United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-93/061
May 1993
ve/EPA Superfund
Record of Decision:
Bonneville Power Administration
Ross Complex (USDOE)
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REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Reclplent'a Acce8alon No.
PAGE EPA/ROD/R10-93/061
4. Tltla and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 05/06/93
Bonneville Power Administration Ross Complex (USDOE) 6.
(Operable Unit 1), WA
First Remedial Action
7. Author(a) 8. Performing Organization Rept. No.
9. Performing Organization Name and Addr- 10 Project TlakIWork Unit No.
11. Contract(C) or Orant(G) No.
(C)
(0)
12. Spon80rlng Organization Nlrne and Addraaa 13. Type 0' Report .. Period CoYerad
U.S. Environmental Protection Agency 800/800
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Note.
PB94-964620
16. Abatract (Umlt: 200 worda)
The 235-acre Bonneville Power Administration Ross Complex (USDOE) (Operable Unit 1) is
an active power distribution center in Vancouver, Clark County, Washington. The site
is bordered by two streams, Cold Creek to the north of the site and Burnt Bridge Creek
to the southwest of the site. The Columbia River is located approximately 2.7 miles
south of the'Bonneville Power Administration (BPA) Ross Complex., Land use in the area
is predominantly residential, light industrial, and recreational. The estimated 18,000
people who reside within a one-mile radius of the BPA Ross Complex use the Pleistocene
alluvial aquifer and the Upper Troutdale Formation to obtain their drinking water,
domestic, and irrigation supplies. No wetlands exist on the site however several
wetlands were observed west of the site along ~urnt Bridge Creek. Since 1939, the site
has been used to distribute hydroelectric power generated from the Columbia River to
regions throughout the Pacific Northwest. Since its construction, the Ross Complex has
provided research and testing facilities, as well as, maintenance, construction,
operations, waste handling, and storage facilities, for the BPA. Maintenance
activities at the Ross Complex' routinely involved the handling of transformer oils
containing PCBs, and organic and inorganic compounds associated with the storage of
(See Attached Page)
17. Document Analyall I. Dascrlptora
Record of Decision - Bonneville Power Administration Ross Complex (USDOE) (Operable
Unit 1), WA
First Remedial Action
Contaminated Medium: soil
Key Contaminants: organics (dioxins, PAHs, PCBs, phenols), metals (arsenic, chromium,
lead)
b. IdentlfieralOpen-Ended Term.
c. COSATI FleldlGroup
16. Availability Statement ..-/ 19. Security Class (ThIs Report) 21. No. 0' Pag..
None 102
20. Security Clus (ThIs Plge) 22. Price
None
50272.101
.
(SM ANSI-Z39.18)
SHlnstructlons on Reverse
OPTIONAL FORM 272 (4-77)
(Formerty NTI5-35)
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EPA/ROD/R10-93/061
Bonneville Power Administration Ross Complex (USDOE)
First Remedial Action
(Operable ~nit 1), WA
Abstract (Continued)
preserved wood poles, paints, solvents, and waste oils. The waste units investigated at
the BPA Ross Complex are primarily the result of past research, storage, and improper
waste handling activities. The site has been divided into OUs 1 and 2 for remediation
purposes. OU1 consists of 19 of the 21 waste units at the BPA, a recreational hiking
trail (the Ellen Davis Trail), and the possible exposure from airborne contamination.
Subsequent evaluation of the 19 waste units indicated that 3 of these units required
remedial action: the Wood Pole Storage Area East, the Ross Substation and Capacitor Yard,
and the Capacitor Testing Lab. In addition, because of exceedances of the State soil
cleanup levels, the State required BPA to conduct removal actions for soil in another
seven waste units. This ROD addresses the threats posed at the three waste units
identified above, as OU1. A future ROD will focus on potential shallow and deep ground
water contamination, surface water and sediment quality in Cold Creek and Burnt Bridge
Creek, and subsurface soil investigation in the two remaining waste units at the BPA, as
OU2. The primary contaminants of concern affecting the soil are organics, including
dioxin, PAHs, PCBs, and phenols; and metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating and treating onsite 3,700
yd3 of soil from the Wood Pole Storage Area East using ex-situ bioremediation; performing
a treatability study to determine treatment cell parameters; using an ethanol/water
solution and. ultraviolet lights to enhance the bioremediation process; conducting
laboratory testing to monitor contaminant levels in the treated soil; backfilling and
implementing one of two soil caps (depending on the static level of contaminants) at the
Wood Pole Storage Area East, if contaminant concentrations do not decrease continuously;
excavating and disposing of 1,196 yd3 of soil from the Ross Substation and Capacitor Yard
and 68 yd3 of soil from the Capacitor Testing Lab area offsite in a TSCA approved
landfill; conducting confirmatory testing in each excavation to ensure that cleanup
standards have b~en met, then back~illing these with clean fill; and providing a
contingency for onsitedisp9sal and capping at Wood Pole Storage Area, if .site
contaminants exceed cleanup levels after treatment. The estimated capital cost for this
remedial action is $950,000. .
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil cleanup standards are based on the State of Washington Model Toxics
Control Act (MTCA) requirements, and include PAHs 1 mg/kg and PCP 8 mg/kg for the wood
Pole Storage Area East; PCBs 1 mg/kg for the Capacitor Testing Lab Area; and PCBs 10 mg/kg
for the Ross Substation and Capacitor Yard. The Wood Pole Storage Area East and the
Capacitor Testing Lab are considered residential areas under MTCA so their cleanup levels
correspond to residential health based levels of 10-6. The Ross Substation and Capacitor
Yard is considered industrial under MTCA so its cleanup level corresponds to industrial
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FINAL
RECORD OF DECISION
FOR
BONNEVILLE POWER ADMINISTRATION
ROSS COMPLEX
OPERABLE UNIT A
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DECLARATION
."
. -
BONNEVILLE POWER ADMINIsrRA TION
ROSS COMPLEX
VANCOUVER, W ASmNGTON
RECORD OF DECISION
SITE NAME AND LOCATION
Bonneville Power Administration, Ross Complex
Vancouver, Washington
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for Operable Unit A, one of two
operable units, of the Bonneville Power Administration (BPA) Ross Complex Superfund site in Vancouver,
Washington. This document was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable, the National Contingency Plan (NCP).
This Record of Decision is based on the administrative record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response actions selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare. or the environment.
DESCIUFI10N OF THE REMEDY'
The selected remedies for Operable Unit A (OUA) address the risk posed by the soil conblmination
at the site by removing and/or treating soil contamination to levels that are protective of human health and
the environment and comply with Applicable or Relevant and Appropriate Requirements (ARARs).
Remedial Action is required at the Wood Pole Storage Area East, the Ross Substation and Capacitor
Yard and the Capacitor Testing Lab.
The major components of the selected remedies under this ROD include:
.
Excavation of contaminated soils at the Ross Substation and the Capacitor Yard and the Capacitor
Testing Lab;
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.
."
.
.
.
Off-site disposal of contaminated soils from the Ross Substation and Capacitor Yard and the Capacitor
Testing Lab at a TSCA approved landfill;
On-site enhanced bioremediation treatment of contaminated soil plus capping and institutional Controls
if necessary at the Wood Pole Storage Area East, and;
Confirmation soil sampling and analysis to ensure that remediation goals have been met.
Removal actions have been completed at a number of waste units throughout OUA to satisfy state
requirements. Additional remedial action under CERCLA is not necessary at the remaining waste units
because contaminant concentrations found in the soil do not pose an unacceptable risk to human health or the
environment consistent with the NCP.
DECLARATION
The selected remedies are protective of human health and the environment, comply with Federal aod
State requirements that are legally applicable or relevant and appropriate requirements to the remedial action
and are cost-effective. These remedies use permanent solutions and alternative treatment technology to. the
maximum extent practicable, and satisfy the statutory preference for remedies that employ treatment that
reduces toxicity, mobility or volume as a principle elemo:nt.
A five year review will not be required at the Capacitor Testing Lab sioce hazardous substances will
not remain on-site above health-based levels. A five year review will be required at the Ross Substation ~d
Capacitor Yard. There is a contingency built ioto the bioremediation remedy for the Wood Pole Storage Area
East whereby hazardous substances that exceed the remedial action objectives may be left on site and capped.
In that case, a five year review will be required.
~ 19'?:s
David Dunahay
Bonneville Power Administration
Ross Complex Managei' .
Date
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Signature sheet for the foregoing Operable Unit A, Bonneville Power Administration, Ross Complex. Record
of Decision between the U.S. Department of Energy, Bonneville Power Administration, Ross Complex and
the U.S. Environmental Protection Agency, with concurrence by the Washington State Department of Ecology.
. .
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~/'lq~
Dana A. Rasmussen
Regional Administrator, Region 10
UoitedStates Environmental Protection Agency
Date
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Signature sbeet for the foregoing Operable Unit A, .Bonneville Power Administration, Ross Complex Record
of Decision between the U.S. Department of Energy, Bonneville Power Administration, Ross Complex and
the U.S. Environmental Protection Agency, with concurrence by the Washington State Department of Ecology.
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r~ ~. J.-1-~bA-
~3
Carol Fleskes. Program Manager
Toxies Clean-up Program
Washington State Department of Ecology
Date
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TABLE OF CONTENTS
.'
Section
Pa~e
. .
1.0 IN'fRODUcrION """""""""""""".""""""""'" 1
2.0 SITE LOCATION AND DESCRIPTION. . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . .. 1
2.1 SITE LOCATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
2.2 CURRENT LAND USE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . .. 3
3.0 SITE HISTORY AND ENFORCEMENT AcrIONS .."".'....""""""" 3
3.1 SITE mSTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . . . . . .. 3
3.2 INITIAL INVESTIGATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3
3.3 ImMEDIAL INVESTIGATIONlFEASmILiTY STUDY (RI/FS) .......... . . . .. 3
3.3.1 Fa!!: Chamber Dump. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
3.3.2 Wood Pole Stora2C Area South. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
3.3.3 DOB-l Drain Une. ..................................... 6
3.3.4 DOB-2 Drainfie1d ................................. . . . .. 6
3.3.5 Top Coat Test Area . . . . . . . . . .,. . . . . . . . . . . . . . . . . . . . . . . . . .. 7
3.3.6 Caoacitor Testin!!: Lab . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
3.3.7 Paint Stol'82e Facilitv .................. . . . . . . . . . . . . . . . . .. 7
3.3.8 Paint Shop (-Plumbin~ Shop-) .'.'...'.'..""."""""'" 8
3.3.9 Sandblastin2 Area ........ - - . . . . . . . . . . . . . - . . . . . . . . . . . . . - 8
3.3.10 Van's Way Oil Storal!:e Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
3.3.11 Wood Pole StOI'8!!:c Area East .............................. 8
3.3.12 Ross Substation and Caoacitor Yard. . . . . . . . . . . . . . . . . . . . . . . . . - 9
3.3.13 U&D Yard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
3.3.14 Hazardous Waste Storal!:e Buildinr ...................... . . . .. 9
3.3.15 Herbicide Storare Area ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.16UntankinrTower...................................... 10
3.3.17 Laboratorv Waste Sto1'32e .....:.......................... 10
3.3.18 PCB St0l'82e Buildinr . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.3.19 Cold Creek Fal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.3.20 Bint OillWater Seoarators . . . . . . . . . . . . . . . . . '. '. . . . . . . . . . . . . . 11
3.3.21 TemDOt'BlY Paint Storare Area . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . 11
3.3.22 Ellen I>avis Trail. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
4.0 COMMUNrrY RELATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
4.1 COMMUNITY RELATIONS DURING THE RI/FS . .. . . . . . . . . . . . . . . . . . . . . 12
4.2 COMMUNITY RELATIONS TO SUPPORT SELECTION OF REMEDY ......... 12
5.0 SCOPE AND ROLE OF RESPONSE AcrION WITIDN SITE srRATEGY ..... - . . .. 13
6.0 SUMMARY OF SITE CllARACl'ERISI1CS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
6.1 PHYSIC.AL SEITING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
6.2 GEOLOGICAL SEITING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
6.3 HYDROGEOLOGIC SE'ITING ................................... 16
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TABLE OF CONTENTS
(CONTINUED)
..
Section
~
"0
6.4 NATURE AND EXTENT OF CONTAMINATION 000......0...00...0'..0. 16
7.0 SUl\BfARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . : . . . . . . . . . . . . . 29
7.1 COMPOUNDS OF CONCERN AND USE OF DATA. . . . . . . . . . . . . . . . . . . . . 34
7.2 HuMAN HEALTH RISK ASSESSMENT o' . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
7.2.1 EXDOsure Assessment. . . . . . . . . . . . . . 0 . . . . . . . . . . . . . . . . . . . . 35
7.2.1.1 Site SettiDg . . . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . 35
7.2.1.2 Potentially Exposed POpulatiODS . . . . . . . . . . . 0 . . . . . . . . . . . 36
7.2.1.3 Idcotification of Exposure Pathways. . . . . . . . . . . . . . . . . . . . 39
7.2.2 Toxicitv Assessment. . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . 39
7.2.2.1 Noo-Carcinogenic Effects. . . . . . . . . . . . . . . . . . . . . . . . . . . 39
7.2.2.2 Carcinogcuic Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
7.2.3 Risk Characteri7.ation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
7.2.3.1 Evaluation of On-Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . 40
7.2.3.2 Evaluation of Off-Site ............................. 44
7.2.4 UncertaintY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . . . . . 44
7.3 ECOLOGICAL RISK ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
7.3.1 Risk Characterization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. 46
8.0 REI\fEDIA TION GOALS ........................................... 49
9.0 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 50
. 9.1 ALTERNATIVE A: NO ACI10N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
9.2 ALTERNATIVE B: INSTlTt1l10NAL CONTROLS. . . . . . . . . . . . . . . . . . . . . . 51
9.3 ALTERNATIVE C: EXCAVATION WITH OFF-SlTE DISPOSAL. . . . . . . . . . . . . 51
9.4 ALTERNATIVE D: ASPHALT CAPPING wrrH INsnnmONAL CONTROLS. . ., 51
9.5 ALTERNATIVE F: KPEG (POTASSIUM POLYETIIYLENE GLYCIL)
D~ORINATION ....................................... 51
9.6 ALTERNATIVE G: SOIL WASHING.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
9.7 ALTERNATIVE H: BES'P EXTRACI10N . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
9.8 ALTERNATIVE I: EX-SITU SOLID PHASE BIOREMEDIATION ............. 52
9.9. ALTERNATIVE J: THERMAL TREATMENT WITH OFF-SITE DISPOSAL. . . . . . . 52
9.10 ALTERNATIVES RETAINED FOR DErAILED EVALUATION. . . . . . . . . . . . . . 52
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . 53
10.1 COMPARATWE ANALYSIS FOR WOOD POLB STORAGB AREA BAST ..... 55
10.1.1.1 Overall Protection of Human Health and the Environment. . . . . . . 55
10.1.1.2 Compliance with ARARs .......................... 55
10.1.2 Primarv Balancin2 Criteria. . .. .......................... 56
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TABLE OF CONTENTS
(CONTINUED)
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Section
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10.1.2.1 Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . 56
10.1.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment. .. 56
10.1.2.3 Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . 56
10.1.2.4 Implemcotability ., .'........""" ...............57
10.1.2.5 Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
- 10.1.3 Modifyiol! Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S8
10.1.3.1 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S8
10.1.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . 58
10.2 ROSS SUBSTATION AND CAPACITOR YARD . . . . . . .. . . . . . . . . . . . . . . . . . S8
10.2.1 Threshold Criteria. . . . . . . . . ',' . . . . . . . . . . . . . . . . . . . . . . . . . . S8
10.2.1.1 Overall Protection of Human Health and the Environment. . . . .. S8
10.2.1.2 Compliance with ARARs .......................... S9
10.2.2 Primarv Balaucinl! Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
10.2.2.1 Long-term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . 60
10.2.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment. . . 60
10.2.2.3 Short-Term Effectiveness. . . . . . . . . . . . . . ; . . . . . . . . . . . 61
10.2.2.4 Implemcntability ............................... 62
10.2.2.5 Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
10.2.3 Modifvin2 Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
10.2.3.1 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
10.2.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . 63
10.3 CAPACITOR TESTING LAB .................................. 63
10.3.1 Threshold Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
10.3.1.1 Overall Protection of Human Health and the Environment. . . . . . 63
10.3.1.2 CompliaDce with AR.ARs .......................... 64
10.3.2 Primarv Balancio2 Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
10.3.2.1 Loog-term EffectivcoeSs . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
10.3.2.2 Reduction of Toxicity, Mobility, or Volume through Treatmcot . .. 6S
10.3.2.3 Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . 6S
10.3.2.4 ImplemcntabUity ............................... 66
10.3.2.5 Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
10.3.3 Modifvinl! Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
10.3.3.1 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
10.3.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . 67
11.0 SELECl'ED REl\fEDY ............................................ 67
11.1 KEY ELEMENTS OF SELECTED REMEDY FOR WOOD POLE STORAGE AREA
EAS1' ................................................. 67
_11--1'-
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TABLE OF CONI'ENTS
(CONI'lNUED)
Section
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11.2 KEY ELEMENTS OF SELECTED REMEDY FOR ROSS SUBSTATION &
CAPACITOR YARD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
11.3 KEY ELEMENTS OF SELECTED REMEDY FOR CAPACITOR TESTING LAB .. 70
11.0 STATUI'ORY DETERMINATION
12.1 PR0TEC110N OF HUMAN HEALTH AND THE ENVIRONMENT. . . . . . . . . . . 71
12.2 COMPUANCE WITFI ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
-.". 12.2.4 Other Criteria. Advisories. or Guidance To-Be-Considered ITBC) . ~ . . . . . 72
12.3 COST EFFECrIVENESS ...................................... 72
12.4 UIUlZATION OF PERMANENT SQLUI10NS AND ALTERNATIVE
TREA TMEN'f TECllNOLOGIES . . . . . . . . . . . .. . . . . . . . . . . . . . . ~ . . . . . 72
12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT ............. 73
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . .. . . . . . . . . . . . . . . . . . 73
_11--1.-
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Tables
Table 1 -
. .
Table 2 -
Table 3 -
Table 4 -
Table S -
Table 6 -
Table 7 -
Fil!Ures
Figure 1 -
Figure 2 -
Figure 3 -
Figure 4 -
Figure S -
. Figure 6 -
Figure 7 -
Figure 8 -
Figure 9 -
Figure 10 -
oIi8c.,.........
LIST OF TABL~ AND FIGURES
Waste Unit Designation
Summary of Laboratory Soils Results
Description and Summary of Human Receptor Groups (Residential and Occupational) .
Potentially Exposed to Operable Unit A Contaminants
Estimated Hazard Quotients and Ufetime Cancer Risk. Hypothetical On-Site Residential and
Occupational Receptors
- Estimated Hazard Quotients and Ufetime Cancer Risk, Off-site Recreational Receptors
Compound-Specific Exposures; Contributions by Pathway
Preferred Alternative Tier, Wood Pole Storage Area East
Site Location Map
Operable Unit A Site Plan
Distribution of Pentachlorophenol (PCP), Wood Pole Storage Area, East
Distribution of Total HPAH, Wood Pole Storage Area, East
Estimated Areas of Contaminated Soils, Wood Pole Storage Area, East
Distribution of Total PCB, Ross Substation and Capacitor Yard
Estimated Areas of Contap1in!ltM Soils, Ross Substation and Capacitor Yard
Distribution of Total PCB, Capacitor Testing Laboratory
Estimated Areas of Contaminated Soils, Capacitor Test Laboratory
Relationship of Screening Criteria
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DECISION SUM:MARY
0-
1.0 INTRODUCI10N
The Decision Summary provides a condensed description of the site-specific factors and analysis that
led to the selection of the remedy for Operable Unit A (OUA) at the Bonneville Power Administration, Ross
Complex Superfund site, beginning with the early identification and characterization of tho problem
(documented in the remedial investigation (RI). proceeding through identification and evaluation of candidate
remedial alternatives (documenting the feasibility study (FS», and concluding with the remedy selected in this
Record of Decision (ROD). The involvCD1ent of the public throughout the process is also described, along
with the enviroomental programs and regulations that relate or direct the overall site remedy. The way in
which the seleCted remedy meets Comprehensive Enviroomental Response, Compensation and Liability Act
(CERCLA) and the State of Washington Modd Toxies Control Act (MTCA) requirements are also
documented.
2.0 SITE LOCATION AND DESCRIPTION
2.1 SITE LOCATION
The BPA Ross Complex (referred to hereafter as the Site) consists of a 23S-acre tract on the eastern
side of U.S. Highway 99 and is bordered to the north by Cold Creek Canyon (Cold Creek). a Burlington
Northern Railroad right-of-way, NE Minnehaha Street, and to the east and south by a residential
neighborhood. Burnt Bridge Creek bordezs the Site to the southwest and west, and Highway 99 and Interstate
5 border the Site to the west (Figure 1). The Site address is 5411 NE Highway 99, Vancouver. Washington
which is located in Clark County.
The Site is located approxili1ately 2.7 miles north of the Columbia River and 1.7 miles east of
Vancouver Lake. Two streams border the Site. with Cold Creek forming the north border of the Site and
Burnt Bridge Creek bordering the southwestcrD side of the Site. Cold Creek. a tributary to Bumt Bridge
Creek, flows into Burnt Bridge Creek just west of the Site. Burnt Bridge Creek flows into Vancouver Lake
(Figure 1). The location of the creeks in rdation to the Site is shown in Figure 2. Vancouver Lake is used
for recreation purposes such as boating. swimming and fishing. The site does not lie within a 100 year flood
plain. .
Census tract information for the Vancouver area indicates moderate-density human habitation south
of the Site, and low density habitation north of the Site. Approximately 18,000 residents live within a one-
mile radius of the Site. This includes residents and businesses with workers occupying the area immediately
to the east of the Site between St. Johns Ave. and St. James. residents between St. Johns Ave. and 19th St.
(southeast of the Site), an area which iocludes several schools and churches; residents inhabiting the area
between ,19th St. and Leverich Park to the southwest of the Site (mcludiog a trailer park adjoining the Site
boundary) and residents inhabiting the area north of the Site between the Cold Creek drainage and Minnehaha
Avenue.
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N
A
B .P.A. Ross
Complex
,0
1
2
.
Scale In Miles
Figure 1. Site Location M~p
)
)
f'
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2.2 'CURRENT LAND USE
..
The Bonneville Power Administration (BPA) owns and operates a power distribution center known
as the Ross Complex in Vancouver, Washington. The facility coordinates and distributes hydroelectric power
generated by the Federal Columbia River Power System throughout the Pacific Northwest region. Since its
construction in 1939, the Ross Complex has provided research and testing facilities; and maintenance,
construction, operations, and waste handling and storage facilities for BPA. Research and testing focuses on
evaluation of the durability of electrical storage and transmission equipment under various climatic and
weather conditioDS. Equipment stored, maintained and repaired includes transformers, bushings and other
electrical transmission and storage equipment.
3.0 SITE IUSfORY AND ENFORCEMENT ACTIONS
3.1 SITE HISTORY
The Site is an active facility that has been owned and opecated by the Booneville Power
Administration (BPA) since 1939 to distribute hydroelectric. power' generated from the Columbia River to
regioDS throughout the Pacific Northwest. Since its construction, the Site has provided resc:arch and testing .
facilities, mamteDance construction operations, and waste storage and handling operations for BPA.
Mainteaancc activities at the Ross Complex have routinely involved handling transformer oils containing
polych1oriDated biphenyls (PCBs), and organic and inorganic compounds associated with the storage of
preserved wood transmission poles, paints, solvents, and waste oils. Testing and laboratory activities include
the use .of heavy metals (such as mercury) and other organic and inorganic compounds.
The waste units investigated in the PAISI and the ~UA RJIFS are primarily the result of past waste
handling Practices at the Ross Complex. Some of these areas are no longer active; others continue to be used
in current operations.
3.2 INmALINVESTIGATlONS
Five investigations were conducted at the Site between 1986 and 1990: a Preliminary Assessment (pA
1986), a Site Investigation (SI 1988), a soil gas survey and ground-water quality assessment (Weston, 1989),
a prelimillJlt)' hydrogeologic investigation (Dames & Moore, 1989), and a Vancouver We1J Field Special
Survey (E&E, 1990). BPA has also conducted DWDerous individual sampling programs in various areas of
the Site. The findings of these investigations are SUII1ID81ized in detail in the -Remedial Investigation Report,
Operable Unit A, BooneviUe Power Administration, Ross Complex. dated May 15, 1992.
3.3 REMEDIAL INVESTIGATlONlFEASmILlTY STUDY (RJIFS)
The Site was listed on the Natiooal Priorities List (NPL) in November 1989 based on the presence
of volatile organic compounds (V0Cs) in ground water and the Site's proximity to the City of Vancouver's
drinking water' supply. As a result of the listing, pursuant to a Federal Facility Agreement (FFA) signed by
BPA, EPA, and the Washington Department of Ecology (Ecology) on May I, 1990, BPA conducted a
Remedial InvestigatioolFeasibility Study (RIIFS) to determine the D8b1re and cxtent of contamination at the
site and to evaluate alternatives for the cleanup of contaminated areas. The RI field investigation began in
the summer of 1991 and included the collection and chemical analysis of soil, surface water, sediment. and
groundwater'samples. A total oftweDty one individual areas of concern or .waste unitsW were identified for
investigation based on historical chemical handling. storage and disposal practices and the results of previous
600:1/--1.-
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investigations. The waste units investigated included:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Fog Chamber Dump Trench Areas I and 2
Wood Pole Storage Area South
. DOB-I Drain line
DOB-2 Drainfie1d
Top Coat Test Area
Capacitor Testing Lab
Paint Storage Facility
Plumbing Shop
Sandblasting Area
Van's Way Oil Storage Area
11. Wood Pole Storage Area East
12. Ross Substation and Capacitor Yard
13. Utilization and Disposal Yard
14. Hazardous Waste Building
15. Herbicide Storage Area
16. Untanking Tower
17. Laboratory Waste Storage Area
18. PCB Storage Area
19. Cold Creek Fall
20. Oil/Water Separators (OWSI through OWS8)
21. Temporary Storage Area
-.
Initially the RI was designed to address the entire Site but during the summer of 1991, BPA, EPA
and Ecology decided that the Site would be divided into two separate operable units (Units A and B) to
facilitate the CERCLA process. Opemble Unit A is the investigation of soils in 19 of the 21 waste units, the
Ellen Davis Trail, and the possible exposure from airbome conmminsation. The 19 waste units evaluated in
Operable Unit A include: Wood Pole Storage Area South, DOB-2 Drainfie1d, DOB-l Drain line, PCB
Storage Area, Capacitor Testing Lab, Hazardous Waste Building, Top Coat Test Area, Untaaking Tower,
Laboratory Waste Storage Area, Van's Way Oil Storage Area, Paint Storage Facility, Wood Pole Storage
Area East, Plumbing Shop, Herbicide Storage Area, Ross Substation and Capacitor Yard, OiVWater
Separators (OWSI through OWSS), Utilization and Disposal Yard, Sandblasting Area, and the Temporary
Storage Area. This ROD addn:sses only OUA. Based on the evaluation of aU these areas, the Wood Pole
Storage Area East, the Ross SUbstation and Capacitor Yard and the Capacitor Testing Lab were selected for
action in the OUA ROD.
Opecable Unit B will focus OD potential shallow and deep groundwater, surface water and sediment
quality of Cold Creek and Burnt Bridge Creek, and subsurface soils investigation in the Fog Chamber Dump
Trench Areas 1 and 2 and Cold Creek Fill.
An investigation of the Ellen Davis Trail (where the trail passes through the Site) was performed to
evaluate potential risks to area residents who use the trail for recreational purposes. Waste unit locations and
the Ellen Davis Trail are shOWD in Figure 2. Waste storage, banclling, and disposal practices associated with
each Wwaste unitW are described below.
4itc:l'--1U""
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. .
-,
LECEND
.
~
EXlsnNC MILL LOCAnONS
Q\. IIIAItR sr,,uAfONS
_u- ROSS cou~r. PROPERlY LIN[
_.. - CREEH
t:::1 WASTt UNit
N
A
o
400
800
1.000.
,
SCALE IN F'EEf
9
~
..
~
:<
~
~
JOB NO. 06737-012-055
FIGURE 2
OPERABLE UNIT A SITE PLAN
BPA ROSS COMPLEX
DAMES & MOORE
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3.3.1 Fo!!: Chamber Dumo
Trench Area 1
Trench Area 1 in the Fog Chamber Dump consisted of an open pit dump located in the prescnt site
of the Fog Chamber Test Facility. The Fog Chamber Dump is the only confirmed area on the Ross Complex
where spent capacitors containing PCB oils' have been disposed along with other assorted incidental solid
wastes such as wood pallets, waste paper, and glass insulators. Reportedly these wastes were set on fire and
allowed to bum. Historical aerial photographs indicate that an open pit approximately 12 feet by 120 feet with
a depth of 20 feet existed between 1956 and 1960.
. .
Trench Area 2
Aerial photographs dated 1942 and July 21, 1951, initially revealed the presence of six subparallel
linear featureS in Trench Area 2 (located southeast ofTreoch Area I) and appeared to represent closed spaced
backfilled excavatiODS or dirt roadways. A 19S5 aerial photograph showed active grading areas and the
presence offill material which was most likely from the Ross Substation and Capacitor Yard and the 345 kV
yard.
3.3.2 Wood Pole Stora2e Area South
The Wood Pole Storage Area South is located east of the Fog Chamber Dump, Trench Area 2. This
area was used to store treated transmission poles before distribution throughout the Pacific Northwest.
Historically, the poles were treated off-site with PCP and/or creosote as antibiotics to increase their longevity
in the environment. The poles were stored on cross poles to keep them off the ground.
3.3.3 DOB-I Drain Une
Operation of the BPA District Chemistry Laboratory in the DOB-l building from approximately 1953
to 1978 resulted in the draiuage of liquid bazardons materials to on-site disposal systems. The exact location
and design of the disposal systems associated with tbis building bave not been confirmed. The laboratory
wastes disposed in this area are presumed to include hazardous chemicals, including mercury compounds,
niaobeozeue, herbicides, pesticides, paiDts, tbiDDeIs, PCP, chromic trioxide, sulfuric acid, lead, arsenic, and
titrating solvents. Laboratory wastes were directed to a disposal system located south of DOB-l prior to the
construction of the Diumer Building in 1970. The disposal system reportedly coDSisted of a dry weU (or
weDs) coDDeCted to the 1aLo<ory by a buried 4-inc:h cast iron pipe which drained the laboratory sink system.
This draiDfield was reportedly separate from the S8Di1ary drainfield that served the DOB-I and DOB-2
building. The area where the dry \W1l was suwosecDY located is preseDtly covered by an asphalt access road
north of the Diumer BuDding. No specific documentation concerning the location of the dry we1I(s) or the
possible draiofield was available. Construction of the new Dittmer Building and grounds in 1970 disrupted
the area south of DOB-I where the laboratory waste disposal area was supposedly located.
3.3.4 DOB-2 Drainfield
The DOB-I and DOB-2 Sani1ary Drainfield (tefemd to hereafter as the DOB-2 Drainfield) was
located between and behind (M:St of) the two DOB buildings. This drainfield may have received liquid
bazardons wastes from the chemical laboratory in DOB-l building. 1be former DOB-I lab was used to test
transformer oils, top coat preservatives fortraDSmission poles, herbicides, clean oil bottles and oily glassware.
Chemicals that were either tested or used in the aaalytical testing laboratory include: inorganic chemicals;
""~lAac
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.'
acids (such as: nitric, hydrochloric, and sulfuric acids); bases (such as: sodium hydroxide); heavy metals
(such as: lead, mercury, silver, zinc, copper and arsenic); organic chemicals (such as: PAHs, PCBs, PCP,
creosote, chloroform, paint thinners, isopropyl alcohol, and acetone); solvents for titrating and TCE, TCA);
and synthetic such as potassium dichromate and chromic trioxide. The exact location of the original chemical
drain system from this laboratory is not known nor is its relationship to the sanitary drainfield that served both
DOB-I and ooB-2. It is possible the sanitary drainfield received the chemical laboratory waste until about
1970 when construction of the Dittmer Building disrupted the drainfield and ended its use.
Effluent from the chemica1laboratory reportedly contained chromic trioxide and sulfuric acid, which
were used to clean oily bottles and glassware over a 2S-year period. Other constituents that may have
contaminated the drainfield, but in smaller quantities, include mercury, lead, arsenic, silver, zinc, and copper.
Typical organics that may have been released to the drainfield include nitrobeuzene, herbicides, paint thinners,
pentachlorophenol (PCP), and toluene.
A large proportion of the DOB-2 Drainfield was reportedly removed during coDStIUcbon of the
Dittmer Building in 1970. The area now is almost eotirely covered by the Dittmer Building and its asphalt
parking lot.
3.3.5 Too Coat Test Area
. .
The Top Coat Test Area was located behind (west of) the DOB-l building and began operation in
J 962. The purpose of this facility was to test wood trausmission poles that bad been treated with PCP
formulations. Storage of drums containing spent transformer oils and other chemical wastes may also have
caused some direct soil contamination in this area. 'lbe test poles were removed in 1969 just before
construction of the Dittmer Building. Grading and other constrUction activities in this area may have caused
mixing and/or removal of the CODtaminsatM surface soil to the Cold Creek Fill Area. The Top Coat Test Area
was capped with an asphalt parlcing lot in 1973. .
3.3.6 Caoacitor Testin2 Lab
The Capacitor Testing Lab is located near the center of the Ross Complex. This facility is consideted
an operating facility but is no longer routinely used for capacitor testing and the use of the laboratory was
discontinued in 1984. In the past, when the building was used to stress test capacitors, fluid containing PCBs
spilled onto tbe concrete floor as well as onto the dirt and gravel beyond the garage door. Ac:cording to a
long-time BPA employee who worked in tbe area, capacitors were ruptured by short duration electrical arcing,
which may have potentially produced heat. Stress testing of capacitors Was conducted in two ovens located
on stands near the east wall of the laboratory. Reportedly the capacitors were stressed to failure within the
ovens and then the remains were removed and stored on the laboratory floor prior to disposal. PCB-
containing oils were reportedly spilled on the floor during the removal of the capacitor remains from the oven
and also leaked onto the floor during temporary storage of capacitolS. 'lbe north waD of the laboratory area
was reportedly removed wheo the building was converted to a storage area (after the laboratory was removed).
The building is currendy used for storage purposes.
3.3.7 Paint Storal!C Facilitv
Paints, paint thinners, fiberglass resin and hardeoer, ethanol, glycerine, white lime, insulating foam,
asbestos, acetone and ot.ber materials have been stored in the southern balf of the Paint Storage building. The
northern half of this building was the Capacitor Testing Lab. Based on aerial photographic evidence a
building was constructed 10 house the Paint Storage Facility and Ule Capacitor Testing Lab between 1952 and
_1"-"1'-
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1956. The Paint Storage Facility occupied the southern two-thirds and the Capacitor Testing Lab occupied
the northern one-third of the building.
3.3.8 Paint Shoo ("Plumbinl! Shoo")
Two underground storage tanks were removed from the Paint Shop ("Plumbing Shop") area near the
southeastern comer of the building in June 1987. Tbe tanks were actually located near the northeast comer
of the Plant Services Building opposite the Paint Shop (Building Z 671). One of the tanks had a capacity of
500 gallc:!$ and was used to store "Socal II" paint solvent. The second tank had a capacity of 1.000 gallons
and was used to store lacquer thinner. Spi11age occum:d when an employee: was filling a 55-gallon drum with
an electric pump from the underground storage tank. The tanks and surrounding soils were eventually
removed and samples collected to assess the success of the remediation. Soils, west of the tanks, that extend
uDder the fouD~tion of the Plant Services Building were not removed for fear of loosing structural support.
The area of the formertaDk nest is currently paved'w:ith asphalt. Solvent reclaiming equipment is
currently located west of the former tank location along the outside building wall.
. 3.3.9 ~~.::-::dblastinl! Area
The Sandblasting Area is located between the plasma torch building and the Capacitor Testing Lab and
was used for approximately 7 years for sandblasting trailers, transformers. cranes. underground storage tanks.
circuit breakers, and other equipment to remove corrosion and paint before repainting. 1bis area is DO longei'
used for sandblasting. Some of the equipment origiDally may have been coated with lead paint. The
sandblasting waste. which consists of relatively clean medium- to coarse-grained sand, formed an
approximately 4-inch thick layer OD the ground in the beavily used area. The waste reportedly bas been
spread beyond the area where sandblasting was performed by truck traffic and wind dispcrsa1. Sandblasting
of small to medium sized equipment (eye beams, pipes, etc.) is performed inside the southern portiOD of the
plumbing shop. Garnet sand, which is used inside the building. has collected on the shop floor and is visible
on the road outside the building door, behiDd the building, and in and arouDd a hopper beneath an air filter
apparatus outside the building.
3.3.10 Van's Wav Oil Storae Area
The Van's Way Oil Storage Area was an aboVe-groUDd tank storage facility. This facility contained
tanks used for.storage of iDsuJatiDg and other oils before distributing them to areas within the BPA system.
Oils stored in the tanks coataiDed less than SO ppm PCBs. When in operation, 41 storage tanks were present
with a combined capacity of 185,250 gallons. Some iDcidental spillage was evident Dear the tank drain spouts.
Solvents are believed to have been used in the past to dean equipment in the area. Surface nmoff from this
site is directed through oillwater separators before release into Cold Creek.
3.3.11 Wood Pole Storae Area East
The Wood POle Storage Area East is located OD the eastern edge of the Ross Complex. This area is
used to store treated transmission poles before distributing them to points throughout the Pacific Northwest.
Waste storage, handling, and disposal practices for this area are the same as for the Wood Pole Storage Area
South. .
_11-..11""
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3.3.12 Ross Substation and Caoacitor Yard
. .
The Ross Substation is located in the central portion of the facility. to the east of Area B. Tbe
substation is built on a flat-topped hill which slopes very steeply approximately 20 to 30 feet to the south, west
and north. The ground surface is covered in gravel to varyingllepths throughout the substation. Most of the
oils in transformers currently in the substation are reported to contain less than 500 ppm PCBs. Equipment
that contains oil including transformers and circuit breakers is located within the approximately IO-acre fenced
area.
The Capacitor Yard is located in the southwestern comer of the substation. There are 6,002 .
. capacitors in the Capacitor Yard. Many of the capacitors contain oils with PCB concentrations ranging from
approximately 5,000 to 6,000 ppm PCBs. 00 average, the capacitors have a capacity of about 2 to 3 gallons.
Spills of PCB oils from faulty capacitors and leakiag equipment have occasionally occuned within the
substation.
Faulty- capacitors and oiMilled equipment have released PCB-containing oils into the underlying
graveled surface. Surface runoff is channeled through oillwater separators before exiting the Complex. BPA
records indicate that small spillS of PCB oils occurred in the Capacitor Yard in August, 1989. Chlorinated
solvents were used exteusively within the Capacitor Yard and to a lesser degree throughout the substation area
to clean up oil spills, particularly in areas around circuit breaker pads and power pads.
Underground pipes, which are now abandoned, were used to transfer oil from six existing sto~e
tanks near the Oil House to cireuit breakers. An underground storage tank was removed near the Oil House
in June 1987 and fouod to have leaked diesel fuel. When the underground pipes were abandoned, the lines
were capped and the above ground fixtures were rcmovt:d, although the pipes are still underground.
3.3.13 U&.D Yard
The Utilization and Disposal Yard (U&D Yard) is used for the temporary storage of materials before
their fiDaI disposition. Temporary storage of capacitors started in 1962 in an area 40 by 60 feet in the
southeast comer of the U&.D Yard. Oils which potentially may have contained low concentrations of PCBs
were reportedly sprayed on the ground surface for dust control throughout the yard. In the mid-1970s, the
entire yard was paved with asphalt after 3,500 cubic yards of soil potentially contaminated with PCBs and oils
(equivalent to 6 inches over the eatire yard) bad been removed and disposed of at the Cold Creek Fill Mea.
. Soil samples coUected in 1984 along the feaced perimeter of this yard indicated only limited migration (at
trace levels) of PCBs from the former capacitor storage area. BPA records describe an oil spill that occum:d
in August, 1987 in the U&.D Yard. The spill was cleaned up with an organic solvent. .
3.3.14 RA'nIt"CIous Waste StoRR Buildin2
The Hazardous Waste Storage Building is currently used for the storage of solid and liquid hazardous
wastes before shipment, including, but not limited. to degn:asing solvents, PCP, and inorganic acids. The
maximum inventory of the building is 224 55-gaUon dlUms, or 12,320 gallons of waste contained in drums.
Waste drums are stored on woodeD pallets and may be stacked two high. . Four or less drums arc secured to
each pallet. The Hazardous Waste Storage Building is beaned and measures 38 feet 5 inches by 31 feet 9
inches inside of the curbing. Pavement near the loading areas has been treated with an impermeable emulsifier.
No significant spiUs or leaks from these areas are known to have occuned.
""I~I'"
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3.3. 15 Herbicide Stora2e Area
Herbicides and PCP-<=ODtamin!ltM spill cleanup debris are currently stored in the flammable materials
storage building (Z-814) (Figure 2). This building has three sloped storage bays that are connected to a 2,000-
gallon underground tank used for spill control. Information obtained from BPA files indicate that a variety
of herbicides were stored and/or applied at the Site.
3.3.16 Untankin2 Tower
The Untanlcing Tower is located betw'Cen the north and south Ampere buildings and is used for the
maintenance of large electrical equipment including transformers. Solvents have reportedly been used
extcosivelyj)t the building for cleaning oils and grease from equipment. Six above ground tanks are located
directly to thO.east of the building. .
. ...."
;~r::-
3.3.17 LabOAto~ Waste Stora2e
.'.ene
waStes generated at the Dew chemical laboratory located in the South AmpeI'C building are stored in
a shed designed for flAmmable materials. The storage shed is located in the parking lot Deat the east side of
the building. Waste materials iDc1ude speat-oil samples, transformer oil, PCB samples, spcut-chlorinated
solvents (TCA), waste iso-octaDe, and anon-pyridine reagent. Prior to 1986 drums were used to store the
laboratory wastes. The use of dnIms for laboratory waste storage was discontinued and use of the stonge
shed began in approximately 1986 due to a reduction in volume of waste generated by the laboratory. This
area was paved around 1986 prior to the use of the storage shed for laboratory waste storage.
A second, smaller shed for flammable materials storage is also located OD the east side of the Ampere
Building. The smaller storage shed belongs to the Instrument SerVices group. This shed was reported to have
been used to store a variety of chemicals including ether, gasoline, 1,1, I-trichloroethane, ethylene
glycol,ultrasonic cleaning solvents, containers of gasoline, motor oil, trich1oroelhane, Scotch Grip Solvent No.
2, Shell Donax Oil T-S, KS 7470 Oil, and alcohol (ISOpropyl).
3.3.18 PCB StOr'82C Buildinl!
The PCB Storage Building has been in operation since 1972 and houses transfOrD1e1'S and capacitors
containing PCBs, as weU as large tanks. used to contain oils with over SO ppm PCBs. Some PCB
transformel'S, capacitors, and other electrical equipment may have been stated outside of the PCB Storage
Building. The PCB Storage Building is intemaI1y curbed and the cement floor was originally sealed with an
impermeable coating. The coatiDg was reapplied in September, .1990. This area has also been used as a
loading and unloading area for hazardous wastes. The major portion of the area to the east has beea recently
paved; the area south of the building is also paved. Oil-stained gravels have been observed in an area directly
behiDd the building where bushings are currently stored. Solvents were reportedly dumped down a storm
drain in front of the storage building in the past.
Chlorinated solvents were used heavily in the repair shop located to the wesi of the storage building
(Building Z-m) and may have been disposed of in a storm sewer leading from the west side of the building
to Cold Creek.
_11--''''''
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3.3.19 Cold Creek Fill
. .
The Cold Creek Fill Area is a former landfill in Cold Creek Valley 8l0ng the northern boundary of
the Ross Complex. Cold Creek runs through a culvert covered by fill to a depth of 30 to 80 feet. In the past,
fill materials came primarily from construction activities on the Complex. In later years, use of the fill area
was limited to excess soils that had been teSted for PCBs. These excess soils included excavated soils from
the Dittmer Building construction (mcluding DOB-I and DOB-2 Sanitary Drainfield). A second source of
potentially contaminated fill came from graded material associated with paving of the Utilization and Disposal
Yard. Approximately 3,500 cubic yards of soil potentially contaminated with oils and PCBs were excavated
and diSposed as fill at this area. Evidence of spent sandblasting materials potentially containing heavy metals
has also been found. .
Another potential source of fill may have been from the grading of the Top Coat Test Area. The Top
Coat Test Area was partially excavated and removed to accommodate the new Dittm~ Building in 1969-1970.
The excavated materials were reportedly dumped in the Cold Creek Fill Area. The excavated soils may have
been contami.,pted with PCP formulations and metals used to test wood poles at the Top Coat Test Area.
3.3.20 Eieht Oil/Water Seoarators
Eight oiVwater separators, designated OWS-I through OWS-8, are located throughout the Site. Storm
water runoff from the site is collected in the oiVwater separators where oily substances are retained before
discharge of the water to Cold Creek, Burnt Bridge Creek, or to open ditches. The oiVwatcr separator tank
bottoms are located 14 to 20 feet below ground surface.
The outflow from Oi1IWater Separator '1 empties to an unlined ditch north of the Fog Chamber
Dump that drains to the west. Water from the unlined ditch is absorbed into underlying soils by percolation.
The outflow of Oil/Water' Separator #2 flows to the southwest through a culvert to Bumt Bridge Creek.
Oil/Water Separators #3, IS, #7, and #8 discharge water to Cold Creek through culverts. Design drawings
for Oi1IWater Separator '6 are unavailable, and the outflow is not clearly defined.
Oil/Water Separator #4 was specially designed in 1988 to contain oil from a potential major spill or
leak associated with the above-ground tank farm at the Vans Way Oil Storage Area. Fluids are stored and
recycled through two holding tanks, and then discharged to Qil!Water Separator #3 where they are processed
a second time before draiDing to Cold Creek.
3.3.21 Temporary Paint Stora2C Area
The Temporary Paint Storage Building, also known as the Paint Shop Annex, was formerly located
immediately east of the South Ampere Building. Aerial photographs indicate it was constructed in the early
1940's and tom down around 1977. The Temporary Storage Building was used to prepare materials for
painting and solvents, paint thinners and caustic solutions were stored in and around the building. Some
materials were dipped in the caustic solution prior to painting. The use of caustic solutions were reportedly
discontinued and replaced by sandblasting which was conducted in an open faced stnlcture attached to the
north end of the Temporary Paint Storage Building.
3.3.22 Ellen Davis Trail
The EIleo Davis Trail is an indepcndeot area of investigation near on site waste units. The Ellen
Davis Trail extends approximately 1.75 miles from St. James Avenue east of the Site to Leverich Park south
_1I--1.dDc
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of the Site. The majority of the trail was constt11cted in the late 1980's, although some portions of the trail
are stiU being constnlcted. The trail follows the southern Site boundary and cuts across BPA property south
of the Ross Substation. Use of the trail is open to the public.
..
4.0 COMMUNl'lY RELATIONS
'.
Following the completion of the site investigation in July 1988, three fact sheets were mailed to the
public in April and May 1990 which described the listing of the site on the National Priorities List (NPL) and
the CERCLA process and associated schedule that BP A would undertake.
On May 1, 1991, a community relations plan (CRP) was prepared by BPA's Community Relations
Group in accordance with CERCLA, as amended by SARA. The CRP included establishing information
repositories ana communication pathways to di~_inAte information. Information repositories are located
at both the Ross Complex and in the Vancouver Regional Library, 1007 East Mill Plane Boulevard,
Vancouver, Washington 98663.
4.1 COMMUNITY RELATIONS DURING THE RIIFS
AI! administrative record was established to provide the basis for selection of the remedial action in
accordance with section 113 of CERCLA. The Administrative record is available for public review at the Ross
Complcx or the VancouvCl' Regional Library. During the RIlFS, BPA issued a press release and five
additional fact sheets. The chronology of the community relations is listed. below.
8
May 22, 1990 A scoping meeting was held to provide information to the public and hear concerns
about environmental conditions at the site.
8
July 1990
March 1991
Fact sheet No.4 described the results of the May scoping meeting.
8
Fact sheet No. S described chronology of events and the work plan for the RI/FS.
.8
May 1991
August 1991
Fact sheet No.6 described the RI and FS programs and current site work.
8
Fact sbeet No.7 described status of the RI field work.
8
May 1992
Fact sheet No.8 defiaed Opemble Units A and B, discussed OUA RI and risk
assessment findings, and activities planned for the summer of 1992.
4.2 COMMUNITY RELATIONS TO SUPPORT SELECTION OF REMEDY
The pubUc was giVeD the opportunity to participate in the remedy selection process in accordance with
sections 117 and 113(1c)(2)(B) of CERCLA. The proposed plan for Opemble Unit A. which summarized the
altematives evaluated and presented the preferred alternative, was mailed to approximately 800 interested
parties on August 14, 1992. BPA provided pubUc notice through a display ad in the Columbian and.
Oregonian on August 24, 1992 to cxpiain the proposed plan, list the public .;otDIDent period, and announce
the public meeting. Press coverage was also provided in the local news media which resulted in a DCWS article
of August 20. 1992. .
60:11""'1.-
-------
. A 30-day public comment period was held from August 14 to September 14. 1992. Approximately
20 people attended a public meeting, which was held on September 2,1992 at the Ross Complex, DOB
Auditorium. Thirty-nine verbal comments received at the public meeting and four written comments are
included in the attached Responsiveness Summary.
. .
Copies of the ROD and the Responsiveness Summary will be placed in the administrative record and
in the information repositories.
5.0 SCOPE AND ROLE OF RESPONSE ACI10N WITIDN SITE STRATEGY
The OUA RI evaluated the nature and extent of contamination in soil in 21 waste units and the Ellen
Davis Trail. Results from the Base1ioe Risk Assessment indicate that a CERCLA rem~ial action is necessary
for contaminated soil located in three areas of concern, Wood Pole Storage Area East, the Ross Substation
and Capacitor ¥ ard, and the Capacitor Testing Lab. Table 1 summarizes the Operable Unit A waste unit
regulatory categorization. RI results indicate that high molecular weight polycyclic aromatic hydrocarbon
(HPAHs) contamination in the Wood Pole Storage Area East and polychlorinated biphenyl (PCB)
contamination in the Capacitor Testing Lab and the RosS Substation and Capacitor Yard exceed health-based
levels and will.require remediation as outlined in this ROD. The final remedial actions selected in this ROD
address the removal and destruction of contaminants. Additional sampling and analysis will be conducted to
determine if the contaminants were removed.
The fioal selected remedies include: (1) excavation and off-site disposal of PCB contaminated soil
in the Capacitor Testing Lab and Ross Substation and Capdcitor Yard; (2) enhanced bioremediation ofHPAH
and pentachlorophenol contaminated soil in the Wood Pole Storage Area East; (3) monitoring during
biorcmediation to evaluate if contaminants have been removed and/or arc degrading overtime; and (4) soil
sampling and analysis to ensure that remediation goals have been met.
The results of the RI indicated that metals, HPAHs, PCBs, and/or volatile organic compounds were
pl'CSCDt in seven individual waste units and that they exceeded soil cleanup levels promulgated under MTCA.
These compounds were not laterally or vertically extcDsive but were present only in individual spot locations.
EPA determined that the contaminants found did not present an unacceptable risk to human health and the
environment in accordance with CERCLA. However, EcOlogy determined these exceedences were actionable
under MTCA. BP A undertook removal actions in the areas 1isted in Table 1. There was no need for action
in ten of the waste units.
Operable Unit B will focus on potential shallow and deep groundwater ,surface water and sediment
quality of Cold Creek and Burnt Bridge Creek, and subsurface soils investigation in the Fog Chamber Dump
Trench Areas I and 2 and the Cold Creek Fill. The RIlFS for Operable Unit B will be completed in the
spring of 1993. The Proposed Plan for Operable Unit B is scheduled for release in June 1993 and the draft
Record of Decision is scheduled for August 1993.
_1/-..dl.4oc
-------
Table 1
Waste Unit Designation
Operable Unit A
BPA Ross Complex RI
No Fwther Action Required Under SoD Contamination Addressed by Further Action Required Under
CERCLA Removal Action CERCLA
D08-1. D08-2 Drainfields Sandblasmg Area Ross SUbstation/Capacitor Yard
Top Coat Test Area Lab Waste Storage Wood Pole Storage Area East
Van's Way OJ Storage Alea Wood Pole Storage /vea South. Capacitor Testing Laboratory
UtiDzation & Disposal Yard. Hazardous Waste Storage Bulding
Herbicide Storage Alea PaInt Shop
Paint Storage FacIity \k\tanking Tower
Temporay PaW Storage D08-1 Dranlne
PCB Storage BUlc:tng
Wood Pole Storage /vea South
DOB-1Drcmine
Sandblasting Area
Laboratory Waste Storage Area
Haze,deus Waste Storage BUlc:tng
Paint Shop
tkltanlcing Tower
Elen Davis Trcit
Oil Water Separators (8)
. .
JCIb No. 0673741ND5
(WAsnUDJCLS I 4/'l2I93 f 81)
-------
6.0 SUMMARY OF SI'[E CHARACfERISTICS
6.1 PHYSICAL SEITING
. .
The Site is located on an ancient alluvial terrace. Creeks and streams in the area have been cutting
into the terrace deposits, creating incised channels. Elevations across the Site range from greater than 250
feet above mean sea level to approximately 40 feet above mean sea level. The surface gradient generally
slopes to the west across the Site, with localized steep slopes toward Cold Creek to the north and Burnt Bridge
Creek to the southwest (Figure 1). Two streams border the Site, with Cold Creek forming the north border
of the Site and Burnt Bridge Creek bordering the southwestern side of the Site. Cold Creek, a tributary to
Burnt Bridge Creek, flows into Burnt Bridge Crce1c just west of the Site. Burnt Bridge Creek flows into
Vancouver Lake (Figure 1). The location of the crce1cs in relation to the Site is shown in Figure 2. Site
stormwater' nmoff is directed through oil/water separators and then drains to either Cold Creek or Burnt
Bridge Creek.
No wetlands were found at the Site. Several wct1aDds were observed west of the Site along Burnt
Bridge Creek near Vancouver Lake. These include a palustrine-cmcrgent wetland and a palustrine open-water
wetland that are hydrologically coDDCCted to Burnt Bridge Creek. There were no threatened or endangered
species observed at the Site or adjaCent to the site.
A site survey to determine the presence of historic structures or features. was performed in 1987.
Four sites were found to be eligible for historic nomination; the Control JIouse, Oil House, Switching Yard
and the landscaping around the Control House and Oil House. None of the sites have been nominated and
no site has been listed in national, state, or local preservation registers.
6.2 GEOLOGICAL SETTING
The Site is located on terraces that range in elevation from 40 feet to more than 250 feet above mean
sea level (msl). The western two-thirds of the Site occupies an east-west trending ridgeUne. The ridgeline
slopes to the west with a modemtely steep fIauk slope to the north towards Cold Creek. It also has a
moderately steep slope to the southwest towards Burnt Bridge Creek. The eastem third of the Site occupies
a valley averaging about 240 feet above msl with gendy sloped sides. This valley drains to the west into Cold
Creek.
Geologically, the Site rests on Pleistoceoe alluvial cicposits in the Fourth Plains area of Clark County
(Walsh et al, 1987). The Pleistoceae cicposits consist of 110 to grcatcc than 177 "feet of unconsolidated
Pleistoceae-aged sands, silts, and clays underlain by modcrate1y consolidated Upper Troutdale Formation silty,
sandy, or clayey gravels. The Upper Troutdale Formation underlies the Pleistocene deposits. The Upper
Troutdale Formation is characterized by gravelly deposits as opposed to finer grained deposits of the
Pleistocene-aged materials. The contact between the Troutdale and the younger Pleistocene sediments appears
to be an erosional unconformity. Tbe unconformity is expressed by a change in elevation of the contact across
the Site. The subcrop or surface of the Troutdale Formation is encountered in borings ranging from 14 to
110 feet msl or 110 to 164 feet below ground surface (bgs). The Upper Troutdale Formation consists of
unconsolidated to moderately consolidated silty, sandy, and clayey gravels. The Upper Troutdale Formation
materials appear to be well drained except for the clayey gravel units.
The Site is manded by Lauren-Sifton-Wind River soils resting on nearly level to gendy rolling terraces
typical of southwestern Clark County. The soils arc gravelly and medium to coarse-grained, have a large
available water capacity, and are excessively drained. The soil in the southwestern portion of the Site consists
4ioc 1''''''"'''1.-
-------
of Wind River sandy loam, which extends over approximately 30 percent of the Site. This soil is excessively
drained and exhibits moderately high permeability. In active areas on site, the upper soils are compacted and
are less permeable than the loose undisturbed soils.
6.3 HYDROGEOLOGIC SEITING
Two important aquifers exist in the Portland-Vancouver area, the Pleistocene alluvial deposits and the
Upper Troutdale Formation. The Pleistocene alluvial deposits are used for domestic and some irrigation
supplies. The pleistocene deposits yield up to 1,000 gallons per minute (gpm) or more from the coarser sand
and gravel units; where deposits are thin and less permeable, perched or semi-perched ground-water zones
may occur. Regionally, many domestic and inigation water supply wdls were completed in the Pleistocene
alluvial deposits in the area between Burnt Bridge Creek and Salmon Creek (north of Burnt Bridge Creek).
The Site is within the Burnt Bridge Creek/Salmon Creek Area. A perched water table is located in the eastern
and central portions of the Site, underlain by fine-grained sediments and appear on a local basis ranging
between 10 and 70 feet below ground surface (bgs). The groundwater flow direction in the percl1ed water
table in the eastccD portion of the Site is northwest toward Cold Creek. Ecological receptors are present in
Cold Creek; however, the cree1c is culvertcd through the majority of the Site and therefore, access to the
Creek by ecological receptors is limited.
The Upper Troutdale Formation is used for municipal and most irrigation supplies. Wells completed
in the Upper Troutdale Formation sand and gravel yield as much as 1,000 gpm (Mundorff, 1964). A deep
aquifer has also been identified at or near the top of the Upper Troutdale Formation, that underlies the Site
ranging between 80 and 180 feet bgs. Groundwater flow in the deep aquifer is toward the southwest.
Potential receptors are located hydraulically downgradient of the Site, although the nearest municipal well is
approximately one mile away.
6.4 NATURE AND EXTENT OF CONTAMINATION
The Operable Unit A Remedial Investigation included characterization of soils in 19 individual waste
units and from the Ellen Davis Trail. The soil samples were analyzed for volatile organic compounds (VOCS);
base neutral acid compounds (BNAs); high molecular weight polynuclear aromatic hydrocarbons (HPAHs);
metals; polychlorinated biphenyls (PCB); carbamate, urea, and triazine pesticides; and chlorinated herbicides.
Select soil samples collected from the Capacitor Testing Lab waste unit were analyzed for polychlorinated
dioxin and furans (PCDDIPCDF). Table 2 summarizes the concentration ranges of organic contaminants .
detected in each waste unit, and the waste uait concentration ranges of antimony, arsenic, chromium, copper,
lead, and zinc detected in surface and subsurface soils. Additi9naI metals were deteeted, but their preseoce
did Dot exCeed risk-based criteria or background concentrations.
_1'--1''-
-------
Table 2
Summary of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
1'«). not det..cted
Depth I AnoIVte I Concentration I flequency of
Range Detection
Pf1Int Storage FacltIIy
surface arsenic 2.7 1/1
benzo(a)anttvacene 0.057 1/1
benzo(a)pyrena 0.054 1/1
beIUO(b)lU:xanthene 0.09 1/1
benZo(g.hJ)peIy\ene 0.096 1/1
benzoOOftuoranlhene 0.056 1/1
c:tvorrUn 22.6 1/1
c/vysene 0.071 1/1
copper 22.8 1/1
dibenZO(a.h)anltvac:ena 0.019 1/1
fIuorc:.t1hene 0.1 1/1
Indeno( l.2.3-<:d)pyrene o.os 1/1
lead 15.9 1/1
pyrena 0.11 1/1
zinc 89.5 1/1
subsurface cneric 3.6 1/1
c:I'Iron'Un 25.2 1/1
copper 25.5 1/1
lead 7.7 1/1
zinc 72.6 111
PCIb Slomge BUIdng
surface Aroclor 1254 NO - 0.086 4/8
arseric NO-5 7/8
benzO(a)an1hracen9 NO - 12 2/8
benzO(a)pyrena NO-11 2/8
beIUO(b)tkJoronthene NO-17 4/8
bls(;MthyhIItyOphthalate NO - 0.18 1/6
~thoIate NO - 0A3 5/8
COIbazcIe NO-7.8 218
ctvcmiun 6.9 - Z2 8/8
c/vysene NO - 13 3/8
copper 15.3 - 48.7 8/8
di-n-octyIphlhalate N) - D.036 6/8
dibenZOfuan 1'«)-2 2/8
IIuoranIhene 111).31 2/8
lead 6.9-27.1 8/8
pentac;hJorcphenoI III) -1.5 2/8
phenanttvene NO-27 2/8
~ N>.27 2/8
zinc 44.3 - 96.2 8/8
subsurface aseric 1.5 - 3.9 6/6
benzo(a)anttvacena NO - 0.D22 2/6
benzo(a)pyrene NO - 0.021 1/6
benzo(b)1U:xan1hene NO - 0.026 2+ 16
benzo(g.hJ)pelylene N)-0.017 2+/6
benzo(1c)IIuorathene .N> - 0.018 2+/6
bulylbenzylphthalate N> -0.041 1/6
c:hIa1Un 12.6 . 22.4 6/6
~ NO - OJJ2a1 2+/6
copper 18.2 - 26.1 6/6
dbInZO(a.h)anttvacene N> - 0JI04 1/6
ftucranthene N> -0.075 2+/6
t'ucrene N> - 0.D92 216
n:B1o(1.2.kd)pyrene NO -0.018 216
lead 2.6-8.7 6/6
phenonttvene NO -0.067 1/6
pyrena N> - D.053 216
zinc a16.5 . 66.9 6/6
Depth I Anatvte I Concentration I flequency of
Range Detection
OttIlIe AIeG 8GCIcgrocnd
surface arsenic 1.2 - 6.2 4/6
ctvomum 8 - 93.6 5/12
copper 13.3 - 52.1 1/4
lead 5.7 - 378 2/14
zinc 36.7 -387 4/12
aaurface asenIc: 1.2 - 1.9 4/7
c:tvonUn 7.6-12.7 5/12
copper 15.6-2D.8 12/79
lead 3.5 - 5.8 1/26
zinc - 41.9-55.3 3/43
OtIIIte NaIIId 8tJdct/fOCltd
IUface 0ISenIc Q.83 - 2.2 1/46
c:hrcIrrUn 12.7 - 54 14/19
copper 10.4 -55.7 2/f/J
lead 6.4 - 25.1 5/14
zinc: 60.1 - 1420 2/30
OI/WtDr $epCftltOtJ .
subsurface 1.1.1-lric:NcI'oethane ND-0.14 4/39
1.1~oelhalle I'«) - 0.036 2/39
1.1~thene I'«) - 0.Q04 2/39
2A-d I'«) - 0.013 1/39
4~2-pentanone I'«) - 0.11 8/39
AracIor 1248 N) - OJR7 1/39
Aloc:lat 1254 N) .0.27 6/39
AracIor 1~ NO - D.088 3/39
acetone N)-0.11 2/39
ametrvn NO - D.29 1/39
asenic 0.87 - 7.9 39/39
atrazIne N) - D.35 1/39
benZo(a)ardh.1X8l1e NO - 0.01 8/39
.benZo(~ N) - 0.027 8/39
benZo(b)lluaranthene NO - D.035 10 1 39
benZD(g.hJ)perytel1e I'«) - Q.034 7/39
benZo(1c)I'uxanthene N) - D.047 6/39
~ N) - 0.07 1/39
chranUn 9.2-218 39/39
etvysroe NO - 0.014 5/39
copper 14.5 - 7Z2O 39/39
~1haIate NO - 2.2 a1/Y1
dibenZO(a.h)anlhoac:ene NO - 0.Q06 3/39
dicc:In'tIa NO .0.2 1/39
dielhylphlhalate NO-4 4/39
dinos8b N) - 0.0072 1/39
fk.u. 0. dtIene NO - 0.029 13/39
1ndBno(1.2.3<:d)pynJne NO - 0.022 8/39
lead 2-7OQO 39/39
methvl8ne chIorId9 N> - D.69 3/39
pentacNorophenol NO - 0.072 1/39
prometon NO - 0.26 2/39
pyrena NO - 0.024 11/39
~ N>-0.13 4/39
total xyIenes III) - 0.007 1139
ZInc:: 41.2 - 2580 39/39
JQb No. 06737~12-CD1
(OUAAODJCI.S I Ql.6//13 I 81)
-------
Table 2
Summary of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
Depth I Analyte I Concentration I freQUenCY ot
Range Detection
Ct/pGeIttN Testfng Lt:boftI/ory
surface Aroclor 1248 N)-42 2/5
Aroclor 1254 N) -0.D66 1/5
Arecler 1260 ND-0.93 4/5
arsenic: 1.3-3.8 5/5
benzo - 0.048 4/5
1ndeno(1.2.3-cd)pyrene N) - 0.054 4/5
lead 12.6 - 43.8 5/5
pyrene o.cm - 0.G44 5/5
zinc 74.8 - 711 5/5
2378-TCOD N)-l.6ppt 2/3
123478+btCOD NO-2.4J ppt 1/3
123678+11tCOO N)-.c.9Jppt 2/3
123~ N) - 4.5 ppt 2/3
1234678-HpCDO 3.5-61.7 ppt 3/3
OCDO N) -0 ppt 2/3
2378-TCOF 0A3 - 118 ppt 3/3
2378-PeCOF N)-16ppt ' 3
23478-PeCOF 0.29 -31.8 ppt 3
123478-HxCOF N) - 8.3 ppt _,3
123678-HxCOF N) - 2.8 ppt 1/3
234678-HxCOF N)-4.5Jppt 2/3
123789-HIICDF N)-1.9ppt 2/3
1234678+!pCOF N)-19ppt 2/3
1234~ N) - 24.9 ppt 1/3
OCOF
Total TCDD 0.3-2.1 ppt 3/3
Total PeCDD 0.49-23.1 Jppt 3/3
Total HaCOO 1.8 - 22A J ppt 3/3
Total HpCDO 7.9-98.4Ppt 3/3
Total TCDF 0.96 - 6) ppt 3/3
Total PeCDF 0.29 - 2D3 ppt 3/3
Total HIICCF 2 - 66.8 ppt 3/3
To1aIfpCOF 0.3 - 59.6 J ppt 3/3
aaeric 1.9-5.1 6/6
c:tvornurn 13.9-24.1 6/6
ccpper 19.3 - 29.6 6/6
lead 4.3-8 6/6
methylene chloride 0.12-QA9 2/6
PYf8I18 N) - o.oD3 216
zinc 59.7 - 71.7 6/6
NO - not del8ctec:t
Jab No. 06737.012.(106
-------
Table 2
Summary of laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
Depth I Anotvte I Concentration I freQUenCY ot
Range Detection
008-2 SGrIIcq Dralnfleld
subsurlac:e 4-methy\-21)E11'1tanane ND - 0.007 3/13
asenIc: f'()-1.9 11 /13
benzoCa)anttvacene N> - 0.037 1/13
benzo(a)pyrene ND - 0.026 1/13
benzo(b)ftuaranthene NO - Q.027 2/13
benzo(g.hJ)perylene N> - 0.018 1/13
benzIa(1c)ftuaIlhene N>-Q.021 1/13
bls(2-e~h1halate N> - Q.38 1/13
c:hran"Un 4.5 - 18.8 13/13
ctvysene N>-Q.021 1/13
copper 13.3-26.6 13/13
dibenzo(a.h>anttvocene N> - Q.OO6 1/13
tk.oIQI othellO N> - 0.07 3/13
lluarene N> - 0.012 1/13
ndena(1.2.3-<:d)pyrene N> - 0.015 1/13
lead 3.1 -6j 13/13
ph8I a dtweIlO N> - Q.OS3 1/13
~ ND -0.075 2/13
zinc 3S.8 - 62A 13/13
S8n DcMI nr.
swface cnenIc 1.9-17.3 3/3
benzo(a)anlhracene 0DJ4 - 0.01 3/3
benzo(a)pyrene 0.01 - 0.021 3/3
benzo(b)fluaranlhene 0.01 - 0.022 3/3
benza(g.hJ)petylene o.m7 - 0.Q26 3/3
benm(lc)l'Alaralhene o.oos - Q.039 3/3
c:hran"Un 12.6-17 3/3
~IO 0JX)9 - Q.031 3/3
copper 14.5 - 19.7 3/3
dibenzIO(a.h)anttvocene N> - 0JX)3 1/3
fk.w.... IIh..I0 0.015 - G.o33 3/3
ndena(1.2.3-<:d)pyrene o.oos - Q.021 3/3
lead 8.6-37A 3/3
~ 0JXI2 - Q.034 3/3
taIuane N> - 0.016 2/3
totat xyIonm NO - o.ooe 113
zinc tH.7 - 78.2 3/3
abuface 0II8nIc: 1.3-2.5 2/2
c:hran"Un 11.3 - 22.1 2/2
copper 21.7 - 26.9 2/2
lead 3.3 - 8.2 2/2
~ 0.002 - 0.(1)4 2/2
zinc 46.2 - 55.1 2/2
lID - not del8ct8d
Jab No. 0673NII~
«)I.WIOOJCLS I 4/26m I 80
Page30fl
Depth Anatvte
HazrftIous Wasle Stomge 8Uk1ng
surface 2-methylnaphlhalene 0.36 1/1
Araclat 1254 0.046 1/'1
acenaphlhene 2.9 1/1
acenaphthylene 0.093 1/1
anllvacene 3.1 In
arsenic 1.2 1/1
bento(a)anIhracene 4.1 1/1
bento(a)pvrene 3.4 1/1
benzo(b)fluaranthene 4.1 1/1
benzo(g.hJ)pery\ellO 2.6 1/1
benzo(Ic)fUaIanlhene 1.2 1/1
carbazcI& 3.8 1/1
chorrilnl 8.2 1/1
ctwysene 3.7 1/1
copper 22.1 1/1
diben1o(a.h)anttvacene 0.64 1/1
dibenzofuIan 1.7 1/1
dimethVlPhlhalate 0.32 1/1
1k.o.0I othellO 13 1/1
nucx- 2.3 1/1
Indeno(I.2.3<:d)pvrene 2.6 1/1
lead 15.1 1/1
methylene chloride 1.3 1/1
nophth!:Mn8 0.55 1/1
pentachlorophenol 0.1 1/1
phenanttvene 16 1/1
pyrena 8.6 1/1
zinc 95.4 1/1
SIbuface arsenic 1.8 - 2.4 2/2
c:twonUn 11.8 - 15.2 2/2
copper 20.1 . 23.8 2/2
lluaranlhene ND - 0.1108 1/2
lead 6.2 - 10.4 2/2
methylene chloride NO - O.~ 1/2
-------
Table 2
Summary of laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/ICg.
Depth I Analvte I Concentration I HeQuency of
Range Detection
Hetblelde StOtOge Area
Mace acetone ND .0.028 1/2
anthracene ND - 0.038 1/2
arsenk:: 0.52 - 1.1 212
ber-.zo(a)onttvacene 0.02-0.19 212
bf:,: :-:J)pyrene 0.004 - Q.23 2/2
bE. '~)ftuoranthene NO - 0.44 1/2
be- :.'1.1)pert1el1e ND-0.19 1/2
be- '~<:Jlldhelle ND - 0.029 1/2
bls' .~ ND -0.92 1/2
ct';: '. 3.2-7.3 2/2
chr 0..D41 - 0.31 212
CQpI:.:.~, 19.2 - 20.9 212
dIbenzo(aJI)anthracene 0.0073 - 0.054 2/2
ftuoIQI dhelle 0.031-D.59 2/2
fluor.- ND . o.oos 1/2
1ndeno(1.2.3<:d)pyrene o.oos - 0.18 212
lead 46 - 8.2 2/2
phenan~ lID - D.44 1/2
pyr8W 0l1Zl- 0.52 2/2
toluene ND - om7 1/2
total xvtenes N>-0.013 1/2
zinc 29.9 - 66.4 212
subsurface acetone N> - 0.D33 5/6
arsenk:: 1-2 6/6
c:hrorTiu'n 8.1 -12.4 6/6
copper 13.7 - 18.3 6/6
tk.o.....1t _Ie ND - o.oos 1/6
lead 3.2-8.7 6/6
zinc 36.8 . 63..1 6/6
Jap Cod J.II AI8G
surface an81Ic 1.1-2,6 2/2
benzo(a)onlNacelle ND - 0.Q32 2/2
benzo(~ NO - 0.018 2/2
benzo(b)tk........ ,It _Ie NO - o.oss 2/2
benzICI(g.hJ)pel ilelle N> - oms 1/2
benzI:IOc)tIuar lID .0.007 212
cl1rorram 11.1-210 2/2
ctwysene NO. 0..Q86 112
copper 21 .31.6 2/2
dibenzo(a.h)anthracene I'D - D.OO6 . 1/2
fIuoran1tww NO - 0.D64 2/2
lead 5-9A 2/2
phenanttvene N>-0.13 1/2
pyr8W N> -0.D61 212
zinc 63..8 - 70.1 212
Mbufac:e an81Ic 1.1-2.1 717
beNl:l(a)an1hraoel1e lID - 0.019 217
beNI:I(~ lID - D.028 217
tMno(b)ftuaranthene lID - 0.027 217
benm(g.hJ)perylene lID - 0.C25 217
benm(lc)tluclrathene lID - D.OO9 117
chrorrUn 9.4 - 22.3 717
c:twysene III) . 0.02 217
copper 16.5 -23 717
~e III) . D.28 217
~a.h)u. jlt....oecle lID - D.OO4 217
lIuoranthene N> - 0.D42 2/7
1ndeno(1~ N> . G.023 217
lead 3.9 - 5.9 717
methytene c:hIoItde N>-0.19 117
~ lID . D.033 217
IODNo. 06737.0.;& 45A - 75.2 717
A. .
Depth I Analyte I Concentration I HeQuency 01
Range Detection
LaboratOf)' Waste St«uge Alea
SUIface 2-butanone NO - 0.007 1/4
ArocIor 1254 NO - 0.45 2/4
anthracene ND-0.14 1/4
0I$EINc 0.85 J 1.5 4/4
benzo(a)onttvacene NO - 0.55 2/4
benzo(a)pyrene. NO - 0.57 2/4
benzo(b)lIuoranthene NO - 0.86 1/4
benzo(g.hJ)perytene NO - D.34 2/4
benzo(Ic)ftuoranthene NO - 0.24 1/4
chIoIpropham 1 1/1
ctvomum 4.1 - 10.3 4/4
c/'vyIene NO - 0.67 2/4
copper 18 - 41.5 4/4
dibenzOanttvacene NO-0.017 1/4
ftuoranthene NO .1.8 2/4
nuor- NO - D.35 1/4
Indeno(I.2.3-cd)pyrene NO - 0.44 2/4
lead 4.6 . 33 4/4
methytene chloride NO - D.54 1/4
n-fttr0S0. o.m2 1/6
ctvomum 5.6 - 10.8 6/6
ctvv18- lID - o.m2 1/6
<:q)peI 12.5-26.2 6/6
dibenzIO(a.h)anttvacene III) - o.oos 1/6
IIuaIDI.thelle III) - 0.018 3/6
lead 3.6 -7.9 6/6
pyrene ND-0.017 1/6
zinc 32.8 - 57.9 6/6
ND - not detec18d
-------
Table 2
Summary of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg//(g.
. .
Depth I Anolyte I Concentration I Frequency at
Range Detection
PlIInbIng Shop
SUIfoce cmenIc 4.8 1/1
benZO(a)anttvacene 0.009 1/1
benzoCa)pyrene Q.OO4 1/1
benZo(b)ftuoranlhene 0.005 1/1
benZOCg.hJ)pely\ene 0.002 1/1
benlOOc)ftuOranlhene 0,004 1/1
butytbenzylphlhalate 0.042 111
cIvorrium 8.3 111
chr,sell8 0.008 1/1
copper - 44.4 111
ftuofanlhene 0.Q2S 111
IIuorene 0.004 111
IndenoCl.2.)<:d)pyrene o.oos 111
lead 199 111
p/'181...,dhrell8 0.2 111
PYfen& o.m6 1/1
zinc 51.2 111
absurface ~...,(QI1OI18 t - Q.32 13/32
~1haIat8 NO - 0.D23 2132
c:tvonUn 6.7 - 49.9 32/32
c:tvysene t
-------
Table 2
Summary of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
Depth 1 Analvte I ConcentTatlon I freQUenCY of
Range Detection
SGtdJItIIIIttg AI8G
uface Arodor 1248 lID - 0.052 1/5
Arodor 1254 lID -0.078 1/5
Arodor 1260 lID -0.11 3/5
CI,III.aony lID - 182 7/24
cnenic 2.1 - 23.5 24/24
benZo(a)anttvacene lID - 0.A4 4/5
benZo(a>Pvrene lID - Q.043 3/5
benzaCb)Cluon:nlhene 1ID-0.19 4/5
benzo(ghJ)perylene lID - 0.89 5/5
benza(Ic)IIuOra lID - CI.066 3/5
~tha1at8 lID - 11 4/5
c:twonUn &.5-170 24/24
ctvysene lID - 0.22 415
copper ZJ.2 - 141 24/24
dbenZoCaJ\)anttvacene lID - 0JXJ3 3/5
~QI MIeII8 lID -0.56 4/5
ftucRnt lID - o.ms 2/5
1ndeno(1~ lID - Q.043 5/5
isophoIoIl8 N)-0.11 1/5
lead 3-651 24/24
phe!1CI .tho. 18 N)-0.12 1/5
pyrene N) - 0.A4 5/5
ZInc C1.3 - 3330 24/24
absurfac:e cnenic Q.66-6 19/19
c:twonUn 9 - 30.4 19 119
copper 17,A-37.8 19/19
Ieac:t A.4 - 2250 19/19
ZInc 61.7 - 101 19/19
,~ StotGf1eAI8G
subsirix:e cnenic N)-2 7/8
benZo(a).. .1tvaceI18 N) -CI.048 1/8
benZo(~ N) - 0.013 1/8
b8nzIo(b)lk,...... lit 118118 N)-0.12 2/8
benzo(g.hJ)p8ry N)-o.oBS 3/8
b8nIO(k)III.ufQl dhell8 N)-0.015 1/8
~ N) - Q.34 3/8
chIonUn 7.1-9.7 8/8
~ N) - CI.092 2/8
copp8r 15.3-18 8/8
dibenZlD(aJ\)anttVac:ell8 N) - 0JXJ3 1/8
.......:. dheI. N)-0.073 1/8
~l.2.3-cd)pyrene N) - Q.069 2/8
I8c8d 1.4 - 10.5 8/8
,*""~cphellOI N) - o.oB8 1/8
~ N)-0.077 3/8
ZInc 34,A-57.7 8/8
Depth I Analvte I Concentration I Frequency of
Range Detection
Wood Pole SIotage A/fH:I south
surface A1oc/Joll254 NO - 5.3 217
cnenIc 1.1 -1.9 717
benzo(a)onttvacene NO . 0.1 517
benzo(a>PYrene NO - O.oss 517
benzo(b)ftuoranlhene NO-0.19 417
benzo(g.hJ)peryIene NO - Q.038 517
ben1O(k)lIuoranlhene NO -0.067 617
c:tvorrUn 12.7 - 20.5 717
c:tvysene NO - CI.25 617
ccpper 14.3 - 26.8 717
dibenZO(aJ\)antl1racene NO -0.m6 317
dimethytphthalate NO - 0.22 117
1lucxanth8ne NO - Q.6 517
Indeno(I,2.3-cd)pyrene NO - 0.045 517
lead 6.6 - 640 717
methylene chloride NO - 0.67 317
perllac:hlofaphenol NO - 0.78 317
phenan1hrene lID - 0.2 117
pyrena NO - 0.53 617
toluene NO - 0.a2s 317
zinc 66.3 - 184 717
SIbUface 4-m8thv\-21*\tanan8 NO - o.oa7 1/25
A1oc/Jol 1254 NO - 0.0B6 1/25
arsenk: . 0.76 - 1.8 25/25
benzo(a)anttvocene f\D - D.063 2/25
benzo(a)pylene lID - Q.067 2/25
benZO(b)lluoranthene IID-0.15 4/25
benzo(g.hJ)perylene 1ID-0.078 1/25
~thene NO - o.oD4 1/25
c:tvonium 7.7 - 18.4 25/25
c:tvysene NO-0.1 3/25
ccpper 15.2-~ 25/25
dibenZO(aJ\)anlt.ac:el18 lID - 0.D02 1125
dim8thytphthalate NO - 0.23 1/25
1II.uo.. dhell8 /ID- 0.14 2/25
1ndenO(1.2.kd)pyren8 NO -Q0S3 1/25
lead 3.5 - 11.3 25/25
n-. ilrcsodlphen"........ /ID - Q.045 1/25
penlac:t.tolophellOl IID-1 1/25
PYI8n8 /ID -0.16 4/25
tck8'8 NO - 0.016 4/25
ZInc 46.1 -70.9 25/25
NO - not detect8d
Jab No. 06737001NOS
(OUAROOJU I 41261'13 I 81)
-------
Table 2
Summa"ry of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
. .
Depth I Analyte -I Concentration I l'feQUency of
Range Detection
UtttncJng Tower
surface 1.1.1-trIchIoroethane NO - 0.35 1/2
1.I~thene NO-0.016 1/2
Noc/IOIl254 NO-5.9 1/2
Noc/IOII2«> NO - 0.069 1/2
arsenic 1.6-2.1 2/2
benzene NO - 0.012 1/2
benzO(a)anttvccene NO -0.D37 1/2
benzO(a)pyrene NO - 0.rX127 1/2
beruO(b)lIuoranthene NO - 0.093 1/2
benzoCgJlJ)perylene 0.018 - 0.23 2/2
benzo(Ic)fIuoIathene NO-o.ol1 1/2
~thaIate NO - 0.24 1/2
ctvomum 13.8 - 21 2/2
avv-w 0.098 - 0.38 212
copper 24A-311 2/2
I\uoranlhene 0.091-0.22 2/2
1ndeno(1.2.:k:d)pyrene NO-o.o19 1/2
lead 15.6 - 69.1 2/2
phenan~ N) - 0.24 1/2
~ 0.04 - 0.24 2/2
toIus1e NO - Q.084 1{2
total xytenes NO - 0.024 1/2
zinc 84.2 - 240 2/2
IUbsurface 1.1.1-trtc:h101oethane N) - 0.007 1/9
AIocfot 1248 N)-O.o74 1/9
AIacIof 1254 N) - 0.095 1/9
cnenIc 1.1-1.8 9/9
benzo(a)an1tYcx:en9 N) - 0.067 2/9
benzo(~ NO - 0J)28 2/9
benzIo(b)ftuolanthene N) - o.oe 119
benzo(g.hJ)pelylene N) - ().042 1/9
beNo(1c)ftuoranthene NO - 0.Q29 1/9
butybenzytphlhalote NO -0.15 8/9
ctwonUn 7-13.8 9/9
chIysene N) - 0.077 1/9
capper 14.7 -20.5 9/9
dIberuo(a.h)Q.dtvac8l19 N) - o.oos 1/9
Ik.uo.. dhell9 N) -0.13 4/9
hdenoCl.2,3-cd)pvrene N) - 0.D39 1/9
I90d 2.7-7.1 9/9
phei.....1I._.e N)-0.13 1/9
PYI8"8 N)-0.15 2/9
zinc: 31A-60.2 9/9
NO - notdetectecl
Jab No. 0673H112-C1015
COUI'IIOOJCLS . 4n6I93 . eo
Page 7018
Depth I Anotvte I Concentratton I I'fequenc:y ot
Range Detection
U/IIlzatlon aid Dtrpord Yard
surtace 2-methytnaphlholene NO-o.ll 1/9
4-me1hy1-2-pentonone NO - o.ooe 2/9
0-1242 NO - 0.54 1/9
acenaphthene NO - 0.85 3/9
anthracene NO "- 1.4 3/9
arsenic NO - 4.7 8/9
benzo(a)anlhracene NO -3.1 7/9
benzo(a)pyrene. 111)-3.1 5/9
benZo(b)t'ucran1hene NO-3 6/9
benZo(gJlJ)pelytene 1«)-2 7/9
benZo(Ic)t'ucranIhene III) - 2.3 6/9
butytbenZylphlhalate NO - 0.077 1/9
carbazOle NO-l.3 2/9
chromium 5.8 - 24.7 9/9
ctvylene III) - 3.2 7/9
copper 17.7 - 49.9 9/9
dibenzo(aJ1)anllYaCene 111)-0.4 40/9
dibenzOfuan NO - 0.59 219
diefhvlphlhalate NO - 0.D36 1/9
tIuoIanthene 111)-6 6/9
tIuofene NO - 2.2 5/9
indenO(l.2.3-cd)pyrene III) - 1.8 6/9
lead 2.4 -11.2 9/9
methytene chloride NO-O.IS 1/9
naphlhalene NO - 0.46 2/9
phenanthrene NO - 6.9 4/9
pyrena NO - 8.3 7/9
toluene III) - 0.046 2/9
tolal xy\enes N)-o.o14 1/9
zinc: 28.8-76.7 9/9
$I.Csurface 4-meft1VI-2-pentonane III) - o.D4 3118
acenaphthene III) - Q.028 1/18
acetone NO - o.D22 1/18
anthracene NO -0.D31 1/18
arSenic: 1.1 - 6.6 18/18
benZO
-------
Table 2
Summary of Laboratory Soil Results
Operable Unit A
Concentrations expressed in mg/kg.
Depth I Analyte I Concentration I frequency 01
Range Detection
Vc.IS Way Stotttge A/fHJ
surface anttvoc- NO -1.9 1/6
arsenic: NO-5 4/6
benzo(a)anthtacene NO - 0.008 3/6
benzo(a)pyrene NO - 0.46 5/6
. benzo(b)fluclfanthene NO - 0.35 4/6
benzo(g.hJ)petylene NO-0.94 4/6
benzo(Ic)ftuofanthene NO - 0.007 3/6
bisC2-e~h1haIat8 NO-I.1 2/6
chron1Um 8.2 - 18.5 6/6
chrysene NO - 0.45 3/6
c::opper 23.5 - 27.8 6/6
dibenzc(a.h)an~ I'[) -0.21 3/6
d!ethytphlhalate NO - 2.6 2/6
ftuoranthene 1'[)-2.8 6/6
1ndeno(1~ I'[) - Q.CIS3 4/6
lead 5.3 - 55.2 6/6
me1hv\eIle chloride NO - Cl.041 3/6
I'M III/OIOCIIphenyIarr NO - O.os 116
phenannv- NO -2.1 216
pyrena NO-2 '6/6
tQIuene NO - 0.064 316
total xytenes NO - 0JXI6 1/6
zinc 54.4 - 182 6/6
2-buIanone NO - o.ooe 1/21
~1OI1e NO - o.m7 1/21
4-m8thvI-2-pentanone NO - 0.036 17/21
antmonv NO - 22.2 1/21
arsenic: NO - 5.5 7/21
benzo(~ NO - Ct.OD2 1/21
benzo(b)lIuoIanthene NO - Ct.OD2 2/21
bIs(2-e~hlhalat8 NO - 3.3 1/21
butylberuytphthalote NO - 0.72 4/21
c:/'worTUn 10.9-28 21/21
chrysene NO - 0.m3 1121
copper 18.1-33.2 21/21
dibenzc(a.h)an1tvacel1e NO - Ct.OD2 2/21
di8~ttaate 1'[)-0'13 1/21
lead 3.8 - 18.6 21/21
".,~..;t.....- NO - Q.048 2/21
pyr8W I'[) - o.oD3 1/21
taUne N) - D.038 4/21
total xytenes N) - o.ao 1/21
zinc 53.9 -127 21/21
NO - not det8ct8d
Jab No. 06737'()12.(JOS
(OUIIJIOOJCLS I 4126/93 I .,
Page 8 aU
Depth AnaIy1e
-
Wood l'oIe Stomge A/fHJ East
surface acenophthene . NO-0.16 117
acenophthytene NO-2.6 517
acetone NO - 0.008 117
anttvacene NO ~ 6.3 617
arsenc: 0.92 - 13.2 717
benzIO(a)annvac- NO-30 617
benzIO(a~ NO - 24 617
benzIO(b)tuoranthene 0.15-28 717
benzIO(g.hJ)perytene 0.17-6 717
benzo(1c)fIuorathene 0.021 - 13 717
bis(2-ethvlhexvt)ph1halate NO - 0.092 117
CCIbaloIe NO - 8.6 517
chrorTium 5.7 - 12.9 717
chrysene. NO-45 617
copper 23A - 82.6 717
dibenZO(a.h)anIhrac- NO-0.13 617
diben1Of\mn NO - 0.25 217
tk.ooiauthelle 0.074 - 350 717
I'AIor«W NO - Q.67 617
1ndeno(1~ NO-4.4 517
lead 4.8 - 15.8 7/7
mefhVlene c:hIcride NO - 0.27 2/7
naphthalene NO - O.osa 117
pentachIorophen NO-62 6/7
phenannv- PC) - 21 617
pyrena 0.Q66-12O 717
zinc 42.9 - 71.2 717
subsurface 2-buIanone NO - 0..014 1/23
~2i* dallOIle NO - 0..012 10/23
cneric 1-7.4 23/23
benzIO(a)an~ NO - 0.43 1/23
benzo(~ NO - 0.45 1/23
benzIO(b)tuoranthene NO - 0.36 2/23
benzIO(g.hJ)perylene NO - 0.25 1/23
ben2I:I(Ic)t\IOthene NO -0.19 2/23
bls(2-e1hyhlxyl)phttaate NO - 3.2 9/23
c:tvcnUn 8.8 - 32.2 23/23
. chrysene NO - 0.37 1/23
copper 16-28.9 23/23
~ NO - 0.39 3/23
db8nm(a.h)aldtvacene N) - 0.043 2/'13
dlelhvlPhthalate NO - D.064 1/'13
........ dhelle NO -1.4 8/23
IIuonnI NO-0.31 1/23
1ndeno(1.2.3
-------
Although a broad list of compounds were found in soils the areas investigated in OUA. a subset of
these compounds were identified as .compounds of concern. based on their frequency of detection.
concentrations relative to background levels, and concentrations relative to risk-based and regulatory criteria.
The compounds of concern evaluated in the risk assessment include:
. .
. metals:
antimony, arsenic, chromium, copper, lead, and zinc;
. HPAHs:
total HPAHs and individual HPAHs including benzo{a)anthracene, chrysene,
benzo(b)f1uoroanthene, benzo(k)f1uoranthene, benzo (g ,h ,i)perylene,
dibenzo(a,h)antbracene, indeno(1,2,3-cd)pyrene; (benzo(a)pyrene was individually
evaluated;
. pentachlorophenol;
. bis(2-etbylhexyl)phtba1ate;
. PCBs, and;
. dioxins (2,3,7,8-TCDD; only for the Capacitor Testing Lab).
Compounds of concern were not found or found in low concentrations in ten of the waste units. In
these areas, nO action was required by the State or EPA. Compounds of concern that exceeded MTCA
cleanup standards were found in seven waste units. These were addressed by removal actions.
Various compounds of concern were found in laterally extensive areas in the three actionable waste
units: Wood Pole Storage Area East, Ross Substation and Capacitor Yard, aDd Capacitor Testing Lab. The
contaminants of concern identified in the Wood Pole Storage Area East are HPAHs and pentachlorophenol.
HPAHs and pentachlorophenol are considered to be carcinogenic. HPAHs are relatively insoluble in wa~,
have a high affinity for soils and therefore, are relatively immobile. Pentachlorophenol is relatively soluble
in water, tends to sorb to particulate matter and is readily biodegradable. Mobility of pentachlorophenol is
expected to be limited due to the presence of compacted soils containing low permeability rates in this area.
Contaminated soil in the OUA are not RCRA wastes since the material would not designate as a dangerous
waste based on WAC-173-303-070(3). It is also not a federal hazardous waste as defined in 40 CFR Part 261
because it is neither a listed waste nor is it characteristic. HPAHs were detected in soils throughout this waste
uait from 0 to 3 feet bgs, and pentachlorophenol was dete<:tM only in surface soils throughout the area. Trace
levels of HPAH «0.003 mgllcg) were detected at 7.5 feet bgs at select locations. Figures 3 and 4 show the
conccotration and distribution ofpentacb1oropbenol and HPAH in this area, respectively. Figure S shows the
estimated area of conmmiluatM soil and the estimated volume of CODmminlltM material is 3,6SS yd3. HP AHs
and pentachlorophenol fOUDd in soils in this area were from chemicals that dripped from the treated
transmission poles stored in this area.
_1,..-1"'"
2S
-------
o WPE-SB11A
o WPE - SB03A
o WPE - SB09A
<:> WPE - SB08A
"
o WPE-SB01A
~ WPE-SB02A
o WPE-SB04A
. WPE - SB06A
-$-WPE-SB07A
-$-WPE-SB10A
.............
-.....
"
Wood Pole Storage Area, East
.
L£C£NO
----
SPA ROil Co"'pl.. Boyndru y
fenCl
~.a ~..d
9uildin9
$ lOCOI;on 01 lomplc(.) hovin9 a dtl,ct,d onOlr" obove AAO. .
-$- lOCOliOn 01 ,o,"ple(.) f\o..;n, 0 d",eatd O"Olyl. b.lo- AAO
o locotiO" 01 lO""'Dlf(.) "OW;"9 "0 detected O"OI,lf
e::z:::ZJ
Job No. 06737-012-005
1
e,,,,,,,,,,'I,,,, " '."IIC"",..1\1"81 ."
'"8.''' 't-, I.,,,,. A,.. r..,
SI"'.Of D£'I" CONe. OJAl
---
1IPC-180'0 0 II
""[ -18010 0 ,. J
.-r "SIOIA 0 " J
.(-11074 0 " J
_(-SlIOA 0 '.8 "
Voh,.. "'" It. 1110 "IM
J .. Ihl ...8111'" ."'" " 'ft '''.'''01''
."."111,.
N
A
0 60 120
SCALE IN rEEf
o WPE-SBI2A
Figure 3
Distribution of Pentachlorophenol (PCP)
Wood Pole Storage Area, East
BPA Ross Complex
-------
-$- WPE-S811 A
-$- WPE - S803A
eWPE-S809A
o WPE - S80BA
-$-WPE-SBI2A
"
-$- WPE-SB01A
+WPE-SB02A
-$- WPE-SB04A
+ WPE - SBOSA
-$-WPE-SB07A
-$-WPE-SB10A
'"
---
........
-$- WPE - SB05A
Wood Pole Storage Area, Eest
.
.
e'''llAh,li.". .t ht,. t"C'''''''''''8 ""AM
'" '''' -... "," s.o,... A'.. hll
".., lOtI 0['1" co.c: av.,
- --
WP(-SIOIA 0 a -a.
...r -S80IA 0 "1 .
,~ 000'
"[-S80)' ) 0 001
,~ 000'
~[-seo"" ,. a 0.1
tlPr -SIOU. 0 )0 "
-r ...'.01& 0 II"
,. 0001
..( -no" 0 ...
""(-SlIOA 0 . .
,~ 0 00'
_[-111'4 ) .,
IIII'(-Slt,a ) 0 001)
YOlu.. "'0' I.' '" ,,....
J .. 1Ji1t "'lei,l,d .01"" 01 ."" ....-...
'1"...1,',
N
fA.
o
60
120
SCALE IN rEET
~
SPA Ron Comp'u 801.11""0"
,."co
Aoa Rood
e,,3~:t\9
.. LOCOlion of lampl'(') ho.nnQ 0 "e'C(18d 01\01)'1. otlO~ AAO.
~ Locotion 01 lampl.h) hOvinV 0 dltecled O"Olr" b.la- AAO.
G> local:O"l 01 .~""If(') hOvinO no CSllfcted anat)'lc.
Figure 4
Distribution of Total HPAH
Wood Pole storage Area, East
BPA R088 Complex
DAMES & MOORE
,
~
I
J
.
l!C!NO
-------
CJ
...) "'" ~ ~ ~
.............. -....---- '--- ~ -~
.' ..- ,,' ,~
----.............. -'. .
~~~ ~
~~ ~$ ~~ ~ ~
Total Cubic Y
ords = 3,655
Wood Pole St
. orage Area, East
~ W#ff#hI
J---- .
----
----
----
- -
, ---
, --
------
---------
---
----
------
------
--------
BPA ROil C
- f.nc. ompl,. Boundory
~ Rail Road
c::::::J e~ildin9
V////////A
Elt. C::ontomin
otcct AreOI
N
. fA.
o
.
160
.
SCALE IN rEET
80
Estlmat d
a Araas of C Figure 5
Wood Pole StOntamlnatad Solis
orage A
BPA rea, East'
Ross Complex
DAMES & MOORE
LEG£ND
Job No
. 06737-012-005
-------
..
PCBs were the compound of concern identified in soils in the Ross Substation and Capacitor Yard.
The Ross Substation and Capacitor Yard is a IO-acre fenced area that contains numerous capacitors and
transformers. Spills of PCB oils from faulty capacitors and leaking equipment have occasionally occurred
within the substation. Figure 6 shows the distribution of PCB contamination and Figure 7 shows estimated
area of contaminated soil,' a volume estimate of approximately (1,196 yd3), in the Ross Substation and
Capacitor Yard.
PCBs are the compounds of concern identified in the Capacitor Testing Lab area. PCBs were detected
in surface soils around the outside of the Capacitor Testing Lab. Figures 8 and 9 show the distribution of
PCB contamination and the estimated area of contaminated soil (volume estimate of approximately 68 yd3) in .
the Capacitor Testing Lab Area. PCB-containing oils were reportedly spiUed onto the concrete floor during
storage of the failed capacitors, as well as onto the soil and gravel beyond the garage door. Potential heating
of the PCB-containing oils with the capacitors may have produced dio~.
PCBs are considered to be carcinogenic, are relatively insoluble in watec and have a high affinity to
sorb to soils. It is unlikeJy that PCBs will be mobile in soils in either the Ross Substation and Capacitor Yard
or the Capacitor Testing Lab based on the physical conblminant cbaracteristics and because soils in these areas
are compacted and have low permeability characteristics. PCBs are regulated as a dangerous waste in
accordance with WAC-I73-303 and are also regulated under TSCA, 40 CFR Part 761.
7.0 SUMMARy OF SITE RISKS
CERCLA response actions for QUA at the BPA Ross Complex site as described in this Record of
Decision are intended to protect human health and the environment from curient and potential future exposure
to hazardous substances in soil at the site. To assess these risks at the site, human health and ecological risk
assessments were conducted as part of the remedial investigation to characterize the magnitude of rislcs
associated with exposure to conmmin~tM surface soils and to prioritize areas within QUA for remedial action.
Human receptors included a hypothetical on-site residential child and adult (potential future sceuario); on-site
worker (current iDdustrial scenario); and off-site residential (recreational) child and adult. Ecological indicator
species selected for this site included the American robin (T. migratorius), raccoon (P. lotor), and black-tailed
deer (0. hemionus columbianus). The results of the risk assessments were used to decide whether remedial
. action is necessary and then used in the feasibility study for selection of cleanup guidelines to protect human
health and the environment.
The approach followed for both the human health and ecological Baseline Risk Assessment consisted
of the following general steps: (I) identification of chemicals of potential concern, (2) exposure assessment,
(3) toxicity assessment, and (4) risk characterization.
_I/~I'"
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Distribution of Total PCBs
Ross Substation, and Capacitor Yard
BPA ROBS Complex
DAMES & MOORE
-------
. .
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1196 Total Cubic Yards
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FIGURE 7
ESTIMATED AREAS OF CONTAMINATED SOilS
ROSS SUBSTATION AND CAPACITOR YARD
BPA ROSS COMPLEX
DAMES & MOORE
-------
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ESTIMATED AREAS OF CONTAMINATED SOILS
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-------
7.1 COMPOUNDS OF CONCERN AND USE OF DATA
Twelve compounds of concern were selected from a broader list of chemicals of potential concern
identified by the Washington Model Toxies Control Act (MTCA), and EPA regional and national guidance
(EPA 1988, EPA 1991) based on comparison with natural and area background soil concentrations,
prevalence, and toxicity. The compounds of concern selected for inclusion in the risk assessment are as
follows:
. .
.
Metals: antimony, arsenic, chromium, copper, lead, zinc.
Suspected carcinogenic high molecular weight polynuclear aromatic hydrocarbons (HPAH)
were evaluated as total HPAHs. The carcinogenic HPAHs considered in the total HPAH are
benzo(a)anthracene, chrysene, benzo(b)fluoranthene, . benzo(k)fluoranthene,
benzo(g,h,i)perylene, dibenzo(a,h)anthraceDe, fluoranthene, indeno( 1,2,3 )pyrene,and pyrene.
- (Benzo(a)pyrene, a carcinogenic HPAH, was considered separately);
Pentachlorophenol;
Bis(2-ethylbexyl)phthalate;
Total polychlorinated biphenyl compounds (PCBs); and
Dioxin (2,3,7,8-TCDD).
.
.
.
.
.
These compounds of concern were carried throughout the baseline risk assessment and wer'C
considered in the Feasibility Study. The metals evaluated in the risk assessment were elevated above
background levels. Metals including antimony, chromium, copper, lead, and zinc wer'C evaluated as non-
carcinogenic compounds. Arsenic, HPAHs, pentachlorophenol, bis(2-ethylbexylphthalate, PCBs, and dioxin
are evaluated as carcinogenic compounds.
In the risk assessment, the individual waste units iddressed in Operable Unit A were grouped into
seven larger categories or waste unit groups to evaluate conf1lminant exposure potential within relatively
homogeneous exposure areas. The waste units were organized into Waste Unit Groups (WUG) based on
location within the Site, predominant contaminants present, surface water drainage and topography, proximity
to biological habitat, and other exposure considerations. No surface soil samples wer'C collected in association
with the oil water separators, therefore, this unit was not included in a waste unit group. The waste units
within each group are listed as follows:
Waste Unit Group
Waste Unit
1
Van's Way Oils Storage
Wood Pole Storage Area East
2
UtilizatioD and Disposal Yard
Hazardous Waste Storage Building
Herbicide Storage Area
3
Capacitor Testing Lab
Paint Storage Facility
Plumbing Shop (8Paint Shop.)
PCB Storage Building
4
Sand Blast Area
_"-""1'-
-------
5
Laboratory Waste Storage Area
Untaoking Tower
6
Ross Substation and Capacitor Yard
.
7
008-1 and 008-2 Drainfields
Top Coat Test Area
DOB-l Drainline
Wood Pole Storage Area South
Ellen Davis Trail
Samples with chemicals reported as undetected were assumed to contain these constituents at 1/2 the
sample quantitation limit for the purpose of calculating averages, as recommended by EPA guidance (EPA.
1989a). The Baseline RA was conducted for all chemical data sets based on the 9S perceo.t upper confidence
limit (UCL) ot the avenge concentrations in soil. The 95t1i UCL is utilized at the reasonable maximum
exposure (RME) value used in the risk assessment. The RME is defined as the highest potential exposure
expected to occur at a site (EPA, 1989a).
7.2 HUMAN HEALm RISK ASSESSMENT
This section summarizes the exposure assessment, toxicity assessment and the risk characterization
~sociared with the indicator chemicals evaluated in the human health risk assessment.
7.2.1 Exoosure Assessment
The exposure assessment characterizes the general setting in which potential exposures could occur,
including the physical setting and accessibility to CODtaminSltecJ areas; defines potentially exposed
populations;identities exposure pathways; defines the approach for quantifying exposures. including selection
of numerical exposure factors; and estimation of chemical intake.
7.2.1.1 Site Setting
The exposure assessment emphasizes potential exposures associl,l~ with current land use activities,
comprising the baseline sceuario, both on and around the site. In addition, in compliance with EPA Region
10 guicleliDes (BPA, Region la, 1991), a hypothetical on-site residential sceuario, addressing potential
exposures of poteDtia1 future residents is included in the quantitative risk issessment. This sceuario is included
to consider all poteatia1 exposures but is not regarded as likc1y given the presumed continued land usc
designation of the BPA Ross Complex as a power distribution facility. .
The area sunounding the Site exhibits a variety of land uses. These include residential (south,
southwest, and southeast), light commercialfmdustrial (east and northeast), major highways and thoroughfares
(west (primarily), north, east (secondarily», and open space (north, southeast, west). Exposure scenarios are
consistent with this diversity of land usc.
The Complex is generally fenced. Open (i.e., accessible) areas exist primarily in the southern section
of the Complex. Site access by adjacent residents could occur near the southern (19th Avenue) entrance to
the Site, where no steep slopes, bushy vegetation, fences or other controls restrict access. These areas include
the EUen Davis Trail, and Wood Pole Storage-South, which are in W~ Unit Group ff1.
4iIc."--..-
-------
Workers are assumed to have unlimited access to the Site through work-related duties. Hypothetical
oD-site residents are also assumed to have unlimited access to the site. Off-site residents are presumed
exposed in areas where unrestricted access exists, which is primarily on the southern perimeter of the Site.
There is DO known human habitation OD the Complex except for transients which reportedly occupy the
northern portion of the Complex near the Cold Creek landfill. Potential exposures will be addressed as part
of the Operable Unit B Baseline risk assessment.
. .
7.2.1.2 Potentially Exposed Populations
The human receptor groups that were evaluated in the baseline risk assessment included on-site
workers, hypothetical on-site residents, and off-site residents using portions of the site recreationally. Table
3 provides a descriptioo and summary of the various human receptor groups (both o~- and off-site) considered
for the Baseline RA. Hypothetical on-sitc residential exposures to site-related contaminants could also occur
in several ~ on the Site from several different waste units. This hypothetical scenario assumes that at some
point in the future the Ross Complex would no longer be used as a power distribution facility, but that OD-site
contaminant levels would remain the same. Several potential pathways could be involved, based on surface
soils, surface Water, and air.
Two residential receptor -age-classcs- were evaluated. These included children aged 0 to 6 and
-adults- aged 6 to 75. This distinction is believed to most effectively address the different types ofpoteDtiai
exposures occurring within human receptor groups.
Exposures to on-site workers could oc:cur at several areas of the Site based 00 direct contact with Soils
(including dermal contact, incideota1 ingestion, and inha1ation). On-site workers were oot assumed to ingest
produce grown oo-site or fisblshe1lfish taIceu from adjoining creeks. Because oumerous activities occur 00
the Site near contaminated areas, exposure durations and other factors were evaluated based 00 conservative
RME exposure factors.
Off-site residential exposures to site-related contaminants evaluated in this risk assessment were
limited to recreational use of WUG 17. Some direct contact with Operable Unit A Soils is also possible at
the southern portion of the Site where site access is not restricted.
A 1arge portion of the southeastcm area is bordered by a greenbelt through which the eastern portion
of the Ellen Davis trail passes. Consideration of residents around the Site was limited becau~ of Interstate
1-5 and other major thorougbfaRs ~ed to compound and obscure potential impacts from the Ross
Complex. . In addition. the uea to the west (near the Ellen Davis trail) is generally open space with woodland,
vacant lots. and riparian areas. Potential exposures of residents living near the Site are quantitatively
addressed through evaluation of the hypothetical assumption that coDt"ming~ fish aDd shellfish me consumed
and incidental contact with creek waters represented by Cold Creek and Burnt Bridge Creek occurs.
Ucl/..-lUoc
-------
- .
Table 3
DescrIption and Selection of Complete PotentIal Human Exposure Pathways by Receptor
Operable Un" A
BPA Ross Complex RI
Poh~~~t,.~~.~~.~tor
Off~te Residents
. "':..~... ,..,"... ... ',..
Hypothetical On-Site Residents
Route, Medium, and
Point of Exposure
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Incidental Ingestion of soIls
Dermal contact with soils
Ingestion of homegrown fruits and
vegetables '
Incidental Ingestion of surface water or
sediment from Burnt Bridge or Cold Creek
Dermal contact with surface wafer or
sediment from Burnt BrIdge or Cold Creek.
Ingestion of IIJh/shellfish
Inhalation of wnd-borne particulates from
exposed surface soils
Inhatatlon of vapor-phase chemicals
transported off.slte
. . '-I"",.!
Incldentallngesllon of soils
Dermal contact with soils
Ingestion of homegrown fruit. and
vegetables
Assumes that solis could be contamInated via oerlal deposition or surface
water runoff.
Assumes that soils could be contaminated via aerial deposlllon or surface
water runoff.
Assumes that plants moy be Irrigated with contaminated water. planted in
contaminated soli. or that wlndborne contaminants would be deposited on
plant surfaces.
Assumes that contaminants could be taken up by human receptors during
swimming activities.
Assumes that contaminants could be taken up by human receptors during
swimming activities.
Assumes that Ross'Complex contaminants could be taken up by aquatic
organisms and Ingested by human consumers.
Assumes that solJ.borne contamInants could be transported to off-site soils.
Considered highly unDkely .In pori because most of the site Is paved. but was
addressed as BaseDne RA pothway.
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Assumes Ingestion of on-site soils.
. !.' I :i,.,f.. . '~' .' ,"
Assumes dermal contact with on-slte soils.
Assumes that plant. may be IrrIgated with contaminated water. planted In
contaminated soli. or that wndborne contamInants would be deposited on
plant surfaces.
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Job No. 0673HI12-006
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-------
Table 3
Description and Selection of Complete Potential Human Exposure Palhways by Receptor
Operable Un" A
BPA Ross Complex RI
P~~e~t,~.I,R~~.~!.~~._.. .
Roul., Medium, and
Point 0' Exposure
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.:."~ ." .. . .~: .,,-~ ....
Hvpothetlcal On-Site Res/dents
(cant .)
Incidental' Ingestion 0' surface water or
sediment from Burnt Bridge or Cold Creek
Dermal contact with surface water or
sediment from Bumt BrIdge or Cold Creek.
Ingestion of ftsh/shellflsh
Inhalation ofwlnd-borne particulates from
exposed surface soils
Inhalation of vapor-phase chemicals
emitted from site
"1'. ,'.
'.~ ,..'..' ',.,"' .' n(::!~.,,;::;.""'!:":~',,"
Incidental Ingestion of soIls during work
acllvttes
Ross Complex workers
Dermal contact with lolls during work
acllvltes
Inhalallon of wlnd-drlven particulates from
exposed soils
Inhalation of vapor.phase chemicals
emitted from site
Basis for Selection
. ' 1'1-'"' ,~~., ,..,'''''' ....,.", ;""."..... ."'~""'.'._~....,..'''''..J. ~,'I't'.",:'-"'~:o'ot't ,,,'--,,,,,,-,,.,,"'..~I ..."... ';'''':... I . .
. ",; '; .- ~'" "..- ."" -.. ,.
Assumes that contamInants could be token up bV human receptors during
swimming activities.
Assumes that contaminants could betoken up bV human receptors during
swimming activities.
Assumes thai Ross Complex contaminants could be taken up bV aquatic
organIsms and Ingested bV human consumers.
Assumes that soli-borne contaminants are transported Into the air onslte.
Considered highly unnkely.ln part because most of the site Is paved. but was
addressed os Bosenne RA pathway.
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-------
7.2.1.3 Identification of Exposure Pathways
"
Exposure pathways selected for evaluation in the risk assessment were: 1) incidental ingestion of
contaminated soil and dust; 2) dermal contact with contaminated soil; 3) ingestion of contaminated produce;
4) incidental ingestion .of surface water; 5) dermal contact with sediments; 6) ingestion of contaminated
fish/shellfish; 7) inhalation of contaminated particles; and 8) inhalation of organic vapors. Surface soils were
the principle source of contamination evaluated in the baseline risk assessment for: Operable Unit A. Potential
pathways were based on the three receptor groups (off-site residents who use Waste Unit Group #1 for
recreational purposes, hypothetical on-site residents, and on-site workclS) discussed above and summarized
on Table 3.
Table 3 depicts the rationale for selection of the potential exposure pathways for each of the three
receptor groups (off-site residents. on-site workers. hypothetical on-site residents) including route, medium
and eJtposure point. and basis for selection. For on-site workers and hypothetical on-site residents, seven
pathways were evaluated and six were evaluated for off-site residents. Inhalation or other eJtposure to fugitive
dust was evaluated for the RI for both on-site and off-site receptors. Grain size analysis of on-site soils
indicates that these soils are not subject to wind erosion. therefore this pathway was not included in the
quantitative assessment. Guidance for numerical eJtposure factors was generally obtained from EPA (e.g..
EPA 1989a; 1989b; Region 10 1991, 1991c, 1991b) or the opeD literature.
7.2.2 Toxicitv Assessment
'Ibis section summarizes the toxicological basis for aU compound-specific toxicity criteria requiRd
to conduct the Baseline Risk Assessment. These criteria. based on available quantified dose-response toxicity
data, are developed and reviewed within various offices of EPA. Summaries of the basis from which
toxicological values were derived are presented below.
7.2.2.1 Non-Carcinogenic Effects
For noncarcinogeaic chemicals. the reference doses (RID) are ~ as beucbinarks for toxic eudpoints
of conc:em. The goal in developing a RID is to identify the highest n(M)bscrved-adverso-ef'fect level (NOAa)
or the lowest-observed-adverse-effect-Ievel (LOAEL) from wdl-designed human or animal studies.
Uncertainty factors from 1 to 1.000 are incorporated to adjust this level based on the following consideratious:
. I) the duration of the experimental exposure, 2) effecIs elicited (if any), 3) eJttrapolation of the data to other
species (such IS eJttrapo1ation from animals to humans), and 4) scositive subgroups. Additional modifying
factors varyiag between 1 and 10 may also be incorporated in the derivation of the RID if additional
consideratiODS are ~'Y. RID and slope factors for the BPA risk asses<;ment were taken from EPA's
computerized Integrated Risk Information System (IRIS); Health Effects Assessment Summary Tables
(HEAST); Drinking Wa= Health Advisories; or personal communication with EPA Region 10 Risk
Assessment saaff.
The toxicological cbamcterization of compounds of concern was generally confined to chronic (i.e.,
lifetime) rather than acute or subcbronic eJtposures. This cbamcterization is consisteDt with the contaminant
concentratioDS fouad OD-Site, EPA guidance (EPA. (989) and eJtp0sure5 like1y to occur on site.
7.2.2.2 Carcinogenic Effects
For carcinogenic chemicals, slope factors are estimated using a conservative mathematical model
which estimates the relalionship between eJtperimental eJtposure (i.e., doses) and the development of CUCCI'
_11.-..1'-
-------
(i.e., response) that is derived from human or animal studies. Since there is much uncertainty in the dose-
response values generated using this procedure, the upper 95 percent confidence limit of the slope of the dose-
response curve is normally used in deriving the slope factor.
7.2.3 Risk Characterization
. .
The exposure and toxicity assessments form the basis for the characterization of chemical risks posed
by the Site. Carcinogenic risk is estimated as the incremental probability of an individual developing cancel'
in excess of the normal background population incidence over a lifetime as a result of exposure to a chemical
eith~ known or suspected to cause cancec. To estimate cancec risk, slope factors are combined with site
exposure information to estimate the incremental cancer risk, which represents a probability of cOntracting
cancer, and which is usually expressed in scientific notation (e.g., lE-(4). An excess lifetime risk of lE~
indicates that, as a plausible upper bound, an individual has a one-in-ten-thousand chance of developing cancel'
in a lifetime as a result of site-related exposure to a carcinogen.
For known or suspected carcinogens, acceptable exposures arc generally concentration levels that
represent an excess upper bound lifetime cancec risk to an individual of between lE..()4 and lE-06, using
information on the relationship between dose and response (NCP 1990). '
For non-carcinogens, the measure used to describe the potential for toxicity in an individual is IIOt
expressed as a probability. The potential for noncarcinogenic effects is evaluated by comparing an exposure
level over a specific period (e.g., lifetime) with a reference dose derived for a similar exposure period. This
ratio of exposure to toxicity is called a Hazard Quotient. The Hazard Index (HI) is the sum of more than one
hazard quotient for multiple substances andlor multiple exposure pathways. Potential noncarcinogenic effects
may be of concern if the HI exceeds unity (i.e., HI> 1).
7.2.3.1 Evaluation of On-Site Risks
R.esUlts of the Baseline RA indicated that the sum of lifetime cancec risk estimates for all chemicals
of concern for on-site worlcers and hypothetical on-site residential child and adult in each Waste Unit Group
2,4,5, and 7 ranged from 6.3E-06 to 6.7E-5 (Table 4). The highest risk was associated with WUG 14 and
was principally related to arsenic. All hazard quotients were below 1 except for antimony (1.45) in Waste
Unit Group #4. The estimated HQ for antimony found in Waste Unit Group 4 (Sand Blast Area) was for the
hypothetical oo-site residential child. Risks, associated with the contaminants present in the Sandblast AJea
have been removed since this area underwent a removal action.
For Waste Unit Groups, 1,3, and 6, total cancer risk estimates ranged from 4.4&05 to 2.1&04.
Waste Unit Group #1 is located in the northeast comer of the site and consists of two individual waste units
(Van's Way Oil Storage Area and Wood Pole Storage Area East). Total cancec risk estimates for all three
receptors, on-site worker and hypothetical on-site child and adult, ranged from 8.9E-OS to 2.1E-04. Total
HPAHs accounted for approximately 91 ~ to 95~ of the projected risk for each on-site receptor. The
occUrrence ofHPAHs were generally laterally extensive in the Wood Pole Storage Area East and only at spot
locations in Van's Way Oil Storage Area. Hazard Quotient estimates for Don-c:arciDogeoic compounds in
Waste Unit Group 1 were below the Hazard Jnd~ of 1; therefore, adverse health effects associated with the
non-carcinogenic compounds evaluated are not expected to occur,~' this area of the Site.
Waste Unit Group 3 is located in the central industrial core of the Site and consists of four individual
waste units, Capacitor Testing Lab, Paint Storage Facility, Plumbing Shop and PCB Storage Area. Total
cancer risk estimates for the on-site receptors ranged from 4.4E-OS to 1.2E-04.
&e1/.....1.-
-------
Table 4 .
Estimated Hazard Quotients and Ufetime Cancer Risk, Hypothetical On-Site Residential
and Occupational Receptors .
Operable Unit A
BPA Ross Complex RI
.
.
Hypothetical
On-Site Residential
Adult
Based on UCL1
HypoIheHcaI
On-Site ResIdential
CttIIc:I
On-Site
Worker
Compound
~_....~, ~ _.~ _..,~'" - .'~ ~.__.- ,,,"""'''.~.~ "-"""''''''''
.. . '" . .-:-...~~.,~........:~"......'"!O..~:;;;" ~'i""'.'" .. .'..r:"':....,.~~!:.,.!j'n !:r1'~': ~j'~.:;,,+...j...,.. ...<..~.'.. ..~-':.'~ ... . ~..~
--~...._-~...' "'"
Waste untt Group .1
~o~~t~~~!'!r"'!~"~;~'''~1;1''~",:' "
Ovomk.m
Copper
lead
Zinc
Conhlbulion from lead "
Total HPAHs
Benzo(a)pyr8n9
Penta:hlo/OPhenEll
Bis (2-ethy\h8XYt) phthdate
Total PCBs
sun of cancer lisle . "
PeIcent Itsk attIIbutabIe to total HPAHs.
pentac:hlorq)her1O and Iotal PC8s..
Waste Unit GrOUP .2
.. ...'.' 1':","". ........'~~.7!1)}.:::'..~:.+'~-:i."I~"T.,,="... ~
Wn7nrd QuotIent
0vtx'rWm
Copper
lead
Zinc
ContribUtion from lead ..
Total HPAHs
Benzg(a)pyr8n9
Pentad'1IoIopheIlOI
Bis~phthalate
Total PCBs
sun of cancer IIsk . ..
PeIcent dIk aftII)utabIe to total HPAHs.
pentachIorophen and Iotal PCBs ..
Waste Unit Group .3
...:. '':;',':: ."!~I~.W:'''';Ii.:..:~,t:'It':':;:::'lt: "'-':"".:
Wn7nrd Quatient
CtvarrUn
Ccpper
Lead
Zinc
ConI1tIutIon from lead .
Total HPAHs
Benzg(~
Pen~1OI
BIs~~ phthaIat8
. Total PC8I
Total COO/CDF
lUI'I'Iof cancer IIsk I ..
PeIcent Itsk aItrbItaI:IIe to total tf'AHs.
pel1II.d 1IoIq)h8I1OI. en:! total PC8a .
:j.'-'.:... ~''''': ':~A...-.;t... .
-JDoWII~';' .
0.04 0.10
0.04 0.19
0.04 0.16
0.01 0.01
8.1E-05 ~
4.1E-05 9.7E-05
3.3E-06 9~
3.1 E-
-------
Table 4
Estimated Hazard Quotients and lifetime Cancer Risk, Hypothetical On-Site Residential
and Occupational Receptors
Operable Unit A
BPA Ross Complex RI
Compound
Hypothetical
0~51te Residential
Adult
Based on UCl1
Hypotheti~1
On-5l1e Residential
ChIld
- .
On-5l1e
Worker
.~ ",,,,,',,'" ,""," """"';'. .' ..... '.'
'. ..._.,.,............~.,."".~"".,~ '."
:,,,,,"""~--"""'"
..............._~_.........;",.".,.,
,.-.-J--.
~~~.~~~-!~'..'.i'"''''"''<'''
Hmnrd Quotient
AntimDnV
0vcrnUn
Copper
Lead
Zinc
,,,!:':,;~~~,':~;';" "rt'~:.' v~;:j'i'~ i'."~::.!:-' ;...-~;.~::;::,'~ :" :::. ;;';',:;~..::1J!.:-'..":'~'
. '. ;. '!"'~: :,:-':,;:,~,!,:":""''','': ,:::.11'.;;!.i~" .!.::,~:o~;o;:o:IOIiO 'L~.h"JItO"~
0.89
0.19
O.oe
Q.32
0.07
us
0.29
Q.22
1.17
0.11
0.02
<0.01
<0.01
0.04
<0.01
ContributIon from lead ..
IUr1I 01 cancer risk I ..
I'eIc&1t lisle attribUtable to totaIWAHs.
pentachlolophenol. and total PCBs ..
6.OE-OS
3.5E-06
1.5E.()6
~7
1~
1~
6.7E-05
2.1~
5.1~
1.1~
1.8E.Q6
9itHJ7
2.~
3~
1&.06
~
2.5E-07
e.8E-07
1.88)7
1.0E-06
5.6&06
AnenIc
Total HPAHs
8enzD(a)pyI8ne
PentachlcxcphenOl
BG (24thyh1xy1) phthalate
Total PCBs
~
~
69.oI!'J.
Waste Unil Group '5
~.&~ft,;,,~~!~~~~""
Qvomium
Copper
Lead
zn:
",.,~ ,..r, ...~;oI;!:' ":"~ :t.~i ~-''''.'~':' "::!....",,j;"~~..;;.~.;;'(,~!-.,;,;;.:..
"~"". ""t', "
. ~",."'" ".~,"""', ,
, !<...-,;::.~~~ ~':iI ~:ioi.;"::~;:~~~~>
o.os
0.11
0.07
0.01
0.11
0.39
0.28
0.02
<0.01
0.01
0.01
<0.01
ContrtbuIian from lead ..
sum of cancer lisle I =
PeIcent lisle attrIJutabIe to totalWAHs.
pentc:x:l\lolOphellOl. and total.PCSs.
9J1Eo«1
5.1~
U~7
3.1~
1.1~
~
1.AE.05
5.8E..()6
~
7.1~7
2.~
4.6E~
6.3E-06
2.4£.()6
1~
<1.0E-07
1.~.
1~
Total HPAHs
8enzD(~
Pentac:hlolophenol
Bis (24thyh1xy1) phthalate
Toto! PCBs .
87 ..tIa
98A~
1~
,~~-=~~~.iI!I:.~~:;o;'1:~;..;~,.;;,~~:t!!'4i7,,;:.;.~~';!~;-oiIi~....:KP.I"¥~"'''''':...o.:;~:::.:....~,;.",io:-<'-:.,::;.:...-,L' ~,.:,~::.::;:(, . ..'..:..~:;;...
IoImnorf 0. ....tIAnt
Antinony
Chromium
Copper
Lead
Zinc
"."."
, ::=:.:;.;.;.:;..,i...:~;:t;Ii.:..\:i.!.~~~~~,:' ..~~;W!I,N$Ol:'
0.24
0.07
0.07
0.44
0.01
us
0.12
0.17
1.67
0.02
Q.CX)
<0.01
<0.01
O.os
< 0.01
ContrbutIon from lead ..
amd cancer IIIk I.
Percent lisle attIINIabIe to totatWAHs.
penlachIofopheIlOl. and Iotal PCBs.
2.1~
1 JIE.06
6.4E-G7
1.2£.(16
7~
8JE.(I5
1.~
2.QE.06
1J1Eo«1
6.7£47
2JE.04
2JE.04
3JIE.07
6.~
~7
<1~
7.2E0C5
7.3E.(15
Total HPAHs
Ben2Io(a)pyr8n8
JIbj~1OI
BII (24thyhexyO phthalate
Total PC8I
98.4A
99.6~
1~
, . ~.'. ",~,~,'-", .'.....,..... -~ ,~
.,.,.,~-_....,._..,....,~-,,~......~, ", '...'~~ ....~- "".,~ ..~... "". ..............,.".,.~. .,,..~..._...'
~
. n.- C8IauI8I8d bb8nzaC8I..,.- illIGI indIId8d in... _01- .--. 8C8IP iI--- it............AM -.......
Jcb No. 0673NI1241iS
(!OU'..ROOI.ICI.WlTa-4 I 4172193 I 81)
-------
Tobie 4
Estimated Hazard Quotients and Ufetime Cancer Risk, Hypothetical On-Site Residential
and Occupational Receptors .
Operable Unit A
BPA Ross Complex RI
. . .,...-.".~~..'.~'
Compound
Hypothetical
On-Site Residential
Adult
Based on UClI
. Hypolhelic:al
On-SIte Resldenllal
ChIld
On-SIte
WOfIcer
-
.
. ~ ",,, ",.., ..'~ .,,~~ .
......."'~~.. .' ___r,.'"
Waste Unit Group .7
''>;0;_;'...- -X~ ~'''''''':;'~-:::O.'~'"'''''..:<.'I!M:'':''''
1.QE.()7
3.1E-06
4.9E-06
S.QE.()S
Allene
Total"'AHs
Benzc(a)pvnIne -
Pbo ,loQc/'b"opheIlOI
BIs ~phthclate
Total PCBs
20.~
. -..... ...._......~_...__......_..__...,...~.....-_. .........--~._....-......'''' '''''-''''. . '.-.
.....," ''''''. .....~ .....--~..... ,.'-......... .'"''''''
~
. 1118 riIk.........., tar b8nZ0(8j.".. illIIII incW8d n'" - ell - riIk wIuo. IIC8IP .--.ltar it .........Nt riIk......
Jab No. D6137~124QIS
~1JC1.Wl1a04 I ~ I eO
-------
Tbe estimated total cancer risk of 4.4xlO.s was found for the on-site worker. Total PCBs accounted for
approximately 91 % of the projected risk for the on-site worker in Waste Unit Group 3 and were
predominantly found in the Capacitor Testing Lab. Total PCBs occurrences were present in a localized area
in the Capacitor Testing Lab and at spot locations in the Paint Storage Facility, Plumbing Shop and PCB
Storage Area. Hazard Quotient estimates for non-carcinogenic compounds in Waste Unit Group 3 were below
the Hazard Index of 1; therefore, adverse health effects associated with the non-carcinogenic compounds
evaluated are not expected to occur in this area of the Site.
'.
waSte Unit Group #6 consists of one waste unit, the Ross Substation and Capacitor Yard, which is
enclosed by a fence with restricted access. The sum of cancer risk estimates for all three receptors, on-site
worker and hypothetical on-site child and adult, ranged from 8.0E-05 to 2.0E-04. The occurrences of total
PCBs in this Waste Unit Group is comprised of spot locations. Total PCBs accounted for approximately 95%
to 100% of the projected risk for each on-site receptor in this area.
Altl:rough lead was found in Waste Unit Group #6 above background, modeling results from the EPA
Uptake/Biokinetic Model (conducted for children, the most scnsitive indicator) suggested no evidence of
elevated hazard at reported soilleve1s for WUG #6. .
7.2.3.2 Evaluation of Off-Site Risks
The risk to off-sitc residents including adult and child as potential receptors was focused on Waste
Unit Group 7 (Wood Pole Storage A«:a East). This area is located on the southern Site perimeter and is the
only waste unit group that has unrestricted access to off-site residents. The risk was assessed through
exposure by potential recreational use since other routes have not been found to be significant. The lifetime
. cancer risk estimates for both off-site and recreation receptors related to Waste Unit Group 7 range from 1.2E-
06 to < 1.0£-07 which is below EPA's acceptable cancer risk range (fable 5).
Hazard Quotient estimates for non-carcinogcaic compounds in the evaluation of off-site receptors were
below the Hazard Index. of I; therefore, adverse health effects are not expected off-site.
7.2.4 Uncertainty
Major components of the assessment which decreased the certainty of other results were 1) the toxicity
reference values used, and the lack of values for several chemicals; 2) limitations in contaminant concentration
data for soils, ground water, and surface water; 3) the inclusion of concentrations at a level one-half the
detection limit for many chemicals; and 4) the use of a Dumber of assumptions to establish exposure
parameters in computing chemical intakes.
Due to uncertainty in these and other areas, conservative assumptions were made in order to ensure
protection of human health. Cancer and non-canccr risk estimates must be carefully interpreted, particularly
when evaluating noncarcinogenic effects where uncertainty factors of tWo to three orders of magnitude are
used in dose.-response assessments.
Although most parameters addressed and included in the Baseline RA are inexact, all are designed
to be conservative and therefore, are protective of all receptors considered.
_11--1""
-------
Table 5
Estimated Hazard Quotients and Ufetime Cancer Risk, Off-site Recreational Receptors
Operable Unit A
BPA Ross Complex RI
"
Compound
Based on 95"1. UCl for WUG f7
Adult Child
.'. . --.---........--.-.,.... .-,' .....~-.,' .'..
. ~~ ~_......,-_._..__....~. ,~~,--"~"~~-,,,,,,"""''''-' 0. ".~..'.. ."
Hn7nrd Quntient
Ovomium
Copper
lead
Zinc
0.02
0.05
0.05
-------
7.3 ECOLOGICAL RISK ASSESSMENT
The Baseline Ecological Risk Assessment was an evaluation of the potential threats to the environment
from the Site in the absence of any remedial action. It identified potential on or off-site exposures of
environmental receptors iobabiting the area to chemicals of concern, characterizes the toxicological properties
of "indicator" chemicals, and quantifies the extent to which exposures may contribute to ecological risk or
degradation under the conditions defined for the Site.
. .
The terrestrial components of the ecological risk assessment included: (1) identifying "indicator"
chemicals (previously discussed); (2) identifying potential exposure pathways; and (3) identifying biological
habitat and potentially exposed wildlife (or other) receptors. .
The overall approach to both the human health and ecological portions of the baseline risk assessment
are similar, especially in utilizing a Reasonable Maximum Exposure (RME) approach to addressing potential
ecological expOsures. Key differences include: (1) the ecological risk assessment addresses chronic toxicity
(based on available dose-response data, rather than considering carcinogenicity as an endpoint); and (2) several
wildlife iDificator species are ideotified to represem all potentially susceptible receptors. The May 1992
Operable Unit A RI report discusses the physical setting in which pOtential ecological exposures could take
place, including characterization of biological habitat and identification of indicator species and potentially
exposed populations.
For the ecological risk assessment. three key "indicator" species were ideotified, including the
American robin, Raccoon, and Black-tailed deer. These species were selected based 00 criteria intended to
ensure that DO other species are liIce1y to be more exposed than the indicator species, and that they are
representative of the potentially most sensitive species or organisms present at the Site. These criteria include:
sensitivity to cootaminants of concern; habitatioo within C1arlc couoty and potentially the vicinity of the Site;
valued or protected species (e.g., rare or endangered, game species, etc.), to ensure that protected organiSJ;DS
are considered; a mixture of aviaDlm..mnu.li8n species designed to address a variety of life histories and
feeding habits; representativeness of the potential for CODt..minant bioaccumulatioo (addressing predatioo as
a primary feeding habit); and representativeness of local biological communities. No threatened or endangered
species were observed at the Site or adjacent to the site.
7.3.1 Risk Characterization
Results shOWD on Table 6 indicate the total exposure and contribution by individual pathway for the
Baseline Ecological RA. Results are based 00 the 95" uppec confideoce limits (UCL values) by Waste Unit
Group, by teccesb:ia1 ecological receptor, and by "indicator" contamiruant. Similar to the ooo-carcinogenic
analysis of the human health component, when the HQ value is less than one, DO chronic toxicity associated
with Site contaminants is expected. It is conservatively assumed for the purposes of the analysis that all three
indicator species (robin, necooo, deer) could be present at any of the seven Waste Unit Groups of Operable
Unit A.
The results of the exposure assessmeot indicate that the five metals for which HQ values exceeded
one included antimony (Waste Unit Groups 4 and 6), arseaic (Waste Unit Group 4), chromium (Waste Unit
Groups 4 and 7), COppel' (Waste Unit Group 5), and lead (Waste Unit Groups 4, 6, and 7). No threshold
values were exceeded for the blaclc-tailed deer; potential chronic effects could be expected for the robin 001;
for antimony and chromium. while potential chronic effects could be expected for the raccoon oo1y for
arsenic. COpper'. and lead.
6oc1l""'1Aac:
-------
Table 6
Ecological Hazard Quotients by Contaminant, Terrestrial Receptors
Operable Unit A
BPA Ross Complex RI
t.
compou~ ,
Waste Unit Group' 1
~"~;. ,,~~,,:)iN!!!"I!I:!:.!");<;"i'" -"'~r,~'~~~:a;r.I:~""-'-'
Arsenic
Copper
Lead
~
Total HPAHs
Benzo (0) pyrena
Bis (2-EH) phthalate
Pentac:hloroph~
Total PCBs
waste Unit Graup 12
. ~1It""N' :....--.:......,.......:...,~ . ,
Arseric
Copper
Lead
~
Total HPAHs
B;enzo (a) pyrena
Bis (2-EH) phthalate
Pentachlorophenol
Total PCBs
~~~:,~~!.!.~'o.~,!.~",., "
Hsenc
Copper
Lead
me
Total HPAHs
Benzo (a) pyrena
Bis (2-EH) phthalate
Pentachlorophenol
Total PCBs
Total [)ic))cR
waste Unit Group 14
.. '";',,-:,~~''''''''''I,;.~',......;.~\;o,oo.'W'.1 .
Antmonv
Arseric
OYomhn1
Copper
Lead
~
Total HPAHs
Benzo (a) pyrene
Bis (2-EH) phthalate
Pentachlorophenol
Total PCBs
~.... ,............- ."
Jab No. 06737-C1124C1i5
(IOU'-_ROOIJCLw)11L1\ I 4I72J93 I eO
American Robin
." ~:~~~~~~.--
Raccoon
(1'. Iolor)
Black tailed Deer
CO. columblonus)
-...".."" -..,...........-.........,...-.,'
..-........- -.""-' ........-..,.--... ...,
. .'~~:.,~+.. ..~..,~..',~r;:jl!l'.~..I'J:=~II.OI"':'f.'::o.~\0I!~t;-'~1o!....~...,-,(~'~:ot~_",.11,1i.f'I..I~!;ll'#'~:'~' '.~.~,~.~;"""l:!'I:'itri"o~'" ,... ,
0.03
0.02
"""'.";".,' """
0.43
0.33
0.07
0.06
0.01
0.02
<0.01
-------
Table 6
Ecological Hazard Quotients by Contaminant, Terrestrial Receptors
Operable Unit A
BPA Ross Complex RI
. t:orripoU~d
v.:~~,2~:~~..'5,
Arsenic
Copper
lead
anc
Total HPAHs
Benzo (a) PVl'ene
Bis (2~ phthalate
Pentachlorophenol
Total PCBs
American Robin
.f!~ mlgrat"-~'!!'-'H'" .
".: '.:~. ~. ,
0.02
0.07
0.01
0.10
0.02
0.01
0.01
0.05
0.20
wast. Unit Gloup '6
.~iI!,.----~~:;!!:;!t-o"o"r"'''.':''; ';.,
Antinony
Arsenic
Copper
lead
Zinc
Total HPAHs
Benzo (0) PVl'en8
Bis (2-EH) phthalate
Pentachlorophenol
Total PC&
",:,,"'!,":"!<,',.", -.". ,...,
3.02
0.03
0.02
0.08
0.13
0.01
<0.01
0.01
0.05
1.81
waste Unit Gfoup '7
.~ ~ +'!.i'\!I'!':'r".',',
Atseric
CtYomiun
Copper
lead
Zinc .
Total HPAHs
Benzo (a) PVl'en8
Bis (2-&0 phthalate
Pentachlorophenol
Total PC&
:. ""-'"~""'<~0.c5".:.,..:".... ..:.,,::..:.:
40.04
0.01
0.03
0.08
0.01
<0.01
<0.01
0.01
0.11
'~~"'....,..,-,.....,.....__..._,.,-_--."... .'~' ,.,oc.'" ,..'
".,-...,',,,.,"',,""., "...."."
Jab No. 06737~12-4D15
«(OUt.JlaoIJCLW)1a.. I 4fl2I'13 I eI)
Raccoon
(P. Iota"
Black tailed Deer
(0. coIumbIanus)
.._.-. _.'''''",'.....'~
.'. ""'~".-..."-~.__......' ........
':";;.,'
.... 'i ":";:::"'~;;';':'~.;;;;:,.,:~.."",!:"';;'!,~. v",,','
..;:.,."-.--::!:n;",:;".:;;':i\:;-~~.'~',,,,::,
'. .
0.25
1.23
0.29
0.11
<0.01
<0.01
<0.01
<0.01
0.04
0.06
0.11
0.05
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
"".;.~",,".;"'!";!~~~"'f!l!IlIi'r.~il:L~,.........'i::.. :..Z'.:.. """":\.J~ ,.
"', ~""."",~','~')..,' ,J'Io,,:,:., ~ "...;
om
0.44
0.26
2.84
0.13
<0.01
<0.01
<0.01
<0.01
0.34
0.01
0.10
0.02
0.44
0.02
<0.01
<0.01
<0.01
<0.01
<0.01
',~..-r.:;<:!<.4:~o~::::a..~ ~ "::'"~""";":"''''''';';;;'~~~:.O:151oi11''''':::(;o-)': <:P:
QI7 0.04
0.22 0.02
1.11 0.17
0.08 0.01
<0.01 <0.01
<0.01 <0.01
<1J.oI <1J.ol
<1J.ol <0.01
om <1J.ol
-------
The sole organic contaminant which exceeded one for the ecological RA was total PCBs in Waste Unit
Groups 3 and 6. No threshold values were exceeded for the black-tailed deer or raccoon; potential chronic
effects could be associated with exposures to the robin only. It should be noted that there are currently few
or no undisturbed surface soils in these waste unit groups which could provide suitable habitat for robins.
,-
In summary, ecological risk calculations for surface soil metals indicate the potential for chronic
toxicity to indicator species in Waste Unit Group 4 (Sandblast Area). Independent removal actions in
accordance with State of Washington Model Toxies Control Act cleanup criteria were conducted in this area
as well as in Waste Unit Groups 3, 5, and 7 which eliminate the potential ecological risk identified in these
waste unit groups or as in the case of Waste Unit Group 6, provide no suitable habitat now or in the planned
future for these species.
An independent removal action was not conducted in the Top Coat Test Area (a component of Waste
Unit Group #7); however, potential ecological risks associated with surface soils in this Waste Unit are
considered negligible because this area is covered by asphalt pavement and does not provide a suitable habitat
for these species now or in the foreseeable future.
8.0 REMEDIATION GOALS
The results of the baseline risk assessment indicate that no further remedial action is necessary under
CERCLA in 18 waste units in Operable Unit A and the Ellen Davis Trail.
Three waste units, the Wood Pole Storage Area East, the Ross Substation and Capacitor Yard, and
the Capacitor Testing Lab have been identified as requiring further action under CERCLA.
For the Wood Pole Storage Area East, the contaminants of concern are high molecular weight
polynuclear aromatic hydrocarbons (HPAHs) and pentachlorophenol. PCBs are the compounds of concern
in soils in the Ross Substation & Capacitor Yard and at the Capacitor Testing Lab. Based on consideration
of ARARs for this site, the remedial action objectives (RAO or clean up levels) for the compounds of concern
are:
Compounds of Concern RAO Source Soil Clean up Residential Risk
. Level (ppm) at Cleanup Level
Total HPAHs MTCAMethodA I 6.9 X l
-------
under MTCA since unrestricted access exists and they are not located within a recognized industrial area.
Therefore, the residential soil cleanup standards apply to these areas. The Ross Substation and Capacitor Yard
is considered industrial under MTCA since it is a secured area within the borders of a recognized industrial
area. The industrial soil cleanup standard for PCBs is applicable to this area.
-
,
The primary exposure pathway of concern in Operable Unit A is direct dermal contact. Both
residential and industrial soil cleanup standards are protective for this pathway, are within EPA's acceptable
risk range, and are protective of other media.
Actual or threatened releases of hazardous substances for this site, 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.
9.0 DESCRIPTION OF ALTERNATIVES
Nine alternatives were evaluated for soil remediation at the Capacitor Testing Lab, Wood Pole Storage
Area East and the Ross Substation 8£ Capacitor Yard. The general response actions initially considered for
soil remediation alternatives for Operable Unit A included:
.
Alternative A - No Action,
.
Alternative B -Institutional Controls,
8
Alternative C - Excavation with Off-Site Disposal,
.
Alternative D - Asphalt Capping with Institutional Controls,
.
Alternative F - KPEG Dechlorination
.
Alternative G - Soil Washing
.8
Alternative H - BES'P Extraction
.
Alternative I - Ex-Situ Solid-Phase Bioremediation, and
.
Alternative 1 - Thermal Treatment with Off-Site Disposal of Residuals.
Each-alternative is described briefly in the following sections.
9.1 ALTERNATIVE A: NO ACI10N
The No Action altemative is required by the National ContiDgeDcy Plan (NCP) and serves as a
baseline agaiDst which other soil remedial alternatives can be compared. Under this altemative, no remedial
activities would take place. This alternative docs DOt protect the public health or mitigate uoaccertable
environmeDtal risks associated with the contall'lination.
_11--'1.-
-------
9.2 ALTERNATIVE B: INSTITIITIONAL CONTROLS
.
.
This alternative includes the measures to limit or prohibit activities that may interfere with or disturb
contaminated areas and includes long-term monitoring of soils. Measures employed as institutional controls
would include access restrictions, deed restrictions, and land use restrictions. Access restrictions are designed
to prevent unauthorized access to areas where contamination is present and would consist of fencing, signs,
and roadway modifications. Deed restrictions would limit future land use. Land use restrictions would
prohibit disturbance of soil and nearby buildings.
9.3 ALTERNATIVE C: EXCAVATION WITH OFF-SITE DISPOSAL
This alternative involves the excavation of contaminated soils for disposal at an approved landfill.
The excavation would be bacIdi1led with clean earthen fill and compacted.
9.4 ALTERNATIVE D: ASPHALT CAPPING WITH INSTITUTIONAL CONTROLS
'Ibis aftcmative involves the application of a sealed asphalt cap over the contaminatl'Jd area to reduce
potential exposure of humans or the environment to the .contaminAnts. The cap would minimize the leaching
of soil contaminants. The asphalt layer would be of sufficient thiclcness to permit use of the waste unit for
multipurpose storage and would have an impermeability rating as required for landfiU covers. Tbe asphalt
would be sealed to further reduce its permeability and would be appropriately contoured to promote drainage
of non-c:oDtJlmi"At""" storm water to the storm SCWe£. Due to the continued presence of contamiDants,
institutional controls would be implemented. A long-term inspection program would include regularly
scheduled visual examination of the cap surface by qualified persoooe1. Subsidence, buclcling, or craclcing
would trigger maintenance measures. The results of the risk assessment indicated that contamination migration
to air was insignificant. Capping would eliminat... dermal contact. .
9.S ALTERNATIVE F: KPEG (POTASSIUM POLYETHYLENE GLYCn.) DECHLORINATION
The KPEG (potassium polyethyleae glycol) dechlorination process utilizes potassium or other aIJcaIi
metal polyethylene glycolates to degrade cblorioated organics. Excavated contaminated soil is mixed with the
KPEG solution in a heated reactor. When the reaction is complete, the KPEG solution and water is decanted
and the soil is washed with water. Tbe KPEG solution and water are recycled back into the process. KPEG
dechlorination reduces the toxicity of chlorinated contaminants and results in a nontoxic byproduct (EPA,
1989).
After treatment, the soil can be used as clean fill on site. Other .treatment residuals will be handled
properly as hazardous waste, as needed. Tbese residuals will be disposed of according to the specific
requirements for each waste stream.
_I'-'adl.'"
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9.6 ALTERNATIVE G: SOIL WASlflNG
This alternative involves the use of a washing process to remove contaminants from the soil.
Excavated soil is sorted to remove large debris. The soil is then rinsed with the wash solution as the soil is
passed over a series of screens. Contaminants are removed in the wash solution or are concentrated in the
soil fines. Following washing, the treated soil can be used as earthen fill for on-site grading. The
contaminant residual, which may include clays and fines, is sent off site for disposal at an approved RCRA
landfill.
.
.
9.7 ALTERNATIVE H: BES'J'8 EXTRACTION
Basic Extractive Sludge Treatment (BES'P) is a patented process that uses triethylamine to remove
contaminants from the soil. Excavated soil is mixed with the triethylamine, which removes contamin3.nts and
watec from the soil. The triethylamine is separated from the water and cont~minants; it is recycled for reuse
in the extractiOIt process. A small amount of concentrated contaminant residual would remain after treatment,
requiring disposal off site at an approved RCRA landfill. Treated soil can be used as clean earthen fill on site.
9.8 ALTERNATIVE I: EX-SITU SOLID PHASE BIOREMEDIATION
Contaminated soil is excavated and placed in a treatment cell constructed on site. The treatment ceU
would contain a lined enclosure equipped with a leachate collection and retum system, and adding nutrients.
water. supplemental micro-organisms. and oxygen as needed. Treated .soil can be used as earthen fill for
ping on site.
9.9 ALTERNATIVE J: THERMAL TREATMENT WITH OFF-SITE DISPOSAL
Contamiaated soil is excavated and incinerated in a mobile rotary kiln incinerator or fluidized bed
incinerator. Residual ash would be tested and if necessary disposed off-site. It is possible. based on. the
results of the testing. that disposal of residual ash could be OD. site.
9.10 ALTERNATIVES RETAINED FOR DETAILED EVALUATION
Tbe following alternatives were retained for detailed analysis based on the results of the initial
screening.
Wood Pole Storage A1U Btut
.
Alternative A - No Action,
.
Alternative B - Institutional Controls,
.
Alternative C - Excavation with Off-Site Disposal,
.
Alternative D - Asphalt Carping with Institutional Controls.
.
Alternative I - Ex-Situ Solid-Phase Bioremediation.
_1/--'1.'"
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Ross SubstaJion & C4paciJor Yard
.
Alternative A - No Action,
.
AJtemative B - Institutiooal Controls,
"
.
AJtemative C - Excavation with Off-Site Disposal,
.
AJtemative F - KPEG Dechlorination,
.
AJtemative G - Soil WashiDg,
.
AJternative H - B~ Extraction,
.
AJternative J - Thermal Treatment with Off-Site Disposal.
CapadJor Testing lAb
.
AJtemative A - No Action,
.
AJternative B - Institutiooal Controls,
.
Altemative C - Excavation with Off-Sitc Disposal,
.
Altemative F - KPEG DechloriDation,
.
Altemative G - Son Washing,
.
Altemative H - BF..S'P Extraction,
.
Alteroative J - Thermal Treatment with Off-Sitc Disposal.
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives for each waste unit wete compared according to nine criteria as defined and
required by the NCP. The nine criteria are subdivided into three categories: (1) threshold criteria which relate
directly to statutory findings and must be satisfied by each chosen alternative; (2) primary balancing criteria,
which include technical factors; and (3) modifying criteria, which are measures of the acceptability of the
alternative to state agencies and the community.
All alternatives must meet the threshold criteria of overall protection of human health and the
environment and compliance with AltARs. The chart illustrated iD Figure 10 shows the relationship between
the screeoing criteria, the aiDe evaluation criteria, and the role of the criteria during remedy selection.. The
foUowiDg sections .preseat the comparison of alternatives.
.,.
_I,-,""Uoc
-------
Screening CriterIa
NIne EvaluatIon CrIterIa
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Role of Criteria During
Remedy Selection
"Threshold" Factors
"Primary Balancing" Factors
"Modifying" Considerations
Figure 10
Relationship of Screening Criteria
-------
10.1 .COMPARATIVE ANALYSIS FOR WQOD POLE STORAGE AREA EAST
Target Contaminants: HPAHs. PCP
10.1.1 Threshold Criteria
,-
10.1.1.1 Overall Protection of Human Health and the Environment
This criterion measures how the alternative, as a whole, achieves and maintains protection of human
health and the environment.
Alternative A, No Action, does not provide protection to human health or the environment and does
not prevent the migration of contaminants since no remedial activities would take place to reduce exposures
to contaminants.
AI~ve B, Institutional Controls, offers a slightly greater level of protection than Alternative A
through site restrictions designed to prevent exposure to contaminated material.
Alternative C, Excavation with Off-8ite Disposal, offers a higher level of overall protection than
Alternatives A or B, through the eliminAtion removal of CODtamin..~ materials from the Site. ConlBmin..t....t
materials would be transported to an approved landfill for disposal.
Alternative D, Asphalt Capping with Institutional Controls, offers a level of overall protection slightly
higher than Alternative B but lower than AltcnJative C. Alternative D would not remove risks associated with
contamination at the site, but would control risks by preventing exposure to the contaminants, inhibiting future
contaminant migration, and providing long-term monitoring.
Alternative I, Ex-Situ Solid-Phase Bioremediation, offers a level of overall protection comparable to
Altcruative C, but in addition, destroys contaminants to meet regulatory action levels.
10.1.1.2 Compliance with ARARs
Compliance with ARARs is a consideration of bow the alternatives comply with other regulations
explicitly applicable to the site and with those sufficiently relevant and appropriate to warrant inclusion.
There are no ARARs associated with Alternative A since no remedial actions would be taken, ARARs
would not be met. Alternative B wiD comply with MTCA requirements to prevent contact; however, it does
not meet the chemical specific ARARs identified for the site.
AJl contaminated material would be properly transported and disposed under Alternative C; therefore,
ARARs associated with transportation for off-site disposal would be complied with. Alternative D would
comply with MTCA requirements for preventing contact and Alternative I would comply with MTCA cleanup
requirements for residential land use.
Altanatives C, D, and I would comply with the Southwest Air Pollution Control Agency's
(SW APCA) gcaeral standards for maximum air emissions.
Altematives C, D, and I would comply with ARARs. Alternative A does not satisfy the threshold
criteria .because "DO actioo" would not be proteCtive. and therefore, will not be further evaluated.
_I/GanIIII...
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10.1.2 Primary Balancinl!: Criteria
10.1.2.1 Long-Term Effectiveness and Permanence
This criterion evaluates the long-term effectiveness aDd pennanance of alternatives in maintaining
protection of human health and the environment after remedial action objectives have been met.
"
Alternative B, Institutioaal Controls, controls long-term risks by minimizing the potential for
disturbance of contaminated materials. Residual risks to the on-site worlcer will not represent an unacceptable
cancer risk.
Alternative C, Excavation with Off-Site Disposal, has a high degree of long-term effectiveness and
permanence. This alternative minimizes the risks associated with contJllminllltM soils by their removal from
the Site. Residual risk to the on-site worker will Dot represent an unacceptable cancer risk.
Alternative D, Asphalt Capping with IDStitutioaal Controls, would be slightly more effective than
Alternative B but less effective than Alternative C. Under this alteroative, CODtRmiMlnts would be left in place
and a cap would be installed over them. This cap would preveat exposure to the CODtJllmination. The
permanence of Alternative D would depend on the effectiveness of iDstitutional controls and on long-term
maintenance of the cap. Residual risk to the OD-site worlcer will not represent an uDIi'~ble cancer risk.
Alternative I, Ex-Situ Solid-Phase BioremediatioD, offers long-term effectiveness and pcrmaDence
comparable to Alternative C. CoDtaminants would be degraded through treatment. Residual risks would be
compared to Alternative C. .
10.1.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternatives were also evaluated according to their ability to reduce, through treatment, the toxicity,
mobility, or volume of contaminants.
There is no treatment associated with Alternatives B, C, or D.
Only Alternative I, Ex-Situ Solid-Phase BioremediatioD, provides reduction in contaminant mobility,
toxicity, and volume through treatment since contamioaots are destroy~.
I 0.1.2.3 Short-Term Effectiveness
This criterion 8ddresses the effects of the alternative during the COnstructiOD and implementation phase
until remedial action objectives are met. .
Alternative B, Institutional Controls, would not present additioaal short-term risk because
contRm;ntlt~ materials would not be disturbed. Site restrictions would be implemented in about two weeks
and the deed restrictions and other laud use restrictions would take approximately three months to implCIDCIlt.
Alternative C, Excavation witli Off-Site Disposal, prescats more potential for increased short-term
risk to the community. worlcers, and the environment due to the poteDtial exposure to dust geocratcd during
excavation as compared to Alternatives A or B. These risks can be effectively cootrolled using standard dust
suppression mcdlods, personnel protective equipment and through the implementation of a health and safety
_1/--..11.-
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plan. These risks will be eliminated after the implementation of the alternative which is expected to require
eight weeks. This time frame is longer than Alternative A, but less than Alternative B. Measures to control
the risks will be implemented prior to excavation.
"
Alternative D, Asphalt Capping with Institutional Controls, would present a lower short-term risk
than Alternative C. Tbe potential risk would be present only during the spreading of base course materials
over the contaminated surface which may generate a potential exposure to dust; however, this risk can be
effectively controlled. Time to implement this alternative is similar to Alternative B. It will take
approximately two weeks to lay the initial base course thus eliminating the short-term risks. Measures to
control the risk will be implemented before commencing the activities associated with laying the base course.
Alternative I, Ex-Situ Solid-Phase Bioremediation, presents a higher level of potential short~term risk
to the community, workers and the environment associated with exposure to dust from handling soil during
treatment over time as compared to Alternative C. Potential short-term risks can. be effectively controlled.
With treatment time of approximately one year, the time to complete remediation and reduce short term risks
is considerably longer than the other alternatives. Measures ~o control these risks will be implemented prior
to excavating Contaminated soil.
10.1.2.4 Implementability
This criterion addresses the technical and administration feasibility of constnlcting, operating, and
maintaining a remedial action alternative. .
. Alternative B is slightly difficult to implement due to the need for deed restrictions and land-use
restrictions .
Alternative C, Excavation with Off-Site Disposal is more difficult to implement that Alternative B
because approval for landfill disposal will be required.
Alternative D, Asphalt Capping and Institutional Controls, is more difficult than Alternative B but
similar to Alternative C. Labor and equipment for installation of the cap are readily available.
Alternative I, Ex-Situ Solid-Phase Bioremediation, is more difficult to implement than the other
alternatives considered. Treatability studies would be necessary to confirm degradation levels. The labor and
equipment to perform bioremediation is readily available.
10.1.2.5 Cost
Cost is another criterion by which candidate alternatives are compared. Costs in this case are
measured as direct capital costs. The direct capital costs for the remedial alternatives at the Wood Pole
Storage Area East for 3,700 cubic yards of contaminated material is as follows:
_1/.........s1.""
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Alternative
Direct Capital
Cost
Alternative B -
Institutional Controls
$20,520 .
",
Alternative C - Excavation with Off-5ite Disposal'
$513.660
Alternative D - . Asphalt Capping with Institutional
Controls
$396.340
Alternative H - Ex-5itu Solid-Phase Bioremedi«tion
Tier 1: EabaDc:ed Bioremediation
Tier 2: EabaDc:ed Bioremediation.
Gravel Cap. Institutional Controls
Tier 3: -EabaDc:ed Bioremediation,
Asphalt Cap. Institutional Controls
$450.000
$482,120-$586,520
$5 10,520-$870.520
Altemative D. Asphalt Capping with Institutional Controls. is more costly than Altemative B, but
significantly less costly than Alteraative C.
Altemative I. Ex-5itu Solid-Phase Bioremediation. costs more than the Institutional Controls alternative and
costs less than Alternative D.
10.1.3 Modifvin2 Criteria
Modifying criteria are used in the final evaluation of the remedial alternatives. and include comment from
Ecology and from the public.
10.1.3.1 State Acceptance
The State ofWasbington concurs with the selected remedy and comments received from Ecology bave been
incorporated into this Record of Decision.
10.1.3.2 Community Ac:c:eptanc:e
Based on the COJDJDel1ts received during the public review period and at the public meeting. the public
accepts the prefened altemative.
10.2 ROSS SUBSTATION AND CAPACITOR YARD
Target CoIUD1tlinant: PCBs
10.2.1 Threshold Criteria
10.2.1.1 Overall ProtectioD of Human Health aad the Eoviroameat
Altemative A. No ActioD. does not provide protectiOD to human health or the cDvironmeat since nv
'Off-sitc incincralion is elimiaaIed &om coasidentioa bccauIe die eoaI8miaaled IOiI - dcIcnIIiDcd DOt 10 be . RCRA WuIC.
4iIc""""',-
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remedial activities would take place.
Alternative B, Institutional Controls, offers greater levels of protection as compared to Alternative
A, through site restrictions designed to prevent exposure to contaminants.
..
Alternative C, Excavation and Off-Site Disposal, offers a higher level of protection as compared to
A and B because contaminants are removed from the site. The contaminated soil would be treated to meet
applicable land disposal requirements.
Alternative F, KPEG Dechlorination, offers a high level of overall protection of human health and
the environment, comparable to Alternative C. The KPEG process permanently degrades PCBs and leaves
a treatment residual in the soil, but this residual, polyethylene glycol bipheynyl ether is considered to be non-
toxic. '
Alternative G, Soil Washing, provides a lower level of protection of human health and the
environment th!n Alternatives C and F because Alternative G is not expected to achieve comparable redUctiOD
in contamiuant levels.
Alternative H, BEST, offers a level of ovc:tall protection comparable'to Alternatives C and F.
Altemative J, Thermal Treatment with Off-Sitc Disposal of Residuals, offers the same level of overall
protection as Alternative C. The process geocrates an ash that would be sent to a RCRA landfill for cfisposaI.
10.2.1.2 Compliance with ARARs
There are DO ARARs associated with Alternative A. Since DO remedial action would be taken,
ARARs would not be met. Alteroalive B will comply with MTCA teql1irements to prevent contact; however,
it does not meet the chemical specific ARARs identified for the site.
All dangerous wastes and treatment residuals that are dangerous wastes would be properly transported
and disposed under Alternatives C, F, G, Hand J; therefore, ARARs associated with transportation and
disposal would be complied with. Alternatives C, F, G, H and J would comply with MTCA clean up
requiremcnts for industrial land use.
Alternatives C, F, G, H, and J would meet requirements for disposal of PCBs at chemical waste
landfills.
Alternatives C, F. G, Hand J would comply with the Southwest Air PoUution Control Agency's
(SW AJ'C,A) general standards for maximum air emissions.
Alternatives F and G would comply with thc state waste discharge program, since waste watcr
discharges would meet all effluent guidelines.
In summary, Alternative A would not meet ARARs and cannot be selected as the remedial alternative.
Altenlatives C, D, F, G, H, and J would comply with ARARs. Since Alternative A does not satisfy the
threshold criteria of protectivencss,it will not be further evaluated.
UocIl--IAoe
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10.2.2 Primary Balancin!~ Criteria
10.2.2. I Long-tenn Effectiveness
Alternative B, Institutional Controls, is more effective than the No Action alternative. Site restrictions
would minimize the potential for disturbance of contaminated soils and long-term monitoring would provide
information relating to changes in contaminant concentratioDS. This alternative will not represent aD
unacceptable cancer risk to the on-site worker.
. .
Alternative C, Excavation with Off-Site Disposal, has a high degree of long-term effectiveness and
permanence. This alternative eliminates the rislcs associated with contaminated soils by excav~ting and
transporting soils off site to a TSCA landfill. Residual rislcs to the on-site worker will not represent an
unacceptable cancer risk.
Alternative F, KPEG Dechlorination, has a comparable level of long-term effectiveness and
permanence to Alternative C. The riskS associated with contaminants are reduced by permanent degradation.
Residual risks to the on-site worker will not represent an unacceptable cancer risk.
Alternative G, Soil Wasbiilg, provides a lower level of long-term effectiveness and permanence than
Alternatives C and F. Alternative G requires the addition of institutional controls to manage the residual risks.
This is required because soil washing is not expected to reduce the COD~minant levels below industrial soil
clean up levels. Residual risks to the on-site worker will not represent an unacceptable cancer risk.
Alternative H, BES'fG, would provide long-term effectiveness and permanence comparable to
Alternatives C and F. Alternative H minimizes the rislcs associated with on-site con~mination through
removal and treatment of con~minSited soils. Residual risks to the on-site worker will not represent an
unacceptable cancer risk.
The long-term effectiveaess and permaneuce of Alternative J, Thermal Treatment with Off-Site
Disposal of Residuals, would be similar to that of Altematives C, F and H. Alternative 1 would minimize
the risks associated with contaminated soils through removal and incineration of contaminated material. If
necessary, the residual from the incinerator would be placed in a TSCA-approved landfill.
10.2.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
AItemative B, Institutioaal Controls, and Alternative C, .Excavation with Off-Site Disposal, would
not involve treatment of the coD18miDated materials, so DO reduction in mobility, toxicity, or volume would
be achieved using these alternatives.
Alternative F, KPEG Dechlorination, offers a level of reduction of mobility, toxicity, and volume
through treatment of on-site contaminaats. Since the contaminants are degraded to non-toxic compounds, this
alternative provides a higher level of mobility, toxicity, and volume reduction overall on site.
Alternative G, Soil Washing, offers a lower level of reduction of mobility, toxicity, and volume
through treatment than F. This alternative is DOt expected to achieve the cleanup standards, therefore
institutional controls must be implemented.
Alternative H, BEST, offers a level of mobility, toxicity, and volume reduction comparable to
Altematives C and F. The process generates a concentrated liquid containing the contaminants removed from
4ioc:.,.....Uoc
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the soil, which would be sent off site for incineration.
..
Alternative J, Thermal Treatment with Off-Site Disposal of Residuals, offers the same level of
mobility, toxicity, and volume reduction as Alternatives C, F and H. The contaminated soil is incinerated,
thus destroying the contaminants. The ash generated by thermal treatment would be SeDt to a RCRA landfill
for disposal.
10.2.2.3 Short-Term Effectiveness
Alternative B, Institutional Controls, is comparable to Alternative A and would not result in added
short-term risk. It would take approximately one week for installation of site restrictions and about three
months to implement deed restrictions and land-use restrictions.
Alternative C, Excavation with Off-Site Disposal, may involve short-term risk to on-site workers, the
community, and the environment from exposure to dust generated during the excavation of soil as compared
to Alternatives A and B. These risks can be effectively controlled using standard dust suppression methods,
personnel protective equipment and through the implementation of a health and safety plan. These risks will
be eliminated after the implementation of the alternative which is dependent on scheduling shutdowns of the
Ross Substation & Capacitor Yard. Each shutdown would last one week with four shutdowns required to
complete the excavation. This altcmative would take longer to implement than alternative A or B. Measures
to control risks would be in place prior to excavation. .
Altemative F, KPEG DechloriDation, presents a slighdy higher level of potential short-term risk than
Alternative C. due to banding of conUlm;..,.t"'" soil for treatment. Short-term risks can be effectively
minimized by the use of appropriate controls. but would be present until the full implementation of the
alternative. This alternative would take approximately 12 weeks longer than Alternative C. Measures to
control risks would be in place prior to excavation.
Altemative G, Soil Washing. presents a sligbdy higher level of potential risk as compared. to
Altemative F. Potential risk may be increased from exposure to dust during handling of soil
after treatment. Short-term risks can be effectively controlled. Short-term risk will be prescot until the
alternative is fully implemented. which will take 12 weeks longer than Alternative C. Measures to control
risks would be in place prior to excavation.
Altemative H, BESP Extraction. is comparable to Alternative F in short-term effectiveness.
Although there would be potential increased risks to the community, workers, and the environment during
excavation and treatment due to exposure to dust, these could be effectively controlled. Like KPEG, this
altemative takes approximately 12 weeks to complete soil treatment after excavation. Short-term risks will
be eliminated after complete implementation of the alternative. Measures to control risks would be in place
prior to excavation.
The sbort-term effectiveness of Alternative J, Thermal Treatment with Off-8ite Residual Disposal,
would be similar to that of Alternatives F and H. Potential increased risks to the community. workers, and
the environment during excavation and handling can be effectively controlled by using appropriate measures.
Risk associated with the treatment process would be minimal because incineration offers high destructioD rates
and is subject to stringent emission control standards. This alternative would take 18 weeks longer than
Alternative C to implement. Short-term risks would be completely removed after implementation. Measures
to control risks would be in place prior to the start of excavation.
_1/--1.'"
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10.2.2.4 Implementability
Alternative B is slightly difficult to implement due to the need for deed and land-use restrictions.
Alternative C is more difficult to implement than Alternative B. This waste unit is actively used for
power distribution and therefore, scheduling activities within this area is limited due to operational constraints.
BPA has excavated and disposed of contaminated soils from a number of similar sites. BPA has a trained
worle force, standardized procedures and the necessary equipment, readily available to implement this
alternative.
Alternative F is more difficult to implement than Alternative B. This alternative has 'the same
limitations as Alternative C, plus there is the nced for treatability studies.
Alternative G may be more difficult than Alternative F due to the nced for long-term institutional
controls. TheSe institutional controls are required to ~ the long-term risks, since this alternative is not
expected to achieve the cleanup standards.
Alternative H is comparable to Alternative F. Treatability studies would be necessary and advance
scheduling would be required to mobilize the BES'P proCessing equipment.
Alternative J, Thermal Treatment with Off-Site Disposal of Residuals, is more difficult to implemeDt
than Alternatives F and H. Advance scheduling of incineration equipment would be necessary and a test bum
mUst be conducted. Off-gas from the incinerator would require treatment or monitoring to ensure compliance
with air poUution standards.
10.2.2.5 Cost
The estimated cost of each soil cleanup alternative, based on the direct capital costs for remediating
1,196 cubic yards of contaminated material in the Ross Substation and Capacitor Yard fonows:
Alternative
Direct Capital
Cost
AltcrDative B - Iastitutional Controls
$0
AltcrDative C - Excavation with Off-Site Disposal
$447,380
Altcmative G - Soil Washing
SSS9,030
$48S ,580
AltcrDative F - KPEG Dechlorination
Altemative H - BEST Extraction
$650,180
Alternative J - Thermal Treatment with Off-Site
Disposal of Residuals
$812.630
Alternative B bas the lowest cost of all the other alternatives exclusive of the No Action alternative.
060c1/--1..-
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Costs for Alternatives C, F, G and Hare Comparable. Alternatives C and H includes long-term
institutional controls required for remediation to industrial cleanup levels.
Alternative J, Thennal Treatment with Off-Site Disposal of Residuals, has the highest overall cost.
.
10.2.3 Modifvinl!: Criteria
10.2.3.1 State Acceptance
The State concurs with the selected remedy and comments received from Ecology bave been
incorporated into this Record of Decision.
10.2.3.2 Community Acceptance
Based on the comments received during the public review period and at the public meeting, the public
accepts the proposed alternative.
10.3
CAPACITOR TESTING LAB
Target Contaminant: PCBs
10.3.1 Threshold Criteria
10.3.1.1 OveraU Protection of Human Health and the Environment
Alternative A, No Action, does not provide protection to human health or the environment since no
remedial activities would take place.
AIteruativc B, Institutional Controls, offers greater levels of protection as compared to Alternative
A. through site restrictiODS designed to prevent exposure to contaminants.
Alternative C, Excavation and Off-Site Disposal, offers a higher level of protection as compared to
A and B because contaminants are removed from the site.
Alternative F, KPEG DecbloriDation, offers a high level of overall protection of human health and
the environment, comparable to AItcmative C. The KPEG process permanently degrades PCBs and leaves
a treatment residual in the soil, but this residual, polyethylene glycol bipheynyl ether is considered to be Don-
toxic~
Alternative 0, Soil Washing, provides a lower level of protection of human health and the
environment than Alternatives C and F because Alternative G is not expected to achieve comparable reduction
in contaminant levels.
Alternative H, BEST, offers a level of overall protection comparable to Alternatives C and F.
Alternative J, Thermal Treatment with Off-Site Disposal of Residuals, offers the same level of overall
protection as Alternative C, F. and H. The process generates an ash that would be sent to a RCRA landfill
for disposal.
UcIl.-.lIAoc:
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10.3.1.2 Compliance with ARARs
There are no ARARs associated with Alternative A since no remedial action would be taken. ARARs
would not be met. Alternative B will comply with MTCA requirements to prevent contact; bowever, it does
not meet the cbemical specific ARARs identified for the site.
-.
All dangerous wastes and treatment residuals that are dangerous wastes would be properly
transported and disposed under Alternatives C, F, G, Hand J; therefore, ARARs associated with
transportation and disposal would be complied with. Alternatives C, F, G, Hand J would comply with
MTCA clean up requirements for residential land use.
Alternatives C, F, G. H, and J would meet requirements for disposal of PCBs at cbemical waste
landfills. Alternative J would meet requirements for PCB incineration units.
AltematiYes C, F, G. Hand J would comply with the Southwest Air Pollution Control Agency's
(SW APCA) general standards for maximum air emissions.
Alt.ematives F and G would comply with the state waste discharge .program, since waste water
discharges would meet all effluent guide1iDes.
Alternatives C, F, G, H, and J would comply with ARARs. Since Alternative A does not satisfy the
threshold criteria of protectiveness it will not be further evaluated.
10.3.2 Primarv Balancin2 Criteria
10.3.2.1 Long-term Effectiveness
Alternative B. Institutional Controls, is more effective than the No Action alternative. Site restrictionS
would minimi7.e the potential for disturbance of CODf1Iminllted soils and long-term monitoring would provide
information relating to changes in contaminant concentrations. Residual risks to the oD-site worker would not
represent an uoacceptable cancer risk.
Alternative C, Excavation with Off-Site Disposal. bas a high degree of long-term effectiveness and
permanence. 'Ibis altemative ~iminlltes the risks associated with contaQlinllted soils by excavating and
transporting soils off site to a TSCA landfill. . Residual risks to the on-site . worker would not represent an
uoacceptable cancer risk.
Alternativc F. KPEG DechloriDation, bas a comparable level of long-term effectiveness and
permanence to Alternative C. Residual risks to the oo-sit.e worker would not represent an unacceptable cancer
risk.
Alternative G, Soil Washing, provides a lower level of long-term effectiveness and permanence tban
Alternatives C and F. Alternative G requires the additiOD of institutional controls to manage the residual rislcs.
'Ibis is required because soil washing is Dot expected to reduce the contaminant levels below residential soil
clean up levels. Residual risks to the on-sit.e worker would not represent an unacceptable cancer risk.
Alternative H. BES"P, would provide long-term effectiveness and permanence comparable to
Alternatives C and F. Alternative H minimizes the risks associated with on-site contamination through
removal and treatment of contaminated soils. Residual risks to tbe on-sit.e worker would not represent an
Ucll--'t.-
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unacceptable cancer risk.
The long-term effectiveness and permanence of Alternative J, Thermal Treatment with Off-Site
Disposal of Residuals, would be similar to that of Alternatives C, F aod H. Alternative J would minimize
the risks associated with contaminated soils through removal and incineration of contaminated material. If
necessary,the residual from the incinerator would be placed in a TSCA-approved landfill.
10.3.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative B, Institutional Controls, and Alternative C, Excavation, would not involve treatment of
the contaminated materials, so no reduction in mobility, toxicity. or volume would be achieved using theSe
alternatives. .
Alternative F, KPEG Dechlorination, offers a level of reduction of mobility, toxicity. and volume
through treatment of on-site contaminants. Since the contaminants are degraded to nOD-toxic compounds, this
alternative provides a higher level of mobility, toxicity. and volume reduction overall on site.
Alternative G. Soil Washing, offers a lower level of reduction of mobility, toxicity, and volume
through treatment than F. This alternative is not eJtpccted to achieve the residential cleanup standards,
therefore institutional controls must be implemented.
Alternative H, BEST, offers a level of mobility, toxicity. and volume reduction comparable to
Alternatives C and F. The process generates a concentrated liquid containing the contaminants removed from
the soil. which would be sent off site for incineration.
Alternative J, Thermal Treatment with Off-Site Disposal of Residuals, offers the same level of
mobility. toxicity, and volume reduction as Alternatives C, F and H. The contaminated soil is incinerated,
thus destroying the contaminants. The ash generated by thermal treatmczt would be sent to a RCRA landfill
for~. .
10.3.2.3 Short-Term Effectiveness
Alternative B, Institutional Controls would not result in ad~ short-term risk. It would take
approximately one wcelc: for installation of site restrictions and about three months to implement deed
restrictions and laud-use restrictions.
Alternative C, Excavation with Off-Site Disposal. may invol~short-term risk to on-site workers. the
community. and the environment from eJtposure to dust generated during the eJtcavation of soil as compared
to Alternatives A and B. These risks can be effectively controlled using standard dust suppression methods.
personnel protective equipment and through the implementation of a healtb and safety plan. These risks will
be elimilUlltM after the implemcztation of the alternative. This altemative would take longer to implement than
alternative A or B. Measures to control risks would be in place prior to eJtcavation.
Alternative F. KPEG Dechlorination. presents a slightly higher level of potential short-term risk than
Alternative C, due to banding of COPplin.tM soil for treatment. Short-term risks can be effectively
minimized by tbe use of appropriate controls. but would be present until the fuU implementation of the
alternative. This alternative would take approximately 12 weeks longer than Alternative C. Measures to
control risks would be in place prior to eJtC8vation.
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Alternative G, Soil Washing, presents a slightly higher level of potential risk as compared to
Alternative F. Potential risk may be increased during from exposure to dust during handling of soil
after treatment. Short-term risks can be effectively controlled. Short-term risk will be present until the
alternative is fully implemented, which will take 12 weeks longer than Alternative C. Measures to control
risks would be in place prior to excavation.
..
Alternative H, BES'P Extraction, is comparable to Alternative F in short-term effectiveness.
Although there would be potential increased risks to the community, worlc:ers, and the environment during,
excavation and treatment due to exposure to dust, these could be effectively controlled. Like KPEG, this
alternative takes approximately 12 weeks to complete soil treatment after excavation. Short-term risks will
be eliminated after complete implementation of the alternative. Measures to control risks would be in place
prior to excavation. '
The short-term effectiveness of Altenaative J, Thermal Treatment with Off-Site Residual Disposal,
would be similar to that of Alternatives F and H. Potential increased risks to the community, worlc:ers, and
the environment during excavation and handling can be effectively controlled by using appropriate measures.
Risk associated with the treatment process would be minimal because incineration offers high destruction rates
and is subject to stringent emission control standards. This alternative would take 18 weeks longer than
Alternative C to implement. Short-term risks would be completely removed after implementation. Measures
to control risks would be in place prior to the start of excavation.
10.3.2.4 Implemeotability
Alternative B would be not be difficult to implement.
Alternative C is more difficult to implement than Alternative B. This waste unit is actively used for
pnwer distribution and therefore, scheduling activities within this area is limited due to operational constraints.
BPA has excavated and disposed of coutJaminat..n soils from a number of similar sites. BPA bas a trained
work force, standardized procedures and the necessary equipment readily available to implement this
alternative.
Alternative F is more difficult to implement than Alternative B. This alternative has th'e same
, limitations as Alternative C, plus there is the need for treatability studies.
Alternative G may be more difficult than Alternative F due to the need for long-term institutional
controls. These institutional controls are required to manage the long-term risks, since this alternative is not
expected to achieve the resideotial cleanup standards.
Alternative H is comparable to Alternative F. Treatability studies would be necessary and advance
scheduliDg would be required to mobilize the B~ processing equipment. '
Alternative J, Thermal Treatment with Off-Site Disposal of Residuals, is more difficult to implement
than Alternatives F and H. Advaaec schedu1ing of incineration equipment would be necessary and a test bum
must be conducted. Off-gas from the incinerator would require treatment or monitoring to ensure compliance
with air pollution standards.
10.3.2.5 Cost
The estimated cost of each soil cleanup alternative, based on the present worth of the initial capital
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cost and the long-tenn operating and maintenance. costs for remediating 68 cubic yards of contaminated
material in the Capacitor Testing Lab follows:
Alternative
Direct
Capital Cost
$2,800
$35,560
$108,050
$70,120
$95,900
$100,300
Alternative B - Institutional Controls
Alternative C - Excavation with Off-Site Disposal
Alternative F - KPEG Dechlorination
Alternative G - Soil Washing
Alternative H - BEST Extraction
Alternative J - Thermal Treatment with Off-Site
Disposal of Residuals
Alternative B has the lowest cost of all the other alternatives.
. Costs for Alternatives C, F, G and H are comparable. Alternatives C and H includes long-term
institutional controls required for remediation to industrial cleanup levels.
Alternative J, Thermal Treatment with Off-Site DispoSal of Residuals, has the highest overall cost.
10.3.3 ModifyinS! Criteria
10.3.3.1 State Acceptance
The State concurs with the selected remedy and comments received from Ecology bave been
incorporated into this Record of Decision.
10.3.3.2 Community Accc:ptaDce
Based on the comments received during the public review period and at the public meeting, the public
accepts the proposed alternative.
11.0 SELECTED REMEDY
11.1 KEY ELEMENTS OF SELECTED REMEDY FOR WOOD POLE STORAGE AREA EAST
Based upon consideration of the requirements of CERCLA, the detailed analysis of the alternatives
using the Dine criteria, and public comments, the most appropriate remedy for the Wood Pole Storage Area
East is AIteruative I, Ex-Situ Solid-Phase Bioremcdiation with cohancements. The contAminants of concern
in the Wood Pole Storage Area East arc HPAHs and ~.bloropheool. Tbe soil cleanup levels for these
compounds are 1 ppm and 8 ppm, respectively. The estimated volume of contamination is 3,700 cubic yards.
This alternative is preferred because it best achieves the goals of the evaluation criteria in comparison
to other alternatives. This alternative was selected because it employs an innovative technology. It provides
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on-site t: :Zlent with permanent reduction in the toxicity, mobility and volume ~f the soil contamination and
reduces contaminants to levels that are protective of human health and the environment.
""1'''''1--
The selected remedy would be implemented as follows:
.,
A treatability study would be performed on samples of contaminated soil to design the
treatment regimen and refine treatment time estimates. The treatability study needs to
determine the treatment cell size, depth, microbes and oxygen concentrations. Area required
will depend on the DUmber of lifts of treatment which is directly related to the time required
to complete remediation as determined by the treatability studies.
.
Contaminated soil is excavated and placed in an aboveground treatment cell.
.
If a biotreatment cell is coDSttUcted. it would consist of an earthen benned area lined with
- polyethylene and layered with six inches of sand. Runon controls will consist of berms to
divert water around rather than through the treatment cell. Runoff controls will consist of
berms to divert water to one or more sumps. Water is collected in these sumps and pumped
to a nearby storage taDk. Water in the tank will be reapplied to the soil treatment area as
required to maintain soil moisture content within prescribed limits. . It may be treated and
discharged to the sanitary sewer, pending permits.
.
Soils which exceed the residential soil clean up standard for total carcinogenic HPAH of 1.0
mg/kg (MTCA Method A) or for pentachlorophenol of 8 mglkg (MTCA Method B) will be
excavated and treated.
.
The soil is treated with nutrients, and any necessary additives as determined by the
treatability studies. A leachate system is used to irrigate the soil in the treatment cell.
Oxygen required to maintain aerobic conditions can be supplied by adding hydrogen
peroxide to the irrigation water, through forced air piping, or by tilling the soil. To further
ensure that the contamiDants arc reduced to the lowest possible levels, an etbanoUwatcr
solution will be used to enhance bioremediation of organic compounds in the soil. The
ethanol solution is used to eusu1'e the release of organic chemical from the soil to provide a
nutrient source for the microorganisms. In addition to this enhancement, ultraviolet lights
will be used to aid in the degradation of the organic compounds of concern. Wave lengths
have been chosen to provide the maximum degradation potential for the chemicals.
.
Soil samples arc collected from the treatment cell for chemical and biological monitoring of
soil conditions in accordance with the treatmeot and monitoring schedule.
.
Confirmatory soil sampling of the excavation is performed to ensure that all soil which
exceeds resideotial soil clean up levels has been removed.
.
After the remediation is complete the treatment cell will be dismantled and scrapped. If aftcc
treatment the chemical residual levels in the soil exceed the primary cleanup goal of 1 ppm
(HPAHs) and 8 ppm (pentacblorophenol), the soil will be returned to the storage yard and
a determination will be made as to which type of cap should be implemented to contain the
remaining contNDinatioD as shown in Table 7.
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.
Table 7
Preferred Altemative Tier
Wood Pole Storage Area East
Operable Unit A ROD
8PA Ross Complex
PrImary Cleanup Goal ,
Prefetred Alternative tier Capital Cost
HPAH PCP
fief 1: Enhanced Bioremec:liotion 1ppm 8ppm S45Q.ooJ
TIer 2: Enchanced Bioremediotion with
nstalation of Gravel Barrier on Soil 1-23ppm 8-126ppm $482.120 to S586.5202
and nstitlltional Controls
fief 3: Enc:hanCed Bioremediation with
CAP lnstaGation on Soil and > 23 ppm > 126ppm $S 10.520 to S870.520 a
nstitutional Controls
'- The dearAJP level for HPAHs. 1 ppm. is the remedial action objective and 23 ppm is the Ix10-4ris1c
level for the Gn-$ite worker. The dean up level for PCP. 8 ppm. is the remedial action objective
and 126 ppm represents a 1 x 10-4ris1c level for the on-Ste worker.
2 - Cast range is based on a six inch gravel cap covemg 1ar. to 100'1. of the Wood Pole Storage Alea and $20.520
for instiMional controls.
a - Cast range is based on a foU' nch asphalt cop covering ;ar. to 100'1. of the Woad Pole Storage Alea and
$20.520 for institutional controls.
Jet> No. 06737.oi2415
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Laboratory testing will be undertaken throughout the course of the bioremediation project to monitor
contaminant levels in the treated soils. Progress of enhanced bio"remediation toward the targeted remediation
goals will be assessed at the end of the first summer session (approximately four months). If after four
months, contaminant concentrations are continuing to exhibit a reduction in concentration, bioremediation will
continue. However, if contaminant concentrations over time represent static conditions which suggest a
treatability limitation, a determination will be made to select a tiered preferred alternative as shOWD in Table
10. The tiered alternatives are based on the technical ability of bioremediation to achieve the soil cleanup
levels of I ppm for HPAH and 8 ppm for PCP. The rationale for the tiered approach allows for flexibility
in using an innovative treatment technology succeeded by optional altcmatives to achieve the soil cleanup
standards that will be protective of human health and the environment and be cost-effective. If the Tier I
cleanup levels can not be achieved using enhanced bioremediation, then either Tier 2 or Tier 3 will ~ selected
as the optional preferred alternative. The selection of either Tier 2 or 3 will be based on the achievable soil
cleanup levels for HPAHs and PCBs. Tier 2 involves the installation of a gravel barrier on the soil with
institutional controls. Tier 3 involves the installation of an asphalt cap with institutional controls. Table 10
presents the capital costs related to eacb tier.
11.2 KEY ELEMENTS OF SELECTED REMEDY FOR ROSS SUBSTATION & CAPACITOR YARD
Based upon consideration of the reqUirements of CERCLA, the detailed analysis of the aIterDatives
using the nine criteria, and public comments, the selected remedy for the Ross Substation & Capacitor Yard
is Alternative C, Excavation with Off-Site Disposal. The compound of concern iIi. the Ross Substation and
Capacitor Yard soils is PCBs and the industrial soil clean up level is 10 ppm. The estimated volume of
contamination is 1,196 cubic yards.
This alternative is preferred because it best meets the evaluation criteria as compared to the other
alternatives. It can be readily implemented and is protective of bum an health and the environment. The risks
posed by the contaminated soil would be addressed by removal of the soil from the Site.
The selected remedy would be implemented as follows:
.
The Ross Substation & Capacitor Yard is scheduled for sequenced shutdowns in sections, to
facilitate ongoing power distribution.
.
Contaminated soil is excavated, tested and hauled to a TSCA-approved landfill.
.
Soil sampling and testing is performed in each excavation to confirm that the cleanup
standards have been achieved. Clean fill will then be placed in the excavation.
.
Because the area is fenced and isolated from any nearby residential areas and likely to remain
an industrial site, cleanup will be to industrial standards. In accordance with MTCA Method
A requirements for industrial areas, fencing and deed restrictiODS will be maintained after
cleanup.
11.3 KEY ELEMENTS OF .SELECTED REMEDY FOR THE CAPACITOR TESTING LAB
Based upon consideration of the requirements of CERCLA, the detailed analysis "f the alternatives
using the nine criteria and public comments, the selected remedy for the Capacitor Testing Lab is Alternative
C, Excavation with Off-Site Disposal. The compound of concern in the Capacitor Testing Lab is PCBs and
the soil cleanup level is I ppm. The estimated volume of contaminated soil is 68 cubic yards.
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This alternative is preferred because it best'meets the evaluation criteria as compared to the other
alternatives. (t can be readily implemented and is protective of human health and tbe environment. The risks
posed by the contaminated soil would be addressed by removal of the soil from the Site.
The selected remedy would be implemented as follows:
.
Contaminated soil is excavated, tested and hauled to a TSGA-approved landfill. Tbe
estimated volume of soil to be removed was 68 cubic yards.
.
Soil sampling and testing is performed in each excavation to confirm that the cleanup
standards have been achieved. Clean fill will then be placed in the excavation.
.
Cleanup of PCB contaminated soils will be to residential standards.
12.0 STATUTORY DETERMINATION
BPA and EPA's primary rcspoosibility under CERCLA. is to eosure that the selected remedy will
protect human bealth and the eovUoament. Additiooally, Section 121 of CERCLA, as ameoded by SARA,
establishes several other stalUtory requirements and preferences. These specify that, whco complete, the
selected remedy must comply with applicable and relevant or appropriate covironmcotal standards established
under federal and state eoviroamentallaws unless a waiver is justified.
The selected remedy must also be cost-effective and utilize permanent solutions and alternative
treatment tecboologies or resource recovery technologies to the maximum extent practicable. Tbe remedy
should reprcscnt the best balance oftradeoffs among the alternatives with respect to pertinent criteria. Fmally,
the statute includes a prefetcoce for remedies that employ treatment that permanently and significantly reduce
the volume, toxicity, or mobility of hazardous wastes as their principal elemenL
The selected remedies for the contaminated soil at the Wood Pole Storage kea East and the Ross
Substation and Capacitor Yard and the Capacitor Testing Lab meet the statutory requirements.
12.1 PROTECTION OF HUMAN HEALTIi AND THE ENVIRONMENT
The selected remedy will. protect hUIDaD health and the environmcot through removing contaminants
from the site and destroying CODhlnift"ftt~ until the remaioiog levels aie protcc:tive of human health and the
enviroamcot. PCBs in soils Will be removed from the Ross Substation and Capacitor Yard and disposed off-
site. Contaminants, HPAHs and peotacblorophenol. in the Wood Pole Storage Area East will be degraded
through a bioremediationprocess. Engineering controls will be utiliz.cd during excavation and bioremediation
to eliminate the potcotial for exposure to dust. Sampling and analysis win be conducted foUowiDg excavation
and duriDg the bioremediation process to eosure that contaminant levels arc either removed or are below levels
that are protedive of human health ud the environment. There win be no adv~ effects on buman bealth
and the environmcot caused by coostruction and implementation of the selected remedies.
12.2 COMPUANCE wrm ARARs
The selected remedy of excavation and off-site disposal in the Ross Substatioo and Capacitor Yard
and the Capacitor Testing Lab and bioremediation in the Wood Pole Storage Area East will comply with the
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ARARs presented in the following list.
.
Requirements of Washington Model Toxies Control Act (Initiative 97) for clean up of hazardous waste
sites, Chapter 70.105 RCW, as codific:d in Chapter 173-340 WAC.
.
General emission standards under WAC 173-«X>-040 for visible emissions, fugitive emissions and
emissions of air contaminants which are detrimental to persons or property;
-.
.
Ambient source impact levels established under WAC 173-460-070 for new sources of toxic air
pollutants, including sites subject to the Model Toxics Control Act;
.
Performance requirements under WAC 173-460-040, WAC 173-460-060 and Section 400-100 of the
General Regulations for Air Pollution Sources of the Southwest Air Pollution Control Authority.
.
Federal bazardous waste transportation regulations, Title 49 CFR Parts 171 and 172.
12.2.4 Other Criteria Advisories or Guidance To-Be-Considered
BC
PCB cleanup levels are consistent with 40 CFR Part 761, Subpart G. Spill Cleanup Policy Rule. In
addition, off-site disposal of contaminated soil will be at a chemical waste landfill operating in accordance with
40 CFR Part 761 Subpart D (which is not an ARAR because it is oot ol1-site)~ and in accordance with the
revised Procedures for Planning and Implementing Off-Site Response Actions. OSWER Directive 9834.11.
November' 13, 1987,9834.118, January 4. 1988. No other criteria, advisory, o.r guidance are considered
necessary for implerDeotation of the selected remedy.
12.3 cosr EFFECTIVENESS
The selected remedies are the most cost effective alternative because they protect human health. and
the eovironment, attain ARARs, aud meet the objectives established for the remcdia1 action in a way that is
proportional to their costs.
The selected remedy for the Woodpole Storage Area East was in the same cost range as the other
alternatives evaluated; however, the remedy selected is the .most compatible alternative with BPA's future land
use of this area and the innovative treatment technology is expected to be implcmeotable.
The remedy for the Ross Substation and Capacitor Yard and the Capacitor Testing lAb is readily
implcmeotable at a lowei' cost than any other options and provides protection to human health and the
environmCl1t.
12.4 UTILiZATION OF pERMANENT SOLtmONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES
The selected remedy rcpreseots the maximum extent to which permanent solutions and treatment
tA:d1oologies can be utilized in a cost-effective man.nec at the BPA Ross Complex. The selected remedy
provides the best \)!aIAIIN! of tradeoffs in tenDS of long-term effectiveness and permancoce, reduction in
toxicity, mobility. volume achieved through treatment, short-term effcctiveoess, , and cost. The remedy in
the Wood Pole Storage Area East employs an alternative treatment technology that will result in a permanent
remedy.
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12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT
..
The Ex-Situ Solid Phase Bioremediation satisfies the statutory preference for treatment that
pennanently and significantly reduces the toxicity, mobility, and volume of hazardous substances.
Contaminants will be destroyed to the maximum extent practicable.
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES
There are three significant changes pertaining to OUA since the Proposed Plan was released, for public
comment in August, 1992:
(1) Tbe Proposed Plan identified the need for remedial action under CERCLA at the Wood Pole
Storage Area East and at the Ross Substation and Capacitor Yard. However, it was clearly stated that the
Washington Bepartment of Ecology disagreed with EPA's position and supported the need for remedial action
at the Capacitor Testing Lab as well. It was also stated that BPA had agreed to pursue soil cleanup as a
removal action at the Capacitor Testing Lab as described in the Feasibility Study.
Since the release of the Proposed plan, EPA has reevaluated the data and the risk assessment for the
Capacitor Testing Lab. EPA has concluded that there is not a sufficient difference between the risks at the
Ross Substation and Capacitor Yard and the Capacitor Testing Lab to warrant action at one area and not the
other. Therefore, EPA has agreed to include the Capacitor Testing Lab for remedial action under CERCLA
as part of the OUA ROD.
Although the alternatives for remedial action at the Capacitor Testing Lab were not presented in the
Proposed Plan, the Capacitor Testing Lab was evaluated as part of the Feasibility Study. Thus, the detailed
analysis of altematives and cost comparisons have been available for public review and are a part of the
Administrative Record. The contaminant of concern, cleanup standards and remedial action for this area are
identical to the Ross Substation and Capacitor Yard. The Capacitor Testing Lab has been part of the RllFS
process and selection of a remedial action for this waste area is considered a logical outgrowth of the
information already available to the public. Therefore, EP A determined that the Proposed Plan did not have
to be amended because it is consistent with the type of remediation that has been presented for public
comment.
(2) The Proposed Plan specified bioremediation as the preferred treatment aItemative for the Wood
Pole Storage Area East. BPA has determined that 8eobal1Cl!'.ld bioremediation8 which utilizes geochemical
enhancements (UV light and chemical oxidizer's) in addition to conventional microbial activity would have a
greater' assurance of achieving the cleanup standards. In addition, the overall estimated cost of the enhanced
bioremediation is less than balf the cost that was estimated in the Proposed Plan. The selected remedy
includes a contingency that provides for alternative clean up levels if the clean up standards cannot be
achieved. If that is the case, after treatmcnt is completed, the remedy includes on-site disposal with capping.
Depending on the level of contamination remaining in soils, one of the two types of caps specified in Section
10 will be implemented.
(3) The Proposed Plan specified the volumc of conbamination in the Ross Substation and Capacitor
Yard as 4,900 cubic yards. This volumc was overestimated and the correct volume is 1,196 cubic yards.
_11.-..1-
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.
.
ATTACHMENT I
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.
RESPONSIVENESS SUMMARY
OPERABLE UNIT A
BONNEVILLE POWER ADMINISTRATION
ROSS COMPLEX
,"
This responsiveness summary addresses the questions and comments received by the Bonneville Power
Administration concerning the Proposed Plan related to soil remediation for Operable Unit A at the Ross
Complex located in Vaocouvcc, Washington. The Site was listed on the National Priorities List (NPL) in
November 198? based on the presence ofvolatiJe organics compounds in groundwater and the Site's proximity
to the City of Vancouver's drinking water supply. As a results of the listing BPA, pursuant to a Fedcca1
Facility Agreement signed by BPA, EPA, and the Washington Department of Ecology (Ecology) on May I,
1990, BPA conducted a Remedial InvestigationlFeasibility Study (RI/FS) to determine the nature and extent
of contamination at the site and to evaluate alternatives for the clean up of con~min"ted areas.
On May I, 1991, a community relations plan (CRP) was prepared by BPA's Community Relations
Group in accordance with CERCLA, as amended by SARA. The CRP included establishing information
repositories and communication pathways to disseminate information, Information repositories are located
at both the Ross Complex and in the Vancouver Regional Library, 1007 East Mill Plane Boulevard,
Vancouver, Washington 98663.
An administrative record was established to provide the basis for selection of the remedial action in
accordance with section 113 of CERCLA. The administrative record is available for public review at the Ross
Complex or the Vancouver Regional Library. During the RIfFS, BPA issued a press release and five
additional fact sheets. The chronology of the community relations is listed below.
. May 22, 1990
. July 1990
. March 1991
. May 1991
. August 1991
. May 1992
A scoping meeting was held to provide information to the public and hear concerns
about environmental conditions at the site.
Fact sheet No.4 described the results of the May scoping meeting.
Fact sheet No.5 described chronology of events and the work plan for the RIIFS.
Fact sheet No.6 described the RI and FS programs and current site work.
Fact sheet No.7 described status of the RI field work,
Fact sheet No.8 defined Opemble Units A and B, discussed OUA Rl and risk
assessment findings, and activities planned for the summer of 1992.
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The public was given the opportunity to participate in the remedy selection process in accordance with
sections 117 and 1 I 3 (1<) (2) (B) of CERCLA. The proposed plan for Operable Unit A, which summarized the
alternatives evaluated and presented the preferred alternative, was mailed to approximately 800 interested
parties on August 14, 1992. BPA provided public notice through a display ad in the Columbian and
Oregonian on August 24, 1992 to explain the proposed plan, list the public comment period, and announce
the public m~ng. Press coverage was also provided in the local news media which resulted in a news article
of August 20, 1992.
.
,
A 30-day public comment period was held from August 14 to September 14, 1992. Approximately
20 people attended a public meeting, which was held on September 2,1992 at the Ross Complex, DOB
Auditorium. The public comment period was held from August 14 through Septemger' 14, 1992. BPA held
a public meeting on Wednesday, September 2, 1992 to explain the recommended cleanup plan and solicit
public commoots. Four written comments were received during the comment period. Copies of the
transcripts for the public meetings and comment letters received are provided in the Administrative Record.
A summary of the comments received followed by BPA's respoose follows.
Groundwater concerns that were expressed during the public comment period on the Proposed Plan
for the cleanup of contaminated soils at the site will be addressed in the separate Record of Decision that
documents the cleanup decision for the contaminated groundwater at the site. A Proposed Plan for Operable
Unit B, which describes Site groundwater concerns, will be available for public review in June 1993 and the
Record of Decision is scheduled for release in August 1993.
1.
It is imperative that the public know what goes on at the facility and that the remedies select~
will be safe and Will be implemented in a timely manner.
Response:
Since 1985 BPA bas endeavored to keep the public informed about events related to the
hazardous waste investigation at Ross. We have done this by working with the media and
through a series of written notices, information sheets, and public meetings. We will
continue to look for ways to improve communication with our public.
As stated at the public meeting, we have not been able to identify any off-site risks due to
contaminant migration. The remedies now being proposed are directed at on-site risks. These
actions are designed to ensure that there will be nO off-site rislcs in the future and that even
on-site risks win be eliminated. Bonneville recognizes that it needs to deliberate in
undetta1ciilg these actions while moving ahead without undue delay.
The implementation of the remedy in the Ross Substation and Capacitor Yard is scheduled
for fiscal year 1995. At this time, PCB equipment will be replaced and the PCB
contamioated soil will be removed. The remedy for the Capacitor Testing Lab will be
conducted concurrently with the remedy in the Ross Substation and Capacitor Yard.
Planning for implementation of the remedy in the Wood Pole Storage Area East is currently
_11--1.'"
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.
.'"
2.
Response:
3.
Response:
4.
Response:
_1'--11.-
underway. The length of time to complete bioremediation is dependent on biological
reactions. It cannot be accurately predicted although a treatment period of one to two years
is anticipated.
The public want to ensure that the clean-up process is not a temporary solution and that the
problem is really resolved.
As outlined in the proposed plan, in selecting a specific cleanup tccImology, we are required
to consider a number of criteria. Among other things, we must evaluate the short-term
effectiveness, long-term effectiveness, as weD as overall reduction in mobility, toxicity, and
volume of waste through treatment. Long-term effectiveness was a critical component in the
evaluation for the selection of a remedy. The alternatives selected ~ intended to ensure that
the solutions applied provide a penD8DCIJt remedy.
Institutional Controls appears to be the logical choice for containment. It does not disturb the
soil and cause it to be air-bome, the cost is reasonable, and it is unlikely the land be open to a
great deal of public use.
Institutional Controls includes measures to limit or prohibit activities that may interfere with
or disturb contaminated areas. We recognize that the cost for institutional control is
reasonable; however, the use of this alternative W9uld not allow BPA to have unrestricted
access for incorporation of these areas into the long term planning and development process
for the Ross Complex. Therefore, Alternatives I and C, were selected for the Wood Pole
Storage Area East, Ross Substation and Capacitor Yard and Capacitor Testing Lab based on
best the balance of trade offs resUlting from the comparative analysis of alternatives and
when implemented will allow BPA unrestricted use of these areas.
The contaminants do not appear to be a problem. The foUowing alternatives are preferred: 1)
no action 2) institutional control, and 3) certainly nothing more costly than the Table 3 preferred
altematives.
The preferred alternatives for the Wood Pole Storage Area and the Ross Substation and
Capacitor Yard and associated costs presented in Table 3 were selected based on the best
balance oftradeoffs among the alternatives evaluated including costs. The remedies selected
accommodates regulatory treatment preferences and includes the eval~tions of criteria such
as effectiveness, implementability, and cost. The cost estimates have been refined since
issuances of the Proposed Piau and they are significantly lower. BPA, therefore believes it
makes sense to remove these known levels of contamination.
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5.
A concern related to all contaminants at Ross and many other areas of our community exists.
Removal of all contaminants from the site is advocated.
.
Response:
BPA, in worlcing with EPA and the state, has utilized a risk-based clean up approach. Whee
warranted this approach requires the removal of contaminants. In other situations,
contaminants may be contained for the prevention of further migration. Tbe interaction of
these two approaches achieves the clean up requirements of EP A and the state which are
protective ofhumao health and the environment. Historical contamination is being addressed
by the selected remedies. Tbese remediations coupled with changes in the handling and
storage practices which caused the contamination, discontinuing the use of certain hazardous
compounds, and the development of new waste handling facility, ~II when taken together,
represent the best way of reducing the potential for future contamination issues.
.
. .
_"--1.-
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A TIACHMENT II
ADMINISTRATIVE RECORD LISTING
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ATTACHMENT II
Administrative Record List
TitletT . Dote Po es Author lOr nization
,'.,',',',",'.'.',',',',',",',',",',','.','.',','.',",'.',',',',',',',',',',',',',",', ',',',','.,',',",',',', -,',','.-.','.',',',',-,-,','.'.','.'.'.-,','.'.'.'.",'.'.','.'.',','.','.',','.',',',',',','
SITE IDENTIFICATION
.. Background (Suspect Contamination) 7/1/89 15 USEPA
NFL Listing/Site Inspection 9/14/88 21 US EPA
.d Preliminary Assessment Report 4/1/86 50 BPA
Site Investigation (SI) Report 7/1/88 VI/II/III Pacific NW Lab. Richland
REMEDIAL INVESTIGATION (RI)
Work Plan (RIfFS Study) VOl I 6/1/91 Domes & Moore
Work Plan (RI/FS Study) VOl II 6/1/91 Domes &. Moore
RI Work Plan Modification 8/1/91 7 Anthony Morrell. BPA
RI Operable Unit A Vol 1 5/15/92 Dames & Moore
RI Operable Unit A Vol 2 5/15/92 Dames & Moore
RI (Unit A) Appendices Volume 1 5/15/92 Domes & Moore
RI (Unit A) Appendices Volume 2 5/15/92 Domes & Moore
RI (Unit A) Appendices Volume 3 5/15/92 Domes & Moore
RI (Unit A) Appendices Volume 4 5/15/92 . Domes & Moore
RI (Unit A) Appendices Volume 5 5/15/92 Dames & Moore
RI (Unit A) Appendices Volume 6 5/15/92 Dames & Moore
RI (Unit A) Appendices Volume 7 5/15/92 Dames & Moore
RI (Unit A) Appendices Volume 8 5115/92 Dames & Moore
FEASI81UTY STUDY
Feasibility Study Operable Unit A 7122/92 200 Dames & Moore
Proposed Plan 8/11/92 13 BPA. EPA. Ecology
Ltr proposing enhanced bioremed. I 2/12/93 4 Anthony Morrell. BPA
ltr agree to enhanced bioremed. 2/19193 2 Nancy Hamey. U.s. EPA
ltr agree to enhanced bioremed. 2122/93 2 Chris Poindexter. Ecology
RECORD OF DECISION
REMEDIATION I
Removal Action Closure Report 8124/92 Dames & Moore
COORDINATION
Federal Faci6ties Agreement 3/1 /90 60 BPA. EPA. Ecology
Transmit Site Inspection Report 8/8/89 1 Gloria Lenz. SPA
EPA's position re fieldwork act 6/15/90 1 Nancy Harney. U.s. EPA
BPA Commence Fteldwork 5/2/91 1 Nancy Homey. U.s. EPA
Transmits RI Report Operable Unit A 5/15/92 1 Anthony Morrell. BPA
EPA's Comments on Anal RI 6/9/92 5 Nancy Homey. U.s. EPA
EPA's Accept RI Operable Unit A 6/23/92 1 Nancy Homey. U.s. EPA
Transmit Pre6minay Assessment 7/11/86 1 Stephen Sander. SPA
Transmit SIte Inspection Report 8/8/89 1 Gloria lenz. SPA
Accepts RI/FS Work Plan 8/21/91 1 Chris Poindexter. Ecology
Request to Revise schedute 11/1/91 4 Anthony Morrell. SPA
Response to Concerned Citizen 2/3192 2 Chris Poindexter. Ecology
Transmits RI Report Operable Unit A 5/15/92 1 Anthony Morrell. BPA .
FFA Resolution of Disputes Alternate 611/92 1 Chris Poindexter. Ecology
Extension for Draft ROD 7/24/92 1 Chris Poindexter. Ecology
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ATTACHMENT II
Administrative Record list
title IT e Dote Po es Author lOr onization
.. ,",",,'.,",".',. .'.",".','.'.'.'.'.",".",',"."," ,'."."."."..".,'.".',".'.' ,".'.".".".".'.'.".",-.-,",',-.-.'.'.-.".'.-.".-.".'.'.".'.'.',".'.'.".'.'.'.'.".",'.".'.",",".".','.",",',' "
HEALTH ASSESSMENTS
ATSDR Ltr enc lAG. schedule visit 2/28/92 33 Luther DeWeese ATSDR
,".
PUBLIC PARTICIPATION
MemolCommunity Relations Plan 9130/88 7 Asst to Adm. Environment
Community Relations Plan 5/1/90 8 BPA
Ross Community Contact list 11/30/89 5 BPA
Notice of 5/22/90 meeting 4/27190 2 George Gwinnutt. Area M!
Ross Community Contact list 5/12/92 3 BPA
Official Comment Log Close 5/31/90 5/31/90 11 Comments 1-6
Ltr enclosing 5/22/90 question respons 7/12/90 1 John Straub. BPA
Ltr re Superfund Site infonnation 11/16/90 1 John Straub. BPA
Ltr re Superfund Site Activities 3/27191 1 John Straub. BPA
Ltr re Superfund Site Activities Update 5/21/91 1 John Straub. BPA
Ross Complex Dev Guide Info 3/1192 2 BPA
Lte re waste handlinglsite cleanup 4/13/92 2 Dave Dunahay. BPA
Ltr review proposed plan & public mtg 8/11/92 1 Dave Dunahay. BPA
Public Comment Log 9/14/92 5 Interested Neighbors
SPA Notice of Intent (RIfFS) 4/27190 2 Federal Registrar eelS)
Ross Complex Cleanup 5/17/90 1 The Columbian
Ross Complex Looks to Future Jan-92 3 BPA
SPA Announces AR Avail Ubrary , 6/1/92 1 The Oregonian
SPA Announces AR Avail Ubrary 6/1/92 1 The Columbian
SPA Announces AR Avail Ubrary 6/15/92 1 The Columbian
SPA Announces AR Avail Ubrary 6115/92 1 The Oregonian
SPA's Superfund Proposal 8/24/92 1 The Columbian
SPA's Superfund Proposal 8/24/92 1 The Oregonian
Wlthc::' :;wal of NOI to Prepare EIS I 12/4/92 1 Federal Registrar (8S)
EPA Releases BPA Superfund Shedule 7/8/90 1 EPA
SPA Site to be tested for hazards 9/30/84 1 The Columbian
Toxic contamination suspect BPA Sub 7/8/86 1 The Oregonian
Chemical tests to begin on BPA Site 719186 1 The Oregonian
Ross tests trigger S 1.5 million study 1019188 . 1 The Oregonian
EPA stresses three sites for cleanup I 7/14/89 1 Seattle PI
EPA plans to track pollutants 7/14/89 1 The Columbian
Seattle firm to test Bonneville pollution 10122/89 1 The Oregonian
EPA adds BPA site to waste list 11/16/89 1 The Oregonian
Ross contamination still unclear 5/23/90 1 The Columbian
BPA plan will affect site near Hazel Dell 4/19/90 1 The Oregonian
BPA seeles comment on cleanup 8/20/92 1 The Oregonian
Ross Complex takes next step 8/20/92 1 The Columbian
Fact Sheet-Ross Needs a Cleanup 4/1/90 2 BPA
Fact Sheet-CERCLA Process 5/1/90 2 BPA
Fact Shet-Inspection Summary 5/1/90 4 BPA
Fact Sheet-May 22 Meet Q&A 7/1/90 4 BPA
Fact Sheet-What's Happening 3/1191 1 BPA
Fact Sheet-Studies Begin 5/1191 2 BPA
FactShee~UpdCrte 8/1/91 1 BPA
Fact Sheet-What's Happening May-92 2 BPA
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ATTACHMENT II
Administrative Pecord List
II.
Title/T e
.,.",-"."-.,.,...-.."",...,.,.,..-.,.,,,...,...-.""".,',"""""'0"""""""""""""'"
TECHNICAL SOURCES
Summary of CERCLA
History & Statute
EPA Final Rule (Fed Register)
Technical Assistance Grant Update
EPA Guidance for RIIFS Baseline
CERCLA Requirements
...
Dote Po es Author lOr onizotion
"""".",."",.",.-.",,-,',- ,',',',',',',',", """,-.,.."",.".,.-.",,',",',"','.'.'.',',.,.,',',',
1986
11/28/86
318/90
211190
2121190
10/6/89
..-".".,-.""".,..,...,.,....,.-.-......,..-.-,'.'...-.".""",."-"".",."".,.,,,."..'.'.'.',',','.',',',',',','
.
p...~ AOREa«IOJCLSJ
"-3
,",'.'.'.','.'.',',".'
30
70
55
1
25
1
(Index and CERCLA Act)
EPA Region X
Nancy Horney. U.S. EPA
U.S. Dept. of Energy
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