EPA
United States
Environmental Protection
Agency
CM vice o.
Emergency and
Remedial Response
EPA/ROD/R10-85/005
September 1985
Superfund
Record of Decision
Western Processing, WA
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1. REPORT NO.
EPA/ROD/R10-85/005
4. TITLE AND SUBTITLE
TECHNICAL REPORT DATA
(Plttlst rttld Instructions on tht revtnt btfort complttingj
12. 3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September 25, 1985
6. PERFORMING ORGANIZATION CODE
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SUPERFm~D RECORD OF DECISION
Western Processing~ WA
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7. AUTHORCSI
8. PERFORMING ORGANIZATION REPORT NO.
~. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
1,. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
115. SUPPLEMENTARY NOTES
16. ABSTRACT
The Western Processing site occupies approximately 13 acres in Kent, King County,
Washington. Originally, Western Processing was a reprocessor of animal by-produc~s'
and brewer's yeast. In the 1960s the business expanded to recycle, reclaim, treat and
dispose of many industrial wastes, including waste oils, electroplating wastes, waste
pickle liquor, battery acids, steel mill flue dust, pesticides, spent solvents, and
zinc dross. Some of the Pacific Northwest's largest industries had contracts with
Western Processing to handle their wastes. In March 1981, EPA inspected the site and
found numerous RCRA violations. Further investigations found extensive contamination
of soil, surface water and ground water both on- and off site. This prompted EPA to
issue a CERCLA Section 106 order in April 1983, requiring the owners/operators to cease
operations immediately. Current investigations have found approximately 90 of the 126
priority pollutants in the soil or ground water on and off the Western Processing site,
or in Mill Creek.
In August 1984, the first remedial action was approved and a group of over 190 PRPs
eventually agreed to undertake surface cleanup and stormwater control actions. This
secon~ remedial action includes: intensive soil sampling and analysis on- and offsite
during the remedial design~ se~ective excavation and offsite disposal of highly con-
taminated soils, drums and buried wastes in Area I (about 10% of the material in the
(see separate sheet)
.
a.
DESCRIPTORS
KEY WORDS AND DOCUMENT ANAL YSIS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
17.
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Record of Decision
Western Processing, WA (Second Remedial
Action)
Contaminated Media: gw, soil, sw, creek
sediments
Key contaminants: heavy metals, PCBs, VOCs,
chromium, cadmium, toluene, phenol, PAH
1B. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
None
20. SECURITY CLASS (This pGge)
None
21. NO. OF PAGES
60
22. PRICE
!PA '0'111 2220-1 (Rn. .-n)
P"EVIOUI EOITION II OBIOLETE
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INSTRUCTIONS
1,
REPORT NUMBER
Insert Ihe lPA report number as it appears on the cover of the publil:ation.
LEAVE BLANK
.
2,
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by ea~h report recipient. I
TITLE AND SUBTITLE
Title should indicale dearly and briefly the subj«t ~'overa~e of Ihe report, and be display~'d I'rolllinenlly. S." suhlitk. if u~l'd, ill ~mali.'r
type or otherwise subordinate it to main title. When a repon is I'repared in morc than un\' v'llum\', H'p'at Ih~' primary lill~'; ad" vul:lln~'
number and include subtitle for the specific title. .
4,
5.
REPORT DATE
Each report shaU carry a date indicating at least month' and year. Indil:ate th~' hasis 011 \II'hidl i. was ",'Ie~.ted (''.K., o/Ill.' uliulI.,. Jill.. ul
tlpprowll, .r~ o{ p'~ptIrGtion, ~IC.).
PERFORMING ORGANIZATION CODE
Leave blank.
8.
7.
AUTHORISI
Give nafftC{sl in \'t>nventional order (Jolin R. Doe, J. Robe'" Doe. ('Ie). Li,t author's :lfliliation if it dill'ers fmlll th,' I,,'ri'ormina: ...pni-
ution,
B.
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e.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name, sUcct, city, state, and ZIP code. List no more than two levels of :In orj::lnil:llion:ll hire.,d,y,
10, PROGRAM ELEMENT NUMBER
Use the prOlf8m element number under which the report W:lS prepared. Subordinal\' numb\'rs lila)' b\' induJl'll inll:l"'lIlh,'""",
11. CONTRACT/GRANT NUMBER
Insert conUact or Ifant number under which report WIIS prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code.
13, TYPE OF REPORT AND PERIOD COVERED
Indicate interim fmal, etr., and if applicable, dates covered,
.,
14. SPONSORING AGkNCY CODE
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15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such iiS:
To be published in, Supersedes, Supplemenu, etc.
18. ABSTRACT
Include a brief (200 WOI'ds 0' less) factual summary of the mosl sil!nilkllnl inform:llilln ,'unt:lin,'olill Iho' r"l'"rl: litho' "''',,'' ...",101111\ a
significant bibliopaphy or literature survey, mention it here.
Prepared in .:ooperation wilh. Trallsl:l""11 ..... "r"""III,.J OIl ,'..lIh'..'lIn' .....
17. KEY WORDS AND DOCUMENT ANALYSIS .
(a) DESCRIPTORS. Select from the Thesaurus of t:ngineerinll and Sdentilk '["rms the proper :lulhuri'.l'" krill' Ih:ll i""nli"y th~' majm
concept oC the research and are sufficiently spt\:ific: and pre.:isc to be UK.-d as im.h:x entries for ':lItiilu~lna:.
(b) IDENTIFIERS AND OPEN.ENDED TERMS. Use identifiers for projcl:t nilm~S, I:ude names, "'fulpm"nt """a:nillors, "h:. U", "I)J.:II'
ended terms written in descriptor form for those subjects Cor which no d~!it:riptor eAish.
(c) COSA TI I'U:LD GROUp. Field and lfouP assilnments are to be taken hom the 1965 ('OSI\ 1'1 SUhjl'l:t ('all'f!lIry Usl. Sin!.'\,' the ma.
jority oC documents are,multidisciplinary in nature, the Primuy I'ield/Group ils'\ignmcnthl will b\' 'pnifil' Lliwlpline, :lre:l III' human
endeavor, or type of physical object, The application/s) wiU be cron-rcfcren!."Cd with \C~'undary I il'lJ/( ;fUUI' ilSSI!!"III""t' thaI ~'III '"II,,~
the primary posting{sl.
18. DISTRIBUTION STATEMENT
Denote releasabilit)' to the publk or limilation Cor reasons other than S4:L:urity for cxilml'le "Reh::I'L: t;nhllll1l'd," nil' an!! :I~ail;lhilil)' III
the public, with address and prke. .
19..20. SECURITY CLASSIFICATION
DO NOT submit classified reports to the National TeL:hnicallnCormation !it:rvke.
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22. PRICE
Insert the price set by the National fechnicallnformation Scrvil:c or thL: Governmcnll'rinling OITke. if knuwn.
I! PA 'orlll 2220-1 (R... .-771 (R...,..)
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SUPERFUND RECORD OF DECISION
Western Processing, WA..
(Second Remedial Action)
Abstract - continued
top six feet of soil) to reduce the source strength; excav~tion, or cleaning
and plugging all utility and process lines in Area I; following the remedial
design, excavation of all soils which exceed the average daily intake level of
lX10-5 excess cancer risk level; covering/capping all remaining surface soils.
contaminated with priority pollutants above background levels; maintenance of
cover/caps; excavation of utility manholes/vaults near the site; removal or de-
contamination of the lead-contaminated house in Area 8; construction of a ground
water extraction and pre-treatment plant, with operation for a period up to five
years; construction, operation and maintenance of a stormwater control system; in-
tensive monitoring of Mill Creek, the east drain, the ground water and the ground
water extraction system performance, combined with tests and implementation of system
modifications; excavation of contaminated Mill Creek sediments; bench-scale tests
of soil solidification techniques, and if system performance should dictate, pilot
scale tests of in-situ solidification technologies; performance of supplemental
remedial planning studies if shallow ground water contamination beyond the currently
contaminated zone or significant regional contamination is detected. Total capital
cost for the selected remedial alternative is estimated to be $18,100,000 with O&M~
costs approximately $2,000,000 to $3,000,000 depending upon the results of pilot
scale studies on innovative technologies. The final operable unit for this site
y include further ground water and soil remedies plus site closure activities.
These remedial actions will be addressed in another ROD following the performance
evaluation of the second operable unit.
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Record of Decision
Remedial Alternative Selection
SITE
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Western Processing Company. Inc.
Kent. Washington
DOCUMENTS REVIEWED
1 em basing ~ decision primarily on the following documents describing
the analysis of the cost and effectiveness of the remedial alternatives for
the Western Processing site.
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- Western Processing Remedial Investigation
- Western Processing Feasibility Stu~ and Executive Summary
- Summary of Remedial Alternative Selection
- Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
- Intensive soil sampling and analysis on and off the site during
detailed design. .
- Selective excavation of highly contaminated soils and non-soil
materials (drums and buried wastes) in Area 1. Off-site disposal of
excavated soils and materials. Excavate. or clean and plug all utili~
and process lines in Area I.
- , Using the resul ts of the sol1 sampli ng and analysis program.
eliminate direct contact threats in the non-Western Processing property
through excavation of all soils which exceed the ADI level or the 1 x
10-5 excess cancer risk level. and through covering/capping all
remaining surface soils with above background concentrations of
priority pollutants. ~a1ntain cover/caps. Excavate utility lines
leaving the Western Processing site. Clean utility manholes/vaults
near the site. Disposal will in Area I or off-site. Actions will be
l1arlted to those off-site soils which may have been contaminanted by
Western proce~s1ng. The lead-contaminated house in Area 8 will be
removed or decontaminated.
- Construct a groundwater extraction and pre-treatment plant
- Operate the groundwater extraction and treatment system for a period
of up to five years (Initial phase of system operation.) Tbe purpose
of the groundwater extraction and treatment system shall be to prevent
furthur contaminant discharges via the groundwater to Mill Creek and
the east drain at levels which are harmful to aquatic organisms and to
prevent the further spread of. and if possible. remove the
contamination from the shallow aquifer.
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- Construct, operate. and maintain a stormwater control system
- Intensfve monftoring of Mill Creek. the east drain. the groundwater
and the groundwater extraction system performance. combined with tests
and implementation of system modifications such as acid or
solvent-enhanced leaching of u~tals from the soil.
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- Excavate contaminated Mill Creek sediments
- Bench-scale tests of son solidificatfon techniques and. if system
performance should dictate. pilot scale tests of in situ solidification
technologies.
- Perform supplemental remedial planning studies ff shallow groundwater
contaminatfon beyond the currently contamfnated zone or signiffcant
regional contamination is detected.. .
DECLARATIONS
Consistent ~th the Comprehensive Environmental Response Compensation. and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300), I have determined that the above Description of Selected Remedy
at the Western Processing site is a cost-effective remedy and provides
adequate protection of public health. welfare. and the environment. The
State of Washington has been consulted and agrees with the approved remedy.
In addition. this initial phase of system operation/construction will
require five years to ensure the continued effectiveness of the remedy.
These activities will be considered part of the approved action and eligible
for Trust Fund monies for a period of five years.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition. the off-site transport. treatment. and secure disposal
is more cost-effective than other remedial actions. and is necessary to
protect public health. welfare or the environment. . All off-site disposal
shall be in compliance with the policies stated in Jack W. ~~Graw. Acting
. Assistant Adninistrator. Office of Solid Waste and Emergency Response's t~ay
6. 1985 memorandum entitled Procedures for Planning and Implementing
Off-site Response Actions.
If additional remedfalactions are determinf!d to be necessary. a Record of
Decfsfon ~ll be prepared for approval of the future remedial action.
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Date
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Reg10na1 Adm1n1strator
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SUMMARY OF SECOND OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION AT
. THE WESTERN PROCESSING COMPANY, INC. SITE,
- KENT, WASHINGTON
SITE LOCATION AND DESCRIPTION
Western Processing Company, Inc. is located at 7215 South 196th Street in
Kent, King County, Washington. The facility covers approximately thirteen
acres in Section " Township 22 North, Range 4 East (WM). The general area
around the site is rapidly developing for commercial and industrial purposes
although there is a limited amount of agricultural and residential use in
the vicinity. One family lived across the street in a rented house until
May 1984. A vicinity map is provided as Figure 1. a site map is provided as
Fi gure 2.
The site is flat and lies in the Green River Valley. Mill Creek, which is
also known as King County Drainage Ditch No.1, abuts a portion of the
western boundary of the site. Mill Creek eventually reaches the Green
River, which drains to puget Sound. Surface runoff from the site, if not
controlled, would flow into Mill Creek and other adjacent drainage ditches.
Small segments of the site adjacent to Mill Creek and other drainage ditches
lie within the 100 year flood zone.
The groundwater table under the site averages about six feet below the
surface. Tne native soils are generally of moderate to low permeability.
The surficial 40 feet consist of discontinuous lenses of silt, clay and
sand, witn a hydraulic conductivity of 1 to 10 feet a day. From 40 to
approximately 200 feet below the surface, there is fine to medium sand with
discontinuous silt lenses and a hydraulic conductivity of 10 to 100
feet/day. A confining layer of at least 200 feet of dense clay and silt
exists below 200 feet. At the valley margins a deeper artesian aquifer
exists below this unit. .
There are no wells in the shallow aquifer currently used for drinking water
within a one mile radius of the site. . The City of Kent (population 27,000)
has drilled wells into the deeper hydraulically isolated artesian aquifer at
the valley margin less than a mile from the site to develop an additional
drinking water supply for the city. In the past, wells have withdrawn water
for domestic use from the shallow aquifer. However, the background water
quality from some portions of the shallow aquifer would not meet current
drinking water standards, primarily for iron and manganese. .
The surface of the site has been cleared of most above surface wastes and
contaminated facilities. The site is now graded, and stormwater has been
collected and treated on-site by the potentially responsible parties's
(PRP's) contractor prior to discharge to the Metro sewer system. SUbsurf.ce
wastes and contaminanted soils are still in place and include drums of
"foundry sand" and other wastes buried by the owner over many years.
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SITE HISTORY
From 1953 to 1961., the site was leased from its then current owner and
developed and used as a U. S. A~ Nike Anti-Aircraft Artillery facility.
In 1961. the property was sold to Western Processing Company, Inc, which
had been founded by Garmt J. Nieuwenhuis in Seattle in 1957. Western
Processing Company is still owned and operated by Mr. Nieuwenhuis.
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Originally Western Processin¥ was a reprocessor of animal by-products and
brewer's yeast.' In the 1960 s the business expanded to recycle, reclaim,
treat. and dispose of many industrial wastes, including waste oils,
electroplating wastes, waste pickle liquor, battery acids, steel mill flue
dust, pesticides, spent solvents, and zinc dross. Some of the Pacific
NorthWest's largest industries had contracts with Western Processing to
handle their wastes. Reviews of historical aerial photos disclose great
changes in the site's uses and structures every few years as Western
Processing's operations changed.
Tne Kent Fire Department was one of the first agencies to have contact
with Western Processing when fires in the early 1970's brought the
conditions at the site to their attention. The Washington State
Department of Ecology (DOE), and its predecessor agency, the Pollution
Control Commission, have monitored and attempted to control wastewater
discharges from Western Processing for many years. Discharges were.
regulated by permit until 1 ate 1981. At that time Western Processing had
failed to construct wastewater discharge control facilities as required by
permit, and. in 1982, elevated metals concentrations were detected in Mill
Creek adjacent to the site. In August 1982, the King County Superior
Court, acting on a DOE motion, issued an order prohibiting further
discharges of zinc contaminated water from Wester.n Processing into Mill
Creek. The company was ordered to partially close and to remove
zinc-laden wastes from the site at that time. Several other local
agencies, including the puget Sound Air Pollution Control Agency, and the
Seattle-King County Health Department have or have had pending regulatory
actions or concerns with the company.
EPA inspected the site in March 1981 to determine compliance with the
newly-effective regulatory framework of RCRA. Many violations were
documented. Although the company notified EPA of its hazardous waste
, activities pursuant to RCRA Section 3010, an administrative order in May
1981 and substantial negotiations thereafter were necessary to convince
the compa"y to submit a Part A application. (The company claimed that as
a Mrecycler8 they did not have to comply with RCRA.) EPA issued a second
compliance order in June 1982, after another inspection in May 1982
revealed additional significant violations and questionable site
'management. In February 1983, EPA filed suit in Federal District Court
seeking, inter a11a, injunctive relief and civil penalties concerning the,
RCRA violat10ns:--This case has since been amended to include CERCLA
counts against the owner/operator of the site.
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As a follow-up to the earlier DOE and local stream surveys for metals, in
May 1982, EPA conducted a stream survey around Western Processing.
Twenty-six priority pollutants were found in the surface wdters around the
site, all of which were subsequently found on-site. In July 1982 tne site
was added to the National Priorities List.
In August 1982, EPA issued a RCRA 3013 order requiring the site
owners/operators to investigate the effects of their past practices on
sol1, surface water and groundwater. When the owners/operators did not
comply (due to alleged financial inability), EPA undertook the.
investigation and ordered them to reimburse the Agency for its expenses.
The investigation began in September 1982 and concluded in November. In
al" 130 soil samples were taken and 35 groundwater samples were
obtained. The analyses of these samples confirmed that hazardous
substances had been released into the environment, had been leached into
and contaminated the shallow aquifer, and had caused widespread
contamination of the soi15 at tne site. .
When preliminary results of the Fall 1982 investigation became available
in early April 1983, EPA issued a CERCLA Section 106 order requiring the
owners/operators to cease operations immediately and to provide assurances
that they would and could clean up the site. When the assurances were not
made, EPA used Superfund money to conduct an immediate removal.
The immediate removal began in late April 1~83 and was completed on July
1,1983. The removal project cost $1.4 million. . The purpose of the
project was to eliminate the extremely high hazards of the site and to
stabilize the site as much as possible to prevent additional degradation
of the soil and groundwater. Large quantities (920,000 gallons plus 1,944
cubic yards) of the most hazardous substances on the site were removed.
Attempts were made to find users for the materials, but most were sent to
approved hazardous waste disposal sites. Many other hazardous substances
were stabilized and left on the site.
Once the immediate removal was completed, EPA went back to court to ensure
that the owner/operator would not start up operations which could undo the
work which had been done. A preliminary injunction was issued which
prohibits the owner from receiving or processing materials, gives EPA and
its representatives site access, and requires EPA's prior approval for all
activities the owner/operator may wish to perform on the site. The judge
.150 specifically found that the site was an imminent and substantial
endangerment to the environment.
Stormwater management has been, and will continue to be a major problem
until remedial actions are completed. Using State funds, DOE implemented
a stormwater initial remedial measure involving excavation of the gypsum
sludge pond, restacking and covering the material, and paving a 2-acre
portion of the site. A cooperative agreement for a stormwater lRM to
handle stormwater control over a larger portion of the site was signed in
December lY83, but the project was put on hold when the bidS came in much
higher than the available budget.
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A Focused Feasibility Study for Surface Cleanup was published in May
1984. Through a Phase I Partial Consent Decree, a group 9f over 190 PRPs
eventually agreed to undertake a surface cleanup and stormwater control
actions. The surface cleanup was completed by November 30, 1984, except
for two trailers of dioxin contaminated material which are still waiting
the PRPs provision of permanent disposal. The PRPs have voluntarily
continued the stormwater collection and treatment system beyond the April
1,1985 termination date in the Partial Consent Decree. The PRPs have
spent approximately $9 million dollars on the surface cleanup.
Remedial Investigation and Feasibility Stu~ work proceeded simultaneously
with these other actions. Phased Remedial Investigation work began during
the summer of 19&3. Periodic data releases culminated with the release of
the Remedial Investigation in December 1984. The Feasibility Study was
released in March 1985.
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CURRENT SITE STATUS
Approximately 90 of the 126 priority pollutants have been found in the
soil or groundwater on and off the Western Processing site, or in Mill
Creek. In addition, many tentatively identified compounds have been
listed by the laboratories. In the Feasibility Study, sixteen of the
priority pollutant compounds were selected-as indicators to characterize
the contamination on and off the Western Processing property. These'
indicator compounds include metals and representatives of all classes of
organic priority pollutant compounds. Table 1 lists the indicator
contaminants.
Table 2 lists the location of the classes of indicator compounds by their
location within the soil profile. Analysis by CH2M Hill has shown that -
over 95' of the contamination at Western Processing is located in the
uppermost 15 feet of soil. In the top 6 feet (above the water table), all
the contamination is located in the soils. In the saturated zone, the
contamination is located in both the groundwater and the soils. Table 3
shows the results of the contaminant distribution analysis for the Western
Processing site and two adjacent properties which have been contaminated.
The Feasibility Study remedial analysis areas are shown in Figure 2.
Areas 1 and VII are owned by Western Processing Company, Inc..
The groundwater contamination has not migrated significantly from Western
Processing. - The highest concentrations of contaminated groundwater are
directly under the property, as shown in Figures 3 and 4. The groundwater
to about 50 or 60 feet below the surface probably discharges into Mill
Creek adjacent to the site, or into the East Drain, which is tributar,y to
Mill Creek. For the pureoses of the Feasibility Study and NOD, this has
been termed the ushallow groundwater system. EPA's consultants believe
that the lateral extent of the groundwater contamination is bounded by
these waterways, though during the public comment period, a neighboring
property owner's consultants thought that tne existing evidence was not
conclusive.
The groundwater system is complex. While the regional groundwater flow
direction is generally northwest, a groundwater IImound" beneath the site
creates radial, and to some extent, downward, flow from the site. A major
early concern was that this hydraulic head was driving contaminated
groundwater down into the artesian aquifer currently used as a water
supply. However, after a major effort during the Remedial Investigation
and other studies refined the understanding of this groundwater system,
EPA and EPA's consultants now believe the artesian aquifer does not exist
below the site and there is no reasonable pathWay by which any of this -
contamination could reach the deep artisian drinking water aquifer at the -
valley margins. In addition, the current conceptual model of the
effective capture depth of Mill Creek is about 50 to 60 feet below the
surface. .
The adjacent property owner's consultants believes that the 260 ppb of 1,2 .
trans-dicloroethene detected in Well 35 has migrated down into the
regional groundwater system from Western Processing and has crossed under
the creek (below the effective capture depth) to his client's property.
This may be considered a worst case analysis. Hart Crawser & Associates,
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an independent EPA contractor, has stated that nThe source of this
contamination is unknown in that the hydrogeology of the site would tend
to make it difficult for this contaminant to migrate to these wells from
the Western Processing site.- However, to ensure protection of public
health and the environment, this worst case possibility is addressed in
the Recommended Alternative. In addition, 13 additional wells were
drilled in July and August 1985 to the west of the Western Processing
site. Infonnation from these wells win also help resolve this question.
No known present or currently proposed public or industrial water supply
wells could be threatened by this contamination.
Most of the soil contamination is immediately below the site or adjacent.
to the site. The maxilll.lm concentrations of contamination are generally on
the Western Processing property (Area I), and within the top 6 to 9 feet. .
(Table 2). Off-property areas with contamination because of Western
Processing activities include Area IX to the north of the site (former
surface water drainage across S. 196th Street), Area V to the west between
the Western Processing property line and Mill Creek and Areas II and X to
the east of the site between Western Processing and the east drains and
ditches (former surface and subsurface water drainages.) Area VIII has
high surface levels of lead, which may have come from truck traffic making
deliveries of battery chips and other metal containing wastes to Western
Processing. Figures 5 through 9 illustrate the extent of soil
contamination.
The conditions in Mill Creek support the idea that it has received most of
the contamination that has left the Western Processing site over the
years. The concentrations of metals in the stream water and sediments
increase many times as Mill Creek flows by Western Processing. While the
surface water discharges from the Western Processing property has ceased,
contaminated groundwater is still adding pounds of zinc and other priority
pollutants, particularly metals to the creek every day.
Western Processing is not the only source of hazardous substances and
degraded environmental conditions in the area. Area VI is the former site
. of another hazardous waste handling firm, Liquid Waste Disposal. This
firm transported hazardous waste liquids. Closure of this site is being
handled by the Washington State Department of Ecology under the delegated
RCRA program. Also, water quality conditions upstream from Western
Processing limit the resource value of Mill Creek with low dissolved
oxygen levels. The concentration of phthalates, some PAH's, and some DOT
derivatives tends to be higher upstream of Western Processing than through
Western Processing. Metal upstream concentrations are also often above
ambient water quality criteria for aquatic organisms.
Endangerment Assessment
Two methods were used in the endangerment assessment to determi ne the
public health risk presented by the contaminants at Western Processing.
One method was used to address the risks associated with contaminants
known or suspected to be carcinogensi the other method was used to address
risks associated with non-carcinogens. The endangerment assessment
considered all priority pollutants for which there were either cancer
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potencies or Acceptable Daily Intakes (ACls). For carcinogens, excess
lifetime cancerr1sks were calculated by using a procedure that estimates
the increased probability of developing cancer for someone who ingests the
soils or water from Western Processing site over a long period. For
non-carcinogens, there are a few legally enforceable standards (such as
federal or state drinking water standards), as well as other criteria such
as published guidelines that calculate the amount of a particular chemical
that can be ingested without harm.
Assuming that a person works on the site for 40 years, ingestion of the
on-site s011s up to 12 feet deep (assuming the maximum concentrations
fOU~d on site) would lead to a maximum excess lifetime cancer risk of 2 x
10- , principally from PCB cont,mination. There is a potential excess
lifetime cancer risk of 5 x 10- associated with the ingestion of onsite
surface 50ils with site mean concentrations 10 a future worker scenario.
An estimated potential cancer risk of 5 x 10-5 is associated with the
ingestion of soils if the maximum surface concentrations are used. Excess
lifetime cancer risks in three potential future residential scenarios
ranged from about 0.8 times to 50 times greater than the worker scenarios.
Soils in six off-property areas (II, III, V, VI, and IX and Mill Creek
sediments) also had detected PCB IS, though only in surface soils. Areas
VI and IX had at least three reported detections in the surface soils, and
thus an excess cancer risk could be calculated. With the mean and maximum
concentrations and the worker scenario, the potential excesl lifetime
can~er risks associated with ingestion of sails are 9 x \0- and 4 x
10- , respectively, in Areas VI and 3 x 10-5 and 5 x 10- ,
respectively, in Area IX. Again, excess lifetime cancer risks in three
residential scenarios would be 0.8 to 50 times greater. However,
residential development in this area is very unlikely.
No known domestic or industrial water supplies are currently affected by
tne site. Use of onsite groundwater as a potable water source for a work
place, however, would present 'an estimated excess lifetime cancer risk of
0.2 using maximum onsite:concentrations and 0.008 using mean onsite
concentrations. Cancer risk would increase to an estimated 0.5 if a
residential scenario is used with maximum concentrations and 0.02 if mean
onsite concentrations are used. Organic compounds contribute most of this
excess lifetime cancer risk.
A number of Anls are also exceeded with an assumed consumption of 0.1 gram
of soil per day or 2 liters of groundwater per day. These include lead,
chromium, cadmium, toluene, l,l,l-Tricholoethane, phenol, mercu~, and Bis
(2-ethylhexyl)phthalate.
While organic priority pollutant contamination in Mill Creek does not
appear to pose a threat to human health based on recreational use; the
water in Mill Creek near and downstream of Western Processing is likely to.
be toxic to a wide variety of aquatic organisms. While Mill Creek may
have once supported salmon runs and trout, only three-spine sticklebacks
have been found in Mill Creek between downtown and Springbrook Creek in
recent years. (Coho salmon and cutthroat trout have been found upstream
of downtown.) Concentrations of several dissolved metals, such as zinc,
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cadmium, copper, and possibly chromium. exceed the ambient water quality
criteria concentrations for the protection of freshwater aquatic organisms
by several orders of magnitude at the Western Processing site. probably as
a result of groundwater flow into Mill Creek from Western Processing.
Sediments in Mill Creek are also contaminated with priority pollutant
metals. The concentrations of organic contaminants in Mill Creek do not
exceed the ambient water quality criteria for the protection of freshwater
aquatic organisms.
These releases will continue unless remedial action is taken.
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9
ENFORCEMENT
Of the approximately 300 generator and transporter PRPs at the Western
Processing site, over 190 PRPs signed the Phase I Partial Consent Decree
and contributed money towards the surface clean-up work. The Western
Processing Coordinating Committee, representing a large but unknown number
of PRP's, submitted a subsurface clean-up proposal to the government in
October 1984. This proposal was presented to the public (and identified
as the PRPs proposal) as Example Alternative 4 in the Feasibility Study.
Also, the PRPs had their contractor continue to gather data for detailed
design and bid specs for the subsurface clean-up. The Coordinating
Committee has also voluntarily continued the stormwater control actions
beyond the period agreed to in the Partial Consent Decree.
Negotiations for the Phase 11 remedial action began in late May 1985 and
concluded unsuccessfully in August-September 1985 when the PRPs and the
goverments (EPA and WDOE) failed to agree on a remedy.
The use of the Fund is recommended to ensure a proper remedial action
which will protect the public health and welfare and the environment.
Also, it is recommended that the filed Western Processing case in federal
court b~ amended to include recovery of the Goverments' costs.
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ALTERNATIVES EVALUATION
. '
After completion of the remedial investigation. the types of problems
existing at Western Processing were categorized as follows:
- Potential direct human and animal contact with contaminants from
Western Processing.
- Past and potential future contaminated surface water runoff
- Infiltration and subsequent leaching of contaminants from the
unsaturated zone into the groundWater. .
- Contaminated groundwater beneath the site
- Contamination of Mill Creek via groundwater migrating from the site
to levels that exceed background or ambient water quality criteria for
aquatic organisms.
Given the nature and extent of contamination on and off the Western
Processing property and the environmental and human health risks that the
contamination poses. a comprehensive list of possible remedial action
technologies that could be used to remedy the contamination was developed.
An initial screening was conducted to identify the technologies that are
proven and most applicable to and feasible for the problems at Western
Processing. The list of suitable technologies was then used to develop a
set of remedial action components that were determined to be particularly
suitable for these problems. None of the remedial action components is
capable by itself of addressing all the problems at Western Processing.
Therefore the components were combined into comprehensive remedial actions
for the detailed analysis of alternatives.
The Feasibility Study contains seven example alternatives Which. were
developed to mitigate the problems identified in the nature and extent of
. contamination and the endangerment assessments. The example alternatives
include a No Action alternative. totally on-site disposal. totally off-site
disposal. and an alternative which has been developed and proposed by the
PRPs. The PRP's alternative was developed separately from the government
and they used different goals in developing their alternative. While all
seven are feasible alternatives. they are called example alternatives
because there are an infinitely large number of alternatives. particularly
when the possible areal extent of a particular component is considered.
Alternative 4 has only source control measures. Alternative 7 has only
offsite measures. and Alternatives 2. 3. and 5. while generally source
control measures. do include some offsite measures as well.
The example remedial action alternatives were evaluated and compared to
determine their relative cost. and their technical feasibilitY. public
health. and environmental aspects. Table 4 summari~es the seven .
alternathes and the evaluations. The numbered areas refer to the numbered
parcels in Figure 2.
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The nature and extent of contamination on and off Western Processing is a
function of the type of materials which were released on the site and the
pathways by which those materials were able to move. Each contaminant's
mobility or ability or lack of ability to dissolve into, and move with,
water, greatly affects the extent of contamination of that chemical.
110bility also affects the relative success a particular example
alternative has in removing that contaminant. As the summary chart shows,
any of these alternatives will work if it is operated for long periods of
time. Such an extended period may not be technically or administratively
practical. .
The two-volume Feasibility Study and Executive Summar.y contains more
information on the screening criteria and the steps used to develop the
alternatives. .
One of the findings of the Feasibility Study was that complete excavation
and off-site disposal of contaminated soils would be prohibitively
costly. Also, removal of metals from these soils with the proposed
groundwater extraction and treatment system is likely to be a very long
,term operation. Therefore EPA has reconsidered the potential for in situ
soil treatment technologies.
In situ enhanced leaching would involve lowering the pH and/or adding
other chemicals to the leaching solutions applied either at the site
surface or in the very shallow unsaturated zone. (The acid leaching would
be followed by a neutralization step.) Enhanced leaching allows the
contaminants, particularly the normally very hard to remove metals, to be
removed mucn faster. The preliminary results of soil column tests done by
the PRPs on Western Processing soils have shown that the available zinc
can be reduced about 10 times faster when leached with pH 3.b water.
Additional capitol costs to implement this technique once the groundwater
extraction system is operating are estimated to be $600,000, assuming that
adequate solution can be applied through an infiltration trench~ '
Through soil washing, chelating agents, such as EDTA, can also remove the
metal contaminants from the soil. Because of the high cost of the
chemical and potential environmental effects, these chelating agents would
not be used for in situ leaching. Rather, use of these agents would
require digging up the soil, washing the soil in a special on-site unit,
and then replacing the soil. Preliminary results of soil column tests
performed for EPA on Western Processing soils have shown heavy metal
removals of from 15' for nickel to essentially 10~ for lead and cadmium.
In-situ stablization is another innovative technique. This uses
stabilization chemicals thoroughly mixed with the contaminated soils to
tie the contaminants in place, immobilize soil particles, decrease the
permeability of the soil mass in relation to surrounding soils, and
occasionally, to transform certain chemicals into less toxic forms.
Metals are particularly amenable to this technique. Among the advantages
of this technique are that an extremely hard and stable layer is formed
which can serve as a foundation for other structures, such as a cap or a
road. Laboratory scale tests are currently underway using Western
Processing soil. The estimated cost of this technique is $35 per cubic
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yard within 15 feet of the surface, or $9,000,000 for the 11 acre site, 15
feet deep. Long term operational and maintenance expenses are estimated
tu be minimal at a properly stabilized site, involving only periodic
performance monitoring.
If either soil stabilization or 5011 washing technology is chosen in the
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COMMUNITY RELATIONS
A community relations program has been in place for two years. DOE and EPA
have taken an active role in this plan. The major elements have included:
monthly interagency meetings with tne Kent City Mayor and her staff; pUblic
presentations/meetings whenever the city or city council has requested it;
press releases at all major events, such as the release of data or reports,
or the start of particular on-site activities; wide distribution of press
releases and fact sheets; and the availability of government staff by phone
to respond to questions from the public. Public interest is sporadically
high, though the City of Kent, certain neighboring property owners, and a
few individuals have had a high level of continued interest. .
In mid4.~rch 1985, a letter, a fact sheet, a separate Executive Summary, and
the t~o volume Feasibility StudY was made available to the public. Over 500
letters, fact sheets, and Executive Summaries were sent out. (This includes
the approximately 300 copies which were sent to the PRPs.) Over 100 copies
of the entire Feasibili~y Study were sent out to individuals, PRPs, and
dgenc;es known to be interested in the site. A dozen copies were made
available through the local public and EPA regional libraries. In addition,
copies were available free from EPA for the asking. The 30 day comment
period closed April 10, 1985. As of April 26, 1985, 19 comment letters had
been received. No letters were identifiable as being from any PRP or the
PRP cOllll\ittee.
A series of four pUblic meetings/workshops were held at the Kent City Hall.
By tne second meeting, virtually all attendees were what could be called
Mextremely or financially interested parties.- Presentations were made by
tne PRP's coordinating committee's consultants, a neighboring property
owner's consultants, the owner/operator of Western Processing, the most
active environmentalist, and the fisheries biologist of the local Indian
tribe, as well as by CH2M Hill. The on-going lawsuit between the
neighboring property owner and the PRPs limited, to some extent, the range
of potential exchanges between those two parties. Special small briefings
were held for the affected property owners, natural resource agencies,
environmentalists, and t,he press.
The major issues that were raised were:
- Adequacy of the data. Statements were made that there isn't enough
data to answer all the questions or to decide on a remedial action.
The major areas which were affected by this concern are groundwater (Is
there deep groundwater contamination which has reached the regional
f1 ow system?); M111 Creek (How far downstream and how deep are the
sediments contaminated?); a"d, to a IlUch smaller extent, so11 (There.
isn't enough information to determine the exact extent (vertical and.
horizontal) of contamination so that excavation or capping can be
defined.) During the conment period, most interested parties agreed
that at least some components of a remedial action, especially
on-property excavation with off-site disposal,-could and should begin
while any missing data are collected. .
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- Future public participation. Any further information which is
collected needs to be shared with the pUblic and further pUblic input
requested before major decisions are made.
- Property values. The neighboring property owners are greatly
concerned about being able to profitably develop and sell their land.
A major, though not always successful, goal of the public comment period
and meetings was to encourage participants to come up with and to give to
EPA constructive ideas as to how the site should be cleaned up, rather
than to focus on the problems they perceived in the Feasibility Study.
Alternatives which involved excavation and off-site disposal appeared to.
be favored, while almost no one gave serious consideration to AJternative
3, the on-property landfill. Improvement of the groundwater was also
favored. However, only very general feedback was given to EPA on what
levels of .clean. were considered important. It appears that clean was
generally assumed to mean background (e.g. upstream) water quality in Mill
Creek, and adequately low soil contamination to allow City and the Health
Department approval of industrial developments. One individual suggested
that extremely stringent soil contamination levels were necessary along
the underground utility corridors where maintenance workers may need
access. Capping and then developing the entire area was suggested by some
others.
Mill Creek appears to be a potentially complex issue. A number of people
suggested that rerouting Mill Creek Could be a good solution to the
Western Processing situation. A number of the property owners are
extremely interested in having Mill Creek rerouted so that the existing
creek bed could be filled and their proper~ more. easily. and fully
developed. Some of the suggestions for moving Mill Creek could make the
extent of shallow groundwater contamination greater and thus would be
detrimental. These alternatives would be environmentally acceptable only
if the existing creek bed would be replaced by a French drain, and if tne
.French drain was properly maintained. The natural resource agencies and
the Indian tribe are most concerned that Mill Creek water quality and fish
habitat are improved.
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RECOMMENDED ALTERNATIVE
. .
The objectives of any remedial action at the Western Processing site are to:
(1) prevent direct human contact with or ingestion of contaminated soils
either on or off-site; (2) prevent the further spread of and, if possible,
remove the contamination from the shallow aquifer; (3) prevent further
contaminant discharges (via groundwater) to Mill Creek at levels which are
harmful to aquatic organisms; and (4) control contaminated storm water
runoff from the site. The example alternative presented in the Feasibility
Stu~ which includes deep excavation with short~term pumping and treating of
groundwater appears to come closest to meeting all of the objectives, but
its cost is prohibitively high. On the other hand, the results of the
groundwater model used during the Feasibility Study indicate that the
shallow excavation option (with metals laden soils left in the satuated
zone) may permit metals to discharge from the groundwater to Mill Creek at
concentrations ha~ful to aquatic life for many years after the pump and
. treatment system is turned off and the present hydraulic gradients are
reestablished. Therefore, some intermediate alternative such as partial
excavation with some pumping/treatment of groundwater, followed by in situ .
stablization of the metals in the soil might ultimately prove to be the most
cost-effective remedy. However, the cost and technical feasibility of in
situ soil stabilization (or other innovative technologies) has not yet been
evaluated and thus cannot be a part of this present remedial action.
Therefore, the proposed remedial action is an interim approach. The
following components are proposed for the present operable unit:
- Intensive soil sampling and analysis on and off the site during
detailed design.
- Selective excavation of highly contaminated soils and non-soil
materials (drums and buried wastes) in Area I to reduce the source
strengh. Off-site disposal of excavated soils and materials.
Excavate, or clean and plug all utility and process lines in Area I.
- USing the results of the soil sampling and analysis program,
eliminate direct contact threats in the non-Western Processing property
thrgugh excavation of all soils which exceed the ADI level or the 1 x
10- excess cancer risk level, and through covering/capping all
remaining surface soils with above background concentrations of
prioritY pollutants. Maintain cover/caps. Excavate utility lines
leaving the Western Processing site. Clean utility manholes/vaults
near the site. Disposal will in Area I or off-site. Actions will be
limited to those off-site soils which may have been contaminanted by
Western Processing. The lead-contaminated house in Area 8 will be
removed or decontaminated.
- Construct a groundwater extraction and pre-treatment plant
- Operate the groundwater extraction and treatment system for a period
of up to five years (Initial phase of system operation.) The purpose
of the groundWater extraction and treatment system shall be to prevent
further contaminant discharges via the groundwater to Mill Creek at
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levels which are harmful to aquatic organisms and to prevent the
further spread of, and if possible, remove the contamination from, the
shallow aquifer.
- Construct, operate, and maintain a stormwater control system
- Intensive monitoring of Mill Creek,the groundwater and the.
groundwater extraction system perfo~nce, combined with tests and
implementation of relatively inexpensive system modifications such as
acid,or solvent-enhanced leaching of metals from the soil. .
- Excavate contaminated Mill Creek sediments.
- Bench-scale tests of soil solidification techniques and, if system
performance should dictate, pilot scale tests of in situ solidification
technologies.
- Perform supplemental remedial planning studies if shallow groundwater
contamination beyond the currently contaminated zone or significant
regional contamination is detected.
The final operable unit should occur after the initial phase of system
operation and might include:
- Continued groundwater extraction.
- In situ solidification of contaminated soils.
- Site close-out with a cap and provisions for long-term monitoring.
- Long-term institutional controls and deed restrictions.
- Alternative concentration limits for groundwater.
Determination of the final operable unit components will be made in another
ROD pending evaluation of the performance of the second operable unit.
Each component is discussed individually below. The discussions include the
recommended alternative and the costs. The cost-effective remedy is one
which effectively mitigates and minimizes threats to and provides adequate
protection of public health, welfare and the environment, considering cost,
technology, reliability, administrative and other concerns. Adequate
protection is considered to be, at a minimum, a remedy which attains or
exceeds applicable or relevant Federal public health or environmental
standards. Primary consideration has been given to these standards in the
selection of the recommended alternative. The recommended alternative'
combines elements from the different example remedial alternatives examined
in the feasibility study, as well as other eleme~ts brought to EPAls
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On-site (Area 1) Soils
The recommended alternative for Area 1 consists of: a non-destructive
geophysical subsurface survey of Area 1 to locate drums, tanks, and buried
utilities, to be followed by probing and sampling as necessary of discovered
items; excavati on of abandoned ut_ili ti,es, concentrated non-soil C)r
containerized wastes, and areas of known PCB concentrations over 50 ppm;
excavation, or pumping out, cleaning, and plugging of buried tanks and
facilities if they cannot be excavated; and a deed or title restriction on
tne use of the site. Test1ngand sampling to define the excavation would be
done during the remedial design, while the type and design of the cap would
be determined during the next phase of remedial action. The estimated costs
for this alternative are: $625,000 for the sampling and analysis during
detailed design; $5,200,000 for the excavation and other on-site work during
this phase of the remedial action. This cost estimate is based on
. excavating and disposing off-site 10,650 cubic yards, or.1(n of the material
in tne top six feet. The cost for the excavation and disposal phase is only
an estimate and cannot be accurately determined until the sampling is
completed. These activities will reduce the source strength.
The alternatives considerea in the Feasibility Study included leaving wastes
in-place and placing a multilayer RCRA cap over the site, placing all the
material in the unsaturated zone in the double-lined landfill on the site,
and excavating to background with transport and disposal off-site.
Significant contamination is found down to 15 feet. Cleaning to background
would cost more than $164,000,000 (Alternative 5 present worth, based on
disposal costs in Spring 1985). The selected alternative is similar to
Al ternative 2, but is more protective. (Al ternative 2 placed a RCRA cap
over the site, and excavated only buried containers and utilities.) In
addition to the protections provided by Alternative 2. the recommended
alternative would remove from the site the most hazardous materials and the
materials most likely to make it hard to achieve the groundwater
improvements or cap stability. It differs from Alternative 2 by excavating
some of the waste materials on the site, allowing some of the currently'
off-site soil contaminated by Western to be brought back on to the site and
placed under the cap. and postponing placement of the cap until the
groundwater extraction program is completed. It is not known whether the
cap would be compatible with the extension of 72nd Avenue S. or other
development under consideration by the city of Kent.
Off-site 50115
The recommended alternative for off-site soils consists of: extensive
additional soil sampling and analysis; excavation of abandoned utilities
leaving Area I; excavation of soils contaminated with PCBs over 2 ppm;
excavation of hot spots (defined below); covering/capping soils above.
background; inspection and cleaning of .'iveM utility line vaults/manholes
which may have been affected by Western Processing; and the removal or
decontamination of a lead contaminated house. Additional excavation of
soils with zinc or cadmium or other heavy meta' concentrations which may
affect achieving the Mill Creek and shallow groundwater 90als may also be
necessary.
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. .
The estimated costs for the recommended alternative are: $1,000,000 for the
sampling and analysis during detailed design; and $625,000 for tne
excavation, capping/covering and other off-site work. The cost for the
excavation and disposal phase is only an estimate" and cannot be determined
until the sampling is completed and decisions are made on what material can
be consolidated on Area I. This estimate assumes that almost all of the
excavated off-site 50115 will be placed on Area I. (See Selection of
Disposal Facility section.)
The additional soil sampling and analysts would be done during remedial
design. All off-site remedial analysis areas would be sampled except for
Area VI. The sampling program would be phased, with the initial phase.
consisting of over 300 sampling locations. The tightest grids and deepest
samples would be in the areas of former overland flow in Areas II, V, and.
IX. Table 5 contains more details on the initial phase of the soil sampling
program. ..
~oils contaminanted from Western Processing activities with above background
priority pollutants will also be covered with materials of permeability less
than or equal to the natural subsoils, unless it is more cost-effective or
practicable to excavate these soils. Excavation of soils with below hot
spot concentrations will be likely in the S. 196th Street ditch and other
drainage ditches. as placing a cover/cap may not be practicable. Off-site
areas with small areas of above background concentrations may be
cost-effective to excavate. The decision on whether tne cover/cap should be
soil or other materials (such as asphalt or concrete) will be mostly
dependent on what alternative will have the lowest maintenance requirement
for a particular property. Discussions with the property owners will also
be a part of this decision. Detailed design work may disclose that, for
certain off-site areas (e.g. Area II), it is more cost-effective to cap the
area, even if certain utilities must be moved.
The exposure assessment/risk analysis approach has been used to set the
action levels for defining hot spots, or the residual contamination which
.may be left in place as it will not pose a threat to health or the
environment through any route of exposure. The impacts of the off-site
soils on the groundwater are addressed through the shallow groundwater
component. For direct contact, a hot spot has been defined to be soil with
a~ one compound exceeding the ADI, or with I cumulltive Clncer risk in
excess of 1 x 10-5, or PCB concentration above 2 ppm. These cancer risks
are extremely conservative, IS they are based on a 40 year exposure, while
the maximum likely exposure to the non-surface soils would be short-term
while placing utilities or foundations on these properties for light
industrial developments. The cover/cap will provide additional protection
against release to the groundwater, surface water, or to the public (through
inhalation.)
Alternatives considered in the FeasibilitY Study for off-property areas for
remedying direct contact were no action, multilayer RCRA capping, and one
foot or three feet of excavation and fill. Other alternatives raised during
or after the comment period include total excavation to the water table, hot
spot excavation in the top 4 feet, excavation to background, and deed or
title restrictions.
. .. - ...~.. ..
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The otner alternatives for off-property areas are not as protective of
public health or ire not cost-effective, or have institutional problems.
For those soils above background, no action and a uniform one foot
excavation are not as protective of pUblic health. A uniform 3 foot
excavation would be more costly than the recommended alternative while
providing fewer pUblic health benefits because there would be less depth of
hot spots removed. The property owners do not want a multilayer RCRA cap on
their properties which may disrupt their. development plans for their
properties., As a reflection of community desires, the City of Kent also
strongly supports measures that will allow these properties to be developed.
Selection of Disposal Facility
The proposed alternative involves both on-site and off-site disposal. To
minimize unnecessary utilization of limited double-lined landfill capacity,
and to redUce costs associated with this remedial action, contaminated soils
which are currently off-site and which are not WDOE extremely hazardous
wastes and which do not contain PCBs may be brought on to Area 1 for
placement under the eventual cap, and/or to be handled as part of any
in-situ treatment or stabilization. This consolidation of wastes from
releases from Western Processing is considered to be fully compliant with
the applicable and relevent provisions of RCRA. The soils which will be
brought onto Area 1 will generally be less contaminated than the current
Area I site average soil contamination, and will be a much smaller volume
than the total amount of on-site contaminated soils and wastes, but may be a
larger volume than the soils and wastes which will De excavated and taken to
off-site disposal from Area 1. The placement of off-site soils would be
scheduled to occur after completion of the on-site excavation. A clean
surface (e.g. gravel) would be placed on top of all soil to provide a clean
work surface for the groundwater extraction system. Careful design will be
needed to ensure that the contaminated soil will not add sufficient depth to
interfere with the operation of the well point system.
Off-site transport and disposal of some of the hazardous substances are is
necessary to protect pubJic health, welfare and tne environment from a
present or potential risk and to improve the reliability of the proposed
remedial actions. Excavation and removal to an off-site disposal facility
would include transportation in accordance with DOT regulations, disposal in
a government approved facilitY, and replacement with clean fill if the
excavation is not in Area I. Selection of a disposal facility will be in
accordance with the guidelines in the Acting Assistant Administrator, Office
of Solid Waste and Emergency Response, Jack.W. McGraw's May 6, 1985
memorandum Procedures for Planning and Implementing Off-site Response
Actions. This policy requires that, among other items, all off-site
disposal of hazardous waste must use disposal facilities and units which.
.have at least two liners and a leachate detection, collection and removal'
system above and betWeen the liners. In addition, the facility must have no
significant RCRA violations (as determined by EPA), unless the owner or
operator of the facility has committed through an enforceable agreement with
the government to correct the problem. The sites must be inspected within
six months of disposal of the CERCLA waste. .
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Shallow Groundwater
. The recommended alternative for the shallow groundwater component is a
groundwater extraction system in Areas I, U, V, and IX, unless design
studies demonstrate that a smaller array will be sufficient to establish an
inward hydraulic gradient throughout the currently contaminated shallow
groundwater zone. The recommended alternative includes low capital cost in
situ chemical leaching techniques after monitoring the site to ensure that
adequate gradient control has been established and after sufficient
laboratory scale testing. Institutional controls to permanently prevent the
extraction and beneficial use of the zone of contaminated groundwater will
also be necessary prior to site close-out.
The objectives for the shallow groundwater component are: (1) no degradation
of the shallow groundwater beyond the currently contaminated zone, and (2) a
reduction in groundwater contamination concentration to levels that will
protect the aquatic organisms in Mill Creek. (See the Mill Creek component
section.) These objectives w111 be achieved at least partly by a well-point
groundwater extraction system, with treatment and discharge of the extracted
water to Metro. The clean-up of Western Processing will not be considered
to be complete until these objectives are achieved and continue to be
achieved after termination of the groundwater extraction system operations.
The alternatives considered in the Feasibility Study included no action,
pump for five years, pump for 30 years, pump for 120 years, and excavate
300,000 cubic yards of soil while pumping for four years. Because of the
unknowns in predicting groundwater and contaminant behavior in this system,
as demonstrated in the analysis in the Feasibility Study, only a phased
remedy for the shallow groundwater component can be addressed at this time.
As described in the Alternatives Considered section, a number of innovative
technologies were brought to EPAls attention after the Feasibility Study was
completed. The preliminary testing column testing for enhanced .leaching of
Western Processing soils indicates that metals removal can be accelerated
several times. Leaching solutions applied to the site would be collected by
the well point system. However while these techniques may work in theory or
in lab scale tests, these leaching techniques may have real life practical
. or cost-effective limits in the field. Pilot scale tests may be necessary.
Other techniques SUCh as in-situ stabilization may become more feasible over
the next few years and may make it possible to achieve the shallow .
groundwater objective by immobilizing the metals rather than removing them.
The initial capitol cost of the selected alternative 1s estimated to be
$6,800,000 if the treatment plant is designed to handle enhanced leaching.
The annual O&M expenses are estimated to be $1,500,000 to $2,500,000 (in
constant 1985 dollars) for the first 15 years. Fifteen years is the.
estimated .11fespan for the major equipment items. The O&M expenses are.
dependent on whether the enhanced leaching system is operating. If detailed
design studies disclose that the costs.associated with enhanced leaching are
significantly above these estimates, a decision on enhanced leaching will be
postponed to the next phase of remedial action.
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The first performance standard - no further degradation of the shallow
groundWater - will be achieved by placing monitoring wells and checking
their water levels and quality. The shallow groundwater flow pattern is
largely controlled by the presence of Mill Creek and the East Drain.
The second performance standard - water quality protective of aquatic
organisms in Mill Creek - is expected to be achievable relatively quickly on
a temporary basis when the groundwater extraction and treatment system
changes hydraulic gradients and stopS the groundwater discharge to Mill
Creek. Achieving the standard on a permanent basis (e.g. without the
operation of the groundwater extraction and treatment system) will require a
reduction in the site groundwater concentration of the inorganics with the
largest loaoing' to Mill Creek from the Western Processing site, namely zinc,
cadmium, and possibly chromium. Based on a mass balance/dilution analysis,
CH2M Hill has determined that the groundwater target levels to meet creek'
water quality criteria are zinc at 500 ppb and cadmium at 10 ppb. To
achieve these groundwater target levels, over 99 percent of the available
(mobile) zinc and cadmium would have to be removed from the site. Assuming
all of the zinc and cadmium measured at the site is available, over 120
years of groundwater pumping would be required to achieve the required
1 evels.
Originally, another objective of the shallow groundwater component was to
improve the shallow groundwater at the boundary of Area 1 to drinking water
standards. However, this standard is may not achievable for technological
reasons. While organic contaminants can be mostly eliminated from the
shallow groundwater system (or reduced below drinking water standards or
criteria) in 5 to 30 years of pumping, some of the inorganics found below
the site could not be reduced to drinking water standards in over 120 years
of pumping, though the technologies which may be necessary to produce
groundwater quality which will protect Mill Creek will also greatly reduce
the concentrations of those inorganics for which there are drinking water
standards.
If groundwater cannot be returned to HCLs or other health based criteria
. (e.g. acceptable excess cancer risk levels or ADIs), ACLs may be established
in a future ROD. The ACLs may utilize institutional controls.
Institutional controls on both the state and local level may be proposed to
ensure that there will be ,no threats to public health from this contaminated
groundwater. WOOE may be able to restrict groundwater extracted at rates
over 5000 gpm, but has no control over domestic sized withdrawals. However,
the industrial zoning of the area, alternate water supplies, and city
controls should preclude the smaller sized withdrawals.
Forces other than institutional controls are more likely to ensure that no
one withdraws this water for use. The shallow groundwater under the site"
as discussed in the Section on Consistency with Other Environmental Laws, is
not an important groundwater source in the Kent area because of generallY
low yield (less than 100 gpm) and poor water quality. Large amounts of
excellent quality water are available from the City of Kent production and
distribution system. The agency's original concerns for the threats to the
City of Kent water supply wells have turned out to be unfounded, as the
artesian aquifer only exists at the margins of the valley, not below Western
Processing.
.~..... -- 0.""" -.
-------
22
Mill Creek
The objective for remedial action in Mill Creek is to eliminate those water
quality conditions in Mill Creek which limit aquatic organisms of concern
and which are caused by Western Processing. This objective will 'be met by
groundwater control, shallow groundwater quali~ improvement, and sediment
excavation.
The perfonaance standard is to return Mill Creek waters and sediments to
ambient water quality criteria for aquatic organisms or to upstream (creek
or groundwater) background, whichever is less stringent. However Mill Creek
has a number of unusual conditions which would exist even if Western
Processing were not present. These include background (upstream) .
concentrations of certain metals and organics above water quality criteria
for aquatic 'organisms and background groundwater concentrations which are
also above water quality criteria. The upstream concentrations above
criteria are probably from both other sources of pollutants and the high
natural groundwater concentrations of metals.
The lack of valuable aquatic organisms in Mill Creek is probably more from
the many sources of pollutants and habitat modifications in Mill Creek, than
from the high background groundWater concentrations. The aquatic water
quality criteria are based on the most sensitive species. A review of the
criteria development documents snow that the fish of most concern in Mill
Creek - namely salmonids and trout -can live in zinc concentrations much
higher than the Federal water quality criteria. Similar information is
available on cadmium.
The east drain water and sediment quality will also be improved with a
combination of groundwater control, shallow groundwater quality improvement,
and sediment excavation.
.In addition, the recommended alternative includes a sediment excavation
program to remove sediments contaminated with metals in a bioavailable form
because of tne potential threats to bottom-dwelling or bottom-feeding
organisms. This removal would be planned for after the groundwater control
system has been effective in stopping groundwater discharge from Western
Processing to the creek. At a minimum, the stream length to be excavated
would extend from the upstream end of Area 5 to downstream of the railroad
drainage ditch discharge. Additional downstream areas of known deposition
would be tested for bioavanable metals which came from Western Processing.
Other alternatives for Mill . Creek presented in the Feasibility Study were no
action and groundwater control to achieve the water quali~ criteria but no
sediment excavation. The groundwater control only alternative would be
protective of the environment, but would take longer to remedy the problem.
The groundwater control only alternathe would a110w natural sedilllent .
transport to clean out the sediments over a number of years. The
recommended alternative is more quickly protective of the environment and is
thus a cost-effective alternative.
-------
. .
23
Storm water controls
Storm water must be managed both on and off the Western Processing site.
as well as during and after construction. The PRPs have been collecting
and treating Area I stormwater prior to discharge to the Metro system. If
necessary. a similar system will be continued by EPA and WDOE until
construction begins. During construction on and off the Western
Processing property, all stormwater must be handled according to good
construction practices. This may include collecting and treating the
water prior to discharge. After Area I is capped, clean stormwater will
run off the site, with the rate and quantities consistent with the City of
Kent's stormwater ordinances. The off-property covered/capped areas will
require maintenance to ensure that erosion and sedimentation will not
occur.
Besides no action, there are three other alternatives for handling Area I
stormwater during the groundwater pumping period. (The final RCRA cap
would be placed on the site after pumping is completed.) These are: 1)
- continued collection, treatment, and discharge to Metro of the stormwater;
2) a temporary cover/cap on the site which would allow the water running
off the property to be uncontaminated; and 3) store the stormwater on the
site and allow it to infiltrate through the unsaturated zone. The no
action alternative is not protective of public health or the environment.
Collection, treatment, and discharge of the stormwater would have the
highest aIM of any of these alternatives, and would use up a large
percentage of the potential sewer line capacity which will be needed for
discharge of the treated groundwater. Of the other two alternatives. the
infiltration of the rainwater ;s the recommended alternative because it
will enhance the leaching of the metals and lower the operating costs for
the acid leaching system.
The capitol cost of the recommended alternative is included in the grading
to install the groundwater pumping system.
......, .. ."..'
-------
24
. .
Monitoring
The recommended alternative includes an extensive monitoring program
designed to monitor the effectiveness of the remedial action, to provide
information for future phases of , the remedial action, and to investigate the
deeper regional (50 to ISO' deep) groundwater conditions. .
This monitoring program will include:
- Nine to twelve well clusters encircling the contaminanted groundwater
zone, with ti to 8 shallow wells screened at 10 to 30 feet within the
contaminated zone. The well clusters will included wells screened at
.10 to 30 feet; 40 to 60 feet; and 80 to 100 feet below the surface. At
least three clusters will include a well screened at 120 to 140 feet
below the surface.
- Mill Creek and East drain water and sediments upstream and downstream
of the Western Processing site.
- Air monitoring for organics and particulates during construction.
Most alternatives in the Feasibility Study had groundwater monitoring. The
no action alternative is not adequately protective of public health and the
environment, and would not comply with the RCRA groundwater protection
strategy.
Monitoring costs are estimated to be $540,000 per year.
.. '",' """.
-------
. .
25
Community Relations
A major comment during the public comment period on the Feasibility Study
was the interested community's desire to have access to monitoring data and
other information on the status of the site before significant decisions are
made. EPA intends to remain the lead agency for community relations, with
active participation by WDOE and tne contractors.
Activities will include:
- Public presentations on the progress of work on the Western
Processing site, with the frequency and location to be guided by public
interest and the City of Kent. A suggested approach is for monthly.
presentations at the City of Kent City Council Workshops throughout the
design and active remedial construction period. with quarterly or
annual presentations during the extended OIM and monitoring periods.
- Preparation and distribution of a public notice and fact sheet at the
completion of engineering design
- Continuation of the information repository at the City of Kent and
EPA Regional library. At a minimum, copies of all pUblic and press
releases; QAed groundwater, surface water, soil, sediment, and air
monitoring data; supplemental remedial planning documents and all other
simila~ documents will be placed in these r~positories promptly.
- Public presentations on the supplemental planning studies, if any are
initiated. Public presentations would, at a minimum, be made during
the design or scoping of the study, and igain when the study is
completed and recommendations are made. These public presentations may
be part of the above regular public presentations, with additional
public announcements on the agenda of the presentation.
Other Issues
Any construction in the flood hazard areas in Mill Creek will be designed to
not adversely change flood elevations and to comply as much as practicable
with all applicable local rules, regulations, and ordinances.
-------
. .
26
Costs
The estimated costs (+5OS to -3OS) for the recommended alternative is:
Detailed design $3,415,000.
(Of which, $1,625,000 is for 5011 and waste sampling and
analysis. )
Capitol Costs
On-site 5011 s
Off-site sol1s
Groundwater pump and treat
Ennanced leaching
Mill Creek excavation
Total
$5,200,000.
625,000.
6,800,000.
2,600,000.
1,300,000.
18,100,000
Operation and Maintenance
Annually, during initial phase of system operation
Without enhanced leaching 2,000,000.
With enhanced leaching 3,000,000.
The present worth of the proposed alternative for the five years of initial
system operation is estimated to be $26,300,000, not including detailed
design and sol1 samplfng and analysis.
Most of these costs are based on the data in the Feasbil1iy Study. The
costs for the enhanced leaching and soil sampling programs were developed
after the Feasil1ty Study was completed.
-------
. 27
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The following federal environmental standards are applicable to remedial
actions at the Western Processing site:
- Hazardous Waste Regulations (RCRA), Subpart G - closure and
post-closure
- Hazardous Waste Regulations (RCRA), Subpart F - Groundwater
protection requirements, including potential ACLs for the most toxic
and persistent chemicals
- Hazardous Waste Regulations (RCRA) relating to compliance at off-site
disposal facilities
- Clean Water Act pretreatment standards for discharge into a publicly
owned treatment works
- TSCA requirements for PCB disposal .
- Guidelines for Specification of Disposal sites for Dredged or Fill
Material
- National Ambient Air Quality Standards
- Floodplains Executive Order
- OSHA Requirements
- DOT Hazardous Materials Transport Regulations
The following federal environmental standards are relevant to remedial
actions at the Western Processing site:
- Water Quality standards for Mill Creek, a~ determined by the State of
Washington under tne Clean Water Act, if there is a surface water
discharge
The following federal environmental criteria, guidance, and advisories are
to be considered in remedial actions at the Western Processing site:
- RMCL
- Federal Water Quality Criteria
- EPA's Groundwater Protection Strategy
- Floodplain Executive Order
The following state environmental criteria, guidance, and advisories are to
be considered in remedial actions at the Western Processing site:
- State groundwater approval
- State How Clean is Clean policy
The RCRA Subpart G - Closure and Post-closure - technical requirements were
applied in a number of different ways. . Example Alternative 2 was designed
to comply with the standards for closure as an existing land disposal unit.
Example Alternative 3 was designed to comply with the standards for closure
-------
28
as a new land disposal unit. Example Alternative 5 was designed to comply
with the standards for closure for a storage facility. The RCRA Subpart F -
Groundwater Protection technical requirements were sati$fied in Example
Alternatives 2. 3. and 5. .
The recommended alternative is an interim measure. However, the relevent
and applicable standards, criteria. guidance, and advisories have been
considered in the recommended alternative whenever practicable.
Aspects of the recommended alternative which are compliant with the
applicable and relevant portions of RCRA regulations include:
- Groundwater monitoring
- PCB clean-up levels (The 2 ppm off-site level in also consistent
with WDOE policy.)
- Off-site soil cover design and maintenance
- Title/deed restrictions if certain off-site areas are capped instead
of excavated.
Aspects of the "recorrmended alternative which are consistent with the
Assistant Administrator's application of RCRA to the Crystal Chemical CERCLA
site include:
- Consolidation on-site of hazardOUS substances which have migrated
off-site from Western Processing
- When combined with the recommended alternative's groundwater
actions, the off-site excavation criteria
- In situ stabilization and treatment
Aspects of the recommended alternative for which RCRA compliance will be
determined in the next phase of remedial action include:
- Acceptable shallow groundwater concentration limits.
- On-site cap design.
- Title/deed restrictions in Area I.
The federal Water Quality Criteria for aquatic organisms are used to set the
Mill Creek water quality needs in all Example Alternatives and the "
recommended alternative. As described below in the recommended Llternative
section, the recommended alternative is consistent with EPAls Groundwater
Protection Strategy. The shallow groundwater is technically Class II,
though it has some elements of the Class 111 definition. Alternative water
supplies are available.
Other key requirements which will be complied with include: RCRA
requirements at off-site disposal facilities. Clean Water Act pretreatment
. >.. .'.--"'_._.__0 .
-------
"
29
standardS for discharge into a publicly owned treatment works; TSCA
requirements for PCB disposal; guidelines for the disposal of dredged
material; air quality standards; floodplain protection requirements; DOE
Hazardous Materials Transport Regulations; and the State of Washington Water
Quality Standards for Hill Creek.
The State of Washington Department of Ecology participated in the
development of the Feasibility Study and has concurred in the recommended
.1 ternati ve.
-------
30
OPERATION AND MAINTENANCE (OiM)
The DIM activities required to ensure effectiveness of the remedy include:
Operation of the groundwater extraction and treatment system as long
as necessary .
Maintenance of the RCRA on-site cap and off-site caps/covers, and
stonIWater control system for a minimum of 30 years
Long-term monitoring of the shallow and deep groundwater, and Mill
Creek water and sediment quality.
These OIM activities may be required in perpetuity if these or other
remedial actions do not mitigate the releases or if problems are
detected. Alternatively, certain of these activities may be allowed to
cease after EPA has determined that no threats to public health, welfare,
or the environment would occur.
Annual OIM costs witn the operation of the groundwater extraction and
treatment system are estimated to be $2,000,000 to $3,000,000 depending on
whether tt1e enhanced leaching system is operating. Annual OIM costs would
be lower when the groundwater extraction system ceases operation.
Because this is an interim remedy and the initial phase of system
operation/construction will require up to five years, monitoring and the
operations and maintenance of the pumping system for five years is part of
the remedial action which will be paid for by both the Fund and WDOE. An
EPA/State contract or cooperative agreeement will be the mechanism for
this OIM. WOOE acknowledges that O&M in future years will be the
responsibility of tne state.
. .- --.. -'..'.--.. .- ,. .
-------
31
SCHEDULE
- Complete Enforcement Negotiations
- Approve Remedial Action (sign ROD)
September, 1985
September, 1985
- Award lAG for Remedial Design to COE
- Start Design
October, 1985
November, 1985
- Award SUperfund State Contract for Construction
- Advertise for Construction Bids
April 1986
April 1986
- Complete Major On-site Excavation
- Start Groundwater Extraction
June 1986
August 1986
- Start Construction
1987
Fund-financed and state financed actions will be neccessary for stormwater
control actions until construction starts in 1986.
. -p,-"'. ~ ..~. ''''
-------
32
FUTURE ACTIONS
The additional remedial activities which are required to complete the site
response may include:
Supplemental remedial planning and possibly a third operable unit if
the extent of groundwater contamination is not adequately control by
the shallow groundwater extraction and treatment system, if the
contamination in the shallow groundwater is not adequately reduced by
the shallow groundwater extraction and treatment system and in situ
chemical leaching, or if contamination from Western Processing is found
in the -regional aquifer.
Site close-out with a cap.
Long-term O&M on the groundwater extraction and treatment system, cap,
cover and stormwater control systems, and monitoring systems.
--.. -, --.,..-~-~. ---- ~~.~.. . .
-------
. Tab18 "1
IBDICATOa CONTAMINANTS USED AT WESTERN
OrQanic8
volatile orqanic.:
1,1, I-Trichloroethane
Tran.-l,2-Dichloro8thene
Tetrachloroethene
Trichloroetb8ne
Toluene
Chloroform
Acid Extractable Compound.:
. 2, 4-Di.m8tbylphenol
.'henol
..- - -Ia.e/Neutral C01I\ioun4.:
Total ,AJI'.
Total 'hthalate.
other orqanic.'
'CB'.
oxazoli4one
PROCESSING
Inorqanics
Metal.:
Cadmium
Chromium
Copper
Nick81
L8al!
Zinc
aTotal priority pollutant polycyclic aromatic hydrocarbons
(,AS's).
-.
Table .2
LOCATION OF CHEMICALS WITHIN THE SOIL 'ROFILE
Incu.cator
C01DPOunc!.
Depth ..10" the surface
Where CQ8POunc!. Were
Mo.t rrequentlY rounc!
Depth Below the
surface Where Compognc!.
Were roun4 1ft the
Hiqhe.t concentration. .
o to 9 feet
o to 9 feet
Metals
volatile or9anics
6 to 9 feet
6 to 9 feet
Acia .ua~les
9 to 21 feet
9 to 21 feet
.a..lI'e1lua1s
'foUl ,AIls
'hthA1ate.
o to 3 feet
o to 9 feet
o to 3 feet
surface .0U
sudace .011
10 feet (on-property)
Surface .011 (off-
prop8~ty)
'O's
-
-------
Table -- S
'1'O'I'AL MASSF.S AND SI'1'1 AVERAGB COIWAMIHAN'f COIICEIIftA!'IOHS
C HONDE'fEC'I'S . 0» WaS'I'ERN PROCESSIHG, ._, WASIIIIIGI'OtI
t
, an..... awe.....
Iotal"'" Total .... Total lie.. ........ sou a.,..... SOU an ~m Nt.8.. Gnu8dHt...
18 SoU 18 SoU 18 SoU COac8at...U- eo.-tnU- a...t...tIOll eo.-t...UOll
H ft. 6-15 ft. 15-JO ft. 6-15 It. I5-JO It. 6-15 It. 15-10 It.
!!!! COIIt_IMllt CI,I CI,) CI,I CUl/IG) CUIIIG' CUl/LI ~~
IIU Vol.tUe.
""'1 . 291 72t 190 2,929 tIO ' 18,5a 1,.90
IleU.,I- eblorlde U7 158 61 1,." I" 56,172 .1,911
Tr- 1,2-c1lebloroet"" 0.01 I I 2 I 20,297 IS.
0.101'0(01'8 28 99 1 tOl 2 2,171 2,012
Trlcbloroet.... 2,2tS 5,220 17 21,105 .. JI,S8 7,2"
I,I,I-Trlebloroetbanl 176 81 I 2,275 I 21,601 1,01.
Tol..... 1,016 2,122 22 1,512 52 1,613 11.
Tet..8dllor..t.... 1.1 271 0.1 1,091 I 101 °
It.., I""... 12 201 I 119 I 2 °
!!!l!!
IlAplatb8lene 8,201 169 . 1,.91 II 2 2J
"""'U.rene 22,191 St9 ° 2,221 ° ° °
fC8 51 279 ° 1,121 ° ° °
"I'''' 17,001 81 ° U. ° ° °
"..rut.... 991 US ° St. ° ° 0
1leD&0Caluthra- 1,086 . ° 11 ° 0.1 °
BI.C2-et..,lbla,1I
pbtb8l.te 1,988 1,207 In 12,"8 156 ° °
!!!!!!!
.'eUl 19,160 20,16. 5,101 11,511 U,JIO 15,129 1.,250
CadU- .,nl 7,171 605 lI,tSl 1,- 2,191 ".
IlK 777,160 .9.,287 91,7U 1,872,Ul 227,155 IH,.n 117,'87
CIa.-I- 76,129 1",679 16,611 665,119 .0,- 5,2.9 IU
ar-Ic 1,112 155 1,151 1,.51 .,2U 1. U
CcIppe.. 51,012 1.,195 10,618 1",250 ,25,. I,JJI 751
.... 1,151,198 616,0" 5,285 2,561,661 12,121 Ita HI
. 0.' 0'
, .
\ :,
.;
-------
Table ~ If'. '\(cant. )
,..... ,,,......
total .... Total .... total .... "'1'''' Son 'weI',,- Ion .. -.ter ~at.1'
i8 Son iD SoU i8 SoU eo.-tnti- ~U- Co8C8traU- ~traU-
0-6 It. 6-15 It. 15-10 It. 6-15 It. 1s-JO It. '-is It. 15-30 It.
AI'8@ Cont_inlftt Ilg) .Ig) ,IG) luo/IQ) 1..1Ia) I"'U (..II.)
V VolaUI..
.....-1 2' U Q 1,2tO 0 7.5,'54 It
Ilet",leD8 c:bloride I 4 161 60 1,621 . 40,601 122
'fI'8D8 1,2-cUcbIOl'oetb8D8 0 0.01 1 0.2 1 147,G05 0
01101'010'" 0 0 0 0 0 1,21J 1,111
fl'icblol'oeth,1'" 0.1 J 1 21 6 19,5J5 I,no
l.l,1-fl'ichloroetb8n8 0 0 0 0 0 1,620 0
ToI"'" 1 I 4 20 n I 44
fetl'acblol'ot'" 1- 0.02 I 0.1 15 I 181 0
Ethy 1"".'" 0 0 0 0 0 0 0
..,al
-
.....Usal- 0 0 0 0 0 0 21
,........U...8118 0.1 0 0 0.06 0 0 0
10 5 0 0 1 0 0 0
"1'8118 0.1 0 0 0.06 0 0 0
flUDrlDtbaM 0.1 0 0 0.06 0 0 0
""0 la) antbracene 0 0 0 0 0 0 0
Bi.C2-etb,)h88,I)
"Uaalate 0.01 0.04 0 I 0 0 0
. lletall
---
.i~e1 654 654 951 10,140 9,456 1,127 461
C8d8i- 111 46 16 151 162 61 119
liac 10,641 7.1" 1,221 121,41' 12,042 11,2" 10.116
Oar_i- 1.619 ,;a4 199 15,111 1,- " 80
an8Dle 106 124 IU 5,111 1..7 5 15
CallP8I' 1,115 1.112 2,010 19,4'" 20,-. 42 24
. . ...... 1,057 196 2U 1),191 2,U4 29 21
;
;
~ .~
-------
!'able L ~cont.) .
,
~... 8011 &wer... .....a...
Yotal ..... rota I ..... Yota I ..... a..r..,. Ion Gnu8dNter Gr""at.r
18 SoU In SOU 18 SOU c.c..traU- r08CllltnU- tGac88trata.. CoaaaIItratl-
~ ft. 6-15 ft. 15-10 ft. '-IS ft. 1'-JO ft. 6-15 ft. 15-30 It.
!!!! eont_IDaDt C.!l1 C.gl C.gl C""14I1 e...,... C...,... 't'./~
.1 Vol aU Ie.
......1 0 0 0 0 0 0 0
Iletb,lene chlo..l. . 1 . 67 .. 10 5
Yr... 1,2-dlchloroetb,lene 0 0 0 0 0 "I II
a.loroforll 0 0 0 0 0 0.3 0
blcbloroeth,lene 0.01 0.1 0.01 2 0.1 106 ..
1,1,I-YrlchloroethaDe 0 0 0 0 0 10 7
701.... O.OJ 0.1 I J II 0.1 0
t8tracblorotbrl... 0 0 0 0 0 0 0
Rbr I"""... 0.01 0.01 0 0.1 0 0 0
!!!!!!
llapbthal... 0.2 0 0 0 0 0 0
RleDutbreM 0.02 0 0 0 0 0 0
IIC8 37 0 0 0 0 0 0
~..... 0.2 0 0 0 0 0 0
Fluor.theM 0.1 0 0 0 0 0 0
BenaoCalanthracene 0.3 0 0 0 0 0 0
BisC2-etb,lbea,11
phthalate 1 1 .U 10,719 6,557 0 0
!!!!!!!
III~I 59. 541 721 u,SOt 10,710 5.0 0
Callal.. U5 81 25 1,"2 167 9t 0
Iinc lS,ns 1.,2U 'I, }, ~". 'S ~1J,:JiI ~ 6 ~ "r 3 " i.> I
Cbr_I.. 9,no J,767 817 92,928 12,092 7 .0
"'88Dlc JJJ US .u 10,719 6,557 0 0
Copper 2,120 1,718 I,U9 U,I72 21,161 J 0
Lead 1,698 n9 1.2 ,11,109 . 2,098 0 0
, .. I .,
-------
.......
a,,"""-
,.
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..... I .. II. ...
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......... ....... I'.
11- '. II, , .. I.,
-". "..,.... ..
r.. .......-
.......
.JI!I!L
S!II!d
...
...
- Tab1e 4
SUMMARY OF PUBLIC HBAL~, BNVIRONMBNraL,
AND 7BCHNICAL BVALUA710HS
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decide on . remedial action. The major areas wnicn were affected by tnis
concern are groundwater (Is there deep groundwater contamination which has
. reached the regional flow system?); Mill Creek (How far downstream and how
deep are the sediments contaminated?); and, to a much smaller extent, 5011
(There isn't enough information to determine the exact extent (vertical and
norizontal) of contamination so that excavation or capping can be defined.)
During tne comment period, most interested parties agreed that at least some
components of a remedial action, especially on-property excavation with
off-site disposal, could and should begin while any missing data are
collected. .
2. Adequacy of the data to demonstrate that there is a public health or
environmental problem. The owner of Western Processing provided a detailed
critique of many of the governments' and PRPs' documents. In his opinion,
the data either does not exist or is inadequate or is unscientific to
support the governments contention that there are any hazards associated
with the site. Some examples are that the forms of lead and chromium on the
site are non-hazardous, and that where and when there m~ be data showing
contamination, that contamination is the result of the governments'actions
or from other pollution sources. Other cammenters questioned the validity
or realism of the endangerment assessment because adults don't eat soil and
no one is drinking the shallow groundwater.
3. Future public participation. A major coanent during the public corrment. :
period on the Feasibility Study was the interested community's desire to '
have access to monitoring data and other information on the status of the
site before significant decisions are made. Any further information which
is collected needs to be shared with tne public and further public input
requested before major decisions are made.
4. Property values and future land use. The neighboring property owners
are greatly concerned about being able to profitably develop and sell their
land. The City of Kent would prefer tnat future use of the Western
Processing site for roads and industrial development not be foreclosed.
-.
s. Protection of workers during maintenance activities on tne surrounding
utilities. The remedial action should include actions ~hich will protect
- utility employees who must in the future maintain the subsurface utilities
near the site.
6. Preferred subsurface alternatives. A major, though not always
successful, goal of the public comment period and meetings was to encourage
participants to come up with and to give to EPA constructive ideas as to how
the site should be cleaned up, rather than to focus on the problems they
perceived in the FeasibilitY Study. Alternatives which involved excavation
and off-site disposal appeared to be favored, while almost no one gave
serious consideration to Alternative 3, the on-property landfill.
Improvement of the groundwater was also favored. However, only very general
feedback was given to EPA on what levels of .clean. were considered
important. It appears that clean was generallY assumed to mean Dackground
(e.g. upstream) water quality in Mill Creek, and adequately low soil
contamination to allow City and the Health Department approval of industrial
developments. Capping and then developing the entire lrea was suggested by
some others. Other ideas included: lowering the water table at the site by
".-., .._-~_.~_.
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
WESTERN PROCESSING SUPERFUND SITE
KENT, WASHINGTON
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY FOR
SUBSURFACE CLEAN-UP
INTRODUCTION
A community relations program has been in place for two years. DOE and EPA
have taken an active role in this plan. The major elements have included:
monthly interagency meetings with the Kent City Mayor and her staff; public
,presentations/meetings whenever the city or city council has requested it;
press releases at all major events, SUCh as the release of data or reports,
or the start of particular on-site activities; wide distribution of press
releases and fact sheets; and the availability of government staff by phone
to respond to questions from the public. Public interest is sporadically
high, though the City of Kent, certain neighboring propertY owners, and a
few individuals have haG a high level of continued interest.
In mid-March 1985, a letter, a fact sheet, a separlte Executive Summary, and
the tWo volume Feasibility Study was made available to the public. Over 500
letters, fact sheets, and Executive Summaries were sent out. (This includes
the approximately 300 copies which were sent to the PRPs.) Over 100 copies -
of the entire Feasibility Study were sent out to individuals, PRPs, and -
agencies known to be interested in the site. A dozen copies were made .
available through the local public and EPA regional libraries. In addition, .
copies were available free from EPA for tne asking. The 30 day comment
period closed April 10, 1985. As of April 26, 1985, 19 comment letters had
been received. Table 1 lists the letters which naG been received. No
letters were identifiable as being from any PRP'or the PRP committee.
Copies of all letters have been placed in the libraries.
A series of four public meetings/workshopS were held at the Kent City Hall.
By the second meeting, virtually all attendees were what could be called
Mextremely or financially interested parties.M Presentations were mad. by
the PRP's coordinating committee'S consultants, a neighboring property
owner's consultants, the owner/operator of Western Processing. the most
active environmentalist. and the fisheries biologist of the local Indian
tribe, as well as by CH2M Hill. The on-going lawsuit betWeen the
neighboring property owner and the PRPs li8ited, to some extent. the range
of potential exchanges betWeen those two parties. Special small briefings
- were held for the affected property owners. natural resource agencies,
environmentalists, and the press.
The responsiveness summary documents for the public record the comments
raised dUring the comment period on the feasibilitY study and how EPA and
the WOOE considered and responded to these concerns.
CONCERNS RAISED DURING THE COMMENT PERIOD
The major issues that were raised were:
1. ,Adequacy of the data to define an adequate remedial action. Statements
-------
4
Processin.g site, witn the frequency and location to be guided by public
interest and the City of Kent. A possible approach is for monthly
presentations at tne City of Kent City Council Workshops throughout the
design and active remedial construction period, with quarterly or
annual presentations during the extended DIM and monitoring periods.
- Continuation of the information repository at the City of Kent and
EPA Regional library. At a minimum, copies of all public and press
releases; quality assured groundwater, surface water, soil, sediment,
and air monitoring data; detailed planning studies and supplemental
remedial planning documents and all other similar documents will be .
placed in these repositories promptly.
- Public presentations on the supplemental planning studies, if any are
initiated. Public presentations would, at a minimum, be made dUring
the design or scoping of the study, and again when the study is
completed and recommendations are made. These public presentations may
be part of the above regular public presentations, with additiona' .
public announcements on the agenda of the presentation.
- Preparation and distribution of a public notice and fact sheet at the
completion of engineering design ~
4. PropertY values and future 'and use. The recommended remedial
alternative will not foreclose development of property outside Area 1 in the-.
future. The off-site soil clean-up criteria will allow safe development of
tne properties, though worker protection may be recommended by the health
department during deep excavation for utilities. Cap/cover maintenance will
be necessary until a site is aeveloped ana an alternative cover placed on .
the site by the property developer. For certain properties, development in
the short-term may not be possible because groundwater extraction wells and
other facilities vital for the clean-up may not be compatible with
development.
Decisions of whether Area 1 can be developed will have be wait. If the
soil on the site is eventually solidified or stabilized in place such that a
RCRA cap is no longer ~ecessary for the protection of public health and the
environment, aevelopment of the site may be possible. If a RCRA cap was to
be placed on the site today. future development of the site may not be
possible. Depending on the final design, a RCRA equivalent cap ~ or may
not be compatible with development.
".
5. ProteCtion of workers during maintenance activities on the surrounding
utilities. The recommended alternative includes inspection and cleaning of
the nearby manholes and vaults which may be entered auring regular.
maintenance activities. 50ils along the Olympic pipeline which may pose a
direct contact hazard will be removed or the pipeline moved. ..
.
6. Preferred subsurface alternatives. The selected remedy incorporates
maoy features which were discussed or raised during the public comment
period. Examples include additional soil and groundwater testing (as
discussed above); reconsideration of alternative technologies to reduce the
hazards of any any materials left on-site, excavation and off-site disposal
. . . .~ ., ~... ,. .....
-------
, .
planting poplar trees and jeruselum artichokes; incineration of the 501,.
and excavatfon and then lining the site to use it as a stonlaJlater detention
pond. Questions raised about the PRPs proposal (Example .Alternative 4)
include the location of and effect of the diversion wa", the number of
years of groundwater extraction, and the need for off-site clean-up.
7. Preferred Mill Creek alternatives. A number of people suggested that
rerouting Mill Creek could be a good solution to the Western ,rocessing
situation. In addition, a number of the property owners are extremely
interested in having M111 Creek rerouted so that the existing creek bed
could be filled and their proper~ more eas11y and fully developed. The
natural resource agencies, the Indian tribe, and others are most concerned
that Mill Creek water quality and fish habitat are improved. Excavation of
contaminated sediments harmful to aquatic organisms was generally supported.
.
RESPONSE TO COMMUNITY CONCERNS
1. Adequacy of the data to define an adequate remedial action. The
proposed remedial action has been staged to ensure that there will be
adequate dati to make the necessary decisions about the details of the
remedial action. Some examples include:
a. Extensive additional soil sampling, particularly off-site, will be:
performed as part of final design of the remedial action to determine'
where and to what depths there are soils that should be excavated.
b. The first set of long-term monitoring wells have been installed
west of Area I. Samples from these sets of wells will help resolve
questions regarding the regional groundwater flow and contamination.
These and other wells will be extensively monitored to ensure the
effectiveness of the remedial action.
c. Conditionally required actions will be implemented if regional
groundwater contamination from Western Processing is detected.
Decisions on the final level of groundwater clean-up will be postponed
until the limits of the proposed remedial action are studied.
2. EPA's dati has geoeral1y been collected and analyzed according to
approved EPA proceedures. EPA disagrees with the owner's interpretation of
the data which forms the basis of his arguments. For example, the 1980
Storet Clata does shOW greatly increased contllllination betWeen the upstream .
and downstreUl data points. Zinc is a good example. The upstrea8 sample is
below the ambient water quality criteria for aquatic organisms while the
downste18 s.-ple is approximately 15 tiles the criteria. On another point,
the largest set of data on the on-site contamintion (the -3013 report-,
dated May 1983) was based on samples taken in the fall of 1982 while Western
Processing was still operating. All sample results will continue to be sent
to the property owner and all other interested parties.
3. Future pub11c participation. EPA intends to remain the lead agency for
communi~ relations, with active participation by WDOE and the contractors.
It is EPA's intention that communitY relations activities will include:
- Public presentations on the progress of work on the Western
-------
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-------
T Q.~(
WES1ERN PROCESSING
0E5I GN p...,gE SAMPL I NG PLAN OUTl.I HE
PH~LIMINARY DRArl
AU I-=: 85
F IfI!>T ANAL Yl I CnL ROUND
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.3 Ff.ET
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TOTALS
------------------------------------------------------------------------------------------------------------------------------
NOTES
SAMPLES
-----------------------------------------------------'---------------------.----------------------------------------------------
DRILLING
AREA I Not Included in Eat iIIUltll
AREA II 0.8 50 14
AREA III 1.7 4 4
AREA IV I. S 3 .'
AR£:A V 3.4
~RLAND rLOW AREA I. ~ 30 58
DALANCE OF AREA 2.2 100 10
AREA VII 0.9 50 If>
AREA VIII o. ',I 50 16
AREA IX 2.6
OVERLAND FLI1W AREA (1.0 .10 3<)
IJnLANCC OF AREA 1.8 100 0
AREA X ~). 5 50 <)C.
GW EMERG ZONES 1.0 50 11
BALANCE 0..- AREA .1t.5 HII) ~c)
I 5(.
I) 0 0
I) (I 0 3
I 0 114
I (J 30
(. ° (. If.
(t (J (I If.
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I I) 51
I) 0 40
TOTAL SAMPL£S 5£.£.
ANAL V COSTS .56f>, (11)(1
DRILLING COSTS .54, 150
LABOR COSTS .Bc>..E.40
--..------
SUBTOTAL S706, 790
EXPENSES ."0,679
---------
SU(tfOTAL .777,4£.9
CONT I NGENCY I ,,'J ."7,74-'
--------.-
GRAND TOTAL S955,216 II
13-AUQ-85
W6(1816. NI)
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12
348
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351
24
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-------
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. e-88
11.9
"'.9
Table 4
.continued'
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-------
, '.
\
.
'.
5
of the most hazardous materials, a performance standard approach for
groundwater cleanup, and off-property clean-up. A diversion wall is not
part of the selected remedy.
7. Preferred Mill Creek alternatives. The possibility of moving the creek
was reconsidered after the comment period closed. While moving the creek
may have benefits for some property owners wishing to develop their
properties, the Fund and the NCP is designed to mitigate environmental
problems from releases of hazardoUS substances. Because Mill Creek is the
groundwater .s1nk. for water under Western Processing, some of the
suggestions for moving Mill Creek could make the extent of shallow
groundwater contamination greater and thus would be detrimental. Moving the
creek would be environmentally acceptable only if the existing creek bed
would be replaced by a French drain, if the discharge from the French drain
would be guaranteed to meet NPDES standards, and if the French drain was.
properly maintained. This would be more expensive than the selected remedy
without environmental benefits. Also, a good sized easement for the
re-routed creek would be necessary to ensure adequate flood flow capacity.
The selected alternative is largely oriented towards ensuring improved water
quality in Mill Creek. It also includes excavation of contaminated
sediments which may be harmful to aquatic organisms.
September 1985
.
-------
Tabl e 1
"
'WESTERN PROCESSING
PUBLIC COMMENT PERIOD ON THE FEASIBILITY STUDY
As of April 26, 1985, written comments had been received from the
'following: '
Greg W1ngard,'TEAC and tne Proposal Consensus Group
The Department of the Interior
01ymp1c pipe Line Company
Metro
NOAA
Puget Power
Dean Bitney and ChuCk GrouwS
u.s. A~ Corps of Engineers
, The C1 ty of Kent
Myron Harr,
Western Processing
Karen 01son Rasmussen, Frank1in I Watkins
Pacific Nurthwest Be11
, Puget Sound Alliance
" ,
/
. .
I,'
/
..
'1'-'.'"
, '--,
HazardouS We
Information R~
US EP A Regiol
Philadelphia,
'.
, '
.~ '.
, ,
. '
'. ... . .~: ~. ", .., .
, .
, Trout Unlimited
" "
Wasnington Institute for Judicial Review ~:(;;;, " :~
, '
,,'
EPA-ORD, HazardouS Waste Engineering Research Laboratory, :'C1ncinnat1
. .
Standard Equipment, Inc.
Department ofCQlll/lUnity Development"
, .
o
", ~. " ... . ,. ,~" '.
. -. ,'---' ~:..-..... . ... ... ..
------- |