 to 140 beet below ground surface (bgs).  A 3- to 7-foot-
 thick, low-permeability, sandy silt/clay with gravel is present below the sand that represents the
 weathered top of the Troutdale.  Gravel with variable amounts of sand and silt is present beneath
 the silt/clay unit to depths in excess of 300 feet bgs.

 Boring logs for wells in the immediate area of WS4 describe silty sand with minor amounts of
 gravel to depths of approximately 80 feet bgs. A gravelly silt to clay is present from
 approximately 80 to 130  feet bgs in the western portion of the area (data from MW4-6) that thins
 to the east (data from MW4-4). These sediments are assumed to be alluvial deposits from the
 Columbia. The Troutdale is observed below the alluvial sediments.  The weathered top of the
 Troutdale does not appear to be present in the lower elevations  (i.e., elevations similar to those of
 WS4) at the base of the Mill Plain bluff.

 The physical conceptual site model (Figure 6-1) is based on an interpretation of the geological
 data that concludes that the weathered top of the Troutdale was eroded in the area between WS4
 and the top of the Mill Plain plateau by the Columbia River prior to the deposition of the
 Orchards Gravel. Wells installed in the Mill Plain plateau to the north of WS4 provide strong
 support for the conclusion that the Orchards Gravel is prominent on the plateau, but not present
 at the lower terrace occupied by WS4.

 6.1.3  Hydrogeology

 Groundwater in the Vancouver area is produced primarily from two formations  the Orchards
 Gravel (also referred to as the shallow groundwater zone) and the lower portion of the Upper
Member of the Troutdale Formation (referred to as the deep groundwater zone).  Production
wells at WS4 are screened in the deep groundwater from either the Troutdale Formation or
alluvium in direct hydraulic  communication with the Troutdale Formation.

WS4 produces groundwater from a gravel unit within the lower portion of the Upper Member of
the Troutdale Format.on.  This deeper groundwater formation extends  approximately from 200 to

-------
                                       Representative
                                       Shallow Monitoring Well
                                                                                             Representative
                                                                                             Deep Monitoring Well
                                                                                                                                                    Representative
                                                                                                                                                    Private Well
                       Mill Plain Plateau^
                                                                      i&iinifr^.-..?-.-^T"- l&nttl..-— - Tl""

                                 Hypothetical Ckintaminanl/Groundwater Migration Routes
               	Groundwater Aquifer Surface

                                 Hypothetical Contaminant Plume
                                                                                                                                                           Wellfield-
                                                                                                                                                           Water Station 4
          REGION 10
           Figure 6-1
Physical Conceptual Site Model
      54-52-OJ3C
Vancouver Water Station 4
 RECORD OF DECISION
41F006252030-2M41499

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                             Pa£e 16
  EPA Region 10


  250 feet bgs and is known to be present below the Mill Plain plateau, with a hydraulic gradient to
  the south-southwest toward the Columbia River.  Specific capacities are reported to exceed 300
  gallons per minute per foot of drawdown, and the individual production well yields range from
  600 to 2,000 gallons per minute.
      -r              Shall°W Sroundwater z°ne >s ™t known, although it is known to exist in
 the Mill Plam plateau, specifically in the area of the Tower Mall shopping center The shallow
 groundwater zone is found at a depth of about 120 feet bgs and is generally about 10 to 20 feet
 thick  Apparent groundwater flow in this perched zone is to the west.  Based on boring logs
 developed during s.te investigation activities, the Orchards Gravel does not appear to provide a
 potential for significant water resources in the immediate area of WS4.


 6.2    NATURE AND EXTENT OF CONTAMINATION

 PCE is the primary chemical of concern, although acetone and bromoform have also been
 detected.

 6.2.1   Chemicals of Potential Concern

 PCE is the only chemical of potential concern (COPC) identified in untreated water from
 production wells, monitoring wells, or private wells in the vicinity of WS4 because it is the most
 frequently detected chemical and is detected at concentrations significantly greater than the risk-
 based screening concentration (RBSC). The RBSC is equal to \x\0~6, using EPA standard
 exposure assumptions for drinking water use. Other detected chemicals, as well as chemicals that
were not detected but that had sample  quantitation limits greater than the RBSCs, were eliminated
from further evaluation for one or more of the following reasons:

      •     The chemical was infrequently detected or not detected in any sample  (e g
             bromoform in production wells; 1,1,1-trichloroethane in deep wells; and acetone in
             shallow wells).  Numerous volatile organic  compounds were analyzed  for in
             samples collected but were never detected.

      •      The chemical was detected at concentrations less than the RBSCs (e g
             bromoform in production wells; 1,1,1-trichloroethane in deep wells acetone in
             shallow wells).

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                               ge
  EPA Region 10


        •      The chemical was detected at concentrations greater than the RBSCs, but the
               magnitude of the exceedance was not great, or the concentration has decreased to
               less than the RBSCs during recent sampling events (e.g., chloroform in deep wells;
               benzene in shallow wells).

        •      Available data from prior to 1996 may not be representative of current conditions
               because of changing groundwater conditions over time.

 6.2.2 Acetone Detections

 Although PCE was the only COPC for the WS4 site, acetone was recently detected at elevated
 concentrations in the groundwater beneath the Mill Plain plateau. In September 1998, acetone
 was detected in samples from five wells (MW4-DP1, MW4-DP2, MW4-5S, MW4-14S, and
 MW4-PHC).  At four of these five wells, the detected concentrations of acetone were much less
 than the RBSC of 3,650 ug/L. (An MCL for acetone has not been established.)  In MW4-PHC
 however, the reported concentration of acetone was 42,600J ug/L.  Because acetone had not
 previously been detected in this well, and had never been detected at any elevated concentration in
 a monitoring well in the vicinity of WS4, MW4-PHC was resampled in January 1999 The
 concentration of the sample collected in January was 930 ug/L, less than the RBSC but still higher
 than any other detected concentration of acetone in wells near WS4. The elevated concentrations
 of acetone in MW4-PHC are too high to have been caused by laboratory contamination.
 (Acetone is commonly used as a solvent in laboratory extractions, so low levels of acetone
 detected  in environmental samples are often attributed to laboratory contamination.) Accordingly
 these concentrations are probably representative of actual groundwater conditions.

 The City of Vancouver has been notified about  the detected concentrations of acetone in
 groundwater at the Mill Plain plateau. The City has indicated that it will begin monitoring for
 acetone in samples routinely collected from production wells at WS4. (The current practice is to
 analyze these samples only for PCE). Further investigation into the acetone detected in MW4-
 PHC is not being pursued under EPA's investigation of the PCE contamination at WS4 for the
 following reasons: (1) acetone was detected only recently and has no apparent relationship to the
 historical releases of PCE, (2) acetone was detected in the Mill Plain area only at  low
 concentrations (except for MW4-PHC), (3) MW4-PHC has shown a significant decrease in
 acetone over a 4-month period, and (4) acetone is both miscible in water and readily
 biodegradable, and therefore is unlikely to reach WS4 in concentrations approaching the RBSC of


Therefore, PCE is the only chemical evaluated in the remedial investigation.

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 FINAL RECORD OF DECISION                                                        page 18
 Vancouver Water Station 4
 EPA Region 10


 6.2.3   PCE Concentrations

 Summaries of PCE concentrations are presented by medium in the following paragraphs.

 Soil-Gas

 Soil-gas sampling was conducted in early investigations to identify PCE "hotspots," particularly
 near the existing and former dry cleaning facilities on the Mill Plain plateau. When the
 concentrations of PCE began to increase at WS4 productions wells and at PW-2, additional soil-
 gas sampling was conducted in the PW-2 area.  The results were useful in helping locate potential
 sites for monitoring well installation, even though none of the concentrations were considered
 indicative of an ongoing PCE source area for which cleanup action could be taken.

 Soil

 Approximately 100 soil samples were collected from a range of depths during installation of six
 monitoring wells in the vicinity of WS4. Additionally, surface soil samples were collected from
 five locations in the vicinity of the dry cleaning businesses on the plateau. Relatively few soil
 samples were collected so the lateral coverage of soil data across the area is therefore limited.
 However, laboratory-reported analytical results from these samples do not show significant
 detections of PCE or degradation products.

 Groundwater

 To evaluate the extent of PCE contamination, existing groundwater data for the site were
 separated into the following three data sets based on well location and the groundwater formation
 in which the well is screened:

       •      WS4 production wells
       •      Wells completed in the deep aquifer (Troutdale Formation)
       •      Wells completed in the shallow aquifer (Orchards Gravel)

Results for these three groups of wells are discussed in the following subsections.

Production Wells.  WS4 consists of six active production wells and one inactive well. The six
active wells, which are all screened at approximately the same depth, are dispersed over a large
portion of the well field. Two of the active production wells (WS4-2B and WS4-5B), both
located in the southern portion of the well field, have had historically the lowest concentrations of
PCE. These are the only wells from which water has been produced by WS4 since 1989. PCE
concentrations in the four remaining active wells (WS4-1, WS4-3B, WS4-4B, and WS4-9) have

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 FINAL RECORD OF DECISION                                                        Pace 19
 Vancouver Water Station 4
 EPA Region 10


 varied over time, but are generally consistent with the overall wellfield pattern of sudden increase
 and gradual decrease in PCE concentrations.

 It is not known to what extent the pattern of higher concentrations of PCE in the northern portion
 of the wellfield (and lower concentrations in the southern portion) are related to the location of
 the release(s) of PCE responsible for contamination at WS4. Although an ongoing source for
 which cleanup actions could be taken has not been identified, the concentration of PCE in every
 production well has significantly decreased over the last several years.

 A summary of PCE detections in WS4 production wells, including maximum and minimum
 concentrations and the total number of samples compared to the number of samples exceeding the
 MCL of 5.0 ug/L, is provided in Table 6-1.

 Deep Wells.  Concentrations of PCE in the  16 deep monitoring wells and 4 deep private wells in
 the vicinity of WS4 vary considerably over time and by location. Low concentrations of PCE (but
 still above the MCL of 5.0 ^ig/L) appear to be widespread in the deep groundwater; PCE has been
 detected in every deep well in the vicinity of WS4 and has been measured in concentrations above
 the MCL in 17 of the 20 wells used in this evaluation.

 The highest concentration of PCE measured in any well during the investigations was 1,600 ug/L
 at PW-2, a deep private well located about 200 yards upgradient of the wellfield.  The next
 highest concentration in a deep well was 145 ug/L, at private well PW-9 about '/2 mile northwest
 of WS4. The highest concentration of PCE measured in a deep well on  the Mill Plain plateau was
 66.7 ug/L, at MW4-DP2.

 These maximum concentrations do not appear to be part of any common plume.  Two deep
 monitoring wells were installed near PW-2. MW4-7, located a few hundred feet east of PW-2,
 had the highest detected concentration of PCE in any of the monitoring wells  sampled during the
 investigations (100 ug/L in 1992). However, concentrations in MW4-1, located a few hundred
 feet west of PW-2, have all been below the MCL. This is strong  evidence that a high-
 concentration PCE plume was not widespread and was limited to a relatively narrow channel that
 was intercepted by PW-2.

 A summary of PCE detections in the deep-zone wells, including maximum and minimum
 concentrations and the total number of samples compared to the number of samples exceeding the
MCL of 5.0 ug/L, is provided in Table 6-1.

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FINAL RECORD OF DECISION
Vancouver Water Station 4
EPA Region 10
                                           Page 20
                                       Table 6-1
                Summary of PCE Detections in Groundwater (1988-1998)
              Minimum
               Detected
              PCE
 Maximum
 Detected
PCE
Detections/
  Total
 Samples
Exceedances/
   Total
  Samnles
  Date
Detected
  Date
Detected
 Production Wells
II WS4-I
WS4-2B
WS4-3B
	 	
WS4-4B
WS4-5B
WS4-9
Deep Wells
MW4-1
MW4-2
MW4-3
MW4-4
MW4-5
II MW4-6
MW4-7
MW4-8D
MW4-8I
MW4-DP1
MW4-DP2
MW4-FS1
MW4-FS2
MW4-HS1
MW4-HS2
MW4-PHC
PW-2
j_ PW-7
PW-8
PW-9
1 Shallow Wells
| MW4-3S
1 MW4-5S
' MW4-8S
5.2
0.98
3.6
15.9
0.24
8

0.6
0.6
12.1
11
19.9
2
1.3
8.6
0.7
0.37
2.2
3.99
2.01
0.9
0.61
1.45
0.2
7.9
11.6
0.77

3.2
5.5
1.6
1989
1990
1989
1997
1990
1998

1997
1997
1998
1989
1998
1998
1997
1998
1996
1990
1998
1990
1990
1990
1990
1990
1989
1990
1998
1990

1998
1998
1996
370
380
450
390
501
520

1.8 J
1.3
17
11
50
5.7
100
8.6
1.1
9.8
66.7
18.8
7.2
7.45
5.71
5.5
1,600
93
55
145

55
5.5
23
1992
1993
1992
1992
1993
1993

1998
1992
1997
1992
1992
1992
1992
1998
1997
1998
1990
1992
1998
1992
1991
1991
1992
1992
1989
1992
"" • '•
1992
1998
1997
290a
287*
258"
294a
293"
276"

5/5
3/5
4/5
1/2
5/5
3/3
5/5
1/6
5/6
7/10
18/18
7/7
6/6
14/15
4/6
9/11
262b
7/7
5/5
5/5

5/5
1/1
8/8
290/290
287/287
258/258
291/294
292/294 1
271/276
J 	 f^ 	 J
0/5 [
0/5 j
4/5
1/2 '
5/5
1/3
4/5
1/6
0/6
2/10
17/18
4,7"
2/6 1
9/15
2/6
1/11
205/262
7/7
5/5
4/5
..-,:,,:^,:,
3/5
~~^I 	
	 — — 	
5/8 \

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4
  EI'A Region 10
                                                                    Page 21
                                   Table 6-1 (Continued)
                  Summary of PCE Detections in Groundwater (1988-1998)
    Well ID*
    MW4-9S
 Minimum
 Detected
PCE i
  Date
Defected
 Maximum
 Detected
FCEl
  Date
Detected
Detections/
  TotaJ
 Samples
Exceedances/
   Total
  Samples
 "Well locations are shown in Figure 3-1.
 "Number of samples in provided data set. Documentation not provided to evaluate nondetects.

 Notes:
 Exceedance - equal to or greater than 5 ug/L
 ug/L - micrograms per liter or part per billion (ppb) equivalent
 ND - not detected
 PCE - tetrachloroethene


 Shallow Wells.  Nine monitoring wells have been installed in the shallow groundwater zone at
 locations near or downgradient from former and current dry cleaning operations on the Mill Plain
 plateau (including four installed during 1998).  These wells were installed in an attempt to identify
 the shallow groundwater plume of PCE that would have first materialized if a surface release of
 PCE was moving down through the soil column.


 The maximum PCE concentration (55 ug/L) was observed in a water sample collected from
 shallow well MW4-3S in October 1992.  The well is located directly downgradient from current
 and historical dry cleaning facilities in or near the Tower Mall. Concentrations of PCE in this well
 have steadily decreased over the last 6 years and in 1998 were below the MCL.

 PCE concentrations exceeding the MCL (23 ug/L at MW4-8S and just under 10 ug/L at
 MW4-9S) had been observed in 1997, but at both locations concentrations were below the MCL
 in the 1998 sampling.  Only one of the four remaining wells has had a detection of PCE that
 slightly exceeded the MCL (5.5 ug/L at MW4-5S). PCE concentrations detected during the
 September 1998 sampling at  newer wells MW4-13S and MW4-14S were 2 5 and 2 8 us/L
respectively.                                                                       '

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  FINAL RECORD OF DECISION                                                       Paee22
  Vancouver Water Station 4                                                              g
  EPA Region 10

                                                                          i
  A summary of PCE detections in the shallow-zone wells, including maximum and minimum
  concentrations and the total number of samples compared to the number of samples exceeding the
  MCL of 5.0 ug/L, is provided in Table 6-1.
                       7.0  SUMMARY OF SITE RISKS


 Typically, a baseline risk assessment is conducted during the remedial investigation at an NPL
 site.  A baseline risk assessment is an analysis of the potential adverse health effects caused by
 hazardous substance releases from a site in the absence of any actions to control or mitigate these
 releases. WS4 differs from the typical NPL site in that remedial action (air stripping treatment of
 drinking water produced from WS4) has already been implemented.  Because of this the human
 health risk assessment (HHRA) for WS4 evaluates both an action alternative (treatment of water
 by air stripping, the current situation) and a no-action alternative (a potential future scenario that
 could occur if air stripping were to be discontinued). The HHRA is summarized in Section 7.1.

 An ecological risk assessment is a process that evaluates the likelihood that adverse ecological
 effects may occur or are occurring as a result of exposure to one or more stressors. At WS4, the
 stressor consists of PCE in the groundwater, which occurs at a depth of about 200 feet below
 ground surface. As discussed further in Section 7.2, no exposure pathway to PCE in groundwater
 has been identified for ecological receptors.


 7.1    HUMAN HEALTH RISK ASSESSMENT

 An HHRA was performed to evaluate risks to residents of Vancouver who use water produced
 from WS4 as their primary source of drinking water.  The risk assessment consists of four main
 components:

       •     Identification of COPCs
       •     Exposure assessment
       •     Toxicity assessment
       •     Risk characterization

These components are summarized in Sections 7.1.1  through 7.1.4. The qualitative uncertainty
analysis is summarized in Section 7.1.5.

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 FINAL RECORD OF DECISION                                                       p   23
 Vancouver Water Station 4
 EPA Region 10


 7.1.1   Identification of Chemicals of Potential Concern

 In accordance with EPA Region 10 guidance, a risk-based screening approach was used to
 identify COPCs in drinking water at WS4.  The chemical screening consisted of comparing
 concentrations of chemicals detected in groundwater at WS4 to risk-based screening
 concentrations established by EPA. In untreated water from production wells, monitoring wells,
 or private wells, PCE was identified as the only COPC because it is the most frequently detected
 chemical  and is detected at concentrations significantly greater than the risk-based screening
 concentration (RBSC). No COPCs were identified in treated water.

 7.1.2   Exposure Assessment

 The exposure assessment identifies potential receptors and estimates the type and magnitude  of
 exposures to the COPC (PCE) that was identified in Section 7.1.1.  The results of the exposure
 assessment are then combined with the chemical-specific toxicity information (Section 7.1.3)  to
 characterize potential risks (Section 7.1.4).

 The four steps in  exposure assessment are characterization of the exposure setting and potential
 receptors, identification of exposure pathways, development of exposure point concentrations,
 and quantification of chemical intakes.

 Characterization of the Exposure Setting and Receptors

 Three groups of receptors were evaluated:
              Future public water supply users
              Future private water supply users
              Current private water supply users
Identification of Exposure Pathways

,The primary medium to which exposure may occur is groundwater. WS4 is one of several water
stations that supply drinking water to people in the city of Vancouver and surrounding Clark
County.  Although there is a potential exposure pathway for current public water supply users
(i.e., people using treated water produced by WS4), PCE has not been identified in the treated
water and therefore the exposure pathway to these receptors is incomplete.

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4
  EPA Region 10
 Page 24
  Three potentially complete exposure pathways (Figure 7-1) were evaluated:

         •     Future public use of untreated water from the production wells if treatment
               to be discontinued
were
         •      Future private use of untreated groundwater from shallow or deep wells installed
               in the area around WS4 (represented by shallow and deep monitoring wells in this
               nsk assessment)

         •      Current private use of untreated water from private wells near WS4 as a drinking
               water source

 Potential exposure pathways for area residents using untreated water as a drinking water source
 include ingestion of PCE in untreated water, inhalation of PCE in untreated water during
 household use of water, and dermal contact with PCE in untreated water during bathing.

 Significant exposures to untreated water by on-site workers are not expected to occur
 (Figure 7-1).  Water is transported through the water station and treatment units via pipes
 making direct contact with untreated water by workers unlikely.                       '

 Potential exposures to PCE in air may occur as a result of stack or fugitive emissions from the air
 stoppers. According to the Order of Authorization to Operate issued by the Southwest Air
  ?2S?!l      Ol Authority in 1997 (Authorization No. 95CL-512), the combined air emissions
 of PCE from two air stripping columns will be controlled by four granular activated carbon
 canisters, and will not result in ambient air concentrations of PCE in excess of the applicable
 Small Quantity Emission Rates as provided in Washington Administrative Code (WAC) 173-460
 The granular activated carbon canisters are designed to achieve better than 95  percent removal of
 PCE from the vapor phase.  The emissions from the carbon canisters are released through a stack
 at a height of at least 12 feet above ground level. Therefore, although there will be som? small
 release  of PCE to the air, potential exposures to site workers or area residents  are believed to be
 minimal.

 Development of Exposure Point Concentrations

 Exposure point concentrations are media-specific concentrations of a COPC that an individual
 may plausibly come into contact with. Exposure point concentrations were developed for the
 future residential scenarios using PCE data collected between 1996 and  1998 from untreated
water from individual production wells at WS4 and monitoring wells installed in the vicinity
during source investigations. Exposure point concentrations were developed for the current
residential scenario using PCE data collected in  1998 from untreated water from private wells It

-------
                                                                                                   Receptors
Source

••
Unknown
Sourcefs)
•

Release
Mechanisms

Direct
— * Discharge to
Soil

Spills/Leaks to
Soil

Discharge to
^""^ DryWell

Leaching
k
t"
teaching
Leac


ling
Secondary
Sources

— »


L


WS4 Treatment -
System


Exposure Media
•M
mmm
1
-*•
*
L

Private
Water
Supply Well



Stack/Fugitive
Air Emissions


Public Water
Supply



Exposure
Pathways
u
i
Currant
Water
Supply
ler Without
reatment
Future
Water
Supply
Jser Without
Treatment
X \
Ingestion
— > Inhalation
Dermal Contact
•
•
•
O
o
o
Site
Worker
/
O
o
o

k-*j Inhalation
O

Ingestion
-* Inhalation
Dermal Contact

o
o
o

o
9 <

•
•
%
O (
O (
O (

Future
Area
tesldentlal
User
/
0
Q
•

D

:>
D
3

•
3
O
Potentially complete exposure pathway
Potentially complete but less significant;
will not be quantified
Exposure pathway incomplete or no
COPCs identified
c/EPA
REGION 10
           Figure 7-1

Human Health Conceptual Site Model
    54-52-OJ3C
Vancouver Water Station 4

 RECORD OF DECISION

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                              ge
  EPA Region 10


  is conservatively assumed that the chemical concentrations remain constant over the assumed
  exposure periods (i.e., up to 30 years).

  EPA guidance states that "because groundwater is a very complex and dynamic medium with
  characteristics that can change seasonally, it is likely that concentrations of a given contaminant in
  each well will vary over time. Therefore, the concentration term is best described by an arithmetic
  average [over time]...". Because of the uncertainty associated .with estimating the true arithmetic
  mean from a limited number of samples, a degree of conservatism is needed in calculating
  exposure point  concentrations. This conservatism is provided by using the 95 percent upper
  confidence limit (UCL95) on the arithmetic mean or by using the maximum detected value when
  the variability in the sampling results in a UCL95 that exceeds the maximum detected value  The
  methodology used to calculate exposure point concentrations for each of the three exposure
  pathways is described below.

 Future Public Water Supply Users.  An area of high PCE concentrations within the capture
 zone of WS4 was not identified.  Therefore, the arithmetic average concentration (as represented
 by the UCL95) of PCE in each production well over time was used to characterize the range of
 potential future  exposures to untreated groundwater from the production wells.  Although PCE
 concentrations in the production wells appeared to be increasing in the late 1980s and early
 1990s,  concentrations have decreased significantly since the mid-1990s. Therefore, data collected
 during the previous 2 years (i.e., September 1996 through October 1998) were considered
 appropriate for use in this HHRA.

 Future Private Water Supply Users. The available 1996 to 1998 data for monitoring wells
 installed in the shallow and deep aquifers at WS4 were used to estimate hypothetical future
 exposure concentrations for potential future users of untreated shallow aquifer and deep aquifer
 water.  Maximum detected concentrations as reported from the 1996 or 1998 sampling events for
 the two location groups (shallow and deep) were used as exposure point concentrations.

 Current Private Water Supply User.  The available 1998 data for the four private wells located
 near WS4 were used to estimate current exposure concentrations for private well users  Specific
 uses of area private wells are unknown (e.g., drinking water, irrigation, industrial uses); therefore  -
 the same exposure pathways assumed for the production well source were assumed for the private
 InfCilS
Quantification of Chemical Intakes

Chemical exposures, or intakes, were determined using exposure models that combine various
exposure parameters related to behavior and physiology, such as exposure frequency and body

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 FINAL RECORD OF DECISION                                                         Page 27
 Vancouver Water Station 4
 EPA Region 10


 weight, with exposure point concentrations. Reasonable maximum (or high end) exposures
 (RMEs) were evaluated for this HHRA.

 The equations used to calculate intake from each exposure pathway are presented in the RI/FS
 report and are consistent with guidance from EPA Region 10.  Exposures were calculated for
 adults only.  EPA default exposure parameters were used to quantify these models; sources for
 the exposure parameters include EPA Region 10 supplemental guidance and EPA standard default
 exposure factors. Exposure is averaged over a lifetime (70 years, or 25,550 days) for carcinogens
 and over the exposure duration for noncarcinogens. A body weight of 70 kg was assumed for all
 exposure pathways.

 7.1.3  Toxicity Assessment

 Carcinogenic Effects

 Chronic inhalation exposure of mice and rats to concentrations of PCE resulted in liver cell
 carcinomas in male and female mice, an increased incidence of mononuclear cell leukemia in male
 and female rats, and an increase of renal tubular cell tumors in male rats.  No evidence of skin
 tumors was observed in a mouse skin initiation-promotion assay and no studies were located
 regarding cancer in humans after dermal exposure to PCE.

 In evaluating cancer, the numeric descriptor of carcinogenic potency is termed  a slope factor (SF).
 The slope factors for PCE are not available  on the EPA Integrated Risk Information System
 (IRIS) database, although they are reported in EPA's Risk Assessment Issue Paper for:
 Carcinogenicity Information for Tetrachloroethylene. The oral slope factor as listed was 0.052
 (mg/kg-dy1 and the inhalation slope factor was 0.002 (mg/kg-d)"1 for PCE. The IRIS database is
 typically selected as the primary source of toxicity criteria when evaluating health risks or setting
 health-based cleanup goals because of the extensive research effort and scientific review.
 However, the National Center for Environmental Assessment (NCEA) serves as an adequate
 source if toxicity criteria are not available in IRIS.

Noncarcinogenic Effects

Chronic exposure to concentrations of PCE in air caused abnormal hepatic function,
lightheadedness, headache, malaise, and dizziness in humans. Chronic occupational'exposure to
PCE in air causes significantly impaired functioning on neurobehavioral tests as compared to
controls.  In  another study, dry cleaning workers exposed primarily to PCE in air exhibited minor
liver and kidney changes. No studies on humans were found  in the literature regarding chronic
oral exposure to PCE.

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  EPA Region 10
Page 28
        mrn    r                            US6d in risk assessment are tenned reference
        (RfDs)  These are route- and duration-specific estimates of the average daily intake that
  can occur without appreciable risk of any adverse effects.

  The chronic oral reference dose of 0.01 mg/kg-day for PCE was derived based on a 6-week

  fcE accl± 'f mC?    reSUltCd ^ liV6r tOXidty-  ThC Uncertain* factor of 1.°°° ^signed to
  PCE accounts for '"traspecjes variability and extrapolation of a subchronic effect level to Jts
  chronic equivalent  The RfD confidence level is considered medium. Assuming a 100 percent
  oral-to-dermal adjustment factor, the dermal RfD value is the same as the oral SfD value The
  inhalation RfD of 0.  4 mg/kg-day used in the risk assessment was reported in EPA Region 9s
  preliminary remediation goal tables.                                           region y s

 Dermal Toxicity Values

 Calculation of risks from dermal exposures to groundwater requires dermal toxicity values
 Dermal toxicity values must be based on the absorbed dose (rather than the exposed or   '
 ~tT? ?    f X T6 de™al intakes are calculated M absorbed doses. Since EPA has not yet
 established any dermal toxicity values, approximate toxicity values were derived by extrapolation
 from oral toxic.ty values, assuming an oral absorption fraction of 1 .                  *poiauon

 7.1.4   Risk Characterization
                                 rCSUltS °f the exposure and toxidty assessments into a
            description of potential cancer and noncancer risks.  The method for risk
characterization used in this HHRA is consistent with EPA guidance.
cancer nsk of 1E-06 (or 1 x 10"6) corresponds to one additional cancer case in an exoosed
population of 1,000,000 people.  Similarly, an excess cancer risk of lE-oT(o^Tx 10°
corresponds to one additional cancer case in an exposed population of 10 000  Excess cancer

                     ^<^=^^^
                                                     °f IE-"6 '<> 1E-04 (40

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 FINAL RECORD OF DECISION
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 EPA Region 10
Page 29
 For current residents consuming treated water, no COPCs have been identified and therefore no
 excess cancers are expected to occur.  Therefore no chemicals were identified as chemicals of
 concern (COCs) in treated water.

 Cancer risks were calculated for residents using untreated water as the primary drinking water
 source. Results are summarized in Tables 7-1 through 7-3. Due to the inherent uncertainty in
 cancer risk calculations, total cancer risk values are reported to only one significant figure
 Potential cancer risks to residents using untreated water range from 2E-05 to 5E-06  The cancer
 risks are attributed primarily to water ingestion and dermal contact with water  Even thoush
these risks are within the NCP acceptable risk range, it is necessary to take an action at WS4
because groundwater has been shown to have persistent concentrations of PCE above the MCL.

                                       Table 7-1
                               Summary of Cancer Risks
                     Future User of Untreated Public Water Supply
                                      Table 7-2
                              Summary of Cancer Risks
                          Future Private Water Supply User

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 FINAL RECORD OF DECISION
 Vancouver Water Station 4
 EPA Region 10
Page 30
                                       Table 7-3
                               Summary of Cancer Risks
                           Current Private Water Supply User
Location kH>~ 'Ifrr*!
PW-2
PW-7
PW-8
PW-9
•-^IfffJSSi^
^rffinSkon?^
2.6E-06
1.1E-05
7.1E-06
7.4E-06
•fJEittliiligi'^S
3.8E-07
1.6E-06
l.OE-06
1.1E-06
:^OermSi^MitAA' '?
1.6E-06
6.8E-06
4.4E-06
4.7E-06
^S^l^P^-'-' ^
5E-06
2E-05
1E-05
1E-05
The potential for noncancer health effects from exposure to a chemical is evaluated by comparing
the estimated intake of a chemical over a specific time period with the RfDs for that chemical
derived for a similar exposure period.  This comparison results in a noncancer hazard quotient
(HQ).  Since exposure to PCE may occur simultaneously by more than one exposure pathway,
HQ values are summed to obtain a hazard index (HI). If the total HI is equal to or less than  1, it
is believed that there is no appreciable risk that adverse noncancer health effects will occur. If an
HI exceeds 1, there is some possibility that adverse noncancer effects could occur, although an HI
above 1 does not indicate an effect will definitely occur.

Potential noncancer hazard to residents using untreated water ranges from  an HI of 0.02 to an HI
of 0.2.  Results are summarized in Tables 7-4 through 7-6.  Since the total HI is less than 1 for all
pathways evaluated, there is no appreciable risk that adverse noncancer health effects will occur.

                                       Table 7-4
                            Summary of Noncancer Hazard
                     Future User of Untreated Public Water Supply
* ' X ' ,'„ „' X » ^?"
Location ID • '-
WS4-1
WS4-2B
WS4-3B
WS4-4B
WS4-5B
WS4-9
• ^;^'->?f f
•''•'l^e&iMfM
0.089
0.080
0.12
0.12
0.045
0.065

0.024
0.022
0.032
0.031
0.012
0.018
' -i''-"--"^'^-,^-,. '1^-"-,:
"- Dennal €&ata£t*
0.056
0.051
0.076
0.072
0.028
0.041

0.2
0.2
0.2
0.2
0.09


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 FINAL RECORD OF DECISION
 Vancouver Water Station 4
 EPA Region 10
Page 31
                                        Table 7-5
                             Summary of Noncancer Hazard
                            Future Private Water Supply User
                                       Table 7-6
                             Summary of Noncancer Hazard
                           Current Private Water Supply User
7.1.5  Uncertainty Assessment

There are a number of factors that can introduce uncertainty into any exposure and risk estimate.
The key factors and assumptions that contribute to uncertainty in this risk assessment are
summarized in the following discussion.

The estimates of risk in this assessment were based on the results of analytical data from several
separate sampling rounds. Although different analytical laboratories may have been used, it is
assumed that they used standard methods and followed similar quality control measures. '
Although the possibility exists for interlaboratory differences in measuring contaminant
concentrations, this uncertainty is not expected to be large.

Water samples collected from the production wells were pulled from the turbine pumps and
therefore some PCE may have volatilized during sample collection. EPA Superfund protocols
recommend sampling for VOCs under low-flow conditions to minimize loss of VOCs during
sampling. The effect of these sampling methods on concentrations of PCE is not known;

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  Vancouver Water Station 4                                                             *>a£e 32
  EPA Region 10


  however, they may result in an underestimate of PCE concentrations and the corresponding
  human health risk.                                                                 °

  Because an ongoing source (or sources) of PCE in the groundwater for which cleanup action
  could be taken have not been defined, there is considerable uncertainty associated with the
  potential PCE concentrations in off-site wells. It is possible that areas or pockets of groundwater
  with higher concentrations of PCE exist. If water from a private well in or near one of these areas
  was used  for domestic water purposes, the potential risk to users of the water from these wells
  could be higher than those presented in the HHRA.

  The RBSC comparison was designed to be conservative and the elimination of chemicals is not
  likely to result in a significant underestimate of risk.  All data available from sampling of untreated
  water in 1989 through 1998 were used to determine COPCs. Due to the limited set of avaiSe
  data (the City of Vancouver tested regularly only for PCE at WS4), these data may  not reflect the
  current concentrations of organic and inorganic contaminants other than PCE in untreated water.

 In some cases, analytical procedures were not sensitive enough to detect chemicals potentially
 present at  concentrations greater than RBSCs. For 1, 1-dichloroethylene and vinyl chloride high
 sample quantitation limits and their potential presence in the aquifer associated with WS4 may
 result in an underestimate of risk.                                                      y

 The evaluation of human health risks for the future resident used arithmetic average
 concentrations in untreated water over a period of time from 1996 through 1998.  It is not known
 whether concentrations will decline over the long term as natural attenuation processes reduce the
 concentrations of the COPCs, which would decrease risk, or whether input from existing or
 potential future sources may result in an increase in water concentrations of VOCs which would
 increase risk.  Therefore, potential future risks may be over- or underestimated.  The magnitude
 of this over- or underestimate cannot be determined with available information (although the data

                              the PCE contamination at WS4 peaked in the eariy 1990s and has
The daily intakes in this risk assessment were calculated in a very conservative manner
Conservative exposure parameters (e.g., intake rate, exposure frequency, and exposure duration) '
were used to calculate daily intakes.  This may result in an overestimation of risk  In add-on
there is significant uncertainty in the volatilization factor that predicts the concentration of VOCs
in indoor HIT.

Risks from dermal exposures were calculated based on dermal toxicity values extrapolated from
oral values using an absorption fraction of 1 . Because organics are readily absorbed, the degrS

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 FINAL RECORD OF DECISION                                                         Pa
 Vancouver Water Station 4                                                               age
 EPA Region 10


 of uncertainty associated with this assumption is believed to be small.  Thus, actual risks are likely
 to be slightly underestimated.

 No EPA-approved cancer SFs for PCE are available on the EPA IRIS database. The oral and
 inhalation SFs used in this risk assessment are reported in EPA's draft document Risk Assessment
 Issue Paper for: Carcinogenicity Information for Tetrachloroethylene. Therefore, there is a
 high degree of uncertainty associated with the cancer toxicity of this compound, and the actual
 risks may be over- or underestimated.

 In summary, estimates of exposure and risk are subject to a number of uncertainties that may lead
 to either an overestimate or an underestimate of risk.  While the magnitude and direction of these
 uncertainties is largely unknown, it is most likely that risks estimated in this assessment have been
 overestimated as a result of the conservative  assumptions contained in the various steps of the
 assessment.  In either case the selected remedy would still be appropriate and protective and
 would not change.
 7.2     ECOLOGICAL EVALUATION

 An ecological risk assessment is a process that evaluates the likelihood that adverse ecological
 effects may occur or are occurring as a result of exposure to one or more stressors.  The EPA
 framework consists of a three-phased approach:  '

        •      Problem formulation
        •      Analysis
        •      Risk characterization

 Problem formulation is a formal process for generating and evaluating preliminary hypotheses
 about why and how ecological effects may occur as a result of human activities. During problem
 formulation, available information is collected about the sources of stressors, stressor
 characteristics, exposure, the ecosystem potentially at risk, and ecological effects.  Assessment
 endpoints can then be identified, and a conceptual site model developed. The conceptual site
 model describes the predicted relationships between ecological entities and the stressors to which
 they may be exposed. A complete exposure pathway from the stressor source to an ecological
 receptor must exist for the risk assessment to proceed.

 A qualitative ecological risk assessment was performed for WS4 that consists of the conceptual
 site model portion of the problem formulation phase. The stressor present at the site (i e  the
wellfield) is PCE in the groundwater.  WS4 is located in a primarily undeveloped area with open
fields nearby where ecological receptors such as birds,  small mammals, and invertebrates forage

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  Vancouver Water Station 4                                                          PaSe 34
  EPA Region 10


  and live However these receptors are not exposed to contaminated groundwater, which occurs
  at a depth of about 50 feet below ground surface.

  The aquifer that supplies raw water to WS4 (Troutdale Formation) is believed to discharge to the
  Columbia River approximately 3,500 feet downgradient from WS4. Although the Columbia River
  sustains major fisheries, it transports vast quantities of water, and infiltration of contaminated
  groundwater from WS4 would be unlikely to have a detectable effect on water quality in the
  Columbia River.

  Because there are no potentially complete exposure pathways at WS4, there is no ecological risk.


                 8.0  REMEDIAL ACTION OBJECTIVES


 8. 1    NEED FOR REMEDIAL ACTION

 Even though the risks presented in the baseline risk assessment are within the NCP acceptable risk
 range, lt ,s necessary to take an  action at WS4 because groundwater has been shown to have
 persistent concentrations of PCE above the MCL.  EPA's 1991 guidance (Role of the Baseline
 Risk Assessment ,n Superfimd Remedy Selection Decisions) states that exceedances of the MCL
 can trigger the need for action.  In addition, the NCP requires that MCLs must be met in
 groundwater, not just at the tap.

 Although there are many uncertainties associated with this risk assessment and PCE

 2SST* ^ 8™"dwT ^ WS4 ^ bee" deCreasing Since ™d-19'93' Concentrations
 during 1998 were still from 2 to 8 times the MCL.

 Actual or threatened releases of hazardous substances from WS4, if not addressed by

                        action selected in this ROD' may present imminent
8.2    POTENTIAL SOURCES
                  n^StiSations h^e been conducted and 25 monitoring wells have been

been iden             *** " °ng°ing ^ ** wWch deanup action could be taken h- **

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                              rage 35
  EPA Region 10


  Dry cleaning facilities on the Mill Plain plateau, approximately 1 mile north/northeast of WS4
  were identified early in the investigations as a probable source of the PCE at WS4. However'
  these investigations were largely completed by 1992, before the sudden increase in PCE
  concentration at WS4 and nearby PW-2.  Although 17 monitoring wells have been installed in the
  vicinity of the dry cleaning facilities, PCE has been detected in these wells at only a fraction of the
  concentrations measured in WS4 wells. While it is therefore difficult to conclude that the dry
  cleaners are the primary source of PCE at WS4, it is probable that they contributed to the
  contamination.  Elevated concentrations of PCE have been measured in both the shallow and deep
 ground water zones in the plateau area.  The capture zone of WS4, although not well defined,
 almost certainly includes deep ground water from the plateau area.

 The extent of the high-concentration PCE plume is not known, but the significant reduction in
 concentration in production wells, monitoring wells, and private wells over the last several years
 indicates that there is not an ongoing source of PCE contamination in the area.

 Other potential primary sources of PCE at WS4 are speculative. The sharp increase and relatively
 fast decrease in PCE concentrations are consistent with a large, sudden release in the immediate
 vicinity of the wellfield, perhaps from illegal dumping.  There is no direct evidence of this
 however,  and the identity of the source or sources primarily responsible for the observed PCE
 contamination at WS4 remain unknown. Because the PCE concentrations at WS4 have been
 steadily declining, and the treatment system at WS4  is effective and reliable, further investigation
 into source identification does not appear to be warranted.  Given the extensive area in which the
 release could have occurred, and the improbability of identifying the source even with a larger
 investigation, the cost of additional investigation was determined to be disproportionate to the
 benefit. The concentration of PCE at the source or sources has almost certainly decreased
 significantly during the last 10 years and it is unlikely that an effective cleanup could be
 completed, given the high probability that PCE has moved via groundwater and sorbed onto soil
 over a large area. A fully effective cleanup of the source would not, in itself, immediately
 eliminate the need for continued treatment at WS4.


 8.3    TRANSPORT OF PCE TO WATER STATION 4

A pulse of groundwater with high concentrations of PCE moved through the WS4 wellfield and
immediate vicinity from about 1991 through 1993. The highest concentrations of PCE
(approximately 500 to 1,600 ug/L) were measured at the production wells and a single nearby
private well (PW-2).                                                            '      3

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  Vancouver Water Station 4                                                               ge
  EPA Region 10


  8.3.1  Mill Plain Release Scenario

  If dry cleaners on the Mill Plain plateau were the primary source of PCE at WS4 it seems likely
  that hundreds of gallons of PCE (and perhaps much more) would have had to have been released
  in a relatively short time to account for the spike in concentrations that began in 1992  More than
  200 gallons of PCE have been removed to date by the air stripping system at WS4, so the primary
  source of PCE would have had to have been at least several times that volume (or even more if
  the release point was as far away as the Mill Plain plateau).

  If such a large release had occurred in the Mill Plain area, it would have almost certainly caused a
  high-concentration plume of PCE in the shallow groundwater zone.  Any PCE that was released
  at the surface on the plateau would have migrated through the soil column and dissolved into the
 shaHow aquifer. A steady, long-term release would have gradually increased the concentration of
 PCE in the surrounding shallow groundwater.  A sudden, large release could have resulted in
 free-phase PCE settling onto the aquitard at the bottom of the shallow groundwater zone  (This
 would only occur if the release of PCE was large and sudden enough to overcome the solubility
 limit in water, approximately 150,000 ug/L.) The resulting plume of PCE would have spread
 with groundwater flow (towards the west). Although such a plume could have been relatively
 narrow, it seems highly unlikely that it would be undetected by any of the shallow monitoring
 wells in the area.

 8.3.2  Flowpaths to WS4

 To reach WS4, the plume of PCE in shallow groundwater (or, if present, free-phase PCE) would
 next have had to move through the aquitard at the bottom of the shallow groundwater zone
 through an unsaturated zone above the deep groundwater, and finally into the deep groundwater
 being drawn towards WS4. Even if most of the PCE moved through a large hole in the aquitard
 a plume of PCE in the shallow groundwater should still be identifiable. But investigations to date
 have not indicated the existence of such a plume; concentrations of PCE measured in shallow
 groundwater at the Mill Plain plateau have exceeded 25 ug/L only three times.

 The  next highest concentrations of PCE in groundwater (approximately 50 to 150 ug/L) have
 been measured in several locations in the vicinity of WS4 (mostly in deep wells), but they do not
 form an apparent pattern or indicate a common plume of PCE contamination.  It is possible that
 these areas are related, although the available data are not sufficient to establish relationship  It is
more likely, however, that the PCE contamination in groundwater near WS4 is the result of
multiple, independent releases or sources; PCE has been detected over too large an area to be
accounted for by a single point release.  It is also likely that one or more of those releases was
relatively large and sudden, given the sudden increase and relatively fast decrease in PCE
concentrations at WS4 production wells.

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 FINAL RECORD OF DECISION                                                        Page 37
 Vancouver Water Station 4
 EPA Region 10
 Of more than 30 production, monitoring, and private wells sampled in various investigations over
 the last 10 years, only monitoring well MW4-3, a deep well on the plateau, has not shown a
 significant trend of decreasing PCE concentrations since 1992. Concentrations at MW4-3 have
 remained relatively consistent at 10 to 20 ug/L.

 8.3.3  Preferential Pathways

 Controlled studies have shown that PCE can travel in narrow, preferential pathways, particularly
 through the unsaturated soil column.  Although it is possible that such preferential pathways have
 transported PCE to WS4, it is not likely that a large volume of PCE could have moved through
 two groundwater formations and an intermediate aquitard without being detected by an array of
 shallow and deep monitoring wells between the presumed source (Mill Plain plateau) and WS4.

 8.3.4  Degradation of PCE in Groundwater

 PCE will eventually degrade into less complex molecules, leaving a chemical chain of breakdown
 products that includes TCE and DCA. The conditions that lead to chemical degradation can be
 complex, but degradation is  generally thought to best occur under anaerobic conditions.   A
 comprehensive study of PCE degradation was not conducted at WS4 because a primary, ongoing
 source was never identified and the treatment system is effective and reliable.  However,  primary
 degradation products of PCE (including DCA and TCE) were analyzed for in all monitoring well
 samples.  Although these compounds were occasionally detected, they were not found in
 sufficient concentrations to indicate that chemical degradation of PCE was a significant factor in
 the trend of decreasing PCE concentrations in groundwater near WS4.


 8.4    CONCLUSIONS

 The PCE contamination at WS4 is persistent and present at levels that require continuing
 treatment to protect human health. (There are no complete pathways for ecological receptors and
 therefore there is no ecological risk.)  There is no suspected ongoing PCE source for which
 cleanup action could be taken, and additional investigations into possible sources or channels
would not be cost-effective.  Such investigations would be cost prohibitive because the area to be
covered is extensive.  It is probable that even an exhaustive investigation would fail to provide
significant additional information about potential sources. If a potential primary source were
 identified, it is probable that  no direct action would be feasible. Even if further remedial action
were feasible, it is likely that continuing operation of the treatment system at WS4 would be
required. It is therefore appropriate to continue treating the water from WS4, both to remove
PCE from the drinking water supply and to reduce the concentration of PCE in the groundwater.

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                                             Air Out
                         Untreated
                         Water In
«EPA
REGION 10
                                                             Water Distributor


                                                             Packing Restrainer
                                                             Random Packing
                                                             Water Redistributor
                                                            Packing Support

                                                            	Air In
                                                               - Treated
                                                                Water Out
     Figure 9-1
Typical Air Stripper
     54-52-OJ3C
Vancouver Water Station 4
 RECORD OF DECISION

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FINAL RECORD OF DECISION                                                        Page 41
Vancouver Water Station 4
EPA Region 10


       4.     Reduction of toxicity, mobility, and volume through treatment
       5.     Short-term effectiveness
       6.     Implementability
       7.     Cost of implementation
       8.     State acceptance
       9.     Community acceptance

The following sections summarize the detailed evaluation of alternatives in regard to these nine
criteria. For the WS4 site, the evaluation of alternatives is limited to the operating treatment
system alternative and the no-action alternative.
10.1   OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

The operating treatment, air stripping, has been proven to be effective in removing VOCs,
including PCE, from water, based on operational data at this and other sites. It therefore meets
the threshold criterion of protecting human health. (There is minimal risk to the environment
from this site because there is no potentially complete and/or significant exposure pathway to
untreated water for ecological receptors.) If compared against other removal technologies or
measures, air stripping would be rated excellent for protecting human health.

The no-action alternative would not be protective of current human health because routine
monitoring of untreated water has shown consistent concentrations of PCE above the MCL.
Furthermore, because most of the samples taken from untreated water were analyzed only for
PCE, it is possible that other VOCs are present in the groundwater. Exposure  to other VOCs  in
the groundwater, together with exposure to PCE, could increase the risk.  Given this uncertainty,
the no-action alternative would not be adequately protective of human health.  The no-action
alternative would not be protective in the future because users of water drawn  from WS4 would
be exposed to unacceptably high concentrations of PCE.
10.2   COMPLIANCE WITH ARARS

This criterion states that remedial alternatives will meet all ARARs of other federal and state
environmental and public health laws or provide justification for invoking a waiver.

The most significant ARARs for this site are the following:

       •     Federal and state Safe Drinking Water Act MCL for PCE of 5.0 ug/L

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  Vancouver Water Station 4                                                           PaSe 42
  EPA Region 10



               Washington State Model Toxics Control Act (MTCA) Method A level for PCE of
               5.0 jig/L; if other chemicals of concern are found in future monitoring, the cleanup
               level for those chemicals shall be determined by the ARARs listed in Section
               1 J~* • ^. I .


  The operating air stripping system as installed is compliant with all ARARs Moreover if

                                           —  a* — —" be —'
                                                                waste' so tre^ent or
                carbon from the strippers must be compliant with Resource Conservation and
 Recovery Act (RCRA) Subtitle C and Washington State dangerous waste regulaSonl
   mn^rf TIteT ^ W°Uld n0t bC C°mpliant With ARARs because PCE concentrations in
 samples of untreated water consistently exceed the MCL. Under both the NCP and MTCA, the
 5.0 ug/L concentrate of PCE must be met both at the tap and throughout the groundwater


 10.3   LONG-TERM EFFECTIVENESS AND PERMANENCE

 Remedial alternatives are typically assessed for long-term effectiveness and permanence and the

                   81                                            '
     vn                vnr                                      , is effective in
 nH ^h 8     ,an  Oter V9Cs that may be Present> from water. This treatment is permanent
and achieves a high degree of certainty of success.                              permanent


The no-action alternative would rate relatively low for long-term effectiveness and permanence
because there would be no removal of contaminants from water.                permanence
                  ^^
                                                              s~s

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 FINAL RECORD OF DECISION                                                         Page 43
 Vancouver Water Station 4
 EPA Region 10
 The no-action alternative would rely on natural degradation processes to reduce the toxicity,
 mobility, and volume of PCE.  These degradation processes are complicated and have not been
 examined in sufficient detail at this site. Accordingly, the no-action alternative would rate very
 low for this criterion.
 10.5   SHORT-TERM EFFECTIVENESS

 The alternatives were evaluated in terms of their effectiveness in protecting human health and the
 environment during construction and implementation of the remedy and until the response
 objectives have been met.

 The operating treatment system has already been installed, so there are no short-term
 effectiveness considerations for this site. Had the system been evaluated under this criterion
 before a decision was made, however, air stripping would have rated highly effective because the
 technology is well established and has proven to have relatively few short-term risks or potential
 environmental impacts. The proven nature of the technology also means that a construction
 schedule would have relatively few uncertainties.

 The no-action alternative would probably rate average for short-term effectiveness. Although
 there are no impacts or risks for implementation of the no-action alternative, the time until
 protection is achieved would be very long.
10.6   IMPLEMENTABDLITY

The technical and administrative feasibility of the alternatives was evaluated.

The operating treatment system has a well-established history as an effective means of treating
water contaminated with VOCs.  Air stripping systems are relatively simple to design and
straightforward to maintain.  Start-up and shut-down can be accomplished quickly, and the
modular design makes an air stripping system easy to construct. Air stripping would rate high for
implementability in any comparison with other alternatives for water treatment.

The no-action alternative would be easily implementable, so it would also rate high for this
criterion.

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4
  EPA Region 10
                                                                               Page 44
  10.7  COST OF IMPLEMENTATION
           t              ,            ir Stripping system at WS4 cost approximately
       ion to des.gn and build (including approximately $2 million to build a pumping station and
  cnn0^6 ^ City'S Water SyStCm With°ut WS4 until the Batmen' sys'tem a  WS4 was
  complete ). Operating costs are estimated to be approximately $230,000 per year not ncludinT

                 -
                                 "* **
                                                           Because there is no cost for
 10.8  STATE ACCEPTANCE
                                           of state agency
10.9   COMMUNITY ACCEPTANCE

The community was given the opportunity to review the Proposed Plan and to request a

         S°
Vaoerrnm
Vancouver  All comments were supportive of the selected remedy.  A detailed response to
comments ,s provided in the Responsiveness Summary (Appendix A)  Tlw,Wno^ir fn
public meeting and there were no objections to EPA'Tproposed Plan               q      "
                     1 1.0  THE SELECTED REMEDY
contaminated groundwater.
                            protective of human health anS the environment, provides the

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                              age 45
  EPA Region 10


  best overall effectiveness proportional to its costs, and includes treatment as a principal element
  The selected remedy also includes monitoring to evaluate system effectiveness at removing PCE
  from both groundwater and drinking water produced from WS4.


  ll.f  AIR STRIPPING

  Air stripping is a treatment technology in which the water to be treated trickles down through a
  tower in a "packed column" that breaks up the flow of water to create as much surface area as
  possible (Figure 9-1). Large volumes of air are then forced upward through the water
  transferring the volatile contaminants from the surface of the water to the air through the process
  of evaporation.                                                                   K

 The air to which the contaminants have been transferred is then treated by forcing it through
 carbon filters, which adsorb the contaminants.  The filters are then regenerated or treated and
 disposed of as a hazardous  waste.

 The air stripping system at WS4 consists of two packed columns operating in series and has been
 operating since January 1992. Use of air stripping has reduced concentrations of PCE in
 production water to below the level, of detection.

 The air stripping system is, and will continue to be, operated and paid for by the City of
 Vancouver. All drinking water produced by WS4 will be treated by the air stripping system until
 the City, the Washington State Department of Ecology, and EPA agree that the remedial action
 objectives have been met and the treatment can be terminated.

.Groundwater will be pumped from WS4 at a rate that varies, depending on the time of year and
 customer demand. All water pumped by WS4 will be treated and distributed to customers as
 drinking water.  Estimated costs for this remedy are:

 Capital costs:                      $5,000,000 (construction completed in 1993)
 Operation and maintenance costs:    $230,000 per year (includes monitoring but not
                                  depreciation)


 11.2   GROUNDWATER CLEANUP

By extracting and treating large volumes of groundwater for drinking water, WS4 acts as a very
large pump-and-treat system for removing contaminants from the aquifer near WS4.  The captun
zone for WS4 is estimated to be approximately 5 square miles over a 30-year period of time any
ture

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FINAL RECORD OF DECISION                                                       Page 46
Vancouver Water Station 4
EPA Region 10


contamination within this zone will eventually be pulled into the wellfield at WS4. Although the
large capture zone has made it impractical to try to identify an ongoing source of PCE for which
cleanup action could be taken, the high pumping rates for the production wells provide an
effective means of reducing the concentration of PCE in the groundwater near WS4.  Eventually,
the extraction of groundwater will flush out residual contaminants in the wellfield, although the
time to achieve the remedial action objectives is not known. Any decision to stop operating the
treatment system must be made with the concurrence of EPA and the Washington State
Department of Energy.                                                            *
11.3   GROUNDWATER MONITORING

Periodic monitoring of the groundwater will be performed by both the City of Vancouver and
EPA to evaluate the effectiveness of and the need for continued operation of the treatment system
at WS4. Groundwater monitoring will consist of sampling production wells  and monitoring wells
for PCE and other VOCs. The City of Vancouver will continue to monitor the water at WS4 and
will take at least one sample each year from each active production well.  EPA will continue to
review the City's data annually and will periodically, but no less often than every 5 years, sample
the available monitoring wells near WS4.

The results of groundwater monitoring will be evaluated annually and at the 5-year review for
WS4. Decisions on whether to continue and/or modify the monitoring program will be made by
EPA in conjunction with the City of Vancouver and the Washington State Department of
Ecology.
                12.0  STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select remedies that are protective of human health and
the environment, comply with applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and use permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. In
addition, CERCLA includes a preference for remedies that employ treatments that permanently
and significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected remedy meets these statutory
requirements.

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 FINAL RECORD OF DECISION                                                      p    47
 Vancouver Water Station 4
 EPA Region 10


 12.1   PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

 The selected remedy protects human health through treatment of drinking water produced from
 WS4 as well as groundwater by using air stripping to reduce PCE concentrations.  The
 contamination of groundwater at WS4 with PCE does not pose a threat to the environment
 because the groundwater is 50 feet below ground surface.

 Treatment of water produced from WS4 by air stripping reduces PCE concentrations to below
 detectable levels, and therefore there were no COPCs identified in treated water. There are no
 excess cancer or noncancer risks associated with ingestion, inhalation, or dermal contact with
 COCs in treated water because no such chemicals were identified.

 Air emissions for the treatment system are in compliance with the permit issued by the Southwest
 Air Pollution Control Authority.


 12.2   COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
       REQUIREMENTS (ARARS) AND OTHER CRITERIA AND GUIDANCE

 12.2.1  ARARs

The selected remedy, treatment of drinking water produced from WS4 by air stripping, complies
with all applicable or relevant and appropriate requirements (ARARs) that have been identified.
The chemical-,  location-, and action-specific ARARs are presented below.

       •      National Primary Drinking Water Regulations (40 CFR Parts 141.50 and
             141.60) and Washington State Maximum Contaminant Levels (MCLs)
             (WAC Chapter 246-290-330). These regulations, established under the Safe
             Drinking Water Act, are applicable to water at the tap. The federal MCL is
             relevant and appropriate to the groundwater of this drinking water aquifer.

       •      Washington State Model Toxics Control Act Cleanup Regulations (WAC
             Chapter  173-340-720). The groundwater cleanup levels established in the MTCA
             cleanup regulations are applicable to the groundwater at this site.

       •      RCRA Regulations (40 CFR Part 261) and Washington Dangerous Waste
             Regulations (WAC Chapter 173-303).  The City of Vancouver has designated
             the spent activated carbon units from the air strippers as dangerous waste. The
             units are sent off site for regeneration or disposal  as dangerous waste, and as such

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  FINAL RECORD OF DECISION                                                       Page 48
  Vancouver Water Station 4
  EPA Region 10


               the requirements for manifesting and transport as dangerous waste and treatment
               or disposal at a permitted RCRA Subtitle C treatment, storage, or disposal facility
               are applicable.

        •      U.S. Department of Transportation (49 CFR Parts 171 through 180) and
               Washington State Transportation of Hazardous Waste Materials (WAC
               Chapter 446-50).  If the spent activated carbon units contain hazardous waste,
               these transportation requirements would be applicable.

        •      Washington Minimum Functional Standards for Solid Waste Handling
               (WAC Chapter 173-304); Washington Criteria for Municipal Solid Waste
               Landfill (WAC Chapter 173-351); County Health District regulations.  If
               carbon filters are NOT dangerous waste then they will be disposed of off site as
               solid waste under the applicable regulations.

        •      General Regulations for Air Pollution  Sources (Section 400), Southwest Air
               Pollution Control Authority. On November 11, 1997, the City was granted
               Order of Authorization to Operate SWAPCA 95-CL-512 to operate the air
               pollution control equipment. Therefore, the requirements of the General
               Regulations and the Order of Authorization to Operate are applicable to the
               operation of the air strippers.  Independent of CERCLA,  the requirements of this
               permit (Order of Authorization to Operate) are the air pollution control
               requirements.

 12.2.2  Other Criteria, Advisories, or Guidance to Be Considered (TBCs) for This Remedial
        Action

 If the spent activated carbon used in treating the air stream at the air stripping system is disposed
 of or treated off site, the NCP off-site disposal rule (58 FR 49200, September 22, 1993) must be
'followed.
 12.3   COST-EFFECTIVENESS

 EPA believes this remedy eliminates the risks to human health. The system was designed and
 installed in 1992 at an estimated cost of $5 million. It has been operating successfully since then
 at an estimated cost of approximately $230,000 a year for operation and maintenance and
 monitoring (depreciation not included). Therefore the selected remedy provides an overall
 effectiveness proportionate to its costs, such that it represents a reasonable value for the money.

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  FINAL RECORD OF DECISION                                                       p
  Vancouver Water Station 4                                                              8
  EPA Region 10
 The selected remedy ensures a high degree of certainty that the remedy will be effective in the
 long term because of the significant reduction of the contamination in the water that has been
 achieved to date through use of the existing air stripping system. No other treatment options
 were evaluated because the existing system was already in operation when the site was listed on
 the NPL and the technology has proven to be effective for removal of VOCs from water.
 However, the cost for installing and operating an air stripping system compares well to other,
 equally effective treatment alternatives such as activated carbon or ultraviolet treatment.


 12.4   USE OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
        TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE
        MAXIMUM EXTENT PRACTICABLE

 The selected remedy represents the maximum extent to which permanent solutions and treatment
 technologies can be used in a cost-effective manner for final source control at WS4.  No ongoing
 source for the PCE in groundwater at WS4 has been identified within WS4, and numerous
 investigations  have failed to determine an ongoing off-site source or sources of the PCE in the
 groundwater at WS4 for which cleanup action could be taken.  Therefore a remedy that is focused
 on treatment of the drinking water produced from WS4 has been determined to represent the
 maximum extent to which permanent solutions and treatment technologies can be used in a cost-
 effective manner.

 Because air stripping was already in operation when WS4 was listed on the NPL, it was the only
 remedy evaluated.  However, treatment of the water using air stripping has been proven to be
 protective of human health, and it complies with ARARs. EPA and the State of Washington have
 determined that air stripping provides the best balance of trade-offs in terms of long-term
 effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment; short-
 term effectiveness; implementability; and cost; while also considering the statutory preference for
 treatment as a  principal element and considering state and community acceptance.

 Air stripping, the selected remedy, treats the principal threat posed by exposure to drinking water •
 produced from WS4 by reducing the concentration of PCE in treated water to below detectable
 levels.  This remedy provides a proven technology for removal of PCE from water and is cost-
 effective. The selection of air stripping  treatment of the contaminated water is consistent with
 program expectations that indicate that  contamination in water used for public drinking water
 supply is a priority for treatment. The selection of air stripping treatment as EPA's remedy
ensures long-term effectiveness by requiring that the treatment system remain in operation as long
as necessary to reduce PCE concentrations in groundwater around WS4 to less than 5.0 ug/L

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 FINAL RECORD OF DECISION                                                     p   ,Q
 Vancouver Water Station 4                                                            8
 EPA Region 10


 12.5   PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

 Treatment by air stripping addresses the principal threat posed by drinking water produced from
 WS4 through the use of a proven treatment technology.  By using treatment as the sole remedy,
 the statutory preference for remedies that employ treatment as a principal element is satisfied.


      13.0 DOCUMENTATION OF SIGNIFICANT CHANGES


 The Proposed Plan, released for public comment in May 1999, discussed remedial action
 alternatives for  WS4 and identified air stripping as EPA's preferred alternative. No public
 meeting was scheduled. The public comment period was May 5, 1999, to June 3, 1999. Written
 comments on the Proposed Plan and RI/FS report were received from two individuals and the
 City of Vancouver.

EPA reviewed the written comments submitted during the comment period.  Upon review of the
comments, it was determined that no significant changes to the remedy for WS4, as it was
originally identified in the Proposed Plan, were necessary to satisfy public concerns.

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     APPENDIX A




Responsiveness Summary

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  FINAL RECORD OF DECISION
  Vancouver Water Station 4                                                        Appendix A
  EPA Region 10                                                                   Page A-1
                                     APPENDIX A
                                Responsiveness Summary


  This responsiveness summary will address public comments on the Proposed Plan for remedial
  action at Water Station 4 (WS4) at Vancouver, Washington, upon completion of the public
  comment period.

  The remedial investigation/feasibility study (RI/FS) report and Proposed Plan were released for
  public comment in May 1999. The two documents were made available to the public in the
  Administrative Record maintained at U.S. EPA Region 10, 1200 Sixth Avenue, Seattle
  Washington, and at the information repository maintained at the Vancouver Public Library Fort
  Vancouver Branch, 1007  E. Mill Plain Boulevard, Vancouver, Washington.  The notice of
  availability of these two documents was published in the Vancouver Columbian on May 5,  1999.

 Opportunity for Public Comment

 The public comment period was held from May 5, 1999, to June 3, 1999. Written comments on
 the Proposed Plan were received from two individuals and the City of Vancouver during the
 comment period. Comments on the draft RI/FS report that were received from the City of
 Vancouver during the comment period for the Proposed Plan are also included in this
 Responsiveness Summary.

 Opportunity for Public Meeting

 The public had an opportunity to  request a public meeting.  No requests for a public meeting were
 received.                                                                  ,

 This responsiveness summary does not reproduce the original comments, but instead presents
 compilations of related comments that address the same concern.  Original comments that relate
 to several different portions of the RI/FS report or the Proposed Plan have been combined and
 one response is given. Comments have been numbered to facilitate reference.  The complete text  -
 ot the written comments is available in the Administrative Record file.

     Comments on the Draft Final RI/FS Report Received From the City of Vancouver
                During the Public Comment Period for the Proposed Plan
Comment 1: While u.s true that no exclusive source of the PCE contamination at WS4 has been
identified, and that EPA has not identified any specific sources that currently require source
control remedial actions at the source location, it is not the case that no source has been

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 FINAL RECORD OF DECISION                                                     Appendix A
 Vancouver Water Station 4
                                                                                 Page A-2    ^^
EPA Region 10
 identified.  PCE concentrations measured in groimdwater samples collected immediately
 downgradient of Griff ee 's Cleaners and the Town Plaza strongly indicate that those dry cleaning
 operations are sources of PCE contamination. We suggest that all statements to the effect that
 no sources have been identified be rephrased to state that no sources have been identified that
 currently require source control remedial actions at the source location.

 Response 1 :  This commenter is correct that the term "source"  as used in the RI/FS report and
 Proposed Plan needs clarification.  As used in the RI/FS report and Proposed Plan, the term
 "source" was intended to describe a source that could be either (1) primarily responsible for the
 sustained high concentrations of PCE measured at WS4, or (2) subject to cleanup or other source
 control measures. The maximum PCE concentrations detected downgradient of Griffee's
 Cleaners and the Town Plaza were 1/1 Oth of the average concentration of PCE measured at the
 wellfield in 1992 (and less than l/20th of the concentration measured at PW-2, immediately
 upgradient of the wellfield.)  Although the dry cleaners on the Mill Plain plateau may have
 contributed to the PCE contamination at WS4 to some extent (as stated in the RI/FS report), the
 data indicate that another source or sources were primarily responsible for the sustained high
 concentration of PCE measured at WS4.

 To more precisely bound the definition of "source," that term in the Record of Decision (ROD)
 has been clarified by wording such as "no ongoing source of PCE contamination for which
 cleanup action could be taken."

 Comment 2:  EPA should clarify that although source control remedial actions may not be
 currently required at potential sources, those potential sources "may still be liable for remedial
 action costs" associated with the investigation and groundwater remediation.

 Response 2:  This commenter is correct that whether or not source control remedial actions are
 required for potential sources, those potential sources are not necessarily ruled out from potential
 liability for remedial action costs. Such liability issues are not addressed in these documents.  The
 purpose of the RI/FS report is to assess the nature and extent of contamination and to analyze the
 range of cleanup alternatives for the site.  The purpose of the Proposed Plan is to present EPA's
 proposed remedy for public comment. The purpose of the  ROD is to document the final decision .
 regarding the remedial action selected for the site and to explain why that remedy was selected.
 Issues of liability are not addressed in the RI/FS report, the Proposed Plan, or the ROD. These
 are technical documents that  address matters related to the  selection of the remedy.

Comment 3:  Section 2.6 should state that the hydrogeologic unit in the WS4 area most likely
consists of recent alluvium and Orchards Gravel,  not the Troutdale Formation.

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 FINAL RECORD OF DECISION                                                     Appendix A
 Vancouver Water Station 4                                                            p,™ A -,
 EPA Region 10                                                                     3gC   3


 Similarly, in Section 4.2, the following wording is suggested for the seventh bullet on page 4-4:
 "WS4 wells pump from the alluvium in hydraulic communication with the deep zone. "

 Response 3:  The commenter appears to be making the assumption that the Orchards Gravel
 extends from the Mill Plain plateau to the WS4 wellfield and therefore that there is a hydraulic
 connection between the shallow groundwater region at the Mill Plain plateau and the groundwater
 from which WS4 draws its water.  The shallow aquifer beneath the Mill Plain plateau is known as
 the Orchards Gravel.  The deeper groundwater zone is known as the Troutdale Formation. The
 alluvium is material near WS4 that could be hydraulically connected to either of these
 groundwater formations.

 Based on a review of boring logs for the site, the Orchards Gravel does not extend to the base of
 the bluff where WS4 is located.  The bluff itself likely represents an erosional surface where the
 Orchards Gravel was eroded by the Columbia River. The erosional surface somewhat increases
 geologic complexity and resultant subsurface uncertainty.  However, it appears reasonably clear
 that the WS4 wells are screened  either in the Troutdale Formation or in recently deposited
 alluvium in direct hydraulic communication with the Troutdale Formation.

 Comment 4:  Only March and September 1998 groundwater elevation data are presented.  The
 text lacks discussion of seasonal variations in groundwater elevations, groundwater flow
 direction, and hydraulic gradient, which would affect fate and transport processes, particularly
 migration pathways from potential source areas to WS4.

 Response 4:  Groundwater Elevations. This commenter is correct that the RI/FS report does
 not include data showing seasonal variations in groundwater data. Seasonal variations in
 groundwater  elevations, groundwater flow direction, and  hydraulic gradient were not discussed
 for two reasons:  (1) a full dataset for groundwater elevations was available only for March and
 September of 1998, and (2) those data did not indicate a significant difference that would affect
 the conclusions of the RI/FS report or the decision to continue operating the treatment system at
 WS4. A table showing the available seasonal groundwater surface elevations has been provided as
 an addendum to the final RI/FS report and is also attached to this responsiveness summary. Data
from the entire study area are available only from two dry season dates (October 1992 and
 September 1998) and one wet season date (March 1998) because EPA had suspended the
investigation.  The time gap (almost 6 years) between October 1992 to September 1998
confounds comparison of these two data sets.  The limited temporal data from the entire study
area limits the evaluation of seasonal groundwater surface elevation fluctuations and therefore
seasonal influences on contaminant fate and transport. However, the data do not indicate
significant effects to fate and transport processes, including migration pathways.

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  FINAL RECORD OF DECISION                                                    A    dix A
  Vancouver Water Station 4                                                           £„ _. A  ,
  EPA Region 10                                                                      g   ~*


  Seasonal Fluctuations.  Groundwater surface elevations in the shallow zone decreased in every
  measured well from March 1998 to September 1998. These decreases ranged from approximately
  0.5 to 1 foot, with an average decrease of approximately 0.7 feet. This is an expected seasonal
  fluctuation from the wet season (March) to the dry season (September).

  Groundwater surface elevations in the deep zone decreased in all but one of the wells from March
  1998 to September 1998.  The decreases ranged from approximately 0.25 to 4 feet, with an
  average decrease of approximately 2.9 feet.  This is an expected seasonal fluctuation from the wet
  season (March) to the dry season (September).

 Groundwater Flow  Direction. The RI/FS report states that "groundwater flow in the deep zone
 is to the south-southwest across most of the study area." The two comprehensive data sets
 (March and September 1998) suggest that some seasonal fluctuation in the groundwater surface
 elevation occurs.  However, the same general flow pattern was observed at both times.  These
 limited observations indicate (1) that seasonal fluctuation of the groundwater surface elevations
 do not result in seasonal variation of contaminant fate and transport, and (2) that generally, PCE
 in deep zone groundwater will migrate to the south-southwest in the study area regardless of the
 season.

 Comment 5: The apparent deep zone groundwater divide indicated in Figures A-3 andA-4
 likely does not exist.  MW4-PHC is deeper than other wells in the Troutdale Formation and the
 lower groundwater elevation at this well was used, in part, to create the figures, which resulted
 in the apparent divide.  A more reasonable groundwater elevation map would indicate a
 southerly groundwater flow for the entire Mill Plain plateau.

 Response 5:  Given the limited deep zone data available in the area, the existence of a
 groundwater flow divide in the  Parkhill Cemetery area cannot be conclusively confirmed or ruled
 out.  The available data (without consideration of data collected from MW4-PHC) do suggest
 that groundwater flow in this area does have an easterly component.  Inclusion of MW4-PHC
 suggests an even greater easterly component to flow. The gradient from MW4-3 to MW4-8I
 suggests an easterly component to flow.  The gradient from MW4-2 to MW4-8I suggests a
 southeasterly component to flow. However, the gradient is much shallower in this area than from.
 the Tower Mall to WS4. The shallow nature of the hydraulic gradient in this area introduces
 uncertainty that precludes drawing a high-confidence conclusion with respect to interpretation of
 groundwater flow.

 Comment 6:  The text does not discuss the hydraulic connection between the shallow and deep
groundwater zones or compare  horizontal flow to vertical flow in the shallow groundwater zone
 Groundwater in the shallow zone flows to the west and also discharges vertically into the deep
groundwater system.  This connection  is  the primary pathway for contaminant migration frc
rom

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FINAL RECORD OF DECISION                                                      Appendix A
Vancouver Wat
EPA Region 10
 Vancouver Water Station 4                                                             page
 potential sources on the surface in the Mill Plain plateau to WS4. The aquitard separating the
 two zones likely is a former weathered surface that was subsequently covered by the Orchards
 Gravel.  The deposition of the younger gravel likely incised channels into and through the
 aquitard, which would have created vertical migration pathways.  The detection ofPCE in the
 deeper groundwater strongly indicates vertical contaminant migration through the aquitard.

 Accordingly, we suggest the following wording for the 10th bullet on page 4-4:  "Pumping from
 WS4 wells captures groundwater over a large area from both the shallow and deep zones to the
 north. "

 Further, the statement that a large sudden release of PCE probably did not occur on the Mill
 Plain plateau is refuted by the indications of vertical flow discussed above.  Vertical flow
 through the unsaturated zone, the thin shallow groundwater zone, and the aquitard, and/or a
flushing event that released residual PCE in soil in the Mill Plain plateau are entirely plausible
 scenarios for the pulse detected in WS4.

 Response 6:  The competence of the aquitard and the presence of the unsaturated zone directly
 beneath the aquitard suggests that there is no significant direct hydraulic connection between the
 shallow zone (Orchards Gravel) and the deep zone (Troutdale Formation). That is, contaminant
 migration from the Orchards Gravel to the Troutdale Formation is likely to be limited to leakage
 from the Orchards Gravel through the aquitard.  This leakage is probably dominated by
 percolation of groundwater through the aquitard at a rate controlled by the permeability of the
 aquitard material (orders of magnitude lower than the Orchards Gravel).  In the absence of any
 direct evidence, the presence or absence of "incised channels," cracks, windows, or any other
 preferential vertical migration pathway in the aquitard can only be speculative. The existing
 evidence also cannot rule out a preferential vertical migration pathway through the aquitard.

 Hydraulic communication between WS4 and the shallow zone (Orchards Gravel) is limited to the
 groundwater that percolates through the aquitard and reaches the saturated portion of the deep
 zone (Troutdale Formation) within the capture zone of WS4. The aquitard is competent enough
 to create the shallow saturated zone that is relatively areally extensive. This suggests that the
 effective average permeability of the aquitard is orders of magnitude lower than the Orchards
 Gravel. In addition, blow counts of the aquitard material range as high as  50 blows per 2 inches
 of penetration. This indicates that the aquitard material is very hard and not readily eroded.

 In the Mill Plain area, the aquitard ranges from 4 to 8 feet in thickness, with the base of the
 aquitard at approximately 140 to 125 feet msl. Deep zone groundwater surface elevations
 average approximately 110 feet msl. These observations indicate that an unsaturated zone of soil
 that ranges from 15 to  30 feet in thickness is present beneath the aquitard.

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 FINAL RECORD OF DECISION                                                     .     ,- A
 Vancouver Water Station 4                                                         Appendix A
 EPA Region 10                                                                      ge


 Pumping from WS4 wells captures groundwater over a large area from the deep zone (Troutdale)
 and/or alluvium.  However, the WS4 wells are screened at elevations between 150 to 200 feet
 below the base of the Orchards Gravel. The unsaturated zone between the bottom of the aquitard
 and the top of saturation in the Troutdale Formation precludes any sort of direct communication
 between the two formations or direct influence of WS4 pumping on the shallow zone. Given (1)
 the lack of direct hydraulic connection between the Orchards Gravel and the Troutdale
 Formation, (2) the differences in groundwater flow direction between these two units, and (3) the
 vertical separation between the intake screens and the bottom of the Orchard Gravel WS4 wells
 will capture groundwater from the Orchards Gravel only to the extent that it percolates through
 the aquitard to the underlying WS4 capture zone.

 The detection of PCE in the Troutdale could suggest that PCE has migrated vertically through the
 aquitard and into the deep zone. However, detected PCE concentrations are generally lower in
 the shallow zone than in the deep zone (excluding WS4 sample results). Under these geologic
 and hydrogeologic conditions, and given available data, it is difficult to develop a scenario in
 which a PCE release from the Mill Plain area would result in concentrations in the deep zone that
 are greater than concentrations in the shallow zone. It is more likely that the PCE concentrations
 in the deep zone are a result of a release from an area  outside of the Mill Plain area with
 contribution from the Mill Plain area via percolation through the aquitard.

 Comment 7: The statement that degradation products of PCE include trichloroethane (TCA)
 and dichloroethane (DCA) is inaccurate. TCA is a primary chlorinated hydrocarbon compound
 used for industrial purposes, andDCA is a degradation product of TCA. The presence of TCA
 indicates a source of chlorinated hydrocarbons that may or may not be related to the potential
 sources of PCE.

 The presence of TCA andDCA does not indicate degradation of PCE, which would occur under
 specific geochemical conditions that are not present in the area of WS4.  PCE degradation likely
 is not occurring because of the lack of organic carbon required for microbial metabolism, and
 the presence of elevated dissolved oxygen concentrations, which limit PCE degradatl
non.
Response 7: The RI/FS report did mistakenly include TCA as a degradation product of PCE
TCA is not a degradation product. However, there is evidence that dichloroethane (DCA) can be
a breakdown product of PCE (although a minor one). As stated in the RI/FS report there is very
little evidence of degradation products of PCE in groundwater in the area of WS4  The lack of
PCE degradation products could be either the result of specific geochemical conditions (as noted
in the comment) or relatively low concentrations of PCE.  Determining whether the very low level
of DCA detected in groundwater was the result of PCE degradation or a release of DCA to the
environment was beyond the scope of the investigation and would not have affected the selected
remedy.

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 FINAL RECORD OF DECISION                                                    Appendix A
 Vancouver Water Station 4                                                            «.„ A -
 EPA Region 10                                                                     fageA-/


 Comment 8: Groundwater results indicate the presence ofPCE at WS4 both before and after the
 pulse ofPCE in 1991.  This indicates that the 1991 pulse was not the only release event that
 impacted the wellfield. PCE was likely released from multiple sources and multiple events. The
 distribution and migration pathways of PCE are unknown and no data exist that preclude
 another pulse of PCE entering WS4 in the future.

 Response 8:  The high concentrations of PCE measured at WS4 beginning in 1991 (the "pulse of
 PCE") may or may not be associated with the lower concentrations measured prior to that time.
 Data presented in the RI/FS report indicate that multiple sources of PCE probably contributed to
 the contamination at WS4. However, this conclusion is better supported by the high
 concentrations  measured at PW-7, PW-8, and PW-9 than by the sudden increase at WS4 in 1991;
 it is likely that low concentrations of PCE would both precede and follow a higher-concentration'
 pulse regardless of the initial source or sources.

 We agree that no data exist that preclude another pulse of PCE entering WS4 in the future. It is
 inherently impossible to preclude  that no future pulses of contamination will occur. Even if the
 past and current source or sources of PCE at WS4 were known, there is always the possibility of
 new future sources, particularly given the fact that surface stormwater runoff is routinely disposed
 of through  dry wells in the area around WS4.

 Comment 9:  The pattern of decreasing concentrations applies only to the pulse of
 contamination.  Continuous detections of PCE upgradient of WS4 indicate persistent
 contaminant migration, and a steady release of PCE to grovndwater. Releases of PCE at the
 surface may have ceased, but residual PCE in soil may be slowly releasing PCE to groundwater
 especially at MW4-3S, MW4-8S, and MW4-9S.

 Response 9: The commentor is correct that residual PCE in soil may be slowly releasing PCE to
 groundwater; residual PCE in soil could be responsible for the PCE measured at both WS4 and
 monitoring wells in the vicinity. However, the data presented in the RI/FS report clearly show a
 pattern of decreasing concentrations of PCE in wells throughout the area of WS4 (of 29
 monitoring and  private wells, all but 3 showed decreasing concentrations of PCE from 1992
 through 1998.)  The continuing detections of PCE, both at WS4 and in wells throughout the area, -
 clearly indicate that PCE remains in the environment. Whether these detections are the result of '
 residual PCE in  soil or in groundwater (or both) was beyond the scope of the investigation, and
 would  not have  changed either the conclusions or the selected remedy.

 Comment 10: The distribution of PCE in the area north of WS4 indicates potential sources at
 Griffee 's Cleaners and the Town Plaza.  Although PCE concentrations may be lower than
concentrations at or near the wellfield, this does not preclude them from being contributors of

-------
 FINAL RECORD OF DECISION                                                     Appendix A
 Vancouver Water Station 4                                                            PaeeA-8
 EPA Region 10


 PCE to the wel/field.  As staled in the text, groundwater may flow in narrow channels, especially
 mar sources where dispersion effects are small.

 Response 10: Data presented in the RI/FS report indicate that dry cleaning operations at the Mill
 Plain plateau could have contributed to the PCE contamination at WS4. Although PCE plumes
 can flow in narrow channels, it is unlikely that a large (or steady,  longer-term) surface release of
 PCE on the plateau could be the primary source of PCE contamination at WS4 (measured at
 hundreds of ug/L) without being detected at similar concentrations between the plateau and WS4.

 Comment 11: The PCE concentrations in PW-7, PW-8, andPW-9 northwest of the wellfield are
 similar to those in the Mill Plain area, indicating that both areas contributed to the PCE at the
 •wellfield.                                     .

 Response 11: The concentrations of PCE measured at PW-7, PW-8, and PW-9 were higher than
 any concentration detected in the Mill Plain area. (The maximum measured concentration in these
 three private  wells was almost three times the maximum concentration measured in any
 monitoring well in the Mill Plain area.) The groundwater flow patterns (both shallow and deep) in
 the area do not  support a  link between these two areas. It is reasonable to conclude that there
 probably are multiple sources of PCE in the area of WS4 as stated in the RI/FS report and the
 Proposed Plan.

 Comment 12: Figure 4-1 suggests northerly groundwater flow in the shallow zone. All data
 indicate shallow groundwater flow is to the west.

 Response 12: Figure 4-1  was not intended to show directional flow; it is a highly simplified
 illustration of the features affecting potential contaminant transport in the vicinity of WS4.  As a
 two-dimensional representation of a three-dimensional condition, some  simplification was
 necessary, and the groundwater flow direction arrow referred to in the comment was intended to
 represent flow out of the page.  Directional headings are meaningless on this type of a simplified
 drawing. Calculated directional flows for both the shallow and deep groundwater zones are
 shown in Appendix A of the RI/FS report.

 Comment 13: The soil-gas concentrations may be too low to indicate an exact location of a
release of PCE, but do indicate at least a proximity to a source area, because PCE is a
manmade chemical used for specific purposes and is not expected to occur widely in the
environment.  In addition, PCE is relatively volatile, and will not remain in the soil unless
released in more than trace quantities. Soil-gas results should be considered as indicators of
either a nearby  source, or an old source that has substantially volatilized.

-------
 FINAL RECORD OF DECISION                                                    Appendix A
 Vancouver Water Station 4                                                           Page ^.9
 EPA Region 10


 Response 13:  As the comment notes, PCE is relatively volatile. Indeed, studies have shown that
 gas-phase PCE can travel relatively long distances through soil. Measurement of PCE in soil-gas
 may or may not indicate proximity to a source. Soil-gas data alone are insufficient to quantify the
 proximity, age, or size of the source.

                    City of Vancouver Comments on the Proposed Plan

 Comment 14:  The following statements in the Proposed Plan should be rephrased:

       Introduction,  page 1 ("no source of the PCE contamination has been positively identified
       for possible cleanup")

       Background, page 2 ("no source of the PCE contamination at WS4 was definitively
       identified")

       Results of Previous Investigations, page 3 ("neither the source nor the extent of the high-
       concentration PCE plume is known")

       Recommended Remedy, page 4 ("no PCE source has been identified")

PCE concentrations in groundwater samples collected immediately downgradient ofGriffee 's
Cleaners and the Town Plaza strongly implicate those dry cleaning operations as potential
sources of PCE to groundwater.  PCE concentrations at WS4 have not decreased to below
detection limits, indicating that residual PCE sources remaining in soil continue to release PCE
into groundwater. Potential PCE sources have been identified, but may not presently be
amenable to direct cleanup.

We suggest that the following language be used on page 4 of the Proposed Plan: "No single
PCE source of all contamination at WS4 has been identified. Multiple releases of PCE in the
area of groundwater  capture are likely responsible for PCE contamination at WS4.  Recent
groundwater test results suggest that source control/treatment is not called for, and that
groundwater treatment at the water station is the preferred remedial action. "

Response 14:  The Proposed Plan for WS4 is final and its language will not be rephrased.  The
purpose of the Proposed Plan was to briefly summarize the information used to select the
proposed remedy (continued air stripping at WS4), not to present a complete, detailed
explanation of the more complex question of specific sources.  The Proposed Plan stated that
"Neither the source nor the extent of the high-concentration PCE plume is known."  As noted in
the responses to previous comments on the RI/FS report, this is a reasonable conclusion to draw
from the available facts.

-------
 FINAL RECORD OF DECISION                                                    Appendix A
 Vancouver Water Station 4                                                          Page A-10
 EPA Region 10


 Comment 15: Page 2 of the Proposed Plan states that "Both the City and EPA continued these
 investigations. "  The City of Vancouver is currently continuing to pursue identification of
 possible sources ofPCE.

 Response 15: Comment noted.

 Comment 16: Page 3 of the Proposed Plan states that "the significant reduction in PCE
 concentration over the last several years strongly supports the conclusion that there is not an
 ongoing source of PCE contamination in the area. " However,  PCE concentrations have not
 decreased to below detection limits at WS4. indicating the persistence of PCE sources in soil.
 Historical operations at dry cleaners typically did not manage wastes as rigorously as current
 industry practices. It is likely that multiple releases of PCE occurred in the groundwater capture
 area of WS4 in the past. These sources have the potential to continue to release PCE into
 ground\vater that will migrate to WS4.

 Response 16:  As noted in  both the RJ/FS report and responses to previous comments, it is likely
 that residual PCE in soil will continue to release PCE into the groundwater that is eventually
 pumped from WS4.  This residual PCE could be the result of one or more releases, as stated in
 the RI/FS report.  Indeed, the high probability that PCE will continue to be present in the
 groundwater near WS4 was a major factor in EPA's decision to select continued air stripping as
 the remedy for this site.

 Comment 17:  Recent sampling results several thousand feet upgradient of WS4 indicate
 measurable PCE concentrations in groundwater. No data exist suggesting that another pulse of
 high-concentration PCE from an unidentified source will not move through the wellfieldin the
future.

 Response 17:  As stated in  the RI/FS report, PCE has been routinely measured in groundwater
 throughout the area upgradient of WS4; 21 out of 29 monitoring and private wells sampled during
 the WS4 investigations had detections of PCE above the MCL.

 EPA agrees that no data exist suggesting that another high-concentration pulse of PCE from an
 unidentified source will not move through the wellfield  in the future.  In fact, it is impossible to
 provide such data. The practice of disposing of surface stormwater runoff to dry wells in the
 vicinity of WS4 only complicates the question of whether concentrations of PCE will decrease,
 stay steady, or increase. In  any case, the selected remedy will be  sufficient to protect against any
 likely future increases in PCE concentrations at WS4.

 Comment 18: Page  3 the Proposed Plan states that "this deep groundwater is the source of
water pumped from WS4. "' However, we believe that WS4 captures both shallow and deeper

-------
 FINAL RECORD OF DECISION                                                    A    dix A
 Vancouver Water Station 4                                                          p-0- A ,,
 EPA Region 10                                                                   Page A-11


 groundwater from a 5-square-mile area. Shallow groundwater within the capture area migrates
 vertically downward into the deep groundwater through a leaky aquitard.

 Response 18: As stated in previous responses to comments on the RI/FS report, there are no data
 supporting a direct connection between the shallow groundwater (from the Mill Plain plateau) and
 the groundwater from which WS4 draws.  The shallow groundwater appears to be largely
 independent of the deeper groundwater zone. The extent of "leakage" through the aquitard has
 not been estimated, but the available data indicate that the aquitard is effective in preventing
 significant communication between the two groundwater zones.

                   Private Individuals' Comments on the Proposed Plan

 Comment 19: I was offended when I found out mywater was "not proper water." I contacted
 the city and a representative visited my home and instructed me now to treat the water from my
 taps so that it would be potable. I installed a water cleaning system and am now having no
 difficulties. I appreciate your efforts. I have recently been trying to use the water without my
 cleaning system and have found it acceptable. The result is that I believe that the means you are
 using to make the water acceptable are effective.

 Response:  It is unclear whether the water from this commenter's tap was from a private well or
 supplied by the City of Vancouver. Further, the nature of the difficulties with the commenter's
 tap water is unknown. If the commenter is using water from a private well, the air stripping
 system being  used to treat City of Vancouver water from WS4 is not treating this water and the
 quality of the commenter's private well water, with or without use of an in-home cleaning system,
 is unknown.

 If the commenter's water is being supplied by the City of Vancouver, it meets all EPA drinking
 water standards, and use of in-home water filtering would be based purely on personal preference
 for improved  taste or odor but would not be required for health or safety reasons.

 Comment 20:  Thank you for the update.  You appear to have  done a thorough job in containing
 the risks from the pulse ofPCE that entered the system.  If the pulse has in fact passed,  I would
 be interested in a discussion of the need to treat water compared to the value of monitoring, the
 cost of treatment compared to monitoring, and the possibility of using the savings [from
monitoring instead of treating], if any, for other sites.

Response 20:  Both monitoring and treatment need to be continued at WS4. PCE concentrations
have dropped significantly; however, the concentrations of PCE in untreated water still exceed the
maximum contaminant level (MCL) set by EPA for safe drinking water. Treatment will continue
to ensure that PCE concentrations in the drinking water are reduced to levels that are below safe

-------
FINAL RECORD OF DECISION                                                      Appendix A
Vancouver Water Station 4                                                            Page A-12
EPA Region 10


drinking water standards before the water is distributed to citizens for domestic uses. Monitoring
will keep us informed as to the effectiveness of the treatment and will alert us if PCE
concentrations rise to a level that would require increased treatment or other appropriate action.

-------
FINAL RECORD OF DECISION
Vancouver Water Station 4
EPA Region 10
Appendix A
 Page A-13
                                                   Table A-l
                   Summary of Depth-to-Water Measurements and Groundwater Surface Elevations
                                           Vancouver Water Station 4
-li'r-'&ii
il?8
Shallow Wells
MW4-3S
MW4-5S
MW4-8S
MW4-8I
MW4-9S
MW4-10S
MW4-11S
MW4-12S
MW4-13S
MW4-14S
»eeiWeifs>f'
MW4-1
MW4-2
MW4-3
MW4-4
MW4-5
MW4-6
W'-f :«fl
I1SI
tfl^'Mt^
293.57
285.46
297.97
297.41
299.38
294.11
302.59
293
292.64
291.74
'/• • . •'»-, -•• ;
132.66
291.56
293.68
30.56
283.51
139.04
•'' X &<.•'*£. 4$
• ,;- Screen;-:^
•^It^Wl
151 to 171
153 to 163
153 to 173
120 to 125
150 to 170
144 to 164
151 to 171
148 to 168
153 to 173
153 to 163
;-«-, - ' :• ,,/.
1310-17
92 to 1 12
89 to 109
-44 to -64
84 to 104
-41 to -61
'.**?• i**
^•jftejpthto,,
^VWjjtej* '
>t4l;^-ff/
129.02
NI
NI
NI
NI
NI
NI
NI
NI
NI
' - y';-;^ ' ,
126.84
175.55
178.53
27.42
167.01
134.36
•?>•:••' '*•$•-,
Grounttwater , ;
.',^ferla'<:«Jlcv.*
,h:<<-;v|!B -^
164.55
NI
NI
NI
NI
NI
NI
NI
NI
NI
•f • '
5.82
116.01
115.15
3.14
116.5
4.68
.. 1 INI, ,,n..|,. mi !••.
flSS

127.34
NI
121.3
NA
122.51
115.84
123.85
NI
NI
NI
f: • ,
120.51
172.98
175.75

164.46
129.17
=====
: Groundwater
>.^;v%'iV-r~
166.23
NI
176.67
NA
176.87
178.27
178.74
NI
NI
NI

12.15
118.58
117.93
Well
Abandoned
119.05
9.87
— - _!!_•••••• __
'V-^Septeia
Jieptli to
*t: (ftb^i,,..
"' j' ' ' * >NC *'*'' '(
127.78
121.47
121.93
121.47
123.13
116.55
124.75
126.64
125.65
126.42
t '•••
124.98
173.22
176.05

164.3
113.23
	 !—••— •••
»cr i998 / '-}. \ '
Groundwater
'StJjfaceiiev,
_;,_|-''(ftiMsD^
"" \ ' * ''•-.* ' *"
165 79
163.99
17604
17594
17625
17756
17784
16636
166 99
165 32

7 68
11834
11763

119.21
5.81

-------
 FINAL RECORD OF DECISION
 Vancouver Water Station 4
 EPA Region 10
                                                                                                   Appendix A
                                                                                                    Page A-14
      Wel
     MD .
                                                     Table A-l (Continued)
                       Summary of Depth-to-Water Measurements and Groundwater Surface Elevations
                                                  Vancouver Water Station 4
              ^Screen/
           'f~" Interval
             Depth to
              Watli*
             ' (ft-btoc)
                                                         Groundwater
                            Depth to
                             Water
Grarao&water
SurfaceEIev,
Depth to
 Witerf
Gmrndwater
Surface EFev.
-   ffttfili)  :
  MW4-7
156.55
-23 to -43
148.57
                                                             7.98
                                                        142.36
                                                          14.19
                                                                                                       146.36
                                                                                                   10.19
  MW4-8D
297.25
91 to 101
 NI
                                                              NI
                                                        194.68
                                                         102.57
                                                                                                       198.45
                                                                                                   98.8
  MW4-DP1
284.38
 45 to 65
                                              205.55
              78.83
                                                        181.18
                                                                                          103.2
                                                                        182.17
                                                                                                  102.21
  MW4-DP2
284.34
 5 to -5
174.33
                                                            110.01
                                                         NA
                                                          NA
                                                                                                         201
                                                                                                   NA
  MW4-FS1
 38.97
 7 to -8
 NI
                                                              NI
                                                         29.82
                                                                                          9.15
                                                                        33.94
                                                                                                                      5.03
  MW4-FS2
 38.75
-42 to -52
                                                NI
                                           NI
                                             NI
                                                                                           NI
                                                                                     33.68
                                                                                                                      507
  MW4-HS1
138.95
 lto-9
                                              134.75
                                           4.2
                                                                           129.71
                                                          9.24
                                                                                    133.88
                                                                                                                      5.07
 MW4-PHC
292.12
 62 to 72
"Source: R.F. Weston 1993

Notes:
ft btoc - feet below top of casing
ft tnsl - feet above mean sea level
NA - not available
NI - well not installed on specified measurement date
                                              198.12
                                           94
                                           193.94
                                                                                         98.18
                                                                                    199.46
                                                                                      92.66

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