United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-86/009
September 1986
$EPA
Superfund
Record of Decision:
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TECHNICAL REPORT DATA
(Pitta. rtad "",ructIOffS Off tht ftVt1f' ~f(Nt com"fttiff')
1. A&POf'T NO. I~' 3. RECIP'E~T'S ACCESSION NO.
EPA/ROD/RIO-86/009
.. TITLE AND SU8TITLe 5. REPORT OATE
SUPER~UND RECORD OF DECISION Sectember 30.1986
Toftdahl Drums, WA 8. PERFORMINCi ORCiAN'ZATION COOE
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7. AuTHORISI 8. PERFORMINCi ORCiANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME ""NO ADDRESS 10. PROCiRAM ELEMENT NO.
11. CONTRACT/CiRANT NO.
,~. SPONSORINCi AGENCY NAME ANO AOORESS 13. TYPE OF REPORT AND PERIOD COVEFlEO
U.S. Environmental .Protection Ag~ncy Fin.:!1 ROD Rennrt
401 M Street, S.W. I.. SPONSORING AGENCY CODE
washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Toftdahl Drum site, approximately 15 acres in area is located four mil es
east-southeast of Battleground, It/ash ington, and contains three main areas where ~
hazardous substance haulingactivitfes may have occurred: a drum clear.ing area; an
initial burial trench; and a final drum burial area. The surface of the site slopes
downward to. the northwest to a spring and a small wester~y:flqwing tributary of Morgan
Creek (informally referred to as Toftdah1 Creek), or about 350 feet to .the southeast
directly to Morgan Creek. The general land use in the area is rural residential .,... it!:
approximately 14 homes within an approximately 90-acre area. In the early 1970s, "I r.
Toftdahl allegedly had 100 to 200 drums containing unknown amounts of industrial was:e,
possibly from a plywood manufacturer, del i v.ered to his property. His intent was to
clean and resell the drums. Unable to resell about 50 uncleaned drums, he constructe':! 3.
burial trench about 500 feet from the cleaning location, placed crushed drums into t!:e
trench, and covered the trench with mounded d i rto The drums were rediscovered in :!:e
mid 1970s when the Davis Family, new owners of a portion of the Toftdahl property,
attempted to level the mound over the burial trench. In 1978 or 1982, Mr. Toftdahl
removed appro;: ima tel y 38 drums and disposed of them in a local landfill, while
approximately 12 drums were reburied in the' f ina 1 burial location. In 1982 the
washington Department of Ecology, not ified of the possible presence of buried drums at
(See Attached Sheet)
17. J(EY WORDS AND DOCUMENT ANALYSIS
a. DesCRIPTORS b.IOENTIFIERS/OPE.\j ENOEO TERMS C. COSATI F,eld:Croup
Record of Decision
Toftdahl Drums, WA
Contaminated Media: N/A
Key contaminants: N/A
18. DISTRIBUTION STATEMENT '.9. SECURITY C\;.ASS / Tllis R~po.tJ ~,. NO. OF PACiES
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None 31
.' I . . ~O. SECURITY CLASS!Tlris PQg~1 2~. PRICE
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:I!PA ',Oflll 2220-1 (R.;'. .-771
PIIICVIOUI IOITION II 08101.ITI
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EPA/ROD/RIO-86/009
Toftdahl Drums. WA
16.
ABSTRACT (continued).
the site, conducted an investigation. Approximately six crushed and badly
rusted drums were sampled and stored onsite and a fence was placed around
the final drum burial area. In November 1983 the Washington Department of
Social' and Health Services (DSHS) determined, based on the available
sampling data from nearby residential wells, there was no immediate public
health hazard in the drinking water. However. DSHS was concerned. about the
potential for future contam~nation from the high levels of heavy metals and
synthetic organic compounds detected in the soil and drum samples. While
several priority pollutants were detected in the RI sampling and analysis
proqram, the concentration of such contamination is very small and could
reflect a source(s) not related to this particular drum cleaning and
disposal operation. In. most sampling cases, the concentration levels could
not be reliably differentiated from background' values or ' .
laboratory-introduced variability. No significant or extensive
contamination of surface soils. surface water. or ground water is present at
the site. Indicator constituents, defined as having been detected at least
one time during investigational sampling include: heavy metals, VOCs.
base-neutral organic compounds. cyanides. and PCBs.
The remedial action selected for this site includes a no further action
response and semi-annual ground water monitoring for five years, followed by
ten years of annual monitoring pending continued. funding by the. Washington
State Legislature,
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site:
Toftdahl Drums, Brush Prairie, Clark County, Washington
Documents Reviewed'
I, am basing my decision primarily on the following documents
describing ,the Toftdahl Drums site.
- Final Report Remedial Investigation for the Toftdahl Drpm
Site. July 17, 1986 '.
- Summary of Remedial Alternative Selection. Toftdahl Drum
Site. August 1986
- Responsiveness 'Summary dated September 22, 1986
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DescriPti?n Qf Selected Remedv
No further action.'to r'emediat~ the site
sa~ple and analyze groundwater sample~ from existing
monitoring wells and private residential wells semi-annually
for five years, and then annually for ten additional 'years,
subject to funding by the Washington State Legislature.
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Declarations
Consistent with 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
"no further action" alternative combined with precautionary'
monitoring of the groundwater by sampling the existing monitoring
and private residential wells on or near the site is the
appropriate remedy for the Toftdahl Drums site. Because of the
lack of significant contamination at the site, and the lack of
evidence that contamiantion has migrated from the site, these
, measures are adequate to protect public health, welfare, and the
environment. The washington Department of Ecology (Ecology) has
been consulted and agrees with this remedy. Ecology has also
agreed to undertake the precautionary monitoring.
I have also determined that the act ion be'ing taken is
appropriate when balanced against the availability of Trust Fund
m 0 n i e s for, use. at, o. the r sit e s . T.h e " No Fur the r Act ion"
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alternative in conjunction ith groundwater 'monitoring will
adequately protect public healt lfare, an the environment.
~-'10~~~
Date
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
TOFTDAHL DRUM SITE,
BRUSH PRAIRIE, CLARK COUNTY, WASHINGTON
~ Location And DescriDtion
The Toftdahl Drum site is apprqximately 15 acres situated
approximately 4 miles east-southeast of Battleground, washington.
,(See Figure 1.) The site 1 ies on a cons iderably dissected,
ir regular, roll ing upland sect ion of the Troutdale bench, a
north-south trending feature about 2 miles wide situated between
the Cascade foothills to the east and a broad alluvial plain to
the west~ "
The three main areas of the site where hazardous substance
handling activities'may have occurred are a drum cleaning area,
an initial burial trench, and a final drum burial area. (See
figure 2) These areas are situated in a saddle at approximately
500 feet above mean sea level. The land slopes uphill to the
east and west. The surface of the site slopes downward to the
northwest to a spring and a small westerly flowing tributary of
Morgan Creek (in£ormally referred to as Toftdahl Creek), or to
the southeast directly to Morgan Creek, about 350 feet away and,
ZOO ~eet lower in elevation. ' ' '
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The general land use in the area is rural residential, with
approximately 14 homes in the, approximately 90 acres' between' NE
, l89th Street and Morgan Creek. Most of these homes obtain their
water from wells which are screened at least 70 feet below the
surface. The natural vegetation at the site is dense and
consists of a mixture of second-growth coniferous forest and
brushy cut-over areas. Access to these homes and to the site is
via an unpaved road.
s..1.U. Historv
In the early 1970's, Mr. Toftdahl is alleged to have ha~
delivered to this property 100 to 200 drums containing unknown
amounts of industrial waste material, possibly'from a plywood
manufacturer. His intent was to clean and then sell the drums,
but he was apparently unable to sell about 50 drums in which
waste residues remained. Mr. Toftdahl subsequently constructed a
burial trench about 500 feet from the cleaning location, placed
crushed drums into the, trench, and covered the trench with
mounded dirt.
The drums were rediscovered in the mid 1970's after the new
owners of a portion of the Toftdahl property, the Davis's,
attempted to level the mound over the burial trench. In 1978 or
1982" approximately 38 drums were removed from the site by Mr.
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Toftdahl and disposed of in a local landfill, while approximately
12 drums were reburied in the final burial location.
The washington Department of Ecology (Ecology) was first
notified about the possible presence of buried drums in 1982. In
1983 the Environmental Protection Agency's (EPA) FIT contractor,
Ecology and Environment (E&E), conducted a site investigation
which included a magnetometer survey, soil and surface water
samples, residential well groundwater samples, and a subsurface
exploration in the area defined by the magnetometer survey as
potentially having buried metal materials. Approximately six.
crushed and badly rusted drums were sampleq and stored on-site.
A fence was placed around the final d rum bur ial area. (Area I I I .
in Figure 2.) Samples were collected from six of these. drums.
In November 1983, the Washington Department of social and
Health Services (DSHS) determined that, based the 'available
sampling data, there was no immediate public health hazard in
drinking water taken from residential wells. near the site.
However, DSHS was concerned that there was an .obvious potential
for contamination ..[from] inorganic sources of contaminationW as
the soil and drum samples did have high levels of both heavy'
metals and various synthetic or~anic compounds in the area of
E&E's first sampling. Additional samples from several wells
taken i~ February, March, July, and November 1984 and. Kay 1985 by
Ecology continu.ed to. show no signific.ant d.egradation of water
qua 1 i t Y . ( 5 e e the' Cur r en t S j. t e ,S tat u sse c t i '0 n below. for.
addi tional information.)
I~ Kay 1984, Ecology nominated the Toftdahl Dr~m site for
,addition to the National Priorities List under CERCLA. Also in
May 1984, Ecology took soil samples from the area where Mr.
Toftdahl's drum cleaning activities were alleged to have
occurred. No organic ,contaminants were detected, and no gross
quantities of heavy metals were found in this area.
using state monies, ECology's contractor, Dames & Moore,
became involved with the site in December 1984 with a site survey
and magnatometer survey designed to identify additional potential.
burial areas. Six potential drum burial locations were
identified, including five outside the E&E fenced area. After
plans and specifications were prepared by Dames and Moore for
drum and contaminated soil removal, Initial Remedial Measure
(IRK) work was initiated in June 1985 by Riedel Environmental
Se rv ices, Inc..
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No subsurface drums were found outside the fenced area
during the IRM. The five potential drum burial locations were
found to generally contain metal debris at or just under the
surface. Exploratory digging was also performed where paint chip-
looking materials were found. These waste materials were present
. at widely scattered locations from 0 to 6 .inches below the ground
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surface.
Twenty exploratory pits were dug inside the fenced area. In
total, five crushed drums and parts of additional drums were
unearthed and 40 cubic yards of vlsibly contaminated soil
collected. Subsequent analysis demonstrated that none of the
material was classifiable as a RCRA hazardous waste by the EP
toxicity procedure. All drums, contaminated soils, waste
materials and decontamination waters were disposed of off-site at
the CSSIhazardous waste landfill at Arlington, Oregon.
As lead agency for the site, Ecology's Remedial
Investigation (RI) was performed by Dames & Moore and was
designed to: 1) characterized the nature and extent of the
contamination present, and 2) provide a data base sufficient for
the evaluation of r~medial alte~natives. The RI was begun in
December 1985 and was completed in July 1986.
Current ~ Status
The recent environmental sampling and chemical analysis
program shows no significant or extensive contamination of
surface soils, surface water, or groundwater at the site. While
several priority pollutants have been detected in the RI sampling
and analysis program, the concentration of such .contamination is
'very small and in most cases could not be reliably differentiated
from background values or laboratory-introduced.yariability. In,
fAct most of the potentially waste related indicator constituents
that have been detected have not been consistently detected over
repeated sampling events at the site.
Wastes
Pre-RI chemical data for drum/waste samples and adjacent
soil samples show that, the drum cleaning and disposal activities
at the Toftdahl site did introduce some contaminants at the site.
Priority pollutants which had been detected at least 1 time in
the drum/waste or nearby soil samples were used as indicator
constituents in the RI. (See Table 1.) The indicator constituents.
include metals, volatile organic compounds, base/neutral organic
compounds, cyanides, and PCBs. .
As waste characterization was based sOlely on chemical
analysis of samples collect at the site, rather than on certain
kn~wledge of the source or nature of the drummed materials, it is
possible that other organic compounds found during the RI and
earlier ~ampling may have been waste r~lated. Available
information on the source of drums found at the Toftdahl site
indicates that they came from a plywood manufacturing plant. The
chemical profile shown by the waste analyses is consistent with
paint sludge wastes. Many plywood operations use paints for
marking the edges of. ply~ood sheets to indicate type and grade.
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The concentration of contaminants in the laboratory analyses
of the wastes and soils collected from the site near these wastes
showed that they wer,e not RCRA hazardous wastes nor Ecology
,dangerous wastes using both the EP toxicity test and the Ecology
bioassay test.
, Some, white cake-like material similar to that found ,in and
near drums on the site is still visible at several scattered
locations on the site. These materials look like paint chips.
The Ecology 'project manager has described the density of these
.paint chips. as about what would land on a ne~gh~or's lawn if
one's house had been scraped. As noted above, none of these
materials are RCRA hazardous wastes. "
Soils
After the IRM was completed, RI samples from the top foot
of soil were taken from the suspected drum cleaning area, the
alleged initial drum burial area, the final drum burial area, and
a designated background area. Ecology had earlier taken samples
from the alleged'drum cleaning area. Tables 2, 3 and 4 summarize
the results.
. These tablesshoy'no ~~gnificant inorganic contamination in
the' soil; The, only significarit concentrations of organic
compounds are non-priority pOllutant, tentatively identified
compounds at the several thousand parts per billion (ppb) levels.
These appear to be primarily hydrocarbons and are probably,
related to traffic on the dir~ road rather ~han tD site
contamination' from drum disposal activities., A few common
solvent and phthalate organic compounds were detected at low ppb
concentrations. The EP toxicity test results show that none of
the soils could be classified as hazardous waste by that test.
Surface Water
Analysis of water samples from Toftdahl Creek identified'
contaminants which are consistent with minor contamination from"
surface runoff, distinguishing such minor effects from normal
variability between sites, geochemical influences and laboratory
and sampling errors cannot be done with assurance. Morgan Creek
does not appear to have received contaminants from the site.
The upstream Morgan Creek sampling location had the highest
zinc concentration, and had marginally higher concentra~ions of
the other' inorganic parameters and phenols than the downstream
Morgan Creek sampling location.
For inorganic waste constituents other than zinc, Toftdahl
, Creek has ,generally ~ad higher maximum concentrations than Morgan
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Creek. Assuming a hardness of 50 mg/l, three of these inorganics
exceeded the freshwater aquatic ambient water quality criteria:
cadmium with a maximum concentration of 3 ppb, though cadmium was
not' even detected in' 5 out of the 7 sampl ing events at Toftdahl
Creek, lead with a maximum concentration of 23 ppb, though lead
was not detected in 4 sampling events, and copper with a maximum
concentration of 20 ppb, though copper was also not detected in 4
sampling events ~t Toftdahl Creek. Again assuming a hardness of
50 mg/l, water quality criteria for aquatic organisms for
cadmium, lead, and copper. are as follow: cadmium, 2 ppb for both
long and short term1 lead, 25 ppb short term and 1.0 long term1
copper 6.4 ppb short term and 5.8 ppb long term. 'Only copper at
5 ppb was found in samples collected in 1986 at the location
downstream of the site. '
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The generally higher . maximum concentrations of potentially
waste-related inorganic constituents at Toftdahl Creek sampling
locations may reflect the unpaired comparisons over time, as
Morgan Creek. was not sampled on the same dates as those maximums.
They may ~lso reflect some natural geochemical or soils
differences. If they do reflect movement of Toftdahl site
contaminants by ground- or surface water, the magnitude of the
effect is quite small.
A total. of 14 organic 'compounds has been detected in
Toftdahl Creek. .'. How~ver,. only four ors!!nic compounds' have been
detected on more than one sampling event, and of these, only two
phthalates have been reported at more than 1 ppb. Both 'of .these
phthalates were found in blanks during at least one round of
sampling. The two latest rounds of surface water samples have
shown no detectable organic compounds in Toftdahl Creek.' Again
the lack of persistence over time may indicate that most reported
results are anomalies of sampling or laboratory procedures. This
conclusion is also supported by the generally low concentrations
of 'these compounds reported. No organics other than phenol were
detected in any of the Morgan Creek samples.
'The areas ~f alleged drum cleaning and drum burial have very
slight topographic slopes and are moderately to well vegetated..
These influences tend to restrict surface runoff. However, the
soils present at the. site hav. a moderate to high runoff
potential due to a reddish brown clay which is present near the
surface throughout much of the site. This clay has a vertical
permeability of 6.5 x 10-7 cm/sec, which impedes the downward
movement of water. .
Geology and Hydrogeology
A complex sequence of discontinuous sediments, sedimentary
rocks and volcanics underlies the site. Extensive' weathering
and/or hydrothermal alternation has altered all but a few of the
0~1ginaldeposi~~.t~.~lays and silts~ Generally, groundwater
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occur!il in the coarser stratified sand, gr.avel and clayey gravel
zones at various depths. These water-bearing zones occur between
thicker sequences of clay and silt.
During construction of the five shallow RI monitoring wells,
groundwater was encountered at very variable depths ranging from
6 to 33 feet below ground surface. It was not possible to
evaluate the hydraulic connection between the shallow saturated
z~nes, and thus, the potential shallo~ contaminant migration
pathways. It is likely that groundwater occurrences in some of
the thin shallow saturated zones is seasonally dependent, as some
of the shallow monitoring wells dried up during ~he RI study
period. ' . '
Deeper groundwater was encountered at approximately 95' feet
and 70'feet below the surface in the two deep monitoring wells.
This aquifer is a confined aquifer as the water levels in the
deep borings rose to approximately 50 feet below ground level
after the w~ter bearing zone was penetrated. Measured
groundwatet elevations in the deep monitoring and private wells
indicate that the hydraulic gradient of the confined aquifer
ranges from 0.05 to 0.009, sloping generally ,to the, south.
'However, as the deeper water bearing strata is discontinuous,
there is some uncertainty regarding the hydraulic communication
between these units.
. 'Groundwater'
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Private wells surrounding the Toftdahl site were sampled on
nine occasions. A total of 10 residences have been sampled at
leasi once, with one of the 10 served by a'water supplier, rather
than by a pr ivate well. These pr ivate wells include both
upgradient and downgradient directions with respect to
groundwater flow from, the site. Five shallow monitoring wells
and 2 deep monitoring wells were constructed as part of the RI.
The shallow monitoring wells were all constructed in areas
thought to be downgradient of the site's waste activity areas.
All private wells are deep.
Tables 5 and 6 summarize the groundwater chemistry data. It
should be noted that while private and RI monitoring well results
are displayed separately in these table, upgradient and
downgradient well results have not been separated.
, Shallow groundwater (which has been sampled only from nearby
new monitoring wells, as all domestic wells are deep) appears to
have higher concentrations for many pa~ameters than were measured
in deeper groundwater samples. The potential for pathways
between the relatively less pure shallow groundwate~ and the
deeper groundwater could not be established on the basis of
existing data.
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A total of 22 organic priority pollutant compounds (plus
other tentatively identified compounds) have been detected in
. groundwater. They have not, however, been persistent and are
typicallY at very low ppb concentrations. Of these 22 organics,
nine had been found in the waste constituents. Also, of these
22, only five compounds out of 22 have been detected in more than
one sampling. Less than half of the organics have been
quantified at levels of 1 ppb or higher, and only two at 5 ppb or
higher. These two - bis{2~ethyl .hexyl) phthalate and methylene
chloride - are both waste indicator constituents, but are also
common compounds that are sometimes seen in the blank quality
control samples. Also, of these 22, 13 have been found in
private wells that are upgradient of the site and are unlikely to
be related to the Toftdahl site by any potential surface or
ground-water contaminant pathway. The RI'S conclusion is that at
least part of the data set is an artifact (lab or sampling
problem) or the contamination is from an ~ndependent source. For
example, the one residence that is connected to a water supplier
had three organic compounds detected, 'all on one sampling round.
No organics appeared in any other sampling rounds at that
residence.
Compared to the regional background values, the maximum
ground-water concentrations of the metals at and near the
Toftdahl site are almost uniformly higher. This may reflect, in
.part, the small number of samples ,included in the regional
'back.ground. 'd.ata s.et for some pa~amet.ers. For example, while
aluminum is a possible constituent of paint sludge wastes, it's
presence in the drums handled at the Toftdahl site has not been
well documented. Hydrothermal alternations of soils and.rocks
may contribute to higher local levels. The private well~ have
shown higher maximum concentrations of copper and zinc" which is
probably related to their design and construction. For other
metals, the concentrations are higher in the shallow monitoring
wells than in either 'the deep monitoring and private wells.
However, Table 7 demonstrated that there are no significant
violations of drinking water standards in any well for the
inorganic waste indicator constituents.
Summary
It is likely that at least a substantial portion of the
surface and groundwater sampling results is an artifact of the
sampling and analytical program or reflects a source of
contaminants not related to the drum cleaning and disposal
operation at the Toftdahl site. However, the data is
insuffi(~ient to entirely eliminate the possibility that one or
more contaminants related ~o waste materi~ls is still present at
the site. Whether related or not, the magnitude of the
contamination is extremely small and does not exceed any
applicable or relevant and appropriate Federal public health or
environmental standard and does not appear to be a potential
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source for public health risks. There is no information to
determine what levels of contamination existed at the site prior
to 1983. .
Enforcement.
No enforcement actions have been taken and none are
currently underway. The ownership of the site is in dispute
between Kr. Toftdah1and the Davis's. A determination on whether
to recover Federal and State past costs will be made at a later
time. .
~munitv Relations
Local interest in the site and media coverage of activities
has been 1 ight and sporadic. Ecology held one public meeting in
December 1983 to discuss the test results and possible cleanup
actions. Community relations have also consisted of fact sheets
and direct communications advising residents when there will be
well and water samp1 ing as well as investiga"tion and cleanup
activities. Nearby residents have requested and received copies
of maps and reports on the test results on wells and streams neat
the site. The residents' concerns include impacts on property
owners who are trying to sell their homes.
Alternative Evaluation
A number of preliminary remedial technologies were "listed in
the RI as maybe being appropriate for consideration as additions
to the actions which have already been taken at the site. These
" include control of any possible contaminant release by removing
any remaining surface waste material and contaminated soil or
surface sealing, control of any possible contaminant migration by
grading or revegetating bare areas, and monitoring surface and
groundwater.
The site currently poses no health hazard to the public.
This is because the level of contamination at the site is very
low. Testing and analysis show that previous actions have
effectively eliminated any threats to the public health, welfare;
and the environment. Therefore a Feasibility study will not be
performed at this time.
Recommended Alternative
According to section 300.68(i)(1) of the National Oil and
Hazardous Substances Pollution Contingency Plan, the appropriate
extent of remedy is that cost-effectiv& remedial alternative that
effectively mitigates and minimizes threats to and provides
adequate protection of public health and welfare and the
environment.
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The recommended alternative is that no further Superfund
remedial action is necessary. Previous Ecology actions have
removed drums and any significant quantities of wastes from the
site. More than two years of groundwater monitoring have
demonstrated that there is currently no threat from the Toftdahl
. drum site to drinking water quality at the 'nearby residences.
Similarly, there are currently no threats to surface waters from
the Toftdahl drum ,site.
For additional verification, Ecology intends to continue
performance monitoring by sampling and analyzing nearby private
residential and monitoring wells semi-annually for five years,
and then annually for ten additional years, subject ,to funding by
the legislature of the State of Washington. EPA concurs with
this precautionary measure. If significant contamination is ever
found in these wells, the no further action decision could be
reconsidered.
The no further action alternative is consistent with other
env i ronmental laws. No RCRA hazardous wastes nor Ecology
dangerous wastes are present at the site. Federal drinking water
standards are met at the downgradient private wells for all waste
indicator constituents. No substances regulated by TSCA have
been found at the site.
This site may ,be recommended for de~etion from the National
,Priorities ~ist, as it nQ longer presents a significant threat to
public health or the.' environment. .
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LEGEND
- !fE..eE ON AI'f'III08.
- ~,.,...
_u
Sca.. In F...
~ ,."wl." L8II
-- . - RIIC8
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---- .......
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Surface Soil Sample Location M
-------
~
.,
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"
TABLE 1
WASTE MATERIAL INDICATOR PARAMETERS (a)
Or9anics
Bis(2-ethyl hexyl)phthalate
Di-n-butyl phthalate
Di-n~octyl phthalate
Benzyl butyl phthalate
Napthalene
phenanthrene
Fluorene
PCB 1254
PCB 1560
Toluene
Ethyl benzene
Methylene chloride
Tetrachloroethane
Benzene
Acetone
2-Butanone (MEK)
4-Methyl-2-pentanone
a-Xylene (1,2~dimethyl benzene)
Inorqanics
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Zinc
Cyanide
Concentration Range
b
b
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o'
o
o
5
o
o
25
o
in Wastes
(ppm)
400
91
15
12
7.1
.41
.18
.41
- .61
- 44000'
- 5500 ,
.453
.4
SOM
2.2
.42M
1.7
.16M
l8'.~
3.1
li9
590
- 1000
115.1
- 4430
16.3
(a) Includes (I) those organic compounds that were specifically
identified and for which quality control sample blank ,results
were below detection limits, and (2) those inorganics for whi~h
sample results were above soil background values. The list o~
inorganic indicator parameters includes three that are only
marginally above background values (arsenic, cadmium, and
chromium) and is thus conservative. It is possible that the
waste contains forms of these chemicals (or others) that are more
mobile than normal background soils1 EP toxicity testing of
wastes, however, shows detectable leachate values only f~r
chromium (0.14 ppm.)
M designates an estimated value.
1 on the mercury value indicates that, spectral interference
prevented confirmation. The highest value unaffected by
interference is 19.4.
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-------
Table 2
$UIIMR' OF SOILS NIAL TS£S
INORGANICS '~R~~TER5
(in ,pI. d'1 ~19h\ bOlil)
VIII£ SoH So.Un, DoIIi I 11001'1 Soil SOICIlin,
~19114 U6116
--
MO.rs LIEA nOIf 110. rs LOCATIOH
SMPLES 2M OF!lAI SNlPI.£S 211. If MX
PMNlTEII ANN. ,SO lIin1l111 lIoxi.1 lto.i.1 CIItCDITMTlOM(.) MIlum lIinilul "'-i.1 lIo.i... CQIIC£MTRATIOII(')
ALImIIUI 0 - (c) , 27,200 (d 49.700 (e) 45,000 (I) 5-'
MIT I IIOIf'f (II) 4 IIDW II II , .. III lID
M5D1IC 4 0.1 1.:1 0.:1 2-1 , 3 Cd 5 CI) 4 Co) 5-'
WIIit 0 - 6 61 132 122 5..
IERTt.LIUII 4 0.29 0.48 0.38 2-1 ' lID . liD
CADIIIIM 4 0.02 0.05 0.03 1-' , . III .. -
CALCIIJI 0 , 468 . 1~3O t41 H
CHRc..1 III 4 7.5 21.4 13.4 2-D , . 12 22 21 S-S
COBALT 0 , 8.4 34 25 5-S
CIMII 4 22. 49 41 H ' 14 30 17 S-S
. IR1* 0 ., . 1',200 40,800. 37 ,500 5-S
Lid 4 ' 12 I. 1-5i2-1 6 IJ 17 .15 . 1-4
MGIlESIIM . 0 6 71S t.l40 1,010 5-5
MNGNlES[ 0 6 704 2,270 1.820 5-S
II[RCUrf 4 0.012 0.082 0.066 2-1 ' liD I) lID
IIICm 4 20 40 29 2-D 6 . 17 II 5-S
POTASSIIM 0 6 444 2.210 'M 5-4
!lLEllIII 4 .1CD 0.$ . 2-D 6 lID III lID
SILVER 4 0.01 0.03 0.02 2-5 ' liD lID lID
SODIIit 0 6 to 1~0 119 S-S
THM.L lID! 4 liD 0.1 O.t I-D;~-s.D , liD lID lID
TIll 0 - 6 lID 18 15 5-]
~IIADIIJI 0 , 49 110 104 5-5
Wit 4 37 57 42 2'" 6 TlCo) 71 Co) 64 (0) 5..
CTANIII 0 , liD lID IfI
Co) Th'II ',lUl\1 01'1 '1099" 01 'I\ill\ll. 1101" on \hl GAiDC "vi.w 0' \h. '0\4 SI\ b1 [col091 ond Environllft\, Inc.
C" nit rtlUlh ,., ...\iIOll1 ~'I rt';K\td 111 \h. [col091 GIld Elvil'Olllfll\, I.e. CWQC 'tYitll du. to 1l1li OfthlDll1 spilt 'KOIIt,i".
Cc) - 'tftO\" *~ UIt ,orun., III.... WOI no\ \lIt" '0' ill \hi I 11\ of onebl".
CI) lID 'IIIOtft \h\ \M OI"nii '0' \IIil ,oruI\I, .1 '1"0"" lIu\ \IIe\ i\ .. 10\ ,.\leWd (0\ e ..fial' 1-' lili\ 01
..\.(\illl).
(,) JoUl "'Ill.. (0-12') u4 '''' (o",ai.hlJ A') ...,1,. ..,. .tlinllll - cDa,OIi\td I,. \110 IO.,Ii", lreol. 5i. li\l. w.,.
1O.,ltd .... COIIIOli\" 'rOI or" 1 Co11'9td d,UI cl1Onin9 or") III' \hrtt li\" WI', 101111" oaf co"oli\l' ,,. or.. 2
(111".(\.. initiol 'rlil bu,io1 I'"). Ste Fi,urt 4-4 "'. 4-5. Thl '"i,notionl 1/1.. 10891. loco\ia el. ..."'; '0' ')108,11'
1-1 ind_co\.1 "'. Iholiow co"oli\" 1...1. in 0,.. 1.
CI) All 'urfoc. soq I0ICI1" WI" oII\oin.' "01 0.'" I (11119" 'N c1.Ofti", 0"0). s.. Fi9u,. 4-4.014 4-5).
..
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~-34'
I I
\., \ 1\ i
\
I
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, I
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. .
:. ," .
.~. . .'. ..
. ...
, .
-------
Table 3
SUMH~RY OF SOILS ~H~LYSES
ORGANIC COMPOUNDS,
(in, ppb, dry weight basis)
-----------------------------------------------------------------------------------
WDOE SOIL SAMPLING
5/9/84
No orqanic co.pounds detected
-----------------------------------------------~-----------------------------------
DAMES' HOORE SOIL S~"PLING
1/6186
-----------------------------------------------------------------------------------
CONSTITUENT
MAXIMUH-
CONCENTMTlON
NUHBER OF TIHES
IIETECTED IN 6
SAMPLES
LOCATION
OF MXIMUH
CONCENTRATION(C)
tetrachloroethen.' (0)
trichloroethene (a)
aethylen. chlorid. (a),(b)
acetone
total xylenes (0)
bis(2-ethylhexyl)'phthalate (a)
di-n-octyl phthalate (a)
other tentativelY identified
co.pounds:
5 J 5 S~4' 5-~
3 J 5 S-2
67 J 3 S-J
27 3 5-4
8 J 3 5-4;5-6
48 J 2 5-3
1~ J 1 S-J
nuaber per sa.ple
16 to
20
total conc.ntration per sa.ple, elti.ated
7,270
to
17,789
80xiaua concentration for on. co.pound
per saaple, .sti.ated
980 to
2,310
-----------------------------------
(a)
Reported values are e,ti.ates (01 indicQted .by J on lob reports).
(b)
"ethylene chloride wa..reported in the .ethod blank a\ 5 ppb. Two other
co.poundS were ~lso reported in the .ethod blank: fl~oranthen. at 33 ppb
and pyr.n. at 23 ppb.
, .. .
, (c)
~11 laaples were taken fro. the alleged drua cleaning area
, "
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.." . .
. ,
, , .
. :
" ,
. ~. :." .,".
." . ~. I .
. '.' .',
-------
Table 4 .
DAMES' MOORE SOIL SAMPLING
JANUt"IF.;Y 6.-8, 1 ':/86
SUMMARY OF EP TOXICITY TEST RESULTS
PARAMETER
----------------------------------------------------------------------~---
NUMBER OF
TIMES
QUANTIFIED
IN 42
PlNPlL YSE5 (.~)
MPIXIMUM
(IJtK E N-H,A T ION
( 11 g / 1 ) .
LOCATION
OF
MAXIMUM
LOCATION (c)
Of-;INKING
WATER
S T ArJtlAf\1)
. ( I) g / 1 )
PlF:S£:N I C
Br'\R.I UM
CADMIUM
CW:':OMIUM
LEAtl
MERCURY
SEl.ENIUM
~.IL',.'ER
o
37
3
4
1
o
o
o
~W(b)
288
7.8
12
18
~m
tW
t-W
5-12
5-36
5-31
5-14
~o
1,000
10
50
50
2
10
~,o
----~--~---~-------
( .)
Inclyding four duplicate anal~ses.
ND denot~s the analyses were p~rformed and the parameter WQS not
detected in any of the EP toxicity tests (at a defined lower
linlit of detection).
(b)
.
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. .
"
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. . .
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. .
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Table 5
GRDUHI WATER SNflES
IIIItGMIC ~LTSES
( MTA SllVWtT: IWIIIIIt alHaMTMTIIINS iii 11911: "II)
Dun , Koort
EEJ - ... 11& V& ~III" 1986
pMAI£TD 8I4/G 1119/83 ZII/14 7/23184 11/15/84 rRIVA 1£ II» 1111
PRIVATE PRIVATE rRIVATE PRIVATE PRIVATE ElLS IEUS E.LS
IlEU.S IlEU.S 1lELL5'.) 1lEU.5 (,) IlEUS SMU.OIU n DEEP(9)
-...... - ---
dIU - (.) 29 15,500 83:5
MlTIJOIT . ell) 1 Nt . "
ARSOIC D 11 ' 6 3 1 ID .. .
IMIIII -, . 2 81 JCII) 10 J
IIItTU.JII D .. II D 1 . I,
.... .. II "
WlDIII 0 1 '.2 1.6 4 lID III .
allllUIII C c) 7 . III 23 6 181 ZI ID
CDIILT IID~ , .
comI 71 130 167 :" 129 115 25 4
JJDI 1010 770 113 (124)(.) 28,230 (45,460)(') 1,038
WI 24 6 60 7 8 ... 12J 'ID
IWI6MESIE '17 73 12 (12)(') 11$ (240)(') 26
IEJIDIrf . II ..06 '.21 ..54 III 0,2 J .
lOem D III ID 64 30 ID 21 .
SELOIIIII .. 1 1 4 3 ... . .
IlL IJD .. II - II .. .
nw.LI\I . 1 - .. . li
t" om - 'ID " .
WtlMDIIII . - 6,3 37,7 2
ZlIlC 83 m 6340 2S2 1774 402 45 6
CTAlIII . . 4 .. NI . lID
CM.C1111 11,040 6,234 J ',327 J
fWiNES1111 - 3,630 ' 3,140 J 3,148 J
SOD1\11 6,535 <10,500) W 7,6IfI J 10,500 J
POT ASSIUII ND 1,523 MD
lINER II' SNIUS 3 6 , 6 6 4 1 2
"
CI) - '"oi.n \118\ 10 whlil 'or Ut '11'UI\lr .... 1181 ,'''0l'81li,
'II) lID dlllcMI tlltt en "'Il"il 1181 "r'o'lfII 'or VI. pI,..\I, I"M lIut \II.t 110 dtt«talll, fjutitll1l1trt rtpo,w. ,.t . .ifill'"
IMr I111t of .t\tcUaa),
CC) llnevel.t orcaiu 181 tII~ . 0111, 8. .,li., rauU .d GIll, 0\ \II". 111.11. lIIIi\orll1' .111 111\811111 II, 11111 , Iloo".
Tht IIIIIVd.t'o..laa -bill ." ''''0''" II, 1 .1If....t 10lio1'0\0" \hn ,,"0l'81li VI, totel cll,.i. _1"", TII. 1811 '
, .11" l1li10 tnlvell1t dlai. 101 ,.. 101 1185-2A, ,*lclI ...1 .110 ''',,'lin" \0 II. or'Kted h 'POIt c8\oi..\ion III'
tIIt"'o" 1111\ tlcl..- 11 \lit dt" -",
W TIlt vel,.. .... 1. ,.,"'WtII I,. \M 1Ui- 1,., ",.";1, .. 1od1..1 "lu" I'IpOrted ,.. ..,....tt ...\1,
...l1t,/.\lr CC8\ainIU. GIll"" ""0'" ., Ut. EN P;~.:ICbn\lr"", T1Itw cC8I\itu\l "'1,,\1, .Uco\l ..bill 'or
tlltll ,lnIIt.In, '
(II) TII. AIIdt,. .\lr ..,h 11 inc1l1dld i. UlIIt dl\ol tIId tIIi""c. 11 '14141&111 . \0 I loed ...\1, "'- l1li011 IOUre' 11 .t I0Il
'11\8. ,... \II, ToNol litt III' 11 .0\ po\IIUllh "'Kted II, .., To,\40111 lit. Con\uiIllUC8,
. .
, \;,. ',~' . ~'), 1"'I~o\l1 sIIlll,!" ~1~~: ~ (dote 'or 118S-1A III' 1185-2A d.l.i.td II I ....It 41' ,rout caa\o!liIlO\iCIJ),
." ... . ...' .. :.. ,,".\'... .'. . ... '.."" .'.. t. .'. 4. .. . I . .
,. (,) Indico\n ."".11': 18'5-18, 1IB5-28. . .
. .. ... . I.. I
.1 .. , . . . . . . . '. ." ! ~
, , (II) J 1IIIiutli UIot \lit 011OC1I\II _,icd ~1. 11 on IIU.t" qt.nib ilK lUll qMlllit, control cri\l,io ..." 10\ .,.
-------
(
Table 5 (Continued)
GROUND ,",TER SMP\.£S
INIItG~NIC ~LTSES
DATA StlWiY: MXIIUt CONCtHTMTIONS Un 1,19/1: ppb)
. '
Do..1 , Moare
,.rU 1986
PARMETER PRIVATE 10 lIE.. MPlLL PHWtETIR
WELLS WELLS IIEU.S IlAXIIUI
S1W.L1N(f) , mCt)
filmIIUt 61 21," 2,045, 21,630 Al
MTIIOf'f lID III 0' 3 Sb
MSDIC lID ID lID 13 AI
BMIIIt 2 17J 20 J 81 IG
BOYLLl'" 0.1 0.7 lID 0.7 "
BOR01I lID d . .
CAMIIIt 1m 1m lID 4 Cd,
Dl'OftI'" (c) 2 37 6 't1 c,
COBAlT 1m 12 lID' 12 Co
afP£R ,71 33' 3 167 Cu
IRCIt 2,088 n,775)(1) 't1,ooo C25,220)C~) 3,318 45,460 ' Ft .
LEAD 30 21 MD 60 Ptt
IWfGH£SE 9 C12Hd) m (135)W 58 240 ""
tOC\ItY NO 3.4 NO 3.4 Ht
NICKa lID 20, MD 64 Ii
saDI'" NO NO ND 4 si
SILVER lID 3.3 2.2 3.3 Aq
TMLLIlit NO NO NO lID 11
TIN lID lID NO ND Sn
WtlW)IUIt 6.7 51.4 9.8 51.4 V
ZINC 427 56J 8 J 6340 In
CT~NlDE NO IfD NO 4 Cn
;; CM.CI'" 11,360 12,270 12,270 12,270 C4
MGNESllIt 3,717 2,004 J 3,717 J 3,717 ",
SODI'" 6,762 (8,900)(d) 2,295 J 12,910 J 12,910 IIa
POT MSll1t NO 1,434 J 2,823 J 2,823 K
IUtIO If SNlUS 4 1 2 44
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Table 6
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ow 1_111
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7 Jltl
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-,
let ... c..... e.. e'.. .. .. .." c..U\alii U., elM ...1. 1-21.
C.. all8 ,... tI. ..... ..hz" .. tIIil ro-' .. ....U...
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e.1 1M ..I. .. ,.,.\IInn II \lie ..... of "".,., .""." ...U".. I""." ....,... C.. ..ll1ell..n, ., .. .,.... ..eU_I.
en ... c...'nU. .... iI UII ..i- '0' .., liltll \18""." ,..U"" c"'-', all........,..w.. flU8II8s. .. ,...tllft" il \0"1
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ph",..Ulrtn' (c) ,
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chnHIII
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rlUOrGII\ll"'.
blftzo(b,k)fluotQn\llfftl
~IfIZO (e)Qft\ll I'GCtn'
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tIft\tth.ly id",tifiM cDIPaundl .(f)
di-n-butyl phUlQIQW (c)
1,3~i..u.y1 b"'UI' (c)
phllol
Qc.noph\htn. ,
btnzyl butyl phUlaltw (c)
b"'ttn'
1,1,I-trichlorDlUlQnl (c)
1,I-dichlorOlUltn'
.thylchlorid.
I.thyl",. chloridl (c)
benzoic Qcid
aldrin
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Table 6 (Continued)
GROOHI WATER SMPlE5 .
IRWtIC MW.. 15£5
MXIItU" COIUNTRATIOHS
(iD u9/1 : ppb)
"" Willi
SlIt 11011
. '"
,.,11 1986
.... ..,111
Dtttt
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Privew "'111 in !laIWI (b)
(in Ut/k9 : pp')
26
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2.12
3.85
14 J (2H.)' .. 9 '(1H,)
0.79
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15,000
410
610
to
91,000 .
160 M
1.200
200
453
-------
TABLE 7
GROUNDWATER INORGANIC CONCENTRATIONS VS. DRINKING WATER STANDARDS
Inorganic Existing Maxmimum Concentration
Waste Drinking Detected (ppb)
Indicator Water . pr ivate Deep Shallow
~ Constituent Standard Wells Monitoring
_l12RQL ---- __---Hells
Arsenic 50 (a) 13 ND ND
Cadniium 10 (a) 4 ND ND
Chromium 50(a) 23 6 37
Lead 50 (a) 60(c) ND 21
~ercury 2(a) .54 ND 3.4(e)
Zinc 5000(b) 6340(d) 8J 56J
Cyanide 200(b) 4 ND ND
ND-
Not detec~ed, with a defined lower level of detection.
J
Estimated concentration.
(a) - These standards are from the current National Interim
Primary Drinking Water Regulation.
(b) . These standards are from the Ambient Water Quality Criteria
for Human Health.
(c)
is 30.
The next highest concentration for lead in a private well
(d)
is
The next highest concentration for zinc in a private. well
1724.
..
(e) The next highest concentra~ion for mercury in a shallow
Thonitoring well is .2J.
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September 24, 1986
Responsiveness Summary
Toftdah1 Drums Superfund Site
..
On August 19, 1986, the Washington Department of Ecology (Ecology)
began a public cOlllllent period on the "Final Report Remedial Investigation,
for the Toftdahl Drum SiteK dated July 17, 1986, and prepared by Dames and
Moore; and on EPA.s draft Record of Decision, dated August 8, 1986.
'Ecology's activities during this public comment period included release of a
fact sheet and a press release,: letters to residents near the Toftdahl site,
and placing copies of the above documents in a nearby information repository
and in the local ,health department office. The public cOlllllent period was,
scheduled to close on September 10, 1986; however, at the request of one of
the commenters, coments were accepted until September 19.
One letter and one phone comment were received. The phone comment was
from Jim Davis. The Davises used to live at the Toftdah1 site. Mr. Davis
was concerned about whether Mrs. Davis.s health problems were caused by the
contamination at the site. Mr. Grant submitted written comments (copy
attached). Mr. Grant is an attorney for the Davises. His primary concern
is about the condition of the property prior to 19Sa and the health hazards
'which may have exhte~at the site pri~r ~o EPA and Ecology actions.
"In response to'these comments, the Record of Decision has'more fully
summarized the Washington Department of Social and Health Services. 1983
concerns about the site. Also, the Record of Decision has been revised to
, clearly state that neither EPA nor Ecology have any information from ~hich
to evaluate the potential health risks associated with the site prior to
1983. None of the comments affect the remedy selection.
'". .
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QIfP(hlf
ST-\TE OF wASHINGT(')!'oI
DE? ART,V1ENT OF ECOLOGY
,\r.J Slop P\!.l1 . 01~'mpi.. W.Jsni"8Ion 98S().I-8:"11.. (~("'J ~S~-6r()()
~,:.
, TOFTDAHL DRUM SITE. BRUSH PRAIRIE, CLARK COU~TY
..
August 1986
~~AT CAUSED THE PROBLEM AT THE TOFTDAHL DRUM SITE?
About 1970, Mr.Toftda~l allegedly drained or buried up to 200 drums of
paint, glues, and rel~ted chemicals on his property at 22033 N.E. 189th
Street, Brush Prairie~ The illegally disposed drums vere probably ~rom a
plywood manufacturing' plane. ' Analysis shoved that some of the contaminants
vere similar to paint sludge vaste.
--
The Ecology Department became avare of the site in early 1982 and began to
test soil and vater for contamination. In late 1982 the landowner removed
most of the drums and transported them to a landfill.
~~AT PROBLEMS DID THESE DRUMS CAUSE?
Tests of soils, and, ground and surface water in the area occasionally
revealed the presen~e,of metals~ volatile organic compounds, other organic
compounds, cyanides and polychlorinated biphenyls" (PCB),. Hovever. theU
chemicals occurred at very lov levels and not all soil or ~ater sample
locations contained the chemicals consistently.
.
~~AT HAVE ECOLOGY A~D EPA DONE ABOUT THE CONTAMINATION AT THE SITE?-
Both Ecology and EPA have been involved vith the Toftdahl site. EPA
excavated, sampled and stored some crushed and rusted drums. then fenced
the drum burial area for' safety in 1983.. Because of the levels of
chemicals in these drums and the uncertainty of the degree of contamination
in soil and vater. Ecology nominated the site for the National Priority
List under the, Comprehensive Environmental Response. Compensation. and
Liability Act; the federal "Superfund" program. When EPA placed the site,
on the national priority list, it became eligible for federal "Superfund"
~oney. This enabled Ecology, under an agreement vith EPA. to do more tests
on soil and vater in the area.
In addition. Ecology has removed drums and soil, and disposed of the
contaminated materials in a hazardous vaste landfill approved under
Resource Conservation and Recovery Act requirements.
\,!HAT WERE THE STt.'DY RESULTS?
The study. called a Remedial !nvesti~ation. revealed
significant contamination. In addition. there vas
chemicals from, the ,drum~,~had moved off the property.
the site vas free of
n..s evidence that
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The pollutants present in soil and water on the site were at very low
levels. Moat were similar to the normal background levels for the
indiv,idual chemicals. In some cases. normal variability in the laboratory
results could explain the apparent presenc~ of chemical. .
. -
1S THERE NOW OR HAS THERE BEEN A HEALTH HAZARD FROM THE PRESENCE OF THESE
CH~ltCALS?
No. The levels of. pollutantS from the Toftdahl Drum site did not exceed
state and federal public health and environmental standards. In most cases
the levels of pollutants were similar to normal background' levels.
.
"''HAT 1S HAPPENING W1TH THE SITE RIGHT NOW?
.
The Ecology Department and the U. S . Environmental Protection Agency (EPA)
are recommending that there be nor further action to cleanup the Toftdahl
Drum site. However. Ecology intends to test nearb)' residential and
QoniLo:ing we.lls fur coctGmina~icn periodically. ,.
WHAT IS THE PROCESS FOR MAKING AND IMPLEM~TING THIS RECOMMENDATION?
Because the site is on the National Priority List. EPA must prepare a
Record of, Decision. which is a formal step in the cleanup process under
Superfund. EPA and Ecology ~re making drafts of the document available for
review during a three-week comment period.
. . '
After the comment period. E,cology' and, EPA ,will evaluate the coment.s. .
prepare a "responsiveness summary." then s81ect their final recommendation-.
The responsiveness summary. which provides decisionmakers with information
about the community's preference and concerns and agency responses to those
concerns. will be available when EPA announces their final decision-on the
site.
There will be no comment period for the final decision.
WHAT WILL HAPPEN IF ECOLOGY'S PERIODIC TESTING REVEALS CONTAMINATION?
.
Ecology and EPA will evaluate any test results, showing that pollutants are
present in residential and ,monitoring wells at higher levels than in
previouS stu~ies to see if additional testing or cleanup is needed.
WHERE CAN I REV1EW THE STUDY RESULTS AND THE DRAFT RECORD OF DECISION?
Review copies of the study results and the draft record of decision are
available at'the following locations:
Southwest Washington Health District. contact Gary Bickett, 696-8428
Hockinson Post Office' '
Department of Ecology, Rowesix Office. tacey' '.
WHO CAN I CONTACT FOR MORE INFORHAT!O~?
If you have ariy,questiO"[\'s about the study results, the, record of decision,
, . ' or the" site itself,. plea~e ,call or 'Jt'1te Phyllis BaGS, 206/459-6286, or
':.J~net \Rhodes 3,t 206/~"5')-:6501;Haz3rdous, Waste Cleanup. Program, Dept. of
". Ecology. Main Stop P.V-l.l. ,o~~pia, WA 9.8504.
-------
.' ,
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Sectel.1rf
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:-i.'-: S?ftL:\-'..-\ ';
C:....c.r","'II' :
STATE OF \\I,...sHh'GTO~
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
Ol)'mpi.. w..shington 985~
November 18, 1983
"
"
.
I
I
FROM:
John F. Spencer
Deputy Director
Department of Ecology
PV-ll
.
TO:
"
John A. Beare, M.D., M.P.H. ft
Director '
Division of Health ET-21
. .:- ..
.'
SUBJECT: HAZARDOUS WASTE SITE, IN CLARK COUNTY
As you know, both you'r staff and DSHS staff are dealing with the recently
discovered Toftdahl/Davis hazardous waste site in Clark County. The South-
west Regional Office of DOE has reacted in a most ~xpeditious manner to the
situation. 1 would like to thank your staff for providing us wjth the,
available water quality data. The DSHSDivision of Health has 'evaluated the
confirmed handwritten data from'the EPA Manchester Laboratory, as we11 as
follow-up heavy metal samples collected and analyzed by. DOE. The data on
hand does'not demonstrate an imnediate public health hazard with :-espect to
, drinking water quali'ty in private wells. tlone of the wells sa:npled' have
levels of contaminants which represent acute health hazards. The Division
,of Health does not recorrmend that any of the private wens be abandoned or
that any treatment to the drinking water be stipulated at this time.
, ' .
.
However. there is an obvious potential for contamination of inorganic sources
of drinking water. The soil and drum samples did have high levels of both
heavy metals, as well as various;'synthetic organic contaminants. DSHS wil1,
reevaluate the public health significance of new water quality data as it
becomes available. In addition, DSHS would like to review and comment 0"
future DOE testing and sampling strategies which are designed to define the
scope and significance of ground water and drinking water contamination. If
it is determined that alternative methods of supplyi~g drinking water to
affected 'parties is appropriate, then DSHS will assist in the identi~ication
and implementation of appropriate solutions,' ,
"
i
I
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Dr. Sam Mi lham should be contacted (753-6408)- if you or staff have questions
regarding health effects of drinking water contaminGtion or this recommendation.
Hazardous waste sites and all of the associated proble~ are new issues for
all of"us, the DOE~' DSHS.-'local health departments, the public, ,and water
:,'purveyors.. ,In:or,der.,to fa~ilita~e,:~ir.i,e~y.~n~ ~~~~,cpriate actions, DSHS
~ ' I " ' ' ' '" '
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John F. Spencer,
~ovember 18. 1983
~ age Two
..
staff are pre,paring standard procedures for DSHS involvement in hazardous
waste sites and i"cidents. The standard procedures will address DSliS
activities to determine the health significance of contaminated drinking
water and our role in determining the scope and significance of the contam-
ination. and in facilitating appropriate solutions to mitigate situations of
, unsafe drinking water. .' '
The department appreciates the opportunity to continue working with you and
your staff on this important area of progr~ coordination.
.
cc: Richard W. 8il1s, M.D. '
S~ Milham, H.O.
Ken'Merry
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DONALD w, MOOS
", Director
STATe OF WASHINCTO~
DEPARTMENT OF ECOLOGY
~i Stop PY.11 . Olympia, Washington 98504 . (206; 4S9-6cixJ
November 7, 1983
RECElvr:r'
. . '- LJ
NOV 8.1983
DEPARTMEN'"
SOUTHVIEsT R~GOF ECOlOGY
, .. IONAl OFFICE
TO:
1.ynda L. Brothers
Ron HOlcom~ .
Tofdahl Drum Site
FROM:
SUBJECT:
A coordination meeting regarding the Toftdahl Drum site (Clark County) was
held on Mond~y, October 31, 1983. 'Representatives from WDOE (Headquarters
and Southwest Regional Office), Department of Social and Health Services
(DSHS), and the Southwest Washington Health District (SWHD) were present.
EPA officials were'invited but did not attend. .
BACKGROUND
The meeting was held due to 'tMe ryature of pr~liminarytest results received
from EPA. T.he test results include drinking' water, surface water, soil; ar)d
drum samples. The preliminary findings indicate elevated levels 01 heavy metals-
cadmium, chromium, cooper, lead--~drinking water, surface water, soil, drums),
PCB's (drinking water, surfac~ water, soin, PNA's (drinking water, surlace
water), and phthalates (soil, drums). Test results covering volatiles hav~ not
been received from EP A.
RECENT ACTION
EPA notified DSHS of the test results and contacted the residence (one famiJy)
that has PCP's in their well water.
CURRENT ACTION
As a result of the meeting, the following persons were designated with lead
r esponsibili ties:
Eric Egbers, WDOf. -- Main Project Contact
BiU Liechty, DSH-: -- Health Contact
Ron Holcomb, WDOf. -.; Media Contact
Rick HaU, WDOf. -- Contracting
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In addition, SWHD agreed,to contact the other two residences that were affected.
Those contacts were to be made during the first week in November. ~
It was also decided to proceed in arranging for a contractor to remove the
drums from the site. A contractor could be selected and on site by November
28, 1983. ..'
PENDING ACTION
The department is currently waiting to receive the final test results from EP A.
Until we receive them, the department is not in a position to' tell the medial
public anything very specific other than "the preliminary test results indicate
there' may be a problem and as a precautionary measure, the three residences
nearest the site have been advised not to drink their well water." Also, an
"oUiciaJ" decision to utilize state funds to cleanup the site has not been made.
ANTICIP A TED ACTIONSI ACTIVITIES
The following actions/activities are underway or planned:
* WDOf and DSHS will.develop an expanded drinking water sampling
progra~ for other private wells in the. area.
* DSHS will look into alternative drinking water sources for affected
residents. .
. DSHS will assess several health cases that may be related to the site.
, .
. When the decision is made to remove the 'drums, the following ac~ons/acti';ities
will likely occur: .
. Local oUicials, legislators, Governor's Office should b~ notified and
briefed on the situation. '
* News release announcing the test results and actions planned to be
issued. '.
. Public meeting (~attle Ground) to explain the planned action.
* "Living room" briefing for affected residents.
.. Determine how remedial investigation will be conducted.
* Update local officials, stat'e officials, public, and news media throughout
the project.
SITE HISTORY
A ttached is a chronology.of events regarding the T ofdahl site.
RH:la
cc: Earl Tower
John Littler
Rick Hall
Frank M'onahan
'-Eric Egber~
Ats' Kiuchr
:".'
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TOFDAHL DRUM SITE, CLARK COUNTY
CHRONOLOGY OF EVENTS. .
NOVEMBER 1983
, .
. WDOE notified that during March 1982 an earthen dam breached on a creel<
.bordering the Toftdahl property. WDOE investigated for water quo!jty prob-
lems (silt, fish kills, etc.). A property owner adjacent to the Toftdahl property
(Don Gintner) told WDOE Held. personnel about buried drums on the Toftdah!
property.
. On March 23, 1982, WOOE conducted a Resource Damage Assessment relative
to the dam incident. Mike and Pam Davis, who were in the process of buying
the Toftdahl property, tool< WDOE personnel to drum burial site. Partially
buried drums were observed. .
. WDOf ( Egbers) wrote a letter on May 27, 1982, to Ellis Toftdahl requesting
information on the drums (how many, how were they bured, what were
the contents, what was the condition of the drums, did he have any disposal
permitS, or if untrue). A response was requested by June 11, 1982.
. Toftdahl telephoned WOOf on June 2, 1982, and said he did bury some "trash"
on hi.~ property. WDOE again requested a written response.
. No resp.onse. received by November so ancther letter was written a.sking
for a.n immediate response or the case would be .tu.rned o~er to ~PA. Cave
until December I', 1982 for response. No response by "that date. .
. WOOE contact~d EPA regarding the situation in January 1983.
. In March 1983, a Richard Edwards told WOOE that his kids would sign witness
statements stating that trucks came to the Toftdahl property. The trucks
allegedly had Leichner Landfill markings. Mr. Leichner claimed he. knew
nothing about drums being taken to this site.
. EPA again contacted by WOOE in March 1983.
. EPA requested the Rededial Action Field Investigation Team to investigate.
A "drive-by" investigation was conducted by Ecology 6c Environment in early'
March 1983.
. Later in March, a field inspection was conducted (metal detector, soil samples,
sudace water samples, and magnotometer).
. Also in March, a neighbor stated that in November of 1982 a truck and
bulldozer were on the Toftdahl property and removed some of 1:he barrels.
. Ecology 6c Environment reported on April 6, 1983' that a magnetic "anomaly"
in 1,600 square foot area indicated the presence of buried metal.
,''''~
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,
. John Meyer, EPA, called Toftdahf to ask permission to go on- site with a
backhoe. Toftdahl gave verbal permission to come on site but said they
wouldn't find anything because he removed the materials last winter. .
. On JuJy 20, 1983, Ecology &: Environment unc;overed six drums and prepared
them for sampling. E &: E a150 constructed a chain link fence around the
site. During the excavation, Eric Egbers handled. news media inquiries because
no EP A personnel were present. .
. On August 4, 1983, E &: E excavated three additional barrels and took soil,
drum, surface water and well water samples. WDOE again handled all media
inquiries as no EPA officials were present. Samples were sent to the EPA
lab in Manchester. ..
.
In September 1983, WDOE indicated to EPA that the .state wouJd like to
assume lead responsibility for the Toftdahl site. john Barich, EPA, was
quoted on September 21, 1983, in the Battle Cround ~eflector: "the state
agency (WDOE) had been determined to have adequate laws, regulations, .
and staff to manage toxic waste problems. ,The state will use federal test
results to pursue cJeanup and penalties, as necessary."
* On October 10, 1983, WDOE wrote to Toftdahl stating that the agency is
waiting for results from the sampling and again asked for information on
the drums. No response has been received to date.
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* . Pr~iimin~y lab results provided ~o WD~~ on Friday, October '28, 1983.
* Coordination meeting held on' Octob~r 31, 1983, involving WDOE, DSHS,
and Southwest Washington Health District.
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