United States Off ice of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R10-91/030
September 1991
EPA Superfund
Record of Decision
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50272.101
REPORT DOCUMENTATION 1" REPORTNO. I ~ 3. Recipient'8 Acceaaion No.
PAGE EPA/ROD/R10-91/030
4. 111Ie and SWtItIe 5. Report Date
SUPERFUND RECORD OF DECISION 09/30/91
Yakima Plating, WA
6.
First Remedial Action - Final
7. Aulhor(8) 8. Perfonnlng Orgllnizatlon Repl No'
8. Perfonnlng Orealnlz81lon Name and Addre88 10. ProjectlT88klWork Unit No.
11. Con1r8C1(C) or Grant(G) No.
(C)
(G)
1~ Sponaoring Org8lU8llon Name and Addre88 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street', S.W.
washington, D.C. 20460 14.
15. SUpplementary No,"
16. Abatract (Umit: 200 worda)
The 0.94-acre Yakima Plating site is an inactive nickel-chrome automobile bumper
replating facility in Yakima, Yakima County, Washington. The site lies within a mixed
light commercial and residential area, and there are four schools within 1 mile of the
site. Ground water from the shallow alluvium aquifer supplies much of the domestic
and irrigation water in the Yakima Basin, and many residences adjacent to the site
utilize private ground water wells for their water supply. Yakima Plating began
operations in 1965 utilizing 20 to 30 above-ground holding tanks, which were stored
within the plating building. These tanks were used during the electroplating
operation cleaning, plating, and rinsing processes. Rinse water and spent plating
tank solutions were disposed into a floor drain within the plating room. The floor
drain was connected to an underground sedimentation tank and drain field line that
collected the sedimentation tank overflow and distributed the wastewater to subsurface
soil. The wastewater system operated from 1965 until plating operations ceased in
1990. Site assessments and investigations conducted by EPA contractors in 1984 and
1990 determined that the sludge and effluent from the settling tank were a dangerous
waste under State regulations and that the potential exists for public exposure to
(See Attached Page)
17. Documen1 An8Iyala L De8crlpton
Record of Decision - Yakima Plating, WA
First Remedial Action - Final
Contaminated Media: soil, debris, sludge
Key Contaminants: metals (arsenic, chromium, lead), other organics (pesticides)
b. Identifiera/Open-Ended Terms
c. COSA TI FieIdIGroup
18. Availability SI8tement 18. Security a... (This Report) 21. No. of Pages
None 92
20. Sec:urity a... (This Page) n PrIce
Nnn'"
'0 onRe- 2n: \4-111
(See ANSl-Z38.18)
SeeIMIru<:/i M
(Formetly NTI~)
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EPA/ROD/R10-91/030
Yakima Plating, WA
First Remedial Action - Final
Abstract (Continued)
metals from contact with contaminated surface and subsurface soil. This Record of
Decision (ROD) addresses remediation of contaminated onsite soil, debris, and sludge.
The primary contaminants of concern affecting the soil, debris, and sludge are organics
including pesticides; and metals including arsenic, chromium, copper, lead, and nickel.
The selected remedial action for this site includes removing 1,500 gallons of liquid
and 6.5 cubic yards of sludge currently in tanks and containers, and treating and
disposing of these materials at an offsite facility; excavating, treating, and
disposing of contaminated soil at an offsite landfill; excavating and decontaminating
underground tanks using a solvent or water-based solution; abandoning the tanks in
place, and covering the tank areas with clean fill; treating and disposing of any
liquids or sludges generated during the decontamination process at an offsite facility;
and excavating and disposing of 540 cubic yards of soil and underground drain lines at
an offsite facility; ground water monitoring; and implementing institutional controls
including land and ground water use restrictions. The estimated present worth cost for
this remedial action ranges from $310,000 to $377,000, depending on the type of
solution used for debris decontamination. There are no O&M costs associated with this
remedial action.
PERFORMANCE STANDARDS OR GOALS: Clean-up levels for soil and ground water are set at
the more stringent of NCP and State standards. Chemical-specific soil remediation
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RECORD OF DECISION
DECLARATION, DECISION SUMMARY,
AND RESPONSIVENESS SU~R~
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".FbR'
REMEDI.AL ACTION
AT
YAKIMA PLATING
YAKIMA, WASHINGTON
SEPTEMBER 1991
UNITED STATES
ENVIRONMENTAL PROTECTION
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
. '. :,",
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AGENCY
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TABLE OF CONTENTS
pec1ar~tion of the Record of Decision
De~i'si:on ::.sUnuliary.>' :'.." ..
section
I.
II.
III.
IV.
V.
VI.
VII.
,.
. .
INTRODUCTION. . .
. . . . .
. . .
. . . .
SITE DESCRIPTION.
. . . .
........
SITE HISTORY AND ENFORCEMENT ACTIVITIES.
COMMUNITY RELATIONS.
........
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SCOPE AND ROLE OF THE RESPONSE ACTION WITHIN THE SITE
STRATEGY. . . . . . . . .. . . . . . . . .
SUMMARY OF SITE CHARACTERISTICS. .
. . . . . .
SUMMARY OF SITE RISKS. . . . .
. . . . .27
. . . .
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . .
DESCRIPTION OF ALTERNATIVES. . .
. . . .42
IX.
X.
XI..
. . .. .
THE SELECTED REMEDY. .
. . . . . .
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STATUTORY DETERMINATIONS. . . . . . .
. . . . . 59
DOCUMENTATION OF SIGNIFICANT CHANGES. . .
. . . 62
Appendices
Appendix A:
Responsiveness Summary
Administrative Record Index
...
Paqe
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4
7
8
9
10
48
54
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I
LIST OF FIGURES
1.
2.
3.
4.
5.
6.
.7.
.Page
Location Map. . . . . . . . . . . . . . . . . . . . . 5
Sample Location Map. . . . . . . . . . . . . . . . .12
Surface Soil Distribution. . . . . . . . . . . . . .20
Background Surface Soil Locations. . . . . . .21
Conceptual site Model. . . . . . . . . . . . . . . .29
Conceptual site Model (cont). . . . . . . . . . . . .30
Defi~~.ci A:r:~as of Surfac~ .Soil. CQnta.IniJ1~!:.~on . . .. ....58
.' . . . '. . ..:. .' . .' . . I '.
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LIST OF TABLES
1. Inventory of containerized Wastes . . . . . . . 14
2. Sample Results for Tank Sludge. . . . . . . . . . . . 15
4. . Summary of Inorganics in site Soils. . . . . . . . . 18
5. Summary of Pesticides in site Soils. . . . . . ... . 19
6. Summary of Organics in Groundwater. . . . . . . . . . 24
7. Summary of Inorganics in Groundwater. . . . . . . . . 25
8. Contaminant Concentrations for Risk Assessment. . . . 32
9. Excess Cancer Risks Summary. . . . . . . . . . . . . 35
10. Excess Cancer Risks Summary (cont). . . . . . . . . . 36
11. Excess Cancer Risks Summary (cont). . . . . . . . . . 37
12. Hazard Indices for Noncarcinogens Summary. . . 38
ii
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DECLARATION
Yakima Plating
Superfund site
SITE NAME AND LOCATION
Yakima Plating Facility
Yakima, Washington
STATEMENT OF PURPOSE
. ... .This decision document. pre~ents. th~ remedial: ..action . selectE?.d..:
... by the U'. S:. :.Environmental .pxQtection. Agency... (EPA) .. ~o~ ..tlle: 'Y13-kimc;i. . ..
Plating Superfund site. in. Yakima, Washington. . The sel€cted
action was developed in accordance with the Comprehensive
Environmental Response compensation and Liability Act of 1980.
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of.1986 (SARA), and, to the extent
practicable, the National'Oil and Hazardous Substances Pollution'
contingency Plan (NCP).
. ..
.. This decision is based on the Administrative Record for this
site. The attached index identifies the items that comprise the
Administrative Record upon which the selection of the remedial
action is based.
The State of Washington concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at and
from this site, if not addressed by implementing the response
action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public, health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Yakima Plating site addresses
contaminant threats at the site by removing liquids and sludges,
decontaminating tanks and pipes, and excavating and disposing of
contaminated soils. The remedy is designed to significantly
reduce exposure to the liquids/sludges and contaminated soils.
The goal of the selected remedy is to remove liquids and sludges'
and remediate soils to levels that are protective of human health
and the environment~
The maior components of the selected remedy include:
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Liquids and sludges that are currently in tanks and
containers would be removed and treated and disposed
off-site at a permitted RCRA hazardous waste facility.
Underground tanks (sedimentation and septic tanks)
would be excavated and decontaminated using either a
solvent or water wash solution. Upon decontamination
the tanks would be abandoned in place. Liquids/sludges
generated during the decontamination would be treated
and disposed at an off-site hazardous waste facility.
Underground pipes would be excavated and disposed of
with contaminated site soils.
.
contaminated soi~s above cleanup levels would be
.excavat~d',. tre~ted~. and disposed...of . at:. a. R~so:ur
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Signature s~e~t for the Yakima Plating Record of Decision by the
U.S. Environmental Protection Agency.
~~
Q-30-Qj
DANA A. RASMUSSEN
Region~l Administrator" Region 10
, : {!. S,~. E~vi~~~~ent,al p::.o,~ec.t~(:m, ~ge~c.y. :
Date
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DECISION SUMMARY
INTRODUCTION
, ,
The Yakima Plating site was nominated to the National
Priorities List (NPL) in June 1988. The nomination was based on
'a Hazard Ranking System (HRS) score for the site resulting from a
site assessment performed by EPA in 1986. The site was placed on
the NPL in March 1989 (54 Federal Reaister 13296, March 31, 1989)
under the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, 42 u. S. C. 99601 et ~, ,as amended by, the,'
Super£~nd Am~ndmeI)ts: a~~ ,R~a,uthori~a,tion A,ct'of.. ).986 " (CER~~ ,91:- " .
,S~p~rfund),~ ',,": " ", ," "."":,,'" '..', :-.' ""',' ,,', .:::',' , ': .." "',"
Pursuant to Executive Order 12580 (Superfund Implementation)
and the National oil and Hazardous Substances Pollution
Contingency Plan (NCP), the EPA performed a Remedial,
Investigation/Feasibility Study (RI/FS) for the Yakima Plating
site.' The Remedial Investigation (RI), completed August '1,' 1991, ,
characterized contamination in liquids/sludges, soils, and' '
groundwater. The Baseline Risk Assessment, completed on August
1, 1991, evaluated potential effects of the contamination on
human health and the environment. The Feasibility Study (FS),
completed on August 1, 1991 evaluated alternativ~s for
remediating contamination. '
. '".
I.
SITE DESCRIPTION
Name and Location
The Yakima Plating site is located at 1804 1\2 South Third
Avenue in Yakima, Washington (see Figure 1). The Yakima Plating
facility occupies the western 0.94 acres of a 2-acre parcel
shared with a separate business, Autocraft Paint & Bodyworks Inc.
The site is located approximately 3 miles northeast of the Yakima
Municipal airport in central Yakima County, Washington. The
Yakima plating facility operates from three buildings on the
site.
Topoqraphv and Veqetation
A majority of the site, which encompasses the adjoining
grounds around the Yakima Plating and Autocraft buildings and the
vacant area north of these buildings, has been disturbed and
little vegetation currently exists. ' Prior to development of the
property for plating operations, the area was dominated by ,
orchards. The vegetation existing currently consists of a few
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W ,- Sf
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SUloCloifT "EW "'
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specimens of big leaf maple, paper birch, red alder, and 'various '
grasses. The western portion of the site consists of native
soils and is covered with automobile bumpers. The remaining
portions of the site are covered with gravel or asphalt paving.
The site is relatively flat, with a gentle slope
(approximate 0.6% grade) toward the southeast. The site is at an
elevation of 1,030 feet above sea level. Surface runoff from the
site flows toward Wide Hollow Creek, which is located
approximately 0.8 miles south of the site. ' The property is
outside the 500-year flood plain of Wide Hollow Creek. There are
no wetlands on the site. The prevailing winds in Yakima are from
the west to northwest.
. .Adiacent Land Uses
. .
. .
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. -. .
The Yakima Plating' site is located.two block~ soutp- o~ th~
city limits' of Yakima in a mixed light commercial'and residential
neighborhood. The businesses and residences which are adjacent
to the sit~ are located approximately 50 feet east and 200 feet
southeast, 'respectively. There are four schools within one mile
of the site. The closest of these is the Broadway Elementary
School which is located approximately 1,000 feet west of the
site. The population of Yakima County was 188,823 in 1990.
Yakima is the main population center of the county with an
estimated population of 54,827 in 1990. '
"
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Surface Water and Groundwater Resources
There are no surface water bodies on the site. Groundwater
from the shallow Alluvium aquifer supplies much of the domestic
and irrigation water in the Yakima Basin. In general, there is
an upward movement of groundwater into the alluvium from
underlying aquifers. The water table is generally 10-15 feet
below the ground surface. The groundwater flows in a east"
northeast direction. The results from pump tests indicate that
the site is underlain by an aquifer with almost instantaneous
recovery.' The water quality is usually considered satisfactory
for most purposes. '
The city of Yakima , uses surface water as the primary water
source for municipal supply. The intake for the supply is
located approximately 4.6 miles north of the site on the Naches
River. Yakima Plating lies within a block of land under county
jurisdiction that has limited hook-up rights to the municipal
utilities (water and sewer). Many of the residences adjacent to
Yakima Plating use private groundwater wells for their water
supply, which are at depths of 10 to 40 feet below ground
surface. There are approximately 410 private wells and 54,200
residents within 1 mile of the site. '
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historv of ~ite Activities
Yakima Plating, a nickel-chrome automobile bumper replating
operation is co-owned by Jack Stanton and Michael Schliep and has
been in operation since 1965. The property on which Yakima
Plating is located is owned by Mr. Robert Mastell, who leases a
section of the 3-acre parcel to Yakima Plating. Also on the 3-
acre parcel is the Autocraft Paint and Bodyworks, which is owned
and operated by Mr. Mastell. Prior to 1962, an orchard existed
on the property.
. Yakim~ Plat:i"pg, wheI! .operat:ing,.: u~ili.zed . approximately 20 to..
. '30abov~gr-ound holding .tanks,: ranging '.in'v6hlme. from :?aO.,.to'.4'£)0 .
gallons, 'which' were" stored within thepl"a;t'ing' buiid~ng ~ . These
tanks were used for 'cleaning, plating, and rinsing during the
electroplating process. Rinse water and plating tank spent
solutions commonly were disposed to a floor drain within the
plating roo~. The'floor drain connects to an underground
sedimentation tank and drainfield line.that collected the
sedimentation tank overflow and distributed the wastewater to
subsurface soils. This system was installed in the early 60's
when operations first began at the site.. This system operated up
until 1990 when plating operations ceased. Sampling results
indicate that the site septic tank may also be physically
connected to the. sedimentation tank.
Historv of Federal and State site Investiqations and Removal and
Remedial Actions Conducted Under CERCLA or Other Authorities.
A Preliminary Assessment (PA) was completed at the Yakima
Plating facility by the Washington Department of Ecology
(Ecology) in 1984. The PA indicated that there was a fairly high
potential that shallow groundwater w~s contaminated with some
metals. As a result of this determination a site investigation
was conducted in June 1986 by Ecology and Environment (E&E), an
EPA contractor. The investigation included a file review;
installation of four monitoring wells around the on-site
drainfieldi collection of composite soil samples during well
drilling; collection of groundwater samples from the four new
monitoring wells and five private residential wells located
around the site; a determination of groundwater flow direction;
and sampling of the influent and effluent from plating rinse
water tanks. Findings of this investigation were presented in a
report dated October 29, 1986 (Site Inspection Report for Yakima
Plating Company, Inc.). As a result of .this study, the Yakima
Plating site was placed on the National Priority List (NPL) on
June 21, 1988. .
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On May 7, 1990, E & E initiated field work for the Remedial
Investigation/Feasibility study (RI/FS) at the site. E & E
completed two RI/FS field events. The first field event was
conducted in June 1990 and consisted of a geophysical survey, a
soil investigation program, and a groundwater investigation. The
second field ~ent occurred in December 1990 and included.
installation of additional monitoring wells, collection of .
additional background samples, trenching around the drainfield
and tanks, and completion of seven additional soil borings.
On March 2, 1990, Ecology conducted a site investigation at
Yakima Plating. The sludge and effluent from the settling tank
both met the definition of a dangerous waste under Washington
state Dangerous Waste Regulations. On- June 25, 1990, Ecology
issued an order to Yakima Plating under the authority of the
. .. state. of Washington's Model. Toxics.. Control :Act... This orper ..
. .. .:~equire~ . Yakima., PJ-a.tirig -to'. stop "a'II:. discharges 't~o:, the - d,rai~"t-ield ~
submit a' schedule for' c'leanout of 'the' settling tank, and ~ontairi'
and manage' all dangerous waste on the site. Except ,for
management and disposal of dangerous waste the facility complied
, with this order. On September 4, 1991, Ecology issued a letter
to the operators of Yakima Plating requiring that a plan and
schedule. be submitted for removal of all sludges and waste'
plating solutions to a Danger04s Waste Management Facility.
. .,
The EPA completed a search of Potentially Responsible
Parties (PRPs) on August 30, 1989. This document identified
Yakima Plating and the site property owner as the only PRPs. On
December 14, 1990, Special Notice Letters pursuant to Section 104
of CERCLA were issued to the property owner and corporate
officers of Yakima Plating. To date none of the PRP's have
indicated a willingness to participate or contribute to the
RI/FS. In addition 'to the special notice, an information request
pursuant to section 104(e) of CERCLA was issued to the property
owner to determine his financial ability to contribute to the
RI/FS or the remediation.
III.
COMMUNITY RELATIONS HISTORY
CERCLA requirements, under sections 113(k) «2) (8) (i-v) and
117, for public participation include releasing the Remedial
Investigation and Feasibility Study Reports and the proposed plan
to the public and providing a public comment period on the
feasibility study and proposed plan. EPA met these requirements
in August 1991 by placing both documents in the public .
information repositories for the site and mailing copies of the
proposed plan to individuals on the mailing list. The public
repository is located at the Yakima Valley Regional Library in
Yakima, Washington. EPA published a notice of the release of the,
RI/FS and proposed plan in the. Yakima Herald Republic on August
12.and September 1, 1991. Notice of the 30 day public comment
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period and the public meeting discussing the proposed plan were
~ncluded iR the newspaper notice. The public meeting was held on
August 21, 1991, at the Cascade Natural Gas Building Meeting
Room. The public comment period ended on September 11, 1991,
with comme~ts-only from the property owner.
To date, the following community relations activities have
been conducted by EPA at the Yakima Plating site:
March 1990
EPA distributed a fact sheet inviting
citizens to an open house, to develop a
Community Relations Plan.
May 1990
Community Relations
included interviews
. community ,aJ)d loc~l
. . ."
Plan was published, which
from m~mbers of the
officials.
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May 1990
. .' . .
EPA 'released a t"act' sheet' 'arm"ounci~g "the
beginning of the. RIfFS. and the availability
of the Community Relations Plan.
February 1991
EPA released a Yakima area fact sheet, which
included all the sites in the Yakima area.
The Yakima 'Plating section contained history
of the site activities and provided an update
on the RI/FS activities.
August 8, 1991
EPA mailed the proposed plan fact sheet,
which explained the. results of the RI/FS and
EPA's preferred plan for public comment. The
fact sheet announced a public meeting for
'August 21, 1991, and gave the dates of the
public comment period.
August 12, 1991
A public notice in the Yakima Herald Republic
described the availability of the proposed
plan and the RI/FS, and announced the dates
of the public meeting and public comment
period. .
August 13 - September 11, 1991
Public comment period for
proposed plan and RIjFS.
August 21, 1991
EPA conducted a public meeting for interested
community members.
September, 1991
Responsiveness Summary prepared.
IV. SCOPE AND ROLE OF THE RESPONSE ACTION WITHIN THE SITE
STRATEGY
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The primary threat at the Yakima Plating site is the
potential for exposure to metals resulting from contact with
contaminated surface soils. The site is located close to several
residences, with several schools within one mile. This response
action is designed to remove the threat to public health by
significantly Leducing the volume of the contaminated soil, and
removing liquids/sludges which could serve as a continued source
of contamination and exposure risk to humans.
In addition, this response action will reduce the potential
for the contaminated soil to act as a source for groundwater
contamination. Although low levels of metals above MCLs were
detected in two groundwater monitoring wells at this site, these
concentrations are believed to have been sampling induced. All
other on-site and off-site wells tested were below ~ealth based
. levels. .Therefo.re the current l.evels of metals in. the .. . .
.-. :'.: groundWater a1;-'the, ;site are hot. believed .'to .:pose 'a :significant:.. .
.. public he.alth thr~at.:' Removal of. :on-site.,sources of. .soil .
contamination and containers of liquids and sludges; which could
serve as continued sources if unaddressed, should reduce the
levels. of metals in groundwater further over time. . Groundwater
monitoring will be continued for several years after
implementation of the remedy to confirm that contaminant levels
are decreasing and that groundwater supplies remain safe for
human consumption.
Currently there are noon-site residents. Levels of metal
contaminants in all off-site domestic wells sampled and in the
on-site domestic well do not currently exceed applicable federal
. or state health based levels. If the .levels of metal .
contaminants exceed these health-based levels, as determined by
the groundwater monitoring program, appropriate measures would be
taken by EPA under a separate response action.
A limited number of soil samples were collected under the
Yakima Plating building during the RI. The results indicate that
some contamination may exist beneath this structure. However
these contaminants do not appear to pose a health risk as long as
the building acts as a cap, preventing infiltration of rainwater
into soils. Future site use will be restricted, if the building
is removed, until the nature and extent of these contaminants are
better known.
v.
SUMMARY OF SITE CHARACTERISTICS
The following discussion summarizes data from the sampling
and analyses performed as part of the RI. The scope of the RI
includes studies for all media that maybe contaminated. Figure
2 identifies the general locations of samples for the site.
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Geoloqv and Soils
The Yakima Plating site area is underlain with approximately
5 to 6 feet of unconsolidated very fine sand and silt which is a
moderately-permeable soil. Beneath the soil is an unconsolidated
alluvium layer of sands and gravels which extend to a minimum
depth of 57 feet at monitoring well MW-5A (See figure 2). The
gravels in this area ranges from pea-size to at least 12 inches
in diameter with little evidence of restricted pore space.
Beneath this layer is an l,800-foot deep layer of semi-
consolidated clay, silt, sand, and gravel. A basalt layer forms
the bedrock for the region to depths in excess of 5,000 feet.
Hvdroloqv
,'. .;' " The availab~e., ~ata ,indiqate groundwater ',£'lo.w pattet;'nS? in, tpe
"".:'., Yakima. Vall,ey are; Comple}{. Thi&. ,comple'x'ity'ls:.'due',to th:e':
, '. distribution of ancient stream' sediments, thejnfiuen~e 'of
irrigation canals, and flows from the upland ridges to the Yakima
Valley. The aquifers in the vicinity of the site are located, in
the unconfined stream alluvium, the post-b~salt sediments, and
the interbeds and fracture zones of the Yakima Basalt., The
shallowest of these'aquifers is the unconfined alluvial
sediments. Water-levels 'in the unconfined alluvium typically
fluctuate on a seasonal basis within the range of 2 to 5 feet.
Water levels are generally highest in May and June and lowest in
November and December. These fluctuations are related to
variations in stream stages, irrigation return flows, and.
precipitation. In general, there is an upward movement of
groundwater into the alluvium from underlying aquifers because
the water table is lower than the piezometric surface of deeper
aquifers.
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Contaminant Characteristics
Contaminants of concern at the Yakima Plating site were
introduced in two distinct phases: through the legal application
of pesticides (organo-chlorine pesticides and arsenic based
pesticides) to surface soils prior to 1962 when the site operated
as an orchard, and through the discharge of plating wastes to
surface and subsurface soils during the operation of the Yakima
Plating Company. The contaminants of concern for human health at
the site. are:
Organochlorine Pesticides: DDD (l,1-dichloro-2,2-di-(4-
chlorophenyl)ethane), DDE (l,1-dichloro~2,2-bis(p-
chlorophenyl)ethene), DOT 1,1,1-trichloro-2,2-bis(p-
chlorophenyl) ethane, dieldrin, endosulfan sulfate, methoxychlor.
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ASPHAl T
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DB-ID X 0&-.
X
.. DRnotll ORAIH
..~~~.
OB-4 X
--.
0&-1
I
-------
-
Inorganics: antimony, arsenic, beryllium, cadmium,
chromium, cobalt, copper, lead, mercury, nickel, selenium,
and cyanide... -
zinc,
Extent of Contamination'
containerized Wastes
In response to an Order issued by the Department of Ecology
in 1990, the Yakima Plating facility operators containerized the
wastes within the facility. These wastes included spent plating
solutions, tank bottom sludges, crystalline materials from floors
. and other debris ,. and are summarized in. Table 1. . The, operators.
. also' .r.emoved the cont~nts: of '..a subsur"face sed:LmEmtation .tank ,..'..:, .
. :..'.¥lh~cn'wci:& 'pa'rt:o'f: t~e wa:st'e syst~ni ~sed..:duriI1g,:plati'ng".' ';:'., . ,.'.' . '
operations." The sampl'e results from the . sedimentation' tank. . .:.'
sludge are summarized in Table 2.' Other containerized wastes'
include raw plating products and reusable plating solutions. The
estimated volume of containerized plating-derived wastes is
approximately 280 cubic feet (10 cubic yards)..
All containerized wastes were sampled and analyzed for.
inorganic and organic analytes. Results indicate that the TCLP
regulatory level was exceeded for total chromium in some of the
containerized wastes and that some of the wastes contain
relatively high levels of arsenic, barium, chromium, copper,
vanadium, lead, nickel,' zinc; ,and cyanide. Samples collected
from the underground sedimentation tank showed relatively high
levels of total chromium, copper, nickel, and cyanide. Similar
constituents were detected in samples from the on-site septic
tank.
Surface Soils
. Prior to and during soil sampling areas both on and off-
site were identified as "background locations". These locations
were identified as areas that were not likely to have been
affected by activities of Yakima Plating. These locations
included areas on the north side of the site (a former orchard
area) and off-site locations in the vicinity of Yakima Plating.
These locations are identified as background samples (BS-) in
Figure 2.
The levels of organic compounds detected in surface soil
samples are provided in Table 3. Low levels of methylene
chloride, di-n-butylphthalate, butyl benzylphthalate, acetone,
benzoic acid, and toluene suggest possible laboratory
contamination. The presence of 1,1,1-trichloroethane represents
an isolated indication of a common degreasing solvent. No other
samples conta"ined the compound. .
13
.
. . ,"
-------
Table 1
.h . "---------______h
I~RY 0..
COIITAIIIDIZBD. P~DIO DIOlIVED MASTES
SYOUD At' YAU.KA P~IIIQ '.'
YAURA P~IIIQ
Yaki_, Washiziqt:oD
Deceaber 1990
",
'.
Estillated
Total COllposite TCLP(21 AnalyU!:al Re.ults
No. of Vol~lIe Sallple Container source(ll (pg(LI
Cont'ainers (ft 1 Descriptor Label As Sa Cd Cr Pb Bg Se "'1
.'
..
6 45 P'SPW-l DQ, DR, DS, 1 10.0 J 320 U 310 100. 59.0 UJ 0.4 .1 910 .14 80.0
D'l', DU, DV
1 5.4 P'SPW-2 DM 2 28.1 J 190 J 40.0 U 264,000 4"i.l U3 0.5 .1 10.0 UJ. 80.0
1 5.4 tSPW-3 DJ 2 13.9 J 1,020 J 40.0 U 1,oio: . 10.0 uj4 0.2 U3 36.3.1. 80.0
4 12.6 P'SPW-4 DK, DM, DK, 2 61.4 J 320 U 40.0 U .57,000: 10.0 UJ4 1.0 3 563 J. 80.0
DL ' ..
2 15 P'SPW-5 . DA, DB 3 10.0 UJ 320 U 120 '9Q.J 79 . 2 U3 0.5 .1 490 J. 80.0
P'SPW-6 (Duplicate of FSPW-51 10.0 UJ4 320 U 150 70'1~.u 80.7 UJ 0.3 .1 420 J. 80.0
t-' 2 15 rSPW-7(31 DO, DP 1
,I>.
(4) ..'
22 -- DO, Dr, DO 2
54 rSST-PTA1(3)PT-A 4
1 15 rS-PTl PT-C 5 103 J. 780 40.0 U 70..0 U 107 .1 0.5 .1 10.0 UJ. 80.0
1 13 P'S-PT2 PT-B 5 26.5 320 U 40.0 U 56.,800 100 0.2 UJ) 100 U 80.0
.'
1 10 rS-PT3 PT-D 5 68.0 320 U 180 45,400 . 922 0.8 .13 100 U 80.0
(11 Source 1 Floor sweeping snd Filtrate Wastes (SoU)
Code: 2 plating Tank Botto. Sludges
3 plating Solution precipitate (Crystaline lor Raw Product
4 Sedi.entation Tank Sludge froll plating Processes
5 Spent Plating Solution (Liquidl .. ;
121 TCLP - Toxicity characteristic laaching procedure - underlined results exceed. regulatory lev~l. IrR Vol. 55, No. 61, Karch 29, 1990).
(3) See text for inorganic results.
..
141 Unable to open containers - IIsterial reportedly similar to rSPW-4.
! .
-------
Table 2
.._..._.. --- ....-...
, , '
AllALY'l'Ip.!.' ~SUL'fS
(FSS'r-P'fAlI 'fAIR SWDGK SAllPLII:
YUDIA PLA'fIJlO
Yald..., WashiDqtOD
Deceabe~ 1990
SKDIJmII'I'A'l'IOJl
salDple No. KJ0621
Challical C18lla Inorqanic
(1I9/kql
Alullinum 4,550
Antimony 40.5 U31
Arsenic 23.9 34
Barium 942
Beryllium 0.45 U
Cadmium 14.6
Calcium 12,100
Chromium 11 , 400
Cobalt 21.6 3
Copper 11,400 34
Iron 18,800
Lead 3,040
Maqneaiu/ll 3,390
Manganese 116
I-' Mercury 0.22 U
VI Nickel 73,000 34
Potassiu/ll 25,100
selenium 2.7 U3
silver ' 8.5
Sodium ~80,000 .14
Thallium 1.3 U
Vanadium 26.5
tinc 6,010
Cyanide 9,470
JQ 521
Voliti1a/S.aiv01atila
(8q/kql
JG 521.'
P..ticid~/PCB
(lDq/kCII
011 AHD 012
Chroaiua VI
(aq/kCI)
Methylena Chloride
Acetone
2-Butanone
4-Kathyl-2-Pantanone
Toluena
Ethylbensene
Styrene
xylena (Totd I
phenol
Bis(2-EthylheKyllphthalate
160
4,000
400
410
540
110
27 J
640
9,300 33
20,000.33
4,4'-DDE, .'
2,0 33
0.13 U
0.12 U
. .
'.
. .
. .
Note: Reter to Appendix r lor a description ot qua1ifers.
.
. .
. .
\
. .
-------
.,
site soils were analyzed for pesticides and PCBs. These
results are summarized in Table 5. Detectable concentrations'of
the pesticides DDT/DDE/DDD and dieldrin were found in nearly all
the surface soil samples taken from the former orchard area
(north background locations), in some surface samples in other
areas of the site, and in some samples taken from off-site areas
not likely to have been impacted by contamination from Yakima
Plating (off-site background locations). Chlordane, endosulfan
sulfate, and methoxychlor were also found in several of these
samples. These compounds were likely introduced through the
legal application of lead-arsenate or other pesticide compounds
to an orchard that existed on the site in the past, and are not
related to plating activity at the site. No elevated metal
concentrations or detectable,pesticide concentrations were fo~d
,i~ any 9f th~.subsurface s9il sa~ple~.Gcil~ecte~ fro~ t~e~~ ar~as.
. .': '. .... "~'" '. . '.. ,"" . .',"':. '''. . .'" . . . . ~.'. . ,'. . :."'. ..: ", .:. : . . ".. .: '. '. . '::.' ,"." .~:' '. .'
Inorganic' contamination relat~d.toplating activities is'
summarized in Table 4.' Inorganics were primarily'identified in
the graveled areas adjacent to the plating facility and in an
area south,of the facility building near the facility's
ventilation ducts. MTCA Method B soil cleanup levels (See
. section IX) were exceeded in these areas for lead, chromium,
copper, and nickel.
. ."
Lead and Arsenic were also identified i~ a number of
locations including background areas. ,These locations exhibited
a strong correlation with those areas that had been used as
orchard areas in the past. A comparison between background soil
results and orchard areas is presented in Figure 4. These
chemicals were likely introduced through the legal application of
lead-arsenate with other pesticides and therefore are not related
to plating activity at the site.
The graveled area adjacent to the facility was separated
into two areas based on inorganic results and plating activity
(see figure 3). The north and west areas of the site (identified
as area A), where minimal plating related activity occurred, had
isolated locations that exceeded the MTCA Method B soil cleanup
levels for nickel and lead. The volume of material that exceeds
MTCA in the nprth area'is estimated at approximately 1,750 cubic
feet (65 cubic yards). The gravel area adjacent to the facility
(Area B) exceeded MTCA cleanup levels for chromium, lead, nickel,
and copper. . The ,total volume of material in this area which
exceeds MTCA is estimated at 2,900 cubic feet (107 cubic yards) .
The location adjacent to the facility's ventilation ducts
(See Figure 7) exceeded MTCA Method B soil cleanup levels for
copper and nickel to an approximate depth of 2 feet below ground
surface. The estimated volume of material in this area exceeding
MTCA cleanup levels is approximately 1,300 cubic feet (48 cubic
yards). '
17
-------
Table 4
..h_--'-'
StnmARy OF CUEJUCALS FOurm IR
yA1tIftA PLATIRG SITS SOILS -
IROROASICS (8g/kg)
"
"
95th Per- Background Surface Shallow Borings, Deep Borings Trench Sallples
centile
Concen- I"' .
tration, Maximum Maximua 'Maximum Maxillum Maximua
"estern Detection Concen- Detection Concen- Detection Concen- DoteCtion Conc..n- Detection ConceD-
Chemical U.S. soils Frequency tution Frequency tration Frequency tration Frequ.~cy tration Frequency tration
Alullinum, 181,000 6/6 11 ,800 6/6 17,100 L 12/12 18,200 L '80/80 17,800 L 7/7 10,600
Antimony" 1.66 0/6 HA 2(12 8.0 LS 19/80 7.6 LS 1/7 13.2 LS
Arsenic" 16.9 6/6 37.3 S 25/36 32. 7 S 12/12 21.7 S &0/80 29.3 S 7/7 26 S
Barium 1,415 6/6 147 6/6 181 L 12/12 189 L 80/8'0, 225 L 7/7 595 L
Beryllium" 2.68 5/6 0.75 5/6 0.57 11/12 lolL 52/80 1.1 L 4/7 0.75
Cadmium" RR 0/6 0/6 1/12 4.9L '101.80 6.8 L 1/7 14.6
Calcium 112,700 6/6 12,900 6/6 7,680, 12/12 19,100 L 8ct/80 ,21,500 L 7/7 23,900 L
Chrollium (total)" 149 5/6 13.8 36/36 6,180 LS 12/12 131L :80)80' 1 , 5'G 0 LS 7/7' 7,870 LS
Chromium (VI)" HR HI'. 3/15 7.04 0/3 ,;. '1/6 1.16 0/4
Cobalt" 21.7 6/6 13 6/6 131 LS 12/12 402 LS ',79;80' 54.4 LS 7/7 91.6 LS
Copper" 69.5 6/6 91.2 S 36/36 10,300 LS 12/12 46,700 LS ?1/80 1,380 LS 7/7 22,300 LS
t-' Iron 63,000 6/6 26,400 6/6 56,500 L 12/12 261,000 LS 80/80 52,200 L 7/7 31,600 L
00
Lead' 44.7 6/6 701 S 35/36 7,580 LS 11/12 550 S ~0/80 2,530 LS 7/7 1,430 LS
MaqnesiuIII 27,300 6/6 5,040 6/6 4,690 12/12 6,440 L 79/80 6,730 L 7/7 4,600
Manganese 1,170 6/6 677 6/6 876 L 12/12 921 L 79"/80 1,150 L 7/7 608
Mercury" 0.185 2/6 0.46'5 0/6 3/12 0.34 S 24/,80 2. 2 LS 1/7 1.5LS
Hickel' 50.8 6/6 253 S 36/36 37,400 LS 12/12 218,000 LS 73/80 2,880 LS 7/7 125,000 LS
potassiull 39,000 5/6. 3,9~0 6/6 4,650 L.. 11/12 4,550 L 7.l/8~ 7,130 L 4/7 3.210
Selenium" 0.99 0/6 0/6 0/12 12/80 2.9 LS 4/7 10.1 LS
silver RR 6/6 13.5 0/6 6/12 77L ~7/80 8.7 6/7 9.0
sodium 29,100 6/6 997 6/6 460 12/12 4,640 L 80/80 1,700 L 7/7 1,850 L
Tha11iuJII 17.5 0/6 0/6 0/12 3/80 0.32 L 0/7
Vanadium 210 6/6 66.7 6/6 90.8 L 11/12 114L '80/80 111 L 7/7 129 L
Zinc' 143 6/6 85.6 36/36 1,630 LS 12/12 4,949 LS 80/80 1,120 LS 7/7 5,210 LS
Cyanide" RR HI'. 1/6 145L 1/12 1.1 L 18/55 14.8 L 2/2 495 L
'Selected as a chemical of potential concern.
Key:
.
NR . Not reported.
NA a Not analyzed.
L . Exceeds local background.
S . Exceeds 95th percentile of
, .
Shacklette and Boerngen (1984) data for westecn U.S. soils.
'. .
\
-------
Table 5
..-------------
SUPIKARY OF OJEJUCALS FOum> III
YAltIMA PLATIIIG SITE SOILS -
PESTICIDES
"
Background Soi18
Surtace Soils
Shallow Borings
10 - 4 ftl
Deep Borings
10-13ftl
'.
Chemical
CRQL
lpg/kg I
Detection
Frequency
Maximum
Concen-
tration
Ipg/k91
Maximum
Concen-
tration
Ipg/kgl
Maximull '
Concen-. '
tration" betection
(pg/kgl ',; .~requency
Detection
Frequency
Detection
Frequency
Maximull
Concen-
tration
(pg/kg)
, CUliulative
Detection
P'requency
Arochlor 1260 2.0 0/6 0/6 0/10 -- 3/16 500 3/38
Alpha-chlordane 8.0 1/6 9.8 3/6 180 2/10 115 0/15 6/31
Gamma-chlordane 0/6 0/6 2/10 1", . '; 0/15 2/31
Chlordane 0/6 0/6 1/10 150, 3/16 588 4/38
'...... 4,4'-000' 2.0 0/6 6/6 4,300 3/10 126, . ,5/16 31 14/38
\D 4,4'-DDE' 2.0 6/6 23,000 6/6 ,18,000 9/10 1,400 ' 14/16 155 35/38
4,4'-DDT' 5.0 5/6 14 , 000 6/6 19,400 6/10 930 14/16 340 31/38
Dieldrin' 2.0 2/6 850 4/6 900 '1/10 18 1/16 10 8/38
Endosultan-I 0/6 2/6 101 0/10 0/16 2/3~
Endosulfan-II 0/6 2/6 94 0/10 -' " 0/16 2/38
Endosulfan sulfate' 5,0 1/6 6.0 5/6 290 3/10 15.. 5/16 130 14/38
Endrin 2.0 0/6 2/6 102 0/10 0/16 2/38
Endrin aldehyde 5.0 0/6 1/6 54 0/10 - " 1/13 12 2/35
Heptachlorepoxide 1.0 0/6 1/6 9.0 0/10 -- ' ,0/16 1/38
Methoxychlor' 16.0 0/6 4/6 180 2/10 11.5 3/15 33 9/31
:
'Selected AS a che.icsl of potential concern.
Key:
.CRQL .. Contract required quantitation limit.
"
'.
.
\
"
-------
I-w-
I
I
I-w-
I
I-w-
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I
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.~. ~.ENCJ
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~ .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. . ..
. "
. .
.. .. .. .. .. .. .. .. .. .. .. .. .. . .. . .. .. .. . .. .. . o' . ..
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . . .. .. . .. .. . .. .
OFFICE
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. . . .. . .. . . .. . .
............0.............
. .. .. .. .. . .. . . .. . .. . . .. . .. . .. . . .. .. .. . .. .
.. .. .. .. .. .. .. .. .. .. .. .. .. . . . . . . .. . ..
..0..................
.. .. .. . .. .. .. .. . .. .. . .. . . . . .. . .. .. .
.. . .. . .. .. .. . .. .. .. . . . .. . .. . .. . . .
'. . . . . . . . . . . . . . . . . . . . . . STORAGE
.. .. .. .. .. .. '. .. .. .. .. .. .. .. .. . .. .. . .. . .
,,,,,.,,,.,,,,,.'.A2 .................... .
. .. .. .. .. .. .. .. . .. .. . .. , .. . . .. .. .. .. .. .. .. . . .. . .. .. .. .
. . . . .. .. .. .. .. .. . . . . . . . . . . .. . . .. . . . .. . . ..
.. .. . .. .. .. .. .. .. .. .. . .. .. . . .. . .. . . .. .. . . . .. .. . . ..
'.'.'.'.'.'.'.'.'.'.'.'0'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'
. .. . .. .. .. .. . .. . . .. . .. . . . . . . .. . .. .. . . . . ..
. .'. ~G:r""72. . . . .' . . . . . . . . .' . . .' .' .' .' . '. . . . . . .' . . .' .' . . .'.
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. . . .. . . .
.. .. .. . .. . . .. .. .. .. .. .. .. . . . . . .. . .. . . . . .. .
.. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. . .. . .. . .
"""""""""""'0""
YAKIMA
PLATING
FACILITY
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. . . . .. ..
.. .. .. .. .. .. .. .. .. .. . .. . .. .. . . .. .. .. . .. .. . . .. .'.
. . . . . . . . . .. .. . .. . .. .. '" .. .'. '" ... .. . .. .. .. .. ..
.. .. .. .. . .. . .. .. .. '" . . .. .. '" .. .. . '" . .. . .. .. . .. .
.. . .. .. .. .. . .. . .. . . . .. .. . . .. . .. .. .. .. .. .. .. .. .. .
.. .. .. .. .. .. .. .. .. .. . .. .. .. .. . .. .. .. .. . .. .. .. .. .. . ..
.. '" .. .. .. .. .. .. .. '" .. .. '" .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
.. .. .. '" '" . .. . .. . .. . .. .. . . . .. .. .. .. . .. .. .. .. . .. .
. .. .. .. . .. .. .. .. .. .. . .. . .. .. '" .. .. .. . .. .. .. . . . .. . .
.'W/-a'.'.'.'.'.'.'.','.'.'.'.','.'.'.'.','.'.'.'.','.'.
L '.-m- ~ ~~":'~ ':~ f': ~:'~ ':~.:~':'~': ~.>
ASPHALT
. .
MN-4
MN~3
MW-2
- .
SURFACE SOIL DISTRIBU110N
YAKIMA PLAIlNG
YAKIMA, WA
AI - SANO AND SILT WITH LITTLE GRAVEl. "
Aa - SANO AND SILT WITH LiTTlE GRAVEl. ; ISOlATED SMAlL
AREAS Of OIL-STAINING (NOT DEPICTED ACCURATELY); 80%
. Of AREA COVERED WITH PAlLETS AND BlM'ERS
8. - GRAVEl WITH SOME SILT
82 - GRAVEL WITH SOME SILT; SLIGHTLY OIL-STAINED
C - SANOY SILT Willi VECETATlON; WELL DRAINED SOIL
X - SIEVE ANALYSIS SAMPLE LOCATION
20
Figure 3
-------
N
f-'
.
son. (mt//1,)
M 37.JO
Pb ea.1oo
M&I),
son. ('"1//1,)
M 21.90
,
son. ('"1//1,)
,.. 21.70
Pb 10100
son. ("../1,)
PI> a.1
(,.,/1,)
son. ("../1,)
PI> 142.00
N 11e.00
, (uc/1,)
IOn. (mtI.A,)
,.. 23.10
PI> 237.00
(,.,/1,)
SOI£ (....f1f)
PI> 'OUO e1.00
",/1,)
001 01 J) 1 J3
B5-:I
~BER
8ACKGROUND SURFACE SOIL LOCATIONS
:~ELATIVE TO FORMER ORCHARD AREAS
YAKIMA PLATING
YAKIMA, WA
"
...J
g
a
VI
~
:r
...
.
~
PARKING lOT
')(BS-6
8S-7
H AVY EOUIPMEt T
REPAIR
1811 5 4TH
AVE
'. .
8U51N ,5S
GA GE
GRAVEL
LEGEND
~ ()lAIN UN>< ftNC[
~ AA[~S' OEPICI£O ~S
ORCHARDS IN 1949
~ER I ~L PHOTOCRAPHS
(EPA 1989)
A. AASEN I C
Pb LEAD
Cu COPPCR
NI NICKEL
X SOIL S~"PLC T\'PES:
sa SHAU.OW BORING
SS SURF ~C(
BS B~CKCROUNO S~PLC
w
~
a
cr
n
:r
~
N
O'
W 100' 1$0'
SCALE I' . 50'
-------
Subsurface Soils'
Inorganic contamination in subsurface soils was also related
to drainfields and plating facility areas. The drainfield
consists of. a PVC perforated subsurface distribution line
surrounded by approximately 8 inches of rounded gravels. Samples
collected at soil locations along the drainfield line exhibited
inorganic concentrations above MTCA Method B and the highest
metal concentrations in subsurface soils at the site. All
elevated concentrations appeared to be within the sand and gravel
unit and within the interval of groundwater fluctuation. The
total estimated volume of soil material associated with the
drainfield line, gravels, and sludge material which exceeds
cleanup levels is appro~im~tely 200 cubic feet (7.5: .cubic yards).
. ,.
. .
. . '. .
,., .." other stibsur.face '~o:i,is"tha.t:exii:ibit~d .inor.ganic,'c.6nS~."itq:erit$" .':.' ...
above MTCA method' a levels were identified at two locations:'. ...
soil boring DB-1 and DB-3. These locations. are identified as the'
monitoring well MW-2 area and the septic tank drain pit area. .
Soil samples collected from DB-1 exhibited concentrations of lead
exceeding the MTCA cleanup levels (See section IX) at least to a
depth. of. 10 feet. .Samples collected from an adjacent soil boring
(DB-12) to a total depth of 30 feet below ground surface (bgs) .
did not exceed any cleanup levels. The estimated total volume of
soils above cleanup levels in the vicinity of DB-1 is
approximately 6,000 cubic feet (222 cubic yards). Samples
collected from DB-3 in the septic drainpit area .exceeded the MTCA
cleanup levels for chromium (See section IX) to a total depth of
at least 9 feet below ground surface. Based on the observed
configuration of the drain pit gravels in this area, the total
volume of materials in this area exceeding cleanup goals is
estimated to be approximately 2,025 cubic feet (75 cubic yards).
As part of the subsurface soil investigation two samples
were collected beneath the Yakima Plating building. One core was
located within a corroded area in the concrete floor (FS-l) and
the other location was randomly selected within the plating room
(FS-2) (These locations are shown in Figure 2). The results from
FS-l indicated that chromium and nickel exceeded the MTCA method
B soil cleanup levels. Sample results from FS-2 were below any
inorganic and organic MTCA soil cleanup levels.
The history of Yakima Plating indicates that the facility
constructed the wastewater system (tank and drainfield) in the
early 1960's when operations began. The RI has identified
contaminants outside the building associated with this system as
previously discussed. This system was in operation up until 1990
when plating operations stopped. Based on this history it
appears to be unlikely that additional disposal occurred beneath
the building. In addition the floor of the building was in good
shape without obvious migration pathways, such as cracks and
22
-------
holes. Based. on this information large amounts of contamination
under the building are not expected to be found beneath the
Yakima Plat~ng building.
Semivolatile and volatile organic analysis indicated that
there were very few organic compounds detected in the subsurface
soils. Those detected were resin compounds or
laboratory/decontamination compounds, such as acetone.
Soils Summary and Miqration Pathways
The site soils consist primarily of silts and sands with a
relatively low organic carbon content. Beneath the soil is an
unconsolidated alluvium layer consisting of predominantly sand
and gravel, estimated to be .a1:: . least 5? f~.et thick. .
. '.'.' 'The' .maj61::"ity. of ~th.e.:C~~tami~ati~n r.ein~iIjing ~t th~' site' i'~'
located' in the 'surface' and sUbsurfa'ce.s'oils. Based on exceedance
of MTCA Method B cleanup goals, an estimated 540 cubic' yards of .
surface and subsurface soils must be remediated. This includes
surface soils in the gravel area immediately north of the Yakima'
Plating building, surface soils along the south fence line,
subsurface soils around. the underground tanks and'drainfields,.
and subsurface soils around monitoring well 2.
There are two main routes of contaminant migration from
soils at the site; through the groundwater and the air. .
Infiltration of precipitation, and fluctuation of groundwater
levels, may carry contaminants into the groundwater. Wind
dispersion of contaminated soil particles is considered to be the
primary route of migration through the air. Since the pesticides
and metals detected at the site have relatively low vapor
pressures, volatilization is not expected to be a significant
pathway.
Groundwater
A summary of groundwater inorganic results is presented in
Table 6 and 7. All of the off-site domestic wells sampled
contained relatively low levels of inorganic and organic
constituents; and no samples indicated that federal or state
drinking water standards were ever exceeded. Organic compounds
detected in domestic well samples consisted of very low levels of
compounds ubiquitous to the environment, such as di-n-
butylpthalate; potential laboratory contaminants such as
methylene chloride; and industrial substances such as phenol.
with the exception of MW-2 and MW-7, all on-site monitoring
wells also had relatively low levels of organics and inorganics
and were below federal and state drinking water standards.
Analytical results from MW-2 indicate that arsenic, nickel,
chromium and lead were detected at elevated levels above MTCA
23
-------
tV
of:>.
.
-c
08
:D:D
(50
-c::
z>
>,
I-
=
0'
l'
tT1
'"
Key:
CRQL a
NE .
P .
S .
SDWA KCL .
Contract required quantitation limit.
None established.
Proaised value.
Secondary KCL based on aesthetic factors.
Sate Drinking Water Act Kaximua Contaminant Level.
. ~
-------
Table 7
SUMMARY OF ClEJUCALS FOUND IR
YAKIMA PLA7IBG SITE GROUNDWhTER
INORGANICS (.gILI
Chemical
SDWA
KCL
I\>
U1
Aluminum
Antimony
Arsenic
Barium
BerylliulII
Cad"ium
Calcium
Chromium
Chrollium
Cob&! t
copper
Iron
Lud
Magnesium
Manganue
Hercury
Nickel
potassium
Selenium
Silver
Sodium
ThalliulII
Vanadium
Zinc
Cyanide
(total)
(VI I
0.05 -0.2 S
0.01 - 0.005 P
0.05
2.0
0.001
0.OQ5
NE
0.1
NE
NE
'1.3 - 1.05
0.3 S
0.015
NE
0.05 S
0.002
0.1 P
, NE
0.01
0.1 S
NE
0.002 - 0.09 P
NE
5.0 S
0.2 P
.
""C
08
2;!:D
G">Q
-c::
z>
>.
1-
:;!
Key:
Background Wells
Detection
Frequency
Haxi.ulI
Concen-
tration
Drinking Water Well.
Halliaua
Detaction Concen-
Frequency tration
0/11
,0/11
10/11 0.0043
0/11
0/11
0/11
11/11 46.6
3/11 0.0241
1/9 0.0082
0/11
3/11 0.0108
0/11
3/11 0.0017
11/11 14.3
6/11 0.0054
0/11
1/11 0.0177
11/11 4.59
0/11
0/11
11/1:1" .'..' 20.1
0/11
11/11 0.0134
6/11 1.530
0/6
Monitoring Wella
I
Kalliaum
Detection Cone en-
Frequency tration
13/16 3. 39 A'
0/16
14/16 0.0113
13/16 0.0876
0/16
1/16 0.0025
16/16 45.2
4/16 0.159 '
1/7 0.0094
0/16
11/16 0.179
12/16 17.25 A'
6/16 0.161 A'
16/16 13.9
16/16 3. 76 A'
5/16 0.40 A'
9/16 0.686 .
16/16 5.38
2/16 0.0021
0/16
16/16 19.5
0/16
16/16 0.0442
5/16 0.143
0/7
.Concentration exceeds the HCL.
A . Markedly elevated levels of aluminulI, iron, and aanganese in aonitoring veIl water aaaple. are often
indicative of auapended aedillent in the aa.ples, in which case the elevated .etal concentretiona are
attributable, at least in large part, to soil ainerals cOllprising the sediaent rather than diaaolved
(mobile, concentrationa. '
NE . None established.
P . Proposed value, not yet finaliled.
S . Secondary atandard based on aesthetic factors.
SOWA HCL . Safe Drinking Water Act Maxiaua'Conte.inant Level.-
-----------.- .-
0/1
0/1
0/1
1/1
0/1
0/1
1/1
0/1
0/1
0/1
1/1
0/1
0/1
1/1
1/1
0/1
1/1
1/1
0/1
0/1
1/1
0/1
1/1
1/1
0/1
0.0191
20.7
0.0057
9.790
0.0022
0.0051
12.5
0.024
0.063
-------
method B groundwater levels. This contamination may be due to
the insurgence of silt at the bottom of the well's sump during
field sampling. Unfiltered samples collected from MW-2 exhibited
significantly higher levels of chromium, lead, and nickel as
compared with_the f~ltered samples. In addition the screened
interval and depth of this well are likely to have contributed to
the collection of silt in the well sump. MW-7 had elevated
levels of chromium, above state and federal standards, during one
sampling round. This sample exhibited similar siltation problems
as found at MW-2. .
Arsenic was detected in several monitoring wells on-site
including the background private well PW-2 and on-site background
well MW-I. Both PW-2 and MW-1 are located within the former
orchard areas and elevated' arsenic conceht~ation have been found
'in surface. soils' peal:" .thes.e locatiQ~s ~.s. 'pre~..i,ously' . d~scus.sed.... :.
.The ars~Id<;:" concet:'lt~ati9'ns 'in th~grotind~ate~ 'see~ more lik~ly.' to.' . "
be related to the use of a'rseriic-contciining pestiC?ides' .in' the' '.
'orchard that formerly occupied the site than, to the recent.
plating operation. Although arsenic in groundwater has been
detected, the levels in groundwater do not exceed the federal
drinking water standard.
Surface Water
There are no surface water bodies on the Yakima Plating
site. The unpaved portions of the site are covered with gravel
or highly permeable soil, and the site has a slope of less than
one percent. Because of these conditions,the:potential for
migration of contaminants by precipitation runoff is minimal.
Requlatorv Requirements for Addressinq site Risks
EPA's National oil and Hazardous Substance contingency Plan
(NCP), found in 40 C.F.R. Part 300, requires that the site's
remediation goals are protective of human health and the'
environment. Initially, contaminant concentrations are compared
to existing criteria such as Safe Drinking Water Act Maximum
contaminant Level Goals (MCLGs) and Maximum contaminant Levels
(MCLs), State of Washington cleanup levels under MTCA method B,
and Clean Water Act Water Quality Criteria (WQC). However, there
are no corresponding criteria for soils and structures. Federal
remediation standards for soils and structures are usually
established by setting contaminant concentrations for cancer-
causing chemicals at levels that represent cancer risks between
one-in-ten-thousand (10-4) and one-in-one-million (10-6). For
toxic compounds not identified as carcinogens, the contaminant
concentrations shall be protective of sensitive human .
subpopulations over a lifetime. Noncarcinogenic effects are
expressed in terms of a I1hazard index,".
26
-------
VI.
SUMMARY OF SITE RISKS
The risks to human health and the environment at the Yakima
Plating Superfund site are described in the site-specific Human
Health Risk Assessment, which was prepared by Ecology &
Environment, inc. for EPA using EPA guidance. The Risk
Assessment followed a four step process: 1) identification of
contaminants which are of significant concern at the site, 2) an
exposure assessment which identified current and potential
exposure pathways and exposure estimates, 3) toxicity
assessments for the chemicals of potential concern at the site,
and 4) a risk characterization, which integrated the three
earlier steps to summarize the potential and current risks posed
by hazardous substances at the site. The results of the Human
Health-Risk Assessment are. discussed below. .
.".' .
.' c6ritam-iria:nts'- o'f 'concern
. .
. . ~. .
. .
. .
. '.
The groundwater, soils, and .tanks and containers were
sampled during the Remedial Investigation for many potential
contaminants, including volatile and semi-volatile organics,
metals, inorg~nics,. Total Suspended Solids (TSS) and Total
organic Carbon (TOC), pesticides, and PCBs. . The chemicals
detected in various environmental media in the RI are summarized
in Tables 3 through 7. Results of these analyses were used to
select contaminants of concern that were used to quantify
potential risks to human health and the environment. A number of
substances, primarily inorganic chemicals, were not con~idered
for the.risk aSsessment because there were present in background
samples at similar concentrations.
Most metals are natural constituents of soils and
groundwater at some concentrations. Therefore, when evaluating
metals data for the risk assessment it was necessary to -
distinguish samples containing naturally occurring concentrations
of metals from those that may actually be contaminated, as well
as distinguishing concentrations due to on-site activities from
those attributable to off-site activities. Initially, the 95th
percentile for literature values of background metals in
surficial soils of the Western United States were used as
reference points, since only 5% of naturally occurring
concentrations would exceed these values (does not represent
"natural background" as defined by Ecology). This information in
combination with a chemicals pattern of occurrence throughout the
site was used to designate the chemicals of potential. concern for
the site. . -,
The human health contaminants of concern included in the
risk assessment include the following: The DDT series (DDD, DDE,
and DDT), Dieldrin, Endosulfan sulfate, methoxychlor, and
antimony~ arsenic, beryllium, cadmium, chromium, cobalt, copper,
lead, mercury, nickel, selenium, zinc, and cyanide.
27
-------
Exposure As?essment
The objective of the exposure assessment is to estimate the
type and magn~tude of exposures from the site. This includes
identifying exposure routes (ingestion, inhalation, and direct
contact), land use scenarios, potentially exposed populations,
estimating exposure point concentrations, and describing
assumptions about exposure frequency and duration. .The risk
assessment calculates exposure point. concentrations based on
average and maximum contaminant concentrations. The following is
a brief summary of exposure pathways evaluated and assumptions
used in the assessment. A more thorough description can be found
in section 7.3 of the Human Health Risk Assessment for this site.
.A conc~ptq.~t. si:t~- model w.a.s prepared. -~~~- .i.s prEase.nt~d . in Fi9ur~s.
5.. and;. 6~ As shown in .the figure; .:thei:e. "a~e:-three. prf:rnary.:..
exposure p~thways:. .. ...
. .
... .
Direct contact with contaminated soils, including dermal
contact and ingestion via hand-to-mouth contact;
Inhalation of airborne soil particles from the site; and
Ingestion of contaminated groundwater as drinking water.
There are four groups of potential receptors under existing
land use conditions: site workers, site visitors, nearby.
residents, and employees .of nearby businesses. In addition; .if
the site were to be converted to residential use in the future,
the future site residents would be. another group of potential
receptors. .
Exposure point concentrations for surface soils were
estimated by using sampling and modeling results to calculate
intake of contaminants in mgfkg-day. Details on these models are
found in Appendix G of the RIfFS. The parameter values were all
selected to correspond to the average and reasonable maximum
exposure (RME) an individual in the receptor-population might
experience. Intakes are inversely related to body weights and
averaging times (the period over which the exposure is averaged).
The exposure point concentrations used to calculate risks are
summarized in tables 7-11 through 7-25 in the Risk Assessment for
this site. .
Direct Contact with surface soils
The surface soil contaminant concentrations found in Areas A
and B shown in Figure 3 were used for evaluating potentia+ direct
contact exposure for site workers and adult site visitors. This.
represents the area where the specified receptors would be
expected to spend the most time while on the site; All surface
28
-------
SOURCE
PLATING WASTES
tV
U)
RESIDUAL PESTICIDES
-
\
Figure 5
CONCEPTUAL SITE MODE~ FOR YAKIMA PLATING
RECEIVIt~G MEDIA
MIGRATION PATHWAY
EXPOSURE MEDIA
EXPOSURE PATHWA VS POTEN11ALL V COMPLETE UNDER EXISTING CONDiTIONS
~ SURFACE SOILS
.. SURFACE SOILS
.. NONE
.. .
WIND EROSION
.. AIRBORNE PARTICLES
DIRECT DISCHARGE TO -- LEACHING AND TRANSPORT --.. GROUNDWATER
SUBSURFACE SOILS BY PRECIPITATION ~
VIA SEPTIC SYSTEM INFILTRATING THE GROUND
LEACH BED .
MIGRATION OF UaUID
WASTES DIRECTLY
TO GROUNDWATER
~ SURFACE SOILS
.. NONE
.. SURFACE SOILS. .
WIND EROSION
.. AIRBORNE PARTICLES'
. .
" .
. "
'.
RECEPTORS AND
ROUTES OF EXPOSURE
~
SITE WORKERS AND
SITE VISITORS
. Dermal contact
. Ingesdon vfa
hand.to-mou!h contact
. .
SITE WORKERS, SITE
.. VISITORS, AND NEARBY
RESIDENTS
. Inha/adon
~
RESIDENTIAL AND
COMMERCIAL USERS OF
GROUNDWATER
. Ingesdon 88 drinking walOf
..
SITE WORKERS AND SITE
VISITORS
. Dermal contact
. Ingesdon via hancJ.to-moulh
contact .
..
SITE WORKERS,
SITE VISITORS, AND.
NEARBY RESIDENTS
. Inhaiailon .
-------
Figure 6
. .. .-.. -
CONCEPTUAL SITE MODEL FOR YAKIMA PLATiN~ '
'. : .,
'.
SOURCE
RECEIVING MEDIA
MIGRATION PATHWAY
EXPOSURE MEDIA
RECEPTORS AND
ROUTES OF EXPOSURE
EXPOSURE PATHWA YS POTENTIALLY COMPLETE UNDER F\JruRE RESIDENT1AL USE SCENARIO
.' .
PLATING WASTES
AND
RESIDUAL PESTICIDES
.. SITE SOILS
to. SUBSURFACE SOIl..8 MAY
BECOME SURFACE SOILS
THROUGH EXcAVATION
ASSOCIATED WITH
CONSmUCTION
ACTIVITIES
.. SURFACE SQIl..8
FUTURE SITE RESIDENTS
. Dermal contact
. Ingesllon vta hand-to-mouth
contact
w
o
mACKING OF SOIL
INDOORS
to. HOUSE DUST'
.'
WINO EROSION
. . .
.. AIRBORNE p~~TidLE:s ~ FUTURE SIT1' RESIDENTS
. Inhalation
'. '.
, .
PLATING WASTES
.. SITE SOILS
.. LEACHING AND TRANSPORT -GROUNDWATER - FUTURE SITE RESIDENTS
BY PRECIPITATION AND . Ingestion as drtnklng watef
AESIDEmlAL IRRIGATION'
INFILTRATING THE GROUND;
DIRECT MOBIUZATION BV
GROUNDWATER DURING
PERIODS OF HIGH
GROUNDWATER LEVELS
. ,
. "
. ,
,,'
.
\
-------
soils site7wide were used as the source area for evaluating
potential direct contact exposure to adolescent site visitors
(trespassers) and for potential future residents, both adults and
children. ~he average and upper 95th percent confidence limit
contaminant concentration for these areas were used for the risk
assessment 'and are presented in Table 8.
Inhalation of Airborne Soil Particles
The surface soil contaminant concentration in Areas A and'S
were used as the source term for all of the potential inhalation
pathways (site workers, site visitors, nearby residents and
workers, and future site residents) because these were the only
areas of,the site that are ,not either substantially vegetated or,
, pave~, and therefore ,they are the only areas that could be
, sUbject to, signi~icant wind ~rosion., ' ' , '
. '.' ," .;0, . ",".'... "'.'.~' -.- : :. : :. :.,- ..,: . .
, ' 'T¥1~' typ~s , of 'm~dels' 'w~re' U~~d': in "d~ve'lQping 'e~p'osu~e ,
estimates. The first model concerned the emission of soil
particles from the ground surface to the ambient air "mechani.cal
resuspension". The second model was an air. dispersion model,
which was used to estimate ambient air concentration downwind
'from the'sourceareas to determine 'the breathing-zone particle
concentrations. These models are discussed in detail in Appendix
G of the RI/FS.
"
-
.'
Inqestion of Groundwater as Drinkinq Water
The Yakima Plating and Autocraft buildings obtain their
drinking water from private well PW-5i therefore, the contam~nant
concentrations (Average concentrations and Upper Confidence Limit
(UCL) levels) found in this well were used to evaluate potential
exposure to site workers via this pathway. The contaminant
concentrations (Average and UCL for private wells) in all of the
downgradient private wells sampled were used to evaluate
potential exposures to nearby residents and workers at nearby
businesses. The contaminant concentration in the site-monitoring
wells were used to assess potential exposure to future site
residents. '
Toxicitv Assessment
The first step of the toxicity assessment, hazard
identif~cation, weighs the available evidence regarding the,
potential for contaminants of concern to cause adverse effects in
exposed individua~s. The second step of the toxicity assessment,
dose-response' evaluation, quantitatively evaluates the toxicity
information and cha~acterizes the relationship between the dose
(in mg/kg-day) and the incidence of adverse health effects in the
exposed population. This is done for carcinogenic and
noncarcinogenic effects. Estimates of the probability of
31
-------
Table 8
CORTAXIRANT CONCENTRATIONS 1ft SURFACE SOILS
USED IN TUE IUSI: ESTlKATE CALCULATIONS
(..ykq)
Area A
Area 8
Areas A and 8
Site-Wide
Che...ic:a1
[noc'j'anics
""ti~ony :1. 71 3'.15 ,0,.86 ' 1.64 0.8J 1. SO;
".. ' Ars.e,n,i,c: - .: 15~O,':' :,, ',20.'6 " 5~19' 9~1-2""
,"".' 7.25, i.3~'." .. 10.0' 17-.1 "
.. ,, " . ,
Bery1liu'... 0.29 0.49 0:26 0.45 0.28 0.41 (1.36 0.44
Cadmium 0.61 1.62 1.31 2.70 0.96 1.80 0.48 0.90
Chromiull III 46.8 77.1 451 749 381 629 298 483
Cobalt 61.5 142 31.1 54.8 46.3 87.1' 30.8 SO ...9.--...-
Copper 6,112 15,&53 1,389 1,998 2,210 3,915 1,659 2,915
Load 152 203 465 801 409 689 ' 412 624
MercurY 0.04 0.11 0.12 0.24 0.08 0.15 0.06 0.10
Hickel ~8,2.93, 72,883 &,305 ,8..937 10,129. 18,045 7,5.09 13,343
Selenium 0.12 0.32 0.62 1.24 0.37 0.70 0.20 '0.36
zinc: 728 1,721 407 510 462 649 383 525
cyanide 1.~7 3.49 22.7 56.3 13.0 31.1 7.85 17.7
ICey at end of table.
Aveca'j'e
UCL
Averaqe
UCL
. Avers9'8
UCL
Averaqe
UCL
32
POOR QUAUTY
ORIGINAL
-------
Table 8
Area A
Area B
Areas A aad B
Site-Wide
Chemical
Avera..e
UCL
Avera..e
UCL
Avera..e
UCL
Average
UCL
organics
DDD 0.0441 0.112 0.0..219 0.0316 0.0356 0.0.166 0.240 0..496
DDE 1.220. 2.618 0..10.8 0.114 0.792 1.67 2.414 4.132
DOT 0..511 1.0.57 0...232 0..40.6 O.~03 0..142. 1.793 3:164
bieldrin .. "0',00.2 .' 0.0.0529 0.'.00.0..71 ".:.0...0.020.3' 0:0..68:" D.14~..
..'-.
.'
-Endosuifan Sulfat~ 0.0.188 0.0.496 0.0.338 0..0141 . 0..0.2(5 0..0483. 0..0.28 0. .0.48'1
Kethoxychlor 0.0.0.588 0.0.155 0..00.826 0.0.188 0..0.0.679 0..0.137 0..0.136 0..0.249
Itey:
UCL = Upper 95% confidence limit on the arithmetic mean
Source:
Ecology and Environment, Inc. 1991.
33
POOR QUALITY
ORIGINAL
-------
carcinogenic effects are based on slope factors. Estimates of
noncarcinogenic effects are not based on probabilities, but are
based on "reference doses." '
,'.. . .
Cancer Risks. Excess lifetime cancer risks were determined for
each exposure-pathway by multiplying the exposure level by the
chemical-specific cancer slope factor. Chemical-specific cancer
potency (slope) factors have been developed by EPA from human
epidemiological or animal studies. This information was obtained
from EPA's Integrated Risk Information System (IRIS) and the
Health Effects Assessment Summary Tables (HEAST). Risk estimates
calculated from these potency factors reflect a conservative
"upper bound" estimate of the risk posed by potentially
carcinogenic compounds. That is, the true risk is very unlikely
to be 'greater than the risk predicted and,could be substantially,
:Lower.', ,The ,resulting risk ,est:i;.mates ,a;re expres$Ed 'in scient,i~i,c
"'nota:tlon(Le'. ,,i",x 10-:6 fori/1,'QOOiOOQ;, 'indicating:',that~'" iO",this "
example, 'an individual'1s not likely'to have greater'than a one,
in one millioncnance of developing cancer over his/her lifetime'
as a result of site-related exposure). Current EPA practice
assumes carcinogenic risks are additive between chemical~ when
assessing exposure to a mixture of hazardous substances.
Therefore, cancer risks have been summed across chemicals and,
across exposure pathways. '
, "
Noncancer risks. Potential concern for noncarcinogenic e~fects
of a single contaminant in a single medium is expressed as the,
hazard index. A hazard index is calculated by dividing the human
dose by the 'reference, dose (RfD) or other suitable benchmark for
noncarcinogenic health effects. RfDs, expressed in units of
mg/kg-day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals, that are not expected to
cause an appreciable risk of harmful effects during a lifetime.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water), can be compared to the RfDs. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). RfDs used in this risk
assessment are from IRIS. The hazard index is often expressed as
a single value indicating the ratio of the estimated human
exposure to the reference dose' values. Adverse health effects
are not expected to occur if the hazard index is less than 1. As
the hazard index increases above 1, adverse effects become more
likely.
Maqnitude and Sources of Risks Posed bv site contaminants
The magnitude of the potential excess cancer risk by the
site contaminants are summarized in Tables 9-12. The hazard
indices for potential noncarcinogenic effects are summarized in
Table 11. As shown in the tables, exposure to contaminants' found
34
-------
Table 9
'...____0.
SUMMARY OF £STI~TED EXCESS CARCER RISKS
ASSOCIATED WI'll! TIlE YAJtI~ PLATING SITE
. .
Exposure
Scena rio
Exposure
Case
Receptors
Adults
Children
1 - 6
Years
Adole"c,!nts
6 - 16
Years
Compod te
Child/Adult
1 - 30
Yea rs
nisk
~ontributions
. ..b~ expoaure
Route"
. (.RMJ: Cue)
Risk I
Contributions
by Chemical"
(RME Case)
sits workers
site visitors
w
U1
Nearby
residents
Adolescent
site visitors
Nearby
workers
Average
RKE
AI!:e rage
RME
Avera'1e
RKE
Average
RKE
Average
RME
-6
3.0 It 10_5
3. 3 x 10
-6
1.2 x 10_5
1.0 x 10
-6
3.0 x 10_5
3. 8 x 10
-5
1.5 x 10_5
2.7 x 10
-5
5.9 x 10_4
1.1 x 10
-outure aite
Oesidents
00
::D:D
(Be
~~
r-- r::these columns are independent of each other.
=
-------
Table 10
.._---_.._-_..-
SUKKARY OF ESTIMATED ExCESS CARCER RISKS
ASSOCIATED WITU TU£ YAltIMA PLM'IRG SIT£
O'I'UER TDA1I 1'1I0SE DUE TO ARSB1IIIC III THB GROUNDWATER
, ,
Exposure
Scenario
EltposUre
Case
Site Workers
Average
RME
Site Visitors
Average
RME
W
0\
Nearby Residents
Average
RME
Adolescent,
AVerage
RME
Receptors
Adults
-&
1.1 It 10
-s
1. 7 It 10
1.2 x 10-6
9.7 It 10-6
Children
1-6 Years Old
Adolescents
6-1& Years Old
COllposite
Child/Adult
1-30 Years Old
Risk Contributions
,', By Exposure
}\oute"
, (RME Cue)
Soil inhalation
DernrA"l' - 34\
Son" irigestion
Drfnk,ing water
- 47\
Rfsk
Contribution
By Chemical"
(RME Case)
Nickel - 46\
Arsenic - 26\
Beryllium - 12\
DDE - 10\
DDT - 4\
Arsenic - 44\
Beryllium -20\
DDE - 18\
Nickel - 8\
DDT - 8\
Dieldrin - 1 \
Nickel - 99\
Arsenic - 1\
Nickel - 39\
Arsenic - 24\
Dieldrin - 1S\
DDE - 9\
DDT - 7\
Beryllium - S\
1.8 x 10-6
7.1 x 10-6
-7
8.0 It 10_6
3.1 It 10
-7
3.0 x 10_6
3.6 It 10
2.1'1( 10-6
1.1' I( 10-S
- 20\
- 0\
Dermal - 58\
Soif ingestion - 34\
Soil inhalation - 8\
" ,
Soil 'inhalation - 100\
DClnkipg water - 0\
soH:' inhalation - 39\
Derllal - 35\
Sol1' irigestion - 26\
Rrin~ing water 0\
-u
08
:D:D
G>O "
-c
:2:»
. >,
1-
'~
-------
Table 14
", ."
exposure
Scenario
exposure
Case
Receptors
Adults
Children
1-6 Years old
Adolescents
6-16 Years Old
Compos! ta
Child/Adult .
1-30 Years Old
Risk, contributions
. By. exposure
, Route"
. fRME Case)
Risk
Contribution
By ChemiFA1"
(RMC Case)
Nickel - 99\
Arsenic - 1 \
Nearby Workers
Future Site
Residents
Average
RME
Average
RME
-8
9.0 It 10_6
3.4 It 10
-5
3.6 It 10_5
6.5 It 10
-5
1.3 It 10_5
8.6 It 10
Soil inhalation - 99\
Drinking water - 1\
. D'umal - 50\
Soil. ingestion - 33\
. SoH, 'inhalation - 18\
Drih~in9 water - 0\
Ber'yUfulII - 7\
Arsenic - 31\
Dieldrin - 21 \
Nickel - 17\
DDe - 1:3 \
DDT - 10\
"These columns are independent of each other.
Both refer to the total recaptor risks.
w
'-I
.
.,.,
08
:B:D
G)O
-c:::
z»
~r
1-
~
-------
Exposure
Scenario
Exposure
Case
site workers
Average
RM.£
Site visitors Average
RM.£
Nearby Average
residents RM.£
W
oo
"dolescent Average
site visitors RM.£
living nearby
.
-c
08
;!!:D
(;)0
-c::
z»
>.
1-
~
Nea rby
workers
Average
RM£
Future site
residents
Average
RM.£
Table 12
SUKKARY or £STIKAT£D 8AZARD IRDI~ES
FOR NONCARCINOGENIC EFFECTS ASSOCIATED
WITU 'l'J1£ YAl:I1tA PLATIRG SIT~
Receptors
Adults
0.55
3.7
0.23
3.5
...-
0.023
0.17 .
Children
1 - 6
Years
ISubchronicl
Adolescents
6 - 16
Years
Compos! te
Child/Adult
1 - 30
Years
0.12
0.24.
0.51
2.0
3.4
7.8
. . .
. .
"I"
'. .
Hazard Indelt
Co~tributions
. by. Exposure
.'. Route-
. IRK£ Case)
':
Derma.1 - 80\
50i1 i~gestion - 13\
Soil inhalation - 6\
Drinking water - 1\
Derllla.l' -' 85\
Soil ingestion - 14\
Soi~:inha1ation - 1\
Drinking water - 89\
Soil :lnha1ation - 11\
Dernal. - 60\
soil:ingestion - 26\
Drinki~9 water - 9\
Soil inhalation - 5\
Driri~i,!g .water - 52\
Soil iri~alation - 48\
Derft~l: - 50\
Soil ingestion - 44\
Drinking water - 6\
'soil. -.inhalation - 1\
HalArd Indelt
Contributions
by'ChemicAl'
(RKE Cue)
Nickel - 76\
Copper - 16\
Chromium (III) - 6\
Arsenic - 1\
Nickel - 80\
copper - 17\
Arsenic - 56\
zinc - 25\
Chromium (III)
Nickel 6\
copper 2\
- 10\
0.39
1.8
0.14
0.27
11
23
Nickel - 69\
Copper - 14 \
Ar..enic - 6\
Chromium - 5\
Zinc - 3\
DOT - 2\
Chroaium (III)
Arunic - 33\
Zinc - 14\
Nickel 4\
- 48\
Nickel - 80\
Copper - 14 \
Arsenic - 2\
DOT .,. 2\
'These colunns sre independent ot each other.
Both reter to the totAl receptor risks.
,
1
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in soils a~ the Yakima Plating site appear to pose some increased
risk of developing cancer and an increased risk of experiencing
adverse noncarcinogenic health effects.
-
Under exist~ng site ,conditions, the estimated potential
cancer risk to all of the receptors exposed to site contaminants
by all of the exposure scenarios evaluated fell between 10-6 and
-4 . . . . "
10 ., Wh1Ch 1S w1th1n EPA's acceptable r1sk range; ,The bulk of
these risks for most of the exposure scenarios were due to
arsenic in the groundwater. The occurrence of arsenic in
groundwater and most site soils is believed to be due primarily
to the area wide legal pesticide application and was discussed
earlier in Section v. Since the groundwater arsenic risk,
dominated the estimated cancer risk and may mask risk tha~ could
be mor2:c~early related to plating operat~ons arsenic is ,excluded
. ','" from' 'grou~dw:a:ter. risks' ,su~arize<:3.' in Tab~e, 10.. H;owever'~with. or, .
': :' ,', withciut,,'A,rsehic, the es't'im~t'e.d pot:e,ritial' ca:nc~r- risk '.to'l;dl. 'or 'the'
'~eceptors exposed to.site contaminants; under bQth ,current' and
potential future site conditions, fall between io-6 and 10.4,
which is within EPA's acceptable risk range. For the site
workers, adult site visitors, and nearby residents and workers,
the most important exposure route for cancer risks appears to be
inhalation of airborne soil particles and the most important
contaminant is nickel. For adolescent site visitors and future
site residents who could be exposed to soils anywhere on site,
the'most important exposure route for cancer risks appear to be
dermal contact with soils and ingestion of soils via hand-to-
mouth contact and the most important contaminants are arsenic,
beryllium, DDE, nickel, and dieldrin.
The greatest risks associated with the site are due to
noncarcinogenic effects from contaminants in surface soils. As
shown in Table 11, increased risks of adverse noncarcinogenic
health effects (Hazard Index greater than 1) associated with
exposure to site contaminants appears to be greater for site
workers, site visitors, and future site residents. Nearby
residents and workers who do not enter the site and thus would
not contact site soils would not be expected to experience
adverse noncarcinogenic effects from their estimated exposure to
site contaminants. Dermal contact with soils and 'ingestion of
soil by hand-to-mouth contact appear to be the exposure routes
that account for the bulk of the potential noncarcinogenic
effects while nickel is one of the most important chemicals.
Lead was not included in the quantitative risk assessment,
because a reference dose or slope factor has not been developed
for lead. Various reference values were used to assess the lead
concentrations in groundwater and soil. Concentrations in
groundwater were compared to MCLs and concentrations' in soil were
compared to the interim guidance soil cleanup levels specified in
OSWER Directive 9355.4-02 and to a potentially acceptable
concentration derived using EPA's biokinetic model for,lead. The
39
.
, '.
-------
comparisons for groundwater suggest that the lead concent.rations
in groundw~ter from the site monitoring wells could pose a risk
if the groundwater from on-site monitoring wells were to be used
as drinking water without treating it to remove the lead. The
comparisons_.fgr soils suggest that the lead concentrations site-
wide and particularly in Area B could pose a risk to young
children who might play in the area or reside on site in the
future. . As stated in the OSWER directive this, risk appears to
increase above acceptable levels when the lead concentration in
the soil or dust exceeds 500-1000 ppm, therefore lead is a
contaminant of potential concern.
Ecological Assessment
A majority of the site, which encompasses the adjoining.
. gro,unq :,arq~nd the, Ya:kima J?lating" 'and A~to~ra,t:t, building~, ~nd the
,vac'a,J:tt lot', n9rth o'f ': these' buildings ~ :"h~s:- beeh ',di$tutJ;:>ed' 'and, '
l.:j..ttle vegetation: currently exist's. prior to 'development of'the.'
property for plating- operations, the area was dominated by an
orchard. The current vegetation consists of a few specimens of
big leaf maple, paper birch, red alder, and various grasses. ,The
native vegetation for this area is mainly forbs, shrubs, and
grasses. .
, '
The' sparse vegetation in the study area provides limited
cover and little food source, which are both important' aspects
for sustaining wildlife habitats. Wildlife in the vicinity of
the site may include species of pocket gophers, field and house
mice, voles, rats, rabbits, and skunks and species of common
perching birds, such as sparrows and starlings. The high level
of human activity discourages most other species from
establishing residence.
The potential impacts of site contaminants on wildlife and
domestic animals in the site vicinity was qUalitatively assessed.
Based on this assessment, no endangered species or critical
habitats in the site vicinity have been impacted or would be
threatened by site contaminants, and the ecological effects due
to releases from Yakima Plating are not expected to be
significant.
Exposure Assessment Uncertainties
The accuracy of the risk characterization depends in large
part on the'accuracy and representativeness of the sampling,
exposure, and toxicological data. Most assumptions are
intentionally conservative, so the risk assessment will be more
likely to overestimate risk than to underestimate it.
Several of the factors adding uncertainty to the estimates
tend to result in overestimation of the exposure. These include:
40
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the direct~d nature of the sampling program; the use of upper
95th percent confidence limits or the reasonable maximum
exposures (RME) for the source concentrations; the use of many
90th-percenti~e values in the exposure estimation calculations;
and the use of the steady state assumption for source
concentration estimates. One factor that could lead to
underestimation of the exposures is the use of sample
quantitation limits that could result in missing low
concentrations of some compounds that might pose significant
risks. The cumulative effect of all exposure uncertainties most
likely is to overestimate rather than underestimate the true
potential exposures.
Toxicitv Assessment Uncertainties.
.' . "., The basic uncertai.nties u~de~lyiI1g th~ ~ss'es'sm~nt .~.~ :.~.f?.e ;
. '." .tox'i~.itY-'?f a ~pe~-ica;Linctu~ie~...".:>' "::"."'. ...:. ""." ::'.. . -. .
". '.
uncertainties arising from the design, execution or
relevance of the scientific studies that form the basis of the
assessment; and
Uncertainties involved in extrapolating from the
underlying scientific studies to the exposure situation being
evaluated, including variable responses to chemical exposures
within human and animal populations, between species, and between
routes of exposure.
Risk Characterization Uncertainties
The risk characterization combines and integrates the
information developed in the exposure and toxicity assessments;
therefore, uncertainties associated with these assessments also
affect the degree of confidence that can be placed in risk
characterization results. The primary factors contributing to
exposure and toxicity uncertainties were outlined above. Two
additional uncertainty factors are the cumulative effect of using
conservative assumptions throughout the process, and the
likelihood of the actual exposures postulated occurring and
estimated in the exposure assessment. Overall, the nature of the
risk estimation process virtually ensures that the true risks
will be overestimated in order to err on the side of protecting
human health.
Conclusions for Human Health Risk Assessment
The major factors involved in estimating the site risks are:
.
The prese~ce of elevated concentrations of metals and
pesticides in the surface soil combined with the
continued use of the site for commercial purposes,
unrestricted access to the site which allows entry by
41
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potential adolescent trespassers, and the possibility
of future residential use of the site.
The presence of arsenic in the groundwater coupled with
the current and probable future use of groundwater for
drinking water supply purposes;
The presence of arsenic in surface soils which may be
responsible for the elevated arsenic concentrations in
the groundwater;
. '.. '-
. ~ ~ .' .
" "
The presence of nickel and other metals in site
groundwater which could be used as a drinking water
source by potential future site residents; and
Th~"pr~sence of"el~vate~ ~eta1s" concentration In"
. $ubsurface' 's<3'il.~. wh'ich 'could'setVe
-------
considered- (TBCs) utilized for the specific components of the
waste management process is provided.
Soil, _debris, and liquids/sludges were considered
independently, and separate cleanup alternatives were developed
for each. Several alternatives were eliminated in the screening
process because they would not effectively address contamination,
were essentially the same as other alternatives, could not be
implemented, or would have had excessive cost compared to an
alternative that would achieve the same degree of protection and
level of effectiveness. A detailed assessment of each alternative
can be found in Section 4 of the Feasibility Study (FS).
Alternatives for groundwater cleanup in the FS we~e
develope~ due to the presence of contaminants above. fe~eral an~
state drinJ:dng wat~r standards at. on~ o.n-s;i.:te.gr~q.ndwater " . .
:. monitor.in(i'w~lL:" Si.nc'e .t~is cqntamii1,at-ic>n':1i1-ay;"b~ "assC?ciat~d ..with
localized' groundwater turbidity,.". and altother wells are below"
standards, EPA has determined that a 'responseaction for the
groundwater medium is not warranted at this time. Therefore,
further discussion of groundwater alternatives is not included in
the following analysis~
Regarding the contamination under the Yakima Plating .
building an evaluation was done comparing the cost for removal of
contamination versus use of institutional controls. Based on the
concrete block construction of the building any removal of soils
beneath the building would likely compromise the overall building
structure.. In .addition any deep core s~mpling beneath the
building would require removal of the roof and walls to
accommodate drilling equipment. Demolition and removal costs for
the building were estimated to be approximately $137,000. This
assumes that all soils down to two feet under the entire building
would require excavation and disposal at a hazardous waste
disposal facility. However, the history of waste disposal
practices to the sedimentation tank and drainfield, and the
apparent effectiveness of the building as a cap would indicate
that' institutional controls are the most appropriate alternative
that is protective of human health and the environment. In the
event that removal of subsurface soils in the area of the septic
tank drain pit and the area of MW-2, which are adjacent to the
building, require extensive subsurface excavation then building
demolition will be re-considered. In such a case the costs to
support the building during this excavation could quickly become
greater than building demolition costs.
Finally, in regards to the orchard contaminants on the site
a determination has been made to not address these contaminants
iri the site remediation unless they co-occur with other plating
related contaminants. Ecology has determined that these'
contaminants were legally applied and the conditions under RCW
70.1050 (3) (b) have been established and the responsible parties
43
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are not liable for thes~ compounds. EPA's primary rationale for
not addressing these contaminants is based upon the following two
reasons: First, as outlined in section V the orchard
contaminants are considered to be present area-wide due to the
legal application of pesticides on orchards in the area (similar
to Ecology's rationale). It is EPA's policy not to clean up
areas the exceed the site boundaries and are associated with an
uncontrollable source. Secondly, and more important, based upon
EPA's risk assessment the presence of the orchard contaminants
alone in surface soils on the site does not present an .
. unacceptable risk to human health. Even the levels of these
contaminants identified in groundwater are within EPA's
acceptable risk range.
A table and summary of the alternatives that were consiqered .for
si.te :sem~~~ati~n...is"~:.esente~"..belo~..." .'..
. '"."' ;
. .'. ., ".'. .
Liqu1ds/S1udg~s'
L/S 1 Off-site Treatment and Disposal
L/S 2 Neutralization, De-Tox, Off-site treatment/Di~posal
. .
Debris.
D1
Decontamination, Abandon in-place
soil
Sl
S2
S3
Excavation, Off-site treatment/disposal
Excavation, Soil Washing, on-site disposal
In-situ solidification/stabilization
No Action Alternative
The No-Action Alternative is required by law to be developed
and acts as a baseline for comparison with the cleanup
alternatives. Under this alternative, no action would betaken
to remove liquids and sludges or cleanup debris and soils,
although a long-term groundwater monitoring program would be
implemented to monitor groundwater quality. Since this
alternative does not change contaminant concentration or
expo~ure, the risk remaining at the site after remedial
activities have been completed would be equivalent to the
current, estimated site risks based on the risk assessment
results. Consequently, this alternative is not protective of
human health and the environment and does not meet ARARs.
Liquids/Sludqes Alternatives
Alternative LIS 1:
Off-site treatment and disposal
44
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All Hazardous Waste liquids and sludges would be transported
to an EPA_approved treatment/disposal facility for either
physical or chemical treatment. The liquids are listed
hazardous wastes under the code designations F007, FOOS, and
F009. Treatment will be conducted to achieve ARARs such as
discharge requirements for liquids and land ban restriction
requirements for sludges. Residues from the treatment process
would, if necessary, be disposed of at an approved hazardous
waste disposal facility. The total volume of containerized
sludges is 6.5 cubic yards (1,309 gallons). The total volume of
liquids is approximately 7.5 cubic yards (1500 gallons). All
liquids and sludges would be placed in drums for transportation
by a licensed hauler to a treatment facility. Removal of
approximately 40 containers of waste would require 1 flatbed,
truck. Total capital costs associated with this alternative are
est,imated to ,be $20,'QOO 'for' the, slu,dges i:U1d, '$10 i{)O~ for, the ",
'liquiQ'S.,: 'There ~re 'rio 'op,~ra:ti~n'aiidma~nte'nanc~,' (O&'Mi.:'cosb,>"; "', '.
associated 'with 'this' alternative. This alternative could be', '
completed in approximately one week.
Alternative tis 2:
On-site treatment and disposal
Under this alternative liquids and sludges'would be treated
on-site using either thermal, chemical, or physical treatment
processes. These liquids and sludges contain listed hazardous
wastes and must be disposed in compliance with RCRA. The land
disposal restrictions for non-wastewater provides the treatment
standards. Residual sludges from the treatment process would be
disposed of at 'an approved hazardous. waste disposal facility.
The treatment processes would require treatment equipment to be
transported to the site and assembled. "This alternative would
take 1-2 months to complete and have an estimated capital cost of
$32,000 for the sludge treatment and $17,000 for the liquid
,treatment. These costs do not include treatability testing which
would be required prior to final treatment on site. Treatability
testing would require additional time on the order of months and
significant additional costs that could more than double the
current 'cost estimate. There are no O&M' costs associated with
this alternative since proven technology would be used for a
short period of time.
Debris Alternative
Alternative D1: Excavate around tanks and open, On-site
washing, and abandonment of tanks in-place.
Tanks would be uncovered and cleaned out using either water
or solvent washing solutions, and abandoned in place. 40 CFR
264.197(a) defines closure and post-closure requirements for tank
systems and are applicable requirements for decontamination of .
the debris. In addition, 40 CFR 261.7 is also applicable and
45
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provides guidance on how to render a container "empty" and
consequent~y exempted from being considered a hazardous waste.
The most effective washing solutions would be determined
during the ~emedial design for the site. Associated pipes would
be excavated, and disposed of with the contaminated soils, since
full decontamination would be difficult. The two tanks are
estimated to hold approximately 500-gallons each. A vacuum truck
would remove all washwater for disposal at an approved hazardous
waste treatment/disposal facility ora municipal wastewater
treatment facility depending on the levels of contaminants. Upon
completion of tank washing, the tanks would be abandoned in place
in a manner to prevent future use, and covered to grade with
clean fill material. This alternative has an estimated capital
cost between $15,000 to $17,000. The higher cost is for the use.
". of:. soJ.ye~t. '.as!' .the ..wash ~olution.. The;re are .nq. O&M.. costs . . .
'.assoc.i~ted .with.this'alternat.bT"e., ... .' .
. . . .
..
soil Alternatives
Alternative Sl:
of Soils
Excavation and Off-site treatment and disposal
contaminated soils and drainfield pipe would be excavated to
achieve MTCA soil cleanup standards and transported to an oft-
site permitted RCRA facility for treatment to Land Disposal
Restriction Standards and disposal. No site-specific
stabilization treatability studies have been conducted; however,
similar wastes. from .other sites have been. successfully
stabilized. The disposal facility would conduct treatability
testing to determine the optimum treatment formulation prior to
the commencement of the remedial action. There is approximately
100 feet of 4-inch diameter contaminated drainfield pipe. The
total volume of surface and s~b-surface soil requiring
excavationc treatment, and disposal is estimated to be 14,500
cubic feet (540 cubic yards). The total capital cost associated
with this alternative is approximately $221,000. This
alternative would take approximately 2-4 weeks to complete.
Alternative S2: Excavation, On-site soil washing, and On-site
Disposal of treated soils/ off-site treatment and disposal of
fines and washwa ter . '.
contaminated soils, which contain RCRA listed hazardous
wastes,. would be excavated and would undergo soil washing as a
volume reduction, or fraction segregation process using a mobile
treatment system. Since the contaminants tend to adhere to fine
particles, these would be separated out, resulting in a volume
reduction of 80 to 95 percent. Treated soils would be backfilled
on site and must comply with the RCRA Land disposal restriction
requirements, unless treatment reduces contaminants to below MTCA
levels and the soils are reclassified as nonhazardous. The
46
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." '"
rinsate sidestream containing solubilized metals would be
recycled through the system and eventually disposed of at a RCRA
treatment facility. In addition a smaller volume of soil fines
and drainfield pipe would also require disposal at a RCRA
treatment facility. A pilot scale study would be required to
develop the best process, choose the correct washing solutions,
and calculate the number of process stages required.. The total
capital cost associated with this alternative is approximately
$213,000, not including bench and pilot scale studies which could
increase costs by at least one third. There is no O&M associated
with this alternative. Since this is a relatively new technology
an estimate of time to complete this alternative is not
available. . .
. 0
Alternative. S3: On site. and in-place treatmentoof soils to
. achieve: LDR standards using S91idoifica~;i.on/stabll"i~ation... °
: traochn,ique's.. .~:ooo 0:. :\..0 .". '0' 0':':..::.: ..:.. /. .00 0.0.. :0'.0. ': :'. o. .0:. . " .
"
.. ~" .
In this alternative contaminated' 'soil's would be treated with
stabilization agents such as lime, fly ash or portland cement to
immobili.ze metals. The LDR requirements would not apply to in-
situ treatment. Bench scale testing of soils would be required
to optimize the solidification' procedures. Stabilized soils
would. remain on site. contaminated drainfieldpipe would be
disposed of at a RCRA treatment disposal facility. Long term
groundwater monitoring and deed restrictions would be required
beyond that required for the other alternatives. A multi-layer
cap may be required depending on. the results from the
stabilization ~ork.o A cap would also require additional
institutional controls beyond that for the other alternatives, in
order to insure the. cap is not disturbed .in the future. The
~stimated capital cost for this alternative is approximately
$99,000, not including the necessary stabilization studies and a
potential cap, which could more than double overall costs
(current treatability studies average $75,000). O&M costs would
vary depending on the length of groundwater monitoring and
whether a cap would be required. This alternative would take
approximately 2-4 weeks to complete, unless a cap is required in
which case the completion time could increase by months.
Common Elements
° All of the alternatives include the following features: (1)
groundwater monitoring to evaluate the effectiveness of the soil
and debris cleanup alternatives (present worth cost for.
groundwater monitoring at the site, ranges from $44,000 to .
$109,000 for a 5 to 30 year time period)O; and (2) . institutional
controls to ensure restricted use of the groundwater at the site,
and ensure notification to future property owners of potential
47
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contamination beneath the Yakima Plating building. Agreements. to
implement this control will be negotiated with the property owner
to ensure that the control is implemented. These controls will
be implemented at the time of the remedial action for the site.
Summarv of-Comparative Analvsis of Alternatives
For the purpose of remedy selection, the relative
performance of each remedial alternative was evaluated in
relation to three categories of criteria: (1) threshold criteria
(a required level of performance]; (2) primary balancing
criteria; and, (3) modifying criteria. The nine evaluation
criteria and the results of the evaluation are discussed below.
.A.
Tb~eshold criteria
""The r~m~diai 'a'lternat.:l.ves' 'w~re.f'irst' ,evaluated, in, 'reiatioh,'
to.ti-te ,threshold .criteria: .6verali'protectlon'of, human'health
and the enviro~ment, and compliance with ARARs. The threshold
criteria are statutory requirements and must be met by all
alternatives that remain for final consideration as remedies for
the site.
, .
1. Overall Protection of Human Health and the Environment.
This criteria addresses whether or not a remedial alternative
provides adequate protection and describes ~ow risks are
eliminated, reduced, or controlled through treatment and
engineering or institutional controls.
All of the alternatives except the No Action Alternative are
protective of human health and the environment.
The alternatives for liquids/sludges are both considered to
be fully protective of public health and the environment. The
significant difference between the two alternatives is defined by
how the containerized waste are treated and disposed. The'
removal and off-site treatment, or on-site treatment and ciff-
site treatment of all containers of liquids and sludges
completely eliminates the potential for migration of contaminants
or exposure.
Alternative D1 for debris is considered to be fully
protective of public health and the environment by eliminating
the residue of contaminants from the site and preventing a
potential source of contamination to groundwater.
Overall protection of human health and the environment at
the site is increased substantially by all soil alternatives.
All alternatives either treat off-site or treat on-site soils to
reduce the overall Hazard Index for site soils and ultimate risk
to human health posed by the site. Alternative 81 off-site
treatment and disposal at a permitted hazardous waste landfill,
48
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would be fully protective if soils were removed down.to health
based leveis or MTCA soil cleanup levels as proposed.
Alternative S2 offers an additional degree of protection,
assuming that_successful soil washing processes can be identified
during treatability studies, since the contaminants would be
removed from the site soils without the risks associated with
transporting a large volume of contaminated materials over long
distances. Alternative S3, in-situ stabilization, would also
provide adequate protection as long as the stabilized soils,
which remain on-site in an encapsulated form, remain undisturbed
and maintain their structure without leaching.
2. Compliance with ARARs. This criteria addresses whether
or no~ a remedial alternative will meet all of the applicable or
, relevant and appropriate 'requirements orproyide,g~ounds for'
" 'invoking':cl waiver.:",'See, Section :X"f(jr'a ':ctiscuss'ion of, .sp-eci"fic'.
ARARs considered in this' analysis. "",,' '.' , ' .' '
The No Action alternative would not comply with the MTCA,
cleanup levels for soil (WAC 173-340-700 through 760), which is
an ARAR for the site.
. . '" .0..:. ,".
Alternatives LIS 1 and LIS 2 would both meet their
respective Federal and State ARARs by using well established
regulated technologies and regulated disposal facilities. The
liquids are listed hazardous wastes under the code designations
F007, F008, and F009. Compliance with all LDR requirements (40
C.F.R.' Part 268), hazardous waste gene'rator and transporter
requirements at 40 C.F.R. Parts 262 and 263, and requirements for
treatment storage and disposal facilities (40 C.F.R. Parts 264
and 265) would apply to these wastes and could be achieved by
removal of waste to a licensed RCRA treatment and disposal
facility. The sludges and liquids would be treated to meet the
concentration -based LDRs prior to being placed in an off-site
RCRA permitted landfill.
40 CFR 264.197(a) for closure and post-closure requirements
for tank systems and 40 CFR 261.7 in emptying and decontaminating
the tanks are ARARs for the Debris. These requirements require
that all waste residues and contaminated containment system
components and structures, must be "removed" or "decontaminated".
Alternative D1 complies with these requirements by removing
wastes and decontaminating the tanks.
Alternatives Sl, S2, and 53 could be designed to comply with
ARARs by using regulated procedures and technologies. Sl and 52
would require 'removal of soils to achieve compliance with MTCA
soil cleanup levels. RCRA Land Disposal Restrictions (LDR5)
would apply to Sl and 52 where wastes are treated and disposed of
either on or off-site. The contaminated soils will have to be
treated to meet the concentration-based LDRs outlined in 40
49
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C.F.R. Part 268 prior to being placed in an off-site landfill.
These requirements will be met through the use of a RCRA
treatment disposal facility. RCRA LDRs would not apply to
alternative S3 where wastes remain in-place on-site. However,
certain lan9 treatment facility requirements (40 C.F.R. 264.270-
283) may be relevant and appropriate. If the treated soils in
alternative S3 remain contaminated with hazardous substances at
levels that exceed MTCA cleanup levels, MTCA compliance
monitoring (WAC 173-340-410) and institutional control
requirements (WAC 173-340-440) will app;Ly.
B.
primary Balancing criteria
, "
Once an alternative satisfies the threshold criteria, five
primary palancing criteria are used to evaluate the tech~ical and
eng~n~ering asp~cts., ?f t}}.e. remed~al, alter~~~ives.,. ,,: '., '
",,:=" 3'~':: 'Lo'nq~~e~' '~i'~ect~ven~~~"~n~"~~~an'e~'c~."'~~is'~rJ."te'r.fa
refers to the ability of a remedial alternative to maintain
reliable protection of human health and the environment once
remediation goals have been achieved. The magnitude of residual
risk is considered as well as the adequacy and reliability of
controls'. '
Alternatives LIS 1 and LIS
reduce the risk associated with
the wastes are removed from the
hazardous nature.
2 effectively and permanently.
the liquids and sludges in that
site and treated to reduce their
Alternative D1 has little long-term residual risk associated
with it. The technology used to control the wastes is reliable,
permanent and readily available.
All soil alternatives are effective in reducing the long-
term risks at the site. In alternative Sl treatment occurs at an
approved off-site treatment disposal facility thereby removing'
contaminants from the site. Alternative S2 is the only
alternative examined that provides decontamination of the
majority of the site soils which also reduces risks at the site.
In alternative 82 the volume of contaminated soil on the site
would be reduced by 80 to 95 percent. The remaining contaminated
soils (5 to 20 percent) would require disposal at a off-site RCRA
disposal facility where it would be treated. In 83 treatment
occurs in place at the site. The effectiveness of 83 in the long
term is not well known and depends on the efficiency of the in~
place blending of chemical reagents with the soil and the
performance of the stabilized materials with re~pect to leachate
release and the effects of freeze-thaw cycles. A long term
groundwater monitoring program would be necessary with 83 to
ensure protection of the groundwater. '
50
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4 . R~ductioD
criteria refers to
technologies which
alternatives,_such
of Toxicity, Mobility, or Volume. This
the anticipated performance of treatment
will be used in the various remedial
as solidification and incineration, etc.
Alternative LIS I and LIS 2 both employ treatment in the
remedy to reduce toxicity, mobility, and volume. LIS 2
accomplishes 'treatment at the site where the toxicity and
mobility of the wastes are reduced prior to off-site shipment for
disposal.
'"'.
Alternative SI, off site solidification and disposal, would.
further restrict contaminant mobility by placing the wastes
within an approved RCRA landfill. contaminant toxicity or volume
is not reduced in the off-site disposal alternative.
. Al terna t i yes' S? al1d S 3 meet th'e.pre.ference. ~or treatm~nt to' .
. . reduce' the .toxicity, . mqbility t arid" vol \,line "of the" "c::ontaJi).ihatianat.
"the site more effectiveiy than Sl. "Alternative S3 woUl~ reduce
. mobility, and perhaps toxicity, by immobilizing the contaminated"
soils. However, the waste volume may increase substantially,
depending on the types of fixation agents used. Assuming.
successful treatability testing results alternative S2" is
effective in'redu~ing the toxicity, mobility, and volume of
contaminated soils.
s. Short-term Effectiveness. This criteria refers to the
period of time needed to achieve protection, and any adverse
impacts on human health and the environment, specifically site
workers and community residents, that may be posed during the
construction and implementation period until cleanup goals are
achieved.
Alternative LIS 1 provides the greatest short-term
effectiveness in that the waste is disposed of quickly and
completely with minimal risk during waste transport. The
effectiveness of LIS 2 is reduced due to on-site short term human
health risks associated with waste handling and the treatment
process. The significant difference between the two alternatives
involves the potential for evolution of cyanide gas during on-
site pretreatment and the possible impact on remediation workers
and the surrounding community. In addition Alternative LIS 1 is
superior to LIS 2 in that pretreatment is performed at an off-
site facility where equipment and the reliability of controls is
greater. In addition~ cyanide detoxification would occur at a
controlled industrial site, rather than the Yakima Plating site
in a residential area.
The short term effectiveness of Dl is immediate as the
cieaning of the tanks and pipes would take less than one week.
The effect of the alternative on the surrounding community and to
on-site workers would be negligible. Environmental impacts would
be minimal. . . .
51
.
. ., ~
-------
- -
It is estimated that all the soil alternatives could be
accomplished within one construction season after commencement of
remediation. However, if extensive treatability testing, pilot
scale work, _o~ cap installation is required the time estimated to
accomplish alternative 52 or S3 could increase significantly. A
potential for worker and community exposure by inhalation of
contaminated dust during excavation exists for all of the
alternatives involving excavation of soils and/or decontamination
of debris. This would be particularly prevalent with Alternative
S2, which would reqUire additional soil handling as compared to
the other two alternatives. All soil alternatives would require
strict air pollution engineering controls to reduce the exposure
potential. Alternative 51 involves transporting soils which
would increase potential community exposure and increase traffic
c;::onges.tion and- the. ri~k: . Qf an accident..'. Howev.'er, : the'. ~otal vpl.ume.
. pf -.soiJ:'s: cpuld. '.be 'removed. 'from the"'site with- :30..: trU.ck,'.loads,:': .'. . <.
.. 'which would not c"ause: a: sign'ificant ~mpact .to :the 'community: . . '.
Alternative 53 probably is the most protective on a short-term
basis, because the contaminated soils would only be minimally
disturbed during .the remedial process. Some dust and would be
created during the stabilization process, but that could be .
minimized through dust-control practices. All alternatives' have.
the potential to mobilize contaminants to groundwater as
excavation approaches the groundwater table. This effect could
be minimized by conducting soil removal at the seasonally low
groundwater level. .
.." .
.- .
6. Implementability.'. This' criteria refers to the
technical and administra'tive feasibility of a remedial
alternative, including the availability of goods and services
needed to implement the selected remedy.
Alternatives L/S 1 and L/S 2 are readily implementable using
existing available technology. Alternative L/S I allows a "one-
stop" contract process as opposed to working with several
separate contractors/subcontractors to perform the neutralization
cyanide detoxification pretreatment.
The equipment required to perform the tank and pipe cleaning
is readily available, mobile, and reliable. Excavation of only
the drainfield pipe and tanks would be required for this
alternative. There would be no maintenance of the equipment.
Off-site disposal, 51, could be readily implementable. .
There are two suitable landfill sites in the Pacific Northwest
and licensed haulers are readily available for transport of the
waste. Controls would be necessary to minimize fugitive dust
emissions during excavation, transport and disposal.
Alternative 52 would be the most difficult soil alternative
to implement. The technology requires that mobile equipment be
52
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transporteq and set up on site. In addition, the reliability of
this process is not well known. A full-scale study has never
been completed for this technology and it is not considered
widely available for use. The equipment and personnel would have
to be highly specialized. .
Alternative S3 would be more difficult to implement due to
uncertainties associated with the reliability and effectiveness
of solidification and the potential for an increase in volume
'that occurs during solidification. None of these uncertainties
can be fully addressed until after treatability studies are
conducted. If the in-situ process was not successful, stabilized
soils would have to be removed to an off-site disposal facility
or covered with a multi-layer cap. In addition the future use of
the sLte,would have ~o be severely restricted, since contaminants
~~u.ld remaip. on si.t,e. . ' ' . , ' .'
. ~ . . ......... : : . . . .." . ,".'.".
, "
, .
7. Cost. This criteria refers to the cost of implementing
a remedial alternative, including operation and maintenance
costs.
Alternative L/S' 1 is the least expensive of the
liquid/sludge alternatives. The cost for this alternative ,is
roughly two thirds the cost of L/S 2. This primarily is due to
the additional mobilization costs and equipment operating expense
associated with alternative L/S 2.
The total cost of the de,bris alternative is $15,0.00'. This
includes costs for excavation, cleaning, disposal of rinsate and'
decontaminated pipe, and backfilling.
The costs of Alternatives S1 are the most certain at
$221,000. .The costs for S2 are less certain. capital costs for
S2 are $213,000 but treatability studies could increase costs by
at least one third. The costs for S3 are even less certain.
capital' costs for S3 are $99,000 but treatability testing, a
potential requirement for a cap, and groundwater monitoring would
increase costs for this alternative significantly above S1 and
S2.
c.
Modifyinq criteria
Modifying criteria are used in the final evaluation of the
remedial alternatives after the formal comment period, and may ,be
used to modify the preferred alternative that was discussed in
the proposed plan.
8. state Acceptance. This criteria refers to whethe+ the
state agrees with the preferred remedial alternative.
53
.
"
-------
Ecology concurred with the selection of the preferred remedial
alternativ~as presented in the proposed plan. Ecology has been
involved with the development and review of the Remedial
Investigation/Feasibility study, the Proposed Plan, and the
Record of D~c~sion.
9. community Acceptance. This criteria refers to the
public support of a given remedial alternative.
written comments were received during the public comment period
from the property owner. These comments were made regarding the
contaminants identified beneath the Yakima Plating building and
are addressed in the Responsiveness Summary in Appendix A.
, '
Yakima residents present ,at the public meeting on August 21,
'1991,',.did ,not ~xpi:ess"a, preference for a particular. 'alternative;
,nor-".'was: 1:b~re any 'ot'posd:tion- :to' the,:'EPA":pi:$ferred ~lternativ~.:',
Community 'response is 'presenteC;i in th~ R:esponsiveness summary,
which addresses questions received during the public meeting and
the comment period.
"
IX.
THE SELECTED REMEDY
The selected remedy is off~site treatment and disposal of
liquids and sludges, decontamination of debris, and off-site'
treatment and disposal of soils. The selected remedy also
includes institutional controls for contaminants remaining on
site and monitoring of on-site groundwater. '
The selected remedy is protective of human health and the
environment, complies with state and federal laws, and is cost
effective. It utilizes readily available technology for
treatment and disposal of liquids/sludges and soils to prevent
groundwater contamination. Promulgated state rules and
regulations which are more stringent that federa~ requirements
are included as ARARs.
Maior Components of the Selected Remedv
Liquids and sludges that are currently in tanks and
containers would be removed and treated and 'disposed off-site at
a permitted RCRA hazardous waste facility. Remaining empty'
tanks/containers would either be decontaminated with other debris
or disposed of with soils and pipes. This procedure would remove
a potential sources of contamination to soil and groundwater
using demonstrated, reliable technologies to treat and
permanently dispose of these materials.
54
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Underground tanks would be uncovered and decontaminated
using either a solvent or water wash solution. Upon
decontamination the tanks would be abandoned in place, in a
manner to pIevent future use, and covered to grade. Drainfield
pipes would be excavated and disposed of along with other site
soils, unless decontamination on-site can be achieved.
Conformational sampling would be conducted to insure that
decontamination of debris was successful. Liquids/sludges
generated during the decontamination would be treated and
disposed at an off-site hazardous waste facility. This procedure
would eliminate a possible future source of contamination to
soils and groundwater.
contaminated soils. above cleanup standarqs w.ould be
excavated, treated, a~d disposed of at ~ RCRA permitted hazardous.
wa$te la.nd1;ill.. ,.Conformatio'nal sampling' would be yonducted .to .
. insi,lre' .that. r~m.oval' .Of soils-to. .G.leanup.levels. .has peen' ach'ieve~ :;.. '.
This'procedur~would reduce contamination to levels that are .'
protective of human health by lowering EPA's Hazard Index in .
surface soils and subsoils. Excavation and removal of these
soils would achieve MTCA Method B cleanup levels, and remove a
large proportion of the site contaminants that could, if remain
untreated on-site, ultimately impact groundwater. .
Institutional controls would be implemented to minimize
potential exposure to release of hazardous substances during and
following remedial activities. The purpose of these controls is
to restrict groundwater use at the site, protect future workers
in the Yakima Plating building from residual contamination on'.
walls and floors, and require conformational sampling under the
building when it is eventually demolished (either during or after
the remedial action). .These controls would remain in effect
until building contaminants are characterized and remediated, if
necessary, and until the groundwater monitoring program.
demonstrates that groundwater is below applicable federal and
state standards and allows for unlimited groundwater use.
A groundwater monitoring program would be implemented to
insure. that the selected response action remains protective of
human health and the environment. This program will specify
which wells are to be sampled, how often, .sampling procedures,
and analytical methodology. In addition the number and locations
of existing wells will be evaluated for their effectiveness in
the groundwater monitoring program. Additional wells will be
installed, by EPA, if EPA determines in consultation with.
Ecology, that the existing network is not adequate. Monitoring
will generally consist of quarterly samples for the first two
years following completion of remedial activities, at a minimum.
If deemed appropriate, the sampling rate will be reduced to a
lesser frequency for an additional 3 years~ This program and
well network will be evaluated periodically, by EPA, until
55
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contaminant levels in all wells indicate that no further action
is require~at the site.
To the extent required by law, EPA will review the site at
least once every five years after the initiation of the remedial
action. This-review assures that the remedial action continues
to protect human health and the environment and assesses the need
for additional remediation by, EPA, for any hazardous substances,
pollutants or contaminants remaining at the site. EPA will also
evaluate risk posed by the site at the completion of the remedial
action (i.e. before the site is proposed for deletion from the
NPL). EPA will continually monitor groundwater to insure that
the remedy is protective of public health.
Remediation Goals
'. . . .
, :,'By uti~lz'i~g: 'the' res:ui t~ ,of the ~Pl\. ,: risk "as~es~merit " : ",' ':-: .-' , "
: revi~wing site ARARS~ consi,dering factors' related to technic'al " ,
'limitations such as detectionjquantitation limits, past history
of the site, uncertainties and other pertinent information,
chemical-specific remediation levels have been developed ~o
mitigate existing and future threats to human health and the
environment. Cleanup'levels in soil'and groundwater are set at
the more stringent of NCP and MTCA standards.
'. ."". ..
Soils and Groundwater
The MTCA cleanup standards at WAC 173-340-700 through 760
are relevant and appropriate requirements for the site. Ecology
has indicated that the MTCA Method B cleanup standards for
56
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residential sites should be applied to Yakima Plating. These
standards for soil and groundwater have been calculated by
Ecology acc9rging to WAC 173-340-720, and are as follows:
Constituent
Soil (mq/kq)
Groundwater (uq/l)
Arsenic
Barium
Cadmium
Chromium
Lead
Nickel
Selenium
cyanide
DDT
20.0
4,600.0
40.0
400.0
250.0
1,600.0
240.0
1,~00.0
2.9
5
800
8
80
50
320
48
320
" .26
, ' ,
'". ." .
. .0' .,.
These concentrations are;estimated, by ~cology" to result in
no acute or chronic toxic effects on human' health via'd1rect .
contact with contaminated soil by ingestion and inhalation and
ingestion of groundwater. Arsenic levels were set at natural
backgrouhd for Washington State as determined under MTCA Method
A; thus, arsenic was not. 'included in Ecology's risk calculations.
DDT, as an orchard contaminant was also not included in Ecology's
risk calculations. Lead cleanup levels are based on MTCA Method
A values, because no reference doses or slope factors are
available.
"..".: .
Based on the sampling results from the Remedial
Investigation these levels will apply to the locations identified
in figure 7 and disGussed in Section V, and correspond to those
areas impacted by plating activities at Yakima Plating. These
areas are as follows: Area B surface soils (those identified in
figure 7), limited locations in Area A, South ventilation Area
surface soils, MW-2 subsurface soils, Septic tank Drainpit
subsurface soils, and DrainlinejDrainfield subsurface soils
(those soils associated with the drainline). Excavation will
occur in these areas and soils will be removed to the MTCA Method
B levels identified above (volume estimates for these areas were
presented in section VII.). Conformational sampling will be used
to identify locations and insure that all soils in these
locations, above MTCA cleanup levels, are removed. As previously
discussed orchard contaminants (arsenic, lead, DDT etc) in Area
A, Area B and the ventilation area will be remediated only if
they co-occur with soil contaminated above clean up goals for
plating associated wastes.
57
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",
MW-8 -$-
FENCE
, '
" . ..'
. ," ,,'
",' '"
" .
APPROXIMATE LOCATION Of'
SEPTIC TANK DRAIN PIT AREA
, 1
M/{-8
l£GENO
RJa AAE.A Of" CONTAMINATION FOR
IL.Lj FACILITY SURfACE SOILS
r7A AREA Of' CONTAMINATION FOR
~ ORAlNF'l ELO St&'ACE SOl LS
IoC)H I TOR I NC 'Et.L
SCALE: I" =30 '
N
,"
. ',", .,.. .",.
'OFF I CE
BUILDING
MW-2
YAKIMA
PLATING
FACILITY
PAINTING
BOOTH
VENTILATION
EXHAUST
'DEf1NED AAEAS OF
SURFACE SOIl CONTAMINAl1ON
YAKIMA PLA liNG
YAKIMA. WA
Figure 7
58
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x.
STATUTORY DETERMINATION
The prDcedures and standards for responding to release of
hazardous substances, pollutants and contaminants at the site
shall be in' accordance with CERCLA, as amended by SARA, and to
the maximum extent practicable, the National oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 300
(1990), promulgated in the Federal Register on March 8, 1990.
'. .
EPA's primary responsibility at Superfund sites is to
undertake remedial actions that are protective of human health
and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences,
including: a requirement that EPA's remedial action, when.
. compiete, must complY'.with applj.cable or. relevant and appropr,iate..
. '~nvi:i:pmD.ental 'standards 'e~tablisbed' under' fe'd~'ral'.laws' and' :.'..., '.
promuigated st.~te. laws', unless' a: 'statutory waiveri's inv'oked; a:
requirement that EPA select a remedial. action that is 'cost-
effective and that utilizes permanent solutions and' alternative
treatment technologies or resource recovery. technologies to the
maximum extent practicable; and a statutory preference for
remedies that. permanently and significantly reduce the volume, .'
toxicity'or mobility of hazardous substances over remedies that
do not achieve such results through treatment. Remedial
alternatives at the site were developed to the maximum extent
practicable to be consistent with these congressional mandates.
The seiected remedy meets statutory requirements of Section
121 of CERCLA, as amended by SARA, and to' the maximum extent
practicable, the National Contingency Plan. The evaluation
criteria are discussed below.
A.
Protection of Human Health and the Environment
The selected remedy will provide long-term protection of
human health and the environment by removing the contaminated
soil and eliminating it as a potential source of groundwater
contamination. These measures will also eliminate the exposure
routes of inhalation and ingestion of contaminated soil
particles, dermal contact with contaminated soil, and ingestion
of contaminated groundwater.
No unacceptable short-term risks or cross-media impacts will
be caused by implementation of the remedy. Soil excavation and
debris decontamination could involve short-term exposure through
inhalation of contaminated soil particles by site workers and
nearby residents and dermal contact with contaminated soils by
site workers. Thes~ exposures can be eliminated through the use
of air monitoring and proper dust control measures during
remedial activities, and by implementing a strict site-specific
health and safety plan.
59
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Institutional controls will also assist in controlling land
and ground water uses.
B.
Compliance with ARARs
The selected remedy will comply with all applicable,
relevant, and appropriate requirements. No waiver of any ARAR is
being sought or invoked for any component of the selected remedy.
The laws and regulations of concern include but are not limited
to the following:
Chemical-Specific ARARs
Chemical-specific requirements are usually health-or risk-.
'. ,based.~numerica1:..vales or'I!)..ethodol.ogies, ti,lat estab,li~h the. ,.
. "~a,ccept~:b:J,.e' 'aIjtoUri~ o'r qoncehtrat'ion :o'f". a... 9~emica,l-' 'in, the -ambient,
environment. The following are the chemica~ spe~ific
'requirements for Yakima Plating.
Cleanup standards from the Washington State Model Toxics
Control Act (MTCA) Method B (WAC. 173~340-740(3) will be the
primary ".applicable" chemical. specific ARAR. Cleanup standards
were calculated using MTCA Method B using the ".residential". site
scenario. Electroplating related substances in the soil and
groundwater that exceed MTCA cleanup standards include cadmium,
lead, chromium, and nickel.
. .
Safe Drinking Water Act (SDWA) Maximum contaminant .Levels
(MCLs) (40 C.F.R. 141-147) are relevant. and appropriate to the
groundwater at the site as well as MTCA Level B groundwater
cleanup levels (WAC.173-340-740(2). For Yakima Plating, the SDWA
MCLs are important ARARs for groundwater cleanup only to the
extent that the method B cleanup standards calculated under MTCA
must be at least as stringent as the MCLs. None of the
contaminants of concern have been detected at levels exceeding
their MCLs, except for MW-2 and one sample from MW-7, which was
discussed in Section V.
Location specific ARARs
No location-specific ARARs affect the remedial action to be
implemented at the Yakima Plating site.
Action-Specific ARARs~
. Action-specific ARARs are technology-or activity-based
requirements or limitations on actions affecting hazardous'
wastes. These requirements are triggered by the particul~r
remedial activities selected to cleanup the site. .
60
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Liquids and Sludges contaminated with listed wastes must be
handled as hazardous wastes, according to the requirements under
RCRA at 40 C.F.R. Parts 260-265, when these materials are
transported, treated, and disposed of. The spent plating
solutions and sludges have been identified as RCRA listed
hazardous wastes. Septic and sedimentation tank sludges are also
listed RCRA hazardous waste. contaminated soil and groundwater
must be managed as hazardous waste until they no longer "contain"
hazardous waste (i.e., have been treated to below risk-based
levels). Sludges and soils will have to be treated to meet the
concentration-based LDRs prior to being placed in an off-site
RCRA permitted landfill. These requirements will be achieved
through use of a RCRA approved treatment and disposal facility.
. ~o CFR 264.197(a) defines 9losure and post-closure.
. requj,.remen1;:s for .:ta.nk .systems and .are applicable.: requi'r~ment? for'
depontaminatidn of the .debris. "In addition:,' 40. .CFR 261'.7.' is.-a:l,so
.applicable and provides guidanc~ on how to render a cont~iner '
"e:mpty" and consequently exempted from being considered' a
hazardous waste. These requirements apply to the debris and
will be achieved through the decontamination procedures. .
since contaminated.soils above MTCA cleanup levels could
remain beneath the Yakima Plating building MTCA compliance, '
monitoring and institutional control requirements (WAC 173-340-
360{8) (b) will be applicable. These requirements will be
achieved through the use of institutional controls on the
property and the ground~ater monitoring program.
Federal and State air standards are administered at the
local level. Emissions (dusts) from the soil excavation and
removal activities will comply with these standards by using
standard and best engineering practices for dust control.
C.
Cost-Effectiveness
.The selected remedy is' cost-effective when the degree of
protectiveness it provides is compared to the overall
protectiveness provided by the on-site treatment technologies.
Given the uncertainties associated with the costs for the on-
site treatment options they do not offer significant savings over
the selected remedy and in fact could ultimately be substantially
more costly.
D. utilization of Permanent Solutions and Alternative Treatment
Technoloqies or Resource Recoverv Technoloqies to the Maximum'
Extent Practicable
In selecting a remedy consideration was given to the total
volumes of material to be remediated, the long term effectiveness
and permanence, reduction in toxicity mobility or volume, short-
term effectiveness: implementability: and cost. In addition
61
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consideration was given to the current and potential future use
of the property. The selected remedy provides the best balance
of tradeoffs in addressing these considerations.
The se~e~ted remedy provides a permanent solution with a
proven technology to meet the land disposal restriction
requirements. The selected remedy provides minimal uncertainty,
and minimal long term-and short term risk. The selected remedy
is more reliable, is cost-effective, and can be implement with
less difficulty and no greater short term impacts than the other
treatment alternatives. It is therefore considered to be the
most appropriate solution to contamination at the site and
represents the maximum extent to which permanent solutions and
treatment are practicable.
.E.
Preference for Treatment as a Principal Element
. -. . . . ::.' . . \. . '. . .' . . . .
. .
. ..
. '. . .
The selected remedy. satt"sfies, in part:,. .the statutory. .
preference for treatment as a principal element. The principal
threat to human health is from ingestion .of and direct contact
with contaminated soils. Soils will be treated prior to disposal
at an approved RCRA landfill. This remedy ~mploys treatment.
technologies. as. required by the RcRA land disposal restriction
requirements.
XI.
Documentation of Significant Changes
The proposed Plan for the Yakima .Plating site was released
for public comment on August 13, 1991. The proposed plan
identified Alternatives LIS 1, 01, and S1 as the preferred
alternatives. written comments from the Yakima Plating property
owner and the Washington Department of Ecology were received
during the public comment period and are addressed in the
attached.responsiveness summary. Based Upon the response to
these comments no significant changes to the remedy, as. it was
originally identified in the Proposed Plan, were made.
62
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App~ndix A:
Appendix B:
APPENDICES
RECORD OF DECISION
YAKIMA PLATING
YAKIMA, WASHINGTON
Responsiveness Summary
Administrative Record Index
63
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YAKIMA PLATING SITE RESPONSIVENESS SUMMARY
I. CommuD1ty Relations History
CERCLA r~~ements for public participation include
releasing the Re~edial Investigation and Feasibility study
Reports and the\~rOPO~d Plan to the public and providing a
public comment pe~iod 0 the Feasibility study and Proposed Plan.
EPA met these requ~remen in August 1991 by placing both
do~u~ents i~ the public in ~rmation rep~si~o~ies for the sit7 ~nd
ma111ng cop1es of the proposed plan to 1nd1v1duals on the ma111ng
list. EPA published a notice~f the release of the RI/FS and
proP9sed plan in the Yakima Herald on August 12'and September 1,
1991. Notice of the 30 day public comment period and the public
meeting discussing the proposed plan were' included in the
newspaper notice. A public meeting was held on August 21, 1991,
at the Cascade Natural Gas Building. The public comment period
ended on September 11, 1991, with one letter from the public. '
To date, the following community relations activities have
been conducted b~ EPA at the Yakima Plating site:
March 1990
May 1990
May 1990
February 1991
August 8, 1991
August 12, 1991
EPA distributed a fact sheet inviting'
citizens to an open house, with the purpose
of developing a Community Relations Plan.
EPA released a Community Relations Plan,
which included interviews from members of the
community and local officials.
EPA released a fact sheet announcing the
beginning of the RI/FS and the availability
of the community Relations Plan.
EPA released a Yakima area fact sheet, which
included all the sites in the Yakima area.
Yakima Plating section contained history of
the site activities.
EPA mailed the proposed plan fact sheet,
which explained the results of the RI/FS and
EPA's preferred plan for public comment. The
fact sheet announced a public meeting for
August 21, 1991, and gave the dates of the
public comment period.
A public notice in the Yakima Herald
described the availability of the proposed
plan and the RIfFS, and announced the ,dates
of the public meeting and public comment
,pariod.
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August 13 - September 11, 1991
Public comment period for
proposed plan and RIjFS.
September 1, 1991
Additional pUblic notice in the Yakima Herald
announcing the end of the comment period on
September 11, 1991.
August 21, 1991
EPA conducted a public meeting for interested
community members.
September 20, 1991
Responsiveness Summary prepared.
II.
overview
Yakima Plating is a plating facility located within the
southern city limits of Yakima, at 1804 1\2 South Third Avenue.
The area surrounding the site is primarily mixed residential and
light commercial property.
The facility conducted electroplating operations of
automobile bumpers from the early 1960's until 1990" During its
operation, the facility discharged a number. of plating wastes to
an on-site sedimentation tank and drairt field. These wastes
contained a variety of metals including nickel, cadmium and
chromium. .
In 1986, an EPA site investigation found evidence of heavy
metals in the ground water at Yakima Plating. On March 31, 1989,
the site was placed on EPA's National Priorities List of sites
requiring further investigation.
EPA recently completed the RIjFS and the Human Health'Risk
Assessment for the site. These reports may be reviewed at the
information repository.
On August 12, 1991 EPA published it's preferred alternative
for cieaning.up the site, in a document called a Proposed Plan.
The Proposed Plan, as well as the reports of the investigation,
were released for public comment. EPA's preferred alternative
included:
Excavation and decontamination of underground tanks on-
site.
Removal of liquids currently stored in containers.
Excavation of contaminated soils.
Disposal of contaminated materials at a hazardous waste
disposal facility.
Monitoring of groundwater until it is determined that the
remedy has been successful.
2
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Institutional controls to restrict site use.
The remainder of this document discusses the comments
received during the comment period from August 12 to September
11, 1991. - .
III. summary of Comments Received and Lead Agency Response
EPA held a public meeting on August 21, 1991 at the Cascade
Natural Gas Building. Approximately seven people attended the
meeting. At this meeting representatives of EPA provided
information on the history and the RI/FS including the risk
assessment and a summary of the proposed plan. A question and
answer period followed the EPA presentations. Questions included
the timing of the proposed remedial action, contamination.
asso~iated with the building, dust control, sampling procedures,
use of institutional controls, the role of the state, and general
technical questions regarding the findings of the RI/FS.
A copy of the meeting transcript, which includes all
questions and answers, is available at the Yakima Valley Regional
Library.
The following is a summary of the questions posed to EPA
during the public comment period and EPA's response to. those
questions:
Comments From the Yakima Plating Property Owner
1. One comment stated that the removal of the debris from
the site was not fully considered and that institutional controls
. would still be required for these materials.
Response: The debris alter~ative will decontaminate the two
undergroupd tanks with either a water or solvent rinse.
contaminated wastewater will be removed for off-site treatment
and disposal. The underground drainfield pipe will either be
decontaminated or removed from the site with the contaminated
soils. After completion of these ste~s there will not be any
contamination associated with the debris and therefore
institutional controls will not be required for these materials.
2. Another comment requested that EPA fully consider
additional sampling under the Yakima Plating building and removal
of contamination if warranted, even if building demolition would
be required.
Response: The presence of the building, as a cap, in combination
with the current information on potential contamination under the
building appears to be adequately protective of public health.
The building floor currently protects individuals from direct
contact with soils and reduces the potential for rainwater to
3
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. .
infiltrate through soils to groundwater. In addition, as part of
the overall remedy for the site groundwater monitoring will be
conducted to insure that the site remedy continues to be
protective. -Inptitutional controls related to the building will
also be required until additional sampling is conducted and
appropriate action, if necessary, is taken.
There is the possibility that excavation of soils in the
area of the septic tank drain pit and MW-2 could impact at least
a portion of the building. If this is the case EPA will have to
re-evaluate the alternatives associated with the building.
Language to this effect will be included in the ROD. If it
became apparent that building demolition would be required in
order. to remove all contaminants in these areas the ROD would be
amended by an Explanation of Significant Difference.' In such a
case EPA would conduct additional sampling under the building and
take appropriate action based upon the results.
Comments from the washington Department of Ecology
1. Filtered groundwater samples are not acceptable for
demonstrating compliance afte~ source removal. .
Response: EPA's goal in sampling is to collect samples which
accurately represent the groundwater quality. The actual type of'
sampling (filtered vs. unfiltered) as well as other groundwater
monitoring details will be developed during the remedial design
and remedial action phases for the site. This program will be
developed by EPA, in consultation with Ecology.
2. Language in the ROD should completely discuss rationale
for the orchard contaminants remaining on site.
Response: Based upon the sampling information collected during
the RI/FS, historical aerial photographs for the site, and our
knowledge of pesticide use in the area in the past it is apparent
that the orchard contaminants (lead, arsenic, DOT) are not .
related to the activities of Yakima Plating. It is EPA's policy
not to clean up an area that exceeds the site boundarys and is
associated with an uncontrollable source. In addition the
presence of the orchard contaminants alone in surface. soils on
the site does not present an unacceptable risk to human health.
Even the presence of these contaminants in groundwater are within
EPA's acceptable risk range. This justification will be included
in the ROD.
3.
Request to see Method B soil volume calculations.
Response:
These calculations were provided to Ecology
4.
units.
Discussions in the ROD should use consistent scientific
4
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Response: - An attempt will be made in the ROD to insure that,
units are consistent in tables and the overall discussion.
5. Cleanup levels are set at the more stringent of NCP and
MTCA standards. The ROD should state so explicitly.
Response: This statement will be included in the discussion of
remediation goals in the ROD.
6. The discussion of alternatives is difficult to follow.
A table of the various alternatives would be helpful.
Response: In the ROD each alternative will be given a self-
explanatory name and a table of all alternatives will be
provided.
7. stating that orchard contaminants remain on site in the
Notice to Deed should be part of the institutional controls.
Response:' These contamir.:1~ts have been identified in a number of
areas both on and off the site and are considered to be area
wide. For this reason ~I'A feels that it is inappropriate to
restrict use of the Yaki~l Plating property with a deed
restriction for orchard '~8ntaminants. If this restriction was
applied to the Yakima Pi1ting site it would'also have to be
applied to all other prc;:0rties where these contaminants were
identified dUring the i:: FS. In addition, based on the site
risk assessment, EPA t(,~ :~~cs that the presence of these
contaminants alone in :: ;:': ice soil, do not present an
unacceptable human hed:.:, :" isk.
8. The sediment,!:" :: :md septic tanks should be abandoned
in a way that prevent~~ :.: '.:re use.
Response:
into the ROD.
EPA a';:..", .3nd language stating this will be put
9. The contamir. ,: : ,:~ under the Yakima Plating building
deserves discussion pt. : ~o being mentioned under institutional
controls.
Response: The s.
include a complete di
Additional discussior.
provided in the RGD pr',
" in the ROD on site contaminants will
,-~ of building contamination.
: .:lding contamination will also be
~; the full alternatives analysis.
5
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u.s.
ENVIRONMENTAL PROTECTION AGENCY.
REGION 10
1200 sixth Avenue
Seattle, Washington 98101
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ADMINISTRATIVE RECORD INDEX
for
YAKIMA PLATING SUPERFUND SITE
Yakima, Washington
September 25, 1991
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09/25/91
u. S. Environmental Protection Agency, Region 10
Page
1
YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING:
1. o.
SITE IDENTIFICATION
SUB-HEAD:
1. 1.
Correspondence
- 0001 Microfilm Reel
DATE: 04/28/81 PAGES: 1
AUTHOR: Kenneth H. Mosbaugh/Environmental Protection Agency (EPA)
ADDRESSEE: Jack Stanton/Yakima Plating
>ESCRIPTION: Letter regarding arrangement fqr.samples to be collected and
~nalyzed
1. 1.
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Ends
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- OO()2~ Microf".f.lm :'Reel' .~
DATE: 10/03/84 PAGES: 1 .
AUTHOR: B. Morson/JRB Associates
ADDRESSEE: Bill Thompson/Yakima Sewer utility
>ESCRIPTION: Record of communication stating no
. . Yakima Plating 'according .to city's
. .
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1;'1.
Frame negins
. Ends'
sewer line within a block of
sewer maps
. - 0003 Microfilm Reel
DATE: 12/10/85 PAGES: 2
AUTHOR: William Carberry/Ecology & Environment (E & E)
ADDRESSEE: Jack Stanton/Yakima.Plating .
)ESCRIPTION: Confirmation of visit to Yakima Plating for a site inspection
1. 1.
Frame Begins
Ends
- 0004 Microfilm Reel
DATE: 04/02/86 PAGES:
AUTHOR: Debbie Flood/EPA
ADDRESSEE: Barbara Lither/EPA
>ESCRIPTION:Memorandum regarding denied access to Yakima Plating
1. 1.
Frame Begins
Ends
2
- 0005 Microfilm Reel
DATE: 10/24/86 PAGES: .
AUTHOR: William Carberry/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: Memorandum regarding residential wells sampled during Yakima
Plating field work
.1. 1.
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09/25/91
U. S. Environmental Prot~ction Agency, Region 10
Page
2
YA~IMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
1. 1.
Frame Begins
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- 0006 Microfilm Reel
DATE: 01/21/87 PAGES: 1
.AUTHOR: A.B. Fortier/Kirschenmann, Devine, Fortier & Raber, Inc. P.S.
. ADDRESSEE: Deborah Flood/EPA
)ESCRIPTION: Request.for report concerning findings from the wells on the
Yakima Plating property
. - 0007 ' Microfilm ,Reei
DATE: '02/02/87 .. "PAGES: . 1
.AUTflOR:" Qeborah :Flpod/EPA' ' , , .' '. . ' , ,'. ' ,
."ADDRES.S~E:' Ro.bert MastetJ~utocraft'. Paint 'and 'Bo~y' .shop', "'.,,. , "
)ESCRIPTION: Notice that 'groundwater is contaminated in ,the' location'
of the downgradient monitoring wells instalied by EPA
1. 1.
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1. I'.
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- 0008 Microfilm Reel
DATE: 04/07/87 PAGES:
AUTHOR: David Bennett/EPA
, ADDRESSEE: William Carberry/E & E
, )ESCRIPTION: Record of communication stating that surface water intakes are,
actually on Bachelor Creek rather than Wide Hollow Creek and
site Investigation Report and HRS Package must be ,corrected
1
1. 1.
- 0009 Microfilm Reel
04/29/87 PAGES:
Deborah Flood/EPA
Robert Mastel/Autocraft Paint & Body Shop
Notice of corrections to be made to site inspection
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DATE:
'AUTHOR:
ADDRESSEE:
)ESCRIPTION:
1
report
1. 1.
Frame Begins
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- 0010 Microfilm Reel
DATE: 07/06/87 PAGES:
AUTHOR: Debbie Flood/EPA
ADDRESSEE: File/EPA
)ESCRIPTION: Memorandum stating the Autocraft well is about 100 feet from
monitoring well #2 installed by E & E
1
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09/25/91
U. S. Environmental Protection Agency, Region 10
Page
YAKIMA PLATING co. - ADMINISTRATIVE RECORD INDEX
SUB-HEAD:
1. 2.
Background
1. 2.
- 0001 Microfilm Reel
DATE: 01/14/72 PAGES: 6
AUTHOR: /Washington Department of Ecology (WDOE)
ADDRESSEE: /
)ESCRIPTION: Various waste water permit documents' regarding Yakima Plating
Frame Begins
Ends
1.~. . - 0002 . Microfilm Reel
. . . bATE: 01/14/72 "',. PAGES: . . 2 ' . .
. '. ::~tlTHOR:' .Jaek 'H-~ 'stantonfYaklma 'Plating . ,.
ADDRESSEE': jWDOE ,", " "
)ESCRIPTION: Application for waste water permit
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SUB-HEAD:
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Dispositions
1. 3.
1. 3.
- 0001 Microfilm Reel
DATE: 03/21/85 PAGES:
AUTHOR: Robert Keivit/EPA
ADDRESSEE: /
JESCRIPTION: Potential ,Hazardous Waste Site Disposition for Yakima Plating
Frame Begins
. Ends
2
1. 3.
- 0002 Microfilm Reel
DATE: 01/20/87 PAGES:
AUTHOR: Deborah Flood/EPA
ADDRESSEE: /
JESCRIPTION: Potential Hazardous Waste Site Disposition for Yakima Plating
Frame Begins
Ends
2
SUB-HEAD:
1. 4.
Preliminary Assessment (PA) Report
1. 4.
- 0001 Microfilm Reel
DATE: 11/20/84 PAGES:
AUTHOR: Ned Theiren/WDOE
ADDRESSEE: /
JESCRIPTION: Potential Hazardous Waste Site
Memorandum for Yakima Plating
6
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Preliminary Assessment Summary
.
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U. S. Environmental Protection Agency, Region 10
Page
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
1. 4.
Frame Begins
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- 0002 Microfilm Reel
DATE: / / PAGES:
AUTHOR: /GeoResource Consultants
ADDRESSEE: /JRB Associates
)ESCRIPTION: Attachment B RCRA Section 3012 Preliminary
Surface and Groundwater Hydrology
3
Assessment program
SUB-HEAD:
1. 5.
site Inspection (SI) ~eport
'.1~. 5. .' :,-:-"OOO~ . Microfilm Re'el . .
DA'I'E.:- . 0'1/04/86 -.: .:. '.pAGES: ": ..4'
. AUTHOR: william Carberry/E &E
ADDRESSEE: John Osborn/EPA
')ESCRIPTION: Yakima Plating Trip Report
Fram~'. Begins..
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1. 5.
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- oa02 . Microfilm Reel
DATE: 10/01/86 .' PAGES: 100
AUTHOR: William Carberry/E & E
ADDRESSEE: J.E. Osborn/EPA
)ESCRIPTION: site Inspection Report for Yakima Plating Company, Inc. Yakima,
washington
SUB-HEAD:
1. 6.
Sampling and Analysis Plan
1. 6.
Frame Begiris
Ends
- 0001 Microfilm Reel
DATE: 03/01/86 PAGES: 32
AUTHOR: William Carberry/E & E
ADDRESSEE: J.E. Osborn/EPA
)ESCRIPTION: Proposed Sampling Plan QA Project
Company, Inc. Yakima, 'Washington
Plan for: Yakima Plating
. SUB-HEAD:
1. 7.
Sampling and Analysis Data
- 0001 'Microfilm Reel
DATE: 06/12/86 PAGES:
AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (inorganics) Yakima Plating, WA
located at EPA Region 10 Headquarters, Seattle,
1. 7.
Frame Begins
Ends
6
(Data package
WA)
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09/25/91
U. S. Environmental Protection Agency, Region 10
Page
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YAKIMA PLATING co. - ADMINISTRATIVE RECORD INDEX
1. 7.
Frame Begins
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- 0002 Microfilm Reel
DATE: 06/12/86 PAGES:
AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (inorganics) Yakima Plating, WA (Data
available at EPA Region 10 Headquarters, Seattle, WA)
9
package
1. 7.
Frame Begins
End,s
- 0003 Microfilm Reel
DATE: 06/17/86" 'PAGES':'
, AUTHO~: Johp. '~yding/E & E" '
',ADDRESSEE:" 'John":OsbornjE?A'" ",,' ,', ", '::',":' ',' """, "
)ESCRIPTION':, Q~ of Case 5951, (lnorganics) Yakima plating, WA
located at EPA Region 10 Headquarters~ Seattle,
9 "
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(Data package
WA) ,
1. 7~
Frame Begins
Ends
,- 0004 Microfilm Reel,
DATE: 06/26/86, 'PAGES: 'II
AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (inorganics) Yakima Plating, WA
located at EPA Region 10 Headquarters, Seattle,
(Data package
WA)
1. 7.
Frame Begins
Ends
- 0005 'Microfilm Reel
DATE: 06/27/86 PAGES: 13
AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA '
)ESCRIPTION: QA of Case 5951 (inorganics) Yakima Plating, WA
located at EPA Region 10 Headquarters, Seattle,
(Data package
WA)
1. 7.
Frame Begins
Ends
- 0006 Microfilm Reel
DATE: 07/01/86 PAGES: 25
AUTHOR: Robert Stuart/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (BNAs & Pesticides) Yakima Plating, WA (Data
package located at EPA Region 10 Headquarters, Seattle, WA)
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09/25/91
U. S. Environmental Protection Agency, Re]ion 10
Page
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YAKIMA PLATING CO. - ADMINISTRATIVE RECQRD INDEX
- 0007 Microfilm Reel
DATE: 07/07/86 PAGES: 77
. AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (inorganics) Yakima Plating, WA
. located at EPA Region 10 Headquarters, Seattle,
1. 7.
Frame Begins
Ends
(Data package
WA)
- 0008 Microfilm Reel
DATE: 07/16/86 . PAGES: 75
. :. A,UTHOR: o!ohn Ryding/E. & E.: . .' .... .' .
.ADDRE:SSEE':: .John OSborn/EPA " ." " :.. . ,.' ' . .,:
)ESCRIPTION: 'QA ot"' Case 5~51 "(organics) Yakima Plating'; WA :(Dci.ta',pa.ckage
. located at EPA Region 10' Headquarters', Seattle, WA) .
1. 7.
Frame Begins
Ends
- 0009 Microfilm Reel
DATE: 07/21/86 PAGES: 55
AUTHOR: John Ryding/E & E
ADDRESSEE: John Osborn/EPA
)ESCRIPTION: QA of Case 5951 (organics) Yakima Plating, WA (Data
located at EPA Region 10 Headquarters, Seattle, WA)
1. 7.
Frame Begins
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t'ackage
1. 7.
Microfilm Reel
PAGES: 10
Frame Begins
Ends
- 0010
DATE: 09/03/86
AUTHOR: /EPA
ADDRESSEE: /
JESCRIPTION: EPA Region X Lab Management
Results Yakima Plating Co.
System Sample/Project Analysis
- Metals EP Toxicity
1.' 7.
- 0011 Microfilm Reel
11/23/88 PAGES: 15
Robert Rau/E & E
Richard Fullner/E & E
Trip Report: Groundwater Monitoring at Yakima Plating
Frame Begins
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DATE:
AUTHOR:
ADDRESSEE:
JESCRIPTION:
1. 7.
Microfilm Reel
PAGES:
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- 0012
DATE: / /
AUTHOR: /
ADDRESSEE: /
)ESCRIPTION: Appendix
Company
4
B Table B2 Sample Summary Table - Yakima Plating
Case No: 5951
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09/25/91
U. S. Environmental Protection Agency, Region 10
YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
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U. S. Environmental Protection Agency, Region 10
Page
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YAK1MA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING:
2. O.
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
SUB-HEAD:
2. 2.
Work.Plan
2. 2.
Microfilm Reel
PAGES:
Frame Begins
Ends
- 0001
DATE: / /
AUTHOR: /
ADDRESSEE: /
IESCRIPTION: Statement of Work, Yakima
Investigation/F~asibility
5
Plating, Yakima, washington
S.t1,ldy
Remedial
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2. 2.
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Frame' Begi~s :
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'.':" .0002. . Microf'ilm R~er
DATE: 04/12/90 PAGES: 144
AUTHOR: /E & E
ADDRESSEE: /EPA .
IESCRIPTION: Work Plan Remedial .Investigation and
Yakima, Plating' 'Yakima Washington.
Feasibility Study (RI/FS)
2. 2.
Microfilm Reel
PAGES: 71
Frame. Begins
1
Ends'
1
- 0003
DATE: 11/13/90
AUTHOR: /E & E
ADDRESSEE: /EPA '. .' .
)ESCRIPTION: Work Plan Remedial Investigation
Yakima Plating, Yakima, WA
and Feasibility Study (RI/FS)
SUB-HEAD:
2. 3.
Quality Assurance Project Plan
2. 3.
Microfilm Reel
PAGES: 42
Frame Begins
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- 0001
DATE: 05/18/90
AUTHOR: /E &. E
ADDRESSEE: /EPA
)ESCRIPTION: Yakima Plating Remedial Investigation/Feasibility
Quality Assurance Project Plan
Study
2. 3.
- '0002
11/13/90
/E & E
/EPA
Yakima Plating Remedial
Assurance Project Plan
Microfilm Reel
PAGES:
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DATE:
AUTHOR:
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)ESCRIPTION:
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Investigation/Feasibility Study Quality
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U. S. Environmental Protection Agency, Region 10
Page
YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
SUB-HEAD:
Sampling and Analysis Data
2. .4.
~. .4.
Microfilm Reel
PAGES: 26
Frame Begins
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1
- 0001
DATE: 09/28/90
AUTHOR: /E & E
ADDRESSEE: /EPA
>ESCRIPTION: Interim Data Presentation for
Yakima Plating, Yakima, WA
the Remedial Investigation at
.SUB-H:EAD: .
.. ... ~ ~e.~.~i~~li~y.~~~~y. ..(FS). .
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PAGES: 132
.1. Ends
. Frame Begins
2. .5.. .."'; 0001
DATE: 08/01/91
AUTHOR: /E & E
ADDRESSEE: /EPA
. >ESCRIPTION:. Feasibility
Study. Report for Yakima Plating. Yakima, Washington
SUB-HEAD:
2. 6.
Applicable or Relevant and Appropriate
Requirements (ARARs)
2. 6.
Microfilm Reel
PAGES:. 41
Frame Begins
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1
- 0001
08/01/91
/E & E
/
Assessment of Applicable or Relevant
Requirements (ARARs) Yakima Plating
DATE:
AUTHOR:
ADDRESSEE:
JESCRIPTION:
and Appropriate
Yakima, Washington
SUB-HEAD:
2. 7.
Remedial Investigation (RI)
2. 7.
Microfilm Reel
PAGES: 520
Frame Begins
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1
- 0001
DATE: 08/01/91
AUTHOR: /E & E
ADDRESSEE: /EPA
)ESCRIPTION: Remedial Investigation
Washington Volume 1
Report for Yakima Plating Yakima,
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U. S. Environmental Protection Agency, Region 10
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YAKJMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
2. 7.
Microfilm Reel
PAGES: 896
Frame Begins
1 'Ends
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- 0002
DATE: 08/01/91
AUTHOR: /E & E
ADDRESSEE: /EPA
ESCRIPTION: Remedial Investigation
Washington Volume 2
Report for yakima Plating Y~kima,
SUB-HEAD:
2. 8.
Proposed Plan
2. ~. . '. - 0001. "Microfilm Reel
/. . . '.DATE: 08/o"a/9i-: ". ::.:'PAG.ES:.' .' 7.
AUTHO~: /EPA '. . .
ADDRESSEE: /General' Public
ESCRIPTION: Superfund Fact Sheet The Proposed Plan
Washington
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Yakima,
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING:
4. O.
STATE COORDINATION
SUB-HEAD:
4. 1.
Correspondence
4. 1.
Microfilm Reel
PAGES:
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1
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1
- 0001
DATE: 01/22/91.
AUTHOR: Bill Adams/EPA
ADDRESSEE: Bonnie Rose/WDOE
>ESCRIPTION: Request for Site-specific
1
ARARs
4.. ..1... . .:..:-: QO'02. ." .'.' MicrESCRIPTION: Letter re: Draft Site-specific ARARs for Yakima Plating
4. 1.
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- 0003 Microfilm Reel
DATE: 04/22/91 PAGES:
AUTHOR: Bonnie Rose/WDOE
ADDRESSEE: Bill Adams/EPA
)ESCRIPTION: Letter re: Yakima Plating -
4
Preliminary Assessment of ARARs
4. 1.
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- 0004 Microfilm Reel
DATE: 06/14/91 PAGES: 24
AUTHOR: Bonnie Rose/WDOE
ADDRESSEE: Bill Adams/EPA
)ESCRIPTION: Letter re: Yakima Plating - Draft
MTCA Cleanup Levels attached
Feasibility Study (FS) Report,
4. 1.
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- 0005' Microfilm Reel
DATE: 07/26/91 PAGES:
AUTHOR: Bonnie Rose/WDOE
ADDRESSEE: Bill Adams/EPA
)ESCRIPTION: Letter re: Yakima Plating - Draft Proposed Plan Comments
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09/25/91
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u. S. Environmental Protection Agency, Region 10
YAKIMA PLATING co. - ADMINISTRATIVE RECORD INDEX
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U. S. Environmental Protection Agency, Region 10
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YAKIMA PLATING CO. - ADMINrSTRATIVE RECORD INDEX
HEADING:
5. o.
ENFORCEMENT
SUB-HEAD:
5. 2.
Affidavits
5. 2.
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- 0001 Microfilm Reel
DATE: 04/30/86 PAGES:
AUTHOR: /U.S. District Court
ADDRESSEE: /
>ESCRIPTION: Affidavit of Deborah Flood
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: . "Noti~e :Let.ters '. a.ncV~esP9ris~s . ::.'
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- 0001" Mi6rofilm Reel
DATE: 12/14/9"0 PAGES:
AUTHOR: Philip Millam/EPA
ADDRESSEE: Robert J. Mastel/
>ESCRIPTION: Notification of potential liability
of CERCLA, notification of response
5. 3.
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6
"as defined 'by section 107(a)
activities
5. 3.
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- 0002 Microfilm Reel
DATE: 12/17/90 " PAGES:
AUTHOR: Philip" Millam/EPA "
ADDRESSEE: Fred Halverson/
>ESCRIPTION: Notification of potential liability
of CERCLA, notification of response
4
as defined by Section 107(a)
activities
5. 3.
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- 0003 Microfilm Reel
DATE: 12/14/90 PAGES:
. AUTHOR: Philip Millam/EPA "
ADDRESSEE: Mike Schliep/ "
>ESCRIPTION: Notification of potential liability
of CERCLA, notification o~ response
4
as defined by Section 107(a)
activities
5. 3.
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- 0004 Microfilm. Reel
DATE: 12/14/90 PAGES:
AUTHOR: Philip Millam/EPA
ADDRESSEE: Jack Stanton/
>ESCRIPTION: Notification of potential liability
of CERCLA, notification of response
4
as defined by section 107(a)
activities
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09/25/91
U. S. Environmental Protection Agency, Region 10
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
5. 3.
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- 0005 Microfilm Reel
DATE: 01/07/91 PAGES: 2
. AUTHOR: F.N. Halverson/Halverson & Applegate
ADDRESSEE: Bill Adams/EPA
JESCRIPTION: Letter confirming joint telephone conversation with Bill Adams
and Mike Schliep on 1/4/91
5. 3.
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- 0006 Microfilm Reel
DATE: 0~/25/91 PAGES:' 3
. . AU:~HOR: .'Jo~eph D~ Hampton/Bogle & 'Gates'
. ADDRESSEE': . BIll" "Adams/EPA . . : :"..":." .' .::
JESCRIPTI"ON: Response to E.PA' s . 12/14/9i noti~e letter
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U. S. Environmental Protection Agency, Region 10
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING:
6. o.
HEALTH ASSESSMENTS
SUB-HEAD:
6. 1.
Correspondence
6. 1.
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- 0001 Microfilm Reel
DATE: 12/29/89 PAGES: 1
AUTHOR: Chester L. Tate, Jr./Agency for Toxic Substances and Disease
Registry (ATSDR)
ADDRESSEE: Phil Millam/EPA
ESCRIPTION: Cover letter for draft ATSDR Health A~sessment
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DATE: 01/23/90 PAGES: '1
AUTHOR: Philip G. Millam/EPA
ADDRESSEE: Chester L. Tate, Jr./ATSDR
. ESCRIPTION: Comments on draft ATSDR Health
Assessment
SUB-HEAD:
6. 2.
ATSDR Health Assessment
6. 2.
Microfilm Reel
PAGES: 16
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- 0001
DATE: 01/02/90
AUTHOR: /ATSDR
ADDRESSEE: /EPA
>ESCRIPTION: Preliminary Health Assessment for
Proposed National Priorities List
Yakima Plating Company
(NPL) site
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25/91
U. S. Environmental Protection Agency, Region 10.
Page
16
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YA~IMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING:
9. a.
PUBLIC PARTICIPATION
SUB-HEAD:
9. 1.
Correspondence
9. 1.
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- 0.60.1 Microfilm Reel
DATE: 12/0.8/88 PAGES:
AUTHOR: Kathryn M. Davidson/EPA
ADDRESSEE: Ken Back/Washington Department of
)ESCRIPTION: Notifica~ion of Yakima Plating as
2
Community Development
a proposed Superfund project
. '9:~. 1. " ,.'" ",;':, 0.:0.0.2 ' Microfilm,' Reel'
,DATE: 0.3/13/90. PAGES:
AUTHOR: Michelle pirzadeh/EPA
ADDRESSEE: Richard Zais, Jr./City of Tacoma
)ESCRIPTION: Confirmation of meeting to discuss
about the Yakim~ Plating sfte
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city and community concerns
9. 1.
- ~o.0.3 Microfilm Reel
0.3/14/90. PAGES:
Michelle Pirzadeh/EPA
Resident/4 Addresses
Cover letter for fact sheet and notification that residents will
have the opportunity to meet with EPA to discuss private well
sampling "
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DATE:
AUTHOR:
ADDRESSEE:
)ESCRIPTION:
4
SUB-HEAD:
9. 2.
Community Relations Plan
-,
9. 2.
Microfilm Reel
PAGES:
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- 0.0.0.1
DATE: 0.5/16/90.
, AUTHOR: /EPA
ADDRESSEE: /General Public
)ESCRIPTION: Community Relations
9
Plan
Yakima Plating
Yakima, Washington
SUB-HEAD:
9. 3.
Fact Sheets/Press Releases
9. 3.
Microfilm Reel
PAGES:
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- 0.0.0.1
DATE: 0.3/15/90.
AUTHOR: /EPA
ADDRESSEE: /General Public
)ESCRIPTION: Superfund Fact Sheet
2
Yakima Plating, Yakima, Washington
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u. S. Environmental Protection Agency, Region 10
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
9. 3.
Microfilm Reel
PAGES:
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- 0002
DATE: OS/28/90
AUTHOR: /EPA
ADDRESSEE: /General Public
'ESCRIPTION: Fact sheet for Yakima Plating Superfund
start of field work and availability of
Plan
2
site announcing the
the Community Relations
9. 3. --0003 Microfilm Reel
. ()AT~: :02j13/91: . P~GES.:.: " 3 "
.:AUTHOR: /EPA"." "". ..
ADDRESSEE: /General:Pubiic . . .
iESCRIPTION: Superfund Fact Sheet: Yakima Area Fact Sheet; updating
information regarding EPA's sites in the Yakima area (including
Yakima Plating) and giving a brief explanation of the Superfund
process
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O~'/25/91
U. S. Environmental Protection Agency, Region 10
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YAKIMA PLATING CO. - ADMINISTRATIVE RECORD INDEX
HEADING: 10. 0.-
TECHNICAL SOURCES AND GUIDANCE DOCUMENTS
SUB-HEAD: 10. 1.
EPA Guidance
.0. 1.
Microfilm Reel
PAGES:
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- 0001
DATE: 07/03/91
AUTHOR: /EPA
ADDRESSEE: /
)ESCRIPTION: List of EPA Guidances used for Administrative Records
4
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