United States Off ice of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R10-92/043
September 1992
SEPA Superfund
Record of Decision:
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~
"
,
NOTICE
The appendices listed in the index that are not found in'thls document have been ~ at the request of .
the issuing agency. They contain material which supplement, but adds no further appflc:abfe information to
the content of the document. All supplementaj material is, however, contained In the administrative record
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Recipient'a AcC888ion No.
PAGE EPA/ROD/R10-92/043
4. Tide and SWtide 5. Report Date
SUPERFUND RECORD OF DECISION 09/30/92
Joseph Forest Products, OR
6.
First Remedial Action - Final
7. Author(a) 8. Perfonnlng Orgllllization Rept. No'
9. Perfonning Orgainization Name and Acldre.. 10. ProjectlTa8klWork Unit No.
11. ContnC1(C) or Grant(G) No.
(C)
(G)
12. ~ng Organlz8tlon Name and AcIdre.. 13. Type of Report 80 PerIod Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
1 S. SUppiementlry Notel
PB93-963613
16. Ab81rlct (Umit: 200 words)
The 18-acre Joseph Forest Products (JFP) site is a wOOd-processing facility in the City
of Joseph, Wallowa County, Oregon. Land use in the area is predominantly industrial
and agricultural. The City of Enterprise uses two springs located 4,000 feet from JFP
to serve as its municipal water supply. In 1974, and again from 1977 to 1985, Joseph
Forest Products, Inc., used the site as a lumber mill, processing wood into lumber
products. Structures located on the facility include a sawing facility, a wood
treating facility and an adjacent drip pad, a drying building, a pumphouse, and
maintenance facilities. Wood treatment operations consisted of mixing a concentrated
preservative paste with water and treating lumber products with the mixture of
chromium, copper, and arsenic (CCA) in a retort. Process wastes, including wood chips,
sludge, and other materials remaining in the retort, were removed periodically and
placed in a cement pit adjacent to the treatment building. In 1974, the treatment
building and surrounding buildings were destroyed by fire. During fire-fighting
operations approximately 200 gallons of contaminated treatment paste and 3,000 gallons
of treatment solution were released into the soil. It is estimated that more than
(See Attached Page)
17. Document Analysis L Deacriptora
Record of Decision - Joseph Forest Products, OR
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: metals (arsenic, chromium, lead), inorganics (asbestos)
b. IdentifieralOpen-Ended Terms
c. COSATi Reid/Group
lB. Avlillbifity Statement 19. Security CI... (This Report) 21. No. of Pages
None 66
20. SecurIty CIa.. (This Page) n PrIce
None
272 (4-77)
(See ANSI Z39.1B)
See InslTucllona on Roveme
(Formerty NT1~)
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EPA/ROD/R10-92/043
Joseph Forest Products, OR
First Remedial Action - Final
Abstract (Continued)
160,000 pounds of CCA preservative concentrate were used at the site between 1978 and
1985. As a result of a 1984 state investigation that identified elevated levels of
metals, EPA conducted a site inspection, which revealed metal contamination in surface
water and soil. In 1985, a state enforcement action instructed JFP to ship eleven
55-gallon drums of waste material to an offsite hazardous waste landfill. In 1991,
during EPA's remedial investigation, a removal action involved excavation and offsite
disposal of highly contaminated soil. This ROD addresses a final remedy for the
excavation and disposal of contaminated soil and debris remaining onsite. The primary
contaminants of concern affecting the soil and debris are metals, including arsenic,
chromium, and lead; and inorganics, including asbestos.
The selected remedial action for this site includes demolishing contaminated onsite
structures, including the process, storage, and mixing tanks, and the wooden structures
and concrete slabs, followed by offsite disposal; decontaminating the concrete drip pad
and tanks, followed by recycling or offsite disposal of debris; excavating surface and
subsurface soil, with screening and segregation of hazardous waste for offsite disposal,
with stabilization, if necessary, prior to disposal at appropriate facilities;
backfilling any excavated areas; removing asbestos from the facility, with offsite
disposal; removing underground storage tanks and any associated contaminated soil, with
scrapping or offsite disposal; monitoring ground water; and implementing institutional
controls, including deed and land use restrictions or environmental notices. The
estimated capital cost for this remedial action is $550,000, with an annual O&M cost of
$24,000 for 3 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil clean-up goals, which are based on EPA risk-based standards,
include surface soil clean-up levels (10-5) for arsenic 36 mg/kg; debris surface soil
1351 mg/kg; copper 10,000 mg/kg; for subsurface soil (10-4), arsenic 336 mg/kg;
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DECLARATION
Joseph Forest Products
Superfund Site
SITE NAME AND LOCATION
Joseph Forest Products
Wallowa, County, Oregon
STATEMENT OF PURPOSE
This decision document presents the remedial action selected by the U.S.
Environmental Protection Agency (EPA) for the Joseph Forest Products Superfund
Sit~ (Site) in Wallowa County, Oregon. The selected 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 Oregon 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 Site includes excavating contaminated soils
to specified cleanup levels, demolishing the existing treatment building,
decontaminating process equipment, and transporting contaminated soil and
debris to an approved off-site disposal facility. The remedy is designed to
significantly reduce exposure to the contaminated soils, debris, and
equipment. The goal of the selected remedy is to remove and remediate soils
and debris to levels that are protective of human health and the environment.
The maior components of the selected remedy include:
Excavation of contaminated surface and subsurface soil to
specified cleanup levels, demolition of the treatment building,
decontamination of the drip pad and treatment equipment, and off-
site disposal of soils and debris. Soil which is classified as a
hazardous waste would be treated as required to meet the land
disposal requirements and disposed in a permitted Resource
Conservation and Recovery Act (RCRA) hazardous waste disposal
facility.
Excavation of ahandoned Underground Storage Tanks (USTs).
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transport of the tanks off-site for disposal or salvage as scrap
metal. Soil samples would be collected from beneath the tanks and
analyzed for total petroleum hydrocarbons as required by Oregon
Department of Environmental Quality (DEQ) tank closure
regulations. If soil contamination is discovered, contaminated
soil would be excavated and disposed of off-site. The excavation
would be backfilled with cl~an soil.
Removal of asbestos from the abandoned wood drying building and
placing it into sealable plastic bags. After all materials have
been removed, the wall surfaces would be vacuumed. Asbestos-
containing wastes would be disposed of off-site in a trench
meeting regulatory requiremants for asbestos waste disposal.
Use of institutional controls such as deed restrictions, or use of
an environmental notice to ensure appropriate consideration of
Site conditions in future land use decisions.
A groundwater monitoring program would be implemented.to verify
.that contaminant levels in all wells and the City of Enterprise
water supply allow for unlimited use. .
STATUTORY DETERMINATIONS
The selected remedy is'protective of human health and ~he environment;
complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the r~medial action; and is cost-effective. This
remedy uti'lizes permanent so1ut.ions and alternative treatment (or resource
recovery) technologi.es to. the maxi.mum extent practicable, and satisfies the
statutory preference for remedies that employ treatment that reduces toxicity,
mobility or volume as a principal element.
Signature sheet for the Joseph Forest Products Record of Decision by the U.S.
Environmental Protection Agency.
11fJAJ-L a-1B~
DANA A. RASMUSSEN
Regional Administrator, Region 10
U.S. Environmental Protection Agency
1(30192-
Date
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DECISION SUMMARY
INTRODUCTION
The Joseph Forest Products Site ("JFP Site" or "Site) was noininated 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 the United States Environmental Protection Agency
(EPA) in 1986. The Site was placed on ,the NPL in March 1989 (54 Federal
Register 13296, March 31, 1989) pursuant to Section 105 of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C.
~9605, as amended by che Superfund Amendments and Reauthorization Act of 1986
(CERCLA or Superfund). '
Pursuant to Execucive Order 12580 (Superfund Implementation) 'and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40
C.F.R. Part 300, EPA'performed a Remedial Investigation/Feasibility 'Study
(RI/FS) for the Site. The Remedial Investigation (RI); completed,July 1992;
charac terized contamination in soils, 'surface water and groundwat~r., A ,"
Baseline' Risk Assessment was completed in March 1992 and 'evaluated potential
.effects of, the contamination on human health and the environment.' The
Feasibility. Study (FS), completed in September 199'2, evaluated alternatives
for remediat~ng :contamina,tio1); " ' , ' '
L
, SITE ~ESCRIPTION
Na~e and Location
The JFP,Site is located in Wallowa County', Oregon, 'approximately'O.75
miles northwest 'of the City of Joseph, on Russell 'Lane. The Site'consists of
a, parcel of approximately 18 acres in'the northwest quarter'of .the southwest
quarter of Section 30, Township 2 South, Range 45 East of, the Willamette
Meridian. See Figure l,for the location of the JFP Site. . Figure .2 shows the
Site plan and significant fea,tures of the site. The Site is' divided into east
and west parcels by the Union. Pacific Railroad tracks and. right~of-way;
Relevant structures at the JFP Site on the east parcel include the
treatment building and the adjacent concrete foundation used as a drip pad, a
maintenance shop,' an abandoned lumber drying building, the remains of a
collapsed wigwam burner, and a developed spring with pumphouse(see Figure 2).
The west.parcel, includes' the location of.the. former JFP office building; JFP' s
former lumber sawing facilities (including saws and a debarker), other
abandoned buildings, and a welL Electrical and telephone utilities were
apparently supplied by overhead lines, with underground. utilities limited to
on-site water distribution and possibly steam lines related to previous lumber
mill operations.' "
Topography and Vegetation
The JFP Site is located on Alder Slope, an alluvial/colluvial fan
associated with the foothills of the Wallowa Mountains. In general, the
topography of the Site is relatively flat. The eastern portion of the Site
(i.e., east of the railroad tracks) slopes to the north-northeast.
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Approximate surface elevations over most of the eastern portion of the Site
range from 4085 feet Above Mean Sea Level (AMSL) at the south boundary to 4075
fee t AMSL at the north boundary. The .low point is the gully" formed by the
outlet stream from the JFP spring. This gully is located at the northeast
corner of the Site. The bottom of the gully is at an approximate elevation of
4067 feet AMSL. The high point of the eastern portion of the Site is the.
extreme southwest corner, which has an approximate elevation of 4090 feet
AMSL.
The western portion of the Site slopes to the north and east. The
surface is slightly steeper than the eastern portion. Surface elevations
range from a high of approximately 4100 feet AMSL at the southwest corner to
4077 feet AMSL at the northeoast corner.
Vegetation at the Site consists of perennial bunch grasses and sparse
trees and . shrubs . Grasses are found over most of the undistur.o.ed .areas of the
Site. Trees and shrubs are found.along the banks of the stream and spring,
and at other scattered locations. .
Adiacent Land Uses
The JFP Site is located in an industrial and agricultural .area. The
property is bounded by Russell Lane to the north, and is bordered by property
owned by the Clifford C. Hinkley Estate on. the east and south, Sequoia Forest.
Products to the south, and by the Joseph Airport to the west. The areas
north, east, and south of the Site are primarily agricultural (e.g., grazing,
forage crops). The nearest residence is the Roup-Daggett residence, which is
north of the Site approximately 100 feet north of Russell Lane. Sequoia
Forest Products is an active lumber mill and is .the major industrial activity
in the area. . .
.Surface Water and Groundwater Resources
Both surface water and groundwater resources exist near the JFP Site.
Surface .water resources include nearby rivers, creeks, lakes, and springs.
The larger streams and lakes; including Hurricane Creek, the Wallowa River, .
and Wallowa Lake are used for recreational and irrigation. Developed springs
may be used for domestic and agricultural purposes. The most important of
these springs in the vicinity of the Site are two springs, located
approximately 4000 feet north of the JFP Site, .which serve as the municipal
water supply to the City of Enterprise. The JFP Site is located within the
City of Enterprise Watershed Protection Area.
Shallow groundwater is used locally for domestic purposes. Other than
the shallow on-site well, which is not currently used, the nearest domestic
well is located at the Roup-Daggett residence, across Russell Lane to the
north of the Site. Depths to the shallow aquifer vary in the vicinity of the
JFP Site, ranging from less than 10 feet to as deep as 80 feet.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
History of Site Activities
JFP began wood treatment operations in 1974 utilizing a vacuum-pressure
treatment process. Treatment occurred within the treatment building
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identified in Figure 2. The treatment process involved initial make-up of the
treatment solution, loading a pressure vessel (retort) with lumber, placing
the retort under vacuum for approximately one hour, filling the retort with
treatment solution, pressurizing the solution-filled retort for approximately
two hours, and finally, pumping out the excess treatment solution and removing
the treated lumber for drying. The initial solution make-up was performed in
a 407-gallon mixing tank near the head end of the retort; the solution was
then transferred to a SlOO-gallon storage tank located just above the head end
of the retort. The retort vessel had a total volume of 3990 gallons. A
layout of the treatment building and equipment is shown in Figure 3.
During the initial operations, JFP used a water-based preservative known
by the trade name of Osmose K-33 (also known as chromated copper arsenate
(CCA) type II or CCA type B). This product is reported to have a chemical
composition of 35.3 percent chromium (VI) (as Cr03). 19.6 percent copper (as
CuO) , and'45.l percent arsenic (as As20s). '£he preservative was supplied to
JFP as a 72 percent oxide paste in 2~-gallon drums. One 20-gallon drum was
used to produce approximately 1500 gallons of ,treatment solution.
During initial operations, treated wood at JFP .was transferred to a
. drying area at the north side of the Site adjacent to Russell Lane. After.
only two weeks of operations in 1974, the treatment building and surrounding.
buildings were destroyed by a fire. An estimated 200 gallons of concentrate'd
treatment paste and approximately 3000 gallons of treatment solution in the
storage tank were lost. It is assumed that the material was washed onto
nearby soil during fire fighting operations. Based on the reported
composition of Osmose K-33, the total amount of metals r~leas~d was estimated
to be 810 pounds arsenic, 500 pounds chromium, and 430 pounds copper.
After the fire, JFP did not resume treatment operations until late 1977..
In 1977, the treatment building was rebuilt to cover only the head-end area
(solution mixing tank, cement sump, and pumps and compressors). The building
was extended to cover the retort in 1979, and a cement block wall was added to
the cement slab foundation for spill containment. When treatment operations
resumed in 1977, Osmose K-33 CCA-type C was used instead of the previously-
used CCA-type B preservative. CCA-type C is composed of 47.5 percent Cr03.
18.5 percent CuO, and 34 percent As20s. The treatment process was the same as
previously described. Empty concentrate containers were rinsed and stored
outside the treatment building along the northeast side. After processing
each batch of wood, a heel of approximately 50 gallons of treatment solution
could not be pumped from the retort and was drained into a cement sump beneath
the storage tank. This solution was then later pumped back into the storage
tank for reuse. Process wastes, including wood chips, sludges and other
materials remaining in the retort, were periodically removed and placed in a
cement pit adjacent to the east side of the treatment building (see Figure 3).
JFP and manufacturer records indicate that JFP used approximately
160,380 pounds of Osmose K-33 preservative concentrate from 1978 through
of 1985, when operations ceased.
July
The JFP Site was owned and o~erated by Joseph Forest Products, Inc. from
1974 through 1985. The company filed for bankruptcy in June 1984, and ceased
operations in 1985. The Site property had been purchased from Mr. Clifford
Hinkley, the adjacent land owner, under a real estate contract. After JFP
declared bankruptcy and defaulted on the purchase contract, the property title
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reverted to the Hinkley Estate, which is the present property owner.
Historv of Federal and State Site Investigations and Removal and Remedial
Actions Conducted Under CERCLA or Other Authorities
Initial regulatory involvement with JFP included a Site visit by Oregon
Department of Environmental Quality (DEQ) staff in 1984. On September 25,
1984, DEQ collected samples of soil, waste material, and surface water from
the Site. Subsequent chemical analysis of those samples indicated elevated
levels of chromium, copper, and arsenic in soil adjacent to the drip pad and
treatment building, waste material and sludges from the waste pit adjacent to
the treatment building, and surface water collected on the drip pad. In the
case of the sludge from the pit and inside the treatment building at the end
of the retort, "extraction procedure" (EP) toxicity hazardous waste limits for
chromium and arsenic were exceeded. EP is the test for determining whether a
waste exhibits. the toxicity characteristic of a hazardous. waste. EPlimits'
for chromium and/or arsenic were exceeded in analyses of four out of six soil
samples from the Site. EP limits and primary drinking water standards for' .
chromium and 'arsenic were' exceeded in analyses of samples .of rain. water
collected from the waste pit. and from the drip pad, and in a sample of
container' r.inse water. Analyses of two water"samples collected from. the
spring on the Site north of.tbe treatment.building indicated concentrations of
copper, chromiurn, and. arsenic below primary and s'econdarydrinking water"
standards.
Following this initial sampling effort, JFP' was issued a Notice' of
Violation (#HW-ER-85-05,. dated March 7, 1985) from the DEQ for unauthorized.
disposa.l and storage of hazardous' waste. JFPre'spondedin that same month by
removing empty'containers and arranging.for'disposal of chemical wastes on
Site. DEQ submitted. a. preliminary assessment' (PA) . report. to EPA on June 8, .
1985 (Site number 068728280). On August 22, 1985, JFP shipped. eleven 55- .
gallon drums of waste material (consisting primarily of sludge and wood chips
from the. pit adjacent to' the treatment building) to an off.-site' hazardous'
waste landfill.. By late 1985, it had become apparent that 'JFP' s insolvency
would prevent any further corrective actions on the part of JFP.
A "site inspection" (SI) of the JFP Site was conducted by EPA .
contractors during September and October of 1985. Sampling efforts continued
from January through April 1986. .The S1 report was issued in. May of 1987.
Field activities during the S1 included installation of monitoring wells and
collection of samples of soil, surface water, and groundwater. Samples were
analyzed for inorganic and organic contaminants. The principal contamination
of concern identified in the SI was elevated levels of metals, . primarily
arsenic, chromium, and copper, in soils at the Site. The highest levels of
these metals detected were 12,400 mg/kg arsenic, 7830 mg/kg chromium, and
13,000 mg/kg copper. The most highly contaminated soil samples were collected
along the east side of the treatment building. Several of these samples also
contained arsenic and chromium in excess of EP limits. In addition, the SI
results indicated detectable levels of total metals in some groundwater and
surface water samples. As a result of the SI and the subsequent HRS score,
the JFP Site was nominated to the NPL.
A search for "potentially responsible parties" or "persons. (PRPs) was
conducted as part of the initial CERCLA activities for this Site. Based on
the results of the PRP search, "special notice" letters, as identified by
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Section 122(e) of CERCLA, 42 V.S.C. 9622(e), were sen~ to Joseph Forest
Products and the Estate of Clifford Hinkley requesting good faith proposals to
conduct the RI/FS. Neither party submitted a proposal. .
The RI/FS. was initiated in January 1990. Field activities associated
with the RI/FS were begun in July 1990. The first phase of field
investigations was completed in August 1990. Subsequent periodic groundwater
monitoring was performed in October 1990; January, April, and September 1991;
and April 1992. Based on the results of the first phase of RI activities, a
removal action was carried out by EPA in October and November 1991. The
removal action involved.excavation and off-site disposal of highly
contaminated soil identified during the RI.
III.
COMMUNITY RELATIONS HISTORY
CERCLA requirements for public participation include releasing the RI/FS
reports and the "Proposed Plan~ (which preceded this Record of. Decision) to
the public and providing a public comment period on the FS and "Proposed
Plan". EPA met these requirements on August 14, .1992 by placing both.
. documents in the public information repositories for the Site and mailing
copies of the "Proposed Plan" to individuals on the mafling list. EPA
published a notice of the release of the RI/FS and proposed plan in the La
Grande ObserVer 6n August 18, 1992. Notice of the .30 day public comment: . .
period and a description .of the . "Proposed..Plan" we.re included in the newspaper
notice. The public comment period. ended on September 17, 1992.and no comments.
from the public were received. . ... .
To date, the foll~wing community relations activities have been
.conductedby.EPA. for the Site:
April 1990
EPA released a. fact sheet .explaining the Remedial
Investigation and announcing the dates of interviews for the
Community Relations Plan.
June 1990.
EPA released the Community Relations Plan, which included.
interviews from member of the public and local officials,
. March 19, 1991
EPA mailed a fact sheet which gave the results o'f the first
round of the field investigation and explained upcoming
activities.
October 1, .1991
A fact sheet announced plans to remove highly .contaminated.
soil from the Site.
August 14, 1992
EPA mailed the Proposed Plan, which explained the results of
the RIfFS, all of the alternatives that were considered, and
EPA's preferred cleanup alternative. The fact sheet also
announced the public comment period. .
August .18, 1992
Newspaper ad ran in the La Grande Observer announcing the
beginning of the comment period and explained EPA's
preferred cleanup alternative.
August 17 - September 17, 1992
Public Comment Period.
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September 1992
Responsiveness Summary prepared.
IV.
SCOPE AND ROLE OF RESPONSE ACTION WITHIN THE SITE STRATEGY
The selected remedy is the second response action conducted at the JFP
Site and represents the final remedial action for the Site. EPA conducted a
removal action in the fall of 1991 after the RI field investigation located
and characterized highly contaminated soils in the treatment building and drip
pad areas of the Site. EPA determined that the removal action was necessary
because the highly contaminated soils posed a threat to the groundwater
pathway. Approximately 600 cubic yards of soil contaminated with arsenic,
chromium and copper was excavated and transported to the Environmental
Services of Idaho Inc. hazardous waste disposal facility for disposal.
Security fencing was installed around the treatment building to prevent
access. The results of the RIfFS shows that other contaminated material
remaining on site needs to be addressed.
The primary t~reat remaining at the JFP Site is the potential for
exposure to metals resulting from contact with contaminated surface soils;
Th&Site is located close to .several residences. This response action is
designed to remove the threat to public health by significantly reducing the
volume of the contaminated soil and removing contaminated debris and equipment
which could serve as a continued source of contamination and exposure risk' to
humans.
In addition, this response action vlill reduce thepot:ential f0r the
contaminated soil to act as a source for groundwater contamination. Although.
low levels of metals were detected in groundwater monitoring wells at this
Site, the concentrations are currently below-Maximum Contaminant Levels (MCLs)
at the City water supply Springs and all wells tested.. Therefore the current.
levels of metals in the groundwater at the Site are.not believed to pose a
significant public health threat. Removal of on-site SOUrces of soil
contamination. and debris, which could .serve as continued ~ources if
unaddressed, will reduce the potential for groundwater contamination.
Groundwater monitoring will be continued for several years after
implementation of the remedy to confirm that contaminant levels are below
health based levels and that groundwater supplies remain safe for human
consumption. 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.
v.
SUMMARY OF SITE CHARACTERISTICS
Geology and Soils
The major geologic feature in the vicinity of the JFP Site is the
Uallowa Mountains. The Wallowa Mountains are located immediately to the south
of the JFP Site and are composed of a dissected dome of sedimentary and
volcanic materials, intrusive granodiorite, and .intrusive and extrusive
basalt. The range has been shaped by the intrusion of the Wallowa Batholith
which forced the overlying sedimentary formations upward and outward.
The JFP Site is within the Wallowa River Valley.
Surficial materials in
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the vicinity of the Site include glacial, alluvial, and colluvial deposits.
Glacial deposits are found on the valley walls and floor. Alluvial deposits
are found on the valley floor. Colluvium is found on the valley walls and
floor overlying glacial deposits. The JFP Site is located on Alder Slope, an
alluvial/colluvial fan associated with the foothills of the Wallowa Mountains.
Monitoring well log data collected during the SI indicate that the Site
is underlain by glacial till at depths of 0.3 to 4 feet. The thickness. of the
till was reported to approach 20 feet or more. The till was estimated to
consist of eroded material from both the Wallowa River and Hurricane Creek
valleys. The till was noted to be overlain with sediments of coalescing
alluvial/colluvial fans.
The soils that have developed at the JFP Site reflect the mixed and
highly variable parent material source. The soil at the Site is mapped as
Matterhorn gravelly fine: sandy loam, 0 to 3 percent slope. The soils are
dominated by coarse rock fragments (as high as 70 percent by volume cobbles
. and gravel in the subsoil). .Matterhorn soils have high surface permeability
and low water holding capacity. These soils are also moderately alkaline and
calcareous throughout the profile. .
Hydrology
Principal surface water features in the vicinity of the JFP Site
originate ~n the Wallowa Mountains and are fed primarily by. runoff and
snowmelt. Thesefea~ures, shown in Figure 4, include Hurricane .Creek to the
...;est ,. ~he Wallowa River to t.he east, .and \-;'allowa Lake to the south. . Hurricane.
Creek drains approximately 30 square miles. The creek flows northeast and. is
within one-half mile of the JFP Site at its closest point. The IJallowa Rive.r
drains approximately SO.square miles upstream of the JFP Site and the flow in
the vicinity of the JFP Site is controlled by Wallowa Lake: The lake is .
approx~rnately four miles long, 0.7S.miles wide, and has a maximum storage
capacity of 47,000 acre-feet.
Groundwater in the Wallowa River Valley occurs in both shallow surficial
aquifer systems in the unconsolidated surface deposits, and in deeper sys.tems
within underlying volcanic sequences.. Depths to the shallow aquifer vary in
the vie ini ty of the JFP Site, ranging from less than te.n fee t to as deep as 80
feet. The depths to groundwater noted in the Site monitoring wells have.
ranged from 2.5 to 13.3 feet. Based on observations of groundwater elevations
in seven monitoring wells at and near the JFP Site, a groundwater flow
direction from southwe.st to northeast across the Site is inferred. .Shallow
groundwater is expected to discharge into the Wallowa River to the northeast
of the Site. During installation of the monttoring wells as part of the SI,
the static water levels in completed wells were consistently observed to be
higher than the depths at which water was first encountered during drilling.
These observations are consistent. with location of the Site in a groundwater
discharge area.
Evidence of groundwater discharge in the vicinity of the JFP Site is
also provided by springs. Groundwater at theJFP Site is observed to
discharge most of the year from a developed spring on the Site, with
subsequent surface flow to the northeast into the Wallowa River. Numerous
ephemeral springs have been observed in the low area across Russell Lane to
the north of the JFP Site. This area also drains into the Wallowa River.
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There are two developed springs, located approximately
JFP Site, which serve as the municipal water supply to
The locations of springs are shown in Figure 4.
4000 feet north 'of the
the City of Enterprise..
The climate of the upper 'Wallowa River Valley is influenced by the close'
proximity of the 'Waliowa M01,1ntains'. Mean annual 'precipitation at the City of
Joseph is 19.4 inches. Potential evapotranspiration is 24 to 36 inches per
year. Mean annual temperature is approximately 45°F.
Contaminant Characteristics
Potential sources of contamination at the Site were identified during
~reparation of the RI/FS Work Plan. roese sources were identified based on
data presented in the SI report and from observations made at the Site during
RI/FS 'Work Plan preparation. Known or suspected contamination sources
iden~ified in the RI/FS work Plan include: .
.
Spills and leaks of CCA treatment solution from the treatment
building and drip pad;
.
Treatment chemical drippagein the' four treated lumber storage'
areas;
.
Spills or leaks fr.om wood treating...vats on .the Hinkley Property
(adj acerit to the JPF Site);
e
. Suspected asbestos-cc!ltaini-ng mater.:ial' (AGM) in the abandoned. wood
drying building; and
.
Abandoned drums and underground storage tanks (USTs)
.The RI was undertaken to determine the nature and extent of
contamination .at these potential. source area. In addition, .the potentially
affected environm~nt, including. groundwater and surface water was sampled.
Relevant results of the RI are summarized below. Based on the results of the
RI, a removal action was underta~en to remove highly contaminated soils
adj acent to the treatment building and. drip pad. The results' of . the removal'
action in reducing levels of contamination are also described below. .
Back~round Metals Concentrations
To assess the nature of metals contamination at the Site, .it was.
necessary to determine local background concentrations of metals in soils.
Triplicate samples were collected at four locations apparently unaffected by
JFP operations. The results of metals analysis of these samples are
summarized in Table 1.
Surface Soils Associated with the Treatment Building and Drip Pad
Surface samples were collected around the perimeter of the drip pad and
treatment building to define the levels and extent of contamination resulting
from spills and leaks. Samples were collected at regular intervals in two
concentric rings around the treatment building and drip' pad perimeter and
analyzed for total metals. Analytical results are summarized in Table 2.
Comparison of these results with background results indicates elevated and
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highly variable concentrations of arsenic, chromium, and copper. The most
highly contaminated areas exist to the east of the treatment building, around
the treatment building apron, and along the north side of the drip pad.
Relatively low levels of contamination were noted. along the south, south-east,
and south-west sides of the drip pad. The levels of contamination appear to
decrease. r-apidly with distance from the base of the foundations. 'In general,
the levels of contamination in the samples from the outer ring were much less
than in corresponding samples from the inner ring. This pattern suggests that
elevated levels of surface contamination should be confined to a relatively
narrow band around the drip pad. This pattern is consistent with spillage or
leakage from the pad as the source of contamination.
Eight of the inner ring perimeter samples, plus two field duplicat:es,
were also analyzed for semivolatile organic compounds. The results of the
semivolatiles analysis was consistent with the results of the analysis of the
background samples. .
Subsurface Soils Associated with the Treatment Buildin£ and Drip Pad
.Subsurface samples were collected.in areas of expected high
c9ntamination to determine the vertical extent of contamination. These sample
locations were .east of the treatment building, at the. southeast corner. of the'
. . .treatment building apron, and at th~ nor.theast corner of. the drip pad:
Samples locations are identified 'as lo.cations SUB~ 1 through SUB-6 in Figure' 5.-
Analytical results are summarized in Table' 3. Comparison:of these results"'.
with background results indicates elevated concentrations of arsenic,
ch~omium, and copper.
The highest. concentrations of arsenic, chromium, and copper were
observed at locations SUB-2, SUB-3, and SUB~4, and were consistent with
visible staining of the soil materials. At.SUB-2 and SUB-3, concentrations'at
.the surface are less than .subsurface concentrations. This trend is consistent.
. with t~e apparent subsurface sources of contamination observed at these
: loca.tions (i..e.., leaks in sumps).
At the other locations, contaminant.concenttations decrease with depth,
suggesting. a surface source of contamination.
Removal Action Around Treatment Buildin£ and Drip Pad
The'removal action implemented during October and November 1991 involved
excavation and removal of approximately 600 cubic yards of contaminated soil
from theJFP Site. During the removal action, sampling and analysis was
performed to delineate the extent of the soil to be excavated. and to confirm
the concentrations remaining after disposal. The boundaries of the
excavations and locations of confirmatory samples are shown in Figure 6.
Analysis to delineate the extent of contamination was performed on-site using
a portable X-ray fluorescence (XRF) analyzer. After the contaminated soils
were excavated, samples were collected from within and adjacent to the
excavations. These samples were submitted to a Certified Laboratory Program
(CLP) laboratory for analysis of total arsenic, chromium, and copper.
Concentrations of total arsenic, chromium, and copper detected in these
confirmatory samples are presented in Table 4.
The results of the confirmatory soil sampling indicate that most of the
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highly contaminated soils were removed from the Site. The only highly
contaminated soils remaining which could not be excavated are those under the
treatment building. The soil under the head end of the building was green in
color and appeared to be highly contaminated. Two samples were collected and
confirm high levels of contamination (see Table 4, samples TlI00325 and
TlI00326). Additional information on the removal action is included in the
RI/FS and ,Administrative Record.
Soil Beneath Drip Pad
Soil samples were collected at 3 locations beneath cracks in the drip
pad to determine whether migration of contaminants had occurred through the
pad. The results of analysis for total metals in soil samples collected from
beneath the drip pad are shown in Table S. These results indicate levels of
arsenic, chromium, and copper above background. The levels of arsenic,
chromiwn, and copper are comparable to the levels observed in the treated
lumber storage areas and do not appear to be indicative of gross
contamination.
Swipe Samples of Drip Pad and Treatment Building Floor
Surface swipe samples were collected from three discrete locations on
the surface of the drip pad and one location inside the treatment building.
Swipes were collected using filter papers .saturatedwith distilled water and '.
dilute nitric acid and analyzed for total metals. All. sample ..loca.tions were
apparently contaminated with CCA, as evidenced by green staining. The results
ir..dicate that portions of this contal!!ir..ation are extractable by dtstilled
water and dilute nitric acid.
Treated Lumber Storage Areas
Surface soil samples were collected from the four known or suspected
lumber storage areas. Analytical results are summarized in Table 6. In
general, the levels of arsenic, chromium, and copper in these samples appear
to be higher than levels in background samples.
The levels of arsenic, chromium, and copper in the storage area samples
are generally much less than the levels observed in samples from the treatment
building and drip pad perimeters. These results appear to be indicative of
slight CCA contamination. Such contamination would be consistent with
drippage from of treatment solution treated lumber during drying.
A subset of the storage area samples were also analyzed
organics. Results were consist with results from analysis of
samples.
for semivolatile
background
Hinkley Property
Three soil samples plus one field duplicate were collected from the
Hinkley Property near vats which were suspected of being used for lumber
treatment. These samples were analyzed for total metals and the results
showed arsenic, chromium, and copper to be within the range of concentrations
for the background samples. The soil samples from the Hinkley Property were
also analyzed for semivolatile organics. Of interest was pentachlorophenol
(PCP), which had been detected in a soil sample collected near the vats during
-------
the SI. The SI results showed an estimated concentration of 17,000 ug/kg (17
mg/kg) in this sample and less than 140,000 ug/kg in the field duplicate.
Results of the semivolatiles analysis of samples collected from the Hinkley
property during the R1 showed PCP to be. the only semivolatile compound above
detection limits. PCP was detected in two of the three samples. A
concentration of 11,000 ug/kg was detected .in one sample and an estimated.
concentration of 46,000 ug/kg was measured in the other. A field duplicate of
the latter sample had an estimated concentration of 48,000 ug/kg. These
results are similar to the SI results and indicate minor PCP contamination in
the vicinity of the wood treating vats.
Wood Drying Building
Fabric material lining the abandoned wood drying building on the JFP
Site was suspected of containing asbestos. This suspicion was based on the
appearance of the material and the presence of heating pipes in the building
which were apparently used to dry lumber. During the RI, three samples of
this material were collected and submitted for analysis of asbestos fibers:
The results of these analyses show the presence Qf asbestos fibers idel:'lt.ified
as chrysotilein all three samples. The chrysotile content of the samples
ranged £rom three to seven percent. For comparison, material containing one
percent or more asbestos fibers is defined under the Clean Air Act to be
Asbestos Containing Material (ACM). .
Groundwater
Gro~ndwater quality at the
seven monitoring wells installed
are shown in Figure
JFP Site was iTIoni to red us ib.g a net\\Tork of
during the SI. The locations .of these wells
7. Five rounds of. monitoring were performed during the RI puly ~nd October
1990; .January, April, .and September, 1991; .and April.1992).. Results for.
analysis of total metals are summarized in. Table 7. These results show total
metals to be highly variable and apparently elevated in some cases.
Evaluation of the groundwater data during the RI indicated that levels of
total metals appeared to be related to levels of suspended sediments in turbid
groundwater samples. In most cases, these results did no.t appear to be
indicative of contamination from the Site.
Results of dissolved metals analysis were more consistent. Dissolved
metals associated with known or suspected Site contaminants were generally.
below detection. Results of dissolved arsenic, chromium, copper, lead, and
zinc above detection are summarized in Table 8. These results show the only
well to consistently have dissolved arsenic. and chromium above detection is
\.]ell MW2. This well is the well most immediately downgradient of the
treatment building. Levels of arsenic and chromium in samples from this well
appear to represent contamination from the Site.
Surface Water
Surface water sampling during the RI included collection of samples from
the Wallowa River at and downstream of the Site, from the on-site spring, and
from the two City of Enterprise springs. The river was sampled during July
1990, and the springs were sampled during each of the groundwater monitoring
events. None of the samples of surface water or the City of Enterprise
-------
springs detectable levels of dissolved arsenic, chromium, or copper.
Potential Routes of Mi~ration
The resul.ts of the site characterization show chemicals of concern to be
present in surface and subsurface soils and groundwater. Potential routes of
migration include air, surface water, and groundwater. Surface contaminants
may migrate in air through suspension and windborne transport of contaminated
dusts. Surface contaminants may also be leached or eroded by surface water
runoff. Surface and subsurface contaminants may be leached to groundwater and
transported in groundwater flow. These potential routes of migration were
considered in development of exposure pathways in the baseline risk
assessment. Migration by these pathways is discussed below.
Air
Surface contaminants may be suspended in air and transported by wind.
Contaminant migration by this route can occ~rif contaminants are present in
particle sizes' small enough 'to be suspended and transported' by wind. Data.
were collected' during. the RI to evaluate the -potential for migration to' 'occur
by this route. Contaminated surface soil samples were collected and.various .
size fractions analyzed to. determine the level :of. contamination in the small"
fractions that could be eroded by the wind. These. results. show levels of
contamination present .inthe smallest size fracti'ons,analyzed.(i.e~, less than
0.05 mmand 0..05 .mmto.2.0 mm) are. essentially the same as the. levels in the
bulk sample. Based on these results, contaminated 'dusts could be generated by
. Ivinds. strong .enough to suspend these clay- to sand-.sized par.ticles. '." .
Modeling to evaluate airborne transport. of contaminants was performed as
part of the baseline ri.sk assessment.. A box model was used to calculate .
concentrations of chemicals of concern in airborne dusts at on-site exposure
points. These results were then used to determine .the human health risk
associated with airborne transport.
Surface Water
Surface contaminants may be transported in surface runoff from. the Site.
Contaminants may either be dissolved and transported in the liquid'phase or
contaminated particles may be. eroded and suspended in runoff.' Contaminant
migration by this route can occur if runoff is present and if surface .
contaminants are either readily soluble or present in particle sizes small
enough to be eroded. Data were collected during the RI to evaluate the
potential for migration to occur by this route.
As described above, soil size fractions were analyzed to determine if
contaminants were present in particle sizes which could be eroded. These
results indicate that levels in easily erodible clay- to sand.sized fractions
are essentially the same as in the bulk sample. In addition, samples were
tested to see if contaminants could be leached into water. These results show
that some of the chemicals of concern, notably arsenic, chromium, and copper,
can be leached from contaminated soils at levels of concern.
The potential for runoff is affected by a number of factors including
topography, vegetation, soil texture, and rainfall intensity. Topographic
data were collected to evaluate the potential for runoff from the Site. These
-------
data show that most of the contaminated areas are relatively flat, having
slopes from 0.2 to 0.5 percent. Other site-specific factors are generally not
indicative of a potential for high runoff. The Site is moderately vegetated
with &rasses and has coarse surface soils. These factors will reduce the
potential. for runoff. This qualitative evaluation of runoff' potential is
consistent with observations made at the Site~ No erosion scars or other
evidence of heavy runoff was noted.
The topographic data indicate that surfaces of all contaminated areas
drain toward the creek that discharges from the JFP spring. The contaminant
migration pathway for runoff, therefore, would include this creek and the
Wallowa River. River sampling performed during the RI did not show any
detectable contamination downstream of where' the creek discharges to the
Wallowa River.
Contaminant transport by surface water was not .evaluated in Qhebaseline
risk assessment. Human exposure through groundwater pathways was determined'
to be great~r than exposure through surface water pathways. . For this' reason,
human exp'osure through surface water was not considered. .
Groundwater. .
Surface and subsurface contaminants may potentially be. transported in
groundwater. Migration in groundwater is comprise~ of two phases, transport .
of contaminants from source areas to groundwater and transport'of contaminants
in groundwater. Factors affecting the first. phase include'. the solubility.of
.the conta.minan-ts and the ability of infiltrating water to c0ntact and dissolve'
contaminants. . As discussed above, chemicals of concern can be leache~.from
contaminated soils andSita conditions are favorable for infiltration of' .
precipitation~ The combination of these factors indicates that contaminants
can be leached from soil. . .
Factors affecting transport of contaminants in groundwater include' .
geochemical interactions between contaminants and aquifer materials. Possible
interactions were not spe~ifically investigated during the RI. The overall'
effect of such interactions was investigated indirectly through analysis of.
groundwater samples for both total and dissolved metals. In general,.these
results 'show that. total.metals conc.entrations a.re. much greater than diss'olved
metals concentrations. These' results 'indicate that most of the metal
contamination present in groundwater samples is associated with the solid
phase rather than the liquid phase. The only results showing appreciable
concentrations. of dissolved contamination were from Well MW2, which is' located
downgradient of the' treatment building. Some of the samples from Well MW2
contained dissolved arsenic and chromium at levels approximately equal to
total levels.
Migration of contaminants in groundwater will also be affected by
factors inf~uencing the transport of the groundwater itself. Important
factors affecting groundwater transport are the groundwater gradient and the
hydraulic conductivity of the aquifer. Groundwater elevation data were
collected during the RI and used to'determine groundwater gradient. These
results show a fairly uniform gradient of approximately 0.01 across the Site.
Aquifer conductivity was evaluated during the SI and results show hydraulic
conductivity values to range from 0.002 to 0.48 feet/min. The product of the
gradient and conductivity yields flux values of 0.029 feet/day and 6.9
-------
feet/day. The combination of gradient and conductivity suggests a substantial
flow of groundwater at the Site. Mobile contaminants in groundwater would be
readily transported from the Site.
Groundwater transport was not modeled in the baseline
Exposure was. evaluated using the measured concentrations of
groundwater on and off the Site.
risk assessment.
contaminants in
Regulatory Reouirements for Addressing Site Risks
The NCP, 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 Oregon cleanup levels under, and Clean Water Act Water
Quality Criteria (WQG). However, there are no corresponding criteria for.
soils and structures. Federal reme.diation standards for soils and structures
are usually established by setting contaminant concentratio.ns 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 "hazard index, II . .
VI.
SUMMARY OF SITE RISKS
The risks to h~~an health and the environment at the Site are described
in the site-specific Human Health Risk Assessment, which was preparp-d by ICF.
Technology for EPA using EPA guidance. The Risk Assessment followed a four
step process: 1) identification of . contaminants which are of signi.ficant
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 eaclier st-eps to sU1!lmarize the
potential and current risks posed by hazardous substances at the Site. The
resul ts of the Human Health Risk Assessment are discussed below..
Contaminants of Concern
Contaminants of concern were identified during the baseline risk
assessment. Contaminants of concern were identified by comparing observed
chemical concentrations with several criteria. These criteria were:
Risk-Based Screening Levels (RBSLs). Maximum concentrations _were
compared to RBSLs developed by EPA for residential exposure
scenarios. Chemicals with maximum concentrations above RBSLs were
selected as chemicals of concern provided that they also met the
other criteria.
Allowable Daily Intake Levels. Maximum concentrations were
compared with allowable daily intake levels for chemicals that are
essential human nutrients. Chemicals were selected as chemicals
of concern if toxicity and nutrient data suggested they are likely
to be associated with adverse health effects.
-------
Naturally Occurring Background. Concentrations of inorganic
compounds were compared with naturally occurring background
levels. Chemicals were selected as chemicals of concern if a
statistical test showed that the mean concentration of the
chemical was significantly different than the background
concentration of the chemical.
Frequency of Detection. The frequency of detection was considered
in selecting chemicals of concern.
Inorganic chemicals were evaluated using these criteria and seven
chemicals were selected as chemicals of concern. These seven chemicals are
arsenic, chromium, copper, lead, manganese, vanadium, and zinc. These
chemicals could pose potentially. significant risks of adverse health effects.
Arsenic and chromium are considered carcinogens. Noncarcinogenic health
effects which could result from exposure to the chemicals.of concern include
effects on the kidney, liver, cardiovascular, neurological and respiratory
systems.
All organic chemicals detected on the
concern. Organics were "rejected because of
because concentrations were below RBSLs.
Site were rejected as chemicals of
a low frequency of detection or
Exposure 'Assessment
The exposure assessment identified exposure pathways under current and
future. use scenarios. For. each pathway being considered,co!...cent::ations of
contaminants at poi~ts of expOSI~rc were determined. The results of the
exposure assessment are described below.
Exposure Pathways
The exposure assessment identified exposure pathways under' current and
future use conditions. A variety of pathways were identified fot .
consideration. These pathways were then evaluated and. those that were
incomplete were excluded from consideration. Complete pathways were further
evaluated to select those to be .included in the risk assessment. When
pathways resulted in similar exposure, the pathway resulting in greater or
more frequent exposure was selected. The following exposure scenarios and
pathways were selected for conditions at the Site:
Current-Use Worker Scenario: Exposure of workers via incidental
ingestion of surface soils and inhalation of windblown dusts; and
Current-Use Nearby Resident Scenario: Exposure of nearby residents
via ingestion of groundwater.
Future-Use On-Site Resident Scenario: Exposure of on-site
residents via incidental ingestion of soils, inhalation of
windblown dusts, and ingestion of groundwater.
Exposure Concentrations
Concentrations of chemicals of concern were determined for the points of
-------
exposure for each of the scenarios and pathways. Reasonable maximum exposure
concentrations were calculated at the 95 percent upper confidence limit of the
arithmetic mean. For soil ingestion pathways, the concentrations were based
on the results of analysis of surface soil samples. Separate exposure
concentrations were developed for background areas, for each "of the four
storage areas, for the combined storage areas, and for the treatment building.
For the current-use worker pathway, the background, combined storage area, and
treatment building concentrations were used, For the future-use residential
soil pathways, the background, individual storage area, and treatment building
concentrations were used.
For inhalation pathways, the concentrations were based on the results of
a box model that predicted concentrations of particulates in the air. Use of
this model is described in the Risk Assessment Report. For the current-use'
worker pathway, a single maximum concentration for the entire Site was
developed based on the.results of analysis of surface'soil samples around. the
treatment building. For the future-use on-site residential pathway, separate
concentrations were developed for each. of the storage areas and the treatment
building.
Concentrations for groundwater pathways were based. on the. results: of.
analysis .of total metals in samples from the monitoring wells. . 'For . the
current-use nearby .resident pathway, results from the on-site . and off -:site
. wells around the nearest downgradient residence (i..e.., Wells MW4, MW5, and
MW6) were used. . Average (average of three wells) and: reasonable maximum case
(highest. well) concentrations were developed. For the future-use on-site
resident pathway, results for the on-site ""ells' (Le., W"el1sMWl,HW2, wn,
and MW4) were used. Average and reasonable maximum .case concentrations' .were
developed.
. The exposure point concentrations were used to .estimate chronic daily
. intakes (CDls) for each of the chemicals.of concern for each pathway.. .
Exposure factors were developed based on EPA'sRisk Assessment Guidance for
Superfund Manual and the EPA .Region 10 Supplemental Risk Assessment Guidance
for Superfund Document.
Toxicitv Assessment
Toxicity data for each of the chemicals of concern were collected from EPA's
Integrated Risk Information System (IRIS) or from EPA ':s Health Effects
Assessment Summary Tables (HEAST). Toxicity data fornoncarcinogens were used
to developchroriic reference doses (RfDs) for ingestion and' inhalation routes
of exposure. As necessary, uncertainty factors were assigned to account for
uncertainty in the data used. Published toxicity data were also. used to
identify cancer slope factors (SFs) for carcinogens for ingestion and
inhalation routes of exposure.
Risk Characterization
In the risk characterization, CDIs developed during the exposure
assessment were compared with RfDs and SFs identified during the toxicity
assessment. This assessment of risk was performed for each of the chemicals
of concern for each of the exposure pathways. For noncarcinogens, .the
quotients of the CDI and RfD were summed to develop a hazard index (HI) for
each pathway. Similarly, chronic daily intakes and SFs were used to determine
-------
the excess cancer risk for each pathway. As described above, exposure
concentrations for different locations were considered for some pathways. The
exposure at the treatment building location is based on conditions existing
before the removal action. For pathways involving adult residents, both
average and reasonable maximum exposure (RME) concentrations were considered.
The results of the risk characterization are summarized in Table 9.
As can be seen from Table 9, the risk characterization results show an
HI greater than 1.0 and excess cancer risk greater than 10-6 for all soil and
water ingestion pathways. All inhalation pathways have an HI less than 1.0
and excess cancer risk less than 10-6. These results indicate current and
potential future risk associated with Site conditions.
The detailed results of the risk assessment show that in almost every
case, the noncarcinogenic risk is due to exposure to arsenic. There were
.limlced instances where the quotient of CD! and.RiD exceeded 1.0 for
contaminants other than arsenic. These cases are:
.'"
Current.use nearby child resident, ingestion of water
to hexavalent chromium and vanadium result in CDIfRfD
.1..06 and 2.18, respectively; ..
--. exposure
equal to
Future-use on-site child resident,
exposure to hexavalent chromium at
CDI/RfD equal to 3.30.
ingestion of soil -- RME
treatment building. results in
In all ingestion pathways, the
arsenic.
eXGess
c~ncer. risk is d~e entirely to
Ecological Assessment
The baseline risk assessment also included an 'environmental assessment
to identify potential impacts. to. non-human receptors exposed to chemicais of
concern. This assessment included identification potential receptors,
determination of exposure pathways and exposure point concentrations,
assessment of the environmental toxicity of chemicals of concern, and.
assessment of impacts to environmental populations.
The potential risks to aquatic life were assessed by comparing
concentrations of chemicals of concern in groundwater and surface water. with
lowest observed effect levels (LOELs) for aquatic organisms. Groundwater
concentrations were considered because of the potential .for discharge of
contaminated groundwater to surface water bodies. None of the observed
surface water concentrations exceeded LOELs. Observed levels of total
arsenic, chromium, copper, lead, and zinc in groundwater were above LOELs.
This situation indicates a future potential risk associated with discharge of
contaminated groundwater.
The potential risks to vegetation, mammals, and birds wer~ assessed
qualitatively because of the limited toxicity data available. The assessment
identified potential phytotoxic effects to vegetation due to high
concentrations of chemicals of concern in soils. Wildlife may be exposed to
contaminated soil, vegetation, or water at the Site, though this exposure was
expected to be intermittent.
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Exposure Assessment Uncertainties
Uncertainties in the exposure assessment can arise from use of sampling
and analysis data, from assumptions concerning exposure scenarios, and from
use of fate and transport modeling. Uncertainty from the use of soil sampling
and analysis data depends on how well the samples collected characterize the
Site. Most of the samples were collected in areas that information from the
SI and the history of Site operations indicated were contaminated. These
areas represent a relatively small portion of the total Site area. The
remainder of the Site is represented by a small number of background samples.
Use of background samples in this way could potentially underestimate risk if
there other areas of contamination not previously identified. However, based
on the extensive sampling during the sr, the results of the SI and RI, field
observations and information about the history of Site operations, it is
unlikely that such areas exist.
Uncertainty from the use of groundwater sampling and analysis data
results from the use of total rather than dissolved concentrations. As
discussed previously, most of the metals present in groundwater appear to be
associated with particulate matter in the groundwater samples. If groundwater
samples had a higher turbidity than would be used as drinking water, the risks
from groundwater ingestion may be overestimated.
For the exposure pathways considered, there are uncertainties ,in the
number and length of times individuals would come into contact with the
contaminants. Two exposure cases were generally considered, the average and
the reasonable maximt~. The reasonable maximum exposure asst~ptions are
intended to place a reasonable upperbound on the. estimate of potential risks.
Upperbound risks are unlikely to underestimate and very. probably overestimate
the actual risks.
A fate and transport mode.l was used to estimate concentrations of.
chemicals of concern in airborne dusts at the Site. This approach was taken
because there were no ~ata on measured concentrations of airborne
contaminants. In applying the model, conservative assumptions were made
concerning the parameters used in the model. These conservative assumptions
likely overestimate the exposure point concentrations in windblown dusts,
which in turn, may overestimate the risk associated with inhalation of
windblown dusts.
Toxicitv Assessment Uncertainties
Uncertainties in the toxicity assessment can arise from use of results
of animal studies, identification of chemical species, and evaluation of
mixtures of chemicals. Use of animal study data involves application of
conservative assumptions in establishing values for RfDs and cancer potency
factors. This approach is likely to err on the side of overestimating rather
than underestimating health risks.
In identifying chemical species for collection of toxicity data, it was
assumed that all chromium at the Site exists in the form of hexavalent
chromium. There are different toxicities with different chromium species and
hexavalent chromium is the most toxic form. Because it is unlikely that all
of the chromium at the Site is hexavalent, this approach is likely to
overestimate risks.
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There is uncertainty in assessing the toxicity of mixtures of chemicals.
There were no data characterizing the effects of chemical mixtures similar to
those found at the JFP Site. As a result, the chemicals at the Site were
assumed to act additively and potential health. risks .were calculated by
summing excess cancer risks and hazard ra.tios for individual 'chemicals.
Risk Characterization Uncertainties
Uncertainties in risk characterization result in compounding individual
uncertainties from the exposure assessment and toxicity assessment. For
example, if a CDI for a contaminant is combined with a cancer potency factor
to determine potential health risks, the uncertainties on the concentration
measurements, exposure assumptions, and the toxicities will all be expressed
in the result.
Conclusions for Human Healch Risk Assessment
The human health risk assessment indicates a potential risk of exposure
by ingestion of soil and groundwater under current and future use scenarios.
The greatest potential risk at the Site is due to.carcinogenic and
noncarcinogenic effects from ingestion of contaminated soils. Site workers.
and future Site resi~ents are at risk. Arsenic'is the contaminant' posing the;
greatest health risk. . .
.An additional potential risk posed by the Site is carcinogenic and
noncarcinogenic effects from ingestion of contaminated groundwater. Current
off-site residents a.nd future on-site residents a::e a.t risk. Arsenic is ::he
contaminant posing the greatest potential health risk.
Although not quantitatively addressed in the risk assessment, surface:
contamination on equipment and structures may also pose a risk from the.
ingestion pathway. In addition, the RI identified several other areas at. the
Site where cleanup activities should be implemented. These activities are:
.
Removal of asbestos-containing material (ACM) from the former
lumber drying building; and
.
Decommissioning of two abandoned underground storage tanks (USTs).
Actual or threatened releases of hazardous substances from this Site, if
not addres~ed by implementing the response action selected in this ROD,may
present an imminent and substantial endangerment to public health, welfare, or
the environment.
VII.
DESCRIPTION OF ALTERNATIVES
Remedial Action Ob;ectives and Goals
Remedial action objectives (RAGs) which describe in general terms what
any remedial action needs to accomplish in order to be protective of human
health and the environment were established for each contaminated medium at
the Site. They specify the contaminants and environmental media of concern,
the potential exposure pathways to be addressed by remedial actions, .the
exposed populations and environmental receptors to be protected, and
acceptable contaminant concentrations (or concentration ranges) in each
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contaminated medium. The acceptable exposure concentrations are known as
remediation goals. Remedial action objectives and remediation goals are
described in the NCP, 40 C.F.R. 300.430(e)(2)(i).
Remediation goals are a subset of remedial action objectives. They
provide numerical. goals. for remedial actions .to meet. Initially, Preliminary
remediation goals (PRGs) are developed and used as a basis for evaluating.
cleanup alternatives. Final remediation goals are determined when the remedy
is selected. PRGs for the JFP Site were established for pathways and
chemicals of concern identified in the baseline risk assessment. PRGs were
compared to existing levels of contamination on the Site to determine the
contaminants to be addressed by the RAGs. The PRGs were also used to identify
specific criteria (e.g., contaminant levelsj to determine when objectives have
been met.
Based on. the pathways and concaminants of conc~rn identified in the
baseline risk assessment, PRGs were developed for soil and groundwater
contaminants considering exposure. via. ingestion. 'PRGs :for. soil. and.
groundwater were developed using the guidance s'pecified in '''EPA Region 10
Supplemental Risk Ass~ssDient .Guidance for Superfund~' (EPA 1991). .
. "
'.
Development of PRGs considered risk-based concentrations, as well ,as
Applicable or Relevant and Appropriate Requi;rements (ARARs).. . Risk .base.d.
.concentrations were developed for target risks of 19-6 and 10-4 fOJ;:'carcinpgens
and a hazard, quotient of 1.0.for noncarcinogens.Both residential and.
industrial exposure conditions were considered. ' . .
No ARARs were identified for soil cleanup levels.. ARARs for ,groundwacer.
are maximum contaminant levels (MCLs) under the federal Safe .Drinking Water
Act. No ARARs were identified,specifying cleanup.levels for contaminated
surfaces. .
PRGs for groundwater and soil are presented in Tables 10 and 11..
respectively..
The RAGs for groundwater are to prevent ingestipn of arsenic and
chromium in excess of MCLs. These objectives will be met if the
con~entrations of arsenic and chromium are below the. MCLs in all groundwater
at the Site. The remaining. contaminants .of COncern (coppe~, lead, manganese,
vanadium, and zinc) 'are' not addressed in the RAOs based on the r.esults from
the RI. as described below. " . .
All groundwater sampling results for total and dissolved copper and zinc
were present below all PRGs. All results for total and dissolved lead were
below the MCL and only three total lead results, all from the first round of
sampling, were above 15 ugjL. All manganese results were below both risk-
based PRGs. Many total manganese results were above the secondary MCL, while
dissolved manganese results were all below the secondary MCL and generally
below. detection. Total manganese in groundwater appears to be naturally
occurring and unrelated to Site activities. Only two total vanadium results
were present at slightly above the residential risk-based PRG,
The RAOs for soil consider'ingestion as well as protection of
groundwater from migration of soil contaminants. The RAOs for soil ingestion
are to prevent ingestion of chromium and copper in excess of the reference
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dose and to prevent ingestion of a~senic causing an excess cancer risk greater
than 10-4 to 10-6. These objectives will be met if conditions on site are such
that the concentration of arsenic is equal to or less than the risk-based
PRGs.
The RAOs for chromium and copper in soil will be met through cleanup to
meet the risk-based PRGs for arsenic. This approach will be effective because
soil samples collected following the removal action indicated that residential
risk-based PRGs for chromium (VI) and copper were only exceeded beneath the
treatment building. These samples also had the highest levels of arsenic.
The remaining contaminants of concern (lead, manganese, vanadium, and
zinc) are not addressed in the RAOs for soil ingestion based on the results
from the RI. Following the removal action, the results from all but two
sample locations were below the residential risk-based PRGs for lead. All
results for manganese, vanadiwn, and zinc were below risk-based PRGs.
The soil RAOs for groundwater protection are to prevent'migration of
ar~enic and chromium from soil .resulting in groundwater concentrations above.
MCLs. .The results of the .RI indicate that migration of contaminants to
. groundwa~er is not presently of concern because. arsenic and chromium are below'o
'MCLs. As with the groundwater .objectives,. the. soil RAOs for groundwater
protection will be met if the concentrations of arsenic and chromium are below
,the'MCLs in all groundwater at the Site. .
The RAOs for contaminated structures and equipment are to prevent
ingest.ion of chr.omium and copper in excess of the reference dose and to
prevent ingestion of arsenic causing an excess cancer risk greater tha.n 10-4
to 10-6 o' These obj ectives will be met if surfaces are decontaminated. so 'that
contaminants are. no longer extractable.
RAOs were also identified for the asbestos material and underground
storage tanks identified at the Site. These RAOs are to remove all ACM from
the abandoned drying building and to abandon the USTs in compliance with
Oregon DEQ regulations for petroleum UST abandonment.
Preliminary alternatives were developed and evaluated against the RAOs
and PRGs. Alternatives that met the RAOs and PRGs were then considered for
detailed analysis. A summary of the alternatives developed and evaluated are
described below. A summary of the actions under each. alternative is shown in
TabLe 12. .'
Alternative 1 - No Action
Alternative 1 in the FS is the No Action Alternative. Under this
alternative, no action would be taken to remove or treat any contamination at
the Site. The alternative would include groundwater monitoring and
maintenance of existing security fencing. Monitoring would include biannual
monitoring of groundwater at and near the Site using the existing network of
monitoring wells. In addition, samples would be collected from the spring on
the JFP Site and from the two City of Enterprise springs. The wells and
springs would be sampled on a biannual basis and samples analyzed for total
and dissolved metals. Monitoring would a1so include inspection of the Site to
verify that there has been no contact with contaminated soils or structures
and that the existing access control fences are in good repair. These
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inspections would be performed biannually in conjunction with the water
sampling: If necessary, repairs to the fences would be made.
Operation and maintenance (O&M) activities for this alternative would
include biannual sampling and analysis of groundwater and the City water
supply Springs and inspection of the Site for a minimum of 2 years.
The cost of the no-action.alternative consists of the costs associated
with continued biannual groundwater monitoring and inspections. There is no
capital cost associated with these activities. The estimated cost for two
sampling events per year, including collection of samples, analysis for total
and dissolved metals, validation, and reporting is $24,000.
Action Alternatives - Common Elements
All of t:he action alternatives, alt:ernatives 2 through 6, have contlIlOIl
elements. These include demolition of the treatment building, excavation of
contaminated soil and debris, removal of asbestos and underground tanks, and
decontamination of process equipment. Operation and. maintenance (0 & M)would
include biannual monitoring of the existing wells and the City springs for a
minimum of 2 years and up to 5 years, except for Alternative3.whichwould
include biannual monitoring for a m~nimurn of 5 years.
A summary of the area and volumes of soil to be excavated for the
different alternatives is shown on Table 13.
L\lternative 2. - Cleanu~o -Backgrol..'l..nd \\Tith Off-Site Disposal of All Soils and
Debris
Alternative 2 consists of demolishing the treatment building and drip
pad, excavating all surface and subsurface soil contaminated above background
for all chemicals of concern, transporting all soil and debris off~site to a
disposal facility, removing ACM from the wood drying building, and removing
the two inactive USTs.
The major portion of this alternative consists of demolishing the
treatment building and drip pad and excavating soils frombeneath.the.building
and pad. Large equipment within the building, including the retort vessel and
steel tanks, would be dismantled and removed from the building. If necessary
for access by lifting equipment, . the roof of the building would be removed.
The wooden structure would then be razed and the wooden debris collected (ie,
into 20- or 3D-cubic yard roll-off boxes). Next, the concrete. floor and drip
pad would be demolished and the concrete debris eollected for transport off
the Site. With the floor and pad removed, contaminated soil would then be
excavated and placed in dump trucks for off-site transport. As soils are
excavated, samples would be collected from the excavation pit and analyzed
using field screening techniques to determine whether the cleanup level had
been reached and whether soils exceed hazardous waste designation levels.
Excavated soils would be stockpiled on site. Confirmation samples would be
collected for laboratory analysis to verify that cleanup goals had been met.
After receipt of confirmation sample data, the excavation would then be
backfilled with clean soil. Once all contaminated soils and debris had been
disposed, equipment used to demolish the building and excavate and move the
50i1 would be decontaminated.
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Soils exceeding hazardous waste levels would be segregated from those
which do not. Hazardous waste would be transported to a RCRA permitted ..
disposal facility for disposal. Hazardous waste would be treated by
solidification, if required to meet. requirements for land disposal, prior to
disposal in a RCRA landfill. Contaminated soil or debris which is not
classified as hazardous waste may be disposed in a permitted solid waste
disposal facility
This alternative also involves removal of ACM from the abandoned wood
drying building. ACM removal would involve wetting the ACM fabric with a
water-surfactant mix, removing it from the walls, and placing it into sealable
plastic bags. After all materials had been removed, the wall surfaces would
be vacuumed. Asbestos~colltaining wastes would be disposed of off-site in a
trench meeting regulatory requirements for asbestos waste disposal.
This alternative a1so includes removal of the two abandoned USTs. Tank
removal activities would include excavation of soil from around the tanks,
removal of the tanks from the ground, . decontamination of the tanks. if any
residuals are present, . and transport o.f the tanks off-site for disposal or.
salvage as scrap metal. Soil samples would be. collected from beneath the
tanks and analyzed for total petroleum. hydrocarbons. as requ'ired by DEQ tank
closure regulations. If soil contamination is discovered, cont.aminated soil...
would be excavated and disposed of off-site. The excavation would be. .
backfilled with clean soil. DEQ soil cl~anupstandards for petroleum would be
used to define the extent of soil requiring cleanup.
C&M activities for this alternative would be limited to periodic
grO\mdvlater monitoring. Existing wells and springs would be. sampled
biannually and samples analyzed for total and dis.solved metals: Moni.toring
would continue for a minimum of two years and may be continued up to five
years if determined to be necessary based on evaluation of the results.
The total estimated capital cost
estimated O&M costs for monitoring are
would take 3 to 6 months to complete.
of this alternative is $1.,540,000.' The..
$24,000 per year. This alternative
Alternative 3 - Cleanup to Background With Treatment and On-Site Disposal of
Soils and Debris
Alternative 3 is very similar to Alternative 2 except that soils would
be treated and disposed of on-site and the concrete and .steel surfaces of the
treatment building and drip pad would be decontaminated by gritblasting or
similar method before demolition. Contaminated .grit would be collected for
off-site disposal as hazardous waste. After decontamination, the structures
would be demolished as described for Alternative 2. Decontaminated steel
would be sent off-site for reuse or recycling. Decontaminated concrete debris
would be disposed of on-site. Because wood cannot be easily decontaminated,
wood debris would be sent off-site for disposal.
The technique employed to treat excavated/stockpiled soils would involve
use of a mobile treatment unit. The specific treatment process would
stabilize the chemicals of concern arsenic, chromium, and copper. Before this
alternative could be implemented, additional testing would be required. The
treatment process would have to treat arsenic, chromium, and copper so that
the treated soil posed no more risk than background soils. Treated soil would
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be used to backfill excavations to within one foot of grade. One foot of
clean topsoil would then be placed over the treated soil. A trench would 'be
excavated on-site to dispose of excess treated soil as well as the
decontaminated debris. Excess excavation spoils would be taken off-site for
use or spread on-site.
The removal of ACM from the abandoned wood drying building and removal
of the inactive USTs would be performed as described for Alternative 2.
This alternative also includes the use of institutional controls such as
deed restrictions, or use of an environmental notice to ensure appropriate
consideration of Site conditions in future land use decisions. The use of
such measures will be dependent on the conditions at the site at the
completion of the cleanup. Environmental notice would provide potential
.purchasers with notification of the types of uses that would be consistent
with the level of cleariup achieved..
O&M activities .for this alternative. would be limited to periodic .
groundwater monitoring and inspection of. the on-site disposal areas. Existing
wells and springs ,would be samp~ed bianpually.and samples analyzed for. total .
and dissolved. metals. In addition, new wells would be ins.talled as .necessary .
to monitor'migration from the disposal areas.. Disposal areas would be . .
inspected to determine if cover soil was in place and would be repair~d as
necessary. .
The total estimated capital cost of this alternative is $1,.890,000, The
estirr.a.ted 0&.11 costs for monitoring and inspection a.re $24,000 per year, This
alternative would takeapproximCitely 18 month~ .to implement,incll.lding time .'
required for treatability studies . Groundwater monitoring .would be: cond'.lcte.d
for a minimum of 5 years. . .
Alternative 4 - .Surface Soil. Cleanup to Residential PRG With Off-Site. Disposal
of All Soils and Debris
Alternative 4 is identical to Alternative 2 except for the cleanup
levels used and the handling of the drip pad. For Alternative 4, .all surface
soils, including the perimeter of the drip pad and the storage areas, would.be
excavated until' arsenic levels meet the 10-5 industrial PRG of 36 mg/kg .
(approximately equal to 10-4 residential PRG). .Subsurface soil (Le. , deeper
than three feet) would be cleaned to meet the. arsenic 10~4 industrial PRG of
336 mg/kg. Contaminated soil under the drip pad meets the 10-4 industrial PRG
and therefore would remain in place. A more stringent cleanup level would be.
applied to surface soil because this is where the greatest potential for human
contact exists. This cleanup strategy would allow industrial reuse of the
treatment building area and residential use of the remainder of the Site.
As with Alternative 2, this alternative consists of demolishing tne
treatment building, tran~porting all soil and debris off-site to a disposal
facility, removing ACM from the wood drying building, and removing the two
inactive USTs.
An important difference to note between Alternative 4 and Alternative 2
. is that the drip pad would not be demolished. Instead, the exterior surfaces
of the drip pad would be decontaminated by gritblasting or similar method.
Treatment equipment would be decontaminated as described for Alternative 3 to
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allow recycling of metal. '
Use of institutional controls or environmental notice would be as
described for Alternative 3. O&M activities for this alternative would be as
described in'Alternative 2. .
The total estimated capital cost of this alternative is $550,000. The
estimated O&M costs for monitoring and inspection are $24,000 per year. It is
estimated that this alternative could be completed within 3 to 6 months.
Groundwater monitoring would be conducted for a minimum"of 2 years and up to 5
years.
Alternative 5 - Surface Soil Cleanup to Residential PRG with Treatment and On-
Site Disposal of Soils and Debris
Alternative .5 is similar to Alternative 3 except, that a soil washing
'treatment technology would be used to treat excavated soils, and.the soil
cleanup levels and handling of the drip 'pad would be as described'iri' .
Alternative 4. The soil washing treatment proces~ would generate contaminated
,residuals that would be disposed off-site at a RCRA permitted disposal'
facility. .
Befo're this alternative' could
be required ~o ~~tablish the proper
soil washing.
be implemented, additional .testing would
tr~atment chemicals and conditions for
. .
ACM from the abandoned wood drying building and rC~Gval of the inactive
USTs would be performed a.s described for Alternative 2, Use of institutional
controls or environmental notice would be as described for .P.lternathre "3. .
O&M activities for thisalternative.would be similar to those for"
Alternatives 4 and 5 and would involve periodic groundwater monitoring 'and
inspection 'of the on-site disposal areas, As with Alternative 3,' new wells.
would be installed as necessary to monitor migration from the disposal areas.
The
estimated
estimated
including
conducted
total estimated capital cost of this alternative .is $1,470',00'0. The'
O&M cos ts for monitoring and inspection are $24,000 per year'..I t is
that.this alternative would take up to 18 months to implement,
time for treatability studies. Groundwater monitoring would be
for a minimum of 2 years and up to 5 years;
Alternative ,6 - Cleanup to. Industrial PRG With Off-Site Disposal of All Soils
and Debris
Alternative 6 is similar to Alternative 4 except tha't both the surface
soils and the subsurface soils would be remediated to the 336 mg/kg industrial
cleanup level. The only identified area of soil 4bove the industrial PRG is
the soil beneath the treatment building. The soil and demolition debris would
be disposed of' off-Site, as described for Alternative 2. Because the soil.
beneath' the drip pad is not contaminated above the industrial PRG, the drip
pad would not be demolished. Instead, the surface of the drip pad would be
decontaminated, as described for Alternatives 4 and 5 and the drip pad left in
place. Treatment equipment would be decontaminated for recycling, as
described for Alternatives 4 and 5,
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AsbestQs and UST removal would be as described for the other
alternatives. Use of ~nstitutional controls or environmental notice would be
as described for Alternative 3.
O&M activities for this alternative would be limited to. biannual
monitoring of existing wells and springs.
The
estimated
estimated
total estimated capital cost of this alternative is $210,000. The
O&M costs for monitoring and inspection are $24,000 per year. It is
that this alternative could be completed in less than six months.
Summary of Comparative Analvsis of Alternatives
Based on a screening with respect to effectiveness, implementability,
and cost, all alternatives except Alternative 3 were selected for detailed
analysis. Alternative. 3 was considered less effective than the other on-site
treatment alternative; Alternative 5, and there are Agency and community
concerns about leaving solidified contaminated material on-site that would be
subject to freeze/thaw cycles and would be located in a.watershed protection'
area.
The detailed comparative analysis of the five remaining alternatives
with respe'ct to the nine. criteria specified in the NCP is described below..
These criteria are presented in three categories,. thresh,old criteria, . primary
balancing criteria, and modifying criteria. .
A.
Threshold Criteria
The remedial alternatives were first evaluated inrelation to the
threshold criteria: overall protection of human health and the environment..
and compliance with ARARs. The. threshold criteria ar,estatutory.requirements
and must be met by all alternatives that remain for final consideratiopa$.
remedies for the Site.
1. Overall Protection of Human Health and the Environmen~. . This
criteria addresses whether or not a remedial alternative provides. adequate
protection and describes how risks are eliminated, reduced, or controlled
through treatment and engineering or institutional controls.
Alternative 1, the no action alternative, provides no protection beyond
the existing baseline and is not considered protective of human health and the
environment. The no action alternative is not carried forward for further
evaluation.
All the action alternatives, Alternatives 2 through 6, would provide
acceptable protection of human health and the environment. As designed, each
alternative would generally provide protection by removing all contamination
above cleanup levels from the Site. Cleanup levels were established for all
action alternatives so as to be within EPA acceptable risk range of 10-4 to
10-6.' With Alternative 2, all materials contaminated above cleanup levels.
would be disposed of off-site at permitted/approved disposal facilities. With
the remaining action alternatives, all materials except the drip pad would. be
disposed off-site. Under these alternatives, the drip pad would be
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decontaminated and remain on site. All the action alternatives provide for
immediate protection by removing potential sources of contamination from the
Site. All four action alternatives should be effective in meeting cleanup
levels; the cleanup levels used for each of the alternatives are different,
however. The effectiveness of Alternative 5 is less certain than Alternatives
2, 4, and 6 because it includes unproven treatment technology.'
2. Compliance with ARARs. This criteria addresses whether or not a
remedial alternative will meet all ARARs or provide grounds for invoking a
waiver. See Section X of this ROD for a discussion of specific ARARs
considered in this analysis.
It is currently expected that all four action alternatives would be
equally effective in complying with ARARs. The alternatives have various
action-specific ARARs related to hazardous waste generation, transportation,
treatment, and disposal; asbestos removal and disposal; and DST removal. It
is expected that these ARARs would be met, though several specific.
requirements are presently uncertain. It is not known whether action~specific
ARARs would apply to gritblasting and soil washing as hazardous waste' .
treatment. It is expected that these ARARs would address preventing'
contaminant releases and could be met through proper design and operation of
treatment processes. ..
B.
Primary Balancing Criteria
Once an alternative satisfies the threshold criteria, five primary
balancing CLi teria are used to evaluate the techni'caland engineering aspects
of the remedial alternatives.
3. Long-Term Effectiveness and Permanence. This criteria refers t~ 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 2, 4, and 6 would be very similar in meeting the criterion
for long-term effectiveness and permanence. These alternatives include.
removal and off-site disposal of contaminants present. above .cleanup levels.
The alternatives, however, result in different residual on-site risks because
different cleanup levels are used.. Alternative 2 results in the lowestiisk,
followed by Alternative 4, then Alternative 6. The e'ffectiveness of
Alternative 5 depends more on controls than the effectiveness of the other
alternatives. Alternative 5 involves on-site disposal and relies .on the use
of treatment technologies to separate contaminants for off-site disposal.
Because of less reliance on controls, Alternatives 2 and 4 are rated highest
in meeting this criterion, followed by Alternative 6, then Alternative 5.
Off-site risk would be controlled through the methods of disposal used
for contaminated residuals. Alternatives 2,4, and 6 would use the same
methods of disposal and would result in similar off-site risks. The volumes
of materials disposed off-site would vary with the alternatives, but all would
result in off-site disposal of the most highly contaminated material.
4.
Reduction of Toxicity, Mobility, or Volume.
This criteria refers to
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the anticipated performance of treatment technologies which will be used in
the various remedial alternatives, such as solidification and incineration,
etc.
, Alternat~ve S provides the greatest reduction of toxicity, mobility, and
volume through treatment. This alternative employs the use of soil washing to
reduce the volume of contaminated' material that must be disposed of off-site.
Alternatives 4 and 6 are rated equal with respect to this criterion because
both use they do not use treatment other than off~site treatment of hazardous
residuals to meet Land Disposal Restrictions (LDR) treatment standards (if
necessary) under the Resource Conservation and Recovery Act (RCRA).
5. 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 6 would result in the least threat to, the community and
workers duringi~plementation because it would .involve' the.'least amount of
c~ntaminated materials handling and treatment. Alternative'4 c~rries a .
.slightly greater shc;>rt-term risk because of the increased volumes of soil..
Alternative.S'would.inyolve even greater risk to workers because of the
potential. fQr contaminant release.s during soilwa.shingand concrete
gritblasting. Alternative 2 does not. include soil washing orgritblasting,'
but does', involve handling the gre~test volume of material' and highest risks
associated with transport ,of the contaminated soil to aneff-site disposal'
facility. . ,
6. Im1>lementability.. This criteria refers to the technical and
administrative feasibility. Of a remedial alternative, includ:lng the',
availability of go,ods .and services needed to implement the selected remedy.
Alternatives 4 and 6 are the most implementable of the action
alternatives because they involve standard construction techniques which were
already used during the removal action (with the exception of the drip pad and
. equipment decontamination). Alternative 2 involves standard construc,tion .
techniques; however, it is less implementable because it involves cleanup to
background levels,.which will be difficult to achieve because of the levels
which exist naturally on site. Alternative 5 is the least implementable
alternative because. of the use of soil washing, an unproven treatment
technology requiring performance of treatability tests. Alternatives 2, 4, S,
and 6 would share similar implementability concerns with respect to off-site
disposal of residuals.
7. Cost. This criteria refers to the cost of implementing a remedial
alternative, including operation and maintenance costs.
All of the alternatives have the same O&M costs. For the off-site
disposal alternatives, costs decrease with increasing cleanup levels.
Alternative 6 has the lowest cost, followed by Alternative 4 and Alternative
2. Alternative 5, the on-site treatment and disposal alternative, has a much
higher capital cost than Alternative 4, the off-site disposal alternative for
the same cleanup level.
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c.
Modifying 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 whether the state agrees
with the preferred remedial alternative.
DEQ concurred with the selection of the preferred remedial alternative
as presented in the proposed plan. DEQ has been involved with the development
and review of the RIfFS, the Proposed Plan, and this ROD.
9. Community Acceptance.
a given remedial alternative.
This criteria refers to the public support of
No written comments were received during the public comment period on
the Proposed Plan. Prior to the removal action conducted last fall, the City
of Enterprise submitted a letter to EPA that supported off-site disposal of '
contaminated material from the JFP Site. Off-site disposal is included'in the
selected remedy. ' ' '
IX.
THE SEL~CTED REMEDY
The selected remedy as described in Alternative 4 is excavation and off~
si te treatment (if' necessary) and dispo'sal of soils, decontamination of
debris, and off-site dizposal of debris. The selected remedy also includes
inscitutional controls for conta..ninants remaining on site and monitoring 'of
on-site groundwater to ensure that concentrations remain below health based
levels of concern. '
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 soils to prevent
groundwater contamination. Promulgated state rules and regulations which are
more stringent than federal requirements are included as ARARs.
Maior Components of the Selected Remedy
The selected remedy involves excavation of contaminated surface and
subsurface soils to meet risk-based cleanup levels, demolition of: the
treatment building, decontamination of the drip pad and treatment equipment,
and off-site disposal of soils and decontaminated debris. This alternative
also includes UST removal, asbestos removal, and groundwater monitoring:
The first major activity in implementation of the alternative shall be
demolition of the contaminated structures. The contaminated process
equipment, including the retort, storage and mixing tanks, and pumps shall be
removed from the treatment building. If necessary, the retort and tanks shall
be cut into small sections with a cutting torch. The wooden structure shall
then be razed, and wooden debris shall be collected into roll-off boxes for
off-site transport. Next, the concrete floor shall be demolished and concrete
debris shall be stockpiled for off-site transport in dump trucks.
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The concrete drip pad shall be decontaminated to prevent exposure via
direct contact. The steel treatment equipment, including the retort and
tanks, shall be decontaminated by pressure washing, gritblasting, or an
equ~valent method. Decontamination metal shall be recycled, if possible, or
disposed off site.
Contaminated soil shall be excavated and placed in dump trucks for off-
site transport. As soils are excavated, samples shall be collected for field
screening and laboratory verification analysis to determine whether the
cleanup level had been reached and whether soils exceed hazardous waste
designation levels. Soils exceeding hazardous waste levels shall be
segregated from those which do not. After receipt of verification sample
data, the excavation shall then be backfilled to grade witll clean soil hauled
in from off-site. Hazardous waste shall be transported to a RCRA permitted
disposal facility for disposal. Hazardous waste shall be treated by
solidification, if req~ired to meet requirements for land disposal, prior to
disposal.in a RCRA landfill. C~ntaminated soil or debris which is not
classified as hazardous waste may be disposed in a permitted solid waste
disposal facility.
ACM shall be removed from the abandoned wood drying building. ACM
removal will .involve wetting the ACM fabric with a water-surfactant mix,
removing it from the walls, and placing it into sealable plastic. bags. .After
all materials had been removed, the wall surfaces shall be vacuumed.
Asbestos-containing wastes would be disposed of off-site ina.trench meeting
federal Clean Air Act requirements for asbestos waste disposal. .
This alternative also includes removal of the two abandoned USTs,. Tank
removal activities shall include excavation of soil from around the tanks,
removal of the tanks from the ground, decontamination of the tanks if any
residuals are present, and transport of the tanks off-site for disposal or
salvage. as scrap metal. Soil samples shall be collected from beneath th~
tanks and analyzed for total petroleum hydrocarbons (TPH) as required by DEQ
tank closure regulations. If soil contamination is discovered, contaminated
soil shall be excavated and disposed of off-site. Soil shall be removed to
meet DEQ soil matrix cleanup levels for TPH. The excavation. shall be.
backfilled tq grade with clean soil.'
During all demolition and excavation activities, air monitoring shall.be
performed 'to verify that dust generation i~ below acceptable levels as
specified in the health and safety plan for the remedial action. If dust
generation becomes a probLem, mitigative measures specified .in the health and.
safety plan.shall be implemented,
All demolition, excavation, and waste handling equipment shall be
decontaminated before leaving the Site. Decontamination wastes shall be
collected for analysis and appropriate disposal.
O&M activities for this alternative shall be limited to periodic
groundwater monitoring. The existing monitoring network of wells and springs
shall be sampled biannually for a period of two years following completion of
the remedial action, Samples shall be analyzed for total and dissolved
metals. After two years, monitoring results shall be evaluated to determine
whether monitoring shall be continued. .
-------
Final Remediation Goals
Final remediation goals were selected based on the PRGs previously
. described and the results of the alternatives analysis. Table 14 shows the
final remediation goals for the JFP Site. All surface soils'shall be
excavated to depth until arsenic ~oncentrations meet the 10-5 remed~ation goal
of 36 mg/kg for industrial use. Soils beneath ,the treatment building shall be
shall to excavated to meet the 10-4 remediation goal of 336 mg/kg for '
industrial use. EPA has selected the more stringent cleanup level for surface
soil because this is where the greatest potential for human contact exists and
it will also allow residential use. Because the 10-5 industrial remediation
goal for surface soils is app~oximately equal to the 10-4 residential cleanup
level, this strategy will allow residential use of all portions of the site
except the treatment building area. Based on the results ~rom the removal
action, cleanup or soil to the selected arsenic cleanup levels will also
achi~ve chromiwn and copper cleanuv levels of 1,351 mg/kg and 10,000 mg/kg, ,
respectively, associated with hazard index of 1. The selected remedy should
meet the final remediation goals.
The State of Oregon cleanup standard is to clean up to background levels',
if possible, or if not, to a level that is protective of human health and the
environment. Background arsenic'levels near the JFP site were 'measured in'the
range of 4 to ,II mg/kg. EPA's cleanup goal of 36 mg/kg' for ,surface soil will
be close to, but slightly higher than, measured background levels. It is
EPA's'judgment that the marginal increase in protection provided by'cleantng
up to background 'levels does not justify the additional remediation effort and
cost~.
Groundwater monitoring results, will be used to verify that arsenic and
chromium levels remain below the MCL.
x.
STATUTORY DETERMINATION
The procedures and standards fer 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
NCP, 40 C.F.R. 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, 42 U.S.C.,9621,establishes several other statutory
requirements and preferences, including: a requirement that EPA's remedial
action, when complete, 'must comply with' applicable or relevant and, appropriate
environmental standards established under federal laws and promulgated state
laws, unless a statutory waiver is invoked; 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 statutory requirements and
preferences.
-------
The selected remedy meets statutory requirements of CERCLA. as amended
by SARA, and to the maximum extent practicable, the NCP. 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
. cou.ld imTolve short-term exposure through inhalation'of contaminated 'soil'
particles by Site workers and nearby residents and dermal contact with
.contaminated soils by S~te workers. .These exposures can be eliminated through.
the us~ of air monitoring and.properdust control measures during remedial
acti,vities. and by implementing astrict site-specific health .and safety plan. : .
Short:-term .risksassociatedwith transportation of contaminated material shall
be. controlled by.using liners'and covers, decontaminating trucks before they
leave the Site i . and'complian~e with. Department of Transpottat.ion r~quirements. .
. Institutional controls and/or environmental notice will also assist in
controlling land uses.
B.
Camp 1. i ance wi th AR!>.Rs
The selected
is being so~ght.or
and regulations of
remedy will comply with all ARARs. . No waiver .of any ARAR .
invoked for any component of the selected remedy." The laws
concern include but are not limited to the.following:'
Chemical-Specific ARARs
Chemical-specific' requirements are usually health-or risk-based
numerical values or methodologies that establis~ the acceptable amount or
concentration of a chemical in the ambient environment. The following are the
chemical specific requirements for the Site.
Safe Drinking Water Act (SDWA) (42 U.S.C. 300(f» (40 C.F.R. 141-147)
establishes the development of national primary drinking water
regulations. The regulations provide maximum contaminant level
standards which drinking water quality cannot exceed. (Relevant and
Appropriate).
The MCLs for the contaminants of concern at the Site include:
Contaminant
MCL. mg/1
Arsenic
Chromium
0.05 mg/1
0.1 mg/l
-------
OAR 340-122-040 -080, and -090 requirements provide a process for
determining required cleanup levels and measures for remedial action.
(To Be Considered).
Location specific ARARs
No location-specific ARARs affect the remedial action to be implemented
a t. the Site.
Action-Specific ARARs.
Action-specific ARARs are technology-or activity-based requirements or
limitations on actions affE:cting hazardous substances. ThE:se requirements are
triggered by the particular remedial activities selected to cleanup the Site.
A)
Excavation of C9ntaminated Soil and Debris
Resource Conservation and Recovery Act (RCRA) requirements for the
generation and transport of hazardous waste. RCRA requirements for
hazardous waste generation and transportation are contained in 40 C.F.R.
262 and 263, respectively. Additional requirements .for generation of .
hazardous wastes subject to LDR are contained in 40 C.F.R, 268.
(Relevant ~nd Appropriate).
Oregon Administrative Rules (OAR) Chapter 340 Divisions 100 to 110 and,
120 regulate hazardous ,V'aste from the time of g€neration through
transportation, storage, treatment and disposal. Divisions 100 to 106
incorporate. by reference, hazardous waste management regulations of the.
federal program, included in 40 C.F.R. Parts.260 to 266,268, 270 and
Subpart A of 124, into Oregon Administrative Rules. (Relevant and
Appropriate).
B)
Removal of Underground Storage Tanks
Oregon Administrative Rules (OAR) sections 340-122-205. through -360~ ..
regulate cleanup of soils contaminated. by petroleum .product leaks from
USTs. These requirements include soil characterization, removal, and
disposal associated with USTremoval. If.determined to be applicable,
soils will be cleaned up to the numeric soil cleanup standards contained
in OAR 340-122-335. (Applicable).
C)
Demolition of Treatment Building and disposal of asbestos containing
materials
National Emissions Standards for Hazardous Air Pollutants (NESHAP)
provisions of the Clean Air Act regulate demolition and renovation of
facilities containing asbestos and disposal of asbestos-contaminated
wastes. Requirements for controlling asbestos emissions during
demolition and renovation are contained in 40 C.F.R. 61.146 and 61.147.
Requirements for disposal of asbestos-containing wastes from demolition
and renovation activities are contained in 40 C.F.R. 61.152.
(Applicable).
-------
D)
Air monitoring
OAR 340-21-050-060 contains requirements for fugitive emissions.
(Applicable).
E)
Groundwater monitoring
DEQ Guidelines for Groundwater Monitoring Well Drilling, Construction,
and Decommissing (August 24, 1992) Section 6.0 contains procedures for
monitoring well decommissioning (To Be Considered).
ro
~
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.
!L
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies 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 '.rolurne, short-term effectiveness;.
implernentability; and cost.. In addition 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 c.onsiderations.
The selected remedy provides a permanent solution with a proven
technology to meet the.LDR 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.
L
Preference for Treatment as a Principal Element
The selected remedy satisfies, 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 which are
classified as hazardous waste and subject to the treatment standards will be
treated as required by the LDR requirements prior to disposal at an approved
RCRA landfill. This remedy employs treatment technologies as required by the
RCRA LDR requirements.
XI.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released for public comment on August
-------
18, 1992. The proposed plan identified Alternative 4 as the preferred
alternative. oNo written comments were received during the public commenL
period. No significant changes to the remedy, as it was originally identified
in the Proposed Plan, have been made in this ROD.
-------
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-------
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FIGURE 2
SITE MAP.
JOSEPH FOREST PRODUCTS
-------
16.3'
CONTAINER
STORAGE
AREA
.-
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(407 GALLONS) I
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(3990 GAlLONS)
CONCRETE FLOOR
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ff X 16"
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RAIL TRACKS
Not to Scale
Figure 3
-------
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-------
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-------
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-------
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FIGURE 7
-------
TABLE 1
SUMMARY OF RESULTS OF METAL ANALYSIS OF BACKGROUND SOIL SAMPLES
DETECTION FREQUENCY RANGE OF GEOMETRIC MEAN
UMfTS OF DETECTIONS CONCENTRATION
ELEMENT mg/kg DETECTION mg/kg mg/kg
I Aluminum NA I 12/12 9,540 - 18,000 13,400
Antimony 3.8 - 4.4 2/12 4.0 - 4.1 4.0
Arsenic NA 12/12 3.7 - 10.6 5.2
Barium NA 12/12 70.0 - 38S .137
Beryllium 0.18 - 0.21 3/12 0.18 - 0.19 . 0.19
Cadmium 0.36 - 0.85 3/12 0.45 - 0.46 . 0.46
Calcium NA 12/12 30,200 - 82,300 56,100
I I . I
I Chromium NA 12/12 9.5 - 22.0 12.7 !
I NA 12f~ 2 I
Cobalt 6.8- 13.5 9.0
Copper NA 12/12 27.8 - 44.3 35.6
Iron NA 12/12 13,300 - 24,600 17,600
Lead NA 12/12 4.3 - 200 10.6
Magnesium NA 12/12 3,790 - 5,240 4,460
Manganese NA 12/12 212 - 1,040. 439
Mercury 0.08 - 0.10 0/12 NA NA
Nickel NA 12/12 12.6 - 19.1 15.5
Potassium NA 12/12 1,520 - 5,450 2,330
--
Selenium 0.35 - 0.80 6/12 0.44 - 1.30 0.59
Silver 1.4 - 1.7 0/12 NA NA
Sodium NA 12/12 478 - 1, 11 0 720
Thallium 0.35 - 0.41 0/12 NA NA
Vanadium NA 12112 30.5 - 68.2 44.6
-------
TABLE 2
SUMMARY OF RESULTS OF METAL ANALYSIS OF TREATMENT BUILDING AND
DRIP PAD PERIMETER SOIL SAMPLES
DETECTION FREQUENCY RANGE OF GEOMETRIC MEAN
UMITS OF DETECTIONS CONCENTRATION
ELEMENT mg/kg DETECTION mg/kg mg/kg
Aluminum NA 90/90 5,&"0 - 21,300 10,100
Antimony 2.2 - 33 35/90 . 2.3 - 59.8 8.4
Arsenic NA 90/90 18 - 26,100 387
Barium NA 90/90 43.9 - 2,670 117
Beryllium 0.10.0.37 24/90 0.10 - 0.35 0.15
Cadmium 0.37 - 1.4 63/90 0.30 - 107 1;7
Calcium NA 90/90 6,720 - 168,000 59,500
Chromium NA 90/90 32.6 -11,300. 376
,--
Cobalt NA 90/00 5.1 - 227 12.3
Copper NA 90/90 41 - 22,200 443
Iron NA 90/90 10,100 - 72, 100 19,700.
Lead NA 90/90 4.7 - 1,880 62.5
Magnesium NA 90/90 2,700 - 9,900 4,370.
Manganese NA 90/90 140 - 7,040 329
Mercury 0.08 . 0.18 12144 0.09 - 0.29 0.15
Molybdenum NA 46/46 0.83 - 12 3.5
Nickel NA 90/90 11.7-232 38.0
Potassium NA 90/90 957 - 14,600 1,700
Selenium 0.59 - 25 19/90 0.67 - 25 1.6
Silver 0.20 - 3.0 1 8/90 0.20-15.9 1.0
Sodium NA 90/90 312 - 1,270 592
Thallium 0.38 - 6.3 1/90 5.0 5.0
Vanadium 3.75 89/90 17 - 85.5 39.0
-------
TABLE 3
SUMMARY OF RESULTS OF METAL ANALYSIS OF SUBSURFACE SOil SAMPLES
DETECTION FREQUENCY RANGE OF GEOMETRIC MEAN.
UMITS OF DETECTIONS CONCENTRATION
ELEMENT mg/kg DETECTION mg/kg mg/kg
Aluminum NA 23/23' 12,600 - 59,000 38,300
Antimony 4.0 6/23 4.0 - 348 61.2
Arsenic NA. 23/Z!. 44 - 104,000 1,630
Barium NA 23/23 161- 719 335
Beryllium 3.6 14/23 9.1 - 25.9 11.8
Cadmium 11.6 - 11.8 0/23 NA NA
Calcium NA 23/23 10,300 - 200,000 87; 100 .
Chromium NA 23/23 300 - 46,100 . 2,040
..'
Cobalt 21.6 0/23 NA NA
I Copper 7.2 17/23 I 262 - 34,400 I 4.230
I
I
i .
iron NA 23/2:3 19,800 - 38.500 27,200
lead 23.6 22123 25.4 - 1,060 280
Magnesium NA 23/23 3,830 - 18,800 12,500
Manganese NA 23/23 350 -1,020 500
Mercury 0.30 1/23 0.64 0.64
Nickel 27.4 - 52.0 0/23 NA NA
- NAI
Selenium 0/23 NA NA
Silver NAI 0/23 NA NA
Sodium 820 22123 1,220 - 11,000 7,260
Thallium .223 - 3,490 0/23 NA NA
Vanadium NA 23/23 54.3 - 148 101
linc NA 23/23 67.6 - 2,100 270
-------
TABLE 4
CONCENTRATIONS OF TOTAL ARSENIC, CHROMIUM, AND COPPER IN SOIL
SAMPLES COLLECTED DURING REMOVAL ACTION'
SAMPlE NUMBER ARSENIC. mg/kg CHROMIUM. mg/kg COPPER, mglkg
T11 00052 437 175. N 42.5
T1100053 223 91.9 N 195
T1100054 496 92.9 N 619
T1100056 22.6 31.0 N 49.7
T1100057 20.1 J 21.4 N 40.8
T1100058 10.1 U 2O.0N 35.1
T1100059 11.1 UJ' 16.5 N 28.1
T1100060 10.5 U 262N 39.0
T1100061 . 40.4 SO.1 N 75.9
T1100062 .10.5 U 33.9N 34.5
T11 ()()C)68 720. J 88.7N 7&4
11.0007:; 657 74.8' I 03.5'
I
T110007< 65S 752 72.7 I
T11ooo75 310 .572 47.8
..
T11ooo76 330 67.3 163
T11 c0017 61.1 27.2 72.9
T11 00078 411 94.6 258
T11 00079 425 89.5 313
T1100081 10.0U 25.4 36.6
T11 00082 26.3 11.2 44.9
T1100083 12.0 20.2 49.3
T110Q08.4 42.0 25.1 63.7
T110008S 101 71.5 S1.5
T1100086 205 155 113
T11 00087 1T7 184 166
T11 00089 131 90.1 155
T1100090 111 85.2 117
T1100091 202 126 90.7
TII 00092 35.3 17.1 31.4
T1100093 360 133 65.3
T1100094 86.9 64.3 R 49.2
-------
CONCENTRA TrONS OF TOTAL ARSENIC, CHROMIUM, AND COPf>ER IN SOIL
.SAMPLES COUECTED DURING REMOVAL ACTION (ConUnu.ed)
SAMPLE NUMBER ARSENIC, mg/kg CHROMIUM, mg/kg COPPER. mcr~g
-
T11 00097 .95." 84.7R 133
T1100098 1 1.0 U 23.3 F. 29.6
T1100099 121 102. R 147
T1100100 11.2 2O.6R 41.4
T1100300 851. J 515. J 888.J
T1100301 31~O 23.8R 50.2
H100302 156 92.6 R 196
T1100308 161 98.5R 202
(Dup. T1 1003(2) =
T1100303 27.4 ~.C~ 4S.9
-i I
I. T1100304
.1
X:2 -J 198. A. 659
T 11 ()('.J305 11.0 21.8 A . 40.8
T1100309 103. J 196. J 116. J
T1100310 2OO.J 193.J 195. J
T1100311 '10.9W 17.9 J 41.1 J
T1 100312 10.9W 23.1J 48.7J
T1100313 124. J 187..J . 51.0 J
TII00314 188.J 2~.J 143. J
T1100315 370. J 297. J 138.J
T1100316 3S9.J 327.J 291. J
T1100317 2OO.J 249.J 72.0J
TII00318 123. J 126. J 93.2J
T1100319 425.J 329. J 307. J
T1100321 698.J 576. J 541.J
(Dup. TI1(0319)
T1100320 ISO. J 154. J 159. J
T1100325 16.50:) 1.860 15.300
T1100326 . 26.200 ~.950 20.700
T1100327 S1.U 57.7 ;:~3
TI1003....'>8 5~.2 J ~.2 ~5.7 J~
-------
TABLE 5
CONCENTRATIONS OF TOTAL METALS IN SOIL
SAMPLES FROM BENEATH DRIP'PAD
ELEMENT, SAMPLE SAMPLE SAMPLE
mg/kg DP1-01-OO DP2-01-OO DP3-01-OO
Aluminum 9,510 ~,120 12,700
Antimony 2.3 UJ 2.0 UJ 2.. 1 UJ
Arsenic ' 341 107 51
Barium 69.8 40.0 B 93.3
Beryllium' 0.23 U 0.20 U 0.21 U
Cadmium 0.79 B 0,94 B 0.68 B
Calcium 79,800 97,200 42, 700
Chromium 284 129 34.6
I I
. Cobalt 6.6 B 7.8 B 12.6----11
-.
Copper 157 I 65.8 6~.4 ~
Iron 14,700 14,500 21,300
lead 5.6 .2.0 4.0
Magnesium 4,740 4,420 5,060
Manganese 239. J 165. J 390. J
Mercury O. 11 UJ 0.10 UJ .0.14 J'
Nickel 13.9 ' 15.5 19.5
Potassium 1,360 1,040 1,630
Selenium 3.5 UJ 3.5 UJ 3.5 UJ
Silver 0.93 U' 0.81 U 0.85 U
Sodium 574.J 655.J 488. J
Thallium 0.46 U 0.42 U 0.44 U
Vanadium 30.3 27.4 48.4
Zinc 67.2J 34.6J 52.2 J
B
Reported value is less than contract required detection limit
but is greater than instrument detection limit.
u
Elemem was analyzed for, but not detected above the level
of the associated value.
J
Anatyte was detected but numerical value may not be consistent
-------
TABLE 6
SUMMARY OF RESULTS OF METAL ANALYSIS OF STORAGE AREA SOIL SAMPLES
DETECTION FREQUENCY RANGE OF GEOMETRIC MEAN
.UMITS OF DETECTIONS CONCENTRATION
ELEMENT mg/kg DETECTION mg/kg mg/kg
Aluminum NA 47/47 6,880 - 13,600 10,400
Antimony 3.7 - 5.0 6/47 3.9 - 5.9 4.7
Arsenic NA 47/47 5.7 - 661 " - 36.6
""
Barium NA 47/47 51.6 - 166 83.5
Beryllium 0.18 - 0.24 10/47 0.18 - 0.28 0.21
Cadmium 0.35 - 0.86 4/47 0.57 - 0.88 0.76
Calcium NA 47/47 17,800 - 207,000 80,000
Chromium "NA 47/47 11,9 - 781 47.3
Cobalt NA 47/47 5.9 ~ 12.9 9.2
I ,
I Copper NA 47/47 3."3.4 - 825 ..~ .
:0..
Iron NA 47/47 12,200 - 41,600 18,400
Lead NA 47/47 3.0 - 204 18.2
Magnesium NA 47/47 3,220 - 6,690 4,760
Manganese NA 47/47 170 - 743 325
Mercury 0.08 - 0.13 9/47 0.08 - 0.14 0.10
Nickel NA 47/47 11.2 - 30.9 16.4
Potassium NA 47/47 1,350 - 2,580 1,830
Selenium 0.35 - 0.75 27/47 0.41 - 4.3 1.1
Silver 1.4 - 1.9 3/47 1.6 - 27.1 4.1
Sodium NA 47/47 347 - 663 517
Thallium 0.35 - 0.49 4/47 0.37 - 0.47 0.42
Vanadium NA 47/47 32.1 - 65.8 46.7
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TABLE 7
SUMMARY OF RESULTS OF TOTAL METALS ANALYSIS OF GROUNDWATER SAMPLES
DETECTION FREQUENCY RANGE OF GEOMETRIC MEAN
UMITS OF DETECTIONS CONCENTRAllON
ELEMENT ug/L DETECllON mg/kg mg/kg
Aluminum 32.0 . 644 38/41 90.8 - 106,000 4,050
Antimony 20.0 - 39:7 0/41 NA NA
Arsenic 1.5 - 3.0 20/41 1.6 - 168 8.0
Barium 10.0 - 13.9 38/41 8.8 - 395 37.1
Beryllium. 1.0 - Z5 7/41 1.2 - 1.8 1.4
Cadmium 2.0 - 5.0 1/41 2.3 2.3
. Calcium NA 41/41 36,300 - 123,000 ' 62,200
Chromium 5.0 26/41 5.0 - 164 . 17.7
Cobalt 2.0 - 40.0 15/41 4.1 - 106 .,21.2,.
I Copper 2.0" 14.2 I 23/41 4.6 - 459 44.4
I
llron . NA 41/41 70.3 - 144,000 3,940 I
Lead 1.0 - 163 24/41 1.1 - 45 4.2
Magnesium NA 41/41 . 2,940 - 45,000 6,350
Manganese NA 41/41 1.7 - 2,800 .77.1
Mercury 0.04 - 0.20 0/41 NA NA'
Molybdenum 2.0 3/16 2.1-2.7. 2.5
Nickel 10.0 - 104 6/41 11:0-,121 25.3
Potassium 604 40j41 i ,090 - 7,680 ,2,300
Selenium 2.0 - 30.0 0/41 NA NA
Silver 2.0 - 4.0 6/41 5.3 - 15.0 7.7
Sodium NA 41/41 1,660 - 14,000 5,900
Thallium 1.0 - 2.5 0/41 NA NA
Vanadium 2.0 . 5.0 31/41 2.5 - 463 25.7
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TABLE 8
CONCENTRATIONS OF DISSOLVED TARGET METALS ABOVE DETECTION
LIMITS IN GROUNDWATER SAMPLES
SAMPLE DISSOLVED DISSOLVED DISSOLVED DISSOLVED DISSOLVED
LOCATION ARSENIC CHROMIUM COPPER LEAD ZINC
AND DATE ug/L ug/L ug/L ug!L ug!L
MW1
July 19BO 32".5 4.2 29.7
Oel 1990 5.8 J
MW2.
July 1990 12.0 S 7.0 B
(Dup.) 10.3 14.4
Oct. 1990 . 14.8
Jan. 1991 11.5
'".....
Sep. 1991 15.2 I
Apr. 1992 6.3 B I
MW3
MW4
Apr. 1992 3.5 B " 4.7 B 2.0 BJ 38.6
MW5
MW6
Oct. 1990 5.9 J
Apr. 1992 1.2 B
MW8
Apr. 1992 1.7 B
JFP Well
July 1990 29.2
B
For samples collected during "July 1990, April 1991, September 1991. and April 1992: Reported
value is less than contract required detection limit but is greater than instrument detection limit.
For samples collected during October 1990 and January 1991: Analyte was detected in analytical
blank as well as in sample.
J
Analyte was detected but numerical value may not be consistent with amount actually present in
the environmental sample.
<:'
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TABLE 9
--
SUMMARY OF RESULTS OF RISK CHARACTERIZATION
01
W
Scenario Exposure Pathway Location Hazard Index ~ Excess Cancer Risk I
Current Use. On.Site Ingestion of Soil Background Areas 0.02. 2x1 O~
Workers -
Storage Areas 0.14 2x10.5
Treatment Building 3.15 6X10-4
Inhalation of Windblown 0.0015 2x10-8
Dust
Current US9 . Nearby Ingestion of Water Average 0.56 Average 1x10-5
Resident, Adult RME 2.51 RME 1x10-4
Current Use. Nearby Ingestion of Water 5.86 6x10.5 .;
I
Resident, Child
Future Use. On-Site Ingestion of Soil Background Areas Average 0.040 Average 1 x 1 O.Q
Resident, Adult RME 0.14 RME 2x1 0.5
Storage Area 1 Average 0.33 Average 2x1 0-5
RME 1.16 RME 2x1 0-4
Storage Area 2 Average 0.14 Average 8x1 O.Q
RME 0.48 RME 9x10-5
Storage Area 3 Average 0.12 Average 6x1 O.Q
RME 0.40 RME 7x1 0-5
Storage .Area 4 Average 0.80 Average' 5x1 0.5
RME 2.77 RME 6x10-4
Treatment Building Average 6.93 Average 4x1 0-4
RME 23'.84 RME 5x1 0-3
Inhalation of Windblown Storage A.rea 1 Average 0.00062 Average 2x1 0.9
Dusts AME 0.00078 AME 1x10~
Storage Aroa 2 Average 0.00007 Average 3x1 0.10
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TABLE 10-
PRELIMINARY REMEDIATION GOALS FOR GROUNDWATER
-
Noncarcinogens.,b (ug/L) C~rclnogensb,C (ug/L)
Hazard Quotient = 1 1 O~risk " 10..( risk Maximum Contaminant
Chemical Residential Industrial Residential IndustliHI Residential Industrial Levels (MCL5) [and goal5
(MCLGs)! (uQ/L)
Arsenic 11 31 0.05 0.16 5 16 . 50 [50 proposed]
Chromium III 36,500 102,200 100 (total Cr) [100]
Chromium VI 183 511 100 (total Cr) [100]
Copper 1351 3781 1300 AL d [1300]
Lead ' NA" NN NA' NA' 50'; 15. AL d [0]
Manganese 3650 10,220 50-secondary MCLo
Vanadium 256 715 \
Zinc 7300 20,440 500a-secondary MCLo
.
, Reference doses for all chemicals of. concern were obtained from EPA's Integrated Risk Information System (IRIS) or Health Effects Assessment Summa/)'
Tables (HEAST). Exposure factors were obtained from EPA Region 10 Supplemental Risk Assessment Guidance for Superfund, dated August 16, 1991.
> Ground\vater PRGs are based on ingestion only, ' , .
, The cancer slope factor for arsenic was obtalr.ed from EPA's Integrated Risk Information System (IRIS), Exposure factors were obtained from EPA Region 10
Supplemental Risk Assessment Guidance for Superfund, dated August 16, 1991, -
. An action level is an MCL that is exceeded if the concentration In more than 10 percent of the targeted tap samples Is greater than the specified value,
I There are no toxicity numbers for lead; however, it is classified as a 82 carcinogen, a probable human carcinogen with sulfide,,! animal data but insufficient
human data,
I The MCL of 50 ugl1 for lead is in effect until December 7, 1992, when the action level of 15 ugll will take its place,
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. '.-----... .-..--......
....---....
".'.'-
TABLE 11.
PRELIMINARY REMEDIATION GOALS FOR SOIL
Nonc~rcinogens.,b (mg/kg) Carcinogensb,e (mg/kg)
Hazard Quotient = 1,0 10.e rl~k 1 O~ risk
Chemical Residential Industrial Residential Industrial Residential Industrial
.,
Arsenicd 81 ' 612 0.4 3 36 336
Chromium III 270,270 2,040,816
Chromium VI 1,351 1 O,2Q4
Copper 10,000 75,510 I .
Lead 500. 1,000. NA' NA' NA' NA'
-
Manganese 27,027 204,082
Vanadium 1916 14,308
Zinc 54,051 408,163
, Reference doses ror all chemicals or concern were obtained from EPA's Integrated Risk Infqrmation System (IRIS) or Health Effects Assessment Summary Tables
(HEAST), Exposure factors were obtained from EPA Region 10 Supplemental Risk Asse$sment Guidance for Superfund, dated Augusl16, 1991.
' Soil PRGs are based on ingestion only. .
( The cancer slope ractor ror arsenic was obtained rrom EPA's Integrated Risk Informa!ion Syslem (IRIS) and Heallh Effects Assessment Summary ,Tables (HEAST)
Exposure ractors were obtained rrom EPA Region 10 Suppl~menlal Risk Assessmenl Guidance for Superfund, daled Augu:;t 16, 1991.
' For comparison, background sample levels or arsenic in soil at the JFP site range from 3.7 to 10,6 mglkg.
I For lead, OSVVER Directive #9355.4.02 was followed, "
, There are no toxicity numbers for lead; however, it is classified as a 82 carcinogen, a probable human carcinogen Yvith sufficient animol data but insufficient humar.
data. . -.---
NOTE: The 10.4 industrial PRG is assoc~ated wi~h an, arsenic
cleanup level of 336 mg/kg. The "industr1al" des1gnat10n means
the estimated risks would ap~ly to a worker assuming ~uture ,
industrial land use. The 10 industri.al,PRG, is assocJ.ated, WJ.th
an arsenic clea~up level of 36 mg/kg, Wh1~h 1S also app~ox~m~tely
equal to the 10. residential level (ass~rnJ.ng f~ture resJ.de~tJ.al
use). The site is currently zoned for J.~dus~rJ.al use and ruture
industrial land use 'i5 expected. The 10 sOll cleanup level for
indu~trial land use is shown in Tbbles 11, 12 andl3 as the
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TABLE 12
SUMMARY OF ACTIONS TO BE TAKEN AT EACH CONTAMINATED AREA
UNDER DIFFERENT ALTERNATIVES
Alternatives
Area 1 2 and 3 4 and 5 6
East of Treatment No action. Soil beneath No action. No action.
Building, Bottom of excavation to
Removal Excavation background"
Drip Pad Perimeter, No action. Soil beneath Soil beneath No action.
Bottom of Removal excavations to excavations to
Excavation background. residential
PRG.
. Drip Pad Perimeter, No action. All soil to All soil to No action.
. Areas not Excavated background. residential
PRG.
I Un:e.r Treatment Fco.---r,;:u soil ~ All SO;I.'O n .-
II
,6':1 soil to I
BUilding . backgroulid. mdus.nal PKG. indus!rial PRG.
Under Drip Pad No action. All soil to No action. No action.
background.
Storage Areas No action. All four areas Areas 1 and 4 No cction.
. to background. to residential
-------
TABLE 13
-. ... ..~. --- ..
SUMMARY OF AREAS AND VOLUMES OF SOIL FOR DIFFERENT ALTERNATIVES
Volume
Scenario and Surface Area, Contaminated Volume Clean
Alternatives Affected Areas sq feet Soil, cu yd Soil, cu yd
. - -
No Action - None 0 0 0
Alterative 1
. Cleanup to Below removal 1517 129 430
Background - excavation, east of
Alternatives 2 and 3 treatment building
Below removal 2315 232 113
excavations, drip
. pad perimeter.
I' Drip pad perimeter I 2560 I 379 I 0 II
I 110t exc-3vated during I
remova!. I
Under treatment 1647 490 0
building
Under c!rip pad 12,950 1440 0
All storage ~reas 75,632 5609 0
Total 96,621 8279. 543
Surface Soil to Below removal 2315 146 .113
Residential PRG, excavations, drip ..'
Subsuriace soil to pad perimeter
Industrial PRG -
Alternatives 4 and 5 Drip pad perimeter 2560 285 0
:101 excavated ~uring
removal
-
Under treatment 1647 387 0
building
Storage areas 1 and 53,370 1978 0
4
Total 59,892 2796 113
Subsurface Soil to Under treatment 1647 369 0
Industrial PRG - building
Alternative 6
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.
TABLE 14
Final Remediation Goals
I Final ] I
Remediation Risk
Goals Levels
.
.
Cleanup Non-cancer
Medium Chemical Level Cancer Risk Hazard
(mq/kg) Index
Surface Arsenic 36 10 -5
Soil
Chromium 1,351 1.0
Copper 10,000 1.0
Subsurface Arsenic 336 10 -4
soil
Chromium 1,351 1.0
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.J
September 28, 1992
Ms. Dana Rasmussen
Regional Administrator
'U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle. W A 98102
Re:
Joseph Forest Products
Propos~d Remedial Action
Ofegon
DEPA~TMfNT OF
ENVIROI\:M£NTAL
QU A L1'!'Y
n?~~~
Dear M/...ussen:
The O,.eg'on Department of Environmental Quality (DEQI has reviewed EPA's proposed
remedial action for the Joseph Forest Products site as presented in the draft Record
of Decision. I am pleased 10 advise you that DEO concurs with EPA'sproposed
, remedial action, based on Alternative 4 of the Feasibility Study. DEQ also concurs
with EPA's proposed cieanup ieve!s for the sit~.
I find ttlat this alternative sarlsfies all applicable state statutory requirements and'
administrative rules'pertaining to the degree of cleanup required and remedy selection
process. Specifically. this alternative is protective, cost-effective, effective,
implementable, 'and uses permanent solutions to the maximum extent practicable in
accordance with ORS 465.315 and OAR 340.122-040 and 090.
The DEO looks forward to the implementation of the remedial action. Please let us
kr'lOw if we can provide further assistance.
Sincerely,
3~
Fred Hansen
Director
cc:
Chip Humphrey. EPA-OOO
. Jill Kiernan, DEQ
.
~ '
~~
.~
$11 SW Sixth Avenue
. Port!;Jt\d, OR 97204, 1390
(503) 229-5696
DEQ-l
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