United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R10-93/060
June 1993
S-EPA Superfund
Record of Decision:
American Crossarm &
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50272-101
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REPORT DOCUMENTATION 1" REPORT NO. 2. 3. Reclplanra Acca8810n No.
PAGE EPA/ROD/R10-93/060
4. Tltla and Subtitle 5. Rlport Data
SUPERFUND RECORD OF DECISION 06/30/93
American Crossarm & Conduit, WA 6.
First Remedial Action - Final
7. Author(s) 8. Parformlng Organization Rlpt. No.
9. Performing Organization Nama and Addr- 10 Projact TaakIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Spon80rtng Organization Nama and Add,.. 13. Type of Raport & Parlod Covarad
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Suppllmantary Not..
PB94-964623
18. Abstract (Limit: 200 worda)
The 14-acre American Crossarm & Conduit site is an inactive wood treatment facility in
Chehalis, Lewis County, Washington. Land use in the area is predominantly a
cOmbination of commercial, light industrial, residential, and recreational. Several
wetlands are located directly south of the facility which drain into a tributary of the
Chehalis Rive r , one of two major rivers in the area. In addition, the site lies within
the 100-year floodplain of the Chehalis and Newaukum rivers in a marshy lowland, one
mile east of the Chehalis River. The estimated 6,500 people who reside in Chehalis use
the Newaukurn River, at a location approximately 17 miles upstream of the American
Crossarm & Conduit (ACC), to obtain their primary drinking water supply. From the
early 1930s to 1985, ACC used the site for wood cutting, milling, and treating
operations. The facility is composed of four areas: a landfill, a mill, kilns, and a
wood treatment works. Wastewater from wood processing operations, at three of these
areas, was discharged directly to the environment until 1983, when the State determined
that the ACC facility was not in compliance with the State's waste handling
requirements. The State required the ACC to eliminate wastewater discharges to the
environment, redirect all boiler blow down to the sanitary sewer collection system, and
prepare a wastewater treatment and disposal plan. In late 1983, ACC ceased the onsite
(See Attached Page)
17. Documant Analye" a. Dasc:rlptora
Record of Decision - American Crossarm & Conduit, WA
First Remedial Action - Final
Contaminated Media: soil, sediment, gw, sw
Key Contaminants: organics (dioxins, PAHs, PCPs)
b. IdantlfiaralOpen-Endad Tarma
c. COSATI FlaldfGroup
18. Availability Statamant 19. Security Class (ThIs Report) 21. No. of Pag..
None 72
20. Security ClalS (ThIs Page) 22. Prlca
None
!
(SH ANSI-Z39.18)
SHlnstrucUons on Rlv8rss
OPTIONAL FORM 272 (4-77)
(Formarty NTIS-3S)
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EPA/ROD/R10-93/060
American Crossarm & Conduit, WA
First Remedial Action - Final
Abstract (Continued)
wood milling and treatment operations. The improper discharges have resulted in both
onsite and offsite contamination, due to runoff via natural site drainage features. The
periodic flooding of the site by the Chehalis River also has transported site contaminants
off site and resulted in adjacent areas of contamination (AOC) directly related to the ACC.
In 1985, PCP-contaminated soil was removed from the facility and used as fill in
residential yards located to the east of the facility. The State ordered ACC to remove
the contaminated soil and clean up the affected areas to a level of PCP 100 ug/kg. In
1986, one of the periodic Chehalis River floods caused the release of 10,000 gallons of an
organic solution to the AOC. This discharge prompted an EPA removal action, which
involved excavation or removal of contaminated soil, debris, furniture, and other material
from the AOC, and consolidation of this material on the ACC facility. In 1988, an onsite
incinerator was installed by EPA to treat this material. In 1992, a second removal action
involved the removal of liquid wood treating wastes and laboratory chemicals from the'
facility, and containment of this material in sealed drums, located on the ACC facility.
This investigation revealed that unacceptable risks to human health and environment exist
from the remaining contamination in soil, sediment, debris, ground water, and surface
water. This ROD addresses these media as the final remedial action for the site. The
primary contaminants of concern affecting the soil, sediment, debris, ground water, and
surface water are organics, including dioxin, PAHs, and PCP.
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The selected remedial action for this site includes demolishing, removing, and recycling,
if appropriate, all existing structures on the ACC facility; excavating 20,000 yd3 of
surface and subsurface soil from the most highly-contaminated areas of the ACC facility,
with offsite solidification followed by off site disposal in an approved landfill;
excavating and consolidating onsite 14,300 yd3 of soil from the AOC with the incinerator
ash from the earlier incineration of contaminated soil and debris; backfilling the
excavated areas of the ACC with the consolidated material, filling the ACC and AOC to the
surrounding grade with soil and fill, and revegetating the area; removing and disposing of
sediment from the stormwater discharge lagoon and the stormwater sewer, with offsite
disposal in an approved landfill; implementing runoff/run-on controls to prevent
contaminated ground water from entering the wetlands; treating wastewater generated from
site activities, with onsite or offsite disposal; abandoning unnecessary onsite wells;
removing any floating product from ground water under the facility, with offsite disposal
at a hazardous waste facility; conducting performance monitoring; and implementing
institutional controls, including deed restrictions, and site access restrictions,
including fencing. The estimated present worth cost for this remedial action is
$9,700,000, which includes an estimated total O&M cost of $250,000 for 1 year.
PERFORMANCE STANDARDS OR GOALS:
Soil and ground water cleanup goals are based on State standards. Chemical-specific soil
excavation goals include dioxins 0.0066 ug/kg; PAHs 172 ug/kg; and PCP 8,330 ug/kg. These
levels are consistent with human health-based risk levels of 10-6 in the AOC and 10-5 at
the ACC facility. Chemical-specific ground water cleanup goals include dioxins 0.00058
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AMERICAN CROSSARM & CONDUIT
RECORD OF DECISION
May 1993
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DECLARATION
SITE NAME AND LOCATION
1
American Crossarm and Conduit (ACC)
Chel,1alis, Lewis County, Washington
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STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial action for the
American Crossarm & Conduit (ACC) site, in Chehalis, Lewis County, Washing-
ton, which was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) (42 U.S.C. 9601), as
amended by the Superfund Amendments arid Reauthorization Act (SARA), and, to
the extent practicable, the National Contingency Plan (NCP). This decision is
based on the Administrative Record.
The Washington State Department of Ecology (Ecology) concurs with the selected
remedy.
ASSESSMENT OF THE FACILITY AND ADJACENT AREAS OF
CONTAMINATION
Actual or threatened releases of hazardous substances from this facility, if not
addressed by implementing the response action selected in this Record of Decision
(ROD), may present an imminent and substantial endangerment to public health,
welfare or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this Record of Decision represents a final
remedy, which includes the ACC facility and adjacent ares of contamination
(AOC). Previous removal actions have been completed. An emergency removal
action was initiated during late 1986 to remove contamination distributed during
a flood in the Chehalis Avenue ~ea. In 1988, an incinerator was brought on the
facility to incinerate the principle threat (e.g. con~m;nated material from that
cleanup). The remedial action presented in this ROD addresses the remaining
low-level threats (to hnman health and environment) by 1) demolish, remove and
recycle existing facility structures, 2) removing the most highly contam;nated soil
on the facility to prevent hnman contact and future dispersion into the
environment, 3) excavate soil _from the Chehalis Ave. Area and consolidate it on
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American Crossarm & Conduit Record of Decision
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the facility, 4) reducing gross floating product in groundwater beneath the facility
to meet applicable or relevant and appropriate requirements (ARARs) at the
facility boundary and prevent migration, 5) covering the facility with clean soil
and vegetation to prevent human contact with and dispersion of the lessor
contaminated soil, 6) invoking institutional controls at the facility to warn future
property owners of potential threats and limit the use of the property (specifically
to prevent intrusive activities), and 7) implementing performance monitoring to
assess the effectiveness of the remedial action.
The major components of the selected remedy include:
. Excavation of contaminated soil from the Chehalis Avenue
commerciaJ/residential AOC and consolidation of this material on the ACC
facility. Excavated areas would undergo confirmatory sampling and be
backfilled with clean soil and revegetated or covered as appropriate.
. Demolition of the ACC facility (e.g., treatment works, mill, kilns, above and
below ground storage tanks, and all other structures).
. Excavation of the ACC facility surface and subsurface soil from the most
highly cont3minated areas.
. Removal of floating oil from groundwater under the facility (treatment
works) as a short-term source control activity.
. Removal of contaminated sediment from the stormwater discharge lagoon
and stormwater sewer for off-site. disposal.
. Disposal of the most highly cont.aminated excavated material at an ap-
proved off-site hazardous waste landfill. The material would be solidified at
the off-site landfill prior to disposal. .
. Covering the ACC facility with clean soil, sloping and contouring land, and
planting grass.
. Implementing fencing and deed restrictions at the ACC facility.
. Maintenance of soil cover and other institutional controls.
. Performance monitoring and five year reviews
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American Crossarm & Conduit Record of Decision
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, compnes
with federal and state requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable for this facility and AOC. Because treatment
of the low-level threat was not found to be practicable, this remedy does not
satisfy the statutory preference for treatment as a principal element of the final
remedy. The ACe facility and AOC lie in an active flood plain, yn:lking the
installation and operation of any remedial treatment process is technically
impractical. In addition, the cost for treatment off-site was found to be excessive
in comparison to the environmental benefits. These conditions precluded selecting
a remedy in which cont:lrninants of concern would be treated on-site.
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Because this remedy will result in hazardous substances rern:lining on the facility
above health-based levels, a review of the facility will be conducted within five
years after commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
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Signature (State)
Date:. ~ /DJ '.,Qti3
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DECISION SUMMARY
INTRODUCTION
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The American Crossarm & Conduit (ACC) facility, Chehalis, Lewis County,
Washington was nominated to the National Priorities List (NPL) in 1989. The
nomination was based on a Hazard Ranking System (RRS) score from a site
assessment performed by the United States Environmental Protection Agency
(EP A) in 1988 pursuant to Section 105 of the Comprehensive Environmental
'Response, Compensation, and Liability Act of 1980,42 U.S.C. Section 9605, as
amended by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA or Superfund).
Pursuant to Executive Order 12580 (Superfund Implementation) and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300, EPA performed a Remedial Investigation/Feasibility Study (RllFS). The
Remedial Investigation (RI) characterized contamination in soil, surface water and
groundwater at the facility and adjacent ares of cont.$lmin8tion (AOC). A .
(baseline) risk assessment was completed as part of the RI and evaluated potential
effects of the eontslminsition on human health and the environment. The
Feasibility Study (FS) completed in September 1992, evaluated alternatives for
remediating cont.jlmination.
NAME, LOCATION, AND DESCRIPTION
The American Crossarm & Conduit facility is located in Chehalis, Lewis County,
Washington in Section 32, Township 14 No~ Range 2 West, of the. Centralia
Quadrangle. The 14-acre inactive wood treating facility is located on the south
edge of Chehalis within the 100-year floodplain of the Chehalis and Newaukum
rivers, Figure 2-1. Areas of contAminRtion adjacent-to the facility cont.$lminRted
from release from the facility are also illustrated.
The facility is constructed east of the elevated.Burlington Northern-Union Pacific (BN-
UP) railroad tracks and placed on pilings and fill in a low-lying marsh. The
facility is composed of four areas including a wood treatment works, kilns, mill,
and a landfill, Figure 2-2. The wood treatment area is enclosed by a fence and
contains underground tanks, sumps, a former surface impoundment, and a control
room which were used to treat wood with a mixture of diesel and pen-
tachlorophenol (PCP).. A city of ChebaJis storm drain runs from Chehalis Avenue
across the treatment area and discharges to a stormwater discharge lagoon.
contiguous to Dillenbaugh Creek. The facility also includes an elevated crane-way
and 8 kilns used to dry timber prior to treatment. The mill is a large wooden
structure' that contained wood crossbars and conduit manufacturing equipment. It
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American Crossarm & Conduit
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ProjIIcI Numbr. 4CIOCH)1-32.(1QQ1 0aI4I: Marcil 1193
American Crossarm & Conduit
Facility and AOC Features
FIGURE
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American Cro~S4rm & Conduit" R~"m f)f Decisio~ .".
is constructed in a low-lying area, on posts/pilings to elevate it to the height of the
kilns. .
A landfill, used from the 1930s to 1985, is located south of the mill. A ditch
parallel to the BN-UP railroad track defines the western edge of the landfill. The
landfill was used for disposal of wastes generated from operation of the facility.
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The AOC adjacent to the facility area include the Chehalis Avenue area (a
commercial/residential section of the city which includes a play field), wetland
south and west of the facility, a section of Dillenbaugh Creek, and a stormwater
discharge lagoon. South of the facility is a wetland area (approximately 37 acres)
which is traversed by the BN-UP railroad tracks. The wetland discharges to Dillen-
baugh Creek.
HISTORY AND ENFORCEMENT ACTIVITIES
History
From the early 1930s to 1985, ACC conducted wood cutting and milling
operations. Wood waste, a waste stream from the milling operation, was placed in
the wetland creating a landfill. N oncontact cooling water and boiler"blowdown
from the mill operation were drained to the wetland. Other waste streams
released from the facility may have included lubricating oils, diesel and gasoline.
Wood treating began in the early 1930s. Crossarms and conduit for electrical
utility poles were treated in open dip tanks with hot or cold creosote and PCP.
Tank sludge is suspected to have been disposed of in the landfill. Solvents, paints,
paint thinners, lubricating oils, petroleum products, and other miscellaneous
wastes may also have been disposed of in the landfill. (It is suspected that
" granular fill from off-site sources Unrelated to ACe activities was deposited in the
landfill.) The landfill was not designed, constructed, or operated in accordance
with current landfill practices.
ACC changed its treatment operation to a pressure-treating process which was - .
constructed north of the kilns. The operation included a chemical make up area,
two pressure retorts, a vapor recovery system, a separation tank, two sumps, a
surface impoundment, and a drag out area for drying treated lumber. The
chemical makeup consisted of an operation in which solid PCP was mixed with
diesel to make a 5% PCP solution.
2-4
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American Crossarm & Conduit Ret:Ord of Decision.
Contamination during plant operations resulted from the wood treatment process
primarily through five methods:
. Discharge of liquids from the vapor recovery system to the city stormsewer,
which subsequently discharged to the stormwater discharge lagoon west of
the facility.
. Discharge of wastewater from the process building sumps to the surface
impoundment.
. Removal and disposal of sludge from the bottom of the surface impound-
ment to the landfill south of the mill.
. Dispersion of contaminants in the treatment works tanks, pipes and sumps
around the facility due to flooding.
. Miscellaneous leaks and spills around the facility.
Wood from the mill was dried in kilns until 1983. Discharges from the kilns may
have contained wood lignin, tannic acids, and other naturally occurring wood
constituents. The kilns are believed to have been heated by burning scrap wood
and other combustible material (although auxiliary diesel fuel was available).
. Asbestos containing materials and electrical equipment cont~in1ng polychlorinated
biphenyls were also present in the mill, but were removed in 1992. Property to
the east of the facility previously housed milling operations. Historical air photo-
graphs indicate that these facilities were torn down between 1960 and .1974. The
demolition debris was placed in the landfill south of the mill.
History of State and Federal Investigations and Removals
In early 1983, the Washington State Department of-Ecology (Ecology) conducted a
compliance inspection of the ACC facility. The inspection determined the facility
was not in compliance with state waste handling requirements. Ecology required
ACC to eliminate discharges of wastewater to the environment, to prepare a
wastewater treatment and disposal plan and to redirect all boiler blowdown to the
sanitary sewer collection system. In late 1983, ACC stopped the wood milling and
treatment operations.
In 1985, soil con~rn1nated with PCP was removed from the facility and used as
fill in residential yards located east of the facility. Ecology ordered ACC to remove
the .contaminated soil and clean up the affected areas to a level of 100 ug/Kg PCP.
The company complied with the order and removed the cont~rninated soil to the
levels specified.' .
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American Crossarm & Conduit Record of Decision
Several floods occurred in the next few years which released contamination to the
surrounding area. In 1986, the Chehalis river flooded ACC spreading appr,>xi- .
mately 10,000 gallons of PCP-diesel solution to the Chehalis Avenue Area (see
Figure 2-10 for observed limits of flood born limits of this release) and potentially
to the wetlands and Dillenbaugh creek. An emergency action was taken to clean
up contamination from this flood. Contaminated soil, debris, furniture, and other
material generated from the cleanup which constituted the principle threat to .
human health and the environment were placed on the facility. In 1987,
contaminated sludge and sediment were removed from the surface impoundment.
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In 1988 an incinerator was brought on the facility to incinerate the principle
threat (e.g. contaminated soil and debris generated from the cleanup efforts).
Incineration generated approximately 207 tons of ash which is presently stored on
the facility.
The American Crossarm & Conduit company, which owned and operated this
facility, is no longer solvent. There are no other viable potentially responsible
parties (PRPs). In 1989, the U.S. EPA initiated an RI/FS. The remedial
investigation was performed in 1990 and 1991. The feasibility study was
completed in September 1992. The RI and FS reports have been placed in the
Anministrative Record.
In 1991 and 1992, the EPA undertook an action to further reduce the potential for
spread of cont;:tminants. In 1991, gravel was spread over the treatment area to
keep fugitive dust cont9ining wood treating chemicals from becoming airborne.
Above ground tanks and piping in the treatment works were decont.aIninated and
the steel taken to a recycler in 1992. Laboratory chemicals and PCB containing
electrical equipment were collected from various buildings and secured by placing
~hem in an overpack. Asbestos was removed from exposed pipe and placed in
sealed drums.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Proposed Plan for the ACC site was published on 28 September 1992, and
was. subject to public comment from 30 September through 30 October 1992. To
notify the community of the opportunity for public comment, the Proposed Plan
was mailed to individuals on EPA's mailing list for the ACC site and a newspaper
notice was published on 30 September 1992 in the Centralia Dailv Chronicle.
During the public comment period EP A held a public meeting to provide
additional information about the Proposed Plan and. to take public comments. The
public meeting was held on 21 October 1992 at the Lewis County PUD auditorium
in Chehalis. The comments and questions raised at the meeting we~ documented
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American Crossarm & Conduit Record of Decision
in a transcript and have been responded to in the Responsiveness Summary,
which is an attachment to this ROD.
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In September of 1989, EPA initiated a community involvement effort to keep the
public informed and address community concerns regarding the Remedial
Investigation at ACC. EP A developed a revised Community Relations Plan for the
site based on interviews with citizens and community leaders. The revised
Community Relations Plan built on activities begun during EPA's emergency
response efforts at the site (1986-1989). EPA published fact sheets during the
investigation to apprise the community of developments.
The following is a summary of activities conducted by EP A to support community
involvement for remedial activities at the ACC Superfund site:
. November 1989-EPA conducted community interviews, which included
meetings with local citizens and business owners, County Commissioners
and the County Assessor's Office, the Lewis County Health District, City. of
Chehalis officials, and the Lewis County Economic Development Council
and Chamber of Commerce. In addition, EP A held an open house for other
interested members of the community. The purpose of the interviews was
for EPA to learn about community concerns related to the ACC site.
. March 1990-EP A published a fact sheet describing site investigation plans.
. April 1990-EP A revised its Community Relations Plan to reflect new
community concerns and to identify public involvement activities and future
site investigation and cleanup activities.
. April 1990-EP A meet with the Lewis County Health Department to
discuss residential yard sampling.
. September 1990-EPA met with Ecology, County Health, and City.of
Chehalis officials from the department of public works, city manager's office
and fire department to update them on site investigation developments and
plans.
. September 1990-EP A published fact sheet on the preliminary Phase 1
sampling activities.
. February 1991-EPA published a fact sheet snmmarizing sample results to
date and announcing the second phase of sampling.
. October 1991-EPA presented an update on site activities to the Twin
Cities Chamber of Commerce.
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American Crossarm & Conduit Record of Decision
. April 1992-EP A published a fact sheet updating activities and describing
some interim cleanup actions.
. September 1992-EPA published the Remedial Investigation and Feasibility
Study (RIfFS) report and Proposed Plan for cleanup for public comment.
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October 19~2-EP A held a 30-day public comment period from October 1st
through 31st. During the comment period EPA held a public meeting on
October 21, 1992.
SCOPE AND ROLE OF RESPONSE ACTION WITHIN THE STRATEGY
The selected remedy is the third and final response action to be conducted at ACC.
EP A performed an emergency response action beginning in late 1986 when the
principle threat (10,000 gallons of PCP-diesel solution) spread from the facility to
the Chehalis Avenue Area during a flood. EP A determined that this response
action was necessary to eliminate the potential risks from human contact with
contslminated soil and debris. Soil, debris, furniture and other material was.
excavated or removed from the AOC and was consolidated on the ACC facility. In
1988 an incinerator was set up on the facility to incinerate the cbnt.::lminated soil
and debris and cont.::lminated sludge which were removed from the surface impound-.
ment in 1987.
In 1992, remSlining potential sources of contamination were secured by removing
liquid wood treating wastes from tanks and piping and confining the materials
along with laboratory chemicals in sealed drums. Above ground tanks and piping
in the treatment works were removed. The drums of hazardous materials are
presently located on the facility.
While the emergency removals eliminated the most immediate health risks, low-
level conts:iminSltion still exists. The cont.s:tminSlnts of concern are carcinogenic
polyaromatic hydrocarbons (CPAHs), pentachlorophenol (PCP), and dioxinlfurans.
The bulk of the low-level contSlmination is on the ACC facility itself. Surface soil
in the Chehalis Avenue Area shows cont~minSltion to a much lesser degree.
Groundwater beneath the facility is. contSlminated with PCPs andCP AHs. A layer
of oil floating on the groundwater (floating product) is present beneath the treat-
ment works in one well. No plume has been identified. Low permeability soil has
this product isolated to a small area beneath the former tanks. Surface water in
Dillenbaugh Creek and the stormwater discharge lagoon are cont.::lminated by
surface runoff from the facility. .
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American Crossarm & Conduit Record of Decision
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Potential risks exist from contact with contaminated soil, future worker exposure
at the facility itself, and potential ecological impacts from contamination in the
AGC (Dillenbaugh Creek and the stormwater discharge lagoon). Although
groundwater beneath the facility is currently not used for drinking purposes, the
cont-
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American Crossarm & Conduit Record of Decision
drinking water supply is drawn from the Chehalis River upstream from its
confluence with Dillenbaugh Creek. The secondary water supply line passes
beneath the southern portion of the facility. Three private irrigation (only) water
supply wells are present up gradient from the facility.
Surface Water and Groundwater Resources
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Surface Water
Dillenbaugh Creek provides local drainage from areas to the east and southeast of
the facility. The creek joins the lowland 2.5 miles southeast of Chehalis and flows
north-northwest parallel to the Newaukum River south of the facility as shown in
Figure 2-1.
The creek flows northwest of the facility and under Interstate 5 where it joins the
Chehalis River. The creek was rechanneled over its lowland reach during construc-
tion of Interstate 5. Dillenbaugh Creek has a low gradient, silty and weedy
bottom, moderate to low velocity, and is prone to flooding during winter months
due to culvert restrictions and backwater from the Chehalis River.
Other major surface water features include wetlands that border the ACC facility
to the south as shown in Figure 2-2. The wetlands drain into Dillenbaugh Creek.
Groundwater
Thirty-three domestic, irrigation, and municipal wells are located within a two
miles radius from the facility. The majority of these wells are located in the
outlying areas of the city to the south and southwest, and are geographically
separated from the facility by the Chehalis and Newaukum rivers and Dillen-
baugh Creek. According to well logs provided by Ecology, well water levels range
from 30 to 110 feet below ground surface, with approximately 75% of the wells
used for domestic purposes. The wells closest to the facility (within a 1/4-mile
radius) are used for irrigation only.
The AOC consists of the Chehalis Avenue Area (a residential/commercial section of
the city of Chehalis, including a play field), wetland south of the facility, a reach of
Dillenbaugh Creek and a storm water discharge lagoon and attendant storm
drain~ The Cheha1is Avenue Area consists of several city blocks of which about
20% is commercial, and over one-half of the balance is open space. The wetland
south of the facility functions poorly as a habitat due to man-made constriction to
flow, and it receives run-of from city streets. The storm water discharge lagoon is
not engineered and is basically a steep-sided settling pond adjacent, to the creek
that was constrUcted by excavation into native soil and fill. The storm drain
exhibits infiltration at joints.
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American Crossarm & Conduit Record of Decision
Facility features (see Figure 2-11) include:
.;
. 8 kilns (14 feet x 15 feet x 140 feet each)
. mill (250 feet x 260 feet x 36 feet high)
. landfill (250 feet x 600 feet x 10 to 14 feet high)
. 4 underground tanks/piping
. spur rail lines
. treatment works sumps
. former surface impoundment
. treatment works control room
. boiler control room
. elevated craneway
. stormdrain
. chemical laboratory building
. kiln shop
. fuel shed
. production well
. ash from the incineration of emergency removal debris and soil
. drummed investigation derived waste (soil), overpacked facility chemicals
and miscellaneous hazardous substances
Known or Suspected Sources of Contslmination
Current sources of conUimination were identified in the RIfFS and include:
. Discharges of waste streams, noncontact cooling water, and boiler blowdown
from milling operations to the wetlands or storm runoff area which drained
to the wetlands.
. Releases of other mill operation waste streams such as lubricating oils,
diesel, and gasoline.
. Disposal of waste streams from the hot dip tank wood treatment operations.
These include tank sludge and solvents, paints, paint thinners, lubricating
oils, petroleum products and other miscellaneous waste which were deposit-
ed in the landfill.
. Discharges and disposal of waste streams from the wood pressure treatment
process. These include:
discharge of vapor recovery system liquids to the city stormsewer
discharges of wastewater from the building sumps to the surface impoundment
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American Crossarm & C(lnduit Record of Decision
disposal of sludge from the bottom of the surface impoundment to the
landfill .
dispersion of contaminants in the treatment works tanks, pipes, and
sumps' around the facility due to flooding.
,-
\J
. Discharges from kiln operations.
. Miscellaneous leaks and spills around the facility.
. Suspected discharges from abandoned and demolished mill and kiln opera-
tion east of the facility. Demolition debris was placed in the landfill.
. Flooding which released contamination from the facility to the surrounding
AOC.
Types of ConvuninSltion and Affected Media
The ACC RI involved the collection of 257 biased and systematic, discrete and
composite surface and subsurface soil samples, 18 discrete surface water samples,
and 50 groundwater samples at the facility and in the AOC. The intent of the
sampling was to characterize the extent of cont.slmination. The -results of the
sampling efforts for each medium are presented in the RI report and are
summarized below. All references to dioxin concentrations are in terms of 2, 3, 7,
8- TCDD and were converted using Toxic Equivalency Factors (TEF).
Surface Soil (0-6 inches)
The remedial investigation found pentachlorophenol (PCP), carcinogenic polycyclic
aromatic hydrocarbons (CPAH), and dioxinlfurans (dioxins) in the majority of
areas sampled (Table 2-1). Figures 2-3 through 2-8 illustrate the spatial distribu-
tion and concentration of the cont.slminants of concern.
Subsurface Soil
The remedial investigation found PCP and CP AH in subsurface soil in the
Treatment Area, Mill Area, Landfill Area, and Lagoon. Subsurface soil in the
Chehalis Avenue area was not conwminated by the surficial application of flooding
and is not of concern. Subsurface soil ~nt~min3tion ranges are snmmarized in
Table 2-2.
-'
-------
LJ u~ U II ..,. -
., -=
o c:J NA
ftj
. G
.
0 go~
00
1)
0:;:/
Explanation
NA Not Analyzed
N D Not Detected
R Data Reiected
2920 Conc:entnltion (ng 'kg)
-1
\ ~J
\
\
\
o
\? 1360
i.
346
d
o
~
DioxinslFurans Concentrations in Surface Soil for
the, Chehalis Avenue Area
Scale in Feet
-
I
o
I
- ~ .
If
'CD
-'
RGURE
-------
:J
'--
c::
~
go r5& ..
Ii
o I
0° NA
.
D
-::J
Explanation
NA Not Analyzed
N D Not Detected
R Dm Rejected
2920 cOncentration (ug I leg)
Scale in Feet
2CII
,
o
,
2CII~
If
'00
\\
-1
. ~J
300
d-
O
~
. Pentachlorophenol Concentrations
in Surface Soil for Chehalis Avenue Area
FIGURE
-------
D ftj
G
a :;O~
~ 0°
.
fJ
~
Explanation
NA Not Analyzed
N D Not Detected
R Data Rejected
2920 Concentration (ug / kg)
\~
~..
\
\
\ 1656
642
Total Carcinogenic PAH Concentrations in
Surface Soil for the Chehalis Avenue Area
Scale In Feet
200
. I
o
I
200 l
Ir
'lID
FIGURE
-------
D
\ ,
tI
~
56000
790
730 ,
NO \ NA
\
18000
50500 I
900
NO
330
NO
Explanation
NO
75
NA Not Analyzed
N D Not Detected
R Data Rejected
2920 Concentnltion (ug I kg)
540
2GII
1
Scale in Feet.
. 0
, .
. Pentachlorophenol Concentrations
in Surface Soil for Treatment, Mill, Landfill,
. and Stormwater Discharge Lagoon Areas
. R~
1111
2GII l
'f
2-6
~
-------
Total Carcinogenic PAH Concentrations in Surface
Soil for Treatment, Mill, Landfill, and
Stormwater Discharge Lagoon Areas
. FIGURE
u
i
821
1110 \
8\8~
~'7r:. 1040
~ 4'63 875
Explanation
NA Not Analyzed
N D Not Detected
R Data Rejected
2920 Conc:entnltion (ug I kg)
Scale In Feet
100
I
o
I
100 ~
If
100
:1
n
11
, I
\
I
1700
NO
NO
130
-------
u
~N NA NA
NA .
NA
to
Explanation
NA Not Analyzed
N D Not Detected
R Data Rejected
2920 Concentnltlon (ng I kg)
96~ \
\
NA
,
1510
NA
NA
NA
NA
NA
NA
Dioxins I Furans Concentrations in Surface Soil
for Treatment, Mill, Landfill, and
Stormwater Discharge Lagoon Areas
. F~~
Scale In Feet
2GO
I
o.
I
2GO ~
Ir
,ell
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American Crossarm & Conduit Record of Decision
Table 2-1-Summary 01 Surface Soli Results
.
Carcinogenic
POlyaromatic
Pentachlorophenol (uglkg) Hydrocarbons (uglkg) Dioxin (ng/kg)
Area Range Average Range Average Range Average
Chehalis ND-13,OOO 689 ND-32,900 2,190 ND-1,360 184
Avenue
Treatment 130-130,000 36,200 1,700- 30,400 3,000-143,000 26,900
Area 258,000
Mill Area ND-1,600 689 ND-33,000 9,260 '1,510 1,510
Landfill ND-1,OOO 147 ND-1,940 406 179 179
Lagoon ND-790 507 88-1,100 733 NA NA
ND = Non detect
NA = Not analyzed.
Table 2-2-Summary 01 Subsurface Soli Results
C~rcinogenic Polyaromatic
Pentachlorophenol (uglkg) Hydrocarbons (uglkg)
Area Range Range
Treatment Area ND-250,OOO ND-54,590
Mill Area 18-1,124 ND
Landfill ND-74,OOO ND-7,OOO
Lagoon ND-1,800 ND-8,450
ND = Non detect.
Surface Water
Water samples were collected from the Chehalis River, Dillenbaugh Creek, and
the stormwater discharge lagoon to assess surface water contamination. P AHs,
PCP, and dioxin were detected in the Dillenbaugh Creek surface water samples.
PAH concentrations ranged from nondetectable to 0.8 ugIL. PCP concentrations
ranged from nondetectable to 19.0 ugIL. Dioxin had a maximum concentration of
0.8 ngIL.
Surface water samples were collected from the Chehalis River downstream of its
confluence with the Newaukum:,River. PAHs and PCP were not detected in the
samples. Dioxin was found in the surface water at concentrations ranging from
0.008 to 0.023 ngIL. "
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American Crossarm & Conduit Record of Decision
Dioxin was found in the majority of samples taken from the storm water discharge
lagoon and ranged from nondetectable to 0.61 ng/L. PAHs were found in one of
two surface water sample locations with a concentration of 3.6 ug/L. PCP was
detected in all surface water samples and ranged from 0.14 ug/L to 68.0 ug/L.
"
Groundwater
P AHs, PCP, and BTEX are groundwater contaminants attributed to operations at
the ACe facility. Groundwater contamination is present at three discrete localized
areas located beneath the treatment area within the facility boundary. These
locations are under the treatment works, near the surface impoundment and south-
west of the kilns.
PCP is present near the treatment works in a dissolved phase and as a floating
phase mixed with diesel. The floating phase has PCP concentrations as high as
12,000 mg/L. A dissolved PCP concentration of 91 mg/L was detected in
groundwater below the floating product.
Samples from monitoring wells west of the kilns were found to be contaminated
with P AHs and BTEX. Samples from one well were found to contain naphthalene
(19 mg/L), phenanthrene (12 mg/L), acenaphthene (7.8 mg/L), fluorene (6.3' mg/L),
as well as fluoranthene, pyrene and anthracene in concentrations ranging from 1
to 5 mg/L. The same well had the highest concentrations of individual BTEX
compounds in the range of 0.2 to 4.4 mg/L.
Wells west of the surface impoundment found groundwater to be contaminated
with PCP. Samples from these wells had concentrations ranging from 0.03 to
2.9 mglL PCP.
Sediment
Sediment from Dillenbaugh Creek, stormwater discharge lagoon, wetlands' and the
Chehalis River were collected and analyzed for organic and inorganic con-
~mlnants.
The.major con~rn;nants in Dillenbaugh Creek sediment were dioxin, PAHs, and
PCP. Dioxin and PAHs were found in the majority of samples with maximum
concentrations of 593 ng/kg, and 36,650 ug/kg, respectively. PCP was detected in
less than half the sediment samples and had a maYirnum concentration of
190 ug/kg. Dioxin, P AH, and PCP concentrations in the creek were highest immedi-
ately downstream of the stormwater discharge lagoon and under the Burlington
Northern railroad bridge. .'
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American Crossarm & Conduit Record of Decision
..
Sediment from the wetlands were found to be contaminated primarily with P AHs,
dioxin, and PCP. P AHs and dioxin were dptected in nearly all samples and had
maximum concentrations of 11,700 ug/kg and 155 ng/kg, respectively. The maxi-
mum concentration of PCP detected was 280 ug/kg. Inorganic contaminants
consisted of beryllium, cadmium, and mercury at maximum concentrations of
1.8 mglkg, 1.9 mg/kg, and 1.1 mg/kg, respectively. Contaminants in the Chehalis
River sediment consisted mainly ofPAHs and PCP with maximum concentrations
of 100 ug/kg and 400 ug/kg, respectively.
Route of Migration
The fate of contaminants originating from ACC depends on site-specific migration
pathways and on the chemical and physical properties of each contaminant. This
section focuses on the contamimmts of concern [dioxinslfurans (dioxin), pentachloro-
phenol (PCP), and polycyclic aromatic hydrocarbons (PAHs)], and identifies their
probable routes of migration in soil, surface water, sediment, and groundwater.
Surface Soil
The principal transport mechanisms of the contJlminants are as suspended soil in
surface and flood water runoff. ContJlminated soil in suspended surface water
runoff is expected to travel downhill from the Chehalis Avenue area and the
facility to the wetland or stormwater discharge lagoon and eventually to Dillen-
baugh Creek and the Chehalis River. Contaminated soil suspended in flood water
may be carried to the north and east into the Chehalis Avenue area before
receding into the wetland to the south. Windblown fugitive dust and plant uptake
are not considered principal mechanisms of transport. Bound to surface soil, the
primary cont.aminants have half-lives of a few days to years, depending on
available degradation processes.
Subsurface Soil
The probable transport mechanisms of the primary contaminants in subsurface
soil are vertical transport of free liquid by gravity and vertical transport of
contaminants by percolation of rainfall. The contaminants, which would be
strongly sorbed in the interstices of soil grains, are unlikely to be readily mobil-
ized by gravity, rainfall, or groundwater without undergoing significant
degradation, although small amounts would continuously leach. In addition, the
low permeability of the fill greatly retards transport. Therefore, in situ
degradation is the likely ultimate fate of the majority of the subsurface
contaminants. As mentioned above for surface soil, the. time reqUired for
degradation depends on the available degradation processes. Because photolysis,
a relatively short-term degradative process; is not available for contaminants in
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American Crossarm & Conduit Record of Decision
subsurface soil, the half-life of the primary cont.=:lminants in subsurface soil is
expected to be longer than for surface soil.
Surface Water
.,
Transport of contaminants via surface water occurs through flooding, surface
runoff, and water flow to Dillenbaugh Creek and between Dillenbaugh Creek 'and
the Chehalis River. Surface water may spread contaminants in liquid phase when
contaminants dissolve, through transport of bulk liquid contaminants, or as
suspended particles when contaminants adhere to soil
Sediment
Sediment con~minated with the primary contaminants was found in the Chehalis
River, Dillenbaugh Creek, in adjacent wetlands, and in the stormwater discharge
lagoon. Mass movement is the mode of transport of contaminated sediment.
Chehalis River-The primary cont.=:lminants in Chehalis River sediment are PCP
and PARs. Mass movement of sediment along the river bed is active because of
the frequent high flows. The half-life of PCP and PARs in sediment is expected to
be short, and redistribution through mass movement will dilute cont.=:lminants.
Therefore, sediment-bound PCP and P AHs in the Chehalis River are not expected
to be very persistent. Mobilized sediment will eventually enter Grays Harbor.
Dillenbaugh Creek-All of the primary cont.=:lrninants were widespread in surface
sediment and sediment at depths of 5 and 10 inches in Dillenbaugh Creek. The
sediment dynamics of Dillenbaugh Creek are unknown, but flooding and high flow
are periodic events that could potentially erode cont.=:lrninated sediment from the
creek bed. Dioxin could persist in sediment for many years. Lighter molecular
weight P AHs and PCP are expected to be less persistent. Mobilized. sediment will
move downstream into the Chehalis River. '. .. . .
Wetlands-The primary contaminants found in wetland sediment are PCP and
P AHs. Mass movement of wetland soil is limited due to the dense vegetative
cover and relatively low water flow rate. PCP and lighter molecular weight P AHs .
are expected to degrade relatively rapidly. Eroded sediment will migrate into
Dillenbaugh Creek. .
Stormwater Discharge Lagoon-The primary con~rninants found in the storm-
water discharge lagoon sediment are dioxin and PARs. Because of the intermit-
tent nature of flow from the stormsewer outfall and the function of the .lagoon as a
settling basin, mass movement of cont.arninated sediment from the lagoon will be
less than that from Dillenbaugh Creek. Dioxin is expected to"persist for many
years in the sediment, while light molecular. weight PAHs will be le&~ persi~tent.
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American Crossarm &-Conduit Record of Decision
Mobilized sediment will move into the lower reaches of Dillenbaugh Creek and
eventually into the Chehalis River.
Groundwater
..
PCP and P AHs are the primary contaminants identified in groundwater. In.
groundwater, these contaminants are typically transported as either dissolved
constituents, as light nonaqueous phase liquids (LNAPL), or as dense nonaqueous
phase liquids (DNAPL). PCP was tentatively identified in three possible forms:
as a dissolved constituent, combined in a diesel-based carrier as a LNAPL; and
possibly as a DNAPL.
Dissolved PCP will be preferentially adsorbed to organic materials in the subsur-
face. Solubilization of PCP from the adsorbed phase and from LNAPL and
DNAPL may provide a continuing source of dissolved PCP for many years. The
dissolved phase may eventually be transported to the river; however, the rate of
mass loading to the river will be slow because of the extremely slow rate of
groundwater movement (3 to 30 meters per year).
The layer of LNAPL PCP and PAHs in the treatment area floats within a hydrauli-
cally unconfined portion of the groundwater system. Any net migration of the
center of mass of the LNAPL pool would be laterally, becoming thinner in the
process. Some cont.slminants will be resolubalized into the water column, and
some will be degraded by biotic and abiotic mechanisms. These degradation
mechanisms will become more efficient as the layer becomes thinner. Long-
distance transport to Chehalis River is very wilikely.
P AHs can be expected to undergo a fate similar to PCP. Many of the P AHs are
even more strongly absorbed than is PCP, so long-distance transport in ground-
water is unlikely.
DNAPL PCP will probably collect within topographic lows in the bedrock surface
where it will be slowly degraded by biotic and abiotic mechanisms and resolubal-
ized into the surrounding groundwater. Long-distance transport of DNAPL PCP
can occur only under a restrictive set of geologic conditions and probably can be
disregarded at ACC.
Potentially Exposed Populations
Current human populations potentially exposed to contamination include children.
and adults in the Chehalis Avenue area who might be exposed to. cont.slmination in
surface soil through dermal exposure (skin contact) .or incidental ingestion during
recreational activities on Dillenbaugh Creek. Trespassers on the facility would
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American Crossarm & Conduit Record of Decision
also be exposed through the same pathways. Future workers on the facility or
future development would be exposed. through the same pathways.
SUMMARY OF RISKS
..
An assessment of the risks to public health and the environment under existing
conditions at the facility and in the AOe involved a 4-step process including the
identification of contaminants of concern, an assessment' of contaminant toxicity,
an exposure assessment of the population at-risk, and a characterization of the
magnitude of risk. The results of this assessment are described below.
Human Health Risks
Persons who may incidentally ingest soil through hand-to-mouth contact were
identified as the population most at risk of adverse health effects. Inhalation is
not a significant pathway from the facility. Dioxin and carcinogenic PAHs were
recognized as the cont~m;nants of concern. The excess lifetime cancer risk from
the reasonable maximum exposure to dioxin and carcinogenic P AHs is two in ten
thousand for persons living in the Chehalis Avenue area and ranges from two in
one hundred thousand to two in one thousand for persons who might work on the
facility under current conditions. Non-carcinogenic adverse health effects are not
expected.
Contamina~ts of Concern
The Remedial Investigation identified soil as the exposure media of greatest
concern. Human exposure via other media such as air, sediment, and surface
water are considered less significant by comparison.
A total of 18 contaminants were identified for evaluation in the Chehalis Avenue
area. These included bis(2-ethylhexyl)phthalate, carbazole, pentachlorophenol,
seven polynuclear aromatic hydrocarbons (benzo(a)anthracene, chrysene,
benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, dibenzo(a,h)anthra-
cene, and indeno(1,2,3-cd)pyrene), PCBs, alpha-chlordane, pmma-chlordane,
dieldrin, dioxin (including all detected dioxin/furan cogeners), and three metals
(beryllium, cadmium, and manganese). Of these, dioxin and P AHs are considered
the contaminants of concern because of their respective contribution to the risk.
Soil concentrations used for the risk assessment in the Chehalis Avenue area were
0.4 ug/Kg for dioxin (including all dioxinlfur31l'cogeners) and 4 ug/kg for PAHs
(total of all PAHs). These concentrations represent the upper 95% confidence limit
of the mean concentration. .
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American Crossarm & Conduit Record of Decision
..
A total of 17 contaminants were identified for evaluation (including the landfill,
mill, and treatment are~). These included carbazole, pentat.:hlorophenol, seven
polynuclear aromatic hydrocarbons (benzo(a)anthracene, chrysene,
benzo(b)flouranthene, benzo(k)fluoranthene, benzo(a)pyrene, dibenzo(a,h)anthra-
cene, and indeno(1,2,3-cd)pyrene), alpha-chlordane, gamma-chlordane, dieldrin,
dioxin (including all detected dioxin/furan cogeners), DDT, heptachlor epoxide, and
two metals (arsenic and beryllium). Of these, dioxin and PAHs are considered the
contaminants of concern because of there relative contribution to the risk. Soil
concentrations used in the risk assessment ranged from 0.2 ug/kg to 50 ug/kg for
dioxin (including all dioxin/furan cogeners) and 7 ug/kg to 60 ug/kg for PAHs (total
of all PAHs). These concentrations represent the upper 95% confidence limit of
the mean concentration. The highest concentration of chemicals of concern were
found in the treatment area.
Dioxin and PAHs account for the overwhelming majority of carcinogenic risk.
Although lead was found in localized areas on the facility, it is not a facility
cont-9minant and was not evaluated because the toxicological criteria for lead are
being revised and no reference doses or cancer potency factors are available for
risk assessment purposes. Target remediation levels for lead in soil are evaluated
using data from the Agency for Toxic Substances and Disease Registry (ATSDR).
.Lead levels in soil ranging from 500 ug/kg to 1000 ug/kg are being suggested as
the point of departure for establishing cleanup levels. Remediation of dioxin and
P AH contRminated soil is expected to effectively address the areas of lead
contamination. Consequently, this discussion focuses on carcinogenic risk from
dioxin and PAH exposures only.
Exposure Assessment
The population currently at greatest risk of adverse health effects from exposure
to site-related contaminants are those persons living in the vicinity of the facility
(i.e., the Chehalis Avenue area), who may incidentally ingest dioxin and PAHs in
soil due to. hand-to-mouth contact. Other populations who could potentially be at
risk would include on-site workers in the future industrial scenario and persons
living on-site under a future residential scenario. The primary route of exposure
for workers and residents was incidental soil ingestion.
Other exposure pathways evaluated include inhalation of particulate matter
(evaluated under both the residential and future industrial scenarios) and inges-
tion of water and sediment while swimming in Dillenbaugh creek (evaluated.
under the residential scenario). The risks due to these pathways were less than 1.
chance in 1,000,000.
In the uncertainty anaJ.ysis, the pathways of dermal absorption of contaminants
bound to particulate (residential and future industrial s~~arios) and ingestion of
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American Crossarm & Conduit Record of Decision
fruits and vegetables grown in the area (residential scenario) were evaluated. The
risks d11e to these pathways were only considered in the uncertainty analysis
section of the risk assessment due to the large degree of uncertainty involved with
estimating exposure. These pathways are not further discussed.
.,
Exposure to cont~rn1nants in groundwater was not evaluated for several reasons.
The source of drinking water for Chehalis is located 17 miles upstream on the
Newaukum River and there are no groundwater wells used for drinking water or
other household purposes within the vicinity of the facility. Contaminated
groundwater is limited to three smallloca1ized areas beneath the treatment area
within the facility boundary. The soil is a tight silt and migration is not expected.
Lastly, deed restrictions are anticipated to prevent future well installation.
Consumption of fish or invertebrates caught in the vicinity of the site (Dillenbaugh
creek) was not evaluated since it is not fished by the local community, because it
is not a viable fishery. It is more likely that a person fishing would be attracted
to the nearby Chehalis and Newaukum Rivers.
Consumption of waterfowl that feed in the area was also not evaluated since
waterfowl are only expected to be present in the area on a seasonal basis. As
such, the duration of their exposure to contaminated media would be minimal.
Exposure point concentrations were determined using both monitoring and
modeling data. For incidental soil ingestion, sediment ingestion, and surface
water ingestion exposures, measured soil, sediment, and. surface water concentra-
tions were used for dose calculations, respectively. Doses from inhalation expo-
sures were estimated using modeled exposure-point concentrations.
Two exposure scenarios were examined to estimate hypothetical risks associated
with potential future site use and current use of the area in the vicinity of the
site. These exposure scenarios cover residential and industrial use conditions.
The assumptions used to calculate doses under each scenario are presented as
follows.
Industrial Exposures
Reasonable rn::tYirnum exposures were determined for the landfill, mill, and
. treatment areas on-site using upper-bound (95th per~ntile) soil concentrations of
7 mg/kg, 32 mg/kg, and 60 mg/kg, respectively for P AHs, and concentrations of
0.2 ug/kg, 2 ug/kg, and 50 ug/kg, respectively for dioxin. In calculating risk from
hypothetical industrial exposures it was assumed that risks from incidental soil
ingestion and inhalation were additive and contributed to the total body burden.
Other key assumptions used were standard Region X assumptions.
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.;.
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American Crossarm & Conduit Record of Deciswn
Residential Exposures
.
In the residential scenario it was assumed that individuals would be exposed to
contaminants in soil over a lifetime (75 years), and to contaminants in sediment
and surface water for 6 years of their lifetime. The reasonable maximum exposure
(RME) in the Chehalis Avenue area was determined using an upper-bound (95th
percentile) value ofOA uglkg for dioxin and 4 mglkg for PAHs in surface soil.
Risks from incidental soil ingestion, inhalation, and ingestion of surface water and
sediment (evaluated for children age 6 to 18 only) were assumed to be additive
and contributed to the total body burden.
Toxicity Assessment
The EP A uses a weight-of-evidence system to convey how likely a chemical is to be
a hnrn:m carcinogen, based on epidemiological studies, animal studies, and other
supportive data. The classification scheme for characterization of weight-of-
evidence for carcinogenicity includes: Group A-known human carcinogen,
Group B-probable human carcinogen, Group C-possible human carcinogen,
Group D-not classifiable as to hnrn~n carcinogenicity, and Group E-evidence of
. non-carcinogenicity in humans.
Dioxin is classified by EP A as a probable human carcinogen based on evidence
from laboratory an1rn~ 1 studies. The potency factors used were obtained from
EPA's Health Effects Assessment Summary Tables (HEAST).
Some PARs (benzo(a)pyrene, benzo(a)anthracene, chrysene, benzo(b )tluoranthene,
indeno(1,2,3-cd)pyrene, dibenzo(a,h)anthracene, and benzo(k)tluoranthene) are
classified as probable human carcinogens based on evidence from laboratory
animal studies. The cancer potency factor to evaluate carcinogenic risk from oral
exposures is 12 (mglkg day )-1, and the potency factor for inhalation exposures is
6 (mg/kg day)"l. These potency factors were obtained..from EPA's on-line computer
database (ffiIS). Toxicity information is currently not available to evaluate the
noncancer health effects of the P AHs included in this risk assessment.
Cancer Potency Factors (CPFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg day)"l, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that. intake level. The term
"upper-bound" reflects the conservative estimate of the risks calculated from the
CPF . Use of this approach makes underestimation of theactUaI cancer risk highly
unlikely. Toxicity information is currently not available to evaluate noncancer
health effects of dioxin. .
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American Crossarm & Conduit Record of Decision
Risk Characterization
Excess lifetime cancer risks are determined by multiplying the estimated intake
level with the cancer potency factor. These risks are probabilities that are
generally expressed in scientific notation (e.g., 1 x 10-6). An excess lifetime cancer
risk of 1 x 10.6 indicates that, as a plausible upper bound, an individual has a one
in one million chance of developing cancer as a result of exposure to site-related
contaminants. Results of the carcinogenic risk calculations are contained in
Table 2-3.
.
For both the industrial and residential scenarios, incidental ingestion of soil
contributed the majority of the risk. For all exposure pathways, the majority of
the carcinogenic risk was contributed by dioxin and carcinogenic P AHs. Total
additional lifetime carcinogenic risk for the industrial scenario was determined to
be 2 in 100,000 for the landfill, 1 in 10,000 for the mill, and 2 in 1,000 for the
treatment area. Total additional carcinogenic risks for lifetime residential
exposures from the highest sample in the Chehalis Avenue area are estimated at 2
chances in 10,000.
The estimate of potential noncancer health effects was below one for all exposure
pathways and all scenarios.
Table 2-3-Results 01 Carcinogenic Risk Calculations
Residential (Present) Industrial (Future)
Age Groups
Exposure Pathway 0 to 6 6 to 18 18 to 75 Landfill Mill Treatment
Incidental ingestion 01 soil 1 E-02 3 E-03 4 E-03 . .... 2 E-05 1 E-04 2 E-03
Inhalation of particulate 1 E-07 7 E-08 8 E-08 5 E-08 6 E-09 . 6 E-08
Incidental ingestion 01 surface - 7 E-07 - - - -
water while swimming
I ncidental sediment ingestion - 2 E-05 - - - -
Total 1 E-02 3 E-03 4 E-03 2 E-05 1 E-04 2 E-03
Total lifetime (added across 2 E-02
age groups for residential
scenario)
- = Exposure pathway not evaluated.
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American Crossarm & Conduit Record of Decision
Uncertainty
The accuracy of the risk characterization depends in large part on the accuracy
and representativeness of the sampling, exposure, and toxicological data. Most.
assumptions are intentionally conservative so the risk assessment will be more
likely to overestimate risk than to underestimate it. .
One source of uncertainty is the analytical data. It should be recognized that all
analytical results have a variability associated with them. This variability or
uncertainty in the result is dependant on the sample matrix, analytical method,
and laboratory performing the analysis. .
Another source of uncertainty in the risk assessment is the assumptions used to
arrive at exposure doses. Although the exposure scenarios are based on a number
of standard assumptions, there are uncertainties inherent in them. In most cases,
these assumptions tend to overestimate risk.
A final source of uncertainty relates to the methodology by which the cancer
potency factors for dioxin and PARs were developed. For both of these chemicals,
the available data indicating their carcinogenic potency was derived from animal
studies. From this data, carcinogenic potency to humans was -estimated using
uncertainty factors which span at least two orders of magnitude.
Ecological Evaluation
Summary of Approach
In addition to the human health risks discussed above, potential ecological effects
were evaluated for the AOC. Soil, sediment, and water cont.aminant concentra-
tions and modeling algorithms were used to predict an exposure dose to the
ecological species of concern. Following exposure. predictions, a quotient method
was used to estimate potential impacts. In the quotient method, the estimated
exposure dose is divided by a toxicity value (i.e., a dose considered "safe" to the
ecological species of concern). A hazard quotient greater than 1 indicates a
potential risk.
Exposure Assessinent
To evaluate potential ecological impacts, the AGC adjacent to the facility was
divided into aquatic and terrestrial habitats (wetland, Dillenbaugh Creek,
Chehalis River, storm water discharge lagoon), and indicator species were
identified for each habitat. For the aquatic habitat, .a cutthroat trout and a fish-
eating bird (kingfisher) were chosen as the species of concern; for the terrestrial
habitat, a vole and a mallard .duck were chosen.
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American Crossarm & Conduit Record of Decision
Risk Characterization
In the aquatic habitat, hazard quotients greater than 1 were estimated for the
cutthroat trout and the kingfisher in the lagoon, upstream Dillenbaugh creek, and
Downstream Dillenbaugh Creek areas. By contrast, the downstream portion of
the Chehalis River and the areas chosen as reference for Dillenbaugh Creek and
the Chehalis River had hazard quotients less than 1 for these species. .
.
In the terrestrial habitat, hazard quotients greater than 1 were estimated for the
vole in the wetland. By contrast, the hazard quotients calculated for the mallard
duck were less than 1 in all areas of the wetland.
In this evaluation, a deliberately conservative approach was taken so that
potential impacts would not be underestimated. Results of this evaluation
indicate the potential for negative impacts to ecological receptors exists, but the
true magnitude or severity of these impacts is unknown due to the uncertainties
inherent in the approach.
REMEDIAL ACTION OBJECTIVES
Actual or threatened releases of hazardous substances from thls facility, if not
. addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare or the
environment.
The remedial action objectives (RAOs) for final action are designed to remove the
potential threats to public health and the environment by significantly reducing
the volume of contaminated soil (mass of cont~minant, see Table 2-4).
Table 2-4-5011 Volumes Exceeding Cleanup levels
I Location I Volume (cubic yards) I
Treatment Area 25,600(8)
Mill Area 1 ,800(8)
Landfill 55,500(8)
Chehalis Avenue Area 14,300Cb)
(8) Soil exc:eecing risk threshold of 104.
(b). Soil exceeding risk threshold of 10~.
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American Crossarm & Conduit Record of Decision
The RAGs include:
. Protect human health in the Chehalis Avenue area by excavation of
contaminated soil to meet MTCA Method B (residential) cleanup standards.
. Protect human health from physical and chemical hazards from the facility
by demolition and removal of facility structures.
. Protect human health and the environment by source control through
excavation of ACC facility soil from the most highly contaminated areas,
and meeting MTCA cleanup standards through containment and
institutional controls. RCRA subtitle C requirements are not applicable to
remedies on the facility or within the AGC because the contaminants were
not listed at the time of release and contamination of the environmental
media remaining after the action is low level. Subtitle C requirements and
the state of Washington minimum functional standards for landfills are also
not relevant or appropriate to remedies at the facility because the
requirements are not well suited to the site or site conditions. For example,
no leachate has been identified and the site is located in a flood plain which
is frequently inundated, depth to groundwater is less than 10 feet, etc.
. Protect the environment through removal of contaminated sediment in the
lagoon and stormwater sewer to meet ambient water quality criteria
(A WQC) and MTCA cleanup standards for surface water in Dillenbaugh
Creek.
. Protect hnmal1 health and the environment by removal of the floating
product underneath the treatment works to meet Safe Drinking Water Act
(SDWA) MCLs and MTCA clean up levels for groundwater at the facility
boundary.
. . Disposal of the most highly cont~minated excavated material at an ap-
proved oft-site hazardous waste landfill. A hazardous waste designation is
relevant and appropriate for off-site transportation and disposal of soil and
debris from the facility.
By cleaning up the facility and adjacent AGC soil the major source of
cont~mination and, therefore, the risk to the general community will be reduced
and eliminated, respectively. In addition, source control and reduction in volume
of contamination will be achieved and state and federal criteria for the protection
of hnman health and the environment will be met.
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American Crossarm & Conduit Record of Decision
DESCRIPTION OF ALTERNATIVES
Alternative 1: No ActionIMonitoring
Evaluation of a no action alternative is required in order to provide a basis for
comparison of existing conditions and risks of potential conditions resulting from
implementation of other remedial alternatives. .
Major Components of the Remedial Alternative
Under the no action alternative, no additional remedial action would be taken to
eliminate existing sources of conu-mination or to reduce the risks to humans or
the effects on the environment. Annual groundwater and surface water sampling
would be performed for thirty years to monitor the presence and migration of
cont-8mination in those media. A five-year review of this alternative would be
performed to assess the threat due to cont$lminated soil and groundwater present.
Treatment Component
There is no treatment component for this alternative. Reduction in toxicity or
volume would occur only through natural processes such as photodegradation or
biodegradation. Toxicity, mobility and volume of the contaminated materials
would remain at their present value for an indefinite period of time.
Containment Component
Containment is not a component of the no action alternative.
.)
General Component
The no action alternative would be implemented'simply by initiating and continu-
ing long-term groundwater and surface water monitoring. Administrativ~ly, a
contract for collection and analysis of the water sampl~s would be established on a
yearly basis or for periodic renewal.
Costs and Remediation Time Frame
The cost for this alternative includes groundwater monitoring, and is estimated at
$250,000. This represents the collection and analysis of ten groundwater samples
and four surface water samples per year ove1" a thirty-year period. There are no
capital costs for this alternativ~. It would take one-to-two months to implement.
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American Crossarm & Conduit Record of Decision
Physical Effects on Environment Caused by Implementation
The no action alternative would not remove contaminated soil or sediment from
the ACC facility or AOC. The risk from implementation of this alternative is
minimal.
Alternative 2: Limited ActioDlIndustrial Controls
Major Components of the Remedial Alternative
In this alternative the facility structures, treatment works, and above- and below-
ground tanks and pipes would be removed. Floating product would be extracted
from the groundwater. Soil from the Chehalis Avenue area would be excavated
and consolidated on the facility. Institutional controls would be imposed and
annual groundwater and surface water monitOring would be performed.
Treatment Component
This alternative does not have a treatment component.
Containment Component
This alternative does not have a cont.ainment component.
General Component
Structures and equipment in the treatment works area would be removed. Pipes,
tanks, and metal debris would be cleaned using high-pressure water, and recycled
or disposed of off-site. Carbon adsorption would treat the wastewater generated
by this activity. The treated water would be discharged into the stormdrain
system. Contaminated water found in tanks and. pipes would be treated with
carbon adsorption and discharged. Uncontaminated building debris would be
recycled or disposed in a municipal landfill as appropriate.
Drums on the ACC facility containing solids and liquids would be recycled or
disposed. Drums of soil.cuttings would have their contents consolidated on the
facility. Filter cake, from incineration of contaminated soil in 1988 and 1989,
would be taken to a. RCRA landfill for disposal. Ash from past on-site incineration
deemed non-hazardous by the state would be consolidated on the facility. Liquid.
in drums would be sampled, recycled if possible, or $ent to a treatment or disposal
facility. All emptied drums would be cleaned with high pressure water .and .
recycled. Non na7.ardous material would be disposed at the. mwlicipallandfill.
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American Crossarm & Conduit Record of Decision
The floating product below the treatment works would be extracted and recovered
by an oil-water separator. Approximately 10,000 gallons of oily water would be
pumped into a holding tank prior to oil-water separation. Treatment following oil-
water separation would be required to achieve the substantive requirements of
National Pollution Discharge Evaluation (NPDES) criteria before the water was
discharged into the storm drain system. Oil recovered from the separator would
be placed in drums and disposed at a hazardous waste treatment facility as per
the remedial design.
Contaminated soil in the Chehalis Avenue area would be excavated from around
homes, yards and the playfield. Approximately 14,300 cubic yards of soil would be
removed. The soil would be transported to the facility for consolidation on the
facility. Clean topsoil would be spread to the original grade in the Chehalis
Avenue area to replace the excavated material and the area would be revegetated.
The entire ACC facility would be covered with 18-24 inches of clean fill, graded
and contoured to a surface slope that promotes drainage. Hydroseed would be
applied to the cover for protection.
Institutional controls would be implemented. Access to the facility and the storm
water discharge lagoon would be restricted by erection of a chain link fence. The
fence would be pos~d with warning signs to keep out potentiaf intruders. Deed
restrictions would be imposed to limit future use of the property. .
Performance monitoring of groundwater and Dillenbaugh Creek water would be
performed as per the Performance Monitoring Plan prepared in remedial. design. '
Costs and Remediation Time Frame
The limited action/institutional controls alternative would take 6 to 7 months to
complete. The total estimated cost for'this alternative is $3.8 million. Capital
costs are $3.5 million, and would include excavation, demolition of the treatment
works, enhancement of facility drainage, wastewater treatment, and security mea-
sure. Long term monitoring would be the same as Alternative 1 and would
represent operation and maintenance costs of $250,000.
Physiccil Effects on Environment Caused by Implementation
The physical effects on the environment are minimal. Runoff of contaminated
rainwater into the wetland could occur during soil consolidation on the facility and
during facility demolition. Dikes, berms and oil absorbing booms would be used to
control runoff. Work would be scheduled during dry. summer months to minimize
runoff. ' .'...
..:
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American Crossarm & Conduit Record of Decision
Compliance with ARARS
~
This alternative may meet ARARS since contaminated soil and groundwater could
be contained and institutional controls and performance monitoring are proposed.
ARARS (MTCA Method B clean up goals) for soil would be met for the Chehalis
Avenue Area and on the facility through containment.
Alternative 3: Off-Site Disposal
Major Components of the Remedial Alternative
In the off-site disposal alternative, contaminated soil and sediment at the facility
and in the AOC, which exceed risk criteria, would be excavated. This material
would be transported to an appropriate off-site facility for disposal. All structures
on the facility would be demolished. The floating product layer below the
treatment area would be removed.
Treatment Component
This alternative has no treatment component for soil, but does treat groundwater
to some extent.
Containment Component
This altern~tive has no containment component.
General Components
Soil in the Chehalis Avenue area conblminated with PAHs, PCP and dioxin above
cleanup criteria would be excavated and transported to a hazardous waste landfill.
The soil would be excavated to a depth of approximately 8 inches involving
approximately 14,300 cubic yards. Temporary relocation of residents and.busi-
nesses may be required during soil excavation. Following excavation, the area.
would be backfilled with clean soil and revegetated with hydroseed or covered as
appropriate.
Removal of the lagoon sediment would require a temporary diversion of the lagoon
stormdrain to the north-south stormsewer that discharges to Dillenbaugh Creek.
The stormdrain would be cleaned and relined.
The lagoon water and sediment would be removed by suction dredging. ,The
sediment would be pumped to a staging basin and press for dewatering. The
dewatered sediment would be transported via trucks for off-site disposal at an
approved .RCRA landfill. . ..
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American Crossarm & (]onduit Record of Decision
Wastewater generated from the lagoon dewatering process would be treated in a
transportable wastewater treatment system. The treatment system would be used
to treat water generated by all cleanup activities on the site. Treated water would
be discharged to the stormsewer system.
~
Structures, drums, tanks, and debris would be removed from the facility as
described in Alternative 2. Construction debris would be recycled or used as
backfill in excavations, depending on the character of the material. Soil would be
excavated from the areas shown on Figure 2-9. Subsurface soil under the treat-
ment works and around the surface impoundment would be excavated to a depth
of approximately 10 feet, generating 25,600 cubic yards of soil. .
Upon razing of the treatment works, the floating product layer would be removed
as described in Alternative 2.
Subsurface soil to the south of the kilns would be excavated to a depth of 6 to
15 feet. Surface soil in the northwest comer of the mill would be excavated to a
depth of 1 foot generating 1,800 cubic yards of soil for disposal. Similarly, 55,500
cubic yards of soil would be excavated from the landfill.
Runoff controls would be implemented during excavation. The facility would be
contoured to promote runoff and covered with topsoil and seeded. Groundwater
and surface water monitoring would be performed annually as described in
Alternative 2. .
Costs and Remediation Time Frame
The estimated time to complete this alternative is 1 year. The total estimated
present worth cost for off-site disposal is $42.7 million. Total capital costs of
$42.5 million include demolition and removal of all structures on the facility,
wastewater treatment, drainage enhancement,. and..cont~m1nated soil disposal.
Operation and maintenance costs of $250,000 consist primarily of long-term
monitoring.
Physical Effects on the Environment Caused By Implementation
Excavation and handling of contaminated media during implementation of
Alternative 3 would pose some risk to the environment. Preventative measures
would be taken to prevent migration of con~m1n~ted materials during remedia-
tion. During excavation on the facility, rele:ises to the environment would be
mitigated by the use of runon/runoff diversion techniques. Flood contingency
plans would be enacted within 48 hours notice of an impending flood to prevent
spread of con~m1nation.' .
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American Crossarm &.Conduit
Offsite Disposal Excavation Plan
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American Crossarm & Conduit Record of Decision
Dredging of the lagoon could damage surrounding foliage and release contaminat-
ed water and sediment into Dillenbaugh Creek. Measures would be taken to
minimize the effects of this action by preventing lagoon flow to the creek during
sediment removal.
Compliance With ARARs
MCLs-This alternative meets SDWA MCLs at the facility boundary through
removal of non-aqueous phase liquid (NAPL) and cont~minated soil which will
reduce the potential for further con~mination of the aquifer and groundwater
monitoring at the facility boundary.
Water Quality Standards-Federal and State water standards for Dillenbaugh
Creek would be met. Treatment of the facility soil to cleanup levels would result
. in con~m;nat\t levels protective of Dillenbaugh Creek based on A WQC.
. .
MTCA-Achievement of risk-based cleanup levels for contaminated soil under the
industrial (ACC facility area) and residentiaI (Chehalis Avenue area) scenarios
would also meet the risk-base4 cl~anup levels.und,er.MrCA Method B.. Restora-. .
tion of the lagoon and creek water. to. 'ambient'waJ.er qtiality criteria would meet. :
MTCA Method A cleanUp levels fot surface water. MTCA Method A cleanup levels
for groundwater would be met at the facility boundary.
'.. ." .-
Clean Water Act-Wastewater would be treated to meet the substantive require-
ments of the state NPDES permit prior to discharge to the surface water bodies
within the area of cont~mination.
RCRA-Temporary storage of soil and wastewater Within the area of
con~m;nation would conform to storage requirements (40 CFR 264 Subparts I, J,
and L). Secondary containment, leak detection devices, and flood-proofing
provided for the storage units would meet RCRA regulations.
The remedial activities at the facility and in the AOC would be conducted
according to applicable sections of RCRA' and Wasbington State Dangerous Waste
regulations using procedures to prevent releases or damage during a IOO-year
flood. Off-site disposal would be performed with RCRA facilities which are in
compliance with their permits and permitted to accept F032 wastes.
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American Crossarm & Conduit Record of Decision
Alternative 4: Incineration
Major Components of the Remedial Alternative
This alternative, consists of removing soil contaminated with PCP, P AHs, and
dioxin above cleanup levels, transferring the material to an incineration system
located on the facility and treating it to levels at or .below the goals. Groundwater
under the treatment area would be remediated using biological degradation. The
floating product layer in this same area would be removed.
Treatment Component
A transportable incinerator would be brought to the facility and set up in the AOC
between Chehalis Avenue, the mill, and the landfill. The incinerator would be
located on a raised earthen platform for flood protection. Contaminated areas in
the location of the platform would be excavated prior to platform construction. A
soil staging pad would be constructed for dewatering and staging the soil fol."' the
.' incinerator..A wastewater treatment system would.be located on th~ p.atfon:xi: ,
. .:. '. '. .:.: .1'J1e.,inCjner~1Dr~~~~4.be ~~.~,in~er{i~~~JIr,ta~'sQ.~ ~JP 'bhe.~!::.q~eh~~~~.: . .t.. '...;j'j\.~~..:..,
- . -. .Iio; ." .'''. ':fiA. :.,;,..,..~)~--::~" .:J ~!.1-:;;;';'~~~""~:.C:1L-'f~:...::tt&..r~.~........ ",.. '~edim~~"~;~:' '" . i~~ ~~,,:,i,..;;,..ij:
"":'):'::.~~""" ;';'i:~.'ftVenu~a"'Ool.l~"lRID"w:...ace.'z:Jul.I"'II'Onx"we&'KJ:I.D agoon'.s (~..,.'surrace' anO"'"" .' ". '..' ,"~':
. .'. ... .. . ,. '., t. . ..' - . . . . .
. . . subsurfac:e soil from .the treatinent area and."landfill, After treatment' is complete
the'incinerator would be removed. .
A groundwater remediation. system using biological degradation would be installed
to remediate groundwater at the three localized ares under the treatment area.
The groundwater treatment system would consist of one extraction well in approxi-
mately the same location as the floating product well and four injection wells.
Groundwater would be extracted, supplemented with nutrients, and reinjected to
enhance natural biodegradation of PCP and P AH. The process would continue
until groundwater cleanup levels were met or the process proved ineffective.
Containment Component
This alternative has no containment component in as much as the treated soil
would be placed back on th~ facility.
General Component
Site structures would be demolished and removed as described in Alternative 2.
Drums of solid and liquid waste would be treated in the incinerator, Drums of
filter cake from the previous incinerator efforts would be Collected for disposal at a
hazardous waste landfill.
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American Crossarm & Cvnduit Record of Decision
Contaminated soil, approximately 1,800 cubic yards, from the mill area would be
excavated and incinerated. Treated soil would be transported back to the facility
for consolidation. Due to the probability that some soil may not meet cleanup.
requirements for lead, a solidification processing unit would be used to solidify the
treated soil or containment as appropriate. The soil would be mixed with.
solidification agents and would be discharged on the facility. Soil that has lead
below action levels would be off-loaded directly to the facility. .
Chehalis Avenue area soil contaminated above risk goals, approximately
14,300 cubic yards, would be excavated and transported to the facility. Soil requir-
ing treatment to achieve cleanup levels, approximately 4,400 cubic yards, would be
processed through the incinerator. -Treated soil would be off-loaded in the mill
area. The remaining Chehalis Avenue soil would not require treatment and would
be taken directly to the facility for consolidation.
Conblminated subsurface soil behind the kilns would be excavated as described in
Alternative 3 and treated in the incinerator. Treated soil would be placed ba:ck on
. the facility. . .
o .
~i~tl~~~~.agoo,,;,~: ~~iif~~d~~~~~~=.~~d Processed through the incin-
o 0, . . 0.00 0 0 .~, 0 00
o 00. 0 erator: . Treated sediment would J>e consolidated on the facility. 00 0
Subsurface soil under the treatment area (surface impoundment and treatment
works), approximately 12,700 cubic yards, would be excavated and processed
through the incinerator. Treated soil would be used for backfill in the same
excavated area. Approximately 5,900 cUbic yards of surface soil in the treatment
area would be excavated to a depth of 2 feet and incinerated. .
Soil in the landfill, approximately 55,500 cubic yards, would be excavated and
screened prior to incineration. Approximately 47,000 cubic yards would be
incinerated and 8,500 cubic yards of debris would betaken to an off-site RCRA
landfill. Treated soil would be placed back into the landfill.
The ACC facility would be contoured to enhance runoff. Clean fill from the
incinerator platform would be spread to a depth of 6 inches over the facility and
revegetated.
The groundwater remediation system described previously would be used to
remediate the groundwater under the treatment works. An extraction system
similar to that described in Alternative 2 wocld be installed to remove floating 0
product beneath the treatment works. Removal of floating product wo~d occur
prior to excavation in the treatment area. . 0
..
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American Crossarm & Conduit Record of Decision
Runoff controls would be installed as well as groundwater and surface water
. monitoring, as described in Alternative 3.
Costs and Remediation Time Frame
This alternative would take 28 months to implement. Groundwater remediation
would continue indefinitely. The total present worth cost for this alternative is
estimated at $103 million. Capital costs, $102 million, include incineration and
consolidation of the soil, construction of the treatment platform and dewatering
pad, building demolition, and wastewater treatment. Operation and maintenance
costs, $862,000, include monitoring costs and groundwater treatment.
Physical Effects on the Environment Caused by Implementation
Although short-term risks for either releases to the environment or exposure to
humans would be escalated during excavation, storage, and treatment activities,
precautions would be taken to prevent exposure and mitigate migration of contami-
nated materials. Those risks would be similar to Alternative 3. The transportable
incinerator would be operated according to treatment performance requirements to
prevent unacceptable risk to the environment. A risk assessment would be
performed prior to implementation of this technology to insure that the'
environment would not be adversely affected.
Compliance with ARARs
MCLs-In situ biological treatment of the contaminated aquifer would be designed
using SDW A MCLs cleanup levels. Although groundwater treatment systems
would not be applied to other areas, source removals may be sufficient in addition
to natural degradation to meet MCLs at the facility boundary.
MTCA-MTCA cleanup standards (goals) would be achieved under this
alternative.
Clean Water Act-Discharges of wastewater to surface-water bodies within the
area of contamination would be treated to meet the substantive requirements of
the state NPDES permit.
RCRA-Temporary storage of soil and wastewater within the area of cont.Am;n9-
tion and flood contingency plans would be performed in compliance with applicable
RCRA requirements.
RCRA treatment and performance requirements for fixed-baSe incinera~rs (40
CFR 264 Subpart 0) would be anticipated to be relevant and appropriate to the
~
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American Crossarm & Conduit Record of Decision
activities described for this alternative. The transportable incinerator would be
designed to meet these requirements, and monitored to ensure compliance.
Alternative 5: Con~inment
Major Components of the Remedial Alternative
Remedial action taken in this alternative consists of consolidating all contam-
inated soil and sediment from the AGC on the ACe facility. The area would be
capped to prevent contact with the contaminated soil and to prevent rainwater
infiltration. The alternative also includes deed and access restrictions and
groundwater and surface water monitoring.
Treatment Component
This alternative has no treatment component.
Contaminant Component
Gon1;::iminated soil and sediment would be consolidated on the facility and covered
with an impermeable layer to prevent people from coming into contact with the
con1;::imination and to prevent rainwater infiltration. Following soil consolidation,
a 6-inch bedding layer would be graded and rolled over the soil. An impermeable
membrane would be placed over this layer. Drainage pipe circumscribing the
capped area would discharge collected surface water to a ditch. The final layer of
the cap would consist of topsoil and vegetation. The cap would be vented.to
release any gases generated.
General Components
In preparation for capping all facility structure.s would be razed and disposed as
described in Alternatives 2 and 3. Drums of waste material, debris, ash, and
above and below ground tanks would be handled as described in Alternative 2.
Approximately 14,300 cubic yards of cont.$lminated soil from the Chehalis Avenue
area would be excavated and placed on the facility. Similarly, dewatered sediment
and soil from the lagoon would be consolidated with the Chehalis Avenue soil.
Con1;::iminated lagoon water would be removed from the sediment, treated, and
discharged to Dillenbaugh Creek. The storm drain would be cleaned and reline~.
Because cont.$lmination would remain on the facility, deed and access restrictions
would be imposed as outlined in Alternative 2. Groundwater and Dillenbaugh
Creek would be monitOred annually as described in Alternative 1.
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American Crossarm & Conduit Record of Decision
Costs and Remediation Time Frame
Containment and associated remedial actions would take 1 year to complete. The
estimated present worth cost for this alternative is $7.1 million. Capital costs
which include excavation, consolidation and capping are $6.8 million. Operation
and maintenance costs are approximately $265,000 and include monitoring,
inspection and fence/cap repair.
Physical Effects on Environment Caused by Implementation
The risks to the environment from this alternative are similar to those in Alter-
native 3 and similar measures would be taken to minimize the impact. Flood
contingency plans would be imposed for this alternative in the short term for
removal of highly cont~minated containerized materials upon notification of an
impending flood. Long-term flood contingency is not needed because the flooding
is passive and not expected to effect the performance of the cap. Additional risks
are associated with leaving the cont.:lminated soil in place without treatment
although transport from infiltration and exposure would be reduced by the cap.
Compliance with ARARS
MCLs- This alternative does not include activities to remediate the aquifer or
remove the subsurface contslmination. Therefore, this alternative is not expected
to meet MCL at the facility boundary.
Water Quality Standards-Federal and state water quality standards would be
met for Dillenbaugh Creek and the lagoon upon removal of contaminated lagoon
water and sediment. No effiuent discharges would be made to the creek. Contain-
ment of the facility soil would mitigate the cont~min~mt source for the lagoon and
creek through stormwater runoff.
MTCA-This alternative would meet the risk-based cleanup levels under MTCA
Method B through contslinment. The pathway for exposure by inhalation,
ingestion, and dermal contact would be eliminated, reducing the overall risk.
MTCA Method cleanup levels for groundwater would not be met at the facility
boundary indefinitely, although natural attenuation would work to reduce
contaminant concentrations. Restoration of the lagoon and creek water to A WQC
would meet MTCA cleanup levels for surface water.
RCRA-This alternative would not meet relevant and appropriate RCRA (40 CFR
264) siting requirements for hazardous waste laluifills, since pgrtions of the
facility landfill are below the seasonally high water table and are located within
the 100-year floodplain without washout protection. Although minimum technical
requirements (MTRs) would not be used, the.4- to 20-foo~ low-permeability layer
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American Crossarm & Conduit Record of Decision
underlying most of the facility area is expected to prevent the' migration of
residual contamination into the aquifer.
Off-Site Treatment and Disposal
Major Components of the Remedial Alternative
This remedial action consists of excavating the contaminated soil from the ACe
facility and AOC, as described in Alternative 3. This material would be sent to an
off-site incinerator for treatment. Incinerator ash would be disposed in a RCRA
hazardous waste landfill. Structures and soil would be removed from the facility.
The areas would be backfilled with clean soil and reseeded.
Currently there are no commercial hazardous waSte incinerators permitted to
treat the wood treating waste found at the facility (F032 wastes). This alternative
would be implemented in the event that a permitted facility becomes available and
includes the assumption that the incinerator facility would also be responsible for
final deposition of the treatment residuals. .
Treatment Component
Treatment would be similar to processes described in Alternative 4 but the
incinerator would be located at an off-site commercial facility.
Containment Component
This alternative has no on-site containment component.
General Components
This alternative has the same general components as Alternative 3 except the
excavated materials would be treated in an off-site incinerator prior to disposal in
a landfill.
Excavated soil and sediment would be dewatered on the facility and shipped to the
incinerator facility in covered transport trucks. Landfill material would require
screening to remove metal and other debris prior to shipment. Material removed.
from the screening process would be taken to an off-site RCRA landfill for
disposal.
After all structures and soil are removed from the facility, these areas would be
backfilled with clean soil and reseeded. . .
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American Crossarm & Conduit Record of Decision
Costs and Remediation Time Frame
Approximately 3 years is estimated for implementation of this alternative. Off.
site treatment and disposal is the most expensive alternative with an estimated
present worth cost of $292.6 million. Capital costs include excavation and off-site
incineration and are $292.3 million. Operation and maintenance costs are
$250,000, similar to all previous alternatives.
Physical Effects on Environment Caused by Implementation
The physical impact on the environment of this alternative would be equivalent to
Alternative 3. Environmental risks would be minimized by providing secondary
containment for storage tanks and other storage areas and by implementing runoff
controls during remedial action. .
Compliance with ARARs
MCLs-Similar to that discussed in Alternative 3, this alternative only includes
removal of the floating product and would only achieve MCLs at the facility
boundary.
Water Quality Standards-Similar to Alternative 3, federal and state water
quality standards are anticipated to be met in this alternative.
MTCA-Achievement of risk-based cleanup levels for cont~m1nated soil under the
industrial (ACC facility area) and residential (Chehalis Avenue area) sce~arios
would meet the risk-based cleanup levels under MTCA Method B. MTCA Method
groundwater cleanup levels would be met by this. alternative at the facility
boundary. Restoration of the lagoon and creek water to A WQC would meet MTCA
Method cleanup levels for surface water.
Clean Water Act-Wastewater discharged to surface-water bodies within the area
of contamination would be treated to meet the substantive requirements of the
state NPDES permit and would comply with Clean Water Act requirements.
RCRA-Tempo~ storage of soil and wastewater within the area of contamina-
tion, and flood contingency plans would meet RCRA storage requirements as
outlined in 40 CFR 264 Subparts I, J, and L. This alternative is not plausible
. without an available permitted hazardous waste incinerator. 40 CFR 264 Subpart
o requires that 99.9999% destruction removal efficiency (DRE) be achieved for dioxin-
cont~ining wastes. This performance standard is expected to apply. Currently, no
commercial hazardous waste incinerator is permitted to burn dioxin-containing
waste. . ..
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American Crossarm & Conduit Record of Decision
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The following section discusses the comparison of alternatives with respect to the
nine statutory CERCLA requirements.
Protectiveness of Human Health and the Environment
All cleanup alternatives except No Action provide protection to human health and
the environment. Alternatives 2 and 5, which allow the most highly contaminated
low-level material to remain on the facility, are less protective.
Institutional controls are relied upon in Alternative 2 to maintain protection of
human health. Some risk to the environment would still exist in Alternative 2 as
a result of contaminated lagoon sediment remaining in place and releasing toxics
to Dillenbaugh Creek.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternatives 2, 3, 4, 5, and 6 which remove surface soil.in the Chehalis Avenue
area would meet the Washington State Model Toxies Control Act (MTCA) Stan-
dards.
None of the alternatives would meet all MTCA cleanup standards for unrestricted
use for soil and groundwater on the facility. Several facts have been considered in
proposing a remedy that complies with MTCA. These include the following:
. It is not possible to reuse or recycle the contaminated soil, nor is it practic-
able to treat all the con~rninated soil and the groundwater. However, if
treatment can be done to significantly lower the risks posed by the site, it
should be done;
. The most highly contJ:lrninated materials should be removed; and
. ContJ:lrninants remaining on the facility should be contained. When
cont8rnination remains, MTCA requires institutional controls to restrict
future access and use.
In the short term, Federal Drinking Water Standards for cont8rninated ground-
water will likely be met at the facility boundary under all of the alternatives.
. However, under Alternatives 2, 3, 4,.and 6, the most significant sources of ground-
water contJ:lrnination would be removed increasmg the compliance term,
All alternatives involving removal and treatment or off-site disposal of con-
~rninated soil would meet Federal and State Resource Conservation ~d Recovery
2-46
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American Crossarm & Conduit Record of Decision
Act (RCRA) standards for proper disposal of this material. These standards
chiefly apply to Alternatives 3, 4, and 6. .
Long-Term Effectiveness and Permanence
Alternative 4, involving on-site treatment, along with Alternative 6, involving off-
site incineration, permanently destroy P AH and other organic compounds.
Altemative 3 involves solidification as the treatment process prior to disposal in
an off-site landfill to permanently limit the mobility of the contaminants in that
material. Alternatives 2 and 5, involving institutional controls and containment,
do not permanently remove or destroy the contaminants.
Alternatives 1, 2, and 5, which allow conUlminated soil to remain on-site, risk the
potential for a flood' to cause off-site migration.
Reduction of Toxicity, Mobility, and Volume
Altemative 4 and Alternative 6 provide the highest reduction of toxicity, mobility,
and volume by permanently destroying the conUlminants. Solidification, employed
in Alternative 3, will limit the mobility of the contaminants in the solidified .
material as it will be disposed in a controlled landfill. Alternative 5 provides reduc-
tion in mobility and volume through enhanced biodegradation and capping.
Altematives 1 and 2 do not provide any reduction through treatment.
Short-Term Effectiveness
Altematives 2 and 5, which involve capping, provide the greatest short-term
effectiveness because they can be implemented most quickly and result in the
least risk to workers and the community. All alternatives other than the no
action alternative involve the removal of contamin8ted soil and could have
negative short-term impacts such as dust generation,. particularly in areas with
heavy contamination. Alternatives 3, 4 and 6 also involve excavation and treat-
. ment or disposal of much larger volumes of so~. Those altematives would present
greater short-term risks and would require the most extensive measures to
mitigate short-term risks.
Implementability
All of the alternatives can be implemented with existing technologies, although
with varying degrees of difficulty. Alternatives 1, 2.and 5 involve less excavation,
making the logistical work involved with their iinplementation relatively easy.
Alternative 4 would require extensive staging of material prior to and immediately
after treatment; and is considered the most complex to implement. This
alternative is also complicated to implement .due to the location of the- facility in
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American Crossarm & Conduit Record of Decision
an active flood plain. Alternative 6 involves the excavation and off-site treatment
of contaminated soil. It may be difficult to locate a commercial off-site incinerator
that could handle the soil in Alternative 6.
Cost
Alternative 1 has the lowest cost due to the minor remedial work performed.
Alternative 2 has the next lowest cost because it relies on institutional controls
which are inexpensive to implement. Alternative 5 is third lowest because it does
not treat soil but contains it on-site. Alternatives 3, 4 and 6 have the highest
costs because they dispose of the soil off-site or treat the soil using incineration,
all of which have significant costs.
THE SELECTED REMEDY
Based upon consideration of CERCLA requirements, the detailed analysis of
alternatives against the nine criteria, and comments from the public, the EP A and
State of Washington have determined that a combination of Alternative 3 (off-site
disposal) and Alternative 5 (containment) is the most appropriate remedy for the
facility and AGC in Chehalis, Washington. The selected remedy is appropriate
because it meets all the RAGs (see p 2-31), has good long-term -effectiveness and
permanence, reduces the volume and mobility of contsimination, is highly effective
in the short term, is quickly implementable, and has a relatively low cost.
Major Components of the Selected Remedy
AGC
Soil in the Chehalis Avenue area contaminated with PARs, PCPs, and dioxins will
be excavated and consolidated on the facility. Appr.oximately 8 inches of soil will
be excavated from the areas outlined in Figure 2-10. This will include the
playfield adjacent to the facility. A total volume of approximately 14,300 cubic
yards will be excavated and the areas will be back filled with clean soil and
seeded. .
....
Discussions with affected home owners will be held to inform them of the plans for
excavation. Permission to excavate soil on private property will be obtained prior
to work in that area.
The design will incorporate requirements to minimize disturbance of residents.
Excavation of soil in the Chehalis Avenue area will be pe~ormed in such a .
manner that disruption is minimized: Areas such as single blocks will be done at
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o 00
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Surface Soil
~ Removal Areas
Limits Of FI~
AA.& Bome Contaminants
- Reported In 1986
~
Scale in Feet.
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ICIII
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I
100
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,
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Chehalis Avenue Area
. . Excavation Plan
AQUAE
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American Crossarm & Conduit Record of Decision
a time to minimize residential impact. Working hours will be set and noise
abatement employed as necessary to be compatible with a residential setting.
The design will incorporate appropriate safety and health protection. Air monitors
will be set up at work area boundaries to assure ambient dust levels and contam-
inant concentrations do not adversely affect surrounding residents. Decon-
f.sIminAtion will occur on heavy equipment prior to entering uncontrolled public
roadways to control cont.AminAtion migration. Dust control measures will also be
employed.
The design will contain a confirmatory performance monitoring plan so that after
soil excavation is complete and prior to backfiHing, confirmatory sampling will be
performed to verify the remAining soil does not exceed cleanup levels. Details of
the sampling scheme will be determined during remedial design.
Cont.Aminated sediment in the storm water discharge lagoon will be removed by
dredging and/or excavating. Contamin9ted sediment from the stormsewer drain
will be removed and the storm drain cleaned. The sediment will be dewatered and
transported to an approved RCRA hazardous waste disposal facility. The sewer
will be relined in such a manner that results in no reduction of flow capacity and
the lagoon contoured to provide containment capacity for the city of Chehalis
stormwater discharges. Removal of the stormwater discharge lagoon sediment
and cleaning and reHning the storm drain will be performed such that no
discharge of contAminAted water or sediment is released to Dillenbaugh Creek.
ACC Facility.
All facilities and structures will be demolished. Figure 2-11 outlines the
structures and equipment which will be removed. These include:
. below-ground tanks
. treatment works
. steam transfer lines
. laboratory building
. boiler control room
. 8 kilns
. sheds
. shop
. crane trestle
. mill
. fuel bin
. .
Demolition debris will be cleaned and recycled when feasible. Otherwise, it will be
disposed in a permitted landfill as appropriate.
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7J
~
Explanation
1 Retort Found8tlon
2 Underground T8IIk
3 Loading 00cIc
4 Trutment Ptmt
5 Trutment Plmt Control Room
6 EleY8tecf Work T8IIk Foundations
78 Steern Transfer Une
7b Stum Transfer Une Trench
8 Labor8tory Building
9 fuel Bin
10 East Boiler Control Room .
11 West Boller Control Room
12 Cooling Shed . Kiln
13 KIlns
14 Production Well
15 Underground Tank
16 Wood Refuse BuDding
17 Shop
18 Shed
19 Crane TrutJe
20 Cooling Shed . Mill
21 Rre Hose Shed
22 Lunch Room
23 Showers
24 Factory (MiR)
25 Mill. KIln Ptatfonn
2aI
I
Scale In Feet.
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20
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o
Locationof Facility Structures
FIGURE
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American Crossarm & Conduit &cord of Decision
The facility production well and unnecessary resource protection wells will be
abandoned in accordance with WAC 173-160.
The most highly contaminated surface and subsurface soil on the facility would be
. excavated as outlined in Figure 2-12. Excavation would include approximately
2 feet of surface soil in the treatment area, 10 feet of subsurface soil under the
treatment works and the surface impoundment, and 6 feet of subsurface soil to the
south of the kiln. Approximately 20,000 cubic yards will be excavated trom the
area and will be transported to a RCRA approved off-site hazardous waste
disposal facility. Treatment studies will be performed to evaluate the benefits of
stabilization prior to disposal. If treatment shows a reduction'in leachability to
below TCLP requirements for lead and PCP, consideration will given to solidifying
the soil at the off-site landfill prior to disposal.
,
During excavation of the treatment works and surface impoundment, physical
processes will be used to remove the floating product on the groundwater. Oil
absorbent materials, water removal pumps an,d an oil water separation or other
equivalent processes will be used to achieve removal of the major mass of floating
product. The oil removed will be disposed at an off-site hazardous waste
treatment facility.
Wastewater generated from site activities will be treated to substantive
requirements of the state of Washington National Pollution Discharge Elimination
(NPDES) standards prior to on-site ~scharge or be taken off-site for disposal.
Incinerator ash from incineration of con~min8ted soil in 1988 and 1989 will be
consolidated with the Chehalis Avenue residential soil consistent with ECology's
determination of the non-hazardous nature of the ash. The consolidated soil and
ash will be used to backfill excavation under the treatment works and surface
impoundment. Clean backfill will be used to fill the excavation to SUlTOunding
grade.
During remedial design, a computer model will be used to compute the backwater
curve so that no or negligible net increase in floodwater elevation will result from
the remedy. The entire facility (see facility boundary Figure 2-2 will be covered
with clean topsoil, properly sloped and contoured and revegetated with grass.
Runon/runoff controls will be implemented to prevent contSlmin8ted water from
entering the wetland"or Dillenbaugh Creek. Work will be scheduled to coincide
. with the dry part of the year to minimi7.e potential flood damage and runoff. The
wetland and creek will be left to recover naturally. .
-------
Scale in Feet
100
.
o
I
50
~
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.. 10' Subsurface Excavation
,
\
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. 6' ~~iface Excavation
~ 2' Subsurface Excavation
ACC Facility
. Soil Removal Areas
FIGURE
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American Crossarm & Conduit Record of Decision
A Performance monitoring program will be developed as a part of the remedial
design. The monitoring program will be designed t.o monitor remedial action
performance and to assess the risks to human health and the environment from
the remedial action. This program will include annual monitoring of groundwater,
Dillenbaugh Creek, the lagoon and other areas, as deemed necessary during
design. The plan will also contain a provision for post-flood monitoring, as deemed
necessary, to assess remedy performance.
In addition to the performance monitoring, post-flood monitoring and O&M
activities described above, Five- Year Reviews are also an important component of
the selected remedy. These periodic reviews, which are required no less often
than each five years after initiation of the remedial action, will evaluate whether
the response action remains protective of human health and the environment. At
this site, the focus of these reviews should include: whether the cover over the
facility remains effective, whether the land use controls remain in place, whether
the water main under the landfill or other utility lines have become a potential
migration route, whether the groundwater contamination rem~1n~ confined to the
facility, and the frequency and cost of O&M repairs and how these relate to
protectiveness. If any of these items indicate remedy failure or a higher than
acceptable potential. for remedy failure, EPA, in consultation with the State, will
consider whether or what further actions should be taken.
Institutional controls will be implemented. Access to the facility will be restricted
by erection of a chain link fence around the entire facility. Deed notices and
restrictions will be imposed to limit future use of the property, ensure that the
cover and contamination below are not disturbed, and that current and future city
utility maintenance, upgrades and or abandonment are consistent with the
remedy objectives. Periodic site inspection and maintenance (cover, fence, signs)
will be completed to review performance of the remedial action and determine
needed maintenance. Five year reviews will be performed to determine the
performance and protectiveness of the remedial a~()n.
Cleanup Levels
The cleanup objectives for the facility and AOC are based on performance
require~ents which are consistent with the numerical cleanup criteria of the
2-54
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American Crossarm & Conduit Record of Decision
Washington State Model Toxics Control Act (MTCA) regulations, Chapter 173-340
WAC. The cleanup standards (Method B, residential) are:
Maximum
Groundwater Cleanup Maximum Soil Cleanup
Compound Concentration Level-Groundwater Concentration Leve~oil
CPAH 600 ug/L 0.012 ug/La 258,000 ug/kg 172 ug/kga
0.3 ug/lb
PCP 91,400 ug/l 0.729 ug/la 250,000 ug/kg 8,330 ug/kga
TCDD ND 0.00058 ng/l a 143,000 nQ/kg 0.0066 ng/kga
0.025 ng/Lb
Notes:
a MTCA Method B (Carcinogenic)
b Practical Quanlitation Umit
ND Not detected
Ecology concurs with the selected remedy. The selected remedy meets the cleanup
levels in the AOC by removal and through containment on the facility [WAC 173-
340-740(6)(d)]. Containment is an acceptable approach due 19 the fact that low
levels of contaminants exceeding cleanup standards are present at all depths
throughout the facility, resulting in large volumes of contaminated soil, and
because the remedy includes compliance monitoring (WAC-173-340-410),
institutional controls (WAC 173-340-440) other conditions of WAC 173-340-360(8).
The cleanup objectives are provided at specific areas within the facility which will
be excavated to a given depth. Those objectives were developed through an alter-
native optimization evaluation performed in the feasibility study. Based on this
evaluation, it was determined that 70% of the total cont.amination could be
removed by excavating 25% of the soil as specified in the selected remedy. This
approach optimizes the balance between contami'nation removal, treatment and
cost, consistent with WAC 173-340-360(5)(d). '
Protection of the Environment During Remedial Action
During implementation of the remedial action, measures will be used to mitigate
impact on the environment.
During excavation in the Chehalis Avenue area, soil will be loaded into covered
trucks. Trucks will be decontaminated to prevent spreading of cont.aminated
material through the streets. Equipment will be cle,anedprior to leaving the areas
of excavation. Stormwater diversion techniques and runofflrunon control'
measures will be employed if necessary.
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American Crossarm & Conduit Record of Decision
Precautions will be taken to prevent release to the environment and mitigate
migration of contaminated material during demolition and excavation activities at
the facility. Stormwater diversion techniques (runofllrunon control measures)
such as covering areas under excavation, construction of diversion ditches, and the
use of dikes and berms will be employed. In addition, excavation in low-lying
. areas will be conducted during the dry season to minimize runoff. Wastewater
generated during the remedial action will be treated to protective levels (e.g.,
NPDES) prior to discharge to Dillenbaugh Creek.
Flood contingency plans will be enacted within 48 hours notice of an impending
flood. These plans include immediate cessation of excavation activities and
securing contaminated material to prevent dispersion.
Cost and Remediation Time Frame
Remediation is estimated to take 8 to 12 months to complete. Costs for the
selected remedy are itemized in Table 2-5. Capital costs are $9.5 million and
include excavation of soil, surface structure demolition, off-site disposal of the
highly cont~rninated soil, and contour and grading of the ACe fa~ty. Operation
and maintenance costs are $250,000 and include water monitoring, cover
maintenance and site inspection. Total present worth value is $9.7 million.
STATUTORY DETERMINATIONS
EP A's primary responsibility under its CERCLA authorities is to ensure that
remedial actions at Superfund sites are protective of human health and the
environment. In addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when complete, final
remedial actions must comply with applicable or relevant and appropriate environ-
mental standards unless a statutory waiver is justified. The selected remedy must
also be cost-effective and utilize permanent solutions.and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
Finally, the statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element.
The selected remedy for the ACC facility, Chehalis, Lewis County, Washington
meets all of the statutory requirements of Section 121 of CERCLA. The
evaluation of the CERCLA criteria are discussed below.
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American Crossarm & Conduit Record of Decision
Table 2.5-Cost Analysis-Selected Remedy
. Description Quantity Unit Unit Cost Cost
Capital Costs
1. MobilizationlDemobilization (Utility Hookup) LS $11,925
2. Site Preparation
Decommission Utilities LS $1,500
Perform Site Survey 3 Day . $910.00 $2,730
Install Temporary Construction Fencing 3,000 LF $5.65 $16,950
Remove & Replace Existing Monitoring Wells 11 Well $3,500.00 $38,500
3. Structural Demolition and Disposal
Mill Building LS $195,314
Kiln Building and Concrete Slab LS $86,865
Platform LS $42,130
Treatment Works LS $45,121
Tramway LS $33,650
Other BuildIngs & Misc. Items LS $5,535
Dispose of Drums w/Contaminated Materials 374 Drum $136.00 $50,864
Recycle misc. items (tires, auto tanks, pipes, etc) 25 Ton $75.00 $1,875
4. Storage Tank Removal & Reclamation 8 Tank $6,750.00 $54,000
5. Water Control
Construct Dewatering Pad 2,500 SY $45.17 $112,925
Install Diversion Ditches & Berms 1,650 LF $3.64 $6,006
6. Consolidation of Solids
Temporarily Relocate Residents 160 PERS $410.00 $65,600
Excavation of Chehalis Ave Soil 14,300 CY $15.12 $216,216
Excavation of Contaminated Soil 19,400.. "" CY $2.30 $44;620
Hydraulic Dredging of Lagoon Sediment 3,300 CY $3.00 $9,900
Dewater wlPlate-Frame Filter Press 3,300 CY $38.75 $127,875
Hauling 14,300 CY $2.25 $32,175
Backfill Excavations w/Clean Fdl 19,400 CY $4.69 $90,986
Clean Topsoil for Chehalis Ave. Area & Hydro-seed 14,300 CY $16.00 $228,800
-"
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American Crossarm & Conduit Record of Decision
Table 2-5-Cost Analysis-Selected Remedy (continued)
Description
Quantity
Unit
Unit Cost
Cost
7. Soil Disposal (Off-Site Landfill) 19,400 CY $250.00 4,850,000
8. Safety Monitoring and Sampling
Soil Sampling and Analysis (1 sample/yard) 80 1 yard $850.00 $68,000
Health & Safety Expend. (30 pers @ $60/perslday) 90 Day $1,800.00 $162,000
9. Wastewater Treatment 350,000 Gallon $0.45 $157.500
NAPL Disposal 10,000 Gallon $4.00 $40,000
10. Facility Cover
Place 2-foot Topsoil Layer 33,700 CY $16.00 $539,200
. RecontourlShape & Grade ACC Facility 50,550 SY $0.53 $26,792
Hydroseed 450,000 SF $0.06 $27,000
11. Clean & Reline Stann Drain 830 LF $225.00 $186,750
Subtotal $7,579,304
Engineering Expenses (10%) $757,930
Contingency Allowances (15%) $1,136,895
TotalCaphalCosts $9,474,129
Operation and Maintenance Costs (present worth)
1. Water Monitoring
Sampling 30 Year $7,470.00 $70,419
Laboratory Analysis 30 Year $11,240.00 $105,959
2. Site Inspections/Cover 30 Year $400.00 $3,771
Maintenance
Subtotal $180,148
Administrative Costs (15%) $27,022
Contingency Allowances (25%) $45,037
Total O&M Costs $252,208
Total Present Worth Value $9,726,337
Note: The costs are present worth estimates (+=50%. -30%), with a 1O~iscount rate for 1 year.
. .
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American Crossarm & Conduit Ret:ord of Decision
Protection of Human Health and the Environment
The selected remedy proiects human health and the environment by removal of
contaminated soil in the Chehalis Avenue area and its consolidation on the ACC
facility where human access and exposure will be restricted by capping/covering,
fencing, and deed restrictions. Thorough removal of the Chehalis Avenue area soil
and subsequent sampling to assure cleanup levels are met will reduce the cancer
risk to residents to within the 1 x 10-6 criteria.
Human health and the environment will be protected by demolition and removal
of the facility structures. Excavation, removal and disposal of highly'
cont~minated soil on the facility and capping will also protect human health and
the environment such that the residual cancer risk will not exceed 1 x 10-5.
Protection of the environment is provided by removing lagoon sediment that
presents a potential risk to terrestrial and aquatic wildlife. Although no
treatment of Dillenbaugh Creek is provided, the creek water contJ:lmination will be
reduced by removing the source of contJ:lmination. Removing the majority of
con~minated soil, covering the area with clean soil and revegetating will
significantly reduce contJ:lmins:tted surface ~off which will reduce the PCP, P AH
and dioxin loading to the creek.
Extraction of the floating product layer below the treatment works will remove
one continuing source of contJ:lmination to groundwater. Groundwater
contslmination above MCLs is only present within the facility boundaries, is not
anticipated to migrate off site due to tight hydrogeologic setting, and would not be
used as a source of drinking water due to very low permeability, expected' well
yield and deed restrictions. therefore, the current and potential beneficial uses of
groundwater beneath the site do not include drinking the water. Additionally,
groundwater contJ:lminants are not expected to migrate vertically downward into
deeper aquifers. Removing most of the sources of cp:g.tJ:lmins:ttion (soils and floating
product) will eventually lead to groundwater restoration within the site boundary
through natural physical and microbial degradation processes or natural .
attenuation. .
Covering the entire facility with clean soil and revegetating will protect hnm~m
health by eliminating soil ingestion, dermal coIitact and dust inhalation pathways.
In addition it will eliminate the migration of contJ:lminated runoff from the area.
Deed and access restriction will assure that the potential threats of the area are
known and that the inadvertent excavation of contslmins:tted soil is avoided.
Monitoring of groundwater, and creek water Will protect hnmaT1s by proViding
early indications of an increase in con~minant concentrations so that additional
engineering or institutional controls can be. implemented.
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American Cr.ossarm &: CJnduit Record of Decision
. .
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Chemical Spe~i/ic ARARs
Federal Safe Drinking Water Act-The sel~ted remedy does not include groundwater actions
other than removal of the floating product and therefore will only meet SDW A MCLs at the
facility boundary. The facility boundary (see Figure 2-2) is the point of compliance for
groundwater.
, ..
Federal Water Quality Criteria/State Water Quality Standards-Although contaminated sedi-
ment will not be removed from Dillenbaugh Creek, water quality standards should be met
over time tbrough natural attenuation and removal of the source of contamination, lagoon
water and ~iment and storm runoff. The deleterious effects, of remedial actions in ,the, '
wetlarids 'or creek outweigh the'potential envir,onmental benefitS'.,:', "'.'" , " :. " :. .,
. . -'. . '" ,.,. '.'" '. '.o'~' . .'. .'.". .'
"0" .,
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Model To~~~ Control Act' (MTCA) (YVAC 173-340)-MTCA cleanup levels for groundwater
will be met at the facility boundary. MTCA B soil cleanup levels will be met for the
Chehalis Avenue area. MTCA B soil cleanup levels, will be met on the facility through
containment and monitoring.
Action Specific ARARs
RCRA/Washington State Dangerous Waste Regulation-RCRA Subtitle C for treatment
storage and disposal of hazardous waste will be met for off-site disposal actions. Storage of
soil and wastewater within the area of contamination will conform to the RCRA storage
requiremen~ for containers, tanks, and waste piles (40 CFR 264 Subpart I, I, and L).
Secondary containment, leak detection devices, and flood-proofing provided for storage units
will meet RCRA regulations. '
Clean Water Act (CWA), 33 U.S.C. Section 1251 et seq; National Pollutant Discharge
Elimination System (NPDES); Washington State Water P~~ution Control Act, RCW 90-48;
NPDES Permit Program requirements, WAC 173-22o-Wastewater will be treated to meet
the substantive requirements of the state NPDES permit prior to discharge to surface water
bodies beyond the area of contamination.
Location Specific ARARs
Executive Order on Protection of Wetlands and Floodplains-The selected remedy is not
expected to adversely impact the floodplain or lagoon; therefore, the standards of this
executive order w:..n be met.
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Shoreline management Act(RCW 90.58 1971 Act) may be A~ and would be met through
the design permitting plan. '
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American Crossarm & Conduit Record of Decision
~, ..:," STW~'- ~e~ 'Cka~~p'~f:B~~~eq~eit/ c6~;iiaitce' kiions ....... .;.:
. Other c~nstruction specific ARARs include:
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RCW 70.95 Solid Waste recovery and Management Act
RCW 18.104 Water Well Construction
WAC 173-162 Licensed Well Drillers
WAC 446-50 Transportation of Hazardous Materials
WAC 206-155 Safety for Construction Workers
WAC 296-62, Part P, WISHA Hazardous Waste Operations
Cost-Effectiveness
'.
The selected remedy is cost-effective because it is protective of hnm8n health and
the environment and achieves an appropriate balance of long-term' effectiveness
and permanence, reduction of toxicity, mobility or. volume, and short-term
effectiveness. The selected remedy proVides an overall effectiveness proportionate
to its cost, $9.7 million.
Utilization of Permanent Solutions and Resource Recovery Technologies to the
Maximum Extent Practicable
EP A and Ecology have determined that the selected remedy represents the
maximum extent to which permanent solutions can be utilized in a cost-effective
manner for the facility and AOC. The selected remedy provides the best balance
of trade-offs in terms of long-term effectiveness and permanence, reduction in
toxicity, mobility, or volume, short-term effectiveness, implementability and cost.
The remedial action also considers state and community acceptance.
Removal of Chehalis Avenue area soil, covering the area with clean soil, and
revegetating will provide a permanent solution in reducing risks to remediation
objectives. Contaminant mobility is reduced due tO~'removal of the soil.from an
uncontrolled environment and consolidation in a controlled environment. Toxicity
and volume are not reduced by this portion of the remedial action.
Risk on the ACC facility will be permanently reduced by off-site disposal of the
highly contaminated soil and demolition and removal of above and below ground
structures. After implementation, risk from surface soil is insignificant due to
placement of a layer of clean topsoil over the area and revegetation. The potential
for recontslminating the Chehalis Avenue area will also be permanently reduced
by this part of the remedial action. The volume of contaminated soil and other
material is reduced by this part of the remedial action as c;lemolition debris and
highly contaminated soil are removed. Mobility of the cont.arnin8ted soil
remaining on the facility is reduced by covering with tol>~oil and seeding.
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:, ';:./:-",~': . ~':>,~,,;;:,~~ ::~' >.~,< :,:~.~~:-.: .:+~:~':~~ :",~~~',}.<;/.:: ""{"":.:': ' ~ :~~:..:~,y'/ ":"~A..~ ':~':':' ':::'.--':':;":.. ,.'~. ;~.:":.'''~<,. ,w: ~::;:::: ~"';:\-~'.~~ ~:",'" '.;:'.;«~,.~'" >~" (::/\'::~
" " ., . . ' . 'Rem~val :~rth~ 'fi~atirig' :prpduM- in. the ir~~dw8.tir' ~1i ~s~jst in expeQitUlg th~;' : :' ,.' '
natura] attenuation of the contaminants and meet compliance with MTCA or MCL. .
requirements at the facility boundary. Removal of the floating product results in
reduction in volume of contaminants.
American Crossarm & Conduit Ret:ordof Decision' " ,
. .
Fencing and deed restrictions will provide a high level of reliability and control in
reducing exposure to potential trespassers. Periodic inspection and repair of the
fence, and cover maintenance will be required to maintain its integrity.
Preference for Treatment as a Principal Element
Preference for treatment as a principle element was met for the principle threat in
the emergency source removal action which involved incineration. The selected
remedy does not meet the' statutory preference f9r treatment as a principal
element for the remaining low-level threat.
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.
INTRODUCTION
.I
This summary responds to comments received during the public comment period
held by the U.S. Environmental protection Agency (EPA) from October 1, 1992,
through October 31, 1992, regarding EPA's Proposed Cleanup Plan for the
American Crossarm & Conduit (ACC) facility in Chehalis, Washington. The
Proposed Plan was developed from information in the Remedial Investigation!
Feasibility Study (RI/FS) report prepared for this site and discussions with
Ecology. The RI/FS report and Proposed Plan are available for'review at the Chehalis-
Timberland Public Library and at EPA's office in Seattle, Washington. Copies of
the Proposed Plan were also sent to local citizens on EPA's mailing list developed
as part. of the community relations effort for this site.
On October 21, 1992, EP A held a public Meeting at the Lewis County PUD
auditorium to present the results of the RI/FS and to discuss EPA's Proposed
Plan. EP A encouraged participants to submit verbal comments during the
meeting and/or submit written comments.
BACKGROUND ON COMMUNITY INVOLVEMENT
. In September of 1989, EP A initiated a community involvement effort to keep the
public informed and address community concerns regarding the Remedial Investiga-
tion at ACC. EPA developed a revised Community Relations Plan for the site
based on interviews 'with citizens and community leaders. The revised
Community Relations Plan built on activities begun during EPA's emergency
response efforts at the site (1986 to 1989). EPA published fact sheets during the
investigation to ~pprise the community of developments.
The following is a summary of activities conducted by EP A to support community
involvement for remedial activities at the ACC Superfund site:
. November 1989-EPA conducted community interviews, which included
meetings with local citizens and business owners, County Commissioners
and the County Assessor's Office, the Lewis County Health District, City of
Chehalis officials, and the Lewis County Economic Development Council
and Chamber of Commerce. In addition, EPA held an open house for other
interested members of the community. The purpose of the interviews was
for EP A to learn about community concerns related to the ACC site.
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American Crossarm & Conduit Record of Decision
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. :Marcb. 1990-EP A published a fact sheet describing site investigation plans.
. April 1990-EP A revised its Community Relations Plan to reflect new
community concerns and to identify public involvement activities and future
site investigation and cleanup activities.
I.
. April 1990-EP A meet with the Lewis County Health Department to
discuss residential yard sampling.
. September 1990-EP A met with Ecology, County Health, and City of
Chehalis officials from the department of public works, city manager's office
and fire department to update them on site investigation developments and
plans.
. September 1990~EP A published fact sheet on the preliminary Phase 1
sampling activities.
. February 1991-EPA published a fact sheet snmmarizing sample results to
date and announcing the second phase of sampling.
. October 1991-EPA presented an update on site activities to the Twin
Cities Chamber of Commerce.
. April 1992-EP A published a fact sheet updating activities and describing
some interim cleanup actions.
. September 1992-EP A published the Remedial Investigation and Feasibility
Study (RIIFS) report and Proposed Plan for cleanup for public comment.
. October 1992-EP A held a 30-day public comment period from October 1st
through 31st. During the comment periodE~ A held a public meeting on
October 21, 1992.
SUMMARY OF PUBLIC COMMENTS AND EPA RESPONSES
Both oral and written comments were received during the public comment period.
. Oral comments consisted of one anonymous telephone m~ssage to EP A in Seattle,
one oral comment from Ecology, and three comments presented during the public
meeting. Three written comments were received. Numerous questions were
raised in the public meeting which were addressed at the meeting and are
documented in the meeting tranScript. Those questions are not addressed in this
responsiveness summary." This .section contains a summary of the comments and
EP A's responses. The comments are organized by subject matter and ~imi1ar
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American Crossarm & Conduit Ret:ord of Decision
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coDiments have been grouped together as appropriate. Copies of the written
r.omments as well as a copy of a transcript of the public meeting are available at
EP A's record center in Seattle and at the Chehalis- Timberland Public Library.
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Public Comments and EPA Responses by Subject Matter
On-site soil consolidation
. Comment: One commenter expressed concern about the proposal for on-site
consolidation of soil removed from the residential yards because the
commenter felt that it would be perceived as a temporary solution.
ResDonse: On-site consolidation of soil removed from the residential yards
is the preferred solution because the soil cannot be recycled, treatment is
not practicable due to site limitations, and off-site disposal in a landfill is
very expensive. The soil will be contained, and institutional controls and long-
. term monitoring will restrict exposure and add to the protectiveness of the
remedial action.
. Comment: Ecology commented in a telephone conversation with EPA, that
the state favors on-site containment of the ash from past incineration of
contaminated material from the removal action. The state said that the ash
is cleaner than other materials on site, there is no additional risk reduction
by disposing of it in an off-site landfill, and on-site containment would have
a substantial cost savings.
ResDonse: EP A concurs with Ecology's recommendation and has
incorporated this recommendation into its final cleanup plan (Record of
Decision). Analytical data sheets illustrating the chemical characteristics of
the ash are available in EPA's Administrative Record file for the ACC site.
Cost
. Comment: Two commenters felt that there are more beneficial uses of the
money EP A proposes to spend to cleanup the ACC site. One of the
commenters further stated that the money should have a.strong, positive
impact on the economy of this local area and the state of Washington for
many years.
ResDonse: EP A is proposing to cleanup the ACC site under its. Superfund
authorities. The Comprehensive Environmental, Response, Compensation,
and Liability Act, as amended (commonly called Superfund) provides EPA
with the authority to use .special "Fund" money to protect hnman health
an~ the environment ~m risks caused or threate~ed by uncontrolled.
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American Crossarm & Conduit Record of Decision
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, ',', ha2ardous substances. EPA is. not authorized to Use this mQney for
activities other than cleanup of hazardous substances. '
Monitoring
..
. Comment: Some commenters asked for clarification on EP A's proposed post
cleanup monitoring described in the Proposed Plan.
Response: The cleanup design will include a plan for post cleanup monitor-
ing to ensure protection of human health and the environment, and the
adequacy of the remedial action over time. Details of the- plan will be
prepared during the remedial design.
Flood Concerns
. Comment: Several commenters wanted to be sure that EP A's cleanup
actions would not result in an incremental increase in the height of flood
water.
Response: The design will account for the estimated volume of clean
material that would be brought to the site and used as cover, and other
changes in site conditions. The design will insure that no (or an acceptable)
increase in the height of floodwater. Available computer programs, which
are used to predict the height of floodwater, will be used during the design
to assure that the flooding conditions are not worsened as a result of the
cleanup.
Scope of and Justification for Cleanup
. Comment: One commenter wanted EP A to include a junkyard property
located at the Northeast comer of the interse(:tion of Chehalis Avenue and
John Street as a part of the residential cleanup area.
Response: EP A does propose to remove surface soil from the junkyard
property that the commenter refers to, which occupies the southern half of
the block on the Northeast comer of Chehalis Avenue and John.
. Comment: Some commenters felt that the health risks were small from
exposure to surface soil in the community and that EP A is being overly
conservative by proposing to remove the residential soil. The commenters
also wondered what control property owners have over soil removal on their
properties. ' " . ' ' .
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.American Crossarm & Conduit Record of Decision
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'Res'ponse: . 'Ef A ~~e~~ ~~~. th~ ~~~osed 'plan is '~~o~e~tive'. The ~~tent" of
the soil removal activities are largely due to EPA's concern for public health
and desire to limit potential exposUre to contaminants in the residential
area. EP A will work with individual homeowners to address specific
concerns about cleanup of their yards.
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Additional Washington Department of Ecology Comments
. Comment: Ecology commented that the proposed plan should be modified to
incorporate: 1) studies of treatment technologies during design of the
cleanup to evaluate whether they are practical and/or would significantly
reduce risk; 2) conformational sampling in the residential yards and play
field; and 3) institutional controls.
Response: EPA has modified its Proposed Plan to reflect Ecology's
comments in the Record of Decision. .
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