United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-91/031
September 1991
EPA Superf und
Record of
Northwest Transformer -
Mission Pole (Amendment),
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R10-91/031
1 ~
3. RecIpient'. Acce88lon No.
'flII 8ubfte
2ERFUND RECORD OF DECISION
Northwest Transformer - Mission Pole, WA
First Remedial Action (Amendment)
7. AuIIor(.)
5. Report Date
09/30/91
..
8.
8. Pltrfonnillll Orgllllization Rept. No.
L ~ OrgelnlDlon N8m8 end Add....
10. Proj8ctlT-*iWork Unit No.
1,. ConInIct(C) or GrIllll(G) No.
(C)
(0)
1~ Spw80rIng Organlz8tlon Name end Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Repor1 & Period Covered
.
Agency
800/000
14.
15. Suppl8m8nl8/y No..
18. Abatr.c1 (LImI1: 200 word.)
The 1.6-acre Northwest Transformer - Mission Pole site, is former transformer storage
and salvage facility, is 2 miles south of Everson in Whatcom County, Washington. The
site is bordered by low-density residential areas to the north and east, and farmland
to the south. Storage and salvage operations were conducted in an onsite barn where
PCB-contaminated dielectric fluid was drained from the transformers prior to
;mantling. Transformer casings and associated parts were incinerated onsite, and
~~me of the recovered oil was burned to heat the barn. Spills and leakages of
PCB-laden oil onto the ground occurred frequently. Additionally, oil was dumped
directly into a seepage pit onsite, and contaminated soil and possibly ground water.
EPA studies from 1977 to 1985 identified PCB concentrations as high as 38,000 mg/kg in
onsite media. In 1985, EPA removed 1,400 cubic yards of PCB-contaminated soil and
debris, 6,660 gallons of PCB-contaminated liquids, and several contaminated transformer
casings. In addition EPA initiated a ground water monitoring program and imposed site
access restrictions. In 1987, sufficient PCB contamination was identified in the soil
to warrant further site remediation. A 1989 Record of Decision (ROD) addressed
remediation through excavation, consolidation, and onsite treatment using in-situ
(See Attached Page)
17. DocuI8I1 AnlJpII .. Dnc:rIptOI'8
Record of Decision - Northwest Transformer
First Remedial Action (Amendment)
Contaminated Media: soil, debris
Key Contaminants: organics (PCBs)
- Mission Pole, WA
II. 1dInfler8/Op8n-End8d T-
c. COSA 11 Fl8ld/Group
-
l' '..blity St8IemenI
18. Security CI... (Thl. Report)
None
20. Security Cia.. (Thla Page)
Nnnl'>
21. No. 01 Pages
40
n Price
(SM AHSI-Z38.18)
See IfUllructJofUI on ReIHl"..,
.FOR~
(Formerly NTlS-35)
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EPA/ROD/R10-91/031
Northwest Transformer - Mission Pole, WA
~ FJ 't Remedial Action (Amendment)
Abstract (Continued)
vitrification. This ROD amends the 1989 ROD and provides a change in the remedy for
soil due to excessive cost. The primary contaminant of concern affecting the soil is
PCB, an organic.
The selected amended remedial action for this ROD includes incinerating approximately 70
cubic yards of soil contaminated with PCBs at levels greater than or equal to 50 mg/kg
at a TSCA-approved facility, landfilling approximately 1,500 cubic yards of soil
contaminated with PCBs at levels greater than or equal to 1 mg/kg and less than 50 mg/kg
offsite at a TSCA-approved facility; demolishing the barn and disposing of the debris.
offsite; testing the soil and concrete within the barn; placing a soil cover over the
entire site; and implementing institutional controls, if necessary. The estimated
capital cost for this amended remedial action ranges from $1,400,000 to $2,300,000
depending on the amount of soil removed. O&M costs were not provided.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil cleanup goals are based on the
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UNITED STATES
ENVIRONMENTAL PROTECTION
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
AGENCY
. AMENDED RECORD OF. D.ECISION.,
. . . .:' DECISION SUMMARY.'" ..'
. . . ..' , .' .
. AND' RESPONSIVENESS SUMMARY
FOR.
FINAL REMEDIAL ACTION
NORTHWEST TRANSFORMER (MISSION/POLE)
SUPERFUND SITE
SEPTEMBER 30, 1991
1
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Declaration for the
Northwest Transformer (Mission/pole)
Superfund Site
Amended Record of Decision
Site
Northwest Transformer (Mission/pole)
Whatcom County, Washington
Statement of Basis and Purpose
.... . . This. deci$ion do.c.ument .presents the amended Remedial Action
. .for.''.the Nor.'t:hwe:st' 'Transformer' site: In' ,Wha~com' C~unty, 'Wa.shingt6"n.;
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
Contingency Plan. This decision is based on the Administrative
Record' for this site, updated in August, 1991, to include new.
information generated since the original Record of Decision was
signed on September 15, 1989. The attached index identifies the
items which comprise the Administrative Record upon which the
selection of the Remedial Action is based.
The State of Washington has concurred on the selected
remedy. A signed statement to that effect is included on page 5.
Assessment of the Site
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD), may present an .
imminent and substantial threat to public health, welfare, or the
environment. .
Description of the Revised Remedv
This amendment addresses contaminated soils and debris, barn
materials, and groundwater in the vicinity of the site. .
The remedial actions described below are the final response
actions planned for the site. They address all threats at the
site, including the principal threat, by removal and off-site
treatment and disposal of all soils and barn debris contaminated
with PCBs above health-based levels. In the event complete
removal of contaminated soil is not practicable and some soils
with greater than 1 part per million but less than 10 part per
million PCBs remain on-site, long term management controls will
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be employed to maintain the integrity of the cleanup.
No groundwater remedial action is necessary to ensure
protection of human health and the environment. This
determination~s subject to completion of the Groundwater
Monitoring Program and EPA evaluation of the final results.
will reassess its decision if groundwater contamination is
detected at levels of concern.
EPA
The major components of the selected remedy for contaminated
soils and barn debris include:
a) Treatment of soils contaminated with PCBs at levels
greater than or equal to ~O ppm by off-site
incineration at a~SCA-~pproved facility;
b) .Renie'dL:iti~h'. ~f' soils - c6~t~minat'~d wi"t.h':'PCB~:' at ".leVels .
greater'thi:in or equal to l' .ppm and. less thi:in 50 ppm' hy.
off-site landfilling at a TSCA-approved facility to the
maximum extent practicable (for this site, EPA and the
Department of Ecology have determined that removal of
. up.to 1,500' cubic yards of contaminated soils is the
maximum' extent practicable). . All soils 'known to be .
contaminated with PCBs greater than or equal to 10 ppm
will be remediated;
c) Demolition of the barn and off-site disposal of the
debris at a TSCA-approved off-site landfill facility.
Soils and co~crete inside the barn (the barn floor)
will be tes~ and remediated if necessary;
d) Placement of a clean soil cover (approximately 2 feet
thick) over the entire site; and,
e) In the event complete removal of soils contaminated
with PCBs at levels greater than or equal to 1 ppm is
not achieved and compliance with the 1 ppm cleanup
level cannot be demonstrated (using the methods
described in the performance standards), and hazardous
substances remain on-site that preclude unrestricted
use of the site, the following institutional controls
will be required: regular inspection and maintenance of
the soil cover and perimeter fence, and reviews no less
often than every 5 years.
Consultation
A consultation with the Office of Waste Programs
Enforcement, OSWER, regarding this ROD Amendment has been
conducted pursuant to the 22nd Remedy Delegation - FY91
memorandum (December 27, 1990).
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Declaration
Ui
The selected remedy for soils is protective of human health
and the en~ir~nment, attains federal and state requirements that
are applicable or relevant and appropriate to the Remedial
Action, and is cost effective. This remedy satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element and
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
For groundwater, no remedial action is necessary to ensure
protection of public health and the environment. The basis for
this determination is that on~ and off-site groundwater studies
since the 1985 removal ~ction have indicated that contaminants
.. :a~e riot pr~sent.~t. a.~e~ection ~imit"~f ~.05 .part~ .p~r bil~ion,
. '.""'. an" ordero~. magnitude' more stringent:. than .the. Maximum' contaminant
Level (MCL). for. PCBs. Since the M.Ci.. is the' standard generally:
used to set exposure levels for PCBs in groundwater that are
protective of human health and the environment, and no
contaminants have been found at the more protective detection
.limit, no remedial action is necessary. This determination is .
subject .to completion of the Groundwater Monitoring' Program and.
EPA evaluation of the final results. EPA will reassess its.
decision if groundwater contamination is detected at levels of
concern.
." .
The remedy will not result in hazardous substances remaining
on-site above health-based levels and no five-year reviews will
be conducted if complete removal of contaminated soils and debris
with 1 or more ppm PCBs is achieved consistent with the
performance standards contained in the decision summary. In the
event complete removal is not achieved as described in the
performance standards and hazardous substances remain on-site
above health based levels, a review will be conducted within five
years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
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Dana A. Rasmussen
Regional Administrator
U.S. Environmental Protection
9'-3cJ'fl
Date
Agency, Region 10
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Slate Concurrence
The I,JClE>h1ngt;..On-l>e.Pflrt.roent of Ecology concurs \\'1th 1:.11", selec.ted n,.medy
3nd Amended Record of Decision for final remedial action at the
Northwesc TrRnsformer (Mission/Pole) Superfund $iC~ in Everson, Washington.
.~/,J-~
Curol Fleskes
Program Manager,
Washington St.at.e Departmellt. of Ecology
Toxics Cleanup. P~ogram
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J~ ./) f:. ;3cJ.;J.$ /
Date'
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NORTHWEST TRANSFORMER (MISSION/POLE)
SUPERFUND SITE
AMENDED RECORD OF DECISION
DECISION SUMMARY
TABLE OF CONTENTS
INTRODUCTION
REASONS FOR ISSUING THE ROD AMENDMENT
SITE HISTORY AND ENFORCEMENT ACTIVITIES
SCOPE AND ROLE OF RESPONSE ACTION
SUMMARY OF SITE CHARACTERISTICS
SUMMARY OF SITE RISKS
DESCRIPTION OF THE NEW SOIL CLEANUP ALTERNATIVES
EVALUATION OF ALTERNATIVES
THE SELECTED REMEDY
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT CHANGES
Appendix A:
Appendix B:
THE RESPONSIVENESS SUMMARY
ADMINISTRATIVE RECORD INDEX
List of Fiqures
Figure 1
site Location
Figure 2
NWT Remedial Action Areas
Figure 3
Comparison of Soil Cleanup Alternatives
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Paqe
7
9
12
13
14
16
16
20
23
25
29
30
35
8
15
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NORTHWEST TRANSFORMER (MISSION/POLE)
SUPERFUND SITE
AMENDED RECORD OF DECISION
Decision Summary
INTRODUCTION
site Name and Location:
The Northwest Transformer Salvage Yard (Mission/Pole) site
(hereafter referred to' as the Northwest Transformer or NWT site)
is located approximately two miles south of Everson in Whatcom
County, Washington, immediately southwest of the intersection of
Mission and Pole Roads (Figure 1). The 'site occupies'
_.app'roxi~ately 1.,6. ,acres -in, the' NE,: 1/4 of ,the.,NE 1./ 4 ,of Se,ctioI}
".i2,,':.T.Ownsh~p' ~9 N/.:R~ng~'.'.:3:'.E.I W.i~lainet~~-Mer.idiap~" "', ..":.
,
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Lead and Support Aqencies:
EPA is the lead agency for this Superfund site, with the
cooperation 'and support of the Washington Department of Ecology
(Ecology) .'
Date of the Oriqinal Record of Decision:
The original Record of Decision (ROD) was signed on
September 15, 1989.
Administrative Record:
This ROD Amendment will become part of the Administrative
Record file for this site, in accordance with NCP section
300.825(a) (2). The Administrative record is available for review
at the EPA Regional Office, 1200 Sixth Avenue, Seattle,
Washington. 98101, and the Everson Public Library on Kirsch
Street. An index of the Administrative Record is included with
this ROD.
Hiqhliqhts of Community Participation:
community Relations efforts prior to 9/15/89 are described
in the Community Relations History section of the original Record
of Decision. The following community relations activities are
relevant to this ROD Amendment:
August 1990
EPA sent drinking water questionnaires to
those citizens living within one half mile of
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i
N
CANADA
. USA ---:L..-
- 118
I .
I
'II HAT C Q,'M
wut 6.00u Ad.
S
B .lIIltg"~tfI
I"~gure 1
.
Soutn p~u Rd.
Northwest
T~nsformer ~
Site. a:
c:
.2
&.
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September 1990
October 1990
March 1991
, ",' August 15', '199i,
August 20, 1991
August 21, 1991
August 27, 1991
September 1991
the site.
EPA released a fact sheet announcing the
expansion of the groundwater monitoring
program. The fact sheet also provided a
general update about the activities occurring
at the site.
Citizens selected for the groundwater
monitoring program were notified by letter.
Results of the groundwater tests were sent to
affected citizens. Results indicated that
the contaminants' tested for were not found in
any of t11e ,wells samp;J.ed. :,
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"EPA '(ji'stributed' the Fropo'sed, 'Rob 'An1endment
pl~n to the mail list~',
"., .
EPA ran an advertisement in the Bellinqham
Herald which described the availability of
the proposed plan and the RIfFS, and ..
announced the dates of the public meeting and
public comment period.
An advertisement ran in the Lvnden Tribune
which announced the dates of the public
meeting and public comment period.
EPA conducted a public meeting for interested
,community members. Approximately 20 members
of the public attended the meeting.
EPA prepared the Responsiveness Summary.
The most significant comments and questions addressed the
cost of past and planned remedial actions. A number of citizens
were critical of the cost and time involved 'with this remedial
project in particular and Superfund in general. $everal citizens
expressed support for the preferred alternative (now the selected
remedy). The only other soil cleanup alternative which received
support was no action, which would not be adequately protective
for soils.
REASONS FOR ISSUING THE ROD AMENDMENT
circumstances that led to need for ROD Amendment:
EPA has determined that a ROD amendment is necessary to
change the selected remedy for contaminated soils on-site and to
select final remedies for the on-site barn and for groundwater in
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the vicinity of the site. The selected remedy for soils must be
changed because of new information about the soils on-site and
aboQt the originally selected remedial technology. This
information-is discussed below. EPA must also select final
remedies for the barn and groundwater since the 1989 ROD merely
identified the need for further study of those media.
Backqround:
. The Feasibility study (FS) completed in 1987 recommended
thermal destruction of PCBs in PCB-contaminated soils with
concentrations at or above 10 ppm (mgjkg). Thermal destruction
technologies included incineration and in-situ vitrification.
(ISV), as well as other thermal-based processes such as catalytic
comb.ustion and infrared. destruction. ..
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... :.: upor( furt~e'roo rev~ew:.aiid ~cost.anal~Sis.byO EPA ° arid furtheor..'o
. revi~w -of docum~ntation on demonsb:ations .of the ° vitrification.
technology, the best thermal destruction process .for this site.
was determined to be vitrification. This determination was made
based on 1) relative ease and expected schedule of mobilization,
2) advantageous costs over other thermal .processes as reflected
in the FS, 3) acceptability of the vitrified mass as an on-site
residue over other conventional materials classified as ash, 4)
the expected local acceptance of contained, "in-the-ground"
thermal destruction of PCB contaminants over conventional
incinerator operations, and 5) the criteria set forth for
technology selection in the FS.
Remedv selected in 1989 ROD:
The major components of the remedy selected on September 15,
1989 included:
1) Excavation, consolidation, and treatment, via ISV, of
approximately 1200 cubic yards of contaminated soil (soils
with a PCB concentration greater than 1D ppm (mgjkg».
2) Abandonment of the on-site well (in accordance with
Washington state regulations).
3) Placement of approximately two feet of clean fill over the
entire site.
4) Implementation of a comprehensive groundwater monitoring.
program to determine whether contamination is moving through
the aquifer.
5) Sampling of the on-site wood structure to determine deeper
matrix contamination.
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Subsequent Events and New Information:
, .
After the ROD was signed, EPA reached agreements with many
of the potentially responsible parties which did business with
Northwest Transformer for them to conduct and finance: 1) a pilot
test of ISv,using material from the site to test the practical
, effectiveness of the selected remedy; 2) a groundwater monitoring
program to determine whether groundwater at or near the site is
contaminated with PCBs; 3) an evaluation of the wooden barn; and,
4) abandonment of the on-site well. ' This work is now largely
complete.
The pilot test of ISV demonstrated that the technology would
work but that the cost was much higher than originally
anticipated. As part 'of this study, additional soil sampling, was
','done ,tp 'r~fin~ the, ~sti,mated:"vo1."~m~, arid extent: of' the ',~oj.l '.,:'" ""
, contamiiratj,on:' ",The sampling ,ccmfirmed ::that 'PCB" "66nCEm~;rat'ioris. ',i"ri,
soils o~-site g~nerallY do not exceed 100 ppm, and 'that there 'are'
less than 70 cubic yards of soil contaminated with 50 or more
parts per million (ppm) PCBs, an additional 350 cubic yards above
10 ppm, and between 1,000 and 4,000 cubic yards above 1 ppm.
'The groundwater monitoring program was set up to 'includ~ 4
rounds of sampling of wells on and around the site. The
detection limits were set at 0.05 parts per billion, one-tenth
the 'Maximum contaminant level for PCBs in groundwater. Two
rounds of monitoring have been completed and the results have
been analyzed. No PCBs have been found in either on- or off-
site wells at or above the detection limit." EPA has not been
able to reproduce the results reported by the Whatcom County
Health Department in 1983-84, when some PCBs were detected in
off-site wells at concentrations slightly above the minimum
detection limit of 0.05 parts per billion. This may be the
result of EPA's removal of source material in 1985. The third
round of sampling, which included a new well near the original
center of contamination, occurred in August, 1991 (initial
reports are consistent with previous data but complete results
are not yet available). A fourth round of sampling will be done
after soil excavation and cleanup is completed.
The information available on the barn indicates that some of
the barn material is contaminated with low levels of PCBs. As a
result, the PRPs have proposed forgoing further characterization
of the barn in favor of simply assuming the barn material is
contaminated and disposing of it in the same way as the
contaminated soils.
Summary of EPA's Rationale for Chanqinq the Currently Selected
Remedy:
EPA began to consider changing the soils remedy in January
1991, because of new information about the site and the selected
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remedy for. soils developed in the course of a treatability study
of ISV using on-site soils. While the treatability study
demonstrated that ISV could destroy the PCBs at the site, other
information developed during the study called into question the
appropriateness of the remedy for this site.
The new information included soil sampling done during the
study which demonstrated that the volume of soil above 10 ppm
PCBs at the site was about 400 cubic yards, less than half the
1,200 cubic yards estimated in the 1989 ROD. Despite the lower
volume of soils, between 1989 and 1991 the estimated cost of ISV
more than doubled to $1.6 million from the 1989 ROD estimate of
$771,000. Finally, the availability of a full-scale ISV unit
became uncertain in February due to problems encountered by the
manufactu~er while testing the apparatus. The manufacturer has
,since ,abandoned its e,fforts to' construct and test a full~scale
ISVunit."-:',. ",:', ':", ',',' , . ,.'-' ',' :. ',',' ,,"," ,', : :', ':',' ':, .
EPA has determined that further study of the groundwater and
on-site barn as specified in the 1989 ROD are sufficiently'
complete to allow selection of final remedies for those media.
Either a new operable unit or an amendment of the original ROD is
necessary to address those media.EPA has decided to' select'
final remedies for the barn and groundwater as part of this
amendment.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1984, the site was added to the National Priorities list
under CERCLA. In 1989, after completion of a detailed study of
the nature and extent of contamination and a detailed analysis of
cleanup alternatives, a remedy for the site was selected and
described in a ROD. Site history and enforcement activities
prior to the original ROD are discussed in that section of the
September 15, 1989 document, to which the reader is referred for
details.
The u.S. filed a complaint for recovery of past response
costs in 1988 and later, when the PRPs would not agree to perform
the remedy, added injunctive relief. The court date for the case
has been postponed several times, and is currently planned for
February 1992, if these matters are not resolved.
Key events that have occurred since the ROD was signed
include:
On 2/9/90, EPA.signed an Administrative Order on Consent
with the PRPs for them to implement a work plan for the
treatability study to evaluate the feasibility of
implementing the selected remedy, ISV.
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On 9/20/90, EPA signed an Administrative Order on Consent
under ~hich the PRPs agreed to perform groundwater
monitoring and prepare a plan for sampling and/or demolition
and safe removal of the barn.
In November, 1990, the PRPs' contractors conducted
round of on- and off-site sampling as part of the
groundwater monitoring program. A second round of
was done in March, 1991.
the first
sampling
. .
In January, 1991, the PRPs presented the results of the ISV
treatability study, which demonstrated that ISV would work,
but that the cost had gone up since the original ROD cost
. estimate was prepared.. -
.: In February,. ~991,aqditional:soil -sa~ples were taJc~n_tq --
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Monitoring.Program.
SUMMARY OF~I~E CHARACTERISTICS
site characteristics are described in detail in the Site
Characteristics section of the original 9/15/89 ROD, to which the
reader is referred for details. The following is a brief
discussion of relevant information, particularly that developed
since that ROD was signed.
.0
The RI/FS documented that PCB-contaminated soils in excess
of 10 ppm remained on-site, and that the risks posed by the
presence of PCBs. at the' site justified taking remedial action.
The .RIlFS. estiIpate: was t~~t.approxim?telY:1,200 cubic yar:d~ of '.
.soils' contamirtat'ed' with 10 .brmor-e; ppm P-q:ss remained' at the. sdte.'. . .
Although groundwater sampling was conducted to .aPlimited extent'
during the RI/FS, and on a number of occasions previous to that,
a thorough groundwater monitoring program was not done during the
RI/FS.
Recent sampling of on-site soils' to refine the RI/FS data
indicate that there are less than 70 cubic yards (cy) of soil
contaminated with> 50 ppm PCBs, an additional 350 cy above 10
ppm, and between 1,000 and 4,000 cy > 1 ppm. RI/FS and
subsequent sampling data have been statistically analyzed to
determine remedial action areas and areas already in compliance
with the cleanup standard (Figure 2).
The groundwater monitoring plan called for in the 1989 ROD
is now underway, and includes three rounds of pre-remediation
sampling and a fourth, post-remediation round. To date, two
sampling events have been completed, with no .PCB contamination
detected above the detection limit (0.05 parts per billion) set
for the program. This detection limit is an order of magnitude
below the MCL for PCBs in groundwater (0.5 ppb). The third
sampling event occurred in August, 1991, and while preliminary
results appear to' confirm earlier results, the validated data
report is not available yet. .
The information available on the barn indicates that some of
the barn material is contaminated with low levels of PCBs.
Additional samples of the floor and soil beneath the barn will be
taken during remedial design to determine the appropriate" .
disposal method for those materials.
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POOR QUALITY
ORIGINAL
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6:.. 'Ii . C II» I! .f @ HI ' J ~ ~ IHI i6 0 ~
KEY
MVT Remodial AcIioo ""'as .
. 0 \IItriI1ca1ion T reatablity Study Sle
SOU SaJT9I8
..' MoniIomg We.
G'- .500 BoIIn9
o .: Abandoned Waler Supply We.
@ t.n.x.ary Bend! Mad<' (TUt.\)
'. (Ii"".. 118.55 Feet
. (Oat~ . LlSL 19211))
.~ RIIFS GrIci System
~R Engin88Itng, 19881
NWT Remedial Action Areas
___.r Figure 2
30
.
Scale In F88I
60
I
o
I
o Aru~ 01 Barn ROOf Remediation
-: ,. WoIpwIousIy -- - NWT.5.
2. Tho...._...,.-.. --_oI..-.--piI
-
..
SItu Sol San11Ing Pragtam San-pIe
("SSsp." pr8flllelirinallld If1II11
idenlifl8l5 101' datilyl
RI Sur1- Sarrple
rAIl
Figure 2
.
1-
I
~
'0
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'-
SUMMARY OF SITE RISKS
The resu~ts of the risk assessment performed for this site
are described in the Summary of site Risks section of the
September 15, 1989 ROD, to which the reader is referred for
details. The following is a discussion of the basis for taking
action to remediate soils and for not taking further action with
respect to groundwater.
Basis for Takinq Action to Remediate Soils:
The risk assessment, using several sets of conservative
exposure assumptions and the average soil PCB concentration on-
site, estimated that the risks from exposure to contaminated soil
. '..o.n~s~.te~a~ged ~.rom. 5 'i,n, .100, 00,0,. (~. :X10:SJ, to ,2: in '~9, 000, '(2: x .
. . 10..4) . " 'Bas~d on the increased risk o'f' 'ca.ncer., and other di'sea$es
. and the requirements of the federal Superfund law, EPAbeli'eves
that soil remediation is necessary.
Basis for No Remedial Action Decision for Groundwater:
For groundwater, no remedial action 15 necessary to ensure
protection of public health and the environment. The basis for
this conclusion is that recent on- and off-site groundwater
studies have indicated that contaminants are not present, using a
detection limit of 0.05 parts per billion. The detection limit
is an order of magnitude more stringent than the Maximum
contaminant Level for PCBs, which is 0.5 ppb. Since the MCL is
the standard generally used to set exposure levels for PCBs in
groundwater that are protective of human health and the
environment, and no contaminants have been found at the more
protective petection limit, no remedial action is necessary.
DESCRIPTION OF THE NEW SOIL CLEANUP ALTERNATIVES
The following is a brief explanation of the final candidate
remedies which EPA considered for remediation of the contaminated
soils. These alternatives were'developed by reviewing the
original Feasibility study and ROD and integrating the new
information about the volume and extent of contaminated soils,
the cost and implementability of ISV, the washington Model Toxics
Control Act (MTCA) regulations, and agency experience since the
1989 ROD was signed.
Remedial actions must at least attain legally applicable or
relevant and appropriate federal and state requirements (ARARs).
ARARs were determined at the time of the 1989 ROD, but since that
ROD is being amended, ARARs have been re-evaluated and are
discussed in relation to the alternatives below.
16
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.'
..i -0".:".
More stringent Washington state requirements have been put
into place since the 1989 ROD was signed. The state cleanup
standard for PCBs in soils in residential areas is now 1 part per
million, wh~le the 1989 ROD was based on federal policy to clean
up soils with 10 or more parts per million PCBs. Since Superfund
cleanups must meet both federal and state requirements, the
selected remedy complies with the more protective state standard
and includes cleanup of soils with between 1 and 10 ppm PCBs.
Key features of the remedy and ARARs that are common to the
aiternatives include:
"
since PCBs are the only contaminant of concern at this site,
the applicable action- and. chemical-specific federal cleanup
. . '.requirements. for' PCBs, are. .described in. the. Toxics ::Substance
'. : . '-Control' Act. . (TSC;:A) '.PCB re'gUlati.on's' for .stor-age "anddisposa!' ..
of PCB-contaminated media (40 CFR '76i>". Because there is rio"
RCRA hazardous waste at the site, federal land disposal'
regulations will not apply.
The Method A cleanup levels for PCBs in residential soils
specified in the washington state Model ToxicsControl Act
(MTCA) Cleanup Regulations (WAC 173-340) are applicable .for
determining cleanup levels at this site.. Other substantive
requirements of. MTCA were also considered in development,
evaluation, and selection of the alternatives. A clean soil
cover will be placed on the site and seeded after
remediation. If material is left on-site containing between
1 and 10 ppm PCBs, the cover will have to meet MTCA
regulations for determining closure and post-closure
performance standards and institutional controls may be
relevant and appropriate. .
All alternatives include excavation of contaminated soils
on-site and demolition of the on-site barn structure by
conventional and protective methods. During these
activities air monitoring will be done and dust suppressive
measures will be utilized as necessary to control the
release of dust and particulates. . These measures will
comply with applicable requirements,including Washington
state General Regulations for Air Pollution Sources (WAC
173-400), which addresses control of fugitive dust and
emissions during excavation and other field activities.
Transportation of materials from the site to disposal
facilities will be done in accordance with Department of
Transportation Hazardous Materials Regulations which address
shipment of any hazardous material off-site (49 CFR,
Subchapter C) .
Materials contaminated with 50 or more ppm PCBs must be
17
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'.
disposed of by incineration at a TSCA-approved facility.
Any off-site incineratqrs will be in compliance with the
TSCA PCB regulations, applicable state laws, and other
requirements of EPA's off-site disposal policy before waste
is shipped.
Materials contaminated with between 1 and 50 ppm PCBs must
be disposed of by landfilling at a TSCA-approved facility.
Any off-site landfills will be in compliance with the TSCA
PCB regulations, applicable state laws, and other
requirements of EPA's off-site disposal policy before waste
is shipped.
Additional ARARs which may apply to particular remedies are
discussed below with the description of the alternatives. ARARs
, are aiso discussed "in some detail ,"in the' Statutory Determinations
". . ';- -,"section. ne~r,.the 'end ,of'this:'d6cu~ent>:':...' " ".' :'"".,', ':".', '" .:',
. '
Alternativ~ 1: In-situ Vitrification and Capping (the orig~nally
selected remedy)
. ' .
This alternative would use an innovative on-site thermal
treatment process to permanently treat (destroy) the PCBs to less
than 10 parts per million (ppm). Soils .contaminated with less
than 10 ppm would be contained on-site with a two-foot clean soil
cover. Future use of the property would be restricted by
maintenance of the soil cover and fence around the site, deed
restrictions, and periodic reviews. '
The major ARARs for this alternative include the ones
mentioned above, plus this alternative would also trigger
additional Washington Dangerous Waste regulations governing new
waste generated by the vitrification process, as well as relevant
air emissions regulations. This alternative does not comply
fully with the MTCA requirement to cleanup to 1 ppm to the
maximum extent practicable.
The cost ,estimate for this alternative was $1,600,000 in
January 1990, before GEOSAFE, Inc., ceaseq development of a full-
scale ISV unit. Current estimates are that the cost could double
to $3,200,000 by the time the technology is available.
Alternative 2: Off-Site Incineration and Capping
Soil contaminated with 10 or more ppm PCBs would be
excavated, transported to a TSCA-approved incinerator off-site,
and treated by incineration. The remaining PCB-contaminated
soils on~site would be contained by placement of a specially-
engineered cap to prevent direct contact with contaminated soil
and to prevent water from seeping down and moving contamination
18
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off-site. Future use of the property would be restricted by
maintenance of the cap and fence around the site, deed
restrictions, and periodic reviews.
The cost-estimate for this alternative is $2,500,000.
The major ARARs for this alternative include the ones'
mentioned above, plus this alternative could also trigger
additional Washington Dangerous Waste regulations governing new
waste generated by the incineration process, as well as relevant
air emissions regulations. This alternative does not comply
fully with the MTCA requirement .to cleanup to 1 ppm to the
maximum extent practicable.
'.
. Alterni!tiv.e .~": _Of.~-S,i.t~ Incirier:ation an~. Off~Site Disposa~:
.. . ..". :".
. All fio!l cont~miI:1ated with 50 or "m"ore 'ppm PCBs pp~ 'w~~ld be
excavated and transported to a TSCA-approved "incinerator off-
site for treatment. All soil and barn material with between 1
and 49 ppm would be excavated, transported to and contained at a
TSCA~approv~d hazardous waste landfill. The site would be
covered with approximately 2 feet of clean fill, "and future use
of the property would not be restricted.
The major ARARs for this alternative are the ones mentioned'
above. This alternative would fully comply with MTCA.
The cost .estimate for this alternative is $1,400,000, if the
estimate of 1,500 cubic yards of material is correct. If
additional soil is removed, the cost estimate would increase to
as much as $4,000,000.
Alternative 3A: Off-site Incineration and Off-Site Disposal
This alternative is a variation on alternative 3. All soil
contaminated with 50 or more ppm PCBs would.be taken to a TSCA-
approved incinerator off-site for treatment. All soil and barn
material with between 10 and 49 ppm would be taken to a TSCA-
approved hazardous waste landfill for containment, as well all
soils with 1 or more 'ppm PCBs, up to a limit of 1,500 cubic yards
of contaminated soil. A clean soil cover would be placed on the
site and seeded. If all contaminated soils are removed, future
use of the property would not be restricted.
If, however, after removal of 1,500 cy of contaminated soil
(including all soils with 10 or more ppm PCBs) additional soil
remains on-site contaminated with between 1 and 10 ppm, the cover
and fence around the site would have to be maintained and future
use would be constrained by deed restrictions.
19
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'.
The major ARARs for this alternative are the ones mentioned
above. Having considered the soil sampling data, EPA and the
State determined that 1,500 cubic yards was a reasonable estimate
of the remaining contaminated soil on-site with 1 or more ppm
PCBs,' and that this alternative would comply with the MTCA
requirement for treatment to the maximum extent practicable
long as all material at or above 10 ppm is removed, as well
least 1,500 cubic yards of contaminated soil (or less if it
be demonstrated that the 1 ppm cleanup level is attained).
so
as at
can
The cost estimate for this alternative is $1,400,000, if the
estimate of 1,500 cubic yards of material is correct~ If.
additional soil must be removed, estimates range to as much as
$4,000,000.
I.
. "A"lt~r~ative' "4":" 'Q'ff~$-it~'Irici~'ei-a.tion'~: Off':Site :Dispqs~l 'and.'""
Capping' ." "
. ". ~
", .
Soil contaminated with 50 or more ppm PCBs would be taken to
a TSCA-approved incinerator off-site for treatment. Soil with
PCB levels between 10-49 ppm wquld be taken to a TSCA-approved
hazardous waste landfill and contained. The site would be .
covered with clean soil and a deed restriction would be placed on
the property. After this alternative was developed and
considered it was determined that it would not meet state
requirements without a more impermeable soil cover.
i
. j
.1
I
I
The major ARARs for this alternative include the ones
mentioned above. This alternative does not comply fully with the
MTCA requirement to cleanup to 1 ppm to the maximum extent
practicable.
The cost estimate for this alternative is $1,000,000.
EVALUATION OF ALTERNATIVES
The following is a brief discussion of the alternatives using the
nine evaluation criteria. A slightly more complete summary is
shown in Figure 3.
Overall Protection of Human Health and the Environment: All of
the Alternatives satisfy this criteria, but Alternatives 1, 2,
and 4 that leave contaminated soil on-site and 3A if it leaves
contaminated soil on-site are less protective. All alternatives
pose some risks of worker exposure or fugitive emissions during
excavation, and Alternatives 2," 3, 3a and 4 pose potential
transportation risks. "
Compliance with ARARs: Alternative 1 met the requirements at the
time the ROD was signed. Alternatives 3 and 3A meet all
20
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requirements. Alternatives 2 and 4 do not meet state regulations
Lonq-term Effectiveness: Alternatives 3, 3A, and 1 best satisfy
this criteria. Alternatives 3,3A, and 4 include off-site
landfilling-of soils with between 1 and 49 ppm PCBs, and so shift
some ,long term risks to the landfills. Alternatives 1, 2 and 4
leave soils up to 10 ppm on-site beneath a soil cover.
'Alternatives 1, 2 and 4 satisfy this criteria as long as the soil
cap is not disturbed.
, ,
Reduction of Toxicity, Mobility or Volume: All of the
alternatives meet this criteria because they reduce the toxicity
of the most highly contaminated soils through incineration. For
the principal threat"materials with PCB contamination of 50ppm
or ,more, incineration will reduce toxicity,by at least 99%,' and
" :~~u~~ }~Y', ~~.,?~~~,t,' 3,~%.,,::',':"" : ,:,' , , "" '-, " ':",' ,
Short-term' Effectiveness:, ' All the alternatives 'could :cr~ate some
risk during the excavation, however, this risk will be, mitigated
by dust suppression and monitoring. Alternatives 2, 3, 3A and 4
create a additional risk during the off-site transport of the
contaminated materials. '
Implementability: Alternative 1 would be difficult to implement
because there is not a full-scale vitrification unit available.
Alternatives 2, 3A and 4 are equally feasible and available.
Alternative 3 does present some uncertainty regarding the total
amount of soil with 1 - 10 ppm PCBs.
Costs: All of the cost estimates are significantly higher than
the cost estimates in the original feasibility study. The
estimated cost of the selected remedy has at least doubled since
the 1989 ROD was signed. Cost estimates varied between
alternatives primarily with the amount of material to be
thermally treated, next according to the amount of material to be
landfilled off-site, and finally by the cover requirements and
whether or not institutional controls will be required.
Alternative 4 was the least expensive, followed by Alternative
3A. Assuming no further action for Groundwater, future operation
and maintenance costs for Alternatives 1, 2, 4 (and 3A if
necessary) would be very small. Some cost estimates were ranges
due to uncertainties described in the preceding narratives. The
cost of the alternatives ranges from $1,000,000 to $4,000,000.
state Acceptance: Alternatives 3 and 3A are acceptable.
Alternatives 1, 2 and 4 are not acceptable, because treatment is
preferable to ,containment where practicable under MTCA.
community Acceptance: Based on written and oral comments
received during the public comment period, Alternative 3A is
acceptable to the community. Details are provided in the
Responsiveness Summary attached to this ROD.
21
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"
~orthwcst Tran
Evaluation
Criteria:
Overall
protection
of Pwl ic
Heal th &
the
Envi rormcnt
C~I i ance
w/ARARs
long-ten8
Effect iveness
RedJct i on of
Toxicity,
!lobi! ity &
Volune
Short-tenl
Effect iveness
I q>l eonent.
abil ity
Cost
State
,\cceptance
~r Mission/Pole Site - Comparison of Soil Cleanup Alternatives
Alternative 1
ISV Soils> 10 ppm PCBs;
Soi I Cover;
Deed Restrictions
Very Protect ive. Thennal
destruction pennanently
destroys PCBs> 10 ppm;
lIhen carbined w/soil cover,
all potential pathways/risks
fro. soils eliminated: Some
potential for airborne
releases. No transport
risks. Source to GW
eliminated.
Met all ARARs at time ROD
was signed: docs not Eet 1
ppm MTCA standard.
High. Risks of direct
contact eliminated, current
& future risks to CW below
10-6: Failure of cap poses
risk < 10-6.
Highest. Principal threat
(50 cy soil with> 50 ppm
PCBs) treated on-site by
ISV, along with 400 cy of
less contllllllnated (10-49 ppm
PCBs) soils: hazardous
Materials destroyed:
Vitrified MaSS non-toxic.
May create air eaissions
during excavation ,
consol idation ardIor during
vitrification: at least 1
year before response
objecti"es could be
achieved.
GEOSAFE ceasing commercial
development: full'scale unit
not available; PRPs very
reluctant
ROD est. = $ 771,000
Current est. = $1.6-3.2 M
S,tate concurred' in 1989,
would not meet MTCA today
AI ternat:jve' 2
Off-Site Inci~ration of
Soils> 10 ~: Capping:
Deed RestriCtions'
Very Protective;'
Incineration;pennanently
destroys PCBs, > 10 ppm:
Carbined w/50ii cover, all
potential pathways/risks
fro. sOils'elilllnated: Some
potential excavation and
transport risks: Source to
CW eliminated, .
" .'
Meets all federal AHARs:
Ecology interpretation of
, MTCA is that '10-1 RCRA cap
is~."',
High. ~isks of direct
contact eliminated, current
& future risks to'CW below
10-6: Fai lui'e of cap poses
risk < 10-6.
"
Very High. Principal threat
(50 cy soi r::With > 50 ppm
PCBs) treated.by
incineratiqn , hazardous
Materials destroyed: 400 cy
of less contininated (10-49
ppm PCBs) soils' ash to go
to TSCA IF: ' .
May create.:air eIIIissions
during excavation; potential
distribUtion of contlllllinated
soi I fran trocks during
transport 'to off-site
incinerator; ~t likely at
least 1 year. before response
objectives coUld be '
achieved.' ','
-:. .
Technicftl~y fe~sible ,
available;"ReCjuires ROO
Amcndnent.' Begin in 1992,
finish In '1993.
"
Current est. 'a $ 2.5 M
Not acceptab\e: clellf'1l4J to 1
ppm specifl~ I~ !:ITeA, ,
Alternative 3
Off-Site Incin Soils> 50
ppm: Off-Site landfill (IF)
Soils 1-49 ppm; Delist
Very Protective.
Incineration pennanently
destroys PCBs> 50 ppm.
Re8DVal of soils> 1 to off-
, site IF el illinates risks .and
hazardous ~terials at site
and to GIi. Some potential'
transport risk and some ri~k
transferred to If.
Meets all federal and State
AHARs: Can Del ist
High. Risks of direct
, contact el iminated,
current/future risks to GU <
10-6: some risk transferred
to If: no PCBs >1ppm left on
site
Satisfies preference:
principal threat (50 cy soil
with >50 ppm PCBs) treated
by Incineration' hazardous
IIBterials destroyed: ash
fraa Incineration of soils
to go to TSCA If.
May create air eaissions
during excavation: potential
distribution of contaminated
soil frOl1l trucks during
transport to off-site
incinerator & landfill: at
least 1 year before response
objectives could be
achieved.
Technically feasible'
available: Requires ROO
Amenctacnt.Begin in 1992,
, finish In 1993.
Current est= $1.4-4.0 M
Acceptable
Alternative 3A
Off-Site Incin Soils> 50 ppm:
Off-Site IF Soils 1-49 ppm to
extent practicable; Delist.
Very Protective. Incineration
pennanently destroys PCBs> 50
ppm. Removal of soils >,1 to
off-site IF elillinates risks
and hazardous IISterials at
site and source to GV. some
potential transport risk and
some risk transferred to IF.
Meets all Federal and State
AHARs: Potential for delisting
High. Risks of direct
contact elillinated, current'
future risks to GU <10-6, SOlIe
risk traosferred to IF; no
PCBs >1ppm left on site
Satisfies preference:
prlncipel threat <50 cy soil
with >50 pp8 PCBs) treated by
incineration' hazarCkMJs
~terials destroyed; ash fraa
Incineration of soils to 110 to
TSCA IF.
May create air ealssions
during excavation; potential
distribution of cont_inated
soil frOll! trucks during
traosport to off-site
incinerator' landfill; at
least 1 year before response
objectives could be achieved.
Technically feasible &
available: Requires ROO
Anlerdnent. Begin In 1992,
finish in 1993.
Current est: $1.4-2.3 M
Acceptable
Figure -
Alternative 4
Off-Site Incin Soils >50 ppm;
Off-Site IF 10-49 ppm; Soil
Cover; Deed Restrictions
Very Protective. Incineration
perManently destroys PCBs> 50
ppm: II/soi I cover, all
potenti al pathways frOll! soi Is
el illinated; low potential for
airborne releases: SOllIe
potential transport risks 'IF
risks; Source to GII
el iminated.
Meets all federal AHARs:
Ecology interpretation of IHCA
is that 10-1 RCRA cap is
needed.
High. Risks of direct contact
elillinated, current' future
risks to GII < 10-6, some risk
transferred to If: Cap
failure risk < 10-6
Satisfies preference:
principal threat (50 cy soil
with> 50 pp8 PCBs) treated by
incineration: hazardous '
-terials destroyed: ash fraa
incineration of soils to go to
TSeA If.
May create air BIIissions
ciJrlng excavation: potential
distribution of contlllllinated
soil fraa trucks during
transport to off-site
incinerator' landfill;
response objectives could be
achieved this year. .
Technically feasible'
available; Requires ROO
Allerd8ent. Could illpleaent in
1992.
CUrrent est. .. $1.0 M
Mot acceptable: clean.p to 1
pp8 specified in MTCA.
~
--I
-1<
-
Ot!}
c:a:
00
o
a..
~
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THE SELECTED REMEDY
The selected remedy for contaminated soils and barn debris
is Alternative 3A: Off-site Incineration and Off-site Disposal.
This alternative complies with all ARARs as discussed previously
and offers a reasonable likelihood of full compliance with the
more stringent 1 ppm state cleanup standard for PCBs, while
allowing for acceptance of institutional controls if complete
removal is not practicable. In consideration of the volume and
levels of contamination at the site and the original cleanup
level of 10 ppm in the 1989 ROD, EPA and the state have agreed
that for this site, removal and disposal of 1,500 cubic yards of
contaminated soil will be deemed practicable, so long as all'
material contaminated with. 10 or more ppm is remediated.
. '. .
'. .
. .
. .
. .
" ".
..0'. ".:The ~a'Joo'r c~mpo~~nts .C;f the", selected:r~m~d~," ~nciU:de.:
a) Treatment of soils contaminated with PCBs at levels
greater than or equal to 50 ppm by off-site
incineration at a TSCA-approved facility;
.'
"
b) Remediation of soils contaminated with PCBs at levels
greater than or equal to 1 ppm and less than 50 ppm by
off-site landfilling at a TSCA-approved facility to the
maximum extent practicable (for this site, EPA and the
Department of Ecology have determined that removal of
up to 1,500 cubic yards of contaminated soils is the
maximum extent practicable). All soils known to be
contaminated with PCBs greater than or equal to 10 ppm
will be remediated;
c) Demolition of the barn and off-site disposal of the
debris at a TSCA-approved off-site landfill facility.
Soils and concrete inside the barn (the barn floor)
will be tested and remediated if necessary;
d) Placement of a clean soil cover (approximately 2 feet
thick) over the entire site; and,
e) In the event complete removal of soils contaminated
with PCBs at levels greater than or equal to 1 ppm is
not achieved and compliance with the 1 ppm cleanup
level cannot be demonstrated (using the methods
described in the performance standards), and hazardous
substances remain on-site that preclude unrestricted
use of the site, the following institutional controls
will be required: regular inspection and maintenance of
the soil cover and perimeter fence, and reviews no less
often than every 5 years.
For groundwater, no remedial action is necessary to protect
23
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'.
public health and the environment, subject to completion of the
Groundwater Monitoring Plan and EPA evaluation of the final
results. EPA will. reassess its decision if contamination is
detected a~ levels of concern.
Remedial Action Performance Standards:
The Remedial Action shall be completed subject to the following
standards of performance.
" B...; '.::
F.
G.
A.
The boundaries of the site Remedial Action (RA) areas
within which soil is to be excavated and/or sampled for
compliance monitoring purposes are shown on Figure 2.
Within. 'the &\a.reas,: ~ll $Qils.a,nd.debriswith" PCB. '" . . .
concentrations .<;>f ,'50 ppin or abqv~: shci11 be'., removed . from,
the site 'and thermally treated in an"off':"'site .
incinerator.
. '. .
C.
All soils and debris with PCB concentrations equal to
or greater than 10 ppm and less than 50 ppm shall be.
dispos~dof off-site by'landfilling at aTSCA-ap~~oved
facility. Soils and debris with PCB concentrations
equal to or greater than 1 ppm and less than 16 ppm
that are removed from the site shall be disposed of by
landfilling at a TSCA-approved facility.
D.
Cleanup shall be deemed non-conditional (as described
in MTCA), and not subject to periodic reviews, if no
hazardous substances remain at the site which preclude
unrestricted use of the site. If cleanup is
con~itional, periodic reviews will be conducted.
For non-conditional site cleanup, remediation of soil
(and barn floor concrete as necessary) with greater
. than or equal to 1 ppm PCBs is required such that
statistical compliance with the 1 ppm cleanup level is
achieved, or a 1S-ft compliance depth (measured from
the surface of the final soil cover) is reached for
soil with less than 10 ppm PCBs.
E.
If a non-conditional
EPA/Ecology will not
controls and reviews
cleanup.
site cleanup is achieved,
require any of the institutional
associated with a conditional site
The areas to be excavated may be divided into the
following two, or possibly three, areas for evaluating
statistical compliance with the cleanup level, "
including at least:
1) The seepage pit; and,
24
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0,-." ".
2) The rest 'of the RA areas shown on Figure 1.
The barn area may be included with 2) above or
considered a separate area.
H.
~epage pit soil sampling grid areas that are shown by
to contain less than 10 ppm PCBs and that have been
excavated to 15 feet below the surface of the final
soil cover will not be included in the evaluation of
statistical compliance with the 1 ppm cleanup level.
This is based on the provision that a sufficient number
of samples are analyzed to calculate a statistically
valid upper confidence interval for the mean PCB
concentration.
1.
A groundwater monitoring program (GWMP) approved by EPA
~ ::i.s, \.1.nderway and .must. pe c.o1t.1plete~ inaccordan.ce with'. .'
. . the exis~inq Groun~waterMonH:.or"ing pf'o.gram -Work Ji>:lan..
In the event. no' PCB concentrations' in . groundwater . .' .
samples exceed a practical quantitation iimit. of 0.25
ppb, the on-site groundwater monitoring wells shall be
abandoned in accordance with all applicable or relevant
and appropriate requirements. . If, after completion of
the Remedial Action, PCB coricentrations in any two.
groundwater samples (as demonstrated by sampling wells
according to the GWMP Work Plan) exceed a practical
quantitation limit of 0.25 parts per billion per
aroclor, additional monitoring or other analyses may be
conducted to determine whether the selected remedial
action remains protective.
STATUTORY DETERMINATIONS
EPA's .primary responsibility under its CERCLA authorities is
to ensure that remedial actions are protective of human health
and the environment. Additionally, section 121 of CERCLA, as
amended' by SARA, establishes several other statutory requirements
and preferences. These specify that when complete, final
remedial actions must comply with applicable or relevant and
appropriate environmental standards unless a statutory waiver is
justified. The selected remedy must also be cost-effective and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. Finally, the statute includes a preference
for remedies that employ treatment that permanently and
significantly reduces the volume, toxicity, or mobility of
hazardous substances as a principal element.
The selected remedy for the Northwest Transformer
(Mission/Pole) site meets the statutory requirements of section
121 of CERCLA, as amended by SARA, and to the extent practicable,
the National Contingency Plan.
25
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'.
Protection of Human Health and the Environment:
The selected remedy for soils is protective of human health
and the environment and will reduce or eliminate the risks posed
through each pathway by removal and disposal of contaminated soil
and debris. If complete removal of contaminated soils and debris
with 1 or more ppm PCBs is achieved, consistent with the
performance standards contained in the decision summary, the
remedy will result in no hazardous substances remaining on-site
above health-based levels (the state's 1 ppm standard is
considered to provide protection for a risk level of lOE-6), and
no further institutional controls or remedial actions will be
necessary. No periodic. reviews. will be conducte<:1..
. .
. .
:.:. '. : ,.' 'rn the. event comple.te' rein6v.~:J;. is not- aChi~\'eq as-'de~c~ibed.'
in the performance standards and hazardQus sUbstances'remain 'on- .
site above health based levels,' institutional controls; including
maintenance of the soil cover and fence and deed restrictions
will be required to protect against the risk of future exposure.
In this event, a review will be conducted within five years .after
commencement of remedial action to ensure that the remedy'
continues to provide adequa~e protection of human health and the
environment. .
For groundwater, no remedial action is necessary to protect
public health and the environment. The basis for this conclusion
is that recent on- and off-site groundwater studies conducted
since the 1985 removal have indicated that contaminants are not
present, using a detection limit of 0.05 parts per billion. This
detection limit is an order of magnitude more stringent than the
Maximum Contaminant Level for' PCBs, which is 0.5 ppb. Since the
MCL is the standard generally used to set exposure levels for
PCBs in groundwater that are protective of human health and the
environment, and no contaminants have been found at the more
protective detection limit, no remedial action is necessary. EPA
will reassess this decision if groundwater sampling after soil
cleanup is complete shows contamination at levels of concern.
Compliance with Applicable or Relevant and Appropriate
Requirements:
Pursuant to SARA Section 12l(d), remedial actions shall,.
upon their completion, reach a level or standard of control for
such hazardous substances, pollutants or contaminants which at
least attains legally applicable or relevant and appropriate
federal standards, requirements, criteria, or limitations, or any
promulgated standards, requirements, criteria, or limitations
under a state environmental or facility siting law that is more
stringent than any federal standard (ARARs).
26
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The selected remedial action satisfies the requirements of
section 121 by complying with all ARARs that have been
identified. No waiver of any ARAR is being sought or invoked for
any componeRt~f the selected remedy. The action-specific and
chemical-specific ARARs include the following:
TSCA PCB requlations in 40 CFR 761.60 - 761.79, address
the requirements for storage, treatment and disposal of
PCBs and PCB-contaminated media. (this is also a
chemical-specific ARAR)
.' .
state of Washinqton Model Toxics Control Act (RCW
70.105D [WAC 173-340]) regulations establishing soil
and groundwat~r cleanup standarqs for PCBs.
;,'~ '.'. . .:.;... ~. .'Depaitm.~~t..: oi:' T.r~ns~rt'~t i6n : :, ~a z a'rd~us: Mat~ria Is .
.. Requlations' in 4~ CFR, Subchapter C,. which address
shipment' of any hazardous material off site. .
Washinqton State Danqerous Waste Requlations (RCW
70.105 and WAC 173-303) address dangerous wastes which
may be: generated during remediation through air or
fugitive dust emissions or accidental releases during
transport are relevant and appropriate.
I
,
. : . !
Clean Air Act (42 USC 3609. 7601) National Ambient Air
Qualitv Standards (40 CFR part 50); Ambient Air Qualitv
standards for Particulate matter (WAC 173-470): and
Washinqton State General Requlations for Air Pollution
Sources (WAC 173-400) address control of fugitive dust
and emissions during excavation and other field
activities.
Minimum Standards for Construction and Maintenance of
Wells (WAC 173.160) addresses how on-site wells will be
abandoned by licensed well contractors. Though
reporting and recording requirements are procedural
requirements, well contractors are required to submit
well abandonment information.
There are no location-specific ARARs for this site.
Land Disposal Restrictions
The selected remedy will not involve the placement of RCRA
hazardous wastes. This being the case, the Land Disposal
Restrictions will not apply.
27
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'\.
Other criteria. Advisories. or Guidance TO-Be Considered (TBC)
The following regulations and guidance were also considered:
TSCA PCB Policy (40 CFR 761) which address the
requirements for cleaning up a PCB spill.
Guidance on Remedial Actions for Superfund Sites With
PCB Contamination (OSWER Directive 9355.4-01, August
1990), which describes the recommended approach for
evaluating and remediating Superfund sites with PCB
contamination.
. '.-
U.S. EPA. Statement of Policy to Protect
EnvironmentallY Siqn,ificant A'qricultural Lands (EPA -
. ,September. 8.' 1978) .Tb~ statement c,allsupo~ thea9.en.cy
. ."to, 'eva'luate and.niitigate .dir.ect:a~d' indirect. .impacts .on'
"agricultural lqnds <;luring the preparatiqn' anc;l review of.
environmental impact statements ("or functionally'
equivalent documents). .
.. '.
.:. ;
Worker Health and Safety .
NCP (section"300.150) specifies that OSHA requlations in 20
CFR Subpart 1910.120, which address worker protection
standards for employees involved in operations at CERCLA
sites are directly applicable to cleanup activities.
Cost-Effectiveness:
The cost-effectiveness of each alternative was evaluated.
The selected remedy is cost-effective as it affords overall
effectiveness and protectiveness proportional to its costs.
Other remedial alternatives including innovative treatment.
technologies and/or treatment of greater quantities of the waste
on-site are more costly than the selected remedy and do not
afford additional protectiveness commensurate with their cost.
.
Utilization of Permanent Solutions to the. Maximum Extent
Practicable:
EPA believes the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies
can be utilized in a cost-effective manner for the Northwest.
Transformer (Mission/Pole) site. The selected remedy provides
the best balance among the alternatives with respect the
evaluation criteria. It is protective of public health and the
environment, complies with all applicable environmental
regulations, and combines permanent destruction of the principal
threat with cost-effective containment of the remaining, less-
contaminated soil. Implementability was an important
28
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consideration in selection of the remedy given the problems
experienced with implementation of ISV. The selected remedy
offers a reasonable likelihood of complete removal of hazardous
substances from the site and future unrestricted use, while
allowing for acceptance of institutional controls to ensure
protectiveness if complete removal proves impracticable.
Preference for Treatment As a Principal Element:
. .
EPA believes that the incineration of soils contaminated
with 50 ppm or more PCBs addresses the principal threat at the
site and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element. . .
DOCUMENTA~ION 0' SIGNIFIC~CHANGES
. .:,..~:..:. .:::. """0 ", "'. '." '.' "~.' '. . ,".':' '..' :0' .:...' ... .
~here h~v.e been"no significant .changes from. the propose~":
plan. . The selected remedy is the same as. the preferred
alternative described to the public in the ~ugust 20, 1991 public
notice and proposed plan.
29
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Appendix A
RESPONSIVENESS SUMMARY
Northwest Transformer Mission/pole Road
ROD Amendment.
Overview:
The Northwest Transformer Superfund Site is located at the
corner of Mission and East Pole Roads in Whatcom County,
Washington. Northwest Transformer operations salvaged and
repaired electrical transformers. Polychlorinated biphenyls
(PCBs) were released during normal operations at ~he facility.
. '. In .19a5,.' EPA' c.onq.uct;~d <:1 rem9val'of contaminated soi1s and
:'sai.vage materia..:).£; from :hot:.. spot' ~r~as'. and.dee;:ontatninated an old
barn on the site. In 1986'; the site was added to' the. National
Priorities List, which is a list of sites requiring additional
study and possible cleanup.
In 198~, following an investigation of the contamination at
the site, EPA proposed a cleanup plan and 'requested public'
comment. EPA considered all comments and decided on a cleanup
plan which was described in a Record of Decision (ROD) issued in
September 1989. The cleanup called for the on-site treatment of
contaminated soils by In-situ Vitrification, a thermal treatment
process that converts contaminated soil into a chemically inert
glass and crystalline product, and further study of the barn on-
site and groundwater in the area.
A pilot test of the remedy demonstrated that the soil
cleanup technology would work, but the cost would be much higher
than the original estimates. Further information showed the
volume of soil needing treatment to be much less than estimated
in the 1989 ROD. In addition, EPA now has enough information to
propose removing the on-site barn material and no action for the
groundwater.
On August 15, 1991, EPA released a Proposal to Amend the
ROD. EPA held a public meeting on August 27 at the Everson
Senior Center in Everson, Washington. Approximately 20 people
attended the meeting and three people gave comments. Questions
raised during the meeting are also summarized below.
A copy of the meeting transcript is available at the Everson
Public Library in Everson, Washington and at the EPA Regional
Office in Seattle.
Backqround on Community Involvement:
Since the 1989 ROD, community interest has been relatively
30
.
'.
..
-------
low. Commu~ity involvement has been primarily through the
groundwater monitoring program where local wells were sampled.
As part Qf the public involvement process, a public meeting
was held on August 27, 1991 at the Everson Senior Center on Main
Street, in Everson, Washington. Approximately 20 people attended,
the meeting with several people giving comments. The meeting
consisted of presentations from EPA, followed by comments, then a
question/answer period.
Summary of Comments Received:
EPA held a public .comment period from August 20 to September
18, 1991~ Comments and question~ raised during the public
comment period are summarized below and grouped by category.
Questions:, ~,ns~er~d quring, th,e public; meeting are gener,alized "
'belo,w.with EPA's 'respons,e to those concerns.', Spec,ffic ques~'iOns
have not been incl,uded, however they can be: found 'in -the meeting'
transcript located in the information repository at Ever~ori
Public Library. '
,RESPONSIVENESS SUMMARY:
, EPA received a total of 4 comments in support of Alternative
3A, one written and three orally at the public meeting. Several
participants at the pUblic meeting stated at various times that
they saw no reason to take action at the site. No other
alternatives received public support or comment.
Comments and Aqencv Responses:
Comment:
EPA received a total of 4 comments in support of
Alternative 3A, one written and three orally at the
public meeting. Several participants at the public
meeting stated at various times that they saw no reason
to take action at the site. No other alternatives
received public support or comment.
Response: Comments Noted.
Comment:
While supporting Alternative 3A,
requested that the EPA keep this
that the site not be returned to
any 'form or fashion.
one commentor
site on the NPL and
its previous use in
Response: Comment noted. If hazardous substances remain on-site
above health-based levels, future use and access will
remain restricted.
31
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Cost:
Comment:
Response:
Health:
General
Response:
Comment:
~
Many people expressed concern about the cost of the
c~eanup. Several people said that the cost would be
passed on to them by increased utility rates. One
commentor felt that EPA should be held accountable for
the amount of money that is spent throughout the
Superfund process.
EPA believes all expenditures have been consistent with
the NCP. Cost-effectiveness was considered as one of
the statutory evaluation criteria for the site response
actions., The commentors have been provided with
addi~ional information de~ailing the purpos~s for which
,~unds, w~~e: expended.... Those, 'responses. are included i~ '
the, Administrative Record. .' ' , ,",:, , " ','
statement:, .
, Commentor stated that when he was little 'he used to
play around the site, and at times he and several other
kids would put transformer oil on their faces. The
commentor said that he does not have cancer and wants
to know why we need to cleanup the site, if there does
not appear to be any risk.
EPA is not aware of any documented health effects
related to exposures at this site. However, based on
the increased risk of cancer and other diseases and the
requirements of the federal Superfund law, EPA believes
that soil remediation is necessary.
A representative from the County Health Department
stated that the County Health Department supports
cleaning up the site. The commentor also said that
cleanup is very costly, but for those living near the
site who have young children, cost does not matter.
Response: Comment noted.
Question: A cQmmentor asked what health affects have been found
related to the site, and whether EPA was aware of a
reported cancer cluster near the site.
Response: EPA is aware of a letter from an individual working
with the Indian Health Service detailing anecdotal and
medical evidence regarding the causes of death and
32
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~llness in a family of people living near the site,
including a number of different types of cancer. This
information is being reviewed by the appropriate health
gr~fessionals (ATSDR). While more work is necessary
before conclusions can be drawn, preliminary
indications are that there would be more likelihood of
a link to a single source if the health effects were
all similar, such as one type of cancer.
General:
One commentor stated that the government required PCBs
in transformer oil as a fire retardant. The commentor
feels that it is not appropriate to be required to do
something and then be held liable for that by the
9?Vernment.
. Response: Comment noted. However, this does not affect the
CERCLA liability of the potentially responsible parties
in this situation.
Comment:
Question:
What direction is the water flow under the site?
Response:
The groundwater beneath the site flows to the North.
Detailed information is included in the Groundwater
Monitoring Program (GWMP) reports in the Administrative
Record.
Question: Has EPA found any wells in area that are contaminated?
If not, why is EPA continuing the cleanup?
Response:
Approximately 17 wells off-site were sampled in
November, 1990 along with on-site wells as part of the
GWMP. In addition, 7 of those wells were sampled in
March, and 7 more in August, 1991. No contaminants of
concern have been detected above the detection limit in
these or any other groundwater samples taken since the
1985 removal. .
While groundwater is not contaminated, EPA believes
that soil remediation is necessary because the
remaining soil contamination on-site presents an
unacceptable risk to public health and the environment,
which must be addressed by remedial action.
Question: What levels of contamination are remaining on-site, and
where are they located?
Response: Detailed soil sampling results are presented in the
33
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A I
recent Site Soil Sampling Program reports, which are
part of the Administrative Record. That report
includes the RI data plus the results of recent
sampling, which demonstrated that the volume of soil
above 10 ppm PCBs at the site was about 400 cubic
yards, less than half the 1,200 cubic yards estimated
in the 1989 ROD. A single sample was slightly over
2,000 parts per billion in one spot south of the barn.
The levels in samples taken from below and beside that
point were much lower. All samples with concentrations
of PCBs which exceeded 1 ppm are within the shaded
areas shown on Figure 2 of the ROD.
Question:
One citizen said that he witnessed the activities
during the removal and said that the trucks which took
the soil off site were not covered. He asked why we
had not covered the trucks and if there was a plan to
prevent that from happening again. .
Response:
No information is contained in the files regarding
covers for the trucks. All remedial activities in the
future will be done according to all applicable federal
and state standards. .
Question: Where would the soil be taken to be incinerated?
Response: Soils and debris contaminated with 50 or more parts per
billion PCBs will be taken to a TSCA-approved
incineration facility.
34
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Appendix B
Administrative Record Addendum
Index
UNITED STATES
ENVIRONMENTAL PROTECTION
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
AGENCY
, ,
. ADMINISTRATIVE RECORD ADDENDUM INDEX
" ' ' , ' , , '. ,for ..th~'. . " ' .
'NO~THWEST.TRANSFORMER (MISSION/POLE)
" SUPERFUND SI1'E , '
Amended Record of Decision
'.. . .
SEPTEMBER 30, 1991
This is an index of items which relate to this ROD Amendment and
which have been added to the site Administrative Record since the
original Record of Decision was signed on September 15, 1989.
35
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09/30/91
. U. S. Environmental Protection Agency, Region 10
Page
1
NORTHWEST TRANSFORMER, MISSION/POLE - REMEDIALA/R ADDENDUM INDEX
HEADING:
1. o.
1989 NORTHWEST TRANSFORMER REMEDIAL A/R INDEX
SUB-HEAD:
1. 1.
Index
- 0001 Microfilm Reel
DATE: 09/08/89 PAGES: 15
AUTHOR: /U.S. Environmental Protection Agency (EPA)
ADDRESSEE:. /
ESCRIPTION: Administrative Record Index for Northwest Transformer - Remedial
Everson, Washington
1.1.
Frame Begins
1
Ends
1
. '
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NORTHWEST TRANSFORMER, MISSION/POLE - REMEDIAL 'A/R ADDENDUM INDEX
,',
HEh..JING:
2. O.
REMEDIAL DESIGN/REMEDIAL ACTION
SUB-HEAD:
2. 1.
Correspondence
- 0001 Microfilm Reel
DATE: 01/16/91 PAGES: 4
AUTHOR: Gary R. Reid/Puget Sound Power & Light Company (puget Power)
ADDRESSEE: Christine Psyk/EPA
~SCRIPTION: Summary of views of Northwest Transformer (NWT) Technical
Committee on additional soil sampling and analysis and the
implications for implementation of the remedy
L 1.
Frame Begins
1
Ends
1
!. 'I. ~ - 0062 Microfilm Reel
DATE:. 01/31/~1 PAGE~:".2 ,'. .,'
.' AUTHOR:' ,Charles' t.. Fin~ley/EPA .. '. .
ADDRESSEE: Gary R. Reid/Puget Power
'3SCRIPTION: Response to 1/16/91 letter concerning additional soils sampling
" Frame Beg ins
1
Ends
, 1
. '.
SUB-HEAD :.
2. 2.
Treatability Study,
, 2. 2.
- 0001 Microfilm Reel
DATE: 01/12/90 PAGES: 168
AUTHOR: /Landau Associates, Inc.
ADDRESSEE: /Northwest Transformer Steering Committee
3SCF ~ION: Final Work Plan Northwest Transformer Site
Treatability Study*
Frame ~egins
1
Ends
1
Vitrification
- 0002 Microfilm Reel
DATE: 02/22/91 PAGES: 121
AUTHOR: /Landau Assosciates, Inc.
ADDRESSEE: /Northwest Transformer Steering Committee
~SCRIPTION: Final ,Report of Engineering Consultation
Treatability Study Northwest Transformer
Everson, Washington
L 2.
Frame Begins
1
Ends
1
Vitrification
(Mission/Pole) Site
- 0003 Microfilm Reel
DATE: 02/22/91 PAGES: 87
AUTHOR: /Geosafe Corporation
ADDRESSEE: /Landau Associates, Inc.
~SCRIPTION: Volume 1: Project Report Engineering-scale Test Report for
Application of In situ vitrification Technology to Soils
Contaminated with Polychlorinated Biphenyls at the Northwest
Transformer Superfund site*
2. 2.
Frame Begins
1
Ends
1
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NORTHWEST TRANSFORMER, MISSION/POLE - REMEDIAL A/R ADDENDUM INDEX
2. 2.
- 0004 Microfilm Reel
02/22/~1- .PAGES: 289
/Geosafe Corporation
/Landau Associates, Inc.
Volume 2: Project Appendices (A through first part of E)
Engineering-Scale Test Report for Application of In Situ
Vitrification Technology to Soils Contaminated with
Polychlorinated Biphenyls at the Northwest Transformer Superfund
site*
Frame Begins
1
Ends
1
DATE:
AUTHOR:
ADDRESSEE:
IESCRIPTION:
2. 2.
- 0005 Microfilm Reel
DATE: 02/22/91 .PAGES: 220
AUTHOR: /Geosafe Corporation.
. ~DDRESSEE: .jLanda.u Associates, In'c.. '. . .
IESCRIPTION: Volume"J.: Project Appendi~es:' (Second' portion of E)'
. Engineering-Scale Test Report for Application of In ~itu
Vitrification Technology to Soils Contaminated with
Polychlorinated Biphenyls at the Northwest Transformer Superfund
site* '.
Frame Begins
1
Ends
1
2. 2.
- 0006 Microfilm Reel
DATE: 02/22/91 PAGES: 240
AUTHOR: /Geosafe Corporation
ADDRESSEE: /Landau Associates, Inc.
'ESCRIPTION: Volume 4: Project Appendices (Conclusion of Ethrough K)
Engineering-Scale Test Report for Application of In Situ
Vitrification Technology to Soils Contaminated with
Polychlorinated Biphenyls at the Northwest Transformer Superfund
Site*
Frame'Begins
1
Ends
1
SUB-HEAD:
2. 2. 1.
Vitrification Cost Estimates
2. 2. 1. - 0001 Microfilm Reel
DATE: 02/25/91 PAGES:
AUTHOR: /Landau Associates, Inc.
ADDRESSEE: /
ESCRIPTION: Section 3.0 Vitrification Cost Estimating Information
Frame Begins
1
Ends
1
6
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NORTHWEST TRANSFORMER, MISSION/POLE - REMEDIAL AIR ADDENDUM INDEX
SUli-HEAD:
2. 3. 1.
Groundwater Monitoring Plan
2. 3. 1. - 0001 - -Microfilm Reel
DATE: OS/22/90 'PAGES: 152
AUTHOR: /Landau Associates, Inc.
ADDRESSEE: /Northwest Transformer Steering Committee
~SCRIPTION: Final Work Plan Northwest Transformer (Mission/Pole)
Ground Water Monitoring Program'
Frame Begins
1
Ends
1
Site
SUB-HEAD:
2. 3. 2.
Phase I Field Activities
2. 3. 2. - 0001 Microfilm Reel
,DATE: .o2/is/91 ' PAGES: 1,43
AUTHOR;. /Landau' Associates I,nc. " ,
ADDRESSEE: /Northwest .Transformer Technical Committee'
::SCRIPTION: Volume 1 '1'echnical Memorandum and Append'ices A-D Ground Water'
Monitoring Program Phase I Field Activities and Ground Water
Monitoring Event 1 Northwest Transformer (Mission/Pole) Site
Everson ", Washington
'Frame Begins
1
Ends
1
SUB-HEAD:
2. 3. 3.
Phase II Field Activities
!. 3. 3. - 0001 Microfilm Reel
DATE: 07/03/91 PAGES: 106
'THOR: /Landau Associates, Inc.
Au~...GSSEE: /Northwest Transformer Technical Committee
~SCRIPTION: Technical Memorqndum Ground Water Monitoring Program Ground
Water Monitoring Event 2 Northwest Transformer (Mission/Pole)
Site Everson, Washington
Frame Begins
1
Ends
1
~. 3. 3. - 0002 Microfilm Reel
DATE: 06/11/91 PAGES:
AUTHOR: Gary R. Reid/Puget Power
ADDRESSEE: Tim Brincefie1d/EPA
~SCRIPTION: NWT Ground Water Monitoring Program
Report - May 1991 and Revision 9 of
Frame Begins
1
Ends
,I
9
(GWMP) Monthly Progress
the GWMP Working Schedule
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NORTHWEST TRANSFORMER, MISSION/POLE - REMEDIAL A/R ADDENDUM INDEX
SUB-HEAD:
2. 4. 1.
Sampling and Analysis Plan
2. 4. 1. - 0001 Microfilm Reel
DATE: 04/04/91 PAGES: 34
AUTHOR: T.R. Pahl/EPA, Environmental Services Assistance Team
ADDRESSEE: Tim Brincefield/EPA
ESCRIPTION: Data Review of NW Transformer PCB Analysis
Frame Begins
1
Ends
1
SUB-HEAD:
2. 4. 2.
Results
2. 4. 2. - 0001 Microfilm Reel
DATE: 05/03/91 PAGES :"" 12
AUTHOR: Gary R. Reid/Puget Power
ADDRESSEE: Tim Brincefield/EPA
ESCRIPTION: NWT Mission/pole Site Validated
Frame Begins
1
Ends
1
Site Soils Sampling Plan Data
2. 4. 2. - 0002 Microfilm Reel
DATE: 08/23/91 PAGES: 105,
AUTHOR: /Landau Associates, Inc.
ADDRESSEE: /Northwest Transformer Technical Committee
ESCRIPTION: Volume 1 Sampling and Analysis Report Site Soil Sampling
Program Northwest Transformer (Mission/pole) Site Everson,
Washington
Frame Begins
1
Ends
1
SUB-HEAD:
2. 5. 1.
Corr~spondence
2. 5. 1. - 0001 Microfilm Reel
DATE: 04/20/90 PAGES:
AUTHOR: Gary R. Reid/Puget Power
ADDRESSEE: Christine Psyk/EPA
,ESCRIPTION: Results of preliminary review of
disposal cost alternatives
7
Frame Begins
1
Ends
1
several barn wood sampling and
SUB-HEAD:
2. 6. 1.
Correspondence
2. 6. 1. - 0001 Microfilm Reel
DATE: 02/22/91 PAGES:
AUTHOR: Gary R. Reid/Puget Power
ADDRESSEE: Charles E. Findley/EPA
ESCRIPTION:'Response to 1/31/91 letter (see document #2.1 0002)
additional soil sampling and possible change in the
4
Frame Begins
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Ends
1
concerning
remedy
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