United States Off ice of Environmental Protection Emergency and Agency Remedial Response EPA/ROD/R10-93/059 June 1993 v>EPA Superfund Record of Decision ------- REPORTDOCUMENTA~ON 11. REPORT NO. 2. 3. Reclpl.nt'8 Acc88810n No. PAGE EPA/ROD/R10-93/059 4. Tltl. and Subtitle 5. Raport Dat. SUPERFUND RECORD OF DECISION 06/30/93 Allied Plating, OR 6. First Remedial Action - Final 7. Author(a, 8. Performing Organization R.pt. No. 8. P.rformlng Organization Name and Addr- 10 Project Ta8lclWork Unit NO. . 11. Contract(C) or Grant(G) No. (C) (G) 12. Spon80rlng Organization Nama and Add,..a 13. Type of Report & Period eov.r8d U.S. Environmental Protection Agency 800/800 401 M Street, S.W. Washington, D.C. 20460 14. 15. Supplementary Notee PB94-964619 16. Abatract (Limit: 200 worda) The 12-acre Allied Plating site is a former chrome plating facility in Portland, Multnomah County, Oregon. The site can be divided into three areas, based on historical uses. These include an administrative and storage building; the layout area, which is occupied by a crane facility; and the low-lying impoundment area, which occupies the northern area of the site. Land use in the area is predominantly industrial, with a riparian (riverbank) area located to the north of the site. The site lies 1,000 feet south of the Columbia Slough, a shallow, steep sided, slow moving body of water that flows across the northern edge of Portland. A single unconfined aquifer was identified beneath the site, whicQ supplies ground water to upgradient facilities for irrigation and potato processing. Drinking water is supplied by the city of Portland and does not originate in the vicinity of the site. Prior to 1947, the site was vacant and most likely used as a pasture. In 1947, the site was leased for use as a wrecking yard, and, in 1957, was leased to Allied Plating. Allied Plating operated the site from 1957 until 1984, when onsite operations ceased. Prior to 1969, wastewater from the facility was discharged to the swale leading into the slough. In 1969, when backfilling isolated the property, liquid wastes from the plating process were discharged onsite directly to a pond within the impoundment area. The metals in (See Attached Page) 17. Document Analyela a. D88crlptora Record of Decision - Allied Plating, OR First Remedial Action - Final Contaminated Medium: None Key Contaminants: None b. Id.ntlfl.rafOpen-End8d T.rms c. COSATI Field/Group 18. Availability Stat.ment 19. Security Clan (ThIs R.port) 21. No. of Pag.. None 122 20. Security Clasa (ThIs Pags) 22. Price None 50272.101 (SM ANSI-Z39.18) SH/natructJons on Reverse OPTIONAL FORM 272 (4.77) (Formerty NTIS.35) ------- EPA/ROD/R10-93/059 Allied Plating, OR First Remedial Action - Final Abstract (Continued) the plating wastewater precipitated out, forming a layer of plating waste at the bottom of the pond. Once onsite discharge ceased, the pond receded, leaving a dry area covered with- ,. plating waste. In 1978, as a result of the discharge of wastewater to the pond, the State required the installation of an onsite wastewater treatment system and discharge and RCRA permits. State studies in 1984 indicated that ground water in the vicinity of the site and. soil in the impoundment area were contaminated with metals, including lead, nickel, and chromium. In 1992, EPA conducted a removal action at the impoundment area that involved excavating approximately 1,100 tons of soil and debris, with offsite stabilization and/or disposal; dewatering 70,000 gallons of pond water from the pond area, and disposing of 120 tons of the resultant filter cake; backfilling the pond and other areas within the impoundment area; and enacting a deed restrictions on the use of the shallow aquifer at the site. During the.RI, it was determined that site contamination was mainly limited to the layer of plating waste. Subsequently in 1992, EPA conducted a second removal action to transport the plating waste offsite. This ROD addresses the impoundment area as a final action. Since the potential risks to human health and the environment have been reduced to acceptable levels by the earlier removal action, there are no primary contaminants of concern affecting this site. The selected remedial for this site is no further action. The previous 1992 removal actions have reduced the health threats associated with site-related contaminants to acceptable levels. PERFORMANCE STANDARDS OR GOALS: Not provided. ------- Record of Decision Decision Summary. and Responsiveness Summary for No Further Action Allied Plating Superfund Site June 1993 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 1200 SIXTH AVENUE ... SEATTLE, WASHINGTON 98101 -- , ------- Declaration for th~ Record of Decision Allied Platina. Portland. Oreaon Statement of Basis and Purpose This decision document presents the No Further Action Decision for the Allied Plating site, in Portland, Oregon, which was chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Uability 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). The Oregon Department of Environmental Quality concurs with the No Further Action decision. The information supporting this remedial action decision is contained in the administrative record for' . this site. Description of the Selected Remedv This Record of Decision is for No Further Action. The site has been remediated by a Removal Action which took place in October and November of 1992. The Removal Action addressed the threats posed by the site. Declaration of Statutory Determinations No Further Action is needed for protection of human health and the environment. . Because the No. Further Action decision will result in hazardous substances remaining on site above health based levels, a review will be conducted within five' years after the commencement of the Removal Action to ensure that the remedy continues to provide adequate protection of human health and the environment. . ~: .- . EPA has determined that its response at this site is complete. Therefore, the site now qualifies for inclusion on the Construction Completion Ust. c ~ ~(~ ¥Gerald A. Emison, Acting Regional Administrator f ( ~1' Dae ------- .' DECISION SUMMARY ALLIED PLATING SUPERFUND SITE PORTLAND, OREGON TABLE OF CONTENTS DECLARATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ii - LIST OF FIGURES. . . . . . . . . . . . . . . . . . . . . . . . . . . .. iii LIST OF TABLES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. iv LIST OF APPENDICES. . . . . . . . . . . . . . . . . . . . . . . . . .. v I. INTRODUCTION.......... ... ...,. . . ..., ....... 1 II. SITE DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1 A. Location and Description, . . . . . . . . . . . ',' . . . . . .. 1 B. Topography........,..................... 4 C. Adjacent Land Uses. . . . . . . . . . . .. . . . . . . . . . . . 4 D. Surface Water and Groundwater Resources. . . . . . . 4 E. Site Geology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 F. Ecological Conditions. . . . . . . . . . . . . . . . . . . . . ~ . 5 III. SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . 6 IV. COMMUNITY RELATIONS HISTORY .'-". . . . .'. . . . . . . . . . . 7 V. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE STRATEGY. . . . . . . . . . . . . . . . . .. 8 VI. SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . 9 A. Purpose of the Remedial Investigation. . . . . . . . . . . 9 B. Results of Soil and Sediment Investigation. . . . . . . . 9 C. Results of Groundwater and Surface Water Investigation. . . . . . . . . . . . . . . . . . . . . . . . . . .. 14 VII. " " " - " REGULATORY REQUIREMENTS FOR ADDRESSING SITE. ------- VIII. IX. X. XI. XII. XIII. XIV. SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . .. 19 A. Risk Assessment Rationale. . . . . . . . . . . . . . . . .. 19 B. Determination of Contaminants of Concern. . . . .. 20 C. Exposure Assessment. . . . . . . . . . . . . . . . . . . .. 20 D. Toxicity Assessment. . . . . . . . . . . . . . . . . . . . . ., 24 E. Risk Characterization. . . . . . . . . . . . . . . . . . . . ~.. 26 F. Risk Assessment Uncertainties. . . . . . . . . . . . . .. 30 G. Human Health Risk Conclusions. . . . . . . . . . . . .. 31 - ECOLOGICAL ASSESSMENT. . . . . . . . . . . . . . . . . . . . .. 31 A. Ecological Profile. . . . . . . . . . . . . . . . . . . . . . . .. 31 B. Data Evaluation. . . . . . . . . . . . . . . . . . . . . . . . .. 32 C. Ecological Assessment. . . . . . . . . . . . . . . . . . . .. 32 REMOVAL ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33 A. Determination to Perform a Removal Action. . . . ., 33 B. Action Levels. . . . . . . . . . . . . . . . . . . . . . . . . . .. 33 C. Removal Actin BoundarieS. . . . . . . . . . . . . . . . .. 34 D. Removal Activities. . . . . . . . . . . . . . . . . . . . . . .. 34 DETERMINATION THAT NO FURTHER ACTION IS APPROPRIATE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 37 CESSATION OF GROUNDWATER MONITORING. ....... 41 FIVE YEAR REVIEW. . . . . . . . . . . . . . . . . . . . . . . . . . .. 42 EXPLANATION OF SIGNIFICANT DIFFERENCES. . . . . . .. 42 APPENDICES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45 '''':'', ------- . Figure 1. Figure 2. Figure 3. Figure 4. - - Figure 5. Figure 6. Figure 7. LIST OF FIGURES Vicinity Map: Allied Plating. . . . . . . . . . . . . . . . . . . . . Site Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Remedial Investigations Sampling Locations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Impoundment Area Sampling Locations . . . . . . . . . . . Conceptual Model Human Health Exposure Pathways. . . . . . . . . . . . . . . . . . . . . . . . . Removal Action Excavation Locations . . . . . . . . . . . . Removal Action Screening and Confirmational Sampling Locations . . . . . . . . . . . . . . ..~. .. . 2 3 10 11 23 35 39 ------- .. LIST OF TABLES Table 1. Range of Inorganic Analytical Results , Impoundment Area Soils. . . . . . . . . . . . . . . . . . . . . . . . . Table 2. Inorganic Analytical Results Monitoring Wells IB06 and IB08 . . . . . . . . . . . . . . . . . . . . Table 3. Inorganic Analytical Results Monitoring Wells MW08A, MW13A, and IB10 .................. Table 4. Inorganic Analytical Results Impoundment Area Surface Water. . . . . . . . . . . . . . . . . . Table 5. Summary of Pathway-Specific Exposure Assumptions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Table 6. Exposure Point Concentrations. . . . . . . . . . . . . . . . . . . . Table 7. Carcinogenic Risk and Non Carcinogenic Risk Indices for Risk Assessment Scenarios. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Table 8. Risk Results for Inorganic Contaminants of Potential Concern in Hot Spot. . . . . . . . . . . . . . . . . . . Table 9. Removal Action Confirmational Sampling Results. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ',..; h. Table 10. Residual Risk for the Post Removal Impoundment Area. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~.- ... .. 13 15 17 18 22 25 27 29 38 ------- Appendix A: Appendix B: Appendix C: Appendix D: APPENDICES Responsiveness Summary Post Removal Risk Assessment State Letter of Concurrence With the No Further Action Decision Administrative Record Index ._~ ------- DECISION: SUMMARY Site Name: Allied Plating .. Site Location: Portland, Oregon I. INTRODUCTION The Allied Plating site was placed on the National Priorities list in February 1990, under the Comprehensive Environmental Response, Compensation, and liability Act of 1980, 42 U.S.C. ~9601 et seq., as amended by the Superfund Amendments and Reauthorizatipn Act of 1986 (CERCLA or Superfund). In accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), the EPA performed a Remedial Investigation (RI) for the Allied Plating site. The RI, completed in April 1992, characterized contamination in soils and groundwater. The Baseline Risk Assessment, part of the RI, evaluated potential effects of the contamination on human health and the environment. Based on the information in the RI, EPA determined that the appropriate course of action was to conduct a Removal Action at the site. The Removal Action took place from October 20 to November 20, 1992, and successfully remediated the site. This ROD presents the No Further Action decision for the Allied Plating site, in Portland, Oregon, chosen in accordance with CERCLA, as amended by SARA, and to the extent practicable, the National Contingency Plan. The decision at the site is based on the administrative record. II. SITE DESCRIPTION A. Location and Description The Allied Plating site is located at 8135 Martin Luther King, Jr. (MU<) Boulevard in an industrial and commercial district of northeastern Portland, Multnomah County, Oregon. It is approximately 1,000 feet north of the intersection of MLK Boulevard and N.E. Columbia Boulevard, and 1,000 feet south of the Columbia Slough (Slough), a local drainage channel that merges with the Willamette River and then the Columbia River. Figure 1 is a map of the north Portland area, showing the location of the site in relation to local features. Figure 2 shows the boundary of the site, the site layout, and the surrounding area. The. site covers approximately 12 acres, and can be divided intothre~areas based on their historical usage. The southernmost section contains the fOrTner . ... ------- ~ ~ .. . ."' ~ v ~f:::::.\". ... .. \i!!!Ii;~}t. .tr;\!i!/}. ../t~~~~~{1[Ji:i!!t:r::.;:.;" Washington '.:.- ..:/f\f:/ .;(~~~!!;r:!(:'" ''';: ALLIED PLATING SITE ~~ : .Iz 2 . KLOMETERS Figure 1 Site Vicinity Allied Plating Portland, Oregon "..:.. . .- ~ f" ".' :"'.' ------- 'I '. ,. .. ..,"" I:.. ~ ~ Edgool fill :!' ~ ~ 4"- \ :; ~ ~~' ~' "'--;i~~ ~ ~ '~~ ..s... :~ ~~~,~ ..s.~- :i ~ ~ ~ "" ~ ..s...s. ~ -- .. ~.I. I'~..s. ~. .'" I,.. tWIt';... ",...JI. .'..1.. .... . . . . . . ! . . \ . I . I . I . I . : . I . "'--~s...~ .' : ~III --..... . . I 't' , . . . . . . ....... W... 11WU~'lDc.IbCWI. e F ILL ., z "' f. II:! t1 I 1 I t 9"'901 POUIOO\C)Wtlll &---1 Layout Area Figure 2 Site Map --- ams- (IooIDw""" -..-..- ""''''''(\Itlooochclln) o ....... .-- ~Uw ........... tIgh Wal8lkw ,,-. Tapo C'.onIIIIn (1181'" MSij ........ ......, .Fn8 Uw ~ NORTH Sc8I kI FMI 1011 0""'1011 ------- administrative and storage building for the former Allied Plating business. This area is across the street from the location where plating activities occurred, and was not considered to be contaminated from operations. The "layout area" contains the former plating operations building and storage yard. This area is presently occupied by the Associated Truck and Crane Company as a repair and storage facility for cranes and various heavy equipment. The "impoundment area" is the northern, low lying area of the property. Prior to the Removal Action, it contained a pond formed from. the discharge of wastewater from the plating business. This area is not used in current site operations. B. Topoaraphy The elevation of the site varies from approximately 12 to 40 feet above mean sea level, slOQing downward to the north. Prior to 1969, the property drained overland to the nort':', into a swale that led directly into the Slough. Wastewater from the plating facility was discharged to this natural drainage. In 1969, extensive backfilling with dirt and construction debris north of the site partially covered the swale, cut off the natural drainage, and left the northern end of the site 20 to 30 feet lower than the surrounding off-site areas. Wastewater discharged from the facility began to collect in this low lying area (the impoundment area) forming a 1.5 acre pond. Surface runoff from the Allied Plating site and surface water draining from the adjacent area contributed to the pond. The pond was drained and filled during the Removal Action. The impoundment area still collects drainage for the area, and so water accumulates at the lowest point. A combined sewer overflow (CSQ) pipeline runs northerly under the impoundment area to an outfall in the Slough. The CSO line is a 36 inch square pipe constructed in 1928. During the 1992 Removal Action, a remote control video camera was used to inspect the pipeline. The pipeline was. still in good condition, and not acting as a conduit for drainage from the pond. . . C. Adiacent Land Uses The site is located in an area of light industry;- Two food 'processing plants, . many small industrial and or manufacturing businesses, a hotel and a 15 unit apartment are located within 1000 feet of the site. To the northeast, on the other side of the Slough, is a mobile home park with 180 mobile homes. D. Surface Water and Groundwater Resources Prior to the Removal Action, the site contained a pond that was formed when backfilling isolated the site from natural drainage. At the time of the RI, the pond was approximately 260 feet long, 105 feet wide, and 3 feet deep. It contained an estimated 376,655 g~lI~ns of water. The pond r~ived water from precipitation and .~noff,. ~~d ------- recharge from groundwater. The pond was filled during the Removal Action. Surface water still collects in the impoundment area. The Columbia Slough is located approximately 1000 feet from the site. The Slough is a shallow, steep sided, slow moving body of water that flows across the northern edge of the city of Portland and along the south bank of the Columbia River. From the site, the Slough flows west about six miles to the Willamette River. From this confluence, the Willamette flows approximately 2000 feet and enters the Columbia River. A single unconfined aquifer, the Troutdale Aquifer, was identified beneath the site. The water level in the Troutdale was measured to be 10 feet above mean sea level, and was found approximately 10 feet below the. surface of the impoundment area. The pr~dominant groundwater flow direction was northwest. A localized shallow . aquifer was found in the vicinity of the impoundment area. The water table in the shallow aquifer was 15 feet above mean sea level. . Groundwater is used by upgradient facilities for irrigation and potato processing. Drinking water is provided by the city of Portland and does not originate from the vicinity of the site. . E. Site Geoloay Three geologic units were encountered during the RI. In order of depth from th~ surface, they are the Holocene alluvial deposits of the Columbia River, Pleistocene post-glacial deposits, and the Pliocene Troutdale formation. 10 addition, the site is un~erlain by fill such as metal scraps, demolition debris, and automotive debris. There was no visible contamination in the area formerly containing the . administration buildings, or in the layout area. The impoundment area was visibly contaminated. The area was covered. with a friable, greenish material (plating waste) to a depth of 2 to 6 inches, and covered in dead grasses. Trees in the area were dead and the bark was visibly blue green. The water io.the pond was dark green. The impoundment area was remediated during the Removal Action (described in Section X). All contaminated soil. vegetation, and debris were removed. The in:tpoundment area is currently graded and covered with rock. . F. Ecoloaical Conditions The .ecological conditions in the vicinity of the Allied site can be categorized into three types of habitats: an urban industrial area. a riparian (riverbank) area north of the backfill area. and the Columbia Slough. Section IX of this Decision Summary describesth"ese habitats in detail. ." . .' '. ..' -- ~ ." ------- III. SITE HISTORY AND ENFORCEMENT ACTIVITIES Available data indicate that prior to 1947, the site was vacant land most likely utilized as pasture. The property was owned by the Hodes family. In 1947, the site was leased for use as a wrecking yard. In 1957, the building was leased by Mr. Ernest Stierly as the site for the Allied Plating, Inc., chrome plating facility which operated from that year until 1984 when the company declared bankruptcy. and ceased operations. Prior to 1969, wastewater from the facility was discharged to the swale leading to the Slough. After 1969, when backfilling isolated the property, liquid wastes from the plating process were discharged to the pond on site. The metals in the plating wastewater precipitated out, forming a layer of plating waste at the bottom of the pond. Aerial-ghotographs indicate that the pond covered the north end of the property while the company was discharging. When the company ceased discharging, the pond receded leaving a dry area covered with plating waste. In 1978, as a result of the discharge of wastewater to the pond, Oregon Department of Environmental Quality (ODEQ) required a compliance schedule for the installation of an on site wastewater treatment.system. In 1980, ODEQ required the facility to get an Oregon Water Pollution Control Facility (WPCF) permit, and as a result of the wastewater discharge, EPA required Allied Plating to submit a Resource Conservation and Recovery Act (RCRA) Part A (hazardous waste permit) application. In 1981, the facility received interim status as a treatment, storage and disposal facility under RCRA, and in 1982 a WPCF permit was issued. . Mr. Stierly contracted with Sweet-Edwards & Associates to install three. groundwater monitoring wells. These wells were required under Allied Plating's RCRA Part A interim status. After Allied Plating ceased operations in 1984. the company did not conduct any additional groundwater monitoring or sampling, and the wastewater treatment system required by ODEQ was never installed. ..:.. . In September 1984, the U.S. EPA and ODEQ jointly requested closure and post closure plans from Mr. Stanley Hodes (the current site owner) as part of a requirement of a RCRA Part B permit. In January, 1985, the Oregon Department of Transportation (ODOT) was informed that the pond encroached on the right-of-way of State Highway 99E (MU< Boulevard) and that ODOT shared the responsibility for site cleanup. Riedel Environmental Services (Riedel) was hired by the ODOT to prepare a closure plan for the site. Riedel installed 10 monitoring wells, hand-augared for soil samples at five locations, and collected two Slough sediment samples and five pond sediment samples. Results from the two studies showed that the groundwa~~r in the vicinity of the site was contaminated with lead, nickel and chromium, and that there . . . ------- were high concentrations of metals in the impoundment area soils (see Allied Plating RifFS Scoping Report (prepared by URS for EPA, 1990) for the results of the previous site investigations). The next two years consisted of submissions of plans and other communications from the property owner and OOOT to the U.S. EPA and OOEO, and reviews, comments and requests for further information from the agencies to OOOT and the property owner. In November 1986, when the closure plans wereHnot accepted, and actions under RCRA were not able to obtain site cleanup, EPA and OOEO reached an agreement transferring program jurisdiction from RCRA to Superfund. The site was proposed for inclusion on the National Priorities Ust January 22, 1987, and w~s listed February 2, 1990. EPA conducted a Remedial Investigation (RI) at the site between January 1990 and April 1992. The RI determined that the contamination of the site was mainly limited to the layer of plating waste formed in the surface of the impoundment area. At the end of the RI, the site was evaluated for a potential Removal Action as part of the Superfund Accelerated Cleanup Model (SACM) Program. The site met the criteria for remediation by a Removal Action (described in Section X), and between October 20, and November 10, 1992, the plating waste in the impoundment area was excavated and shipped off site for disposal at Envirosafe Services, Inc., in Grandview, Idaho (a facility on EPA's off-site policy list of eligible disposal facilities). IV. COMMUNITY RELATIONS HISTORY The RI and proposed Plan for the Allied Plating site were released to t~e public in April 1993. These documents were made available to the public in the Administrative Record, located in the information repositories maintained in the EPA Records Center in Seattle, and at Portland State University's Miller Ubrary and the N.E. Neighborhood Association in portland, Oregon. The notice of availability of these documents was published in The Oregonian on April 29, 1993. A ptJblic-comment period was held from April 28, to May 28, 1993. The Proposed Plan and newspaper notice offered. the option of having a pubic meeting. However, a meeting was not requested by the public. There were no comments received during the comment period. The Responsiveness Summary, documenting that there were no comments received, is included as Appendix A. ,- ------- To date, the following community relations activities have been conducted by EPA at the Allied Plating site: February 1987 September 1987 March 1990 November 1990 June 1991 October 1991 October 1992 April 26, 1993 April 28, 1993 April 26, 1993 May 26, 1993 June 1993 EPA distributed a fact sheet announcing the nomination of the site to the National Priorities List. Community Relations Plan published, which included iriterviews from the community and local officials. EP A released a fact sheet announcing the site was placed on the National Priorities Ust. EP A distributed a fact sheet announcing the beginning of the RI field work. EPA released a fact sheet describing the preliminary results of the Rio Community Relations Plan Schedule updated. EP A mailed a fact sheet announcing the beginning of the Removal Action at the site. EPA mailed the Proposed Plan for No Further Action. In the Proposed Plan, EPA offered the opportunity for a public meeting. No request was made. EPA published a newspaper notice in The Oreaonian announcing the Public Comment Period and the opportunity for a public .rT:Ieeting. Public Comment Period begins. Public Comment Period ends. . ~: .- Responsiveness Summary prepared. v. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE STRATEGY This ROD addresses the decision for No Further Action at the Allied Plating site. The contaminated areas of the sit~ were remediated by a Removal Action which took place from October 20, to Novc;,mber 10, 1993. During the Removal Action, all site. contamination above EPA's selected health based cleanup levels was excavated and disposed of in the hazardous waste disposal facilitY , Envirosafe Services, Inqu in Grandview, Idaho. . " '. .. ,: '. '.,. ' -. ------- VI. SUMMARY OF SITE CHARACTERISTICS A. Purpose of the Remedial Investigation The Purpose of the RI was to investigate the extent of contamination in all media potentially affected by site activities. The information from the RI and the resulting Risk Assessment were used to determine the need for, and the extent of, the Removal Action. Contaminants were released into the environment through the discharge of wastewater by the plating facility to the northern part of the property, and potentially from the dumping of waste from the plating operations onto the property. Prior to backfilling activities, the wastewater flowed to the Slough through natural drainage. Following backfilling, the wastewater ponded on the property. Metals from the wastewater precipitated ~ut forming a layer of plating waste covering the surface of the impoundment area. - The RI investigated contamination resulting from the direct discharge of wastewater or dumping of wastes, and the dispersal of these contaminants through the groundwater. For the soil and sediments investigation phase, samples were taken of the surface soil (top 6"), shallow soil (to 3') and deep soil (greater than 3') in the site vicinity, the outfall swale sediment (the location where water drainage from the site had previously discharged to the Slough), and the Slough bottom sediment. For the groundwater and surface. water investigation phase, gr(jun~water samples were collected from 10 wells installed during previous studies (IS series. wells), 14 wells installed during the RI (MW series wells), and from three commercial wells. Surface water samples were taken from the pond and the Slough. Water samples were taken twice, once in January 1991, and again in April 1991. Figures 3 and 4 show the loeations where the soil, surface water, and groundwater samples were taken. B. Results of Soil and Sediment Investiaation 1. Inorganics During the soil sampling phase of the RI, areas both on and off site were identified as background locations. These locations were selected because they were outside of the area of known or suspected contamination caused by the plating activities, and thus would represent vicinity soil quality. Contaminant levels found in the investigation were compared to background soil samples to determine whether they were the result of site . ------- ~ tl;'f,13UJ BI.DG. ... I '. / "J I / w~ 7 / I I / -- ~ ..- ."810.' '0.04 8180' 10.0' 111101 '. ". , _'01 ell. - - LOC.- "'_.IP U\CI. NV.-' ,"' - ws!. (115- -,- I(U -. - LOC.- -IP U\CI. CUV.-' '". - lit!. -----~- co.- 1LG.IGII -- -- - ~- .cw . . .,100 "'AU .....u -- -~- IIIICI( UN( -1- Ilf I 5 / I ~ / OJ I ~ I $ I S is' (,.. '-" -Ie ¥""" -~ .l r-" wl.1II58ot "- I . IIIIOa / / / ! l1li811 -"'*-18 ....: III "'YOU' AlII: . ~- 1118" I I ~. o ... ,..: III :.c (J ii >- " 0- f ~ I I w I z , , ~ , p.~' 'V~\~ I~~. I ~ , .... o' . I CJWiHIC SCALE 120 I . 120 I. ~ .... j ~' ~ ALLIED PLATING ) .... I Figure 3 Remedial Investieation Sampling Locations . "",. "'-"""""., ------- SBI1S 'I I I I' . I' uo>sl L -1- -1- -1-- -1- -1- -1- -c..... .-- I" .-4 .-4 "... ~ "... ~ "... I I ~,;"'..,. LEGEND ,. ~ ~.-:. "... . 'IS4"" ~, ~ 50 I ~"... ,;"'.. .. o ! ! GRAPHIC SCALE (CONTOUR INTERVAL. 1 foon "... ... ~ 1oIv.Q4B $IB04 1oI000TORIHC WElL HUIoIBEA AND LOCAnOH EXlsnHC UQNITORIHC ~Ll HUUBER AHD LOCAnOH ~ "... -x- r[He( LINE Figure 4 Impoundment Area Sampling locations ...."" "...,..""""" 50 I 151 sao~ .1517 SOIL BORINC HUIoiOER ANO LOCAnOH luPOUNDuEHT SAUPLE HUuBER AHD LOCAtION ..".... ------- activities or were from other industrial or n'alural sources. Inorganics found on site that were potentially attributable to the plating activities included antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, zinc and cyanide. However, chromium, copper and nickel' were the only compounds with significant concentrations above background levels. The RI determined that the majority of the contamination was limited to the impoundment area. Table 1 presents the range of values for inorganics detected in the surface, shallow, and subsurface impoundment area soils. All of the soil samples collected from the impoundment area exhibited levels of chromium, copper, and nickel above background concentrations. The greatest concentrations encountered were in samples of the plating waste layer with consistently high concentrations of chromium (to 20,700 ppm), copper (75,110 ppm), and nickel (to 15,700 ppm). Contamination was mainly limitect to the top 6 to 12 inches. As depth increased, contaminant concentrations decreased. Layout area surface samples exhibited relatively low levels of contamination. The maximum metal concentrations found were chromium (165 ppm), copper (794 ppm), and nickel (1930 ppm). Offsite soil samples were collected at the approximate pre-backfill ground surface from areas north of the site to evaluate whether contaminants from the plating facility had migrated along the drainage swale before the placement of the backfill. With the exception of antimony (16.5 ppm) in one sample, and arsenic (9.8 ppm) and zinc (385 pr;m) ln another, all metals were at background levels. Outfall swale soil samples contained cadmium (maximum 5 ppm), chromium (maximum 46 ppm) and copper (maximum 193 ppm) in excess of surface soil background values. The metal concentrations may be from pre-backfilling plating discharge or from other industrial sources. Columbia Slough bottom sediment metal concentrations were similar upgradient and downgradient from the site. 2. Organics In the impoundment area, toluene (maximum 2 ppb) and xylene (maximum 4 ppb) were detected at 4 locations. In addition, 1,2-dichloroethene (4 ppb) ~nd trichloroethene (12 ppb) were detected in one sample. These levels are not signi~Cant. The source of the organics is ur:"known, but they are corn,monly used for industrial purposes. Polycyclic aromatic hydrocarbons (PAHs) were detected at very low concentrations (below required detection limits) at three locations. PAHs likely came from deposition of car and truck exhaust. Organics were not detected ,in the layout area soils. Outfall surface soils and Slough sediments Contained PAHs. When the samples were collected from the, swate, an', oil sheen was observed on the surface ot the 'Slough. ------- Table 1 Range of Inorganic Analytical Results Impoundment Area Soils1 Antimony < 0.55-379 < 5.20-27.56 0.44-14.5 Arsenic 2.20-147 3.8-7.4 2.20-65.0 Beryllium 0.82-1.00 <0.58-0.61 0.52-1.10 . Cadmium <0.61-10.4 <.78-6.2 <0.49-6.8. Chromium (Total) 107-20,700 57.1-520 43.1-5400 Cobalt 15.8-51.9 15.6-60.7 13.2-39.8 Copper 88.5-75,100 400-6720 253-15,600 Lead 26.3-573 9.0-518 9.40-975 M -Nickel 229-15,700 173-31,900 233-3230 .-4 Silver < 0.76-5.6 < 1.0-2.6 <0.20-15.7 Thallium < 0.48- < 25 < 0.52- < 0.72 0.49-6.60 Zinc 116-1280 63.4-2090 64.2-2550 Cyanide < 0.64-229 0.83- < 1.3 < 0.59-249 tAll values are in mg/kg. 1:::::::::jj,:j::::j:::::\j.::::::\\:j':\!j:$.iEsi,:;$:?nlti.:::;::;;:i:if;f1.lli:m;: ;;~ID.ltlltw'~ilil~Dlt :::~D!:11~~:;;N:K~::$.:;::\:ii;;: filillil:;:tIIIJliDi :::1;,::::.:::::::::::::j::::'::j::::jjjjj:j::j:::tj:::::::::'!l9.i.1;i,~;\::::::\:j::;::::::j;;t[:rt~:::;ill: ;;;;i~fifi~iliiliM~;1;\~;t.g'ilmfti,!;:tfJ.H~;M[:m::::;;' ::~i,~(iff.1111!lt~::@1:.,;,::' i~t ,::':i::I:*:ili::~::::;:: " ------- It is likely that the PAHs in the surface soils bf the swale resulted from PAHs in the Slough. 3. Soil Results Summary Site related contamination was primarily inorganic, and mainly limited to the surface soil of the impoundment area. This area was covered with a layer of plating waste. There was little or no site related contamination in the layout area, the outfall swale soils, or the Slough sediments. Low levels of volatile organics were found in the impoundment area. The source of these contaminants is unknown, but probably the result of the industrial activities in the site vicinity. PAHs were found in the impoundment area, the outfall swale, and the Slough. Th6-PAHs on the site probably resulted from contamination from MLK Boulevard. The sourc~ of the P AHs contamination in the swale sediment, and the sediment of the Slough is unknown; but likely was not related to historical activities at the site. C. Results of Groundwater and Surface Water Investigation Samples of groundwater taken during early site investigations (see Section III) indicated that contamination from the site (chromium, nickel, and lead) was Widespread in the Troutdale and shallow aquifers in the vicinity of the site. However, the results of the RI indicated that the contamination has dissipated. 1. Water Level Elevations The water table was found at two elevations. A shallow aquifer with water at .15 feet above mean sea level was found beneath the impoundment area (wells IB-6 and IB-8) and to the northeast of the site (well MW-10A). The Troutdale aquifer was found at 10 feet above mean sea level throughout the area. The pond water level was at 15 feet above mean sea level, the same level as the shallow aquifer. . 2. Inorganics '...'. Concentrations of inorganics exceeding background values were detected in all groundwater samples. Concentrations were relatively low, and only a few of the inorganic contaminants exceeded either promulgated or proposed Maximum Contaminant Levels (MCLs) for groundwater (drinking water standards). The highest concentrations of potential plating waste derived contaminants (chromium, nickel, and lead) were detected in the mQnitoring wells installed in the shallow aquifer adjacent to the pond (wells 1806 and 1808). Ta~le 2 presents the analytical results for samples collected from these wells. . Only nickel was found above MCLs lexceeding the nickel standard of 100 ppm in 18-6). Samples collected froni monitoring welfs"in the ------- Table 2 . Inorganic Analytical Results Monitoring Wells IB06 and IB081 . -=-~~ Arsenic 4.10 1.8 <3.00 5.80 Berjllium < 1.00 < 1.00 < 1.00 < 1.00 Cadmium <3.00 <3.00 <3.00 < 3.00 Chromium <5.00 <5.00 17.9 15.8 Chromium + . <0.90 <10.0 < 1.00 < 10.0 . Cobalt 9.5 4.5 < 5.00j 5.50 Copper 11.7 <7.07 67.9! 49.9 Lead 9.4 6.4 14.5 7.60 Manganese 3010 2510 5310 3960 'Nickel 655 690 29.0 45.0 ~ ...... Thallium <2.00 <2.00 <2.00 <2.00 Zinc 223 257 36.9 20.2 1 All values are in ug/kg. ------- Troutdale aquifer zone generally contained lower concentrations of the potential plating waste derived contaminants. Results from several wells are shown in Table 3. Manganese concentrations in the Troutdale aquifer were significantly elevated above background levels both upgradient (Le. 11,800 ppb in MW07C, and 17,300 ppb in MW048) and downgradient (Le. 17,700 ppb in MW-13A). The source of the manganese is unknown, but it was not associated with plating operations at the site. Water samples collected from three water supply wells had detectable concentrations of arsenic, cobalt, copper, lead, and zinc. The localized groundwater flow in the area indicates that these contaminants were not migrating from the Allied site, and all results were below applicable MCLs. The_f!1etal concentrations detected in the pond surface water samples were similar to levels detected in the shallow groundwater samples from the impoundment area (18-6 and 18-8). The inorganics analytical results of the impoundment area surface water are presented in Table 4. There were no significant trends in metal concentrations detected in the surface water samples collected from the Slough that can be associated with releases from the site. Nickel was detected downgradient from the site (maximum 24 ppb). However, there was no nickel detected in the groundwater from the wells nearest the Slough. The remaining contaminant levels were below detection limits or were similar upstream and downstream from the site. 3. Organic Compounds Two volatile organic compounds were detected above MCLs during the investigation. Trichloroethene was detected in water samples from MW12C (maximum 6 ppb) slightly above the MCL of 5 ppb during both sampling events. This well monitors groundwater in the Troutdale aquifer northeast of the impoundment area. This compound was not detected in the water samples collected from the other wells. Carbon tetrachlo- ride was detected at 13.5 ppb in MW16A in the January water sample (above the MCL of 5 ppb). This compound was also detected in April water samples from five wells, ranging in concentration from 0.2 to 2.0 ppb. A number of other organic compounds were detected at low concentrations (below MCLs) in the wells including chloroethane, 1,2-dichloroethane, chlorobenzene, 1,2,4-trimethylbenzene, toluene, and tetrachloroethene. The organic contaminants were probably related to the industrial activities in the site vicinity. . Volatile organic compounds were not detected in the January pond water samIJles. Chloromethane was detected at low levels in the. April sampling event (maximum 2.0 ppb). , ------- Table 3 Inorganic Analytical Results Monitoring Wells MW08A, MW13A, and 18101 Arsenic Beryllium Cadmium Chromium Chromium + Cobalt 11.90 Copper 12.0 Lead 2.80 . Manganese 11,700 Nickel < 20.0 Thallium <2.00 Zinc 12.0 1 All val~es are in ug/kg. :,:~'~:::~:~::'.::'19nUgrlni:::}%~lljjj.g~~ji::;:::::jt: :j;;iliij;i;::;j;1;lIijfi!r::;~:::: """.:;i!J.i1i.tll~::~t~~r, ;j;j:ii:::i~m::ri::::)i,;iI9iiit!ii!ng::ml:}.m:...A1:~:*:~]~;:i;:::iij::::. :"':'::'.:::::.:.:::[in~!'il.:::~~:..:.~::::::.;::. :.:.::.::j:::jj:::::..:.i::!pi~t:::.:::i:::~::::::::j::::: .:::j:::ij::::::::::::lj::liuU:!lli.ii!filllm: :::i:iii::mi:::::::j::IRrU)i::mj;:j~::t;:: !::r::::j::i:11~ingg~1!::!!::::::::::::::~ :j::j;:::::l~m::~flpm~::jr~i:ijj!:!:ji::!!:j; <4.7 <2.00 7.30 9.90 6.60 <2.90 < 1.00 1.50 < 1.00 1.30 < 1.00 < 1.00 <3.00 <2.20 4.50 4.10 <3.00 3.5" <5.00 <2.00 <5.00 2.90 <5.00 <2.00 . <0.70 < 1.00 < 5.00 < 2.00 < 10.0 <7.00 4.00 4.5 . 590 572 < 20.0 < 16.0 . < 2.0 < 2.00 36.1 87.2 <16.9 <25.0 <2.00 9690 <16.0 < 1.00 22.2 9.40 <10.0 4.60 11,900 .<20.0 <2.00 <10.0 6.40 <7.00 8.00 9300 <16.0 <2.00 46.9 " .-4 ------- Table 4 Inorganic Analytical Results Impoundment Area Surface Water1 .tll_iii='~~.. Arsenic 3.20 < 1.00 3.30 Beryllium '< 1.00 < 1.00 < 1.00 Cadmium <3.00 <4.40 <3.00 Chromium .' 20.1 16.8 15.9 Chromium + 23.8 Cobalt : <5.00 <2.00 <5.00 Copper : 188 121 171 Lead <3.20 1.80 <3.90 Manganese 125 70.7 115 Nickel 440 206 364 Thallium .<2.00 <2.00 <2.00 Zinc 57.0 23.9 49.6 tAll values are in ug/kg. ]M~:::::!lilpfUJI:m]m; . . 1.90 < 1.00 <2.0 10.0 2.00 <6.20 113 <2.00 83.1 229 < 1.00 32.4 3.30 < 1.00 <3.00 15.9 <5.00 167 <4.10 114 368 2.00 47.0 I ! . , I, . -- <2.10 . 110 <2.00 '87.6 210 < 1.00 . 34.9 co ------- Concentrations of three voiatile orgahic compounds were detected in the Slough surface water samples collected during both sampling events. The maximum concentrations were cis-1, 2-dichloroethane (0.8 ppb), trichloroethane (2 ppb), and tetrachloroethane (3 ppb). No semi-volatile organic compounds were detected. 4. Surface Water and Groundwater Results Summary . '. .. '.',". Conta~i~ation le~els' resultir;'lg f~~m si.te activ.ities appear to nave decr~aSed from. . . - j~;:i'~"i~~~~6~~:~~~~_~2f~4~~iJ1t~~~y,..,;,....,.. . wells were below MCLs. The sh~ill()w aquifer beneath the site contain'ed elevated levers of' . nickel. Concentrations in IB-6 were above the MCL for nickel (100 ppb). Nickel concentrations in the pond water were also elevated. Manganese is the other. contaminant.of note in the groundwater. High levels were found in the Troutdale .aquifer upgradient and downgradient from the site. The source of the manganese is unknown. VII. REGULATORY REQUIREMENTS FOR ADDRESSING SITE RISKS . . EPA's National Oil and Hazardous Substance Contingency Plan (NCP), found in 40 C.F.R. Part 300, requires that the site's remediation goals are protective of human health and the environment. For water, contaminant concentrations are compared to existing criteria such as the Safe Drinking Water Act Maximum Contaminant Level Goals (MCLGs). However, there are no corresponding criteria for soils. Federal remediation standards for cancer-causing chemicals are usually established by setting contaminant concentrations at levels that ensure cancer risks are maintained at or below acceptable I.evels. The EPA acceptable risk range for an increase in the potential number of cases of cancer is between one-in-ten-thousand excess cancers per ten thousand people, and one-in-one- million excess cancers per one million people. For non carcinogenic toxic effects, the effects from the contaminants are measured by a .Hazard Index., and cleanup levels are set at a Hazard Index of 1. An exceedance of the Hazard Index of 1 indicates that there may be toxic effects from exposure. Adverse health effects would not be expected if the Hazard Index is less than or equal to 1. VIII. SUMMARY OF SITE RISKS A. Risk Assessment Rationale The risks to human health and the environment at the Allied Plating Superfund Site Prior to the Removal Action are described in the site-specific Remedial Investigation Baseline Risk Assessment, which was completed in 1992 by URS Consultants, Inc., for EPA, using EPA guidance. This document contains a Human Health Risk Assessment (Risk Assessment) and an Ecological Evaluation. The Risk Assessment followed a four step process: .1) an evaluation of data to identify co'ntaminants which are qtpo~e~tial concern at the site, 2)' an exposure assessment to identify current and potential exposure ------- " . . . .' ." , " I ...-' , . pathways and exposure estimates, 3) a toxicity assessments for the chemicals of potential concern to determine concentrations having adverse effects, and 4) a risk characterization, which integrates the three earlier steps to summarize the current and potential risks posed by hazardous substances at the site, The results of this Risk Assessment were used to determine the need for a '. Removal Action at the 'site. "Following the Removal Action, a final evalu.ati0rl of t~~ .:~ :,: residu~1 site risks V-jas' perfocmed :to ~nsur~ that the site met the .selected ,clean.up ,. . , ' , ...,,'." ~~~J~~' ectiv.~,...;t7he':~S'u~o" t~" "'Ii' ' ,0" ...«(., 'sl(A$SA~sment~e:.discussedJ)eJp~~.~, >t' , "'f~;,~~:. "f.'<'~' o".~:,~.J:~o.I"~~'~">j\f. ...-i". 0 0 .' . .' :y.~,~,~~o~4~;,!....~f'~"'''! , " ErreslJ sopt- the :T1na nsK eva1ua on are. IscuSse, 0'1'1 SeCtton ox; ',~ '''', '. : ~.", " . " ", """. .,..' . .' .'. .- ,,~.... '",' , ~. . .' . . .', ". ° .' ;.. . "", ,'.':':. ' .0.'." ,; . B. Determination of Contaminants of Concern . The s-oits, groundwater and surface water at the Allied Plating Site were sampled during the RI for potential contaminants, including metals, inorganics, and volatile and semi-volatile organics. The results were compared to EPA Region 10 preliminary screening concentrations (comparison concentrations for determining the significance of a contaminant) for water and soil. For the most part, screening concentrations for soil were based on a carcinogenic risk of 1 x 10.7 or a noncancer Hazard Index of 0.1; and those for water were based on a carcinogenic risk of 1 x 1 O~ or a noncancer Hazard Index of 0.1. The contaminants that were not eliminated on the basis of screening concentrations, were included in the risk assessment as contaminants of potential concern. The contaminants of potential concern identified in the risk assessment included the following: for soils, antimony, arsenic, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, nickel, and cyanide; for groundwater, manganese. C. Exposure Assessment The objective of the exposure assessment was to estimate the type and magnitude of exposures from the site. This included identifying land usage, exposure routes, potentially exposed populations, estimating exposure point concentrations (contaminant concentrations that the affected individual is exposed to), and describing assumptions about exposure frequency and duration of exposure. 1. Land Usage The site is currently used for industriaJ purposes. It can be distinguished by two primary areas: the -Layout Area- and -'mpoundment Area-. The layout area is occupied by a crane maintenance facility. The impoundment area, occupying the northern end of the site, contained a pond, which was known to have received plating wastes fro'm the Allied Plating facility. This area is not used as part. of current site operations. . ------- Drinking water in the vicinity of the'site is provided by the city of Portland. Nearby water supply wells are used for industrial processes and irrigation. In the future, it is most probable that the area will remain industrial. However, residential use of the area is a remote possibility. Therefore the risk assessment examined both a future industrial and a future residential scenario. 2. Exposure Pathways Land uses were used to determine exposure pathways for contact with the contaminants. Exposure pathways and associated assumptions for each land use are identified in Table 5 and Figure 5. These exposure pathways were then combined into the following scenarios: Current Industrial Scenario: Employees would receive exposures dermally, via ingestion, or by inhalation of contaminants in soil. Because exposure to contaminated groundwater currently does not occur, groundwater was not assessed as a possible route of exposure. Future Industrial Scenario: In addition to the exposures described above, the scenario assumes the ingestion of groundwater. Future Residential Scenario: Residential exposure pathways are the same as the Future Industrial pathways. In addition, because residential usage of potable water is likely to include bathing, inhalation of volatile contaminants from groundwater was an additional pathway considered for the residential scenario. 3. Exposure Point Concentrations: Exposure point concentrations were estimated for average and reasonable maximum exposures. The average case exposure (ACE) represents average exposure associated with the site. The reasonable maximum exposure (RME) is a worst case estimate of exposure which is still within the range.of..ppssible exposures. EPA guidance recommends that decisions regarding remediation at Superfund sites should be based on RME estimates rather the average, since a significant portion of the population may experience exposures higher than the ACE. However, an evaluation based on the average is useful for illustrating the degree of uncertainty associated with the RME. ACE and RME cases were evaluated for the residential land use scenario. Only the RME case was evaluated for the industrial scenarios. For the exposure point concentrations, the arithmetic averages of the contaminant concentrations were used for the purpose of estimating average exposures (ACE) and the upper 95 percent confidence limit of this average was used to estimate re~!Jn~bl.e ------- Table 5 Summary of Pathway-Specific Exposure Assumptions' ::.::.:~i!'~!~~~:.:::i:illlj!:i:llil:i:jii::jll.j!.:i;i!::!:~I~~~~....::I...I..j.j;~~li"11.Y~:li: Soil Ingtition Pan. Inhalation G. Water Ingtition Inhalation (VOC) All Pathways Exposure Prequency days Ingestion Rate mg/day PEF m Ikg Inhalation Rate m Iday Exposure Prequency days Ingestion Rate L/day Exposure Prequency days Inhalation Rate m Iday Volatilization C. L/m Exposure Time minutes Exposure Frequency days Exposure Duration yr Body Weight kg child adult 100 50 IJE+O IJE+O IJB+. 20 20 20 275 350 250 1.4 2.0 I 275 350 .250 15 15 . . - J . J 10 10 - . 275 350 N N ". 6 9 24 2.S 15 70 70 70 .. " child adult child adult a Taken Crom U.S. EPA (1991h) and U.S. EPA (19918) guidanc:e unless otherwise Indic:ated. b Current industrial scenario: 1900 c:m2. Puture Industrial scenario: 5000 c:mZ' c: See Sec:tion 6.5.4 oC RI. d Taken rrom U.S. EPA Interim Guidanc:e ror Dermal Risk Assessment (U.S. EPA, 1991c:). ACE Average case exposure. RME Reasonable maximum exposure. I ------- ~'''''''''''''-'''''''''''''''''''''''''''''''''''':~'''''''''''''''''''''''''''',.,.,."".,.""",,,'.."'.-.'.. ".",.-.-..".,.,.,..,.,.,,,,,.,.,.,.,.,,,,,.,.,,,,""""'.'''''''''''''''-''-'-'''-~'''''~'-'-'-'4-'''-AA;.~#>''''''''''''-'''''''''''~"""""'''''''''l'...-.....".......,,,,.....,............,...,...,.....,.,.'.. ,'."-'.'...'.'.',"""'."',""'" .','","",,"'.'. > w a: :::> (f) o Q.. X W t- <..> w a: a :z ~ . ~ , i Air WIND TRANSPORT ~ VOlA1UZATION '.'.',""-'.'.'.','.'.'.'.'.'.'.','.','..'.'.'. ."",-,."",.,...,.,-,."""-""",,,'","""-.1","","''''...................'''''-',-,,--'......-.-._n,""".'A"""'.V.l".'.'...,..-.I"........'.'.'....'.v.-.'.""-,,,,'...'.'.','.-.v.".'.'.'.'.'.'.'.'.'...-...'.'.''''''.'.'"""-'.I".,.,...............-_v."""'''''''''''''''''~ ., w <..> a: :::> o (f) Upper Aquifer lower. Aquifer ~ 1 I ~ ; , , i ~ ~ i ~ > ~ j ~ ~ > .l ~ ~ t { I ~ . ! "-'...-.n'oVo/'..-.-.--_...--....d: Ingestion r ; ~ ~ ~ < ~ ! ; ~: i i I i ~ Soils Groundwater PEROOlATION lEAKAGE ~ < W ; :: a: ~ i ~ Ii ., ~ , x l W ~ t- ~ ~ <..> } ! W ~ ~ a:. ~ < - ~ ~ a ~ L__.J~M~'" ~ Dennal Contact .' I . . . ' ", . . '. . . .' . . - . . . . f-<;;%\~~-~~;(?. .,.' Huma~.H~lth~.EijM;tsure Pathways ". ".. : : ~., .,' :" ~ . -. ',' '. ~ ': ". .~" . .". . .'. -, . .', '. . . . AIled Ptdng . Portland: Oregon ..: ~ . '. -. .. ". .: :~' .", . ~.::. ",.. . :.: ;'" '.::.-~. ,::" ~ -:',"'., .:~;. . i-;;..~:'t. .:.-;;.",.~:,,,, ~_I'- . ".:~ :~'\;'.:~". . .:~<: .':,:~{" .':=-: - <~.;.:{;'?~l~~ ~..,. 23 , ." . ';':. - :~:':'i.,::... ------- maximum exposure (RME). These values are shown in Table 6. For current land use, the exposure point concentrations for soil were calculated using concentrations found in surface soil samples. The use of surface soil data assumes minimal disturbance of surface soil from site activities. For future land use, the exposure point concentrations for soil were <::alculated using concentrations found in surface, shallow, and composite samples taken from depths ranging to 3 feet. The use of soil samples from these depths assumes that construction of industrial or residential facilities on the site, along with grading, will result in disturbance of soils resulting in exposure to different soil depths, and mixing of soils. As the probability of using the shallow aquifer for a drinking water source was minimal, only...data for the Troutdale aquifer wells located on site were used for the . purposes of evaluating the risk of consuming groundwater under future land use scenarios. D. Toxicitv Assessment 1. Cancer Risks Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level by the chemical-specific cancer potency (slope) factors. Chemical-specific cancer potency factors have been developed by EPA from human' epiGemiological or animal studies. This information was obtained fr9JT1 EPA's Integrated Risk Information System (IRIS) and the Health Effects Assessment Summary Tables (HEAST). Risk estimates calculated from these potency factors reflect a conservative "upper boundu estimate of the risk posed by potentially carcinogenic compou~ds. That is, the true risk is very unlikely to be greater than the risk predicted and could be substantially lower. The resulting risk estimates are expressed in scientific notation (i.e. 1 x 10~. for 1/1,000,000; indicating that, in this example, an individual is not likely to have greater than a one in one million chance of developing cancer over his/her lifetime as a result of site-related exposure). Current EPA practice assumes Carcinogenic risks are additive between chemicals when assessing exposure to a mixture of hazardous substances. Therefore, cancer risks have been summed across chemicals and across exposure pathways. The carcinogens at the site were arsenic, beryllium, cadmium, hexavalent chromium, and nickel. . 2. Noncancer risks . . Potential concern for noncarcinogenic effects of a single contaminant JD a single medium is expressed as a Hazard Quotient. A Hazard .Quotient is calculated by' diViding ------- Table 6 Exposure Point Concentrations u~.?, . ,.;.' N " ...."..N ',......-., " Wf.X~9!.1 $iW~." ~>, ')19111, -...-, .,~" ". IJji . '. ....... .. ''''', AIIt1moIIy .5.11B+04 1.19B+o.s 1.98B + 04 3.91B+04 .5.32B+03 8.CI5B+03 4.1OB+CO 6.108+ 03 - - Not. 1 Not. 18+04 Anellie 4.468+04 8.01B+04 UtB+04 3.43B+04 1.778+03 3.118+CO 339B+03 4.S8B+03 - - o.as 1 . 48+1 8B+CO BeryitilllD 7.508+01 8.9S8+01 7.43B+01 8.06B+02 9.358+01 1.208+03 1JIB+02 9091B+02 6.21841 7.70841 0.02 28+1 '18+1 18+.5 Caclmlum 3.418+03 5.748+CO 1.238+03 3,.06B+03 1.048+02 1.418+CO .5.'NB+02 . 1.108+02 2.938+00 3.2'78+00 Not. 28.+0 2.18+S Not. OuomIum +. .5.698+ 06 1.068+07 2.608+06 4.10B+06 4.2'78 +04 1.768+04 12OB+04 $.268+04 - - Not. 48+3 Not. 48+3 O"omlum06 4.Q9B+04 7.648+04 1.8'78+04 2.9S8+04 3.07B+02 6.3OB+02 2.3OB+02 3.798+02 - - Not. 28+1 48+2 Not. {.-Cobalt 3.13B+04 4.358+04 1.S7B+ 04 3.OOB+04 2.61B+04 3.1'78+04 2.238+04 16,38+04 6.698+00 9.008+00 - - Not. US+, Copper 1.89B+07 3.638+07 8.89B+06 1.418+07 U4B+o.s 6.13B+1I5 2.62B+o.s 4.79B+05 - - Not. S8+2 Not. 28+' LcacI 1.808+o.s 2.868+o.s 1.7SB+o.s 2JIB+o.s .5.188+04 9.998+04 S.99I!+04 6JQB+04 .5ASB+OO 7.348+00 Not. Not. NA Not. ManPD- - - - - - - - - 4.788+03 6.68B+CO Not. 18+2 Not. m+, N"1Ctc1 43.58+06 a.so8+06 3.198+06 ~.os8+06 7,428+o.s 1,418+06 . .s.t18+o.s 9.128+o.s - ';- Not. 78+1 28+4 .58+.5 'IbaIlI1IID 3.31B+03 6.83B+03 1.878+03 3.07B+03 2.778+02 3.06B+02 2.7SB+02 S.QSB+02 9.66&01 t.008+00 Not. G.3 Not. 28+S Catboo Tetn- - - - - - - - - aJ3B.Ol U78+oo G.3 m+o .58+2 28+4 cII10rlcIe OIlorolorID - - - - - - - - .5.71841 7A6S41 G.3 28+1 18+4 m+.5 cPAli I.4.5B+03 1.478+03 I.39B+03 1.598+03 - .;.. lASB+CO 1.sOB+03 - - 0.7 Not. 68+0 Not. ACE .. ~\'Cn&C - upoIure RMB . ReuoDable awdmum exposure If'\ N ------- the human dose by the reference dose (RiO) or other suitable benchmark for noncarcinogenic health effects. RfDs, expressed in units of mgjkg-day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals, that are not expected to cause an appreciable risk of harmful effects during a lifetime. Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from contaminated drinking water), can be compared to the RfDs. RfDs are derived from human epidemiological studies or animal studies to which uncertainty factors have been applied (e.g., to account for the use of animal data to predict effects on humans). RfDs used in this risk assessment are from IRIS. The Hazard Quotients from site contaminants are then added within a media or across all media to which a population is likely to be exposed. This produces the Hazard Index. Adverse health effects are not expected to occur if the Hazard Index is less than 1. As the Hazard Index increases above 1, adverse effects become more likely. The chemicals at the site which could cause noncancer toxic .effects were antimony, arsenic, beryllium, cadmium, trivalent and hexavalent chromium, cobalt, copper, and nickel. E. Risk Characterization Estimated risks from all scenarios are shown in Table 7 1. Sitewide Risks The sitewide risks for current and future land use represenfihe sum of risks from exposure to impoundment area soil, I~yout soil, and groundwater on site. Assumptions were used to estimate the proportion of time spent in each of the two areas on site based on site usage. These assumptions were as follows: current Industrial scenario: 5 percent of time spent in the impoundment area and 95 percent. in the layout area '....'-. future industrial scenario: 50 percent of time spent in the impoundment area and 50 percent in the layout area, and ingestion of g~oundwater future residential scenario (ACE): 25 percent of time spent in the impoundment area and 75 percent in layout area, and ingestion of groundwater future residential scenario (RME): 50 percent of time spent in the impoundment area and 50 percent in the layout area, and ingestion of groundwater. Carcinogenic risk for all scen~rios was less than or equal to 1 x 10-4. r- - ------- ., Table "7 Carcinogenic Risk and Non Carcinogenic Risk Indices for Risk Assessment Scenarios :~~'m;~t "~~~i~b"{ 0.23 lx10~ 1.18 ; 8x10~ 0.18 8xl0~ ~4t t~&;~::~:~~f~~~i;~;~~~::;;~J;:;. 1.2 ~xlO~ 0.55 4xl0~ 0.14 8xl0~ 0.86 bl0'" 4.39 lxl0~ 3.45 1x10~ 0.49 4x10~ 1.41 4x10"" 1~(~:If.mi~f.]~~~~W' 1.3 lxl0~ 0.71 1xl0~ 0.16 4xl0" 1.01 5x1r scenario,",>.,".,"'W~;~iK' ~i~~~~~i;~";J:;:i:t] ..... N ------- Noncarcinogenic Hazard Indices exceed a Hazard Index of 1 except the current industrial land use scenario, which was less than 1. The Risk Assessment determined that the risk associated with the site resulted from the contamination in the impoundment area. The risks from the two site areas and groundwater are discussed below. 2. Impoundment Area The carcinogenic risks associated with the industrial and future residential ACE scenarios were less than 1x10-4. The future residential RME risk was greater than 1x10-4. The contaminants contributing to the majority of the carcinogenic risks were arsenic, nickel, chromium +6, and PAHs. Hazard Indices for both the current industrial and future residential RME scenarios exceeded 1. The future industrial and future residential ACE scenarios were less than 1. The chemicals contributing to the majority of the Hazard Indices were copper, nickel, cobalt, arsenic, and antimony. These risk values were based on exposure to an averaged concentration and include assumptions related to mixing the soil based on potential site activity. The plating waste in the impoundment area was present as a surface layer." Therefore a separate analysis was run to determine the risks associated with one of these "hot spots". Table 8 shows the RME soil concentrations of inorganic contaminants of concern compared with the concentrations in Location 1526, a sample of plating waste in the impoundment area. The table also shows the noncarcinogenic Hazard Indices and the carcinogenic risks associated with these contaminant concentrations. The residential and industrial Hazard Indices exceed one (12.21 for residential exposure and 1.77 for industrial exposure). The majority of the risk resulted from copper, nickel and arsenic. The cancer risk from the plating waste were greater thai11x10-4 for the residential scenario and less than 1 x1 0-4 for the industrial scenario. "a;'., 3. Layout Area The carcinogenic risk values for layout area soil were below 1x10-4. The major contaminants contributing to the risk were nickel, P AHs, arsenic, and beryllium. " Noncancer Hazard Indices were less than 1. Chemicals contributing to these Hazard Indices were cobalt, nickel, antimony, "arsenic. and copper. r ------- Table 8. Risk Results for Inorganic Contaminants 01 Potential Concern in Hot Spot I;c...~. AIIlimony \.\98+05 1.&\8+04 0.66 o.U 0.10 - ' , - 1918+04 '..18t04 a.oo 0,)6 0.13 - - Atwnic '.0\8+04 1.448 + 03 \.&0 0.1) 0.23 2.98134S S~64S '.4'8tOf 1."8t03 U.o 0..1 L'76 ,... ,4.UB044 Beryllium I.9SS + 02 &.1OS + 02 0.92 '.69E4S 0.00 7.02s.47 "~1W7 '.068+02 1J08+02 1.02 S.98004 ~ SM8006 SJ98.CIS C.dmium $.74S+03 7.74S+03 US O.~ 0.00 1.64 s.47 2.218047 '.060+03 7.'48-43 2.S, G.02 o.os 1.48&07. . 1'HB47 Qromium.) 1.06S+07 \.74S+07 \.64 0.00j 0.0\ - 4.\OOt06 1.'H8t07 4.24 G.02 CI.OI - '. - ,- o.romium~ 7.64S+04 \JZS+03 \.n 0.007 0.0\ \.~E4S 2.S1e.GS 2.9$8+04 1.n8t05 ..., 0.02 0.09 'Jm411 4J68.4S Coball 4J$S+04 4J\8+04 \,04 0.16 0.17 - - 1OO8+0f 4J\8+04 1JO 0.16 G.34 - - Copper 3.638 + 07 7.O\S+07 \,93 0.48 0.93 - - \.4\8+07 7.o\Bt07 .' 437 lJ9 6,91 - - Lud U6E+Cti 4,0\S+03 \,40 - - - - U1Bt03 4.o18t05 , t.60 - - - - Nicke' 8J08+06 9J98+06 \.\0 Ul 0.23 U4E4S U6B04S S.03B+06 939B+06 l.u 0.92 1.71 ' 3J84S' U680QS Thallium 6.&38+03 USB + 04 \.83 0.04 0.09 - - '.078 t 03 1.2.58+04 4.07 O.U o.6S - - TOT AI. b 1.18 1.77 4E4S 18004 14' 12.21 2&Of U1B-4 " 0'\ N . 15-26 is a sample of plating waste from the impoundment area b Risk numbers have been rounded for the table, column totals calculated from unrounded numbers. I, ------- 4. Groundwater The carcinogenic risks associated with groundwater ingestion were below 1x10-4. Beryllium contributed the majority of the risk. However, beryllium was not found on site at elevated levels, and therefore its presence in the groundwater was assumed to result from non-site related factors. .. The Hazard Index under the future residential RME scenario exceeded 1. The majority of the risk was from manganese, which was located at high concentrations in the groundwater both upgradient and downgradient from the site. The shallow aquifer beneath the impoundment area contained nickel above federal drinking water standards. Because the aquifer is shallow and not widespread, it is unlikely that the shallow aquifer would be used for a drinking water supply well. Therefore, the risk from nickel was not included in the Risk Assessment. F. Risk Assessment Uncertainties The accuracy of the risk characterization depends in large part on the accuracy and representativeness of the sampling, exposure, and toxicological data. Most assumptions were intentionally conservative, so the risk assessment will be more likely to overestimate risk than to underestimate it. Uncertainties and their origins are discussed below. 1. Data Evaluation Several of the factors adding uncertainty to the estimates tend to result in overestimation of the exposure. These include: the directed nature of the sampling program, the use of upper 95th percentile confidence limits or the reasonable maximum exposures (RME) for the source concentrations, the use of many 95th-percentile values in the exposure estimation calculations, and the use of the steady state assumption for source concentration estimates. ''''-'. One factor that could lead to underestimation of the exposures is the use of sample quantitation limits that could result in missing low concentrations of some compounds that might pose significant risks. The cumulative effect of all exposure uncertainties most likely is to overestimate rather than underestimate th~ true potential. . exposures. 2. Toxicity Assessment Uncertainties The basic uncertainties underlying the assessment of the toxicity of a chemical indude uncertainties arising from the design, execution or relevance of the ~_cien~fic studies that form. the basis of the assessment; and uncertainties involved in extrapolating ------- from the underlying scientific studies to the exposure situation being evaluated, including variable responses to chemical exposures within human and animal populations, between species, and between routes of exposure. Risks were assumed to be additive across multiple chemicals. In reality, exposures to multiple chemicals can cause risks that are less than additive (antagonism) or more than additive (synergism). However, in the absence of data on a specific chemical mixture, the assumption of additive risk is commonly used. Assuming additive risks may underestimate or overestimate risk. G. Human Health Risk Conclusions Based on the Risk Assessmp,nt, the Allied Plating facility was a moderate risk site. The plating waste layer in the impoundment area posed a Hazard Index above 1 for both the residential and industrial scenario (12.21 for residential and 1.77 for industrial), and a cancer risk);Jreater than 1x10-4 for the residential scenario (5.21x10-4). The layout area posed an acceptable risk; Hazard Indices were less than 1 and . carcinogenic risk was less than 1 x1 0-4. Groundwater posed a carcinogenic risk less than 1x10-4. The Hazard Index associated with drinking the groundwater was associated with manganese which is not a site related contaminant, and therefore would not be the focus of any site specific remedy.. IX. ECOLOGICAL ASSESSMENT A. Ecoloaical Profile Ecological conditions in the vicinity of the Allied Plating site can be categorized into the following three kinds of habitats: An urban industrial area, which includes the site itself, a backfiil area north of the site, and bordering properties to the south, east, and west of the site; A riparian area (the bank of the Slough) that occurs to the north of the backfill area; and . The Columbia Slough. The urban industrial area contains sparse habitat suitable for fish and wildlife populations. Bullfrogs were seen in the pond, and vegetation in this urban industrial.area has been limited to shrubs, brush, and dense blackberry patches along fence rows. Riparian communities occur nearly continuously along the entire length of the Slough. These vegetative communities are highly valued ecological resources because they act as a buffer between the. slough waters and adjacent lands. Veg~~~tiv~ r~parian . ------- communities also provide habitat for a variety of wildlife species, and are important in the life history of numerous birds, mammals, fish, reptiles, amphibians, and insects. The Columbia Slough is a turbid, slow-moving, tidally influenced stream. Animal communities that are highly dependent on the slough habitat include plankton, benthic invertebrates, fish, birds and mammals. 8. Data Evaluation For soils and sediments, the focus of the qualitative evaluation was on relative concentrations of contaminants in soil as judged by comparisons with available information for background levels, or available sediment quality values. The major limitation to this approach is that relative ranking based on elevations above background may not rep!esent relative ranking based on potential toxicity. For surface water, the evaluation of chemical contaminants was based on comparisons with chemical-specific ambient water quality criteria (AWQC) for the protection of aquatic organisms. C. Ecological Assessment Based on their site to background ratios of 10 to 100, and available toxicity information, the trace metals chromium, selenium, arsenic, and mercury in site soils from the impoundment area had the highest potential toxicity to wildlife. Based on site.:to-background and ratios of 10 to 100, PAHs were the substances of greatest concern from the riparian area. The PAHs are not site related. For the Slough sediments, with the exception of 2-butanone, average concentrations of all chetnicals of potential concern for which sediment quality values were available exceeded their corresponding sediment quality values. However, within the site vicinity, the upgradient and downgradient sediment contaminant concentrations were similar, therefore contamination could not be linked wfth certainty to the site. For pond surface water, average concentrations of the following substances exceeded AWQC values: beryllium, cadmium, hexavalent chromium, copper, nickel and lead. These comparisons indicate that metal contamination concern in the pond water' were potentially hazardous to aquatic biota. For groundwater, the maximum concentrations of bis(2-ethylhexyl)phthalate and cadmium exceeded AWQC. For the Columbia Slough, concentrations of cadmium and lead in the surface water exceeded AWQC values. However, because of the general poor water quafity 'conditions ------- in the Slough, and the number of other potential contaminant sources, it is doubtful that increased levels of cadmium and lead in Slough surface waters can be attributed solely to historical activities at the Allied Plating site. x. REMOVAL ACTION A. Determination to Perform a Removal Action The Risk Assessment determined that the impoundment area ~as responsible for the majority of the risks associated with the site. The layer of plating waste covering the impoundment area posed a potential health threat. The risk associated with the plating waste in the impoundment area met the criteria for a Removal Action. After consideration of other potential cleanup options, EPA determined that remediating the site as a pre- Record of De:cision Removal Action was the preferred option. The prospect of performing the pre-ROD Removal Action for final site cleanup was approved by the EPA Superfund Revitalization Organization at EPA Headquarters under the Superfund Accelerated Cleanup Model (SACM) program. A Removal Action Memo which approved the Removal Action was signed in October 1992. EPA signed an interagency agreement (lAG) with the U.S. Army Corps of Engineers (USACE), Missouri River Division, to perform the Removal Action at the Allied Plating site using the USACE Rapid Response Program. The Rapid Response Program is a quick turnaround contact mechanism for site cleanup. . 8. Action Levels The selected goal of the Removal Action was to clean the site so that the Hazard Index would be less than or equal to 1, and the excess cancer risk would' be less than or equal to 1 x1 0-4 for the industrial scenario. EP A determined that the use of the industrial scenario was appropriate based on the fact that the site and vicinity historically were, and currently are used for industrial purposes, and would likely stay that way in the Mure. In . addition, Mure use of the property for building residences would require filling the impoundment area to the grade of the layout area or the. grade. of MLK Boulevard (between 5 and 30 feet of fill). Thus, there would not be contact with any residual contamination. 'Based on information from the Risk Assessment, the contaminants which posed the majority of the site risk were antimony, arsenic, copper and nickel. Their removal would leave the site at an acceptable risk level. The action levels for the Removal Action were based on the assumption that these four major contaminants were present in equally distributed concentrations. Thus, with four contaminants, the cleanup levels were set at 1/4 the individual contaminant values equal to a Hazard Index of 1 (these values were lower than those corresponding to the acceptable cancer risk). The ra!i.onale for this approach is that the cleanup would result in a Hazard Index that at moSt would be 1 ------- (4 x 1/4), this assumes an additive effect from the chemicals. Excavation continued until concentrations were below the following: Antimony Arsenic Copper Nickel 200 mg/kg 150 mg/kg 20,000 mg/kg 10,000 mg/kg The site remediation progress was monitored and evaluated using an X-Ray Fluorescence Spectrophotometer (XRF), a field screening tool. Confirmational samples to provide substantiation that the removal objectives were met were sent to an EPA approved lab for analysis. - C. Removal Action Boundaries The impoundment area was divided into four sections for the Removal Action (Figure 6). The delineations were based on the equipment and procedures needed for each area. Flat Area - the west side of the pond, relatively dry area covered with dead, dry grass and approximately six inches of plating waste , ' Burn Pit - a shallow disposal pit at the south end of the pond containing burned debris, plating waste and soil Pond - surface liquid impoundment containing approximately two feet of water and plating waste contaminated sediment East Hillside - the steep slope leading to MLK Boulevard, covered with brush, debris, and a six inch layer of plating waste. D. Removal Activities 1. Excavation of Contaminated material Cleanup at the site commenced on Friday, October 23, 1992. The first step of cleanup was the dewatering and exCavation of the pond. Because the summer preceding' the Removal Action had been hot and dry, the pond volume was approximately 20% of the level found during the RI. A six inch pump was used to pump the liquids and sediments from the pond to a mixing tank where ferric chloride and lime were added to coagulate the solids. The resulting slurry was then pumped through a filter press to remove the solids. The filter cake. (from the pond sediments) was stockpil~jor .disposal and the water placed into 20,000 gallon. baker :tanks for storage. When needed to Sid in ------- - I I - I L , ' I -.- -.- -1--- -.- -1- '--l:,:- -1-. ".: ;'" .- , I 'I' ~ . '.. . .,,\:- '~';(~~.J/" " I .....' ,.' . " . ~. '. ~":::':.\~",:', ' ,"':,",i\i:H'~':~' ' , " '/<~.' . ./'" :::;;~:....:!:~~. ; ~ ~\))~ft¥':. """ ',:, "',: '" :t.,' . ", .. '"," ." " 50 I o I ! GRAPHIC SCACEl~~ (CONTOUR INTERVAL'. 1 FOOT) / ., , ,'/' /'" ,,~ 0",..... "",n1 Figure 6 A ,.tlnn 1i',YI'nvntion Locations / : ~ ; '~2a..'.;;.~. . NORTH "~,:, ':.: ! : , ~ ~' , , , I , ,. . 0' ------- '. sediment removal, the water was pumped'through a filter, the pH was adjusted, and the water was piped back to the pond where the pressure from the resulting water jet was used to slurry the sediments. During the dewatering process, as the water level dropped, an excavator pushed the exposed surfaces of the pond edges toward the center of the pond. The combination of slurrying the sediments, pumping out water and sediments, and "squeegeeing" of the sediments to the middle, allowed the edges of the pond to be continually backfilled with 12" to 18" diameter rock (brought in from a local quarry), bringing both ends toward the middle, culminating in complete backfill. At the end of the process, all of the pond water had been removed and stored in baker tanks. 70,000 gallons of pond water and 120 tons of filter cake produced from the dewatering operation were generated for disposal. The flat area was excavated to a depth of six inches which included grass, plating waste and soil around the grass roots. Approximately 285 tons of soil and debris were excavated. The burn pit was excavated to a depth of three feet and then backfilled with 6" to 9" diameter rock. Approximately 175 tons of soil and debris were excavated. The excavator was used to scrape six inches to one foot from dry sediment areas around the perimeter of the pond during pond dewatering. Approximately 280 tons of soil were excavated. Backfilling of the pond allowed access to the east hillside for the excavator to scrape six inches of debris, plating waste, and soil from alQng the sloped hillside area. The approximate volume of soil and debris removed for disposal on the east hillside was 190 tons. . The impoundment area Oncluding the former pond) was then backfilled with one foot of 6" to 9" diameter rock. The rock was leveled and graded with a bulldozer so that no low areas were visible. Approximately 5600 tons of rock were placed as backfill. Following backfill, the east hillside was sprayed with a -State specification grass seed mixture to prevent erosion. 2. Disposal The solid waste was either classified as debris contaminated with FOO6 plating wastes for landfilling without treatment under the Hazardous Debris case-by-case capacity variance, or as soil contaminated with FOO6 waste requiring stabilization prior to landfilling. Approximately 1100 tons of material was disposed of at Envirosafe Services, Inc., in Grandview, Idaho. , ------- The 70,000 gallons of water from the pond was disposed of at Tektronix, a treatment, storage and disposal facility in Beaverton, Oregon. 3. Final Site Analysis Based on the results of the confirmational samples which were taken when the XRF samples indicated the areas were clean. the cleanup exceeded the cleanup goals. The results of the confirmational samples are shown in Table 9. The locations of these samples and the XRF samples are shown on Figure 7. Following the completion of the Removal Action. EPA conducted a risk assessment on the contaminant concentrations remaining in the surlace soils of the impoundment area. The analysis assumed a lifetime exposure to the remaining residual contaminant concentrations. The results are shown in Table 10 (see also Appendix B). Under the industrial scenario. the impoundment area poses a risk of 8x10-o and a Hazard Index of 0.35. For the residential scenario. the impoundment area poses a risk of 8x10-5 and a Hazard Index of 2.5. These numbers are extremely conservative and were calculated to provide a worst case scenario. The actual risk likely would be much lower based on the fact that 1) the remaining contamination is now under one or more feet of rock. thus preventing direct exposure to it; and 2) the area fills with water, and is below the surrounding grade, and so Mure residential or industrial use would require additional backfilling, resulting in covering the residual contamination by an additional 5 or more feet of backfill. 4. Deed Restriction Followi~g the Removal Action. the site owner placed a deed restriction on the property to prevent the use of the shallow aquifer for drinking water purposes, The deed restriction contains the following language: . The undersigned as owners of said tracts agree to burden the above described real property with a restriction prohibiting the use of a well for drinking water unless the top of the screened interval is deeper than 20'. below mean sea level, and the water from the well is tested to ensure that it meets drinking water standards before use. . The required interval in the deed restriction will prevent screening of future wells in the shallow aquifer. XI. DETERMINATION THAT NO FURTHER ACTION IS APPROPRIATE EPA's determination of No Further Action for the Allied Plating Site is based on the following: . ~ 37 ------- Table .9 Removal Action Confirmattonal Sampling Results ! , .. , .:'A4.:-"'..,:::;'~7i::;:i:~~;:i:: i~::I~Q';!:I~I:: itm~:1~jl~;;1. Analyte 'AI Arsenic 17.8 16.4 20.4 17 29.8 23 40.9 12 24.7 19.6 12 33.6 Cadmium 2.66 2.07 1.97 1 1.91 2.12 4.72 1 ' 3.73 2.17 0.91 3.72. : Chromium 76.6 76.1 2220 2010 1150 1280 . 5590 166 861 210 219 SUO Copper 553 460 4580 3200 7300 7290 12000 876 4270 1930 318 11800 co Lead 226 169 96.5 73.1 71.4 43.1 203 103 158 127 72.7 234. M Nickel 912 756 1720 973 2840 2300 4960 586 2210 5410 722 2260 Antimony 3 3 14 14 4.5 6.1 36.5 3 3 3 3 37.3 ------- o 2 3 4 5 6 7 8 9 10 11 12 AA . . . .- Flat Area A .. . . .. . .. . . \ . Pond B . . . . . . . . . . c . . . . .. . .. .. .. D .. . . .. . . .. .. A Burn pit 0 (" E . . . . . . Hillside F . . . . . ",,' .. G .. . . H . . . . .. conf irmational sample . ~ o SCALE -u . 50 FU:I' --' ..- ... .......,.," ..-...'". Figure 7 Removal Action ~,.rl>l>nlnn rant1 ""n..f':p.-~.I~__I "-...--" ------- Table 10 Residual Risk for the Post Removal Impoundment Area I " Milit.:.. Antimony 3 26 26 Arsenic 12 28 28 Cadmium 1 . 5 2 3 3 Chromium 76 5590 1581 13,161 5590 Copper 318 12,000 4548 21,817 12,000 Lead 43 234 , 131 190 190 Nickel 586 5410 2137 3928 3928 1 97 23 199 97 Risk Totals 0.2 0.3 0:02 0;06 1.2 0.03 7.7x10.$ 0.05 .8.2xl0~ 0.003 . . 0.008 0 0.16 ~ '. 0.10 0.002 7.7x10.s 0.35 8.2xl0~ 0.7 0.02 2.6 1 Minimum concentration measured in confirmation samples. 2 Maximum concentration measured in confirmation samples. . 3 Mean concentration calculated from confirmation samples. 4 95% upper confidence limit valu~ calculated from the confirmational samples. , 5 Exposure Point Concentration: value is either the 95% UCL value of the confirmational samples, or if the 95% UCL ------- 1) The Removal Action achieved a soil cleanup level in the impoundment area. which left the health threat associated with site related contaminants well below a 1x10-4 excess cancer risk and a Hazard Index of 1 for the industrial scenario. EPA expects the site usage to remain industrial in the future. 2) The results of the Remedial Investigation and Risk Assessment indicated that all other areas of the site were below a 1x10-4 risk and below a HazardJndex of 1 for all scenarios. 3) Site related groundwater contamination above federal drinking water standards was present in only one well, which was contaminated with nickel. The well was in the shallow aquifer in the vicinity of the pond. The concentration of nickel is expected to drop now that the source of contamination has been removed (the plating_waste). No one is currently drinking the water, and the deed restriction should- prevent future use of the groundwater. 4) Although the manganese in the groundwater poses a potential health threat, the contaminant is widespread in the groundwater in the area and is not related to the historical activities at the site. Based on EPA's Risk Assessment for the site, which shows that the Removal Action resulted in a risk in the 10-0 range, and a Hazard Index of less than 1 for the selected industrial scenario, EP A believes that no remedial action is necessary at this site to protect human health and the environment. In light of EPA's decision not to select a remedial action, the requirements of Section 121 of CERCLA including the ARARs provisions of Section 121(d)(2) of CERCL4. are not triggered. XII. CESSATION OF GROUt-.lDWATER MONITORING Although nickel, a site related contaminant, was found in the groundwater beneath the site, EPA does not plan to perform additional groundwater monitoring. This decision. is based on the following: 0...:.- 1) The plating waste which was the source of site related contamination in the groundwater has been removed from the site. Therefore, any remaining .Ievels of contamination in the groundwater are expected to decrease. - 2) Only one well contained nickel above federal drinking water standards. The well is in the shallow aquifer beneath the impoundment area. It is unlikely that this aquifer will be used for a water supply well. The residences and businesses in the area are on the city water supply, and the deed restriction should keep the shallow aquifer from being used in the future. Although both the shallow aquifer and deeper aquifer beneath the site contain concentrations ofmanganes~_abqv~ health based levels, the. manganese is not site related~ ... . ------- XIII. 5 YEAR REVIEW A 5 year review will be conducted to ensure that the land use for the site remains industrial. XIV. EXPLANATION OF SIGNIFICANT DIFFERENCES There are no differences from the preferred alternative in the Proposed Plan. "~: .. . ..0. . ------- Appendix A Responsiveness Summary -- . ...: . ~ . ------- I. Overview Allied Plating Respbnsiveness Summary The purpose of this Responsiveness Summary is to summarize and respond to comments received during the comment period held by the Environmental Protection Agency (EPA) from April 26, to May 26, 1993, regarding EPA's Proposed pian for no further action for the Allied Plating Superfund site. The Proposed Plan was based on information in the Remedial Investigation report prepared for the site, and on the documented results of a Removal Action taken at the site from October 20, to November 10, 1992. These documents were made available to the public in the Administrative Record, located in the information repositories maintained in the EPA Records Center in Seattle, and ~t Portland State University's Miller Ubrary, and the N.E. Neighborhood Association in Portland, Oregon. The notice of availability of these documents was published in The Oregonian on April 29, 1993. The proposed Plan and newspaper notice offered the option of having a pubic meeting. However, a meeting was not requested by the public. II. Background on Community Involvement To date, the following community relations activities have been conducted by EPA at the Allied Plating site: February 1987 , September 1987 March 1990 November 1990 June 1991 October 1991 October 1992 EPA distributed a fact sheet announcing the nomination of the site to the National Priorities Ust. Community Relations Plan published, which included interyiews from the community and local officials. . , EP A released a fact sheet announcing the site was placed on the National Priorities Ust. EPA distributed a fact sheet announcing the beginning of the AI field work. EPA released a fact sheet, describing the preliminary results of the AI. Community Relations Plan Schedule updated. EPA.mailed a fact sheet announcing the beginning of the Aemoval Action at the site. ~ ------- April 26, 1993 EPA mailed the Proposed Plan for No Further Action. In the Proposed Plan, EPA offered the opportunity for a public meeting. No request was made. April 28, 1993 EP A published a newspaper notice in The Oregonian announcing the Public Comment Period and the opportunity for a public meeting. April 26, 1993 Public Comment Period begins. May 26, 1993 Public Comment Period ends. June 1993 Responsiveness Summary prepared. III. Summary- of Public Comments and Lead Agency Response. There were no public comments submitted during the public comment period held from April 26 to May 26, 1993. There was no request for a public meeting, and no oral comments were made. ------- " . . Appendix B Post Removal Risk Assessment . ~. " . ------- ,,\I:;'.., ,f.. ~.{. ;-- ~ &0 ~~~ o '" ~. " o~ «'-1- ,\: 'AI( "00\(;.<' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle. Washington 98101 June 3, 1993 ~ E C E ~ \IT ~.,. :) Reply to Attn. of: ES-098 JU~ .0..4. 19SJ MEMORANDUM SUPERfUND Rf}~fDIAL 8:-:;\;,;C;., SUBJECT: Residual Risk Calculations for Allied Plating Soil Carol sweene~ Health and Environmental Assessment Program; ESD .: FROM: TO: Kevin Rochlin, Remedial Project Manager Superfund Remedial Branch, HWD The attached tables provide calculations of risk for soil left on site after the removal. Because a layer of gravel was emplaced following the removal so that the contaminated soil surface is covered, there is not a complete pathway for human exposure. . Under these current conditions there is little exposure to this soil and therefore little risk.' In response to your request for quantitative evaluation of risk based on the concentrations in the residual soil layer, calculatio~s are shown in the attached tables using the concentration data that you provided. These exposures. and risks would only occur if the gravel were removed or disturbed so that the soil surface. became available for human contact. Other assumptions inherent in the attached calculations include the following: "";':. - Locations sampled are representative of the distribution of contaminant concentrations throughout the site, and distribution of contaminant concentrations is approximately lognormal. - An exposed individual moves throughout the site with an equal chance of contacting soil with any of the concentrations from the distribution. - The exposed individual lives or works at the site for a chronic time 'period and. has a'rea~onably high contact rate and exposure frequency,., consistent;.: , ~.it;.h. reasonable maxi1num" . '.. exposures eRNE). in'; SUPerfund "S~ndard' Default Exposure:," '" Factors (05.WER Direc.tive:" No." 928~~'6~03,"19~1) . . .' ." ------- Results Table 1 shows concentrations of inorganics in soil for twelve sampling points (data provided by you) and summary statistics for this data set. Based on this data and assumptions identified above, exposure point concentrations were developed using 95% Upper confidence limit on the mean (calculated. according to OSWER Directive No. 9285.7-081), or, if this statistic exceeded the maximum sample, using the maximum sample concentration. Table 2 presents EPA reference doses and cancer potency slope factors for oral exposure to these contaminants, exposure point concentrations, and RME risks for residential and industrial exposure scenarios. For the residential scenario, the highest hazard quotient (HQ) calculated is for copper, with a result of 1.2. The HQ for nickel is 0.7. Considering the low precision associated with reference doses, both of these HQs could be said to equal one. Exposures to Copper exceeding the reference dose are associated with gastrointestinal distress, an adverse but not very severe effect. The reference dose for nickel incorporates uncertainty and modifying factors totaling 300, which means that the no observed effect level is lower than the exposure calculated here by a factor of 300. . For the industial scenario, no non-cancer hazard quotient exceeds 0.2. Uncertainties in this Assessment - The chronic RME factors do not represent short-term higher exposures that may occur for a child with a high soil ingestion rate. Chronic risk calculations therefore may not be protective against effects from a contaminant such as cyanide with potential for acute or subchronic effects. - These risk calculations represent exposure to contaminants through a single pathway, incidental ingestion of soil. Other pathways of exposure, such as dermal contact or inhalation of dust, would result in additional exposure to an individual at the site. However,- these other pathways are expected to contribute much less than the ingestion pathway. The physical characteristics of the site are such that there is little potential for generation of airborne dust, as documented in the remedial investigation (RI) report, and therefore little potential for inhalation of contaminants.. Dermal absorption of inorganic contaminants is in general expected .to be small relat~ve t~ ingestion' exposures for soil... Therefore, ~.this single-pathway quantitative. assessment .isbelieved to be protective of all pathway~ of exposure. .. ------- Different species of chromium have different toxicity, but speciation of chromium in soil is uncertain. Reference doses for non-cancer effects of chromium are different for hexavalent vs. trivalent chromium. Risk calculations in Table 2 provide an estimate assuming that most chromium in residual contaminated soil is trivalent, with one percent of chromium in soil hexavalent, consistent with information on speciation provided in the RI. - EPA has not evaluated oral carcinogenicity of chromium. Attachments (2) . ------- EPA Region 10, 6/3/93 Table 1. Allied Plating Residual Soil Contamination: Concentrations and Summary Statistics Che"mlcal Concentration (ma/ka) M1n Mu Mun 95UCLlo9 Arsenic 18 16 12 17 20 34 25 30 20 41 23 12 12 41 22 28 Cadmium 3 2 1 1 2 4 4 2 2 5 2 1 1 5 2, 3 Chromium" 77 76 166 2010 2220 5110 861 1150 210 5590 1280 219 76 5590 1581 13161 Copper 553 460 876 3200 4580 11800 4270 7300 1930 12000 7290 318 318 12000 4548 21817 Lead 226 169 103 73 97 234 158 71 127 203 43 73 43 234 131 190 Nickel 912 756 586 973 1720 2260 2210 2840 5410 4960 2300 722 586 5410 2137 3928 Antimony 3 3 3 14 14 37 3 5 3 37 6 3 3 37 1 1 26 Cyanide 1 1 4 7 13 19 23 55 1 1 38 97 1 1 97 23 . 199 Samele Location A1 A4 D1 A10 A7 G1 D4 C6 D7 C9 C8.A D9.A I I ------- EPA Region 10, 6/3/93 Table 2. Allied Plating Residual Risks: Risk Calculations for Residential and Industrial Exposure to the Contaminated Soil Layer Toxicity Reference Values Risk Calculation Results Cancer Potency Non.Cancer Effects Exposure Weight of Point RESIDENTIAL \ INDUSTRIAL Chemical ~ Evidence ~ BlQQ !J&ME Confldencf~ Concentration J:Q Bl1Is . J:g BW ArsenIc 1.7 E+O (a) A I (b) 3.0 E.4 (c) 3 med I (b) 28 0.3 7.7 E.5 0.05 8.2 E.6 C~dmlum NA 5.0 E.4 (c) 10 high I (b) 3 0.02 0.003 ChromIum Cr III NA 1.0 E+O (c) 1000 low I (b) 5590 0.06 0.008 .. Cr. VI NA 5.0 E.3 (c) 500 low I (b) 56 Copper NA 3.7 E.2 (c) H (b) 12000 1.2 0.16 Lead NA NA 190 NA Nickel NA 2.0 E.2 (c) 300 med I (b) 3928 0.7 0.10 Antimony NA 4.0 E.4 (c) 1000: med I. (b) 26 0.2 0.03 CyanIde NA 2.0 E.2 (c) 500 I (b) 97: 0.02 0~002 Fqotnotes: (a) Cancer potency slope lactor lor oral exposure, /(mg/kg.day). (b) Sources 01 toxicity data are: I = Integrated Risk Information System, EPA on.line database. H = Health Effects Assessment Summary Tables, EPA.ECAO, 1992. (c) Relerence dose lor oral exposure, mg/kg.day: . ------- Appendix C State Letter of Concurrence with the No Further Action Decision '-.". ------- Appendix D Administrative Record Index - '.;-- . . ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 1 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 1. o. SITE IDENTIFICATION SUB-HEAD: 1. 1. Correspondence - 0000014 Microfilm Reel DATE: 03/08/78 PAGES: AUTHOR: Stephen Carter/ ADDRESSEE: Robert S. Forman/ DESCRIPTION: Letter re: first draft of proposed pollution control system for Allied Plating 1. 1. Frame Begins 1 Ends 1 1 - 0000003 Microfilm Reel DATE: 04/18/78 PAGES: AUTHOR: William P. Sells/ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter regarding elimination of all potentially hazardous waste discharges to the holding ponds adjacent to Allied Plating 1. 1. Frame Begins 1 Ends 1 1 - 0000004 Microfilm Reel DATE: 04/26/78 PAGES: 1 AUTHOR: E.P. stier1y/Allied Plating ADDRESSEE: William P. Sells/Oregon Dept. of Environmental Quality (DEQ) DESCRIPTION: Letter stating that Mr. Stierly doesn't believe Allied Plating is discharging hazardous waste and requesting set of guidelines as to what DEQ considers a hazardous waste 1.1. Frame Begins 1 Ends 1 - 0000005 Microfilm Reel DATE: 06/14/78 PAGES: AUTHOR: William P. Sells/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Reply to Stierly's 4/26/78 letter listing laboratory from samples taken from the holding pond, requesting contact City of Portland in regards to connection to sewer 1. 1. Frame Begins 1 Ends 1 1 results stierly to ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 2 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - 0000006 Microfilm Reel DATE: 07/20/78 PAGES: AUTHOR: William P. Sells/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter documenting outcome of 7/13/78 and DEQ 1. 1. Frame Begins 1 Ends 1 1 meeting between Stierly - 0000007 Microfilm Reel DATE: 08/01/78 PAGES: 1 AUTHOR: Rodney Lewis, Jr./McMenamin, Joseph et al ADDRESSEE: William Sells/DEQ DESCRIPTION: Letter confirming conversation of 7/28/89, granting Allied Plating an extension to submit program for discharge of waste 1. 1. Frame Begins 1 Ends 1 - ~000008 Microfilm Reel DATE: 09/20/78 PAGES: AUTHOR: Robert E. Gilbert/DEQ ADDRESSEE: Ernest P. stierly/Allied Plating DESCRIPTION: Letter staing that stierly must submit 10/20/78 1. 1. Frame Begins 1 Ends 1 2 a detailed plan by - 0000010 Microfilm Reel DATE: 10/11/78 PAGES: 2 AUTHoR: Rodney Lewis, Jr./McMenamin, Joseph, et ale ADDRESSEE: William Sells/DEQ DESCRIPTION: Letter requesting a meeting to discuss compliance with DEQ standards 1. 1. Frame Begins 1 Ends 1 - 0000009 Microfilm Reel DATE: 10/18/78 PAGES: 2 AUTHOR: Rodney Lewis, Jr./McMenamin, Joseph, et ale ADDRESSEE: William Sells/DEQ DESCRIPTION: Letter explaining steps Allied Plating was taking to meet compliance schedule timeline 1.1. Frame Begins 1 Ends ------- 06/24/93 u. S. Environmental Prote9tion Agency, Region 10 Page 3 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. Frame Begins 1 Ends 1 - 0000011 Microfilm Reel DATE: 11/18/78 PAGES: 1 AUTHOR: Patrick Raney/Testing Laboratory ADDRESSEE: Allied Plating/ DESCRIPTION: Cover memo for results of sampling 1. 1. Frame Begins 1 Ends 1 - 0000012 Microfilm Reel DATE: 11/~/78 PAGES: AUTHOR: William P. Sells/DEQ ADDRESSEE: Rodney Lewis, Jr./Attorney at Law DESCRIPTION: Letter agreeing to an extension of schedule 1 time to submit compliance 1.1. Frame Begins 1 Ends 1 - 0000013 Microfilm Reel DATE: 12/04/78 PAGES: 2 AUTHOR: Rodney Lewis, Jr./McMenamin, ADDRESSEE: William Sells/DEQ DESCRIPTION: Letter regarding compliance Joseph, et al. schedule 1. 1. Frame Begins 1 Ends 1 - 0000015 Microfilm Reel DATE: 02/01/79 PAGES: AUTHOR: William P. Sells/DEQ ADDRESSEE: Rodney Lewis, Jr./ DESCRIPTION: Letter confirming receipt of schedule 1 12/4/78 letter outlining compliance 1.1. Frame Begins 1 Ends 1 - 0000016 Microfilm Reel DATE: 06/14/79 PAGES: AUTHOR: Bob Forman/ ADDRESSEE: Bill Sells/DEQ DESCRIPTION: Cover letter for 2 proposed system at Allied Plating 1. 1. Frame Begins 1 Ends 1 - 0000017 Microfilm Reel DATE: 10/10/79 PAGES: AUTHOR: Fred Bromfeld/DEQ ADDRESSEE: 1 DESCRIPTION: Status of enforcement action taken by Northwest Region at Allied Plating ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 4 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1.1. - 0000018 Microfilm Reel DATE: 12/19/80 PAGES: AUTHOR: Robert E. Gilbert/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Cover letter for application for Facilities Permit Frame Begins 1 Ends 1 1 Water Pollution Control 1. 1. - 0000019 Microfilm Reel DATE: 03/02/81 PAGES: AUTHOR: Robert E. Gilbert/DEO ADDRESSEE: Ernest P. stierly/Allied Plating DESCRIPTION: Letter requesting additional information Control Facilities Permit Frame Begins 1 Ends 1 1 for Water Pollution 1.1. - 0000020 Microfilm Reel DATE: 03/06/81 PAGES: 1 AUTHOR: E.P. Stierly/Allied Plating ADDRESSEE: Gentlemen/Allied Plating DESCRIPTION: Letter re: waste lagoon Frame Begins 1 Ends 1 1.1. - 0000021 Microfilm Reel DATE: 03/06/81 PAGES: AUTHOR: Kenneth D. Feigner/EPA ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter stating that Mr. Stier~y must determine whether exhibitis any of characteristics of hazardous waste as in the CFR Frame Begins 1 Ends 1 2 waste defined - 0000022 Microfilm Reel DATE: 07/02/81 PAGES: AUTHOR: Robert E. Gilbert/DEO ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter noting that if Allied Plating fails to sub~it information immediately, the DEO will initiate enforcement action 1. 1. Frame Begins 1 Ends 1 ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 5 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1.1. - 0000023 Microfilm Reel DATE: 07/29/81 PAGES: AUTHOR: Linda Dawson/EPA ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter returning hazardous waste correction Frame Begins 1 Ends 1 1 permit application for 1.1. - 0000024 Microfilm Reel DATE: 08/17/81 PAGES: AUTHOR: Charles H. Gray/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter advising that failure to comply information could result in imposition Frame Begins 1 Ends 1 1 with request for of civil penalties 1.1. - 0000025 Microfilm Reel DATE: 02/05/82 PAGES: AUTHOR: Charles Clinton/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter noting two options available from Allied Plating Frame Begins 1 Ends 1 2 for disposal of wastewater 1. 1. - 0000026 Microfilm Reel DATE: 02/23/82 PAGES: AUTHOR: Ernest P. Stierly/Allied ADDRESSEE: Charles R. Clinton/DEQ DESCRIPTION: Letter choosing option 1 Frame Begins 1. Ends 1 1 Plating from Clinton's 2/5/82 letter 1.1. - 0000027 Microfilm Reel DATE: 07/13/82 PAGES: AUTHOR: Charles R. Clinton/DEQ ADDRESSEE: Don Johnson/Allied Plating DESCRIPTION: Letter re: groundwater monitoring 5 Frame Be.gins 1 Ends 1 - 0000028 Microfilm Reel DATE: 10/17/83 . PAGES: AUTHOR: Charles Clinton/DEQ ADDRESSEE: Ernest P. Stierly/Allied Plating DESCRIPTION: Letter stating that if changes are made to the a new permit application shall be submitted 1. 1. Frame Begins 1 Ends 1 1 ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 6 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. - 0000001 Microfilm Reel DATE: 11/04/83 PAGES: AUTHOR: C.R. Clinton/ ADDRESSEE: File/ DESCRIPTION: Chronology 1973 - 1983 Frame Begins o Ends o 2 - 0000029 Microfilm Reel DATE: 11164/83 PAGES: AUTHOR: Charles R. Clinton/DEQ ADDRESSEE: Folger Johnson/U.S. Bankruptcy Court DESCRIPTION: Letter stating that DEQ would like to see that paying of consultants drill monitoring report be made a high priority 1.1. Frame Begins 1 Ends 1 1 1.1. - 0000030 Microfilm Reel DATE: 05/07/84 PAGES: AUTHOR: C. R. Clinton/DEQ ADDRESSEE: File/ DESCRIPTION: Update on status of Allied Plating Frame Begins 1 Ends 1 2 1.1. - 0000031 Microfilm Reel DATE: 05/31/84 PAGES: 3 AUTHOR: V. Joe Poor/Pacific Metal Finishers, Inc. ADDRESSEE: Fred BOlton/DEQ DESCRIPTION: Letter stating that residue from Allied Plating may be contaminated Frame Begins 1 Ends 1 1.1. - 0000032 Microfilm Reel DATE: 07/05/84 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: Fred Hansen/DEQ DESCRIPTION: Letter requesting that DEQ conduct a thorough investigation at Allied Plating 4 Frame Begins 1 Ends 1 - 0000033 Microfilm Reel DATE: 08/01/84 PAGES: AUTHOR: Fred Hansen/DEQ ADDRESSEE: Charles E. Findley/EPA -. DESCRIPTION: Letter stating that inspection of Allied.Plating has no violation of hazardous waste regulations 1.1. 1 Frame Begins 1 Ends 1 ------- 06/24/93 u. S. Environmental Prote~tion Agency, Region 10 Page 7 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. Frame Begins 1 Ends 1 - 0000034 Microfilm Reel DATE: 08/08/84 PAGES: AUTHOR: Charles R. Clinton/DEQ ADDRESSEE: V. Joe poor/Pacific Metal DESCRIPTION: Letter sharing results of 1 Finishers, Inc. sampling done at Allied Plating 1. 1. Frame Begins 1 Ends 1 - 0000035 Microfilm Reel DATE: 09/r7/84 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: Stan HOdes/Transmission Exchange Company DESCRIPTION: Letter requesting Part B application 3 1. 1. Frame Begins 1 Ends 1 - 0000036 Microfilm Reel DATE: 10/01/84 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Charles E. Findley/EPA DESCRIPTION: Letter stating Mr. Hodes' position site 2 as owner of Allied plating 1. 1. Frame.Begins 1 Ends 1 - 0000037 Microfilm Reel DATE: 10/31/84 PAGES: AUTHOR: Charles Findley/EPA ADDRESSEE: Stan Hodes/Transmission DESCRIPTION: Letter stating that EPA 4 Exchange Co. cannot retract request for Part B 1. 1. Frame Begins o Ends o. - 0000002 Microfilm Reel DATE: 11/07/84 PAGES: AUTHOR: Fred Wolf/EPA ADDRESSEE: George Hofer/EPA DESCRIPTION: Report of observations and recommendations Plating facility visited on 11/5/84 1 concerning the Allied 1. 1. Frame Begins 1 Ends 1 - 0000038 Microfilm Reel DATE: 11/26/84 PAGES: AUTHOR: Paul Day/EPA ADDRESSEE: Bill Kor3ak/city of Portland DESCRIPTION: Record of Communication re: Storm 2 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 8 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. Frame Begins 1 Ends 1 - 0000039 Microfilm Reel DATE: 12/03/84 PAGES: 6 AUTHOR: H. Philip Eder/Eder & Schmidt ADDRESSEE: Paul Day/EPA DESCRIPTION: Letter transmitting questions from Stan Hodes 1.1. Frame Begins 1 Ends 1 - 0000040 Microfilm Reel DATE: 12/1~/84 PAGES: AUTHOR: Janet O'Hara/EPA ADDRESSEE: H. Philip Eder/Eder & Schmidt DESCRIPTION: Letter answering questions in Mr. 2 Eder's 12/3/84 letter 1. 1. Frame Begins 1 Ends 1 - 0000041 Microfilm Reel DATE: 12/20/84 PAGES: 2 AUTHOR: H. Philip Eder/Eder & Schmidt ADDRESSEE: Janet O'Hara/EPA DESCRIPTION: Letter stating that if the law requires Mr. Hodes to clean up the material left upon his land then he is resigned to that fact 1. 1. Frame Begins 1 Ends 1 - 0000042 Microfilm Reel DATE: 01/10/85 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: H. Philip Eder/Eder & Schmidt DESCRIPTION: Letter advising that due date 2 for Part B application - 0000043 Microfilm Reel DATE: 01/17/85 PAGES: AUTHOR: Ernest A. schmidt/DEQ ADDRESSEE: H.S. Coulter/Oregon Dept. of Transportation DESCRIPTION: Letter request ion Dept. to submit documentation indicating whether they have any owndership in the Allied Plating facility 2 Frame Begins '. 1 Ends 1 1. 1. - 0000044 Microfilm Reel DATE: 02/18/85 PAGES: 1 AUTHOR: Bryan M. JOhnson/Seton, Johnson & Odell ADDRESSEE: Janet O'Hara/EPA DESCRIPTION: Letter stating that Seton, Johnson & Odell has been retained by Stan Hodes and requesting all technical i,nformation"'that EPA has 1. 1. Frame Begins 1 Ends ------- 06/24/93 u. S. Environmental Prote~tion Agency, Region 10 Page 9 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. Frame Begins 1 Ends 1 - 0000045 Microfilm Reel DATE: 02/22/85 PAGES: AUTHOR: Janet B. O'Hara/EPA ADDRESSEE: Bryan M. Johnson/Seton, Johnson & Odell DESCRIPTION: Cover letter for technical information 2 1.1. Frame Begins 1 Ends 1 - 0000046 Microfilm Reel DATE: 04/03/85 PAGES: 2 AUTHOR: Bryan M. Johnson/Seton, Johnson ADDRESSEE: Harry Edmonds/City of Portland DESCRIPTION: Letter regarding procedures for sewer & Odell connecting to the city sanitary 1. 1. Frame Begins 1 Ends 1 - 0000047 Microfilm Reel DATE: 06/04/85 PAGES: 1 AUTHOR: Bryan M. JOhnson/Seton, Johnson & Odell ADDRESSEE: Janet O'Hara/EPA DESCRIPTION: Letter stating that Seton, Johnson & Odell is no longer retained by Stan Hodes on the Allied Plating project being 1. 1. Frame Begins 1 Ends 1 - 0000048 Microfilm Reel DATE: 06/07/85 PAGES: AUTHOR: Janet Baker O'Hara/EPA ADDRESSEE: stanley HOdes/Transmission DESCRIPTION: Cover letter for data sent 1 Exchange Co. 1.1. Frame Begins 1 Ends 1 - 0000049 Microfilm Reel DATE: 06/20/85 PAGES: 1 AUTHOR: Thomas E. Bottenberg/City of Portland ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter confirming City's position regarding the pumping of the Allied Plating pond 1.1. Frame Begins 1 Ends 1 - 0000050 Microfilm Reel DATE: 07/09/85 PAGES: AUTHOR: George C. Hofer/RCRA ADDRESSEE: stanley Hodes/Transmission Exchange Co. DESCRIPTION: Letter requesting information to be. supplied on the..potential for the public to be exposed to hazardous wastes through releases at Allied Plating ------- 06/24/93 U. S. Environmental Prot~ction Agency, Region 10 Page 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. - 0000052 Microfilm Reel DATE: 07/17/85 PAGES: 2 AUTHOR: Clyde Carlson/Consulting civil Engineer ADDRESSEE: Stanley HOdes/Transmission Exchange Co. DESCRIPTION: Brief summary of Mr. Carlson's thoughts relative of the hazardous site occupied by Allied Plating Frame Begins 1 Ends 1 to the closure - 0~00053 Microfilm Reel DATE: 08/07/85 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: Owner/Operator/Allied Plating Inc. DESCRIPTION: Requirements due to amended interim facilities 1.1. Frame Begins 1 Ends 1 5 status land disposal - 0000054 Microfilm Reel DATE: 08/15/85 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Laura Hamilton/DEQ DESCRIPTION: Letter advising DEQ of reason for Hodes "completeness review dated 5/24/85" 1.1. Frame Begins 1 Ends 1 3 delaying answer to the - 0000055 Microfilm Reel DATE: 10/31/85 PAGES: 3 AUTHOR: J. B. Boyd/Oregon Dept. of Transportation ADDRESSEE: Charles E. Findley/EPA . DESCRIPTION: Cover letter and attached sketch map of the fencing plan for security at the Allied Plating s~~e 1. 1. Frame Begins 1 Ends 1 - 0000056 Microfilm Reel DATE: 01/27/86 PAGES: 2 AUTHOR: Terrence E. Beleunes/Century Environmental Services ADDRESSEE: Tom Bottenburg/city of Portland DESCRIPTION: Letter re: closure of hazardous waste impoundment at Plating 1.1. Frame Begins 1 Ends 1 Allied ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 11 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - 0000057 Microfilm Reel DATE: 02/04/86 PAGES: 1 AUTHOR: Harry G. Edmonds/City of Portland ADDRESSEE: Terrence E. Beleunes/Century Environmental Sciences DESCRIPTION: Letter denying request to pump Allied Plating pond into of Portland sanitary sewer system 1. 1. Frame Begins 1 Ends 1 the City - 00Q0058 Microfilm Reel DATE: 02/18/86 PAGES: AUTHOR: J. B.Boyd/DOT ADDRESSEE: Charles E. Findley/EPA DESCRIPTION: Letter transmitting rough 1.1. Frame Begins 1 Ends 1 1 draft prepared by Reidel Environmental - 0000059 Microfilm Reel DATE: 03/20/86 PAGES: AUTHOR: Laura Hamilton/DEQ ADDRESSEE: George Toombs/Oregon State Health Division DESCRIPTION: Letter forwarding data from the Allied Plating assistance in interpreting the data 1.1. Frame Begins 1 Ends 1 2 site, requesting - 0000060 Microfilm Reel DATE: 05/07/86 PAGES: AUTHOR: Fred Hansen/DEQ ADDRESSEE: Larry Rulien/DOT DESCRIPTION: Letter requesting meeting 1. 1. Frame Begins 1 Ends 1 1 - 0000061 Microfilm Reel DATE: 05/15/86 PAGES: AUTHOR: Janet O'Hara/EPA ADDRESSEE: File/ DESCRIPTION: Summary of 5/12/86 Allied 1. 1. . Frame Begins 1 Ends 1 1 Plating Meeting 1.1. Frame Begins 1 Ends 1 - 0000051 Microfilm Reel DATE: 07/13/86 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: Stanley HOdes/Transmission Exchange Co. DESCRIPTION: Letter stating that all available information has to Hodes' consulting engineers 2 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 12 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. - 0000062 Microfilm Reel Frame Begins 1 Ends 1 DATE: 01/20/87 PAGES: 2 AUTHOR: Michael Watson/EPA ADDRESSEE: Joan Shafer/EPA DESCRIPTION: Overview of data from Allied Plating 1. 1. Microfilm Reel Frame Begins 1 Ends 1 PAGES: 15 - 0000063 DATE: 01/7.-7/87 AUTHOR: Stan Hodes/ ADDRESSEE: Ernesta Barnes/EPA DESCRIPTION: Letter pointing out errors in EPA's 1/22/87 press release 1. 1. - 0000064 Microfilm Reel Frame Begins 1 Ends 1 DATE: 02/20/87 PAGES: 1 AUTHOR: Robie G. Russell/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Reply to Stan Hodes letter of 1/27/87 1. 1. - 0000065 Microfilm Reel Frame Begins 1 Ends 1 DATE: 03/02/87 PAGES: 2 AUTHOR: Stan Hodes/ ADDRESSEE: Robie G. Russell/EPA DESCRIPTION: Replay to Robie Russell's 2/20/87 letter 1.1. - 0000066 Microfilm Reel DATE: 03/04/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Fred Hansen/DEQ DESCRIPTION: Letter commenting on inspection Frame Begins 1 Ends 1 1 report dated 1/7/87 - 0000067 Microfilm Reel DATE: 03/04/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Robie G. Russell/EPA DESCRIPTION: Letter commenting on 1. 1. Frame Begins 1 Ends 1 1 ------- 06/24/93 u. S. Environmental Prote~tion Agency, Region 10 Page 13 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. Frame Begins 1 Ends 1 - 0000068 Microfilm Reel DATE: 03/09/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Russell H. Wyer/EPA DESCRIPTION: Letter stating that data generated by the Oregon DOT and DEQ replaces old data and should be made a part of the record 1 1.1. Frame Begins 1 Ends 1 - 0000069 Microfilm Reel DATE: 03/11/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Janet O'Hara/EPA DESCRIPTION: Letter expressing interest in knowing firm CH2MHill contracting with EPA to 1 more about engineering work on Allied Plating 1.1. Frame Begins 1 Ends 1 - 0000070 Microfilm Reel DATE: 03/12/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Russell H. Wyer/EPA DESCRIPTION: Letter commenting on inspection 3 report of 1/7/86 1.1. Frame Begins 1 Ends 1 - 0000071 Microfilm Reel DATE: 03/13/87 PAGES: AUTHOR: Fred Hansen/DEQ ADDRESSEE: Stan Hodes/ DESCRIPTION: Reply to Mr. Hodes 3/4/87 2 le~ter concerning inspection report 1.1. . Frame Begins 1 Ends 1 - 0000072 Microfilm Reel DATE: 04/02/87 PAGES: AUTHOR: stan Hodes/ ADDRESSEE: Fred Hansen/DEQ DESCRIPTION: Response to Mr. Hansen's inspection report 1 3/13/87 letter concerning the 1.1. Frame Begins 1 Ends 1 - 0000073 Microfilm Reel DATE: 04i27/87 PAGES: AUTHOR: Terrence Beleunes/ ADDRESSEE: Phil Wong/EPA DESCRIPTION: Letter stating century West's involvement with Plating site, stressing that data released was final QA/QC audit 2 the "Allied ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 14 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. - 0000074 Microfilm Reel DATE: 05/01/87 PAGES: AUTHOR: Philip Wong/EPA ADDRESSEE: Terrence Belunes/Century DESCRIPTION: Response to Mr. Belunes' Frame Begins 1 Ends 1 1 West Engineering letter of 4/27/87 1. 1. - 0000075 Microfilm Reel DATE: 05f26/87 PAGES: AUTHOR: Fred Hansen/DEQ ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter attempting to clarify Mr. Hodes' understanding of how environmental protection programs work and his responsibilities as a property owner Frame Begins 1 Ends 1 1 1. 1. - 0000076 Microfilm Reel DATE: 06/03/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Robie G. Russell/EPA DESCRIPTION: Letter stating that Mr. Hodes' permission will be required before CH2MHill contractors will be allowed to enter the Allied Plating site, and stating other conditions that must be adhered to Frame Begins 1 Ends 1 1 1.1. - 0000077 Microfilm Reel DATE: 06/16/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Fred Hansen/DEQ DESCRIPTION: Letter discussing Mr. Hodes acceptance hazardous waste at Allied Plating site Frame Begins 1 Ends 1 3 of responsibility for 1. 1. - 0000078 Microfilm Reel DATE: 07/16/87 PAGES: AUTHOR: Thomas Miller/DEQ ADDRESSEE: Phil Wong/DEQ DESCRIPTION: Cover letter for "Groundwater Elevation Data", observations made on 7/14/87 visit to site Frame Begins 1 Ends 1 2 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 15 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - 0000079 Microfilm Reel DATE: 07/17/87 PAGES: AUTHOR: Tom Miller/DEQ ADDRESSEE: Stanley HOdes/Transmission Exchange Co. DESCRIPTION: Cover letter for groundwater water level measurements, stating observations made on 7/14/87 site visit, and expressing concern about potential worker exposure 1. 1. Frame Begins 1 Ends 1 2 - 0000080 Microfilm Reel DATE: 07/17/87 PAGES: AUTHOR: Edward G. Woods/DEQ ADDRESSEE: stan HOdes/Transmission Exchange DESCRIPTION: Letter giving additional direction as to what activities are allowed at the site prior to finalizing the Superfund cleanup 1.1. Frame Begins 1 Ends 1 2 - 0000081 Microfilm Reel DATE: 11/10/87 PAGES: AUTHOR: Tom Miller/DEQ ADDRESSEE: Phil Wong/EPA DESCRIPTION: Letter requesting information Responsible Parties (PRPs) at 1. 1. Frame Begins 1 Ends 1 1 that EPA may have on potentially the Allied Plating site - 0000082 Microfilm Reel DATE: 02/05/88 PAGES: AUTHOR: Philip Millam/EPA ADDRESSEE: C. Scott Parish/EPA DESCRIPTION: Memorandum re: Allied Plating NP~/RCRA Eligibility 1.1. Frame Begins 1 Ends 1 4 - 0000083 Microfilm Reel DATE: 03/15/89 PAGES: 12 AUTHOR: Bruce Long/EPA ADDRESSEE: Chuck Shenk/EPA DESCRIPTION: Memorandum re: Closure and Plating, Portland, Oregon 1. 1. Frame Begins 1 Ends 1 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 16 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - 0000084 Microfilm Reel DATE: 11/15/89 PAGES: AUTHOR: stan Hodes/ ADDRESSEE: Philip Millam/EPA DESCRIPTION: Letter requesting attorney in 9/87 1.1. Frame Begins 1 Ends 1 2 EPA to reconsider offer made by Mr. Hodes - 0000085 Microfilm Reel DATE: 11/16/89 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Philip Millam/EPA DESCRIPTION: Letter requesting that EPA keep Mr. issues regarding the Allied Plating 1.1. Frame Begins 1 Ends 1 2 Hodes better informed of site - 0000086 Microfilm Reel DATE: 12/04/89 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Philip G. Millam/EPA DESCRIPTION: Letter explaining why fraudulent 1. 1. Frame Begins 1 Ends 1 3 the "Preliminary Health Assessment" is - 0000087 Microfilm Reel DATE: 12/14/89 PAGES: AUTHOR: Philip Millam/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter explaining that EPA cannot accept Mr. Hodes offer settlement, and updating him on the status of the Allied site 1.1. Frame Begins 1 Ends 1 2 for Plating - 0000088 Microfilm Reel DATE: 12/22/89 PAGES: 16 AUTHOR: Stan Hodes/ ADDRESSEE: Philip Millam/EPA DESCRIPTION: Letter commenting on issues 1.1. Frame Begins 1 Ends 1 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 17 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 1. - 0000089 Microfilm Reel Frame Begins 1 Ends 1 DATE: 01/10/90 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Cover letter for RI/FS scoping Report 1. 1. - 0000090 Microfilm Reed Frame Begins 1 Ends 1 DATE: 08/67/90 PAGES: 3 AUTHOR: Stan Hodes/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter making observations and comments about Allied Plating 1. 1. Frame Begins 1 Ends 1 - 0000091 Microfilm Reel DATE: 09/28/90 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter re: Money being wasted on current plans for the Allied Plating site 2 studies and future 1. 1. Frame Begins 1 Ends 1 - 0000092 Microfilm Reel DATE: 10/02/90 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter requesting copy of Natural Resource survey" 2 "Health Assessment" and "Preliminary SUB-HEAD: 1. 2. Background - RCRA and Other Information 1. 2. Microfilm Reel PAGES: Frame Begins 1 Ends 1 - 0000014 DATE: 07/12/78 AUTHOR: DEQ/ ADDRESSEE: / DESCRIPTION: Pollution 1 Complaint made by Bob Purdy, OSHA 1. 2. Microfilm Reel PAGES: Frame Begins o Ends o - 0000001 DATE: 08/20/79 AUTHOR: EPAI ADDRESSEE: 1 DESCRIPTION: Inventory 1 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 18 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 2. - 0000002 Microfilm Reel DATE: 10/01/79 PAGES: 13 AUTHOR: Oregon Dept. of Environmental ADDRESSEE: / DESCRIPTION: Enforcement Referral Frame Begins o Ends o Quality (DEQ)/ 1. 2. Microfilm Reel PAGES: Frame Begins o Ends o - 0000003 DATE: 11f29/79 AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Potential 1 Hazardous Waste site Log 1. 2. - 0000004 Microfilm Reel DATE: 05/06/80 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Hazardous Waste Requirements Frame Begins 1 Ends 1 2 site Evaluation of Section 311 Cleanup 1. 2. - 0000005 Microfilm Reel DATE: 12/19/80 PAGES: 16 AUTHOR: Lloyd A. Reed/EPA ADDRESSEE: Ernest P. Stiely/Allied Plating DESCRIPTION: RCRA Notification Letter Frame Begins o Ends o 1. 2. Microfilm Reel PAGES: 1 Stierly/Allied Plating Frame Begins 1 Ends 1 - 0000011 DATE: 12/29/80 AUTHOR: Ernest P. ADDRESSEE: / DESCRIPTION: Application for a Water Pollution Control Facilities Permit 1. 2. Microfilm Reel PAGES: Frame Begins 1 Ends 1 - 0000012 DATE: OS/21/81 AUTHOR: /DEQ ADDRESSEE: / DESCRIPTION: Polution 1 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 19 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 2. - 0000013 Microfilm Reel Frame Begins 1 Ends 1 DATE: 04/02/82 PAGES: 4 AUTHOR: DEQ/ ADDRESSEE: / DESCRIPTION: Water Pollution Control Facilities Permit 1. 2. - 0000006 Microfilm Reel Frame Begins 0 Ends 0 DATE: 02/~2/83 PAGES: 3 AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: File Review Checklist - 0000007 Microfilm Reel DATE: 11/21/84 PAGES: 17 AUTHOR: Paul Day/EPA ADDRESSEE: George Hofer/EPA DESCRIPTION: Allied Plating, RCRA Meeting, November 5, 1. 2. Frame Begins o Ends o Inspection and Part B Pre-Application 1984 1. 2. - 0000008 Microfilm Reel Frame Begins 0 Ends 0 DATE: 12/13/84 PAGES: 2 AUTHOR: DEQ/ ADDRESSEE: Stanley Hodes, Shirley Hodes/ DESCRIPTION: Notice of violation and Intent to Assess civil Penalty - 0000009 Microfilm Reel DATE: 03/26/85 PAGES: 3 AUTHOR: Seton, Johnson & Odell Inc./ ADDRESSEE: Stan Hodesl DESCRIPTION: Allied Plating site Part B Permit Application Hazardous Waste Surface Impoundment 1. 2. Frame Begins o Ends o to'Close Abandoned - 0000010 Microfilm Reel DATE: 09/18/85 PAGES: 85 AUTHOR: Laura Hamilton/DEQ ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter stating DEQ's decision to evaluate exposure information from Mr. Hodes and Oregon Dept. of Transportation .' 1. 2. Frame Begins o Ends ------- 06/24/93- u. S. Environmental Protection Agency, Region 10 Page 20 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX SUB-HEAD: 1. 3. Notification/Site Inspection/CERCLIS 1. 3. Microfilm Reel PAGES: Frame Begins 1 Ends 1 - 0000002 DATE: / / AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Surface Report) 1 Impoundments Site Inspection Report (Supplemental - 0000001 Microfilm Reel DATE: 04/24/81 PAGES: AUTHOR: EPAI ADDRESSEE: 1 DESCRIPTION: Form 1 General Information 1. 3. Frame Begins o Ends o 8 - 0000003 Microfilm Reel DATE: 11/14/85 PAGES: 7 AUTHOR: Neil Mullane, Laura Hamilton/DEQ ADDRESSEE: 1 DESCRIPTION: Inspection Report for Allied Plating conducted on 11/14/85 1. 3. Frame Begins 1 Ends 1 SUB-HEAD: 1. 4. Preliminary Assessment (PA) Report Microfilm Reel Frame Begins 0 Ends 0 PAGES: 1 Hazardous Waste Site Ten~~tive- Disposition Microfilm Reel Frame Begins 1 Ends 1 PAGES: 5 1. 4. - 0000002 DATE: 05/30/80 AUTHOR: EPA/ ADDRESSEE: 1 DESCRIPTION: Potential 1. 4. - 0000003 DATE: 04/19/82 AUTHOR: IEPA ADDRESSEE: / DESCRIPTION: Potential ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 21 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 4. - 0000001 Microfilm Reel DATE: 07/01/89 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Potential Hazardous Assessment Frame Begins o Ends o 1 Waste site Identification and Preliminary SUB-HEAD: 1. 5. Site Investigation Microfilm Reel Frame Begins 0 Ends 0 PAGES: 13 Hazardous Waste Site Inspection Report Microfilm Reel Frame Begins 0 Ends 0 PAGES: 10 Hazardous Waste Site Inspection Report Microfilm Reel Frame Begins 0 Ends 0 PAGES: 10 Report 1. 5. - 0000001 DATE: 04/23/82 AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Potential 1. 5. - 0000002 DATE: 08/26/82 AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Potential 1. 5. - 0000003 DATE: 01/07/87 AUTHOR: / ADDRESSEE: / DESCRIPTION: Inspection 1. 5. " Frame Begins o Ends o - 0000004 Microfilm Reel DATE: 02/26/87 PAGES: 12 AUTHOR: Laura Hamilton/DEQ ADDRESSEE: Chuck Rice/EPA DESCRIPTION: Cover letter and accompanying RCRA Site Inspection Report SUB-HEAD: 1. 6. ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 22 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 6. - 0000002 Microfilm Reel DATE: / / PAGES: 88 AUTHOR: / ADDRESSEE: / DESCRIPTION: Ground water sampling data 1. 6. - 0000003 Microfilm Reel DATE: / / PAGES: AUTHOR: DEQj ADDRESSEE: / DESCRIPTION: Various data submitted by DEQ 6 1. 6. - 0000004 Microfilm Reel DATE: / / PAGES: 37 AUTHOR: / ADDRESSEE: / DESCRIPTION: Water Well Reports/Data 1. 6. - 0000009 Microfilm Reel ABEIOO D~TE: / / PAGES: 1 AUTHOR: / ADDRESSEE: / DESCRIPTION: Allied Plating Water Samples 1. 6. - 0000010 Microfilm Reel DATE: 08/15/78 PAGES: AUTHOR: IDEQ ADDRESSEE: I DESCRIPTION: Special Survey Data Sheet, Laboratory Data Sheet 9 Frame Begins Frame Begins Frame Begins Frame Begins Frame Begins o Ends o o Ends o o Ends o 1 Ends 1 1 Ends 1 Field Laboratory Analysis Report, 1. 6. - 0000005 Microfilm Reel ABE100 DATE: 03/04/81 PAGES: 1 AUTHOR: Nilda Lum/Weyerhaeuser Laboratory ADDRESSEE: I DESCRIPTION: Inorganic Regional Data Assessment Frame Begins - Soil Sample 1 Ends 1 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 6. - 0000012 Microfilm Reel DATE: 08/20/81 PAGES: 1 AUTHOR: C. L. Chang/Aqua Tech Laboratory ADDRESSEE: Allied Plating/ DESCRIPTION: Chemical analysis of plating wastewater, 7/24/81 Frame Begins Page 23 1 Ends 1 sample collection - 0000011 Microfilm Reel DATE: 01/+2/82 PAGES: AUTHOR: DEQ/ ADDRESSEE: / DESCRIPTION: Ground Water Quality Sample Collection Form 1. 6. Frame Begins 1 - 0000001 Microfilm Reel DATE: 02/01/85 PAGES: 91 AUTHOR: Ecology and Environment (E ADDRESSEE: / DESCRIPTION: Soil and Water Samping Data 1. 6. Frame Begins & E)/ 1. 6. - 0000006 Microfilm Reel ABE100 Frame Begins DATE: 08/27/86 PAGES: 1 AUTHOR: George L. Toombs/Oregon Dept. of Human Resources ADDRESSEE: Laura Hamilton/Oregon Dept. of Environmental Quality DESCRIPTION: Results of groundwater collected 4/28-30/86 - 0000007 Microfilm Reel ABE100 Frame Begins DATE: 06/03/87 PAGES: 14 AUTHOR: Stan Hodes/ ADDRESSEE: Russel H. Wyer/EPA DESCRIPTION: Cover letter and enclosed water quality data summary 1. 6. - 0000008 Microfilm Reel ABE100 Frame Begins DATE: 04/26/90 PAGES: 10 AUTHOR: / ADDRESSEE: / DESCRIPTION: List of samples shipped and analyses 1. 6. 1 Ends 1 o Ends o 1 Ends 1 1 Ends 1 1 ,Ends ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX SUB-HEAD: 1. 7. 1. 7. Century West Engineering Report - 0000001 Microfilm Reel DATE: 09/04/87 PAGES: 25 AUTHOR: Century West Engineering Corp./ ADDRESSEE: / DESCRIPTION: Description of the Current Situation: Summary Report SUB-HEAD: 1. 7. 1. - 1. 7. 1. - 0000001 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix B - Frame Begins Appendices Microfilm Reel PAGES: 36 Engineering/ Frame Begins Remedial Investigation Boring Logs 1. 7. 1. - 0000002 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix C - APSI Sampling Plan 1. 7. 1. - 0000003 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix D - Microfilm Reel PAGES: 87 Engineering/ Frame Begins Microfilm Reel PAGES: 63 Engineering/ Frame Begins Previous Lab Analysis 1. 7. 1. - 0000004 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix E - Results of Laboratory Analysis 1. 7. 1. - 0000005 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix F - Microfilm Reel PAGES: 184 Engineering/ Frame Begins Microfilm Reel PAGES: 0 Engineering/ Analytical Laboratory QA/QC Procedures. Frame Begins Page 24 o Ends o o Ends o o Ends o o Ends o o Ends o o Ends ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 25 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 1. 7. 1. - 0000006 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix G - Microfilm Reel PAGES: 14 Engineering/ APSI - Monitoring Well Construction Diagrams Frame Begins o Ends o 1. 7. 1. - 0000007 DATE: / / AUTHOR: Century West ADDRESSEE: / - DESCRIPTION: Appendix H - Microfilm Reel PAGES: 15 Engineering/ APSI Monitoring Wells Rising Head Test Results Frame Begins o Ends o 1. 7. 1. - 0000008 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix I - APSI Field Data Logs Microfilm Reel PAGES: 22 Engineering/ Frame Begins o Ends o 1. 7. 1. - 0000009 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix J - Microfilm Reel PAGES: 58 Engineering/ APSI Closure Design Calculations Frame Begins o Ends o 1. 7. 1. - 0000010 DATE: / / AUTHOR: Century West ADDRESSEE: / DESCRIPTION: Appendix K - Microfilm Reel PAGES: 11 Engineering/ APSI Post Closure Ground Water Monitoring Programs Frame Begins o Ends o SUB-HEAD: 1. 8. Comprehensive Groundwater Monitoring Program Evaluation 1. 8. - 0000001 Microfilm Reel DATE: 04/28/86 PAGES: 152 AUTHOR: DEQ/ ADDRESSEE: EPA/ DESCRIPTION: Comprehensive Groundwater Monitoring Inspection, Allied Plating Hazardous conducted 4/28-30/86 Frame Begins o Ends o Program Evaluation ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX SUB-HEAD: 1. 9. Closure/post-closure Plan 1. 9. - 0000001 Microfilm Reel DATE: 01/27/86 PAGES: 114 AUTHOR: Century Environmental Services/ ADDRESSEE: Reidel Environmental Services/ DESCRIPTION: Closure/Post-Closure Plans, Allied Frame Begins Plating Site Page 26 o Ends ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 2 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 2. O. REMEDIAL INVESTIGATION/FEASIBILITY STUDY SUB-HEAD: 2. 1. Correspondence 2. 1. - 0000023 Microfilm Reel 1 DATE: / / PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Bob Banbickle/Dept. of Transportation DESCRIPTION: Cover letter for information sent [Copy attached tooriginal] Frame Begins 1 Ends 1 of revised Workplan 2. 1. - 0000001 Microfilm Reel 1 DATE: 01/25/90 PAGES: 1 AUTHOR: Edward J. Kowalski/EPA ADDRESSEE: Lucinda Moyano/Oregon Attorney DESCRIPTION: Cover letter for RI/FS Scoping Frame Begins 1 Ends 1 General's Office Report 2. 1. - 0000002 Microfilm Reel 1 DATE: 03/07/90 PAGES: 2 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: stan Hodes/ DESCRIPTION: Cover letter and attached postal receipt for RI/FS Scoping report Frame Begins 1 Ends 1 2. 1. - 0000003 Microfilm Reel 1 DATE: 09/26/90 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter appraising Mr. Hodes of c~rrent travel situation affecting EPA Frame Begins 1 Ends 1 2. 1. - 0000004 Microfilm Reel DATE: 12/10/90 PAGES: AUTHOR: Stanley Hodes/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter requesting copies Workplan Attachments 1 3 Frame Begins 1 Ends 1 ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 28 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 1. - 0000005 Microfilm Reel 1 DATE: 12/27/90 PAGES: 1 AUTHOR: Dan Saltzman/Enviromental Management Solutions (EMS) ADDRESSEE: Kevin L. Rochlin/EPA DESCRIPTION: Letter formally notifying EPA that EMS will be serving as technical advisors to Stan Hodes Frame Begins 1 Ends 1 2. 1. - 0000006 Microfilm Reel 1 DATE: 01/03/91 PAGES: 2 AUTHOR: Ke~in Rochlin/EPA ADDRESSEE: Filel DESCRIPTION: Memorandum re: Use of Specific Plating Superfund site RIIFS Frame Begins 1 Ends 1 Leaching Tests During the Allied 2. 1. - 0000007 Microfilm Reel 1 DATE: 01/22/91 PAGES: 2 AUTHOR: Terry L. Steinborn/URS Consultants ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter re: Filtration of Groundwater site Frame Begins 1 Ends 1 Samples at Allied Plating 2. 1. - 0000008 Microfilm Reel 1 DATE: 02/08/91 PAGES: 1 AUTHOR: Terry L. Steinborn/URS Consultants ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Correction to letter of 1/22/91 Frame Begins 1 Ends 1 2. 1. - 0000009 Microfilm Reel 1 DATE: 03/01/91 PAGES: 1 AUTHOR: Dan Saltzman/Environmental Management Solutions (EMS) ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter reiterating EMS' desire to review 1st round groundwater monitoring results prior to beginning 2nd round . ~rame. Begins 1 Ends 1 2. 1. - 0000010 Microfilm Reel 1 DATE: 04/03/91 PAGES: 2 AUTHOR: URS consultantsl ADDRESSEE: EPA/ DESCRIPTION: Additional Phase 2 soil sampling specifications Frame Begins 1 Ends ------- 06/24/93 U. S. Fnvironmental Protection Agency, Region 10 Page 29 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 1. - 0000011 Microfilm Reel 1 DATE: 04/23/91 PAGES: 4 AUTHOR: Larry H. Zinky/URS Consultants ADDRESSEE: Diana Phelan/Shannon & Wilson DESCRIPTION: Letter containing modifications scenario Frame Begins 1 Ends 1 to the existing AP soil sampling 2. 1. - 0000012 Microfilm Reel 1 DATE: 05/06/91 PAGES: 8 AUTHOR: Larry H. Zinky/URS Consultants ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter re: Custody History of Impoundment Sediment Samples Frame Begins 1 Ends 1 Archived Allied Plating 2. 1. - 0000013 Microfilm Reel 1 DATE: 10/24/91 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter updating Mr. Hodes on status of project at Allied Plating Frame Begins 1 Ends 1 2. ~. . . - 0000014 Microfilm Reel 1 DATE: 11/05/91 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Mike Stevens/Associated Crane Company DESCRIPTION: Letter apprising of status of moving the drums EPA's field sampling out of the crane yard Frame Begins 1 Ends 1 left during the 2. 1. - 0000015 Microfilm Reel 1 DATE: 11/07/91 PAGES: 16 AUTHOR: Priscilla Anderson/URS Consultants ADDRESSEE: Carol Sweeney/EPA DESCRIPTION: Cover letter and attached key portions of "A Review and Analysis of Parameters for Assessing Transport of Environmentally Released Radionuclides through Agriculture" Frame Begins 1 Ends 1 ------- Page 06/24/93 u. S. Environmental Protection Agency, Region 10 30 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - 0000016 Microfilm Reel 1 DATE: 03/23/92 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Robert Van VickIe/Oregon Dept. DESCRIPTION: Letter updating Mr. Van VickIe Remedial Investigation 2. 1. - 0000017 Microfilm Reel DATE: 03/2~/92 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter updating Mr. Hodes Remedial Investigation 1 1 2. 1. Frame Begins Ends 1 1 of Transportation on progress of the Allied Plating Frame Begins Ends 1 1 on progress of the Allied Plating - 0000018 Microfilm Reel 1 DATE: OS/21/92 PAGES: 2 AUTHOR: Stan Hodes/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter requesting specific 2. 1. Frame Begins Ends 1 1 documents - 0000020 Microfilm Reel 1 DATE: 06/15/92 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ JESCRIPTION: Cover letter for additional copy of the Remedial Investigation for the site - 0000021 Microfilm Reel 1 DATE: 07/13/92 PAGES: 7 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Jill Kiernan/Oregon Dept. of E~vironmental Quality JESCRIPTION: Response to 6/25/92 letter regarding the Risk Assessment - 0000019 Microfilm Reel 1 DATE: 06/12/92 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Cover letter for RI/FS reports 2. 1. 2. 1. 2. 1. . ". . :. .'':'.'~ Frame Begins Ends 1 1 Frame Begins Ends 1 1 Frame Begins Ends 1 1 --- ..:.'. . ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 31 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 1. - 0000022 Microfilm Reel 1 DATE: 08/19/92 PAGES: 1 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Cover letter for 3 documents Frame Begins 1 Ends 1 2. 1. - 1001008 Microfilm Reel Frame Begins 1 Ends 1 DATE: 08/24/92 PAGES: 1 AUTHOR: Division of State Lands (OR)/ ADDRESSEE: / - DESCRIPTION: Waterway Project Permit Review SUB-HEAD: 2. 2. Work Plan/scoping Report 2. 2. - 0000003 Microfilm Reel Frame Begins 0 Ends 0 DATE: 01/01/90 PAGES: 43 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Allied Plating site RI/FS Scoping Report 2. 2. - 0000004 Microfilm Reel Frame Begins 0 Ends 0 DATE: 01/01/90 PAGES: 223 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Allied Plating site RI/FS Scoping Report Appendices 2. 2. - 0000001 Microfilm Reel Frame Begins 0 Ends 0 DATE: 08/08/90 PAGES: 92 AUTHOR: URS Consultants/ . ADDRESSEE: EPA/ DESCRIPTION: Work Plan Investigation/Feasibility for Remedial Study Workplan - 0000002 Microfilm Reel DATE: 08/08/90 PAGES: 272 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Attachments Remedial Investigation/Feasibility Study Workplan 2. 2. Frame Begins o Ends ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 32 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 2. - 0000005 Microfilm Reel DATE: 04/01/91 PAGES: 165 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation/Feasibility (Appendix C has been placed in the Administrative Record) Frame Begins 1 Ends 1 Study Work Plan (Revised) confidential portion of the 2. 2. - 0000006 Microfilm Reel DATE: 04/01/91 PAGES: 404 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Attachments to Remedial Investigation/Feasibility Study Work Plan (Updated) Frame Begins 1 Ends 1 2. 2. - 0000007 Microfilm Reel DATE: 08/15/91 PAGES: 35 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Allied Plating Remedial Investigation/Feasibility Study Work Plan (Revision NO.4) Frame Begins 1 Ends 1 SUB-HEAD: 2. 3. Trip Report 2. 3. - 0000002 Microfilm Reel DATE: 04/23/90 PAGES: 13 AUTHOR: Terry L. Steinborn/URS ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: URS Trip Report covering visit conducted 4/17 through 4/19/90 Frame Begins 1 Ends 1 2. 3. - 0000001 Microfilm Reel DATE: 06/07/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ JESCRIPTION: Cover letter and attached URS Trip 6 Frame Begins o Ends o Report for April 1990 ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page JJ ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX SUB-HEAD: 2. 4. Confidential 2. 4. - 0000001 Microfilm Reel DATE: / / PAGES: 54 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Appendix C : Remedial Investigation/Feasibility Budget (Confidential portion of Admin. Record) Frame Begins 1 Ends 1 Study Project SUB-HEAD: 2. 5. XRF Analysis 2. 5. - 0000001 Microfilm Reel DATE: 07/07/92 PAGES: 254 AUTHOR: Kevin Rochlin/EPA ADDRESSEE: / DESCRIPTION: XRF Analysis of Surface Soil Contaminant at the Allied Plating Site Final Report Frame Begins 1 Ends 1 Distribution and Depth SUB-HEAD: 2. 6. Remedial Investigation 2. 6. - 0000001 Microfilm Reel DATE: 04/13/92 PAGES: 235 AUTHOR: URS Consultants/Shannon & Wilson, Inc./MED-TOX Associates, Inc. ADDRESSEE: EPA/ . DESCRIPTION: Remedial Investigation Allied Plating Site, Portland, Oregon Frame Begins 1 Ends 1 2. 6. - 0000002 Microfilm Reel DATE: 04/13/92 PAGES: 186 AUTHOR: URS Consultants/Shannon & Wilson, ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation site, Portland, Oregon . F::rame Beg ins 1 Ends 1 Inc./MED-TOX Associates, Inc. Appendices A, B, C, and D Allied Plating 2. 6. - 0000003 Microfilm Reel DATE: 04/13/92 PAGES: 364 AUTHOR: URS Consultants/Shannon & Wilson, ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation Appendix Plating Site, Portland, Oregon Frame Begins 1 Ends 1 Inc./MED-TOX Associates, Inc. ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 34 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 6. Frame Begins 1 Ends 1 - 0000004 Microfilm Reel DATE: 04/13/92 PAGES: 768 AUTHOR: URS Consultants/Shannon & Wilson, Inc./MED-TOX Associates, Inc. ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation Appendix F Data Validation Reports, Volume 1 Allied Plating Site, Portland, Oregon - OaOO005 Microfilm Reel DATE: 04/13/92 PAGES: 812 AUTHOR: URS Consultants/Shannon & Wilson, Inc./MED-TOX Associates, Inc. ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation Appendix F Data Validation Reports, Volume 2 Allied Plating site, Portland, Oregon 2. 6. Frame Begins 1 Ends 1 - 0000006 Microfilm Reel DATE: 10/02/92 PAGES: 20 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Appendix G Risk Assessment Tables 2. 6. Frame Begins 1 Ends 1 Addendum - 0000007 Microfilm Reel DATE: 10/12/92 PAGES: 78 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Remedial Investigation Baseline Risk Assessment 2. 6. Frame Begins 1 Ends 1 Addendum SUB-HEAD: 2. 7. Feasibility study (Draft only) - 0000001 Microfilm Reel DATE: 05/13/92 PAGES: 109 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Draft Allied Plating Feasibility Study 2. 7. Frame Begins 1 Ends 1 SUB-HEAD: 2. 8. ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 35 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 2. 8. Frame Begins 1 Ends 1 - 0000001 Microfilm Reel DATE: 02/03/92 PAGES: 46 AUTHOR: URS Consultants/ ADDRESSEE: EPA/ DESCRIPTION: Allied Plating Preliminary screening of Alternatives Report 2. 8. Frame Begins 1 Ends 1 - 0000002 Microfilm Reel DATE: 04/~6/92 PAGES: 15 AUTHOR: John W. Buckley/URS Consultants ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Cover letter and attached Draft Alternatives On-Site Remedial Action SUB-HEAD: 2. 9. Work Plan for Removal and Disposal (incorporated by reference) 2. 9. Microfilm Reel PAGES: 582 the Army, Corps of Engineers/ Frame Begins 1 Ends 1 - 0000001 DATE: 03/29/93 AUTHOR: Dept. of ADDRESSEE: EPA/ DESCRIPTION: (This document is incorporated by reference only - see Allied Plating Removal Administrative Record File 1.6, document # 0010004 for actual copy) Volume 1 : Final Project Work Plan for the Removal and Disposal of contaminated Material 2. 9. Frame Begins 1 Ends 1 - 0000002 Microfilm Reel DATE: 03/29/93 PAGES: 407 AUTHOR: Dept. of the Army, Corps of Engineers/ ADDRESSEE: EPA/ . DESCRIPTION: (This document is incorporated by reference only - see Allied Plating Removal Administrative Record File 1.6, document # 0010005 for actual copy) Volume 2 : Final Project Work Plan for the Removal and Disposal of Contaminated Material 2. 9. Frame Begins 1 Ends 1 - 0000003 Microfilm Reel DATE: 03/29/93 PAGES: 582 AUTHOR: Dept. of ~e Army, Corps of Engineers/ ADDRESSEE: EPAI ' DESCRIPTION: (This document is incorporated by reference only - see Allied Plating Removal Administrative Record File 1.6, Doc. # 0010006 for actual copy) Volume 3 : ,Final Project Work Plan for the ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX Page ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 37 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 4. O. STATE COORDINATION SUB-HEAD: 4. 1. Correspondence 4. 1. Frame Begins o Ends o - 0000001 Microfilm Reel DATE: 02/03/87 PAGES:' 2 AUTHOR: Kathryn Davidson/EPA ADDRESSEE: Delores Streeter/Intergovernmental Relations Division DESCRIPTION: Let~er notifying of potential Superfund project, 60 day period comment 4. 1. - 0000002 Microfilm Reel Frame Begins 1 Ends 1 DATE: 03/17/87 PAGES: 3 AUTHOR: Delores Streeter/State of Oregon ADDRESSEE: EPA/ DESCRIPTION: Oregon Intergovernmental Project Review Frame Begins 1 Ends 1 - 0000003 Microfilm Reel DATE: 04/13/92 PAGES: AUTHOR: Debbie Bailey/DEQ . ADDRESSEE: File/ DESCRIPTION: 4/8/92 meeting with City of Portland Representatives 4. 1. 6 4. 1. Frame Begins 1 Ends 1 - 0000005 Microfilm Reel DATE: 04/13/92 PAGES: AUTHOR: Debbie Bailey/DEQ ADDRESSEE: File/ DESCRIPTION: 4/8/92 meeting minutes 2 SUB-HEAD: 4. 2. ARARs 4. 2. . Frame Begins 1 Ends 1 - 0000001 Microfilm Reel DATE: 01/15/92 PAGES: 200 AUTHOR: Sally Puent/oregon Dept. of Environmental Quality (DEQ) ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Cover letter and attached packet of information on the prelimina~~ list of ARARs - a summary describing the ARARs is ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMIN1STRATIVE RECORD INDEX - Fage ------- 06/24/93 U. S. Environmental Prot~ction Agency, Region 10 Page 39 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 5. o. ENFORCEMENT SUB-HEAD: 5. 1. Correspondence - 0000001 Microfilm Reel DATE: 08/14/87 PAGES: AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe & Hess DESCRIPTION: Letter stating EPA's conditions for a that unless these conditions are met, 5. 1. Frame Begins o Ends o 2 good faith proposal, and EPA will conduct the RI/FS - 0000002 Microfilm Reel DATE: 08/26/87 PAGES: AUTHOR: Lee M. Hess/Swire, Riebe ADDRESSEE: D. Henry Elsen/EPA DESCRIPTION: Letter setting out their 5. 1. Frame Begins o Ends o 3 & Hess client's (Stan Hodes) position - 0000003 Microfilm Reel DATE: 08/27/87 PAGES: 2 AUTHOR: Lee M. Hess/Swire, Riebe... ADDRESSEE: Henry Elsen/EPA DESCRIPTION: Cover letter for Scope of Work submittal 5. 1. Frame Begins o Ends o - 0000004 Microfilm Reel DATE: 08/28/87 PAGES: AUTHOR: D. Henry Elsen/EPa ADDRESSEE: Lee. M. Hess/Swire, Riebe... DESCRIPTION: Letter responding to Mr. Hess' 5. 1. Frame Begins o Ends o 2 letter of 8/26/87 5. 1. Microfilm. Reel PAGES: Wong/EPA Frame Begins o Ends o - 0000005 DATE: 09/01/87 AUTHOR: Philip M. ADDRESSEE: File/ DESCRIPTION: Memorandum stating that if owner does within 60 days, then EPA will conduct initiated for EPA funding 1 not submit a proposal ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 40 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 1. Frame Begins o Ends o - 0000006 Microfilm Reel DATE: 09/01/87 PAGES: AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe... DESCRIPTION: Letter stating that EPA will good faith proposal 1 not extend the 9/8/87 deadline for - 0060007 Microfilm. Reel DATE: 09/08/87 PAGES: 8 AUTHOR: Lee M. Hess/Swire, Riebe... ADDRESSEE: Henry Elsen/EPA DESCRIPTION: Cover letter and accompanying 5. 1. Frame Begins o Ends o good faith proposal - 0000008 Microfilm Reel DATE: 09/15/87 PAGES: AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe... DESCRIPTION: Letter stating 2 conditions continue negotiations 5. 1. Frame Begins o Ends o 1 that must be met in order for EPA to - 0000011 Microfilm Reel 1 DATE: 09/18/87 PAGES: 7 AUTHOR: Lee M. Hess/Swire, Riebe & Hess ADDRESSEE: Edward J. Dunn/John R. Boomer/Richard J. Price/Jay T. Waldron/Roger Westendorf/Lyle Cerney DESCRIPTION: Letter and attachments discussing expense estimate from Century West and deadline for submitting.a~etailed work plan to EPA 5. 1. Frame Begins 1 Ends 1 - 0000009 Microfilm Reel DATE: 09/25/87 PAGES: AUTHOR: Lee M. Hess/Swire, Riebe ADDRESSEE: Henry Elsen/EPA DESCRIPTION: Cover letter and attached 5. 1. Frame Begins o Ends o 6 copy of Industrial Indemnity's letter - 0000012 Microfilm Reel 1 DATE: 01/28/88 PAGES: 1 AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/swire, Riebe and Hess DESCRIPTION: Letter .stating that Hess' offer of consideration and that Monica Kirk to the case 5. 1. Frame Begins 1 Ends 1 settlement is under ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 41 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 1. - 0000010 Microfilm Reel 1 DATE: 02/11/88 PAGES: 5 AUTHOR: Monica Kirk/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe DESCRIPTION: Letter re: Allied Plating Settlement, enclosed Frame Begins 1 Ends 1 Consent for Access form - 0000014 Microfilm Reel DATE: 03/10/88 PAGES: AUTHOR: Lee M. Hess/Swire, Rieve ADDRESSEE: Monica J. Kirk/EPA DESCRIPTION: Cover letter and attached 5. 1. 1 4 & Hess Frame Begins 1 Ends 1 Voluntary Consent forr Blocks Hand L - 0000013 Microfilm Reel 1 DATE: 07/22/88 PAGES: 2 AUTHOR: Yone C. McNally/Oregon Dept. of Environmental Quality ADDRESSEE: Monica Kirk/EPA DESCRIPTION: Letter re: DEQ Administrative Actions Against Allied Plating, et al . 5. 1. Frame Begins 1 Ends 1 - 0000015 Microfilm Reel 1 DATE: 11/14/88 PAGES: 6 AUTHOR: Monica Kirk/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe & Hess DESCRIPTION: Letter re: offer made on behalf of client, and the property owner's responsibility to acquire Associated Crane and Truck Parts ',. 5. 1. Frame Begins 1 Ends 1 noting that it is access from - 0000016 Microfilm Reel 1 DATE: 11/02/89 PAGES: . 1 AUTHOR: Stan Hodes/ ADDRESSEE: Philip Millam/EPA DESCRIPTION: Letter re: EPA's letter of 10/30/89, noting present attorney and advising that he may not be able to meet stated deadline 5. 1. Frame Begins 1 Ends ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 42 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 1. - 0000017 Microfilm Reel 1 DATE: 11/09/89 PAGES: 1 AUTHOR: Marvin S. W. Swire/Sussman, Shank, Wapnick, Caplan & stiles ADDRESSEE: Monica Kirk/EPA DESCRIPTION: Letter confirming that the time be extended to reply to communication asking for field studies on property Frame Begins 1 Ends 1 5. 1. - 0000018 Microfilm Reel 1 DATE: 11/14/89 PAGES: 2 AUTHOR: Monica Kirk/EPA ADDRESSEE: Marvin swire/Sussman, Shank, et al DESCRIPTION: Letter stating terms that EPA can consider, and confirming extension of time to respond to EPAs request for access to the site Frame Begins 1 Ends 1 5. 1. - 0000019 Microfilm Reel 1 DATE: 11/17/89 PAGES: 3 AUTHOR: Jeffrey R. Spere/Sussman, Shank, et al ADDRESSEE: Monica Kirk/EPA DESCRIPT~ON: Letter granting access to portions of the property Frame Begins 1 Ends 1 5. 1. - 0000020 Microfilm Reel 1 DATE: 01/24/90 PAGES: 1 AUTHOR: Edward J. Kowalski/EPA ADDRESSEE: Jeffrey R. Spere/Sussman, Shank, et al DESCRIPTION: Letter inquiring whether RI/FS Scoping Report was stating that EPA needs a signed co~y of an access Frame Begins 1 Ends 1 received, and agreement SUB-HEAD: 5. 2. Notice Letters and Responses - 0000001 Microfilm Reel DATE: 09/02/82 PAGES: AUTHOR: Alexandra B. Smith/EPA ADDRESSEE: Ernst Stierly/Allied Plating DESCRIPTION: CERCLA 104 (e) information request 5. 2. Frame Begins o Ends o ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 43 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 2. - 0000002 Microfilm Reel Frame Begins 0 Ends 0 DATE: 01/31/85 PAGES: 1 AUTHOR: H.S. Coulter/Oregon Dept. of Transportation (DOT) ADDRESSEE: Ernest A. Schmidt/EPA DESCRIPTION: Letter re: state's ownership of property Frame Begins 0 Ends 0 - 0000003 Microfilm Reel DATE: 03/95/85 PAGES: AUTHOR: Robert A. Sandmann/DOT ADDRESSEE: Ernest A. Schmidt/EPA DESCRIPTION: Letter re: state's boundaries requesting a meeting 5. 2. 1 near Allied Plating, and 5. 2. - 0000004 Microfilm Reel Frame Begins 0 Ends 0 DATE: 12/10/85 PAGES: 2 AUTHOR: J. B. Boyd/DOT ADDRESSEE: Charles E. Findley/EPA DESCRIPTION: Response to 11/20/85 Information Request 5. 2. - 0000005 Microfilm Reel Frame Begins 0 Ends 0 DATE: 05/05/87 PAGES: 4 AUTHOR: Charles E. Findley/EPA ADDRESSEE: J.B. Boyd/DOT DESCRIPTION: CERCLA 104 (e) notice letter 5. 2. - 0000006 Microfilm Reel Frame Begins 0 Ends 0 DATE: 05/05/87 PAGES: 4 AUTHOR: Charles E. Findley/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: CERCLA 104 (e) notice letter 5. 2. - 0000007 Microfilm Reel Frame Begins 0 Ends 0 DATE: OS/27/87 PAGES: 1 AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe... DESCRIPTION: Cover letter for copies of information request sent to Hess's client, St;an Hodes ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 44 Page ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 2. - 0000008 Microfilm Reel DATE: 06/05/87 PAGES: AUTHOR: J. B. Boyd/DOT ADDRESSEE: Philip Wong/EPA DESCRIPTION: Response to 5/5/87 notice 4 letter 5. 2. - 0000009 Microfilm Reel DATE: 06/05/87 PAGES: 1 AUTHOR: Lee M. Hess/Swire, Riebe... ADDRESSEE: Charles E. Findley/EPA DESCRIPTION: Letter stating that 5/5/87 notice 5/29/87, requesting until 6/29 to 5. 2. - 0000010 Microfilm Reel DATE: 06/05/87 PAGES: 2 AUTHOR: Wendy A. Robinson/Dept. of ADDRESSEE: Henry Elsen/EPA DESCRIPTION: Response to 5/5/87 notice Justice letter sent to DOT Frame Begins o Ends o Frame Begins o Ends o letter was not received until submit response Frame Begins Ends o o 5. 2. - 0000011 Microfilm Reel Frame Begins 0 Ends 0 DATE: 06/15/87 PAGES: 1 AUTHOR: D. Henry Elsen/EPA ADDRESSEE: Lee M. Hess/Swire, Riebe... DESCRIPTION: Letter granting extension to respond to 5/5/87 letter Frame, Begins 0 Ends 0 5. 2. - 0000012 Microfilm Reel DATE: 06/17/87 PAGES: AUTHOR: Lee M. Hess/Swire, Riebe ADDRESSEE: Phil Wonq/EPA DESCRIPTION: Partial response to 5/5/87 notice letter 3 5. 2. - 0000013 Microfilm Reel DATE: 06/29/87 PAGES: AUTHOR: Lee M. Hess/Swire, Riebe ADDRESSEE: Phil'Wong/EPA DESCRIPTION: Supplement to previous response 1 Frame Begins o Ends ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 45 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 2. - 0000014 Microfilm Reel DATE: 07/01/87 PAGES: AUTHOR: Lee M. Hess/Swire, Riebe ADDRESSEE: Phil Wong/EPA DESCRIPTION: Correction to error on deed Frame Begins o Ends o 1 5. 2. - 0000020 Microfilm Reel DATE: 07/e6/87 PAGES: AUTHOR: Charles Findley/EPA ADDRESSEE: Lee M. Hess (Attorney for stanley HOdes)/Swire, Riebe & Hess DESCRIPTION: Letter stating that RI/FS is determined to be necessary at the Allied Plating Site, offering Mr. and Mrs. Hodes 60 days to make a good faith proposal to conduct the RI/FS Frame Begins 1 Ends 1 3 5. 2. - 0000021 Microfilm Reel DATE: 07/06/87 PAGES: AUTHOR: Charles Findley/EPA ADDRESSEE: Herbert and Gloria Sugg/ DESCRIPTION: Letter stating that RI/FS is determined to be necessary at Allied Plating Site, offering Mr. and Mrs. Sugg 60 days in to make a good faith proposal to conduct the RI/FS Frame Begins 1 Ends 1 3 the which 5. 2. - 0000015 Microfilm Reel DATE: 07/28/87 PAGES: 3 AUTHOR: John s. Karpinski/Attorney at Law ADDRESSEE: Phillip Wong/EPA DESCRIPTION: Response to 7/6/87 request for information Frame Begins o Ends o 5. 2. - 0000016 Microfilm Reel DATE: 02/10/88 PAGES: AUTHOR: Charles E. Findley/EPA ADDRESSEE: Lee M. Hess/swire, Riebe... DESCRIPTION: Cercla 104 (b) request for information Frame Begins o Ends o 2 5. 2. - 0000017 Microfilm Reel 10/30/89 . PAGES: Phil Millam/EPA Stan Hodes/ . Notice letter that EPA will not accept settlement offer, will not enter into negotiations for PRP RI/FS, and, is providing formal notice of EPA conducted RI/FS Frame Begins o Ends o DATE: AUTHOR: ADDRESSEE: DESCRIPTION: ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 46 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 2. - 0000018 Microfilm Reel DATE: 11/02/89 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Phil Millam/EPA DESCRIPTION: Letter stating that Mr. of 11/20/89 Frame Begins o Ends o 1 Hodes may not be able to meet deadline 5. 2. - 0000019 Microfilm Reel DATE: 11/07/89 PAGES: AUTHOR: Monica Kirk/EPA ADDRESSEE: Wendy A. Robinson/Oregon Dept. DESCRIPTION: Letter notifying that EPA does of negotiation with DOT Frame Begins o Ends o 1 of Justice not intend to commence a period SUB-HEAD: 5. 3. Access Agreements 5. 3. - 0000001 Microfilm Reel DATE: 09/06/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: A.F. Grabhorn/ DESCRIPTION: Request for permission to drill and maintain monitoring wells; enclosures Frame Begins 1 Ends 1 7 5. 3. - 0000002 Microfilm Reel DATE: 09/06/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Ted and Elizabeth Lamm/ DESCRIPTION: Request for permission to enclosures 7 Frame Begins 1 Ends 1 drill ~nd'mairitain monitoring well~; 5. 3. - 0000003 Microfilm Reel DATE: 09/06/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Manager/Nabisco DESCRIPTION: Request for permission to drill and maintain monitoring wells; enclosures 7 Frame Begins 1 Ends ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 47 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 3. - 0000004 Microfilm Reel DATE: 09/06/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Navistar International Corp./ DESCRIPTION: Request for permission to drill and maintain monitoring wells; enclosures Frame Begins 1 Ends 1 7 - 0000005 Microfilm Reel DATE: 09/06/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Owner or Manager/Plew's Demolition and Construction, Inc. DESCRIPTION: Request for permission to drill and maintain monitoring wells; enclosures 5. 3. Frame Begins 1 Ends 1 7 - 0000006 Microfilm Reel DATE: 09/17/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Elizabeth Lamm/ DESCRIPTION: Confirmation that Mrs. Lamm has agreed to allow EPA to install wells on her property 5. 3. Frame Begins 1 Ends 1 1 - 0000007 Microfilm Reel DATE: 09/26/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Owner or Manager/Plew's Demo~ition and Construction, Inc. DESCRIPTION: Second request for permission to gain access and install monitoring wells on Plew's property 5. 3. Frame Begins 1 Ends 1 4 - 0000008 Microfilm Reel DATE: 09/26/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: stan B. Collins/ DESCRIPTION: Request for permission to drill and maintain monitoring wells; enclosures 5. 3. Frame Begins 1 Ends 1 4 ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 48 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 3. - 0000009 Microfilm Reel DATE: 10/09/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Al Grabhorn/ DESCRIPTION: Confirmation that Mr. Grabhorn has agreed to allow EPA to install wells on his property - signed agreement and letter attached 3 Frame Begins 1 Ends 1 5. 3. - 0000010 Microfilm Reel DATE: 10/09/90 PAGES: 3 AUTHOR: A.F. Morton/Nabisco Brands, Inc. ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Cover letter and attached signed Right-of-Entry to Property" Frame Begins 1 Ends 1 "Consent for Access and s. 3. - 0000011 Microfilm Reel DATE: 10/11/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Gene Plew/ DESCRIPTION: Letter requesting permission to access property and install monitoring well and stating that EPA has the authority to do this 3 Frame Begins 1 Ends 1 s. 3. - 0000012 Microfilm Reel DATE: 10/19/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Gene Plew/ DESCRIPTION: Letter requesting access request for access 2 Frame Begins 1 Ends 1 to two wells not included on original 5. 3. - 0000013 Microfilm Reel DATE: 10/22/90 PAGES: AUTHOR: Stan B. Collins/ ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Letter resending request 7 Frame Begins 1 Ends 1 . for access to property ------- 06/24/93 u. S. Environmental Prot~ction Agency, Region 10 Page 49 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 3. - 0000014 Microfilm Reel DATE: 10/22/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Terry Steinborn/URS Consultants DESCRIPTION: Letter delaying field work for one week required to obtain court ordered access Frame Begins 1 Ends 1 1 due to additional time to the property 5. 3. - 00~0015 Microfilm Reel DATE: 10/23/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: A.F. Morton/Nabisco DESCRIPTION: Letter acknowledging receipt of Frame Begins 1 Ends 1 1 access agreement 5. 3. - 0000016 Microfilm Reel DATE: 10/26/90 PAGES: 1 AUTHOR: H. Philip Eder/Reeves, Kahn & Eder ADDRESSEE: Dean B. Ingemansen/EPA DESCRIPTION: Letter listing terms under which Eder's client (Stan Hodes) will allow access to property Frame Begins 1 Ends 1 5. 3. - 0000017 Microfilm Reel DATE: 10/30/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: site file/ DESCRIPTION: Letter documenting 10~30/90 Associated Crane, lessee of Frame Begins 1 Ends 1 1 telephone conversation with the Allied Plating site 5. 3. - 0000018 Microfilm Reel DATE: 11/01/90 PAGES: AUTHOR: Dean B. Ingemansen/EPA ADDRESSEE: Plew's Demolition/ JESCRIPTION: Letter explaining statutory authority under which EPA may access to property, includes another request for access 5 Frame Begins 1 Ends 1 gain - 0000019 Microfilm Reel DATE: 11/09/90 PAGES: 3 AUTHOR: H. Philip Eder/Reeves, Kahn & Eder ADDRESSEE: Dean B. Ingemansen/EPA >ESCRIPTION: Cover letter and attached signed "Consent' for Accessand , Right-of-Entry to Property" 5. 3. Frame Begins 1 Ends ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 50 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 5. 3. - 0000020 Microfilm Reel DATE: 11/16/90 PAGES: 1 AUTHOR: Franz Rotter/High Tech Recycling Systems Corporation ADDRESSEE: / DESCRIPTION: Signed "Consent for Access and Right-of-Entry to Property" Frame Begins 1 Ends 1 5. 3. - 0000021 Microfilm Reel DATE: 11t~6/90 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Goerge Helm/Street System Management DESCRIPTION: Letter requesting permit to drill and intersection of NE Mallory Avenue and 2 Frame Begins 1 Ends 1 sample 1 borehole at the NE Halleck Street SUB-HEAD: 5. 4. Deed Restriction 5. 4. - 1001006 Microfilm Reel DATE: 04/13/93 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: Stan Hodes/ DESCRIPTION: Letter requesting that deed restriction property as soon as possible 1 Frame Begins 1 Ends 1 be placed on the 5. 4. - 1001007 Microfilm Reel DATE: 04/15/93 PAGES: AUTHOR: Kevin Rochlin/EPA ADDRESSEE: H. Philip Eder/Reeves, Kahn & Eder DESCRIPTION: Addition to the Deed Restriction 1 Frame Begins 1 Ends 1 5. 4. - 1001005 Microfilm Reel DATE: 04/28/93 PAGES: 2 AUTHOR: H. Philip Eder/Reeves, Kahn & Eder ADDRESSEE: Kevin Rochlin/BPA DESCRIPTION: Cover letter and enclosed copy of the Restrictions Frame Begins 1 Ends 1 ------- 06/24/93 u. s. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX : Page ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 Page 52 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 6. O. HEALTH ASSESSMENTS SUB-HEAD: 6. 2. ATSDR Health Assessments 6. 2. - 0000001 Microfilm Reel DATE: 07/19/88 PAGES: 2 AUTHOR: Agency for Toxic Substances and Disease Registry/(ATSDR) ADDRESSEE: / DESCRIPTION: Pr~liminary Health Assessment for Allied Plating, Portland, Oregon Frame Begins o Ends ------- 06/24/93 U. S. Environmental Prot~ction Agency, Region 10 Page 53 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING:. 7. O. NATURAL RESOURCE TRUSTEES SUB-HEAD: 7. 1. Correspondence 7. 1. - 0000001 Microfilm Reel DATE: 10/20/88 PAGES: AUTHOR: Robert Pavia/NOAA ADDRESSEE: Bruce M. Diamond/NOAA DESCRIPTION: NOAA's Preliminary Natural Resource Survey for (Confidential portion of this document located Headquarters, Seattle, WA) Frame Begins o Ends o 7 Allied Plating at EPA Region 10 SUB-HEAD: 7. 2. Preliminary Natural Resource Survey 7. 2. - 1001004 Microfilm Reel DATE: 04/09/93 PAGES: 21 AUTHOR: Jonathan P. Deason/U.S. Dept. of the Interior ADDRESSEE: Randall F. Smith/EPA DESCRIPTION: Cover letter re: Preliminary Natural Resources Survey and attached "Background and Technical Support Information" Frame Begins 1 Ends 1 ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 54 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 8. O. CONGRESSIONAL/PRESIDENTIAL INQUIRIES SUB-HEAD: 8. 1. Correspondence 8. 1. - 0000001 Microfilm Reel DATE: 03/07/85 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: President Reagan/ DESCRIPTION: Letter to inform President of 3 Frame Begins o Ends o serious problem at Allied Plating 8. 1. - 0000002 Microfilm Reel DATE: 03/17/85 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: President Reagan/ DESCRIPTION: Letter stating the Hodes Plating 5 Frame Begins o Ends o family's thoughts in regard to Allied 8. 1. - 0000003 Microfilm Reel DATE: 04/04/85 PAGES: AUTFOR: Ernesta B. Barnes/EPA ADDRESSEE: Bob Packwood/U.S. Senate DESCRIPTION: Response to 3/19/85 letter 2 Frame Begins o Ends o 8. 1. - 0000012 Microfilm Reel DATE: 02/02/87 PAGES: AUTHOR: Joan Shafer/EPA ADDRESSEE: Representative Ron Wyden/ . DESCRIPTION: Cover letter for Superfund public docket for the Allied Plating facility, 1/22/87 Federal Register announcing proposal to include Allied Plating to the NPL 1 Frame Begins 1 Ends 1 8. 1. - 0000011 Microfilm Reel DATE: 03/17/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: The President/ DESCRIPTION: Letter stating Plating 2 Frame Begins 1 Ends 1 Mr. Hodes' observations of situati~n at Allied ------- 06/24/93 u. S. Environmental Prot~ction Agency, Region 10 Page 55 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 8. 1. - 0000004 Microfilm Reel DATE: 04/09/87 PAGES: AUTHOR: Fred Hansen/DEQ ADDRESSEE: Mark Hatfield/U.S. Senate DESCRIPTION: Response to 3/31/87 letter Frame Begins o Ends o 1 - 0000005 Microfilm Reel DATE: 06/~/87 PAGES: AUTHOR: Philip M. Wong/EPA ADDRESSEE: Ron Wyden/Congressman DESCRIPTION: Cover letter transmitting 8. 1. Frame Begins 0 Ends 0 1 copy of EPA's file on Allied Plating Frame Begins 0 Ends 0 2 8. 1. - 0000006 Microfilm Reel DATE: 08/25/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: President Reagan/ DESCRIPTION: Letter asking for a de minimis settlement 8. 1. - 0000007 Microfilm Reel DATE: 10/07/87 PAGES: AUTHOR: Tom Miller/DEQ ADDRESSEE: Margaret Carter/Representative, Oregon, DESCRIPTION: Letter transmitting Community Relations Frame Begins o Ends o 1 Legislative District 18 Plan 8. 1. - 0000008 Microfilm Reel DATE: 11/13/87 PAGES: 10 AUTHOR: Stanley Hodes/ ADDRESSEE: Mark Hatfield/U.S. Senate DESCRIPTION: Letter re: hexavalent chrome, Frame Begins o Ends o sample charts enclosed - 0000009 Microfilm Reel DATE: 12/08/87 PAGES: AUTHOR: Stan Hodes/ ADDRESSEE: Robie Russell/EPA )ESCRIPTION: Letter in response to 8. 1. Frame Begins o Ends o 1 8/25/87 letter to President Reagan ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 56 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 8. 1. - 0000010 Microfilm Reel DATE: 03/30/88 PAGES: AUTHOR: Tim Brincefield/EPA ADDRESSEE: Merrie H. Buel/Field Representative for DESCRIPTION: Letter transmitting Community Relations Frame Begins o Ends o 1 Congressman Ron Wyden Plan 8. 1. - 0000014 Microfilm Reel DATE: 12f19/89 PAGES: 4 AUTHOR: Mark O. Hatfield/United States Senate ADDRESSEE: Robie Russell/EPA DESCRIPTION: Letter requesting review and response to attached letter from stan Hodes Frame Begins 1 Ends 1 8. 1. - 0000013 Microfilm Reel DATE: 01/05/90 PAGES: AUTHOR: Robie G. Russell/EPA ADDRESSEE: Honorable Mark O. Hatfield/United States Senate DESCRIPTION: Letter in response to the 12/19/89 request from constitutent, Stan Hodes 2 Frame Begins 1 Ends 1 Hatfield's 8. 1. - 0000015 Microfilm Reel DATE: 04/25/90 PAGES: AUTHOR: stan Hodes/ ADDRESSEE: Richard Darman/Office of Management and Budget DESCRIPTION: Letter stating that EPA has involved Mr. Hodes in an expensive Remedial Investigation that by reasonable standards should not take place 8 Frame Begins 1 Ends 1 8. 1. - 0000016 Microfilm Reel DATE: 10/23/90 PAGES: 3 AUTHOR: Walter G. Gilbert/Office of the Inspector General ADDRESSEE: Kevin Rochlin/EPA DESCRIPTION: Cover letter and attached copy of letter sent to Stan Hodes reqardinq his allegations of EPA mismanagement of the Allied Plating Superfund Site Frame Begins 1 Ends ------- 06/24/93 u. S. Environmental Protection Agency, Region 10 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX - Page ------- 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 58 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX . HEADING: 9. O. PUBLIC PARTICIPATION SUB-HEAD: 9. 2. Community Relations Plan 9. 2. - 0000001 Microfilm Reel DATE: 09/01/87 PAGES: 34 AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Fi~l Community Relations Plan Frame Begins o Ends o 9. 2. - 0000002 06/19/91 EPA/ / Superfund Microfilm Reel PAGES: 1 Frame Begins 1- Ends 1 DATE: AUTHOR: ADDRESSEE: DESCRIPTION: Community Relations Plan Addendum Site Schedule Update SUB-HEAD: 9. 3-. Fact Sheets and Press Releases 9. 3. - 0000002 Microfilm Reel DATE: 01/22/87 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: News release 5 Frame Begins o Ends o 9. 3. - 0000003 Microfilm Reel DATE: 01/22/87 PAGES: AUTHOR: EPA/ ADDRESSEE: / )ESCRIPTION: News release 3 Frame Begins o Ends o 9. 3. - 0000001 DATE: 02/02/87 AUTHOR: EPA/ ADDRESSEE: / IESCRIPTION: Fact Sheet Microfilm Reel PAGES: 1 Frame Begins o Ends o ------- 06/24/93 u. S. Environmental Pro~ection Agency, Region 10 Page 59 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX 9. 3. - 0000004 Microfilm Reel DATE: 03/02/90 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Fact Sheet Allied Plating 2 Frame Begins o Ends o 9. 3. - 0000005 Microfilm Reel DATE: 11/01/90 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Superfund Fact Oreqon 1 Frame Begins 1 Ends 1 Sheet: Allied Platinq Superfund Site, Portland, 9. 3. - 0000006 Microfilm Reel DATE: 06/19/91 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Superfund Fact Sheet: investiqate the extent Superfund Site 2 Frame Beqins 1 Ends 1 Allied Plating: EPA is continuing to of contamination at the Allied Platinq 9. 3. ,. - 0000007 Microfilm Reel DATE: 10/19/92 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: Superfund Fact Sheet: Allied Platinq : On 10/21/92 EPA will beqin a removal action to excavate and dispose of contaminated soil from the Allied Plating Superfund Site 1 Frame Begins 1 Ends 1 SUB-HEAD: 9. 4. Newspaper Articles 9. 4. - 0000001 Microfilm Reel DATE: 01/23/87 PAGES: 1 AUTHOR: Michael Rollinqs/The Oreqonian ADDRESSEE: / )ESCRIPTION: Newspaper article "EPA names Portland sludqe pond for Superfund Cleanup" Frame Beqins 1 Ends 1 - ------- .. 06/24/93 U. S. Environmental Protection Agency, Region 10 Page 60 . ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX SUB-HEAD: 9. 5. Public Notices 9. 5. - 1001002 Microfilm Reel DATE: / / PAGES: AUTHOR: / ADDRESSEE: / DESCRIPTION: Newspaper notice announcing the Public Comment Period on Proposed Plan for Allied Plating Superfund Site - 4/28-5/28/93 1 Frame Begins 1 Ends 1 SUB-HEAD: 9. 6. Proposed Plan 9. 6. - 1001001 Microfilm Reel DATE: 04/29/63 PAGES: AUTHOR: EPA/ ADDRESSEE: / DESCRIPTION: The Proposed 5 Frame Begins 1 Ends 1 Plan - PUblic Comment Period 4/28-5/28/93 ------- 06/24/93 U. S. Environmental prot~ction Agency, Region 10 Page 61 ALLIED PLATING - REMEDIAL ADMINISTRATIVE RECORD INDEX HEADING: 10. O. TECHNICAL SOURCES AND GUIDANCE DOCUMENTS SUB-HEAD: 10. 1. EPA Guidance 10. 1. Microfilm Reel PAGES: Frame Begins o Ends o - 0000001 DATE: 08/01/90 AUTHOR: EPAI ADDRESSEE: / DESCRIPTION: List of 4 Guidances Used SUB-HEAD: 10. 2. State Guidance 10. 2. - 0000001 Microfilm Reel DATE: 09/09/88 PAGES: 88 AUTHOR: Fred HansenlDEQ ADDRESSEE: Environmental Quality Commission (EOC) I DESCRIPTION: Agenda Item X, 9/9/88, EOC M~eting, Executive Summary of Staff Report Requesting Adoption of Proposed Remedial Action Rules Regarding Degree of Cleanup and Selection of the Remedial Action, OAR Chapter 340, Division 122 Frame Begins o Ends o SUB-HEAD: 10. 3. Technical Sources 10. 3. - 0000001 Microfilm Reel DATE: I I PAGES: AUTHOR: I ADDRESSEE: / DESCRIPTION: 3 page excerpt on Chromium Frame Begins o Ends o 3 10. J. - 0000002 MicrofilmReel DATE: 07/06/90 PAGES: 11 AUTHOR: Pat Cirone/EPA ADDRESSEE: Superfund Remedial Project Managers JESCRIPTION: Memorandum re: Detection Limits for Frame.Begins 1 Ends 1 and OSC'sIEPA Human Health Risk Assessment ------- |