United States
Environment^' Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-90/021
December 1989
SEPA
Superfund
Record of Decision
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.
50272.101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R10-90/021
3. Recipient's Acce../on No.
4. TlUe snd SubUUe
SUPERFUND RECORD OF DECISION
Teledyne Wah Chang, OR
First Remedial Action
5. Report Dste
12/28/89
6.
7. Author(s)
8. Perfonn/ng Orgsn/mUon Rept. No.
9. Perfonn/ng Orgs/nlzaUon Name snd Add..,..
10. ProjectlTa8klWork Unit No.
~
"
11. Contract(C) or Grant(G) No.
.
(C)
(G)
12. Sponsoring Organization Name and Addre..
13. Typa 01 Report & Period Covered
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
800/000
14.
15. Suppiementary Notes
16. Abstract (Limit: 200 worda)
The Teledyne Wah Chang (TWC) site, in Millersburg, Oregon, is an active plant used to
produce nonferrous metals and products. The site consists of a 110-acre plant site,
which contains the plant's former sludge ponds, and a 115-acre farm site, which contains
four active wastewater sludge ponds. Portions of the TWC site are within the Willamette
River's 100- and 500-year floodplain. The Wah Chang Corporation began operating a U.S.
~ureau of Mines zirconium metal sponge pilot plant under contract with the U.S. Atomic
'Energy Commission in 1956. Additional facilities were subsequently built near the plant
beginning in 1957 to produce nonferrous metals and products. The Lower River Solids
Pond (LRSP) and Schmidt Lake sludge pond, which stored wastewater generated from the
plant operations, are being addressed by this remedial action. The 3-acre LRSP received
sludge from TWC's onsite wastewater treatment plant from 1967 to 1979 and currently
holds approximately 75,000 cubic yards of sludge. Schmidt Lake covers 0.6 acre and
accepted approximately 10,000 cubic yards of sludge from 1974 to 1979. The sludge in
both the LRSP and Schmidt Lake contains heavy metals, organic compounds, and trace
levels of radionuclides. Because the ponds contain radioactive materials and are a
potential source of ground water contamination, TWC decided to clean up the ponds
without waiting for the full site remedial ~nvestigation to be completed. This interim
action addresses the contaminated sludge in the LRSP and (Continued on next page)
17. Document Anslysla L Deacrlptora
Record of Decision - Teledyne
First Remedial Action
Contaminated Medium: sludge
Key Contaminants: organics,
~~.;i.~~.Ended Terme
Wah Chang, OR
metals,
(chromium, lead, zirconium), radioactive
c. COSA TI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
21. No. 01 Pages
58
J
20. Security Cis.. (ThIs Page)
None
22. Price
(See ANSI.Z39.18)
See Inlltruclionll on Reve"",
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(Formerly NTIS-35)
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GPO: 1983 0 - 381-526 (8393)
OPTIONAL FORM 272 BACK
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16.
'Abstract (Continued)
I '
Teledyne Wah Chang, OR
PA/ROD/R10-90/021
chmidt Lake. Contaminated soil in the sludge ponds will be addressed as part of an
overall site remedy. The prima~y contaminants of concern affecting the sludge ponds are
organics; metals including chromium, zirconium, and lead; and radioactive materials.
The selecte~ remedial action for this site includes excavation of 85,000 cubic yards of
.sludge with partial solidification of the sludge, followed by offsite disposal in a
'permitted solid waste landfill. The estimated present worth cost for this remedial
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, . .
"
RECORD OF DECISION,
DECISION SUMMARY, AND
RESPONSIVENESS SUMMAR Y
FOR
INTERIM RESPONSE ACTION
TELEDYNE WAH CHANG ALBANY SUPERFUND SITE
OPERABLE UNIT #1 (SLUDGE PONDS UNIT)
ALBANY, OREGON
. DECEMBER 1989
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGrON 10
1200 SIXTH AVENUE
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~
RtCORD OF D[CISION
REMEDIAL ALT[RNATIV[ S[L[CTION
INTERIM RESPONS[ ACTION
TELEDYNt WAH CHANG ALBANY SUPERFUND SlTt
OPERABL[ UNIT #1
. ALBANY, OREGON
\
. I
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""-"''''.... ...- i\-"'- ""...\"
ktLUKU Ur U~Ll~lU~
;
INTERIM ACTION ~ELECTION (~LUDGE POND~ UNIi)
TELEDYNE WAH CHANG ALBANY
ALBANY; OREGON
Statement of Basis and Purpose
This decision document presents the selected remedial action for the
sludge pond unit at the Teledyne Hah Chang Albany (TWCA) site in Millersburg,
Oregon, just north of Albany, developed in accordance with CERCLA (42 U.S.C.
~9601), "as amended by SARA and, to the extent practicable, the National
Contingency Plan.
This decision is based on the administrative record for this site.
copy of the administrative record index is attached as Appendix C.
A
The state of Oregon has concurred in the selected remedy.
state's letter is attached as Appendix B.
A copy of the
Assessment of the Site
Actual or threatened releases of hazardous substances
not addressed by implementing the response action selected
" present an imminent and substantial endangerment to public
the environment.
from this site, if
in this ROD, may
health, welfare, or
Description of the Selected Remedy
" The sludge unit addressed by this ROD is the first operable unit to be
\ addressed at the THCA site. The Remedial Investigation/Feasibi lity Study
(RI/FS) for the unit did not include certain components of a normal RIfFS,
such as a complete baseline risk assessment, because these will be part of an
overall site RIfFS (currently in the RI stage with the FS scheduled for
completion in 1991). The sludge pond unit is being dealt with separately due
to the property owners', and the public's, wish for an expeditious cleanup of
the sludges, which may be contributing 'to groundwater contamination at the
site.
The remedy consists of:
o
Digging up and removing the sludge.
o
Partially solidifying the sludge with a solidification agent such as
Portland cement, to improve handling and reduce the gross mobility
of the solids. A treatment plant will be built for this pUI'pose.
o
Transporting the sludge mixture to a solid waste 1andfi 11 and
disposing of it offsite.
The wastes being addressed in rhis Interim Action are not hazardous
wastes as defined by the Resource Conservation and Recovery Act (RCRA);
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I;
Hh~n the o'.'eu,i1 site ;eCisi;:.iiitJ Study is c:,rnc.lete:J, ci'e ::1L1J'~e -:
remedy wi11 be i"e'/;e\./ej to as:;ure consistency '..Jit1 the o'/era' 1 ;"e:::ejja:
strategy for the TWCA site.
Declaration
This Interim Action is protective of human health and the environment,
complie~ with federal and state requirements that are applicable or relevant
and appropriate for this remedial action, and is cost-effective. This Interim
Action utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable. This action does
not constit~te the final. remedy for the site, but the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volum~ as a
principal element of the overall site remedy is addressed for this action and
will also be addressed for the final response action. Subsequent actions are
planned to address fully the principal threats posed by this site.
" " " 1/'" ,
d ' P -;--;. I (': ;r /
:l:-r:~w(, ~'\.l/;;;J'I..'--" ;/-'
Regional Administrator'
EPA Reg ion 10
" ,
/ .2- /j..t //'1
Date
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~
DECISION SUMMARY
INTERIM RESPONSE ACTION
TELEDYNE WAH CHANG ALBANY SUPERFUND SITE
OPERABLE UNIT #1
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Page
;
Detision Summary
Site Location and Description
Site History and Enforcement Activities
5
Highlights of Community Participation
Scope and Role of Operable Unit Within Site Strategy
11
Summary of Site Characteristics
12
. 13
Summary of Site Risks
14
Description of Alternatives
21
Summary of Comparative Analysis of Alternatives
25
The Selected Remedy
34
The Statutory Determinations
36
Appendices
A.
Responsiveness Summary
B.
C.
State Letter of Concurrence
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L l:. !~jt 11 ;;il,}:\:J
Paqe
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1..
2.
Location Map
Lower ~Iver Solids .Pond and Schmidt Lake
2
3
LIST OF TABLES
'1. Inorganic Contaminants In LRSP Sol ids 6
2. Inorganic Contaminants in 'Schml dt Lake Sol ids 7
3. Organic Contaminants in LRSP Sol ids 8
'.
. 4. Organic Contaminants In Schmidt Lake Solids 9
5. Cancer Potency 15
6. Risk Summary Table 18
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(TT; ~\I ,', \.1=
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"
Teledyne Wah Chang Albany (THCA), Albany, Oregon
.'
LOCATION AND D~SCRIPTION
;
The TWCA facility is located in Mi11ersburg, Oregon (about three miles
north of A1.bany) in the Wi11amette Valley (see Figure 1). The Superfund site
includes the 110 acre plant site property and the 115 acre facility known as
the "farm site", which has the plant's active wastewater treatment sludge
ponds ("farm ponds") and is located approximately 3/4 mi 1e north of the plant
site. Operable Unit #1, the unit addressed by this Interim Action, includes
the solids in the Lower River Solids Pond (LRSP) and Schmidt Lake, which are
" located on the plant site near the Hi11amette River and have not been used
since 1979.
Of the two major site areas, the plant site contains numerous buildings
and facilities including an extraction area south of Truax Creek, a
fabrication area north of Truax Creek, a solids storage area west of the
Burlington Northern Railroad, and a parking and recreation area east of the
Southern Pacific Railroad. The farm site contains four 2-1/2 acre solids
storage ponds. The remainder of the site is used primarily for agriculture.
The plant is currently operating and employs over 1300 people, making it the
largest employer in the Albany area.
The LRSP and Schmidt Lake lie in the western portion of the plant site,
next to the east bank of the Willamette River, between Murder Creek to the
north and Truax Creek to the south (see Figure 2). The LRSP covers just over
3 acres and holds approximately 75,000 cubic yards of sludge; Schmidt Lake
, covers roughly 0.6 acre and contains approximately 10,000 cubic yards of
~ material. The sludge in both ponds averages 40 percent sol ids. Both ponds
are diked to contain the sludge, which also allows rainwater to collect on the
top of the sludge; the rainwater is collected and pumped back to the plant
wastewater treatment facility for treatment. The top few feet of the sludge
in both ponds have deep cracks that remain year-round, Most of the surface of
the LRSP stays wet throughout the year, but the surface of Schmidt Lake dries
to dust during the summer.
Portions of the TWCA site, including the sludge ponds,
lOa-year and SOO-year flood plains of the Wi 11amette River,
surface in the vicinity of THCA slopes westward towards the
gradient of approximately 11 feet per mile.
are in the
The ground
river with a
Willamette Valley temperatures are moderate, with maximums seldom
reaching 1000 F and minimums rarely reaching 00 F. Roughly 70, percent of the
40-inch annual precipitation falls during November through March, whi 1e only
6 percent occurs during June, July, and August; fall and winter precipitation
is the primary source of aquifer recharge in the area. There are usually only
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0 200 400
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SCALE IN FEET
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LOWER RIVER
SOLIDS POND
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FORMER
MAGNESIUM
RESOURCE
RECOVERY PILE
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FIGURE 2,
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LOWER RIVER SOLIDS PO: ll'j
AND SCHMIDT LAKE
TElEDYNE WAH CHAt-tBAI-JY
AI.BANY, OREGON
, '" .
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The immediate a(.::a sU,';'CL:r~:jj'lg I~'JC':; 13 c,i:i12,ri~J i:1CUS:<;::'. ',':;:'1 ~>,:
land to the north ~ejng used for agrjculrure. The land east cf I~te~state 5
and south of the plant iite is used mainly for residential andcommerc1al '
purposes, while land west of the Willamette River, which borders the plant,
site, is used for farming. Albany, the urban area to the south of the site,"
has a population of approximately 27,000; Millersburg has a population of ('
about 560. '
T~ere are approximately
three miles of the facility;
There are no known domestic,
located bet~een the site and
not used as a drinking water
250 known private drinking water wel 1~ within
all of these wells are upgradient of the site.
municipal, industrial, or irrigation wells
the Wi I lamette River. The Wi I lamette River is
source in this area.
i
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~
~IT~ HI~TCRY AND £NFORCEM~NT ACTIVlfIE~
Site History
Operations at the TWCA site began in 1956 when, under contract with the
U.S. Atomic Energy Commission, Wah Chang~Corporation began operation .of the
U.S. Bureau of Mines, Zirconium Metal Sponge Pilot Plant. Construction of new
facilities at the existing plant began in 1957. These facilities were built
prlmari1y for the production of zirconium and hafnium sponge. However,
tantalum and niobium pilot facilities were later included. Melting and.
fabrication operations were added starting in 1959. TWCA was established in
1967 after Teledyne Industries, Inc., purchased Wah Chang Corporation of New
York.
!
Because of the many processes involved in the production of nonfer~ous
.' metals and products, waste management programs at TWCA consist of a wide range
of activities, including: process wastewater treatment; solid waste
management; hazardous waste management; PCB equipment management; radioactive
material control; waste minimization through beneficial use; and air quality
control programs. Discharge of process wastewater is regulated by a National
Pollutant Discharge Elimination System (NPDES) permit. An Air Contaminant
Discharge Permit regulates air emissions at the facility. Teledyne is
currently classified as a hazardous waste generator under the Resource
Conservation and Recovery Act (RCRA) program.
The LRSP was constructed and placed into operation in 1967 to receive
. lime solids (sludge) from TWCA's onsite wastewater t~eatment plant; Schmidt
Lake was constructed for the same purpose in 1974. Sludge was pumped into the
two ponds until October 1979, when the farm ponds to the north of the facility
were put into operation. The farm ponds were originally part of this operable
unit, but because they are outside the flood plain and contain lower levels of
. radioactivity, they are not considered an immediate threat and are now being
\investigated as part of the overall site Remedial Investigation eRI). The
sludge in both the LRSP and Schmidt Lake contains heavy metals, a few organic
compounds, and trace levels of some radionuc1ides. Tables 1-4 summarize the
contaminants found in the sludge.
In 1978, TWCA modified the process for the production of zirconium and
hafnium metal such that radioactive materials were directed into a separate
solid waste referred to as chlorinator residue.. This residue is managed as a
low specific activity radioactive waste and shipped to Hanford, Washington,
for disposal. Sludge generated since the implementation of this modification
has been stored in the farm ponds.
Enforcement History
The sludge ponds have attracted the attention of regulatory agencies and
the public for many years, particularly because of the presence of low-grade
radioactive materials which was first confirmed by the Oregon State Health
Division in 1977. In March 1978, TWCA was granted a Radioactive Materials
License to transfer, receive, possess, and use zircon sands and industrial
byproducts containing licensable concentrations of radioactive materials.
rNCA took samples from the ponds on sevel'al occasions in 1979 and 1330.
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:a.bie '
INORGANIC _CCNT~~INN~TS =N ~rtS? SCLIDS
Detects/
Samples
Maximum
Minimuma
b
Average
EackaroundC
-
~
Arsenic
40/40
39
2
10
. 24
Barium
39/40
3,500
33
173
, ' -
_.:.c
Beryllium
20/40
1.3
0.5
0.7
\.-I. I
Chromium
39/40
220
65
100
20
Copper
40/40
-..,
I I
29
. ~
...0
- -
Mercury
36/40
7.6
0.3
1.2
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Table 2
.INORGANIC CONTAMINANTS IN S~~IDT LAKE SOLIDS
Detects/ '
Samples Max1mum Min1mwl a Averageb BackgroundS:
Arsenic 10/10 36 8 16 24
BariUm 10/10 72 36 39 116
Sery11iWII 10/10 1.1 0.7 0.8 0.7
CadmiWil 7/10 1.2 0.1 0.3 <0.1
ChromiWil 10/10 13 79 90 20
Copper 10/10 72 34 45 12
Mercury 4/10 1.4 0.2 0.6 <0.2
Nickel 10/10 4,300 1 , 700 2 ,600 14
Lead 10/10 150 70 103 10
Antimony 10/10 14 8 9 <20
SeleniW11 7/10 4 1 2 3
ThoriWil 10/10 59.3 (7.5) 30.8 (3.4) 46.3 (5.1) 3.5
UraniW11 10/10 237.7 (160.9) 104.6 (70.8) 162.6 (110.1) 0.8
Zinc 10/10 97 50 67 39
Cyanide 4/10 110 2.5 5.3 <2
Radiumd
Activity 10/10 (26.4)-5 (14.9) -5 (19.2)-5 (1.0) -7
Concentration 2.54x10 1.44x10 1.8Sx10 9.64x10
ZirconiWlle 10/10 28.8 3.9 7.4 <1.0
\
Note: All concentrations in mg/kg of as-received, wet solids.
Concentrations in parentheses are in pCi/g.
Only constituents that were detected in 10 percent or more of the samples are
shown. .
aMin1mum value detected above detect~on limit.
bGeometric average. Duplicates were averaged to obtain one value that was then lnclucec
1n the geometric average. No values below detection lim~t were included in. the average.
cFrom soU samples taJten east of the Farm PODds, October 1988. See RI report.
dAs radiWil -226.
eUrcOn1ua 15 expressed as a percent.
CVRl26/051-2
-
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Table 3
ORGANIC CONT~~INANTS IN LRS? SOLIDS
Volatiles
Detects/
Samples
~
Methylene chloride
36/40
l,l,l,-~richloroethane
7/40
4-Methyl-2-pentanone
23/40
1,1-Dichloroethane
12/40
Tetrachloroethene
19/40
Semivolatiles
Hexachlorobenzeneo
39/40
bis(2-ethyl-hexyl)
phthalate
5/40
Max imum
22.000
0.860
1,400.000
0.860
0.970
64.000
1.700
Minimum a
0.006
0.053
0.040
0.053
0.005
0.740
1.000
b
Average
0.084
0.1.55
3.929
0.174
0.164
6.600
1.295
Note: All concentrations in mg/kg dry weight.
Only compounds that were detected in 10 percent or more of the
samples are shown.
aMinimum value detected above detection limit.
bGeometric average. Duplicates were averaged to obtain one value that
was then included in the geometric average. No values below detection
limit were included in the average.
\
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Table 4
ORGAN.IC CONTAMINANTS IN SCHMIDT LAKE SOLIDS
I
Detects/ a b
Volatiles Samples Maximum Minimum Average
,
Methylene chloride 10/10 0.090 0.031 0.046
1,1,1,-Trichloroethane 4/10 0.320 0.073 0.168
4-Methyl-2-pentanone 3/10 54.000 24.000 32.708
1,1-Dichloroethane 5/10 3 . 900 0.170 1.054
Tetrachloroethene 1/10 0.073 0.073 0.073
Semivolatiles
Hexachlorobenzene 10/10 25.333 7.300 14.087
bis(2-ethyl-hexyl)
phthalate 1/10 1.000 1.000 1.000
N-Nitroso-di-n-
propylamine 2/10 0.590 0.190 0.048
Note: All concentrations in mg/kg dry weight.
Only compounds that were detected in 10 percent or more of the
samples are shown.
aMinimum value detected above detection limit.
bGeometric average. Dupl~cates were averaged to obtain one value that
was then included in the geometric average. No values below detection
limit were included in the average.
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r~ 192~, "t';e cC~~:'":'J ~.::1;=:::: :I"e ~:c:::::f:'""~;:n': ::"2"";~. "~.:i'::".
Siting Council CEFSC) for a si;:e cei'tificate LO close LRS;:: an.J to s:.:,..:: '
approximately 120,000 cUbic yards of lime solids. The TNCA fac! 1 it) ~as
listed on the National Priorities List CNPL) in October 1983. After several,'
years of hearings, court attlons, and further sampling, EFSC ruled in 1987./
that the sludge was not subject to their jurisdiction, the levels of'
radioactivity being too low. TWCA then submitted a closure plan to the Oregon
State ~ealth Division, but EPA and othef agencies recommended that closure not
take place until after the conclusion of the RI. On May 4, 1987, THCA signed
a,Consent Order agreeing to conduct the Remedial Investigation/Feasibi lity
Study CRIIFS).
The TWCA facility holds permits for water and air emissions. It was
found in violation of wastewater discharge permits in 1975, 1977, and 1978;
subseque~t process changes reduced the toxicity of the facility's wastewater
discharges. TWCA was assessed fines for other water quality permit violations
in 1979, 1980, and 1989. The company was fined for j llegal open bUi'ning in
.' 1983. In 1986, TWCA was cited for several violations of the state's hazardous
waste management rules.
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!I"I'\;:: T./"I!!':"S (',;'I"(',IHtll~IT-I'.j 1'1,~~-7"':,"I\;.A,,!
nL.JnL.~l1n i ur \"UI'!/'!Ul'u I r:', 1\ i l'.,",l~ii i ll.:i'i
TWCA and its activities have always been of interest to the community.,"
Historically. the environmental issue of greatest local concern has been odor'
from the plant. Process changes have since reduced the odor and the number of
complaints about it.
,
TWCA came to the attention of state environmental groups again in 1982,
w~en it submitted its disposal plan to EFSC and became known as a source of
radioactiv~ contaminants. One of the groups, Fore1aws on Board, has sponsored
three state ballot initiatives proposing tighter standards for licensing such
disposal facilities (one passed, two failed), and has also appealed the final
EFSC ruling, which was upheld by the Oregon State Supreme Court in July 1988.
Greenpea~e staged two protests on the issue in 1985.
The following EPA community relations activities have been conducted at
TWCA under Superfund:
\
o
December 1982 - si~e proposed for inclusion on the NPL.
October 1983 - site listed on NPL.
o
o
February-May 1987 - local citizens and officials interviewed in
order to prepare a Community Relations Plan.
o
November 1987 - final Community Relations Plan issued.
November 1987 - Information Repositories established at Albany
Public Library, Department of Environmental Quality (Portland). and
EPA Region 10 (Seattle).
o
o
November 1988 - RIfFS work plan for entire facility sent out for
30-day public'comment period. Work plan was placed in information
repositories and a fact sheet was published.
o
February 1989 - Fact sheet published announcing EPA's approval of
the final work plan.
o
June 1989 - Fact sheet published announcing that TWCA had submitted
a draft RIfFS report to EPA for Operable Unit '1.
o
August 16, 1989 - Interim Action (Operable Unit '1) Proposed Plan
published.
August 18 - October 16. 1989 - Public comment period for the
Proposed Plan.
o
o
September 6, 1989 - Public meeting for the Proposed Plan held in
Albany. This meeting was announced in the Proposed Plan and a local
newspaper.
-------
, ,
SCOPE AND ROLE OF OPERABLE UNIT WITHIN ~ITE ~TRAT~GY
EPA and TWCA decided to separate the sludge ponds operable unit from the
rest of the site in the summer of 1988, soon after commencement of the overall
site RI, because:
.'
,
a)
b)
c)
the ponds are a likely source of groundwater contamination;
they are located in the Wi1lamette River flood plain;
they contain radioactive materials, and thus have been the focus of
community concerns about the site; and
TWCA, in response to these concerns, wishes to clean up the ponds
~ithout waiting for the full site RIfFS to be completed.
d)
The potential for groundwater contamination alone justjfies a separate,
expedited action. Other potential sources of groundwater contamination
"include onsite process plants, drains, and farm ponds, as well as several
offsite sources, such as neighboring pulp and paper plants. The relative
importance of each of these sources, as well as the nature and extent of
contamination, are the fOFuS of the RI for the overall site.
The overall site RIfFS is underway and Phase I is scheduled for
completion in 1990. To the extent possible, this Interim Action is consistent
with future activities.
i
, "
-------
~UMMARY OF SITE C~ARACTERISTICS
Contaminants Present
.'
The sludge in the LRSP and Schmidt Lake was sampled and contains metal
compounds produced by the various onsite.processing units, including
zirconium, hafnium, chromium, mercury, nickel, uranium, and radium; cyanide.
has also been found. Of organic compounds detected, the most prevalent one is
hexachlorobenzene, which is probably a byproduct of plant operations (Tables
1-4) .
TWCA's wastewater treatment system consists of a continuous chemical
precipitation and sedimentation system. Metals are treated by neutralization
with lime; magnesium hydroxide, or sulfuric acid and carbon dioxide to a pH
range between 6 and 8 to form metal hydroxides and sulfates which wi 1 1
.~recipitate. Fluorides are removed by the formation of calcium fluoride.
These compounds are removed in a clarifier by settling. Lime solids, referred
to as "sludge", generated from the operation of the clarifier are placed in
sludge ponds for additional settling, dewatering and storage.
Potential Routes of Miqration
The LRSP and Schmidt Lake are unlined impoundments constructed on native
soils in the Willamette River flood plain; thus, flooding is one potential
cause of contaminant migration. Because the ponds are unlined, they could
also be a source of groundwater contamination. Another possible route is
.dermal contact with the sludge by onsite workers or trespassers. A fourth
potential route; dust, is a major concern because the dried sludge material
can be spread by wind. Some dust is created when the surface of Schmidt Lake
dries during the summer, and more could be created by sludge treatment or.
removal activities. Fortunately, most of the sludge contains a high
percentage of water, which limits its migration as a dust.
-------
r .
~.!t,l~f';"I:j ~:"" "'~"'.- ".!",/""
JUi'!j'!,-li\: ur )llt Kl~\J
. I
The following assess~ent Js based on the data generated and presented .rn.
the TWCA Operable Unit Remedial Investigation (OURD report and deals only'
with the potential hazards associated with exposure to the sludges in the
ponds. Any potential hazards associated with contaminated soi 1s beneath or
surrounding the sludges or with groundwater associated with the ponds wi 1 1. be
evaluated as part of the overall site RIfFS. A baseline risk assessment is a
part of the overall RIfFS.
Identification of Contaminants of Concern
During the OURI, sludges in the LRSP and Schmidt Lake were found to
contain inorganic elements, organic compounds, and radionuclides. In
~ estimating average concentrations, a value of one-half the method detection
limit (MOL) was assumed for cases where no detectable contaminant quantities
were found. Of all the chemicals measured in the sludges, the inorganic
elements, particularly zirconium, were found in the highest concentrations.
Thirty-four chemical substances were detected and positively identified
in the LRSP and Schmidt Lake sludges during the RI. In addition, several
tentatively identified compounds were also detected. Of the 34 positively
identified chemicals, 26 are chemicals of concern and potential contributors
to public health risk.
For carcinogens, since there is no safe dose, an estimate of the
likelihood of developing cancer is derived from the average daily dose over a
lifetime multiplied by the potency factor for that particular chemical. The
potency factor is the plausible upper bound estimate of the probability of a
response per unit intake of a chemical over a lifetime. EPA has developed a
. classification system (A-E) for chemicals which have been evaluated as
~ potential carcinogens. The system is based on a weight of evidence }cheme,
with those chemicals being known human carcinogens considered as A carcinogens
and those for which there is no evidence of carcinogenicity in the E category.
For non-carcinogens, the average daily dose over the period of exposure
is compared to a reference dose or other toxicity constant. A reference dose
is an estimate (with a safety factor of 10 to 1000) of a daily exposure level
for the human population that could occur without producing harmful health
effects. Non-carcinogenic effects include behavior changes, nervous system
disorders, birth defects, and damage to kidneys, blood, liver and lungs.
Carcinogens
Twelve (non-radionuc1ide) chemicals .found in the pond sludges may cause
cancer. Three e1ements--arsenic, chromium, and nickel--are known to have the
potential for causing cancer in human~ when inhaled. Analyses done at 7NCA
were for total chromium, with the type unspecified; in order to be more
protective of public hea1th, this risk assessment is based on chromium VI (the
most toxic form). Eight chemicals are probable human carcinogens through
either ingestion or inhalation (Group B) and one is a possible human
car-cinogen (Gr.)up C>. Pot:?nc:; estimates and EPA c1assifiotion fOI' these
chemicals are provided in Table 5.
-------
TABLE 5
TELEDYNE WAH CHANG
OPERABLE UNIT NUMBER ONE
HUMAN HEALTH RISK ASSESSMENT
~
CANCER
~ POTENCY
--------------
--------------
CONTAMINANT
ORAL INHALATION.
(mg/kg/d) A (-1) (mg/kg/d)A(-l) EPA
CLASSIFICATION
================================================================
Arsenic 1. SOE+OO 1. SOE+01 A
Beryllium 4.80E+OO 8.40E+OO B2
Bisethylhexylphthalate 1.40E-02 B2
Cadmium 6.10E+OO B1
Chromium VI 4.10E+OO A
Hexachlorobenzene 1.67E+OO B2
Methylene chloride 7.S0E-03 1. 40E-02 B2
Nickel 8.40E-Ol A
Tetrachloroethene S.10E-02 3.30E-03 B2
Trichloroethene 1.10E-02 1.30E-02 B2
1,1 Dichloroethane 9.10E-02 C
\
-------
. .
Ra.jjonucl ides
'The presence of uranium, thbrium, and radium isotopes in the sludge; from.
Schmidt Lake and the LRSP presents the potential for radiation induced'
cancer. In the Teledyne Wah Chang Endangerment Assessment (part of the
Operable Unit Feasibility Study), the committed dose equivalent was converted
into an estimate of cancer risk using cOQversion factors from the "Effects on
Populat10ns of Exposure to Low-Levels of Ionizing Radiation" NAS, (1980),
ranging from 67 to 227 cancer deaths per million-man-rem. These factors
suggest that if one million individuals were each to receive one rem, then 67
to 227 exce~s cancer deaths would be observed. These conversion factors may
be translated into estimates of individual cancer risk. The individual cancer
death risk is 6.7xlO-4 per rem. Recent information indicates that the
maximum number of cancer deaths per million-man-rem should be 400 instead of
227. Th~ new number of 400 cancer deaths per million-man-rem was used in the
supplementary assessment to estimate maximum cancer deaths. from radi3t~on
exposure. Radiation induced cancer is assumed to be fatal and chemical iy
"induced cancer mayor may not be fatal.
Non-CarcinoQens
For the non-carcinogens, antimony is likely to produce the most
effect from the ingestion exposure route; barium from the inhalation
Zirconium, which occurs at the highest concentratien, is not acutely
but accumulates in the body and may produce chronic effects.
severe
route.
toxic,
Exposure Assessment
Under current and future operating conditions, if no cleanup actions
undertaken at the site, the most likely exposures are for workers and
trespassers coming into direct contact with the chemicals in the sludge.
addition, if land use patterns change and the sludge site is opened to
residential development, onsite residents may be exposed to contaminated
\s 1 udges.
In order to estimate potential health risks from contact with the sludge,
four exposure scenarios were evaluated in the risk assessment. Two scenarios
were used to describe operations continuing at the facility with no corrective
action. Under these two scenarios workers were assumed to come into direct
contact with pond sludges for an average of 10 years and a maximum period of
40 years. For future risks, if the sludge site should become residential, it
was assumed that the average resident would live on the site for 35 years and
would be in direct contact with the sludges for 22 to 365 days per year. For
the highest residential exposure, it is assumed that an individual would be in
direct contact with the pond sludges for his or her entire lifetime (75 years)
for 66 to 365 days per year.
are
In
Exposure estimates (total dose over a lifetime for carcinogens and ove,"
the exposure period for non-carcinogens) for ingestion of contaminated sludjes
and skjn absorption of chemicals were based on average and maximum
concentrations of chemicals measured in pond sludges. If the ponds dry, th~
sludges could be dispersed into the atmosphere by the wind or man's actions.
In order to complete the assessment for inhalation of chemicals, maximum
particulate concentrations vlere assumed to be equivalent t.:) the federal
particulate standard of 150 ug/cubic meter (National Ambient Air Quality
-------
S:andards, 40 CFR 50, part;c:.Jiate matter- less thi1n 01' equai tc in ",L-(~r':
24 hour average), A particulate concentration of 50 ug/cubi: meter wa~ ~s~~
as an average exposure condition. In addition, contaminant concentraticns. /
were assumed to be the same in the airborne particulates as they are in the
sludges, with particles being 100 percent respirable.
Risk Characterization
A ~ummary of risk estimates for exposure to contaminated sludges is given
in Table 6. As this is only a preliminary assessment for a portion of the.
TWCA facility, the summary risk estimates should not be viewed as a statement
about health risks to residents in the vicinity of the site. The risk
estimates presented in t~is report are representative of long term exposures
to chemicals in the ponds (from 10 to 75 years) for average and maximum worst
case scenarios. Future residential development on the sludge site without
cleanup of the contaminants in the ponds is clearly the maximum worst case
scenario. The purpose of evaluating this unlik~ly event is to provide EPA anj
,.the public with sufficient information to make a decision regarding the
necessity for cleanup of toxic materials in the environment.
Another scenario which is viewed as a potential worst case event is the
movement of contaminants into the Wil1amette River or nearby residential areas
due to flooding. The probability of a flood overtopping the ponds has been
estimated at a one in 500 year event. Due to this relatively small
likelihood. and difficulty in predicting how contaminants would disperse if
such an event should occur, risk estimates were not completed for this
exposure pathway. However, one can assume that the residential scenario
provides a measure of what health effects would be predicted if contact with
contaminants should occur over a long periOd of time. Health risks due to
. flooding should not exceed those which are predicted for a residential
exposure.
Cancer Risk Estimates
The risk of developing cancer ranges from less than one chance in' one
million to greater than one chance in one thousand, depending on the level and
length of exposure. For onsite workers, the greatest risk of developing
cancer is under maximum exposure conditions (40 years at work), Nickel,
chromium VI, arsenic, and hexachlorobenzene are the major contributors to the
increased cancer risk. The potential risk of developing cancer for people who
may reside onsite in the future, if no action is taken, ranges from an
additional cancer risk of one in one thousand to three in one thousand for
exposure over a lifetime. Nickel, chromium VI, arsenic and hexachlorobenzene
are also the major chemicals contributing to the cancer risk for this scenar-io.
,The risks of death from cancer due to exposure to radionuclides if no
cleanup action is taken are equivalent to those from other chemicals, ranging
from seven in one million to one in one thousand. The greatest risk is for
residents under maximum exposure conditions (75 years direct contact with pond
sludges).
Non-cancer Risk Estimates
Under current or future operating conditions, risks of health effects
other' than cancer are only e~pected for the highest worker exposure (40 jEa's
-------
..
TABLE 6 TELEDYNE WAH CHANG
OPERABLE UNIT NUMBER ONE
H'9MAN HEALTH RISK ASSESSMENT
RISK SUMMARY TABLE
; EXCESS
LIFETIME
EXPQSURE EXPOSURE CANCER HAZARD
SCENARIO ROUTE RISK INDEX
FUTURE-NO ACTION* NON-RADIOISOTOPES
AVE. RESIDENT INGESTION 8 X 10-05 1.2
INHALATION 4 X 10-05 0.1
RADIOISOTOPES
INGESTION 4 X 10-06
INHALATION 2 X 10-04
TOTAL RISK 3 X 10-04 1.3
FUTURE-NO ACTION*
UPPER BOUND RESIDENT NON-RADIOISOTOPES
INGESTION 1 X 10-03 10.8
INHALATION 1 X 10-03 5.7
RADIOISOTOPES
INGESTION 1 X 10-04
INHALATION 1 X 10-03
TOTAL RISK 3 X 10-03 16.5
FUTURE-NO ACTION*
AVE. WORKER NON-RADIOISOTOPES
INGESTION 4 X 10-07 0.05
INHALATION 5 X 10-06 0.05
RADIOISOTOPES
INGESTION 8 X 10-08
INHALATION 7 X 10-06
TOTAL RISK 1 X 10-05 1.0
FUTURE-NO ACTION*
UPPER BOUND WORKER NON-RADIOISOTOPES
INGESTION 8 X 10-05 1.1
INHALATION 5 X 10-04 4.1
RADIOISOTOPES
INGESTION 3 X 10-05
INHALATION 5 X 10-04
TOTAL RISK 1 X 10-03 5.2
SHORT-TERM WORKER** NON-RADIOISOTOPES
INGESTION 1 X 10-06 0.74
INHALATION 9 X 10-07 0.06
RADIOISOTOPES
INGESTION 4 X 10-06
INHALATION 1 X 10-05
TOTAL RISK 2 X 10-05 0.8
-------
. . TABLE 6
(cont'd)
TELEDYNE' WAH . CHANG'
OPERABLE UNIT NUMBER ONE
HUMAN HEALTH RISK ASSESSMENT
RISK'SUMMARY TABLE
~
EXCESS
LIFETIME
CANCER
RISK
NON-RADIOISOTOPES
2 X 10-06
RADIOISOTOPES
3 X 10-06
5 X 10-06
. EXPOSURE
. SCENA:RIO
TRESPASSER**.
EXPOSURE
ROUTE
INGESTION
INGESTION
TOTAL RISK
*EPA, September 1989 Supplemental Risk Assessment
**Teledyne Wah Chang Albany, Operable Unit Number One
Endangerment Assessment, August 1989
\
19
.'
HAZARD.
INDEX
0.06
-------
. .
3.t the :>ite.) 5arill':1 is tr.e cr:'/ :',=::-:::3.1 f.)( \'Ir:~.:h t'~~ 3..;;':;= .::;~, .:. :.:::"
exceeded the reference dose, Thi:> ~as due to the high maximum concertratfo~
found at the site. At average concentrations, barium It/ou1d not present a
health risk.
Under a future no actton assessment, the non-carcinogens are not a sou~ce
of health risks to people under average residential conditions. However,
under ~aximum exposure (high contact rates, longer duration and maximum
concentrations) the risks of adverse health effects will exceed acceptable
li~its. The average daily dose of barium, nickel and uranium would exceed
their respective reference doses under these maximum exposure conditions.
-------
OtSCRIPTION Ot ALT[RNATIVES
In the FS for this operabl.e unit, seven cleanup alternatives,
representing three different types of remediation--containment, onsite
landfilling, offsite landfilling--were developed and analyzed in detail. Of
these, ;the four most feasible and protec-tive (numbers 1, 5, 6, and}) were
considered in the Comparative Analysis of Alternatives. The other three
r~present the same range of alternatives, with minor technical variations.
The four alternatives given detailed evaluation are discussed below and in the
following section, using the numbers assigned to them in the FS and Proposed
Plan.
Offsite transportation of the sludge is a component of several remedial
alternatives considered for this operable unit. Under a worst-case scenario,
risk to workers from a spill is considered to be the same as for workers doing
" cleanup onsite.
The sludge is not a characteristic or listed hazardous waste under the
Resource Conservation and Recovery Act (RCRA), so the Land Disposal
Restrictions are not applicable and were not a consideration in selecting
alternatives.
This Interim Action addresses only the sludge materials stored in the'
LRSP and Schmidt Lake, since they are the source of the contaminants of
concern. The surrounding and underlying soils and dikes which will remain
after any sludge relocation actions occur will be investigated as a part of
. the overall site RI/FS which is currently underway. The restoration of the
wetlands or filling of the excavated ponds will also be part of the larger
site study. The sludge materials can be visually distinguished from the soils
forming the bottom and sides of the storage ponds.
\ Alternative 1:
Consolidation, Barrier Wells. Cappinq, Flood Protection
This alternative consists of moving the sludge from Schmidt Lake into the
LRSP, pumping and treating the groundwater downgradient of the impoundment,
stabilizing the dikes, and capping the sludge to minimize infiltration of
precipitation.
\
During the excavation of Schmidt Lake and transportation to the LRSP,
dust control measures would be implemented as needed, including wetting of the
surface sludge if necessary.
Approximately eight barrier wells would be installed in a semicircle
formation downgradient of the LRSP. Extracted groundwater from each well
would be channelled to a pipe for return to the existing plant wastewater
treatment system for treatment and discharge.
According to an investigation by a TNCA contractor (Dames and Moore> in
1981, the existing LRSP dikes would be unstable during a major flood.
Therefore, this alternative incorporates measures for stabilizing the dikes.
This work would be accomplished by conventional earth-moving and compacting
equipment.
-------
,~, n i r.: p e , in e :'\ b 1 e caD ,'1 ':. iJ],: 0 ~ i ~ : ::\ ; ;~:: :: J T.: r : ~ j : ~ ': r s ;- .:" :'. ;, :: :..
5urface water into the LRS? and reduce migration of contaminan:s :0 'I
groundwater. Capping would also el imihate dust and reduce radon flux. Di~e '
stabilization will reduce the risk of contaminant dispersal by flooding. This
alternative does not include any form of treatment of the sludge. /
Applicable or relevant and appropriate standards (ARARs) include
Executive Orders 11988 (Protection of Ftoodplains) and and 11990 (Protection
I
of Wetlands), the Oregon Solid Waste Regulations (for capping), and State,
Historic Preservation Office regulations on identifying the potential for
hlstoric artifacts in previously undisturbed areas. The on site wastewater
treatment plant is subj~ct to Clean Water Act requirements, including an NPDES
permit. Clean Air Act and Occupational Safety and Health Administration
(OSHA) regulations would apply during construction.
Operation and maintenance (O&M) for the barrier wells would be required
for approximately 30 years. O&M for the flood protection and cap would
.' consist of inspection and repair of observed damage twice each year.
Groundwater would be monitored quarterly.
Implementation time for this alternative is estimated to be approximately
one year, and present wo'rth costs are estimated at $1.8 million.
Alternative 5:
Removal, Solidification, Onsite Disposal
This alternative consists of constructing an onsite landfill east of the
present farm ponds, removing the sludge from the LRSP and Schmidt Lake,
solidifying the sludge by adding a solidification agent such as Portland
. cement, and placing it into the landfill. '
The onsite landfillwould'be designed to contain the sludge with minimal
infiltration from precipitation. The major features of the landfill would
include:
o
Above-grade construction to prevent infiltration of groundwater into
the fill (the seasonal high water table in the area of the farm site
is 1-3 feet below the existing ground surface).
o
A gravel underdrain system to ensure that the water table remains
below the bottom liner.
o
A composite liner constructed above the gravel underdrain. Leachate
(liquid runoff from the landfill) is not expected because the sol ids
are non biodegradable and would be partially solidified; if leachate
occurred, it would be pumped from the sump into containers or a tank
truck and taken to the wastewater treatment plant.
o
A 1 andfi II
cOlJer.
In order to mix the sludge ~ith Portland cement (0" whate~2r ag21~ j 5
selected), it would be remOlJed from the rilJer ponds and transpOi'ted
approximately one mile to the solidification mixing plant located neal' the
landfill. Once solidified, it would be placed into the new landfill. The
proposed solidification process is not total solidification but a part~a!
treatment designed to improve'hand1 ing and reduce moisture content in the
-------
sludge. The solidification precess aJso reduces leacha:e pot2~:ial bj
chemically treating the sludges to bond the metal compounds within the
matrtx. . . .
slujge
Treatment of the sludge wj.11 reduce the gros s mobil i ty of the me ta 1 .
compounds, and landfilling will make the contaminants less accessible to human
contact. This alternative also removes the contaminated materials from the
flood p.lain. It would not reduce toxicity of the contaminants.
ARARs for this alternative Include the substantive requirements of the
Oregon Solid Waste Regulations for the landfill (though a permit will not be
required). 'Clean Air Act and OSHA regulations will apply during
construction. Wetlands should not be affected.
O&M .for the landfill would consist of sampling and testing groundwater
from monitoring wells, monitoring the leachate collection system, and
Inspecting and repairing any damage to the landfill.
This alternative would take approximately 2 years to implement.
worth costs are estimated at $12.8 million.
Present
Alternative 6:
,
Removal, Offsite Disposal Without Treatment
Under this alternative, the sludge would be excavated and placed on a
concrete slab where it would be allowed to drain excess water. It would,then
be loaded Into watertight containers and hauled to a permitted disposal
facility. Two new solid waste landfills in north-central Oregon which have
recently been permitted and have the capacity to accept the solids are
. considered as possible facilities. Both are remote from population centers,
with a depth to groundwater of at least 100 feet below ground surface and net
annual precipitation of 4 inches or less. Both landfills have expressed an
interest in receiving the sludges, which would be disposed in a cell separate
from other wastes. A specific landfill would be selected as part of the
\ Remedial Design process.
As with the preceding alternative, the sludge would be removed
permanently from the flood plain, and the potential for human contact would be
even further reduced by the landfill cap. The sludge would not be treated.
ARARs for offsite disposal include, the Oregon Solid Waste Disposal
Regulations. Both landfills being considered in Oregon already have state
permits under these regulations. Hauling would need to be performed by a
contractor authorized by the state as a solid waste hauler and in compliance
with state of Oregon Public Utility Commission rules. Clean Air Act and OSHA
regulations would again apply during construction.
There would be no O&M under this alternative, aside from routine
maintenance to be performed by the landfill operator. Implementation
would be approximately 8-9 months. Present worth costs are estimated
mi 11 ion.
time
at $8.5
Alternative 7:
Removal, Sol idification, Offsite Disposal
This alternative is the same as the preceding one. except that the sludge
IVould be partially sol idified with Portland cement (as in Alternative 5) pJ"ior
?"
-------
to off3ite disposal.
offsite landfill.
~rJ!
-------
SUMMARY OF COMPARATIVE ANAlYSIS OF ALTERNATIVE~
Each of the four alternatives described in the preceding section was
evaluated according to th~. fol)owing nine criteria:
\
i
Threshold Criteria
.
1.
Protectiveness of human health and the environment: whether or not
the remedy provides adequate protection or describes the mechanisms
for controlli~g risk for the different exposure pathways.
Compliance with ARARs: whether or not the remedy ensures compliance
with ARARs of other federal and state environmental standards or
statutes.
2.
Primary Balancinq Criteria
3.
Long-term effectiveness and permanence: the ability of the remedy
to provide protection and reduce risks to health and the environmert
after cleanup goals have been met.
4.
Reduction of toxicity] mobility. or volume through treatment:
anticipated effectiveness of treatment technologies used.
the
5.
Short-term effectiveness: the speed with which the remedy achieves
protection, as well as any adverse effects which it may create
during construction and implementation.
6.
Implementabi lity:
the remedy.
the technical and administrative feasibility of
7.
Cost:
includes capital and O&M costs.
Modifying Criteria
8.
9.
State acceptance:
remedy.
Community acceptance: whether or not the remedy is acceptable to
the community, and how it addresses their continuing concerns about
the site.
whether the state concurs with or opposes the
The following section describes how each ~lternative meets the various
criteria. Table 7 provides a summary of the criteria assessment.
1.
Protectiveness of Human Health and the Environment
Alternative 7 is the most protective, because it reduces contaminant
mobil ity through sol idification, removes the s1udge from the flood plain,
places the sludge in a place where it will have minimal contact with the
env ironment by any pathway (derma 1. air, groundwa ter). .
and
Alternative 6 is the next most protective, as it reduces risk of contact
and removes the sludge from the floodplain, although it does not reduce
con t am i n ant mobil i t Y . A i t ern a t i v e 5 '" e .j u c e s me b i 1 i t Y and r e me II est he s; u d 9 e
-------
Crl terla
Overall Protectiveness
II.,mall licit I t h Pro I eet I on
UII <:ct Contact/Sol Ids I ngest Ion
IIIlldl~t Ion of I~JsI. Ra<1on,
()rIJt'IIll(' Vttpul:.
IrHjCst J4.IO (If ';rlllJfUtw.Jtt"1
rllvllOllOlenl,,1 Prolectlon
11Ispersal by Floodlllg
f.,.)
0'>
Mlgrallon of TOS to Groondwater
Aquifer Restordtlon
CII..plldllCC with ARARs
..-..
Table 7
SIIKHARY OF CRITEIUA ASSESSHENTS FOR INfIIVIOUAL ALTERNATIVES
Alternative I
Barrier Neils, Capping,
'Iood Protection
Capping would redoce access
to solids.
Capping would prevent .Igra-
tlon of .etals and trace
radlonuclldes In dust. Would
reduoe radon fl~ and vola-
tilitation of organics.
To be addressed during overall
site RI/FS.
Reduces risk of dispersal by
flooding by stabillting
dikes.
Capping and barrier wells
curtail further .Igratlon of
TDS to groundwater.
To be addressed during overall
sHe RI/FS.
Satisfies solid waste closure
reqolre.ents for closure of
an existing solid waste dis-
posal unit. Harrier wells
.ay be needed Indefinitely to
prevent groundwater fro. en-
tering the solids, and for
use In long-ter. .onltorlng-
Puhl Ie acce<;s to the area .IISt
be restricted. Coordination
with Dr.O will he needed to
comply wllh retjl.litllons govern-
I n<] wet lands, rivers, st rea liS ,
and £Joodl'1 al liS - An archaeo-
logical survey would be req..lr-
ed for IIevly dlsl,"h"d areas.
Alternathe 5
Re8oval, SOlidification,
00511. Disposal
LandUlled sol Ids "ould be
Inaccessible.
Landflliing "ould prevent
.Igratlon of aetals and
trace radlonuclldes In dost.
Would reduce radon flux and
volatlltatlon of organics.
Solidification enhances
protectiveness.
See Alternative I.
Prevents dispersal by flood-
Ing b, leaovlnq solids fro.
the 5OO-,ear floodplain;
SOlldlflc~tlon enhances
eft ecU veness.
Lined landfill prevents .1-
gratlon of TDS to ground-
water.
See Alternative I.
Solidification of LRSP solids
and construction of new solid
"aste landfill "ould satlsf,
solid "aste disposal and clos-
ure requlreaents. I~ng-tera
.alntenance and 8Onltorlng of
the landfill "ould be required,
as "ell as treat.ent 01 an,
leachate collected. Public
access to the area .ust be
restricted. Coordination
with DEQ will be needed to
coapl, "Ith requlatlons gov-
erning ,..'tldndS, rivers,
strea.s, and floodpldlns. An
archaeological surv"y woold
be re')u Ir cd fur new I y dl s-
I... bed a I .'a~.
Alternative 6 -
Re.oval,
Offslte Disposal As-Is
SOlids landfilled In north
central Oregon site "ould be
feaote fro. population cen-
t.rs and essentlall, Inacces-
sible.
Landfliling "ould prevent .1-
gratlon of .etals and trace
radlonuclldes In dust. Would
reduce radon flux and 901a-
tilitation of organics.
See Alternative I.
Re.oves solids froa flood-
plain.
Lined landfill, arid cll88te,
and distance to groundwater.
.lnl.l&e8 risk of .I'1ratlon
of TDS to groundwater.
See Alternative I.
Offslte disposal of 801Ids
fr- the I.ASP and Sdl8ldt
Lake In a licensed 801ld
"aste dlapositl facillt, would
satlSf, solid waste disposal
requlreaents. The solids
would have to pass the paint
filter test prior to dis-
posal. The solids 80St be
transported by a licensed
hauler In apploved vehicles.
AlternaUve 7
Reaoval, SOlldlflcatlon;---
Of'.lte Disposal
See Altel1Ulthe 6. EUeetlv,,'
ness enhanced br aolldlf tea-
tlon.
See Alternative 5.
See Alternative I.
See Altel1Ultlve 5.
See AltemeUve 6. Sol"'lfl-
cation enhances effectlv,,-
ness.
See Alternatlye 1
Solidification of I~SI'
solids, and disposal 0"
Sch.ldt Lake 8nd LASp suIJ,b
In a licensed solid waste
disposal facilltr would
satisfy solid waste dl:;IIu511'
requlre.ents. The SOlid"
."st be transported by it
J Icens..d hauler In aplln.v,,,,
-------
Cr Iterla
Inng-Ter. [ffectlveness and
Per_nence
Ma'1nltude of ResIdual Risk
- Direct Contact/SolIds Ingestion
Inhahtlon of Dllst, IUIdon,
O'Qanlr Vavcrs
Inqe.' luu o' (ilow,,".'.r
(JI.~I..I L~ Floodln'1
Mlg.atlon 01 105 to Groundwater
IJ
-.'
~dequacy and Rellabillt, of Controls
~llablllt, of TechnologIes
Inng-1'"r. Mana'1e...,lIt
l.onC)-T'~I. HOllttur In9
It fill I,_y..,.. k'e'v I t~W
Altemat"'e I
Barrl.r Mell., CspplnQ,
'1004 Protection
RI.k'of dIrect contsct/lnQl!s-
tlon would be .lnl.lle4 wltb
capping.
RI.k of Inhalation of Detsls,
trace radlonucl1de., snd
ra40n, snd volaUlluUon of
orQsnlcs would b. .Inl.lled
wltb cappIng.
To be 844r...84 durlnv ov.r.11
.It. Ill/n.
Mould .Inl.lle but not .11.1-
nat. rl.k 01 dl.pers.1 of
.ollds b, lloo4ln'1.
.508e resIdual rIsk of further
TDS lo '1roundwater.
All technologIes are .Iaple,
straIghtforward, snd rella-
ble.
Operallon of the barrIer
wells, .alntellance of cap,
and .onllorln9 and treetaent
01 the puaped water would he
requIred. (Restorallon of
the aquIfer In tbls area wIll
be evaluated In lhe overall
site RI/FS and .a, subsU8e
the functIon of the barrier
wells.'
Requ!r".1 to I,rev,,"t futu.e
819.at 1011 01 11J5 to 9roulld-
watel.
N....~d:i 111'1 tUllte (~-Yf'drl
It:vl.,w.
..-'
Tabl. 7
, (ConttmMdl
Alternative 5
Reaowal, 801ldlflcltlon,
OD.U. D18posll
IIDI..I r..ldual risk, solids
would be .olldlfled, totall,
.aclo..d ID .ecure, 8Onltored
landf III.
IIDI..I r..ldual risk of dust
labaletlon, radon e.halatlon
and volltlll.ation of orQan-
Ie. would ba reduced/ell.l-
natad b, clpplnv.
Se. Alt.matlv. I.
".Idual rlak pre.ented.
RI.k .Inl.lled,as lon9 a.
Intevrlt, of lined landfill
I. ..lntl108d. Risk further
r.duced br .olldlflcatlon.
t.act result. of po.lol.nlc
reaction cannot be pradlcted
becau.e of .arlabillt, of
8011ds. Increa.e In .truc-
tural .tr.DQth, reduction of
gross 8Gblllt" and blndlDQ
01 Inter.tltlal water caD be
expeeted. fos8lble reduction
01 radon 11l1li. Otber tecb-
ooloVI.. .tralghtforward and
reUable.
Required for ..Intenanee to
enBure InteQrltr of la04flll.
See ~lterllatlve I.
Need~
rev',.,,-
c '~-r'.dll
AltemaUv. 6
Re8Oul,
Ofl.lte Disposal la-I.
IIDI..I re.ldual risk.
Solids landfilled at north
centr.1 OreQon sU. lIOul4 be
r.8Ote fr08 populatloD 080-
t.r. 80d Inacces.lble.
See Alternative 5.
See ~It.matlve I.
".Idual rIsk prevented.
Rllk .Inl.lled as 10DQ a.
Intevrll, of lined landfill
I. ..Intalned. Residual risk
I. al80 reduced br arid
cll..te, deplb to 9round-
water, 80d distance to
Qroundwlt.r discharge.
ReUable.
LonQ-ter. .ana9....nt pro.lded
.. InteQral part of exlsUnQ
1.041111InQ service, under
requlatlon b, state.
Provided as IlIt"9.al part of
ellslln9 landfIll ser.IL~.
under state leglllaUon.
No periodic ft~¥I.~v .e(IIII."ed.
AltemaU.. 7
Reao..I, SolIdification,
.. Offdte DI.poNI
See Alternatl.. 6. RI.k fur-
ther reduced br eol1d1flcatloll.
See Altemetl.. 5.
See Alternatl.. I.
Residual rl.k prevented.
See Altemathe 6. ,
Rls- further reduced b,
8011d1f IcaUon.
See Alternative 5.
See AllelO8tl.e 6.
"
See ~Iternatlve 6.
H.. "erlodlc review
cli.
-------
CcHecla
PoteDtlal Need to Replace
Technical C08pODent$
Magnitude of Risk If Tech-
nical C08pOOent5 fall
I J
(t)
~~ductlon of Toxicity, MObility,
oc Vol...e Through TreetMnt
Tre.t~nt Process
To.lcHy
1Iol.olilLy
Voluae
I r rever$lbll Hy
AltemaUve 1
Border llella, CapplD9,
flood Protection
If collpOnenta are IIhan on-
lIolng ..Intenonce to pcaveDt
acoalon, the, ahould last
Indeflnltely. lledlanlcal
C08lM>Dents, such aa pll8pa,
and acr..e..., vould need to be
replaced periodical 1,. Ven-
dor estLaates life of HDP£ In
absence of specific daaaga at
1,800 yearli.
Risk to bll88D bealtb and en-
vlronaeDt If furtber .Igra-
tlon of contealnanta to
IIroundvaLer occura vill be
deterelned durlD9 overall
alta RifFS. If dike failed
or Vere breached duCID9 a
flood, U- aolld.. algbt be
vashed downatreea, dispersed
ao vldely as to be IIceatl,
diluted. High vater et lov
velocities, bovever, .Ight
spread the sol Ida ovar a
a..ller area ea the flood
receded, leavlDg a discer-
nible layec_of 11.. 801ld8
accessible Lo receptors.
No lrea"'ent used.
Waste la not eaenable to re-
duction of Its ..In toslc
constltuenu throullh lreat-
.eD 1.
Does DOt tleat vaste to
reduce .obllHy.
Reduction of volll8e Ib, de-
vaterlngl vould locreeae con-
centration of radlonuclldes,
level of radon flus, and dust
genecaUon.
Not appllcable--no treat8ent.
..'
Tabl. 7
IContioued)
Altamatha S
Re8o.el, Solidification,
OIIaita OiaPDsal
See Altematlva I.
Risk poaed b, coat..tnut
.Igratlon to 9Iouodvater .111
be detel8lD8d durlD9 o.arall
alta RIfFS. Likelihood of
botb landfill end ponol8Dlc
reactIon falllll9 Is ..all.
Solidification.
See Altematlve 1.
Solidification reducea IIr08a
80bU It,, locra..aa atruc-
tural stl8D11tb, blD4a Int.r-
atltlel vetar raduclD9 !OS
8111uUon, reducaa radon
flux. Metela and redloou-
clicJea I884ln ~Ua.
See Altamatl.e 1.
Poaaolanlc reaction la
Irre.eralbla. Je"lsl&oca to
pb,alcal dalludetton of
treated aollda cannot be
predicted .Itb cectalnt,
because of bll1b TDS la.ala,
IncludlD9 fluorldea,
chlocldea, and sulfatea.
AUemathe 6
Jeeovat,
Offalte Disposal Aa-Ia
~raUon, ..Intenanc:e, cle-
aUl8, and poat-closur. viii
be perfo""" In accordeoce
vltb Oralloo Ad81ntatretlve
Julea In force at tha ta...
No need to replace landfill
C08pOII8nu la anticipated.
GaoIJrephlc local Ion ud
b,drogeolQ9lc seUlnll ace
aucb that rlak to buean
baaltb and envlroRMnt If
technical coaponenta fail la
8Inl.a"
No u,,""nt used.
See AltamaUve 1.
Sea Altemetlve 1.
See Altarnatlve I.
IIot appUcable--no tree....nt.
AUemaU.e 7
Jeeo.al, Solidification,
Offalte DlaPD8al
See Altirneti.e 6.
See Alternall.. 6.
~-
So lldl UceUoo.
See AUemeUn 1.
See Altematl.. S.
See Alternatl.e I.
See Alternathe S.
-------
Cr Her Ie
Iliherent Hazards Reduced b,
Treal.ent?
Short-Tena Effectiveness
Prolectloll of Co_unH,
Protect 1011 of Workers
tJ
~
~lvlron8enlal lepacts
Tl.e 10 Achieve Objectives
fI..e. 1101 Include plannlll'l and
.Ic~ I 'I" I'er 10ds.1
l.ple8entabtlH,
Technical Feasibility
- Abillt, to Conslruct and
()per ate Technology
1:"581 of .""10,, t ak!"1) ,.11.11 tlolla I
k,'l8Cdllll Act tuns
Alternative I
Barrier Ne))s, Capping,
'load Protection
110
Potent I. I du.t generation
durlDfJ .scavatlon, hauling,
and redlsposal of Scb8ldt
Lake WI II be sddressed b,
wetting of eurface SOlids,
proept cleanup of apills,
frequent hosing of residues.
Inge.tlon, prolonged der881
contact, and Inhaletlon
should be .volded end rea-
sonable precaution. t.ken.
(See Appen,Us 8.1
SIIort -tena I.pects f roe
DOIse, construction, etc.,
will have .lnl881 effect. In
lbl. Industrial area.
Approsleately I year. See-
sonal 11.ltatlons: cap .u.t
be Installed during sueeer,
when surface solids are
driest and can support vork-
ers end Ilqht equlpDent.
Not difficult to construct
or operete.
COlIslstelit vllh probable
future a~l(cr reslorallon
ullder overa 1\ s II" 1I1If'S.
.,-"
Table 7
(Cont louedl
AUernative 5
Re8owal, Solldlflcetlon,
OnsU. Dl.poul
Poe.lble reductions of redon
fllDI. TDS ..peeted to be
les. eoblle. ""t.ls .nd
other redlonuclldes r88eln
188Obtle.
Pot.ntl.l du.t generetlon
durlog exca.atloo, solidifi-
cation, end lendfliling will
be addreesed by wettlnq of
.urfece solids, proept cleen-
up of spilla, frequent hosing
of residues.
See Alternative I.
Se. Altern.tlv. I.
Approsl.atel, ) ,eer.. Se.-
sonel 11.118tlon.1 I.ndflll
construction 11.lted to con-
.tructlon eee.oo CApril to
Octoberl beeeuH of See8On-
.11, hlQh weter t.ble Cup to
Found 8urface et tl8esl.
Reav, winter reln8 would
11.lt excavation, solidifica-
tion, 8nd laadfliling to con-
.tructlon .eaeon.
TedbnolOfJleS not difficult to
construct, oper.te. Exect
results of po..olenlc resc-
tlon cannot be predicted.
BeneflcIsl--re80ves 501lds
per88nenll, froe LRSP area,
where future aQulf"r restora-
tion IS I" 81 und"r over-
all sll"
Altemat tve 6
IIe8Ovel,
Off.lte Dlaposel .AII-I.
No.
Potential du.t generetlon
durlDfJ escavatlon, and h.ul-
lng, wi)) be eddre..ed b, .
w"ttlog 01 8urfeC8 SOlids,
pro8pt cleenup of spU 18, fre-
quent ho81nV of residue..
Short-tena risk 18 Introduced
by tr8nsport to landfill.
(llell transport "III be In-
v"stlvated If this eltem.-
tlve I. selected.1
see Alternative I.
See Alt.m.tI.. I. Tlen8port
to I.ndflll will have .nvl-
rOD8eot.1 I.pecte .s8acleted
with truck eeleslon8, tr.f-
ftc.
8 to 9 eonths. Seesonel 11.-
It.tlo081 .streeel, h.ev,
relo .t TWCA could 1181t .s-
cavetlon, estreee cold .t
landfill could 11.lt pl.ce-
..nt of "e8te.
Not .ppllcable.
Beneftclal--re...ves soltds
I'''''''"''"U, fn,. sHe.
AlternaU.e 1
ae.oval, sOlldlflC8tlon,
OII.lt. Dl.poeel
- See Alt.metl.. 5.
See Alternatl... 5 and 6.
See Altematlv. I.
See Alternative 6.
9 to 1080nths. Se.sonel 11.-
It.tlons: estr...I, beev,
rain et TWCA could 11.lt esca-
v.tloo and solidification,
extreee cold at landlill
could 11.lt pleceaeDt of
"e8te.
Exect results 01 pouo1eulc
reaCtion cennot be predicted,
but technolog, 18 DOt diffi-
cult to construct or operet~.
.,
Reneftclel--ceeoves sol id:i
-------
Cr Her 10
Abillt, 10 Monitor Effective-
ness of AIe.ed,
- Magnitude of Risk II Monitoring
Falls land exposure pathwa, goea
unllel"cted'
A~tlllsllative Feaslbillt,
l.J
o
Avallabillt, of Necessar, Equlp8ent and
Speclallats
- Technoloqles
- Construction
[qulpeent
- ' Special Services
Transpurttlltlon
Of "sll~ I.olull t 111111'
Allernathe 1
Barrier Rella, Capping.
'Iood Protection
Sole re.alnlllg pathway la
potential .Igratlon to ground-
water, wells would be 8Onl-
tored.
Rlak poaed b, cont88lnant
81gratlon to groundwater will
be .valuated during ov.rall
alte RI/t'S.
Conault with Stat. Departeent
01 'lab and Mlldllfe If flood
protection will requlr. alter-
ation of Truax Creek. Conault
wltb Corpa of OIglneera 11
flood protectton will 0190111-
cantl, alter floodplain. Con-
ault wltb 't)~ to be aur. cap
aatlaflea aolld waste closure
requlr_nta.
Technoloqles are avallahle
and bave been de80natrated
for sl.llar applications.
Grading of tbe LRSP elter
placlnq 01 Sch8ldt Lake
aollda wlU require s.-e
expertise b, tbe drag line
operator.
Only conventional equlp8ent
will be required.
A special contractor will be
required to Instell tbe HVPE
liner. Ha.ardous waste-
trained well driller needed
for barrier wella.
Dump trucks with tallqate
gaskets will be used.
Nul dilltl.. dlolt..
..-"
TaMe 7
IConllnue61
Alternative 5
Re8oval, Solidification,
ta.lt. Disposal
Sole re..lnlng pathva, I. po-
tential 8lgr.tlon to ground-
wat.r In e.ent of landfill
failure, wella a04 leachate
would be'8onItored. £olatlng
groundwater cont88lnatlon at
LRSP will be addreaaed In
overall alt. Rl/fS.
See Alternative 1. Rlak la
allgbt because aollda are
,olldlfl.d, landfill la l8p8r-
888ble, leacbate collection
provided.
Right-of-way of eaae..nt
needed froe MIIlaaett. Indu.-
trl.a and Burlington Northern
R.llroad for haul roada bet-
wean LRSP and tb. landfill.
CODOult wltb D~ to detenlne
If landfill deal911 aatl.fle.
solid waat. dlapoaal and clo-
aure requlr...nta.
Se. Alternative 1.
Landfill .,..1911 aa_. us.
of COD.entlon.l dike con-
.huctlon. Sultahle ..t.rl-
al. ere avall8bl. In vlcln-
Itr.
A a,at. of .peelalhed
equlp8ent I. required for tb.
solidification treetaent
plant. Part of tbe plant
wi 11 need to be fabricated.
Special contr.ctora required
to Install aolldlflcatlon
plant and to Insta 11 II)I'E
Hner.
See Alternative 1.
Hot el.pllc"ble.
,Alternat he 6
Ale-val,
Offslt. Dlsposel As-I.
Solids depoalted ot landfill
will b. sonltored. EKlatlnq
groundwater contaalnatlon at
TIICA wOI be eMrea.ed In
overall .Ite Rl/fS.
"Inl8al rlak If sonltorlng
folIa at ollalto landfill
becau88 of re80te08aa of
alt..
Right-of-va, or eaa...ot need-
ed fr08 Nllla88tte Industrl.a
end Burllnqlon Northern Rall-
roed for haul roads between
LRSP and 1-5. Consult wltb
DIQ to detemlne If 18IIdll 11
dealVO .atlaflea anlld waat.
dlaposal and cloaur.
requlr...nta.
See Alternal he I.
Gredlng of haul roeda to 1-5
would not poae e probl_.
Onl, conventional equlpaent
required.
No 8p8Clal servlcea required.
SeaHruck-.ounled sludge
boxes tbet are water-tlghl
will be used. IRaII trans-
port vlll be Inveallqated It
Alternative b or 1 Is
selecled.)
Av..lla"le.
AUernaUv., 1
Ae8oval. Solidification,
, OIfalte DI.posal
See Alternative 6.
See Alternatl.a 6.
See Alternative 6.
See Alternative I.
See Alternatl.e 6.
See Alternative 5.
See Alternative 5.
See Allernatlv."&..
-------
CrHerla
Costs
Capital
Annual OUt
tyture Replace.ent Costs Avera98
Annua I AIIount
h "spnt Wort II
AI S l'''''.''III, JO y"ars
At ~ 1""....,,1. p'''l>''tully
w
Alternative I
Barrier Nella, Cappinv,
'iooci Protection
$1.1 all lion
$U,.OO
$9,.00
$1.6 allllon
$I.8.llllon
- .-.-
Table 7
IContinued)
Alternative 5
leaowal, Solidification,
~.Ha DI.posal
$11.3 allllon
$10,700
None anticipated.
$U.. allllon
SH.8 all lion
AHernat he 6
Reaa.al,
Off.lta DispOsal Aa-I.
$8.5 al1l1011
'0
Not applicable.
S... 8. capital cost.
Sa8e as capital C08t.
" AUanaU.. 7
leaa.al, 801ldUtcaUoII
Of ,. It. Dt.po..1
$10.7 al1l1C81
$0
Not applicable.
88- 88 capital coat'.
S- aa capital ood.
-------
4 .
frcm the flood plah, tlJ: lea'.'e:.-=:l',!d~e in ?:n
high. It would requi:'e '/ery ca:'efc:l c;)"struct1on
ensure protection of the groundwater, '
2 (e? \... h Q :~ e '; " :. i,.::: : :.: ~ - ~ " :-:
and long-teT-m ~oni::f.~~~ j:
Alternative 1 leaves .the sludge where it is and does not reduce its
mobility. though it does offer protection from direct contact and flooding.'
2.
Compliance with ARARs
.
The four alternatives would all comply with ARARs; however, some would
r~quire more effort than others to comply. Alternatives 6 and 7, for example,
involve disposal at landfills already permitted under state regulations, whi 1e
the onsite landfill required by Alternative 5 would have to undergo inspection
and satisfy all substantive permit requirements. Alternatives 1 and 5 would
also have to comply with state solid waste regulations for capping and
construction. In addition, the greater amount of work at the ponds themselves
would be subject to wetlands protection statutes. Alternatives 1 and 5 wo~lG
.' require archeological surveys.
3.
Lonq-Term Effectiveness and Permanence
Both Alternatives 6 and 7 would remove the contaminated materials from
the site. Long-term maintenance would be the responsibility of the landfill
operator or as specified in the applicable state permits and licenses. The
solidification aspect of Alternative 7 increases the long-term stability of
the sludge.
Alternative 5 is less effective, as it would require
site, with higher costs because the groundwater is closer
at the proposed offsite landfills. Alternative 1 is less
it leaves the sludges in contact with the groundwater and
treatment.
O&M on the THCA
to the surface than
effective still, as
does not provide any
4.
Reduction of Toxicity, Mobility. or Volume Throuqh Treatment
The nature of the sludge makes treatment by reducing toxicity or volume
impracticable. However, the solidification treatment performed under
Alternatives 5 and 7 would make the contaminants somewhat less mobile.
Alternatives 1 and 6 do not employ any form of treatment.
\
5.
Short-Term Effectiveness
Alternative 1 presents the least risk to onsite workers, as most of the
sludge (except that in Schmidt Lake) would be left where it is and the
imRlementation time is fairly short.
The other alternatives all involve moving the sludge and therefore
present more opportunities for workers to be exposed to contaminants. In
addition, Alternatives 6 and 7 present the possibil ity of transportation
accidents. Alternative 5 would not present this particular problem, but the
longer implementation time would mean greater opportunity for exposure.
-------
"
\..,.
Imp1 ementabi 1 j t'l
None of these alternatives would be difficult to implement. Al~ern~tYve
6 would be the most easi 1y imp1~mented, as it involves only removal and.
transportation. Alternative 7 would add solidification, marginally increasing
the time and costs involved. Alternative 1 would be more complicated because
of the dike and extraction. well construction activities. Alternative 5 would
be still more complicated because of additional substantive permit
requi~ments for the onsite landfill. as well as construction of the landfill
itself. . .
7.
Cost (estimated)
Alternative 1 is the least expensive:
construction and $31,800 annually for O&M.
$1.1 mi 11 ion capi tal for
Alternative 6 is next least expensive, at $8.5 million with no O&M.
" Alternative 7 would have capital costs of $10.7 million; it too requires no
O&M.
Alternative 5, the most expensive remedy, has capital cost of
$11.3 million and O&M o~ $70,700 per year.
8.
State Acceptance
The Oregon Department of Environmental Quality (DEQ) has been closely
involved with the development and review of the RI and FS processes. DEQ
commented on the RIfFS, worked with EPA on the Proposed Plan, and attended the
public meeting presenting the Proposed Plan to the community. They also
reviewed and commented on the draft Record .of Decision (ROD), providing
updated information on TWCA's compliance history.
The state's letter of concurrence with the remedy is attached as
Appendix B.
9.
Community Acceptance
Community members who commented on the Proposed Plan favored
Alternative 7. Most agreed that it had the highest level of environmental
protection; some felt it was higher than necessary but hoped that this remedy
would satisfy community concerns aboutlthe site. Some commentors had concerns
about the 1andfi11ing component of this alternative but preferred it to other
options. The most frequent concern voiced by local residents and officials
was that the matter should be settled and controversy ended.
The next most popular alternative was number 1, which was seen as
providing sufficient environmental protection at a much more reasonable cost.
However, those preferring this alternative had no serious objections to
number 7. Ne~ther of the other alternatives was preferred by ~ny commenter.
The attached Responsiveness Summary (Appendix A) provides a complete
summary of public comments received during the comment period.
. .'.
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THE S~l~CTED REM~DY
Based upon considerati~n for the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, both the EPA and the state
of Oregon have det~rmined that Alternati~e 7 (removal, solidification, and
offsite~disposal) is the most appropriate remedy for Operable Unit #1 at the
THCA site. It has been selected because it consistently ranked among the best
choices under all the ranking criteria except cost. It effectively reduces
the likelihood of contact with the sludges and ensures that contaminants are
not transported into groundwater, surface water or air. Human health and
environmental risks associated with the identified routes of exposure will be
eliminated or controlled by this remedial action.
Approximately 85,000 cubic yards of sludgE will be excavated from the
LRSP and Schmidt Lake. The sludge will be mixed with a solidification agenr
.' such as Portland cement. Thi s wi 11 improve handl i ng characteri sti cs, reduce
mobility of contaminants, and increase the structural strength for landfi lling
and capping. The mixture will then be transported to an offsite permitted
. solid waste disposal site. The mixture would be placed in a separate monocell
(adequately protected from coming into contact with other wastes) and capped
in accordance with state and local disposal requirements, applicable permit
conditions, and EPA approval. The sludge mixture can be taken to a solid
waste landfill because it is not a RCRA hazardous waste. The monocell must
have a liner and a leachate control system. This Interim Action, including
the removal and relocation of the sludges, is scheduled to be completed within
three years of the signing of the Consent Decree.
/
The sludge relocation removes all of the sludge materials from Schmidt
Lake and the LRSP, both areas which could be impacted by a one in 500 year
flood. The sludge material must go to a permitted solid waste disposal
facility which by definition cannot be in a floodplain. No location or
\facility is specified by this ROD, but two facilities were identified in the
'FS which meet the state requirements for a disposal facility. There are also
out of state permitted landfill disposal facilities available.
The disposal facility must not comingle the THCA waste sludge materials
with any other waste; i.e., it must be a monofill. This is to facilitate
compliance with any monitoring requirements that may differ from those for
other wastes. A suitable cap must be placed which prevents sludge exposure to
people or the environment outside of the disposal unit. The cap must also
protect people from the release of radon contained or created from
contaminants in the sludge.
A treatment step is part of this remedy. Prior to relocation in the
permitted landfill, the sludges will undergo partial treatment by using a
solidification agent like Portland cement. The object of this partial
solidification treatment process is to reduce the free water co~tent of the
sludges, make the ~ludges easier to handle using conventional equipment. and
reduce the mobility of contaminants by chemical and physical processes.
Although this treatment process will not make the sludges into rigid solids.
it will improve the final handling characteristics and provide a level of
treatment to the sludge material~. The FS identified onsite treatment as part
of the recommended alternative. Offsite treatment (e.g., at the di.sposal
faci lity) may be considered during the design phase, jf EP~ can be assured it
'II; 11 be performed in accoI'dance '."i th CERCLA and meet ARARS. .
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The risk recucrion b/ this Inte!"i:"n ,..lct;on is rr.:);n an eS:1m"l:ed:3 '2
-------
iHt STA iUiORY
~--~"'\J'!"'" -~,""'I'A
I !~ : ~ ""'il: :d;: Iii >:!\
L.; i.. I i..! II ! ..It: I ! ~ II 11 '"
Protection of Human Health and the Environment
.'
The selected remedy will protect human health and the environment by
removing the sludge from the floodplain; eliminating it as a sourCe of onsite
groundwater contamination, and placing the material at a site where there wi 1 1
be minimal exposure to it by any pathway. The 'sludge will be mixed with a
solidifying agent to reduce contaminant mobility. Special design features
(composite 'liners, leachate collection, and detection monitoring) will control
the migration of contamInants to groundwater at any approved proposed disposal
facility. A cap will be placed over the material in accordance with state
permit requirements, reducing possible exposure to radon or contaminated
dust. Specifically, radon-226 will decay to solid particles before reaching
the surface if contained under a cover of approximately five feet of normal
soil, or less for compacted clay. A minimum of four feet of final cover,
including at least one foot of clay material, would be required at the offsite
disposal facilities under consideration.
The proposed offsite disposal facilities will provide protection from
exposure to the sludges by dermal contact, ingestion, and inhalation. The
sites being considered in Oregon are located in relatively unpopulated areas,
with low average precipitation and a minimum of 100 feet depth to
groundwater. Should the sludge be disposed in another state, EPA would,
regardless of that state's permitting requirements, stipulate that disposal be
in a solid waste facility that meets RCRA Subtitle D requirements and includes
. the following features: monocell, cap, liner, and long-term monitoring.
Compliance with ARARs
The selected remedy of excavation, solidification, and offsite disposal
. will comply with all applicable or relevant and appropriate chemical-specific,
\ action-specific, and location-specific requirements (ARARs). These are listed
below. This analysis does not include ARARs that might apply in states other
than Oregon.
Action-specific ARARs:
1.
Clean Air Act requirements (40 CFR' 50-99) for control of dusts during
excavation activities. In addition, the Oregon DEQ regulates emissions
of hazardous air pollutants (including beryllium and mercury, two
contaminants of concern identified in the sludge) under OAR 340-25-470
and 340-25-480.
2.
Oregon Solid Waste Regulations (OAR 340-61), which address the siting,
construction and operation of solid waste disposal faci lities in the
state of Oregon.
3.
Occupational Safety and Health Act (29 CFR 1910) requirements for \oJorkel"
protection training and monitoring during remedial action.
4.
Oregon State Health Division Requirements (OAR 333-104), which pro'fide
standards for protection f,'om radiation hazards.
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....
.... .
Oregon Environmental C12anu~ R~les (OAR 3~O-12Z-C9C). w~j:h ~~:1~:~
requirements to restore the environment to levels of contamination that
are equal to background or protective of publ ic health and the.
environment. .
.'
Oregon Public Utility Commission Rules, which regulate commercial
. transportation, including transportation of solid waste.
Chemical-specific ARARs:
6.
-1.
Clean Water Act requirements for discharges under NPDES permits, which
regulqte the water removed from the sludges to be treated at the existing
TWCA wastewater treatment plant.
There are currently no chemical-specific ARARs for sludges or solids.
Location-specific ARARs:
1.
Executive Order 11988, Protection of Floodplains (40 CFR 6, Appendix A)
Executive Order 11990, Protection of Wetlands, which requires that
actions minimize the destruction, loss, or degradation of wetlands.
2.
3.
National Archeological and Historical Preservation Act, which requires
action to recover or preserve artifacts for construction on previously
undisturbed ground.
Other Criteria, Advisories or Guidance To Be Considered for the Selected
Remedial Action (TBCs):
1.
U.S. Regulatory Commission's policy statement on be10w-regu1atory-concern
radioactive material (December 12, 1988, Federal Register) was included
as criteria considered in evaluating the proposed disposal options.
~ Cost Effectiveness
The estimated cost to implement the selected remedy is $10.7 million,
which was in the middle range of the final alternatives evaluated for.this
operable unit. This is within an order of magnitude of the costs associated
with the least costly alternative (Alternative 1) and requires very low
operation and maintenance. It offer~ several advantages by removing a source
of groundwater contamination and providing a much higher degree of certainty
that future risks associated with various pathway exposure will be minimized
by partially solidifying the sludges and relocating them to a facility
designed and permitted for disposal of such wastes.
Land Disposal Restrictions
The selected remedy does not r"equire the placement of any RCRA haz:!l"dous
'tJastes either on or offsite. Therefore, the Land Disposal Restrictions do not
apply.
-------
Ut~ 1"i:atior; cf'Pe:~marlent SC;Jt~cn~ ant ,~.~t2r:-i~:1''/'2 ::"e~:"7",=:'~:: ~=::-.,-:
Re sou rc e Re c::)\/ e r ~I Tee h no i cq i e s D 1: he ~lax-fmu;;;-T< r~~~-,:-~c-::acnc~ b ~ e
,- ", - ~ - .-
- .. , .... -
£PA and the state of Oregon' have determined that the selected remedy
represents the maximum extent to which permanent solutions and treatment "
technologies can be utilized in 'a cost-effective manner. The sludge will be'
partially solidified to reduce contaminant mobility. ,The nature of the sludge
material (low permeability, insoluble co~taminants. low organic content) made
it impr~ctica1 to apply other treatment technology process options that were
considered in the initial screening of alternatives. In addition, the'
treatment options that included further dewatering of the sludge were screened
out because ~f concern over increased dust and radon exposure.
The two permitted offsite disposal facilities identified in the FS would
need to provide long term assurance that risks associated with contaminant
migration' will be minimal. Institutional controls (solid waste disposal
pe.rmit requirements> will ensure that the sludge mixture will continue to be
"isolated from the surrounding environment.
Preference for Treatment to Reduce Toxicity. Mobility, or Volume as a
Principal Element
The partial solidification proposed in the preferred alternative wi 11
help reduce the risk of migration of contaminants to groundwater, increase the
strength of the material for landfi11ing and capping, and provide some
reduction of radon release.
As indicated above, the nature of the sludge makes treatment by reducing
toxicity or volume impractical. A number of treatment technologies were
'initially evaluated and screened out for this operable unit.
The FS for the overall THCA site will evaluate alternatives for reducing
toxicity, mobility, and volume of contaminants that are identified in the
ongoing RI. The statutory preference for treatment as a principal element of
~the overall site cleanup will be addressed by the final ROD for this site.
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.I
,
APPtNDICtS
RtCORD Of DtCISION
TELtDYNt WAH CHANG ALBANY
OPtRABLt UNIT #1
ALBANY, ORtGON
Appendix A: Responsiveness Summary
Appendix B: State Letter of Concurrence
\ .
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;. PPF\IY!:;': "
-. .........-
~''=~Eii~C.er I ~C'~
~
RESPONSIVtNESS SUMMARY
. TELEDYNE WAH CHANG ALBANY
OPERABLE UNIT #~ INTERIM ACTION
Overview
The Teledyne Wah Chang Albany (THCA) facility is located in Millersburg,
Oregon (about 3 miles north of Albany) in the Willamette Valley of western
Oregon. The TWCA Superfund site includes a 110 acre plant site property and
the 115 acre facility known as the "farm site". The entire facility was
placed on the Environmental Protection Agency's (EPA) National Priorities Lis:
.' (NPU in 1983. A Remedial Investigation and Feasibility Study (RI/FS) is
underway for the entire facility. This responsiveness summary addresses
public comments made regarding a proposed Interim Action at the facility.
. This Interim Action addresses cleanup of the Lower River SOlids Pond
(LRSP) and Schmidt Lake which are unlined surface impoundments that previously
received process wastewater from the various operations at the site.
The facility has been operating since 1956 when the Wah Chang Corporation
began operation of the U.S. Bureau of Mines Zirconium Metal Sponge Pilot
Plant. New facilities have been added at the site which now include the
. production of zirconium and hafnium-sponge from zircon sands, melting and
fabrication operations and facilities for the production of other speciality
metals. Solids generated from'the process wastewater treatment system have
been stored in a number of surface impoundments; including the and Schmidt
Lake prior to 1980.
Since 1980 wastewater sludges have been stored in the farm pond~' which
were originally part of this Interim Action, but will be addressed under the
investigation of the entire facility. The TWCA sludges have been the subject
of several ballot initiatives, regulatory control processes, and environmental
group attention since the early 1980's primarily because of the small amounts
of radioactive materials and the location of two of the ponds in the
floodplain of the Willamette River. Inl1979, THCA modified their production
process to significantly reduce the concentration of radioactive compounds in
their wastewater sludges.
In May 1987 TWCA signed an agreement (Consent Order) with EPA to
investigate the nature and extent of the contamination problems at the
facility and develop alternatives for cleanup where necessary. This work is
called a Remedial Investigation and Feasibility Study and is currently
underway. As part of this Order, EPA and TWCA agreed to addres~ the LRSP,
Schmidt Lake, and Farm Pond sludges prior to completion of the RIfFS for the
entire facility. This action was due to concern over the sludges potential
contribution to groundwater contamination, public concern over the materials,
and their location in the floodplain.
-------
. Althouah the Farm FondS were Dart of this investigation.
addressed i~ t"he RI/rs fo,' the r-eiT,air'uEI' of the site and .'1111
necessary,
r he':, ;,': ~ i ~ C1 .::
bE c12a~2d uc j~
On August 16, 1989 EPA's published it's preferred alternative for cleanup
of the two sludge ponds in.a document called a Proposed Plan. The Proposed.' .
Plan as well as the reports of the investigation of the sludges were released
for public comment. EPA's preferred alternative included:
~
o
Removal of the sludges from the LRSP and Schmidt Lake, .
Solidification of the sludges by adding Portland cement to improve
handling characteristics and to reduce contaminant mobility; and
Relocation of .the mixture to a permitted offsite disposal facility.
o
o
Background on Community Involvement and Concerns
As described above, the sludges have been the subject of ballot
initiatives, regulatory control processes and concern by environmental
o' groups. Local residents, state legislators, city (Albany and Mil 1ersburg)
officials, and the media have all expressed interest in the TWCA sludges over
the years. Recently, local officials have expressed their support for TWCA
and EPA's Proposed Plan.
Environmental activists affiliated with statewide or national
organizations have been particularly involved in the activities related to the
TWCA sludges. By far the most vocal of these has been Fore1aws on Board of
Portland, Oregon, which has been involved in sponsoring three ballot measures
aimed at insuring the sludge pond wastes are removed from the floodplain and
treated as low-level nuclear wastes. Greenpeace has also been interested in
. TWCA sludges and staged two protests in 1985.
Overall, community concerns centered around the sludges' location in the
floodplain, the low level radioactive nature of the sludges, and the potential
for groundwater contamination from the unlined storage ponds.
...
A list of community relations activities conducted by EPA can b~ found at
the end of this summary.
Summary of Comments Received
EPA held a public comment period from August 18, to September 16, 1989,
which was extended to October 16, 1989, 'upon the request of a commentor.
Comments and questions raised during the public comment period on the Proposed
Plan for Operable Unit #1 of the TWCA site are summarized below and are
grouped by category.
As part of the public comment period a public meeting was held on
September 6, 1989, at Linn Benton Community College in Albany, Oregon. About
20 people attended the meeting and ten people gave comments. Comments given
at this meeting are included in the following summary. The meeting consisted
of presentations by EPA staff and CHZM Hill
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C1:'~~es 0~ the t:an:Ci-iot =1-2!TI ~he ~e~~~ng ~re ~','ai :~~'~ 3~ t;,; t'~~-.
Public Library, Albany and ~il lerSburgCjty Halis. E?A's Seattle cf~jcs a~c'
the .Portland office of the Dep~rtment of Environmental Quality (DEQ).
RESPONSIVENESS SUMMARY
!
Superfund Process and Policy
/
~
The following comments were made about the process used to arrive at the
preferred alternative.
Comment: One commentor.was concerned about separating the sludges as
operable unit from the rest of the site. The commentor was concerned
information that is to be developed in the future (during the overall
RIfFS) t~at may impact the decision now being made for the sludges.
an
about
site
Response: EPA's Proposed Plan for the sludge ponds
" considering future long term options. EPA believes
consistent with future actions; however, it will be
as part of the overall site RIfFS.
was selected while
the action will be
reviewed for consistency
Comment: One commentor expressed concern that the sludge issues were not only
of concern locally but that individuals state-wide have been interested: The
commentor suggested that additional public meetings be held in Salem and
Portland.
Response: CERCLA 9117(a)(2) provides for an opportunity for public meetings
on the Proposed Plan to be held "at or near the facility at issue". Although
. this does not ,preclude holding additional' meetings elsewhere, EPA believes
that the meeting was widely publicized offering an opportunity for anyone to
attend. The meeting was primarily publicized through the fact sheet which was
sent to all individuals who had previously been interested including
individuals outside the Albany area. A notice of the meeting was also
. published in the newspaper. EPA extended the public comment period for an
\ additional 30 days, during which time no additional requests for public
meetings in other locations were received.
Comment: One commentor stated that further evaluation should be conducted to
determine how each alternative would impact future cleanup activities that may
be needed at the site.
Response:
This type of evaluation will be part of the overall site RIfFS.
Comment: One commentor suggested that the radiological analyses have all been
done by THCA and that independent sampling and laboratory testlng should be
done.
-------
Kesponse: EPfi contraC1:ors have pro'.;ided oversight fOl' al: RI/F"S S3.moi in? ('.re;
analyses of samples has been done with EPA approved methods. EPA has obta~nEO
split samples and has analyzed them independently from THCA labs as parto~
the oversight. EPA a1s6 does qualitY aisurance reviews of all data to insure
they meet agency standards, and is satisfied with the quality of the data fr0m
the THCA site. . .
The split samples for radiological analysis were analyzed by the Oregon
Health~Division laboratory. The EPA radiation office has also reviewed the
radiation oversight program.
The Preferred Alternative
Comment: Several state and local officials, a union leader, and a local
newspaper publisher volunteered their support for TWCA and for an expeditious
cleanup of the sludges. They hope this will end the years of controversy over
the site.
" Response:
Comment noted.
Comment: One commentor expressed disagreement with screening out
Alternative 1, which would cap the sludges in place. He stated that the
preferred alternative assumes a greater risk than is actually present, and
that public disapproval is not a legitimate reason for discounting an
alternative. He further stated that such a lower cost remedy would be
sufficiently protective.
Response: The risks to public health and the environment are judged to be
higher under Alternative 1 than Alternative 7, because Alternative 1 does not
. reduce the mobility of the contaminants, and groundwater is adversely
effected. Also, Alternative 1 requires long-term maintenance of dikes, and
groundwater pumping and treatment. Therefore its long-term effectiveness is
less certain than Alternative 7.
.. Comment: A local official noted that preference for Alternative 7 se.ems to be
'based partly on the reduction of risk that would result from removing the
sludges from the floodplain. However, the commentor noted that it appears
there is no evidence that a flood which dispersed the sludges would cause
detectable contamination downstream.
Response: EPA considered several factQrs in its support for Alternative 7
including: removing a potential source of groundwater contamination as the
ponds are unlined; and reducing potential human contact with the sludges.
Although the risk of dispersal of the sludges through flooding is of concern,
the risks resulting from such dispersal cannot be quantified. Because of this
uncertainty, Alternative 1 is considered less effective in protecting the
environment than other alternatives which remove the sludges from the
floodplain. .
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~
Comment: One commenror bejjevea rhat tn~ sludge materials ~h0uJd nc: je
placed jn a municipal la~dfill and that special attention should be given 'td
their' disposal.
Response: EPA and Oregon D£Q have determined that the sludges are not
"Hazardous Waste" as defined by law. Accordingly, there is no regulatory'
basis for requiring that the material go.to other than an approved solid waste
disposa1 site. However, EPA is requiring that the sludges be placed 1n a '
separate area isolated from other wastes (monoce11). Also, the monoce11 must
be-lined, capped, and regularly monitored.
Comment: Two commentors; who both identified themselves as env1ronmenta1
activists, are concerned that the sludges will be mixed with other wastes when
they are disposed in a landfill. They felt that these wastes deserve special
attention, because they are radioactive.
.'
Response: The sludges would be placed in their own separate cell from other
"landfi11 wastes. Radioactivity levels of the sludges are below regulated
levels and the landfill cap, which is required as part of the relocation to a
permitted landfill, would reduce exposure to the contaminants.
Comment: One commentor indicated that the sludges should be capped with an
impermeable cap once placed in the landfill.
Response: A suitable cap will be placed over the waste to reduce exposure to
the sludge. The permits for the landfills under consideration contain
specific requirements for soil compaction and the permeability of the cap
material, which prevents or minimizes the infiltration of rainwater into the
'fill. The exact design of the cap will be determined during the Remedial
Design phase of the project, following the issuance of a Record of Decision.
Supplemental Risk Assessment
\ The following comments were made about the supplemental risk assessment
'prepared by EPA. The results of the supplemental assessment were presented at
the September 6 public meeting and were published in a document in September
1989 which is available at the information repositories previously mentioned.
Comment: One commentor expressed concern during the pUblic meeting that a
full analysis of the risk assessment had, not been completed by EPA. The
commentor felt that because a written summary was not available at the public
meeting, this indicated EPA was not finished with its analysis.
Response: EPA had concluded its further analysis of the risk assessment and
had completed a supplemental assessment at the time of the September 6, 1989,
public meeting. The final analysis was presented at the meeting, however
because written documentation was not available at the time of the meeting,
EPA extended the pUblic comment period to October 16, 1989, to al low time for
pUblic review and comment on its supplemental risk assessment. This extension
was at the request of the commentor.
Comment: A local official commented that EPA used too many assumptions in its
supplemental risk assessment that were far from actual existing scenarios.
-------
.
Response: In Qrder to b~ pro-;:ecthe of pub,;.: :',eaic:J. ar:.:.: tile .:;i.,;:'c:,-:-;e",:: :..,:,-
the long term, EPA must leak at all possjble futu's ~~2S cf a sj:a. ~1:h:~;~
some of the scenarios used do not existtocay, EPA also attemots to protect I
against future adverse i~pacts a site may have on publ ic health or the
environment.
.'
Comment: Teledyne Hah Chang commented that a risk assessment based on no
action was not required as part of the work plan agreed upon between EPA and
THCA. They further commented that a no iction alternative was not appropriate~
Re~ponse: Although EPA agreed that THCA did not have to consider a "no action
alternative" for the sludges, upon receiving the final reports developed by
THCA and its' consultants, EPA felt information on the potential risks if no
action were taken was needed to help determine the best course of action.
Because EPA had agreed that THCA need not conduct such analyses, EPA elected
to conduct the additional work.
Comment: TWCA indicated that chromium values from the RI were based on total
"chromium. THCA commented that assuming that all of the chrome was chrome VI
for the supplement risk assessment was inaccurate.
Response: For clarification of the measurements of chromium at the facility
see the "Teledyne Wah Chang Albany Endangerment Assessment". Total chromium
was measured in sludges from the ponds. Since the type of chromium was not
specified, EPA assumed for its supplemental risk assessment that the most
toxic form (chromium VI> was present in order to be more protective of public
hea lth .
Comment: TWCA commented on the reference "Personal Communication" used to
'reference a dose conversion factor in the supplement assessment. They felt
that using such a reference was insufficient.
Response: References such as "Personal Communication" are used in the risk
assessment because at this time certain parameters can only be determined
\based on best professional judgement.
Comment: TWCA clarified that ambient air modeling of concentrations of the
pond solids was performed. TWCA indicated that the results of the model ing
showed that the radioactive particulate concentrations averaged 23.5 ug/m3
for the LRSP and 16 ug/m3 for Schmidt Lake. They indicated that these values
were well below the value used in the T~CA endangerment assessment.
Response: EPA was not aware of the modeling described in THCA's comments.
The information provided to EPA by TWCA in their endangerment assessment
indicated that ambient air concentrations were based on theoretical levels
rather than concentrations predicted through modeling. To maintain
con~istency with the exposure assumptions used by Teledyne Wah Chang in their
endangerment assessment, EPA used the same theoretical concentrations.
-------
'ir
. '
C08~ent: TNCA commented that jn c~rj~ct'~; t~s e~j~n~er~s~: a:s~s:,:e~~ ,:
used engineering judgement and EPA guidance as we1l as estimareo risks wn1ch
were, likely rather than'''extreme''. n~CA indicated that its opinion is that
estimating risks which are very unlikely (extreme)' exposure scenarios providft
little or no decision making value unless the actual results show low riSk;,' ,
Response: EPA finds value in evaluating all possibilities in order to be
protective. This allows for a higher de.gree of confidence and a wider margin
of safety in risk management decisions.
Other Concerns
Comment: An environmentalist commented that a careful analysis should be
conducted of sludge deposited by TWCA on agricultural fields near the TWCA
site.
Response: These fields are currently considered to be outside the bounda:'ies
" of the TWCA site and thus beyond the scope of this Interim Action, However,
further evaluation will be done to determine whether these fields would be
appropriately considered as part of the overall site RIfFS. Currently
responsibility for this issue belongs to the state of Oregon and this comment
has been passed on to DEQ.
Comment: An environmental consultant had specific questions about the process
for solidifying the sludges and the requirements for a bidder to bid on 'the
work. Specifically the questions were as follows:
1)
Can the Portland cement or other approved material be added to the sludge
at the point of delivery (as opposed to on site before transportation)?
Response: Although EPA's proposal called for solidification before
transportation, a final decision will be made during "Remedial Design" at
which time all of the specific processes will be outlined. The location of an
. offsite treatment process would have to be as protective to health and the
\ environment as an onsite system to be considered. '
2)
Would EPA permit a bidder to make a fully loaded 600-mile test run of a
specifically designed transport vehicle?
\
Response: More details would need to be provided but nothing precludes tests
to be made prior to final design.
3)
Would EPA permit a bidder to use an approved water reduction process in
order to reduce the weight of the sludge as well as increase its
stiffness?
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Response: The action of the sOlidification process is t\'J(:-f.J~.j: j:TC').~'iC
rhe sludge handling Characteristics and binding contaminanrs t.J ret~:e .
migratjon. The methods for achjeving these properties are not specified .~~
the Record of Decision. However, the RIfFS raised concerns about reducing the
water content of the sludges because of increased risk of releasing radon. .
4)
What is the purpose of requiring Portland cement, and can this step be
eliminated?
~
Response: See above. Tests performed on the sludges using Portland cement
d~d improve handling characteristics and improved the binding characteristics
of the cont~minants. .
Attachment
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-
. .
co;.;r.;~r~~T'T'
RELA7IONS ACTI~I7IES
.The following EPA community relations activities have been conducted at
TWCA under Superfund:
,
o
,
December 1982 - site proposed for inclusion on the National
Priorities List (NPL).
#
o
October 1983 - site listed on NPL.
o
February-May 1987 - local citizens and officials interviewed in
o~der to prepare a Community Relations Plan. .' .~.
o
November 1987 - final Community Relations Plan issued.
o
November 1987 - Information Repositories established at Albany
Public Library, DEQ (Portland>, and EPA Region 10 (Seattle).
o
November 1988 - RIfFS work plan for entire facility sent out for
30-day public comment period. Work plan was placed in information
repositories and a fact sheet was published.
o
February 1989 - Fact sheet published announcing EPAls approval of
the final work plan.
June 1989 - Fact sheet published announcing that TWCA had submitted
a draft RIfFS report to EPA for Operable Unit #1.
o
o
August 16, 1989 - Interim Action (Operable Unit #1) Proposed Plan
published.
August 18 - October 16, 1989 - Public comment period for the Interim
Action Proposed Plan.
o
o
September 6, 1989 - Public meeting for the Operable Unit #1,
Proposed Plan, held in Albany. This meeting was announced in the
Proposed Plan and a local newspaper.
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Department of Environmental Quality
NEIL GOLDSCHMIDT
OOvEA~
811 SW SIXTH AVENUE, PORTLAND, OREGON 97204-1390 PHONE (503) 229-5696
;
DEt 2 0 1989
Mr. Robie G. ~ussell
Regional Administrator
U. S. Environmental Protection
1200 Sixth Avenue
Seattle, WA 98101
Agency
Re:
Teledyne Wah Chang Albany
Record of Decision
Dear Mr. Russell:
The Oregon Department of Environmental Quality (DEQ) has reviewed the draft
Record of Decision, for Operable Unit Number One (sludges), at the Teledyne
Wah Chang Albany (TWCA) Superfund site. DEQ concurs with EPA's selected
remedy (i.e., removal, solidification, and off-site disposal), with the
following condition: .'
If the sludges are to be sent to a disposal site in Oregon, the
disposal site must hold a valid Solid Waste Disposal Permit or
Hazardous Waste Disposal Site Permit, issued by the DEQ, and must
obtain specific written approval from the DEQ to accept these
wastes.
I find that this alternative provides the best balance of protectiveness,
cost effectiveness, and the use of alternative treatment technologies, as
required by ORS 466.573.
I am pleased that DEQ, EPA, and TWCA hav~ reached agreement on this issue.
As you know, the presence of these sludges in the floodplain of the
Willamette River has been a concern to many Oregonians. I look forward to
the swift implementation of the selected remedy and to continued good
working relationships with EPA and TWCA on the investigation and cleanup of
the remainder of the site.
~~
W1}:m
Site\SM2672
cc: Neil Thompson, EPA
Al Goodman, EPA, 000
Mike Downs, ECD, DEQ
Steve .Greenwood, HSW, DEQ
Fred Hansen
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U.s. ENVIRONMENTAL PROTECTION AGENCY
. REGr'ON 10
1200 Sixth Avenue
Seattle, Washington 98101
"
IV 'Dr/hC t C-t J-e of
ADMINISTRATIVE RECORD INDEX
for
TELEDYNE WAH CHANG ALBANY SUPERFUND SITE
Albany, Oregon
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INDEX TO ADMINISTRATIVE RECORD FOR TELEDYNE VAH CHANG ALBANY
SECT ION 1.0 SITE IDENTIFICATION
..
Doc II fl.!.£ Type/DescriDtion Oate fa! Author/Organization Addressee/Organization Ooc Location
1.1
Correspondence
AR 1. 1 0001 1.1 Correspondence Letter/Preliminary evaluation of 5/17/77 2 Vf'llfam Young, Director/ Vincent de Polx,
radiological aspects of plant Oregon Department of President/Teledyne Vah
operations Environmental Quality (DEQ) Chang-Albany (TVCA)
and Keith Putman,
Administrator/Oregon Sate
Health Division (OSHD)
AR 1.1 0002 1.1 Correspondence Notes/Discussion with Ted 5/13/80 3 Bob Stamnes/Ecology and Files
Groszkiewicz from DEQ regarding Environment, Inc.
disposal pits, lagoons, and ponds
AR 1. 1 0003 1.1 Correspondence Letter/Sampling of the Willamette 6/30/81 11 Karen Veliky, Mitchell David Stewart-Smith and
River and Conser Slough with Lyle, Jack Dymond, and Bill George Toombs/OSHD
attached maps and notes Rugh/Oregon State
University
AR 1.1 0004 1.1 Correspondence Memorandum/Status report on TWCA as 11/23/81 9 Hussein Aldis/Ecology and Bill Schmidt/Ecology
controlled vs. uncontrolled Environment, Inc. and Environment, Inc.
hazardous waste site
AR 1.1 0005 1.1 Correspondence Memorandum/Review of status report 12/02/81 2 Carolyn Vi I son/Ecology and J.E. Osborn/Ecology and
on TWCA as controlled vs. Environment, Inc. Envlronmenta, Inc.
uncontrolled hazardous waste site
AR 1.1 0006 1.1 Correspondence Memorandum/Possible EPA involvement 12/1/81 Hussein Aldis/Ecology and Bill Schmidt/Ecology
Environment, Inc. and Environment, Inc.
AR 1.1 0007 1.1 Correspondence Background memorandum 9/19/82 3 Unknown Unknown
AR 1. 1 0008 1.1 Correspondenc~ Notes/Sampling at sludge ponds 9/27/82 3 Unknown Unknown
. .~
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