United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R10-93/067
September 1993
SERA Superfund
Record of Decision:
Bonneville Power Administration
Ross Complex (USDOE)
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4.
50272-101
REPORT DOCUMENTAT10N 1'. REPORT NO.
PAGE EPA/ROD/R10-93/067
Title and Subtitle
SUPERFUND RECORD OF DECISION
Bonneville Power Administration Ross Complex (USDOE)
(Operable Unit 2), WA
Second Remedial Action
Awhor(.)
2
3. RecIpient.. Ace"'" No.
5
Report Dat.
, 09/29/93
6.
7.
8.
Performing OrganIzation Rep(. No.
.
8.
Performing Organization Name .nd Add,...
10
Project TulclWork Unit No.
i
.
11. Contrac:t(C) or Granl(O) No.
R
(0)
12. Sponaorlng Organization Name and Add,...
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
13. Type 0' R.port . Period Covered
800/800
14.
15. Supplemenl.ry Not..
PB94-964622
16. Ab8trac:t (Umh: 200 wordII)
The Bonneville Power Administration Ross Complex (USDOE) (Operable Unit 2) site is part
of a 235-acre active power distribution center that is located in Vancouver, Clark
County, Washington. Land use in the area is predominantly industrial, with residential
neighborhoods located to the east and south of the site. Approximately 18,000
residents live within a one-mile radius of the site, and the primary supply of drinking
water for the area is obtained from the Troutdale aquifer. Drinking water is
distributed by the County through well fields that are located both hydraulically
upgradient and downgradient of the site. There also are private wells located within a
one-mile radius. Two streams border the Bonneville Power Administration (BPA), with
Cold Creek to the north and Burnt Bridge Creek to the west. Cold Creek is a tributary
of Burnt Bridge Creek, which flows into the Vancouver Lake, approximately 1.7 miles to
the east of the BPA. Also, the Columbia River is located 2.7 miles to the north of the
BPA. The site has been owned and operated by the Bonneville. Power Administration since
1939 to distribute hydroelectric power generated from the Columbia River to regions
throughout the Pacific Northwest. Since its construction, the site has provided
research and testing facilities, maintenance construction operations, and waste storage
and handling operations: Maintenance activities have included handling transformer oils
(See Attached Page)
17. Document AnaIyaJa a. D88c:rJpto,.
.Record of Decision - Bonneville Power Administration Ross Complex (USDOE)
Unit 2), WA
Second Remedial Action
Contaminated Medium: soil
Key Contaminants: organics (PAHs, PCBs), metals (arsenic, lead)
b. Idenllller8l'Open
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EPA/ROD/R10-93/067
Bonneville Power Administration Ross Complex (USDOE)
Second Remedial Action
(Operable Unit 2), WA
Abstract (Continued)
containing PCBs, as well as organic and inorganic compounds associated with the storage of
preserved wood transmission poles, paints, solvents, and waste oils. Testing and
laboratory activities at the BPA included the use of heavy metals such as mercury and
other organic and inorganic compounds. Five investigations were conducted at the site
between 1986 and 1990, including a remedial investigation that identified twenty-one
individual areas of concern or "waste units," including the Fog Chamber Dump Trench Areas
1 & 2, and the Cold Creek Fill Area. Trench Area 1 consisted of an open dump/burn pit
measuring approximately 12 feet by 120 feet with a depth of 20 feet that was located in
the Fog Chamber Test Facility Area and received spent capacitors containing PCB oils,
along with other assorted incidental solid wastes such as wood pallets, waste paper and
glass insulators. Trench Area 2 is located southeast of Trench Area 1 and most likely
received waste materials from the Ross Substation, Capacitor Yard, and the 345 Kv Yard.
The Cold Creek Fill Area is a former landfill that was used by the BPA from 1960 to 1986.
It is located along the northern boundary of the Ross Complex and is believed to have
received oil and PCB-contaminated fill material, as well as spent sandblasting materials
that potentially contained heavy metals. It was noted from site investigations that while
ground water quality does not currently pose an unacceptable CERCLA risk, VOCs were found
in two onsite wells at concentrations slightly above MCLs. The site was divided
subsequently into two separate OUs for remediation. A previous 1993 ROD addressed the
soil in 19 of the 21 waste units, the Ellen Davis Trail, and possible exposure from
airborne contamination, as OU1. This ROD addresses a remedy for the Fog Chamber Dump
Trench Areas 1 and 2, the Cold Creek Fill Area, shallow and deep ground water, surface
water, and sediment in Cold and Burnt Bridge Creek, as OU2. Based on site studies, no
further remediation was determined to be needed for the Cold Creek Fill Area, shallow and
deep ground water, surface water, and sediment in the Cold and Burnt Bridge Creek. The
primary contaminants of concern affecting the soil are organics, including PAHs and PCBs;
and metals, including arsenic and lead.
"
I
r
.
The selected remedial action for OU2 includes capping the 2,160 yd3 of PAH- and
metal-contaminated soil within the 8.025 ft2 area known as Fog Chamber Dump Trench 1 with
a minimal functional standards (MFS) cap designed to satisfy State requirements, which
includes a liner over the waste material with sand and geotextile fabric overlain by
crushed rock; conducting long-term soil monitoring; conducting ground water monitoring for
VOCs in the perched shallow water table and deep aquifer; and implementing institutional
controls, including deed and land use restrictions. The estimated present worth cost for
this remedial action is $155,000, which includes an unspecified O&M cost.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific soil cleanup goals are based on the State of Washington Model Toxic
Control Act (MCTA) requirements, and include total HPAHs 1 mg/kg; total PCBs 1 mg/kg;
total metals 250 mg/kg; lead 20 mg/kg; arsenic 32 mg/kg; antimony 2,960 mg/kg; and copper
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DECLARATION
.
.
BONNEVILLE POWER ADMINISTRATION
ROSS COMPLEX
VANCOUVER, W ASlDNGTON
RECORD OF DECISION
SITE NAME AND LOCATION
Bonneville Power Administration, Ross Complex
Vancouvc:r, Washington
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for Operable Unit B (OUB), one of two
operable units, of the Bonneville Power Administration (BPA) Ross Complex Superfund site in Vancouver,
Washington. The remedies selected in this decision document were 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 addressc:d 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.
DESCRIPTION OF THE REMEDY
The selected remedies for Operable Unit B (OUB) address the risk posed by the soil contamination at the
Fog Chamber Dump Trench Area 1 by capping and containing the contaminated soils and by requiring
institutional controls at Trench Area 2. OUB consists of Fog Chamber Dump Trench Areas 1 and 2, the Cold
Creek Fill Area, shallow and deep groundwater, and surface water and sediments in Cold and Burnt Bridge
Creeks .
Remedial action is required at the Fog Chamber Dump Trench Areas I and 2.
The major components of this ROD are:
.
Capping the Fog Chamber Dump Trench Area 1 plus Institutional Controls, and;
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.
Institutional Controls at the Fog Chamber Dump Trench Area 2.
..
No Action is required for surface water, and sediments in Cold Creek and Burnt Bridge Creek or for the
Cold Creek Fill Area. There will be groundwater monitoring in the perched shallow water table and deep
aquifer.
4
DECLARATION
.
The selected remedies are protective of human health and the environment, comply with Federal and 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 for this site. However, because treatment was not found to be practicable~ these
remedies do not satisfy the statutory preference for treatment as a principal element of the remedy. The size
of the trench areas and the nature of the contamination preclude a remedy in which contaminants could be
excavated and treated effectively.
A five year review will be required at the Fog Chamber Dump Trench Area 1 and 2 and for groundwater
since hazardous substances will remain on-site abov~ health-based levels.
rdk~tXf!u1
David Dunahay
Bonneville Power Administration
Ross Complex Manager
~;<1L :z~ B,P'.3
Date
diac2lbpa\rodoub.2
2
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..", ... .....
.' . .- " . ...
Si~ture sheet for the ,~oregoing ~le Unit B, 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 .
.
. (3w:;;1r4
~ . I
d A. Emison
. Acting Regional Administrator, Region. 10
. United States Environmental Protection Agency
dioc21bpa1Jocloub.2
r~27- ;7
Date
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Signature sheet for the foregoing Operable Unit B, Bonneville Power Administration, Ross Complex Record
of Decision between the U.S. Department of Energy, Bonneville Power AdmiiUstration, RoSs Complex and
the U.S. Environmental Protection Agency, with concurrence by the Washington State Department of Ecology .
~/Y'~~
9/;27/93
Carol Fleskes, Program Manager
Toxies Cleanup Program
Washington State Department of Ecology
Date
dioc2\bp:l\t'Odoub.2
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TABLE OF CONTENTS
Section
~
1.0 INTRODUCI'ION ................................................ 1
1.0 'SITE LOCATION AND DESCRIPTION. . . . . . . . . . . . . . . . . . ... . . . ~ . . . . . . . . .. 1
2.1 SITE LOCATION. . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
2.2 CURRENT LAND USE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
3.0 SITE msroRY AND ENFORCEMENT ACI'IONS .......................... 4
3.1 SITE InSTORY ............................................... 4
3.2 INITIAL INV'ESTlGATIONS .,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
3.3 REMEDIAL INVESTIGATIONIFEASIBILITY STUDY (RIIFS) ................. S
3.3.1 Fo!! Chamber Dump. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~. 6
3.3.2 Cold Creek Fin Area ......................................... 6
4.0 COl\fl\fUNITY RELATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
4.1 coMMUNITY RELATIONS DURING THE RIIFS ............... . . . . . . . . ., 7
4.2 COMMUNITY RELATIONS TO SUPPORT SELECTION OF REMEDY ........... 8
5.0 SCOPE AND ROLE OF RESPONSE ACfION WITIDN SITE STRATEGY. . . . . . . . .. 8
6.0 SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
6.1 PHYSICAL SE'iI'ING ........................................... 9
6.2 GEOLOGICAL SE'ITING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
6.3 HYDROGEOLOGIC SE'ITING ..................................... 10
6.4 NATURE AND EXTENT OF CONTAMINATION. . . . . . . . . . . . . . . . . . . . . . . . . 11
6.4.1 Subsurface Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
6.4.1.1 Fog Chamber Dump. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
6.4.1.2 Cold Creek Fill Area .................................. 22
6.4.2 Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . 22
6.4.3 Cold Creek Surface Water and Sediment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
6.4.4 Burnt Brid!!e Creek Surface Water and Sediment. . . . . . . . . . . . . . . . . . . . . . . . 28
7.0 SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
7.1 COMPOUNDS OF CONCERN AND USE OF DATA. . .. .., ., .., . . .. . . . . . . .29
7.2 HUMAN HEALTH RISK ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
7.2.1 EXpOsure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
7.2.1.1 Site Setting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
7.2.1.2 Potentially Exposed Populations. . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
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TABLE OF CONI'ENTS
(Continued)
7.2.1.3 Identification of Exposure .Pathways ......................... 33
7.2.2 Toxicitv Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
7.2.2.1 Non-carcinogenic Effects. . . . . . . . . . . . . . . ; . . . . . . . . . . . . . . . . 35
7.2.2.2 Carcinogenic Effects. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
7.2.3 Risk Characterization. . . . . . . . . . . . . . . . . . . . . . . . . ... . . . .. . . . . . . . . . . 35
7.2.4 On-Site Risk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
7.2.4.1 Evaluation of Off-Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
7.2.5 Uncertainty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
7.3 ECOLOGICAL RISK ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
7.3.1 Risk Characterization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46
8.0 REMEDIAL AcrION OBJECl'IVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
9.0 DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .48
9.1 ALTERNATIVE A - NO ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .49
9.2 ALTERNATIVE B - LIMITED EXCAVATION WITH OFF-SITE DISPOSAL. . . . . . . . 49
9.3 ALTERNATIVE C - IN-SITU VITRIFICATION. . . . . . . . . . . . . . . . . . . . . . . . . . . 49
9.4 ALTERNATIVE D - CAPPING WITH INSTITUI10NAL CONTRoLS. . . . . . . . . . . . 49
9.5 ALTERNATIVE E - EX-SITU TREATMENT AND DISPOSAL. . . . . . . . .-. . . . . . . . 50
9.6 ALTERNATIVE F - INSTITUTIONAL CONTROLS. . . . . . . . . . . . . . . . . . . . . . . . 50
9.7 ALTERNATIVES RETAINED FOR DETAILED EVALUATION. . . . . . . . . . . . . . . . 50
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . 51
10.1 COMPARATIVE ANALYSIS FOR FOG CHAMBER DUMP, TRENCH AREA 1 ..... 53
10.1.1 Threshold Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53
10.1.1.1 Overall Protection of Human Health and the Environment. . . . . . . . . . . . 53
10.1.1.2 Compliance with ARARs ............................... 53
10.1.2 Primary Balancin~ Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
10.1.2.1 Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . . S4
10.1.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment. . . . . . .. 54
10.1.2.3 Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . : . . . . . 55
10.1.2.4 Implementability .................................... 5S
10.1.2.5 Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .56
10.1.3 Modifvin~ Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S7
10.1.3.1 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S7
10.1.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
10.2 FOG CHAMBER DUMP TRENCH AREA 2 ............................ 57
10.2.1 Threshold Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57
10.2.1.1 Overall Protection of Human Health and the Environment. . . . . . . . . . . 57
.w.:2\bpa\rodoub.2
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TABLE OF CONl'ENTS
(Continued)'
10.2.1.2 Compliance with ARARs ............................... 58
10.2.2 Primarv Balancin2 Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
10.2.2.1 Long-term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S8
10.2.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment. . . . . . .. ~8
10.2.2.3 Short-Term Effectiveness. . . . . . . . ~ . . . . . . .'. . . . : . . . . . . . . . . S8
10.2.2.4 Implementability .................................... 59
10.2.2.5 Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .,' . . . . . . . . . .59
10.2.3 Modifyinl! Criteria. . . . . . . : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
10.2.3.1 State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 60
10.2.3.2 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
11.0 SELECI'ED REfdEDY ............................................ 60
11.1 KEY ELEMENTS OF SELECTED REMEDY FOR FOG CHAMBER DUMP TRENCH
AREA 1 [[[60
11.2 KEY ELEMENTS OF SELECTED REMEDY FOR FOG CHAMBER DUMP TRENCH
AREA 2 [[[ 61
11.3 KEY ELEMENTS FOR THE COLD CREEK FILL ........................ 61
11.4 KEY ELEMENTS FOR SITE GROUNDWATER ..........................61
11.5 KEY ELEMENTS FOR COLD CREEK AND BURNT BRIDGE CREEK. . . . . . . . . . . 62
12.0 SfATUTORY DETERMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT.. . .. . . . .. . . . 62
12.2 COMPLIANCE WITH ARARs .....................................63
12.2.1 Other Criteria. Advisories. or Guidance To-Be-Considered ITBC) . . . . . . . . . . . . . 63
12.3 COST EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
12.4 UI'ILlZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT. . . . . . . . . . . . . . . . 64
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LIST OF TABLES AND FIGURES
Tables
Table 1 -
Summary of Laboratory Results, Soil
Table 2 - . Summary of Laboratory Results, Shallow Groundwater
Table 3 -
Summary of Laboratory Results, Deep Groundwater
Table 4 -
Summary of Laboratory Results, Surface Water
Table S -
Summary of Laboratory Results, Sediment
Table 6 -
OUB Soil and Groundwater Cleanup Levels
Table 7 -
Selection of Potential Exposure Pathways by Receptor
Table 8 -
Estimated Hazard Quotients and lifetime Cancer Risk from Subchronic Soil
Table 9 -
Estimated Hazard Quotients and lifetime Cancer Risk for Specific Soil Strata, Worker Scenario
Table 10 - Estimated Hazard Quotients and lifetime Cancer Risk from On-Site Groundwater, Hypothetical
On-Site Residents and Workers
Table 11 - Estimated Hazard Quotients and Lifetime Cancer Risk to Off-Site Groundwater, Hypothetical On-
Site Residents (a) .
Table 12 - Hazard Quotients for Aquatic Receptors, Downstream Unfiltered Water (N=6) and Filtered Water
(N =4)
Fi!!Ures
Figure I - Site Location Map
Figure 2 - Site Plan
Figure 3 - Distribution of HPAHs, PCBs, and Metals and Estimated Areas of Contaminated Soil, Fog
Chamber Dump Trench Area I
Figure 4 - Distribution of HPAHs and Metals and Estimated Areas of Contaminated Soil, Fog Chamber
Dump Trench Area 2
dioc2lbpa\n>douh.2
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LIST OF TABLES AND FIGURES
(Continued)
Figure S - Surface Water Sampling Locations
Figure 6 - Sediment Sampling Locations
Figure 7 - Relationship of Screening Criteria
4ioc2IIIpa1rodoub.2
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~
DECISION SUMMARy
1.0 INTRODUcnON
The Decision Summary provides a condensed description of the site-specific factors and analysis that
led to the selection of the remedy for ~le Unit B (OUB) at the Bonneville Power Administration. Ross
Complex Superfund site, begiDDiDg with the early identification and characterization of the problem
(documented in the remedial investigation (R1). 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 involvement of the public throughout the process is also described, along
with the environmental programs and regulations that relate or direct the overall site remedy. The way in
which the selected remedy meets Comprehensive Environmental Response, Compensation and Uability Act
(CERCLA) and the State of Washington Model 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 borders 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 primary supply of drinking water in the Vancouver area is obtained
from the Troutdale aquifer and is distributed by Clark County PUD through well fields. The well fields are
located both hydraulically upgradient and downgradient of the Site. Well field #3 is located immediately
downgradient of the Site. Private wells are located within one mile surrounding the Site.
The Site is located approximately 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 southwestern side of the Site. Cold Creek, a tributary to Burnt Bridge
Creek, flows into Burnt Bridge Creek just west of the Site. Burnt Bridge Creek flows into Vancouver Lake
(Figure 1). Tbe location of the creeks in relation to the Site is shown in Figure 2. Vancouver Lake is used
for recreation purposes such as boating, swimming and fishing. 'Tbe site does not lie within a loo-year flood
plain. In the Vancouver area, the Troutdale aquifer is the primary supply of drinking water.
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N
A
B .P.A. Ross
Complex
o
1
2
I
Scale In Miles
Figure 1. Site Location Map
)
)
,.
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I 0
J
'.t !Iv.-" r
)
)
.., u... Sf
~
{
N
'A
400
800
1200
]
SCALE IN rEET
)
.
.
.
.
DEEP WElL LOCATION
SHALLOW WELL LOCATION
HYPOTHUICAL WELL LOCATION
DoL I WA ItR SEPARATORS
- ROSS COMPLEX PROPERTY LINE
;....- CREEK
[]~S WAST[ UNIT
OUA INVESl1CA 110M AREAS
I WOOD POL E S TOIIACE AREA. SOUTH
2.009-1&2 SANITARY ORAINFIELD
J 009-1 DRAINLINE
.. TOP COAT TEST AREA
~ ROSS SUBSTATION AND CAPACI TOIl YARO
6. PCB STOIIACE BUILDING
,. UNTANKING TOWER
8. LABORA lORY wASTE STOIIAGE AREA
9. TEUf'OIIARY PAINT STOIIACE
10. PAINT STOIIACE FACILITY
II. CAPACITOII TESTING LABOIIATOIIY
12. SANDBLASTING AREA
I J. PLANT !ERVICES BUILDING
14. UTI II 2AT ION ANO DISPOSAL YARO
I~. HAZARDOUS WASTE STOIIAGE BUILDING
18. HERBICIDE STOIIAGE AREA
17. VAN'S WAY OIL STOIIACE AREA
18 WOOD POLE STOIIAGE AREA. EAST
OUB INVESl1CA 110M AREAS
19 FOC CHAIA!ER OUUP TRENCH AREA I
20 roc CHAUBER ouuP TRENCH AREA 2
21 COLD CREEK Fill AREA
FIGURE 2
SITE PLAN
BPA ROSS COMPLEX
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. Ceusus 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 SL Johns Ave. and St. James, residents between St. Johns Ave. and 19th St.
(southeast of the Site), an area which includes several schools and churches; residents inhabiting the area
between 19th St. and Leverich Park to the southwest of the Site (mcluding a trailer park adjoining the Site
boundary) and residents iDhabiting the area north of the Site between the Cold Creek drainage and Minnehaha
Avenue.
2.2 CURRENT LAND USE
The Bonneville Power Administration (BP A) owns and operates a power distribution centerlcnown
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 conditions. Equipment stored, maintained and repaired includes transformers, bushings, and other
electrical transmission and storage equipment.
3.0 SITE msroRY AND ENFORCEMENT ACTIONS
3.1 SITE mSTORY
The Site is an active facility that has been owned and operated by tbe Bonneville Power
Administration (BPA) since 1939 to distribute hydroelectric power generated from the Columbia River to
regions throughout the Pacific Northwest. Since its construction, the Site has provided research and testing
facilities, maintenance construction operations, and waste storage and handling operations for BPA.
Maintenance activities at the Ross Complex have routinely involved handling transformer oils containing
polychlorinated 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 PAlSI, ~UA RIfFS, and OUB RIfFS 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 INITIAL INVESTIGATIONS
Five investigations were conducted at the Site between 1986 and 1990: a Preliminary Assessment (P A
1986), a Site Investigation (SI 1988), a soil gas survey and ground-water quality assessment (Weston, 1989),
a preliminary hydrogeologic investigation (Dames & Moore, 1989), and a Vancouver Well Field Special
diac2lbpalrodoub.2
-------
Survey (E&E, 1990). BPA has also conducted numerous individual sampling programs in various areas of
the Site, The findings of these investigations are summarized in detail in the "Remedial Investigation Report,
Operable Unit A, Bonneville Power Administration, Ross Complex" dated May 15, 1992 and the "Remedial
Investigation Report, Operable Unit B, Bonneville Power Administration, Ross Complex" dated March 19,
1993.
3.3 REMEDIAL INVESTIGATION/FEASmn..ITY STUDY (RIIFS)
The Site was listed on the National Priorities List (NFL) in November 1989 based on the presence
of volatile organic compounds (V0Cs) in groundwater 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 InvestigationIFeasibility Study (RIfFS) to determine the nature and extent 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 of twenty one individual areas ofconccm or "waste units" were identified for
investigation based on historical chemical handling, storage and disposal practices and the results of previous
investigations (Figure 2). The waste uni~ investigated included:
1. Fog Chamber Dump Trench Areas 1 and 2
2. Wood Pole Storage Area South
3. DOB-l Drain Line
4. DOB-2 Drainfield
5. Top Coat Test Area
6. Capacitor Testing Lab
7. Paint Storage Facility
8. Plumbing Shop
9. Sandblasting Area
10. Van's Way Oil Storage Area
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
Wood Pole Storage Area East
Ross Substation and Capacitor Yard
Utilization and Disposal Yard
Hazardous Waste Building
Herbicide Storage Area
Untanking Tower
Laboratory Waste Storage Area
PCB Storage Area
Cold Creek Fill
Oil/Water Separators (8)
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. Operable Unit A is the investigation of soils in 19 of the 21 waste units, the Ellen
Davis Trail, and the possible exposure from airborne contamination. The 19 waste units evaluated in Operable
Unit A include: Wood Pole Storage Area South, DOB-2 Drainfield, DOB-l Drain Line, PCB Storage Area,
Capacitor Testing Lab, Hazardous Waste Building, Top Coat Test Area, Untanking 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, Oil/Water Separators (8), Utilization
and Disposal Yard, Sandblasting Area, and the Temporary Storage Area. 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. Based on the evaluation of all these areas, remedial action was required
dioc2lbpa\rodoub.:2
-------
at the Wood Pole Storage Area East, the Ross Substation and Capacitor Yard and the Capacitor Testing Lab,
as descnDed in the OUA ROD. The OUA ROD was signed on May 6,1993 by EPA, BPA aDd ~logy.
This ROD addresses OUB. The Operable Unit B Remedial Investigation focused On characterization of
subsurface soils in three areas of concern: the Fog Chamber Dump Trench Areas 1 aDd 2 aDd the Cold Creek
Fill Area. The investigation also included characterization of the shallow perched water table aDd deep
groundwater aquifec beneath the Site, aDd surface water aDd sediment in Cold Creek aDd Bumt Bridge Creek.
Field activities completed in the summer of 1992 to complete site characterization for OUB included the
iDst811ation of additional monitoring wells, continued groundwater monitoring, and surface water aDd sediment
monitoring in Cold Creek.
3.3.1 Fo!! Chamber DumD
Trench Area 1
Trench Area 1 in the Fog Chamber Dump consisted of aD open pit dump located in the present 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, aDd glass insulators. Reportedly these wastes were set on fire and
allowed to bum. Historical aerial photographs indicate that aD open pit approximately 12 feet by 120 feet with
a depth of 20 feet existed between 1956 and 1960. A second shallower disposal area was identified near the
pit location aDd is approximately 150 feet by 15 feet with a depth of 15 feet. A deep aquifer exists in the area
of the Fog Chamber Dump and is approximately 150 feet below ground surface. -
Trench Area 2
Aerial photographs dated 1942 and July 21, 1951, initially revealed the presence of six parallel features
in Trench Area 2 (located southeast of Trench Area 1) and appeared to represent closed spaced backfilled
excavations or dirt roadways. A 1955 aerial photograph showed active grading areas and the presence of fill
material which was most likely from the Ross Substation and Capacitor Yard and the 345 kV yard.
3.3.2 Cold Creek Fill Area
Tbe Cold Creek Fill Area is a former landfill in Cold Creek Valley along the nortbem boundary of the
Ross Complex. This fill area was used by BPA from about 1960 to 1986. Cold Creek runs through a culvert
covered by fill to a depth of 30 to 80 feet. Fill materials came primarily from past construction activities on
the Complex. Potentially contaminated fiU included excavated soils from the Dittmer Building construction
(including DOB-l and DOB-2 Sanitary Drainfield) and from graded- material potentially contaminated with
oils and PCBs associated with paving of the Utilization and Disposal Yard. Evidence of spent sandblasting
materials potentially containing heavy metals has also been found.
Another potential source of fill may have been from the grading Qf the Top Coat Test Area. Tbe
excavated soils may have been contaminated with PCP formulations and metals used to test wood poles at the
clioc2\bp;l\rodoub.2
-------
Top Coat Test Area. A review ofhistorica1 air and ground photographs and interviews with BPA personnel
. indi~. that the base of the fill was likely engineered. ,. - .
4.0 COMMUNITY 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 BPA would undcrtalce.
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 diss..min"t~ 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 RIfFS
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
. August 1992
. September 1992
.
May 1992
dioc21bpa\~.2
A scoping meeting was beld to provide information to the public and bear concerns
about environmental cOnditions at the site.
Fact sheet No.4 described the results of the May scoping meeting.
Fact sbeet No.5 described chronology of events and the worle plan for the RIfFS.
Fact sheet No.6 described the RI and FS programs and current site worle.
Fact sheet No.7 described status of the RI field worle.
A Proposed Plan for Remedial Action of ~UA was mailed to the public. The plan
described proposed remedial actions and selected remedies for ~UA soils.
A public meeting was beld to present the findings of the RIIFS for ~UA and the
selected remedial alternatives outlined in the Proposed Plan for ~UA.
Fact sheet No.8 defined Operable Units A and a, discussed ~UA RI and risk
assessment findings, and activities planned for the summer of 1992.
-------
.
June 1993
Fact sheet No.9 described the results of the RI for OUA and OUB, that
groundwatcc was not a public threat and gave advance notice of the upcoming July
1993 public meeting.
Proposed Plan for OUB Remedial Action of OUB was mailed to the public. The
plan described the results of the OUB RIIFS, proposed remedial alternatives and"
selected remedies for OUB soil groundwater, surface water and sediment.
.
May 1993
.
July 1993
A Public Meeting was held to present the findings of the RIIFS for Operable Unit"
B and the selected remedial alternatives outlined in the Proposed Plan for OUB.
4.2 coMMUNITY RELATIONS TO SUPPORT SELECTION OF REMEDY
The public was given the opportunity to participate in the remedy selection process in accordance with
sections 117 and 113(k)(2)(8) of CERCLA. The Proposed Plan for Operable Unit B, which summarized the
alternatives evaluated and presented the preferred alternative, was mailed to approximately 800 interested
parties on June 24, 1993. BPA provided public notice through display ads in the Columbian and Oregonian
on June 22, 1993 to explain the Proposed Plan, list the public comment period, and announce the public
meeting. Media coverage was also provided in the form of local newspaper articles which appeared on June
2 and 6, 1993 and cable television news coverage on Channel 2S on June 1 and July 9, 1993.
A 3O-day public comment period was held from June 25, 1993 to July 26, 1993. Approximately 20
people attended a public meeting, which was held on July 8, 1993 at the Ross Complex, DOB Auditorium.
No verbal comments were received at the public meeting and three written comments are included in the
attac(hed 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 ACl'ION WITHIN SITE STRATEGY
The OUB RI evaluated the nature and extent of contamination in subsurface soils in the Fo~ Chamber
Dump Trench Areas 1 and 2 and in the Cold Creek Fill Area. The OUB RI also included evaluation of the
shallow perched water table and the deep aquifer beneath the Site, and surface water and sediments in Cold
Creek and Burnt Bridge Creek. Results from the baseline risk assessment indicate that a CERCLA remedial
action is necessary for contaminated subsurface soils in the Fog Chamber Dump Trench Area 1. High levels
of PCBs and metals were found throughout subsurface soils in Trench Area I, up to 20 feet deep in isolated
areas. Although the risk assessment indicated that soils in Trench Area 2 do not represeni an unacceptable
. risk under CERCLA, soils in the Fog Chamber Dump Trench Area 2 contained elevated levels of lead and
other metals above the state cleanup levels in areas which are associated with solid waste debris. Site
groundwater quality does not pose an unacceptable CERCLA risk; however, volatile organic compounds found
in two on-site wells are slightly above the EPA Maximum Contaminant Level (MCL) for l,l-dichloroethene
(DCE) and l,l,l-trichloroethane (TCA). The final remedial action selected in this ROD requires capping and
dilc2\bpa\rodoub.2
-------
institutional controls to both reduce surface water infiltration and contaminant migration, and to prevcot human
exposure to the subsurface contamiuants.
The final selected remedies include: (1) minimal functional standards (MFS) cap with institutional controls
in the Fog Chamber Dump Trench Area 1, (2) institutional controls in the Fog Chamber Dump Trench Area
2, and (3) continued monitoring of volatile organic compounds in groundwater.
There were.no unacceptable ri~ associated with the Cold Creek Fill soils, Cold Creek and Bumt Bridge
CRek sedimcots, or surface water under CERCLA or MTCA; therefore, no further aaion will be RqUired
for these areas. .
6.0 SUMMARy OF SITE CHARACTERlSI1CS
6.1 PHYSICAL SETI1NG
The Site is located on an ancient alluvial ten'ace. Creeks and streams in the area have been cutting into
the terrace deposits, creating incised channels. Elevations across the Site range from greater than 2SO feet
above mean sea level to approximately 40 feet above mean sea level. The surface gradicot generally slopes
to the west across the Site, with localized steep slopes toward Cold Creek to the north and Bumt 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 Creek just west of the Site. Burnt Bridge.. Creek flows into Vancouver
Lake (Figure 1). The location of the creeks in relation to the Site is shoWD in Figure 2. Site stormwater
runoff 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 wetlands were observed west of the Site along Burnt Bridge
Creek near Vancouver Lake. These include a palustrine-emergent wetland and a palustrine open-water
wetland that are hydrologically connected 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 House, Oil House, Switching Yard and
the landscaping around the Control House and Oil House. None of the sites have been nominated and no site
bas been listed in national, state, or local preservation registers. The CERCLA action will not affect any of
these sites.
6.2 GEOLOGICAL SETI1NG
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 ridgeline. The ridgeline slopes
to the west with a moderately steep flank slope to the north towards Cold Creek. It also has a moderately
diK2lbpcalrodoub.2
-------
steep slope to the southwest towards Burnt Bridge Creek. The eastern third of the Site occupies a valley
averaging about 240 feet above msl with geJ.,\t1y sloped sides. This valley drains to the .west into Cold Creek.
Geologically, the Site rests on Pleistocene alluvial deposits in the Fourth Plains area of Clark County
(Walsh et al, 1987). The Pleistocene deposits consist of 110 to greater than 177 feet of unconsolidated
Pleistocene-aged sands, silts, -and clays underlain by moderately consolidated Upper Troutdale Formation silty,
sandy, or clayey gravels. The Upper Troutdale Formation underlies the Pleistocene deposits. The Upper
Troutdale Formation is cbaracterized by gravc11ydeposits as opposed to finer grained deposits of the
Pleistocene-aged materials. The contact between the Troutdale and the younger pleistoceDe sediments appears
to be an erosional unconformity. The 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 62 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 mantled by Lauren-Sifton-Wind River soils resting on nearly level to gently rolling terraces
typical of southwestern Clark County. The soils are 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
of W"lDd River sandy loam, which extends over approximately 30 percent of the Site. This soil is excessively
drained and exhibits moderat,ely 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 irrigation water supply wells 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 Cree1cISalmon Creek Area.
The eastern portion of the Site overlies a sequence of unconsolidated alluvial terrace sediments which
contains shallow perched ground water. The depth to the shallow groundwater varies across the Site from
less than 10 feet at the extreme eastern side of the Site to greater than 100 feet in the central portion of the
Site. Saturated thickness of the perched water table also varies considerably from SO feet to less than 10 feet.
Potential groundwater yield from the perched water table beneath the site are relatively low due to highly
variable hydraulic conductivity both vertically and horizontally and the limited extent of saturated units.
Hydraulic conductivity was measured to vary between 0.6 and 90 ftlday. East of the site, the shallow water
table provides supplies to wells in some areas. The western quarter of the site contains no shallow perched
groundwater due to the absence of low permeability strata within the alluvial sediments. The shallow water
table is perched above the regional aquifer and flows northwest and discharges directly to Cold Creek or
emanates as springs on the banks of the creek and flows into Cold Creek. Based on the information collected
diac2lbpa\rocloub.2
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in the RI, there is insufficient yield in the perch~. water table ~eath the site and therefore cannot be used
as a drinking water source. .
Underlying the alluvial sediments beneath the entire Site is the Troutdale Formation, a partially cemented
sand and gravel sequence whi
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Table 1
. Summary 01 Laboratory Results
Soil
Operable Unit B
Concentrations expressed in
Depth AnaIvte
Fog CharrIber DcnIp-J1ench Area r
Surface Anttmony
ArocIor 12M
ArsenIc
Barium
8enzo(a)anthrac:ene
8enzo(a)pyrene
8enzo(b)fkJofanlhene
8enzo(g.h.l)perylene
8enzo(k)ftuoranthene
Cadmum
Chromium
Chrysene
Copper
Olbenzo(a.h)anthracene
Ruoranthene
Indeno(l.2.3-cd)pyrene
Lead
Mercury
Nickel
Pentachlorophenol
Phenanthrene
Pyrene
Silver
Total carcinogenic HPAHs
Total XyJenes
Zinc
Subsurface 1.1.2.2-Tetrachloroethane
2.4.5- T
2.4-0
2-Methytnaphthalene
Acenaphthene
Acenaphthylene
An1tuacene
AntImony
Aroclor 125'
Aroclor 1260
~c
Barium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g.h.l)perylene
Benzo(k)ftuoranthene
BisC2-ethythexyl)phthalate
Butylbenzytphthalate
Cadmium
Carbazole
Carbafuran
Chlorpropham
Chromium
Chrysene
Copper
Zinc
Job No. 0673HJ12.005
«(GW_HIT.XLW)SoiI I 9/23193 I 81)
R
0.2 . 2A
1.2-3.5
151 - 189
0.006 - 0.13
0.008 - 0.019
NO -0.016
0.008 -0.016
0.006 - 0.011
NO
11.7 - 22.2
0.01 - 0.021
17.9 - 92.9
0.002 - 0.006
0.019 - 0.032
0.009 - 0.012
13.3 - 38.9
NO
12.9 - 16.2
NO - 0.39
NO - 0.083
0.016 - 0.028
R
0.072 - 0.096
NO . 0.007
66.5 - 169
NO - 0.012
NO.0.018
NO.O.Ol
NO - 0.09
NO - 0.06
NO .0.024
NO . 0.54
NO - 83.5
NO - 4200
NO . 12000
OAS . 52.3
64.5 - 2120
NO - 3.8
NO - 1.9
NO - 2.6
NO-2.1
NO - 1.4
NO - 0.024
NO - 0.22
NO-21.6
NO - 0.45
NO - 2.4
NO - 1.2
5.7-311
NO - 4.5
NO - 4590
28.3 . 4730
freQUenCY of
Detectton
0/0
A/A
4/4
4/4
4/4
4/4
3/4
'4/4
4/4
0/4 .
4/4
4/4
4/4
4/4
4/4
4/4
4/4
0/4
4/4
2/4
1/4
4/4
0/0
4/4
1/4
4/4
1/24
1/23
1/23
1/24
1/24
1/24
2/24
30/35
9/49
5/1.9
52/52
52/52
8/52
9/52
8/52
7/52
8/52
1/24
1/24
15/52
2/24
1/24
2/24
52/52
9/52
28/52
52/52
I I Concentration IFrequency of
Depth Analyte Rance Detectton
Fog CItcrnber ~TftIIICh Area I
Sub$urface DkI-butvIphlhalate NO-0.12 1/24
DIbenzo(a.h)anthracene NO - 0.6 7/52
Olbenzofuran NO - 0.036 1/24
DIuron . NO-048 2/24
Ruoranthene NO - 7.5 8/52
Ruorene NO - 0.64 4/52
Indeno(l.2.3-cd)pyrena NO - 2.2 7/52
Lead 2,2-1.210 52/52
Mercury NO -1.6 6/52
Naphthalene NO-0.014 1/24
Nickel 9.5-262 52/52
Phenanthrene NO - 3.9 4/24
Pyrena NO - 9.5 15/52
Silver NO - 182 9/37
Toluene NO - 0.072 2/24
Total carcinogenic HPAHs NO -19.1 12/52
Total Xylenes NO-0.13 2/24
PCOOIPCDF NO - 0.005 8/9
Fog ChombeI OInJp-Trench Are<12
Subsurface Acetone NO - 0.024 1/16
AntImony - NO - 152 3/16
Areeler 1254 NO-0.18 2/16
Areeler 1260 NO - 0.64 2/16
ArsenIc 0.58 - 42.7 16/16
Barium 103 - 5580 16/16
Benzo(a)onthracene NO - 0.44 3/16
Benzo(a)pyrene NO - 0.52 4/16
Benzo(b)ftuoranthene NO . 0.52 5/16
Benzo(g.h)/perylene NO - 0.29 2/16
Benzo(k)ftuoranthene NO-0.3 2/16
BisC2-ethylhexYOphthalote NO - 0.022 1/16
Cadmium NO - 37 5/16
Chlorpropham NO - 1.1 1/16
Chromium 7.9 - 160 16/16
Chrysene NO - 0.39 3/16
COpper 16 - S5600 16/16
Oibenzo(a.h)anthracene NO - 0.074 2/16
Auoranthene NO - 0.47 2/16
Ruorene NO - 0.004 1/16
Indeno(l.2.3-cd)pyrena NO - 0.28 2/16
Lead 3.7.- 16700 16/16
Mercury NO - 9.5 3/16
Methylene chloride NO - 0.67 2/16
Nickel 11.8-139 16/16
Phenanthrene NO - 0.019 1/16
Pyrena NO . 0.3 13/16
Silver NO - 8.2 1/16
Toluene NO - 0.05 6/16
Total carcinogenic HPAHs NO - 2.814 5/16
Total Xylenes NO-0.012 4/16
Zinc 43.3 . 24000 16/16
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Table 1
Sumnary of Laboratory Results
Soli
Operable Unit B
Concentrations expressed in
AnoIyte
Depth .
Cold QweIc fill A1eG
Surface Antimony
Aroeler 1248
ArocIor 1254
Aroeler 1260
AIsenIc
BarIum
Benzo(a)onttvocene
Benzo(a)pyrene
Benzo(b)ftuoranthene
Benzo(g.hJ)perytene
BenzoOOftuaranthene
Bis(2-e!hythexyt)phthalate
Cadmum
Chromium
Chrysene
Copper
Di-n-butytphthalate .
DibenZO(a.h)anthroeene
Auoranthene
Auorena
Indeno(l,2.:H:d)pyrene
Lead
Mercury
Nickel
Pentachlorophenol
Phenanthrene
Pyrena
Silver
Totol carcinogenic HPAHs
Total Xytenes
Zinc
Job No. 0673HJ12.005
«GW_HIT.X1.w)SoiI I 9/14/93 I 81)
NO
NO - 3.8
NO - 0.46
NO - 0.6
NO - 41.2
91.9 - 598
NO - 0.D47
0.002 - 0.059
0.003 - 0.054
NO - 0.045
NO - 0.027
NO - 0.44
NO
9 - 80.2
ND - 0.06
21.9-1930
NO - 0.024
NO - 0.011
NO -0.11
NO - 0.006
ND - 0.058
3.2 - 95.9
ND - 0.57
10.8 - 30.3
ND - 0.56
ND-0.12
ND - 0.098
NO
0.005 - 0.357
ND - 0.007
45.2 - 432
Frequency of
Detection
0/7
3/9
3/9
3/9
6/9
9/9
8/9
9/9
9/9
8/9
7/9
1/9
0/9
9/9
7/9
9/9
1/9
4/9
8/9
2/9
7/9
9/9
2/9
9/9
1/9
3/9
8/9
0/4
9/9
1/9
9/9
I I Concennatlon I Frequency of
. Depth AnoIyte Rance Detection
Cold QNIc FIll A1eG
2-MetnvtnaPhthalene NO - 0.85 1/2/J
~ethyl-2-pentanone NO - 0.012 2/2/J
4~ethytphenol NO -1.6 112/J
. NO - 0.82 1/2/J
Acenaphthene
Acetone Nt> - 0.071 2/20
Anthracene NO -1.2 1/20
Antimony NO 0/8
Arocler 1248 NO -1.1 2/2/J
Aroeler 1254 NO -1.5 1/20
Aroeler 1260 NO - 0.086 1/20
Anenic 1-2.5 2/J/2/J
Barium 59.9-204 20/2/J
Benzo(a)anthrocene NO - 0.082 5/2/J
Benzo(a)pyrena NO - 0.065 6/2/J
Benzo(b)ftuoranthene NO - 0.095 7/20
Benzo(g.hJ)perylene NO - 0.071 4/2/J
Benzo(k)ftuoranthene NO - 0.Q4 6/2/J
Bis(2-ethylhexyl)phthalate NO - 0.47 1/2/J
Cadrrium NO 0/20
Carbazole NO - 0.84 1/20
Chlorprophom ND - 0.27 1/20
Chrorrium 7.6-23.8 20/20
Chrysene - NO -0.11 6/20
Copper 14.7 - 27.2 20/20
Dibenzo{a.h)anthracene NO - 0.021 4/20
Dibenzoluran NO - 0.59 1/20
Diethytphtholate NO - 0.01 1/20
Ruoronthene NO-0.18 9/20
Fluorene NO-0.Ol1 2/20
Indeno(l.2.3-<:d)pyrene ND - 0.068 4/20
Lead 3-26.4 20/20
Mercury NO 0/20
Naphthalene NO - 2.6 1/20
Nickel 11.6 - 20.1 20/20
Pentachlorophenol NO - 0.56 1/20
Phenanthrene NO - 4.3 2/2/J
Pyrene NO-0.18 11/20
Silver NO 0/8
Toluene NO-0.013 2/20
Total corc:inogenic HPAHs NO - 0.552 10/20
Totol Xylenes NO - 0.006 1/20
Zinc 33.9 - 116 20/20
-------
Table 2
Summary of Laboratory Results
ShaDow Ground Water
Operable Unit B
Concentrat\on$ expres.18d In PPM.
Sta1kx11 I Concentration IFrequencyof
AnaIVte .Rance Detectton
HCNW-J
anttmonv. total 0.Q63S 1 I 1
bark.m. total 1.11 1 I 1
ctvorT1u11. total Q.0829 1 I 1
copper. total 0.0:371 1 I 1
lead. total 0.0377 1 I 1
mercury. total 0.0002S 1 I 1
nickel. total 0.0858 1 I 1
zinc. total 0.305 1 I 1
MW-4JA
1.1.1-trlchloroelhane NO - 0.0152 617
1.1~lchloroethene NO - 0.0007 517
arsenic. dissolYed NO . 0.0041 1 16
arsenic. total NO - 0.0032 1 15
barium. dissolYed 0.Q2 - 0.0324 6 16
barium. total 0.017 - 0.04 5 15
chloroform NO - 0.fXXJ31 2 I 7
ctvornium. dis$oI\ied NO - 0.275 2 14
chrorrium. total ND - 0.286 3 14
chJysene ND - O.oeml 2 I 3
copper. total ND - 0.0069 1 14
fluorene Np - 0.cxm2 1 I 3
lead. total ND - 0.0078 2 I 5
merC\IIV. dis$oI\ied NO - 0.fXXJ3 2 I 6
nickel. c:f1SSOlved ND - 0.149 3 I 4
nickel. total NO - 0.152 3 I 4
pyrena NO - 0.cxm22 2 13
zinc. dissolved NO - 0.008 1 I 4
zinc. total NO - 0.0389 2 I 4
MW~
1.1.1-IrIc:Noroelhc:w18 0.152 - 0.82 8 18
1.1-c:1c:Noroelta'le ND - 0.001 4 18
1.l-c:1c:Noroethene ND - 0.078 6 18
barium. dissolved NO - 0.003 5 16
barium. total 0.0357 - 0.0505 4 I 4
bromocU 0.0023 - 0.0033 4 14
chromium. tCJ1gl 0.0495 - 0.0595 4 I 4
copper. dissolYed NO . 0.0094 1 I 4
copper. total NO - 0.0081 1 I 4
lead. dissolved ND - 0.0087 1 15
lead. totol NO - 0.0109 4 15
nickel. toto! ND - 0.0271 3 I 4
zinc. dissolved ND - 0.0141 1 I 4
zinc. totol ND - 0.0216 1 I 4
ND - not detected.
Job No. 06737-012.005
«(GW.HIT.Xl.w)shdIoW I 9123/93 I eO
Statton I I Concentration I Frequency of
AnoIVte Rance Detectton
MW-GISA
antimony. total NO - 0.0178 1 I 4
onenIc. total NO - 0.0048 2 14
borIum. dis$oI\ied -0.0103 . 0.0111 4 I 4
borIum. total 0.0382 - 0.594 4 14
cadmum. total ND - 0.0021 1 14
chromium. total NO - 0.0369 3 14
copper. dis$oI\ied NO - 0.0069 1 14
copper. total NO - 0.0755 2 I 4
dl-n-butytphtholote NO - 0.0034 2 15
cliuron 0.0016 - 0.0051 5 15
Ieod. dissolved NO - 0.0026 1 14
Ieod. toto! NO - 0.0141 3 I 4
neburon NO - 0.00079 1 15
nickel. total ND - 0.0525 2 14
zinc. dissolved NO - 0.0271 1 14
zinc. totol NO . 0.227 3 I 4
MW-()lA
1.1.1-trichloroethone 0.002 - 0.006 . 4 I 4
antimony. tatol ND - 0.0314 1 I 4
arsenic. total NO - 0.0047 3 I 4
borium. dissolved 0.0036 . 0.011 4 14
borium. total 0.0619 . 0.315 4 I 4
benzo(a)onthracene ND - 0.cxms2 1 I 4
benzo(a)pyrena ND . 0.000041 1 I 4 .
benzo(b)fluoronlhene ND . 0.0CXXJ28 1 I 4
benzo(k)fluoranthene ND - 0.oem15 1 I 4
bromocil ND - 0.0014 1 I 4
chromium. total ND - 0.0248 2 I 4
chrysene ND -0.000044 1 I 4
copper. totol ND - 0.0434 2 14
di-n-bu1y1phtholate ND . 0.0018 1 I 4
dibenzo(a.h)onthracene ND - 0.oeml1 1 I 4
diuron 0.0013 - 0.0023 4 I 4
fluoronlhene ND . 0.000049 2 I 4
Ieod. dissolved NO - 0.0043 2 I 4
Ieod. total 0.0035 . 0.0155 4 I 4
nickel. total ND - 0.0288 2 I 4
pyrena ND - 0.00013 2 I 4
silver. dissolved ND - 0.0032 1 I 4
zinc. dissolved ND . 0.0243 1 I 4
zinc. total 0.0763 - 0.165 4 I 4
-------
Table 2
Summary of Laboratory Results
Shallow Ground Water
Operable Unit B
Concentrottons expressed In PPM
Sta1lon I I Concentration I Ft'eQuency of
Analyte Rance Detectton
MW-oaA
1. 1. I-trichloroethane 0.003 . 0.004 6 16
cmanic. total NO - 0.0021 1 16
barium. dissolved 0.0082 . 0.0109 6 16
barium. total 0.0105 . 0.0427 6 16
bromocU NO . 0.0022 1 16
chromium. dIssc/IIed NO . aJ1J77 1 16
chromum. total NO . 0.024 2 16
copper. dissoIIIed NO - 0.0112 3 16
copper. totol NO . 0.0102 3 16
di-n-Outylphtholote NO - 0.00J7 1 16
diuron NO . 0.00055 1 I 6
fluorene ND - 0.!XXXI39 2 16
lead. dissolved ND . Q.OO26 1 16
lead. total ND - 0.0026 2 I 6
nickel. totol NO . 0.012 2 16
zinc.d~ NO . 0.0079 2 I 6
zinc. totol NO - 0.0244 3 I 6
MW.'2AR
1.1-<1ichloroethone ND - 0.0002 3 I 4
arsenic. totol NO - 0.0084 3 I 4
barium. dissolved 0.123 . 0.143 4 I 4
barium. totol 0.173 - 0.472 4 I 4
chromium. totol NO - 0.0354 2 I 4
copper. dissolved ND - 0.0174 2 I 4
copper. total NO . 0.0651 2 14
diuron 0.0042 . 0.0064 4 I 4
lead. dissolved ND - 0.0021 1 14
lead. total 0.0033 - 0.0302 4 I 4
nickel. dissolved ND - 0.0048 1 I 4
nicket. total NO - 0.0326 1 14
pentachlorophenol NO . 0.00095 1 13
pyrene ND - 0.000027 1 14
silver. dissolved NO - 0.0061 2 14
silver. totol NO - 0.008 1 13
zinc. dissolved NO - 0.0262 2 I 4
zinc. total 0.0704 - 0.161 4 14
MW-',A (Background)
barium. dissolved 0.0095 . 0.0195 4 I 4
barium. total 0.0127 - 0.041 4 I 4
chromium. dissolved NO - 0.006 1 I 4
chromium. totol NO - 0.0122 2 I 4
copper. dissolved ND ~. 0.0088 1 14
copper. total NO - 0.0078 1 I 4
lead. total NO . 0.0042 2 I 4
nickel. totol NO - 0.0054 1 I 4
zinc. dissolved ND - 0.0181 1 I 4
zinc. total NO - 0.0219 1 I 4
NO - not detected.
Job No. 06737.Q12.005
«(GW_HIT.Xl.W)shaUow I 9/14193 I 91)
Stafk)n I I Concentration I Ft'equency of
Anatyte Ronoa Detec1lon
MW-''''
1. 1. I-trichloroethane o.am . 0.0005 4 14
arsenic. total NO - 0.0029 1 14
barium. dissolved '0.0157 . 0.0376 4 14
barium. totol 0.084 - 0.215 4 14
bromacD NO . 0.0023 2 14 '.
chromum. total ND - 0.0263 2 14
copper. dissolved ND . 0.0071 1 14
copper. toto! NO - 0.0116 1 14
diuron ND . O.oos 2 I 4
ftuoronthene NO - 0.000021 1 I 4
Ieod. dissolved NO - 0.0021 1 14
Ieod. totol 0.0041 - 0.0133 4 14
nicket. totol NO - 0.0228 1 14
silver. totol NO . 0.0066 1 I 4
zinc. totol 0.0215 . 0.0915 4 14
MW-21A
barium. dissolved 0.0523 1 I 1
barium. totol 0.056 1 I 1
bromocD 0.0031 1 I 1
chromum. c:IissoIved 0.0258 1 I 1
chromium. total 0.024 1 I 1
nickel. dissolved 0.0143 1 I 1
nickel. total 0.0149 1 I 1
MW-28A
arsenic. total 0.0026 1 I 1
barium. dissolved 0.0309 1 I 1
.borium. total 0.395 1 I 1
chromum. total 0.0297 1 I 1
copper. total 0.0625 1 I 1
lead. total 0.017 1 I 1
nickel. totol 0.0273 1 I 1
pyrene 0.COX>15 1 I 1
zinc. dissolved 0.0199 1 I 1
zinc. total 0.121 1 I 1
MW-3OA
1. 1. I-trichloroethane 0.Q1 1 I 1
1. l-<1ichloroethone 0.0005 1 I 1
1.1-dichloroethene 0.001 1 I 1
antimony. totol 0.0256 1 I 1
arsenic. total 0.0021 1 I 1
barium. dissolved 0.0275 1 I 1
barium. total 0.304 1 I 1
chromum. total 0.0226 1 I 1
copper. total 0.0576 1 I 1
lead. total 0.0151 1 I 1
nickel. total 0.0214 1 I 1
zinc. total 0.103 1 I 1
-------
Table 3
Sumrnaiy of Laboratory Results
Deep Ground Water
Operable Unit B
Concentrations expressed In PPM
~I T Concentration I Frequency of
Anatvte ~ Detection
AfW~J
1.1.1-lIIchloroethane NO - 0.008 5 17
1.1-dich1oroethene NO - o.an 4 17
antimony. total NO - 0.0176 1 14
arsenic. dis.toII/ed NO - 0.0024 2 15
arsenic. total NO - 0.0026 1 15
barium. dis.toII/ed 0.0048 - 0.0122 6 16
baiIum. total 0.0091 - 0.0124 4 14
benzo(b)ftuoranthene NO - o.anm 1 14
brornocU NO - 0.0016 2 14
chlorofam NO - 0.005 2 I 7
ctvomum. total NO - 0.0464 2 14
diuron 0.00057 - 0.!XX)99 4 14
lead. total NO - 0.0074 1 15
nickel. dissoIIIed NO - 0.0048 1 I 4
nickel. total NO - 0.0936 2 I 4
Zinc. dissolved NO - 0.0064 1 I 4
Zinc. total NO - 0.0054 1 14
AfW..(J2
arsenic. dissolved NO - 0.0071 2 I 5
arsenic. tota1 NO - 0.0071 3 I 5
barium. dissolved 0.0084 - 0.0156 6 16
barium. total 0.0103 - 0.02 5 I 5
benzo(a)anttuacena NO - 0.000021 1 I 4
benzo(a)pyrene NO - 0.000022 1 I 4
benzo(b)fluoronlhene ND - 0.000013 1 14
chromium. total 0.0254 - 0.113 4 I 4
chrysene NO - 0.00002 1 I 4
copper. dissolved NO - 0.0067 1 I 4
fluorene NO - 0.CXXXI32 1 I 4
lead. dissolved NO - 0.0037 1 I 4
lead. total NO - 0.0081 3 15
nickel. dissolved NO - 0.0095 2 I 4
nickel. total NO - 0.0545 3 14
pyrena NO - 0.000027 1 14
Zinc. dissolved NO - 0.0041 1 14
Zinc. total NO . 0.0035 1 14
AfW-D3BIl
1.1.1-trichloroethone 0.001 - 0.003 4 I 4
barium. dissolved 0.0231 - 0.0241 4 I 4
barium. tota1 0.0236 - 0.0371 4 I 4
bromocU NO - 0.0024 1 I 4
chloroform NO - 0.0001 1 I 6
chrorrium. toto! NO - 0.01 2 I 4
copper. total NO - 0.0073 1 14
Zinc. total NO - 0.0034 1 14
NO - not detected.
Job No. 0673H!12-005
«GW.HIUCLw)deep I 9/14/93 I 81)
Page 1 01 3
Anatvte
Station
MW-lJ4B
1.1.1-trIchIoroethane
barium. dissolved
barium. total
chiorofam
ctvonium. total
copper. total
lead. toto!
nlclcel. dissoIIIed
nickel. total
Zinc. totol
MW-05
1.U-trichloroethane
1.1~ichIoroethane
1.1 ~ich\oroethene
arsenic. dissolved
arsenic. totol
barium. dissolved
barium. toto!
chloroform
chromium. totol
lead. dissolved
lead. total
nickel. dissolved
nickel. total
MW-D9B
1.1.1-trichloroethone
1.1 ~ichloroelhene
arsenic. dissoIIIed
arsenic. toto!
barium. dissolved
barium. total
chromum. toto!
copper. totol
fluoronthene
lead. totol
nickel. dissolved
nickel. total
zinc. total
NO - 0.0061
0.01 - 0.0157
0.0177 - 0.268
NO - 0.032
0.0082 - 1.37
NO - 0.0436
NO - 0.0084 .
NO - 0.0114
.0.0107 - 0.676
NO - 0.102
NO - 0.042
NO - 0.0002
NO - 0.011
NO - 0.0024
NO - 0.0029
NO - 0.02
0.01 - 0.0151
NO - 0.031
NO - 0.101
NO - 0.0026
NO - 0.0094
NO - 0.0052
NO - 0.0585
0.003 - 0.006
NO - 0.0005
NO - 0.0029
NO - 0.0022
0.0136 - 0.0225
0.0226 - 0.0986
0.0207 - 0.884
NO - 0.0359
NO - 0.000016
NO - 0.0047
ND - 0.0121
NO - 0.425
NO - 0.058
FreQUei1cy of
Detection
3 18
6 16
5 15
1 18
4 14
3 14
4 15
1 I 4
4 I 4
2 I 4
6 17
2 I 7
5 I 7
1 I 6
2 I 5
5 16
5 15
4 I 7
3 I 4
1 I 6
1 I 5
1 I 4
2 14
4 I 4
2 I 4
1 I 3
1 I 4
3 I 3
4 I 4
4 I 4
1 I 4
1 I 4
2 I 4
1 I 3
2 I 4
-------
Table 3
Summary of Laboratory ResuHs
Deep Ground Water
Operable Unit B
Concentrations expressed In PPM
~I I. Concentration 1 Frequency 01
AnCIIVte Rcnae Detection
MW-JDB
1.1.1-trlchloroethane 0.005 - 0.007 4 /4
1.1~hIoroethene 0.(0)6 - 0.001 4 /4
barium. dissolved 0.0197 - 0.0316 4 /4
barium. totol 0.0302 - 0.D645 4 /4
carbon tetrachloride 0.00 1 - 0.001 4 /4
chIorolorm ND - 0.001 1 /4
chromium. totol 0.0464 - 0.346 4 /4
copper. toto! ND - 0.007 1 / 4
fluoranthene NO . 0.1XXXI8 1 /4
Isophofone ND - 0.(0)7 1 /4
lead. totol ND - 0.0036 3 /4
nickel. dissolved ND - 0.0358 3 /4
nickel. totol 0.0505 . 0.173 4 /4
PYTene NO - 0.Q(XX)16 1 /4
sillier. totol NO - 0.006 1 / 4
zinc. totol NO - 0.0186 1 / 4
MW-JJB(BocJc~
arsenic. totol ND - 0.0046 1 / 4
barium. dissolved 0.0141 - 0.0192 4 / 4
barium. totol 0.0787 - 0.217 4 /4
chromium. totol 0.167 . 0.252 4 I 4
copper. totol NO - 0.0286 2 I 4
lead. dissolved NO . 0.0032 1 I 4
lead. totol 0.002 - 0.0119 4 14
nickel. dissolved NO - 0.0208 2 I 4
nickel. totol 0.085 - 0.135 4 I 4
zinc. dissolved NO . 0.0031 1 I 4
zinc. totol NO - 0.0556 3 14
MW- JJB
1.1.1-trlchiOfoelhane 0.021 - 0.042 5 /5
1.1-dlchloroethone NO . 0.0002 3/5
l,l-c1ch1Ofoethene 0.009 . 0.01' 5 /5
barium. dissolved 0.0093 - 0.0117 5/5
barium. toto! 0.0093 . 0.018 5 I 5
cadmium. dIsso/IIed ND . 0.0019 1 I 5
chlOfOlorm ND . 0.011 1 /5
chromium. totol 0.0085 - 0.0136 5 15
copper. dissolved NO - 0.0064 1 15
copper. totol NO - 0.0068 1 / 5
lead. dissolved NO . 0.0022 2/5
lead. totol NO . 0.0021 1 / 5
nickel. dissolved NO - 0.0043 1 I 5
nickel. totol NO . 0.0107 3 15
NO - not detected.
Job No. 0673H)12-005
«(GW.HfiJQ.W)deeP I 9123193 I 81)
Frequency 01
Statton Anatyte Detection
MW-J4B
1.1.1-trtchIoroethane 0.001 - 0.003 5 /5
1.l-dich1oroethene D.OOO5 - 0.009 5 /5
balUn. dissolved 0.0137 . 0.0187 5 /5
balUn. total 0.0139 - 0.0164 5 /5
chromllm. total ND - 0.0102 4 /5
copper. total NO - 0.0063 1 /5
nickel. total NO - O.oosl 1 /5
zinc. dissolved NO - 0.0071 1 /5
Zinc. total NO . 0.0071 1 /5
MW-J6B
1.1.1-trtchIoroethane 0.011 . 0.018 4 /4
1.1-dich1oroethane NO - 0.0001 2 /4
1.1-dichloroethene 0.003 - O.oos 4 /4
arsenic. toto! ND - 0.0025 1 / 4
barium. dissolved ND - 0.0091 3 /4
barium. totol ND - 0.01 3 /4
bromoc:U NO - 0.0011 1 /4
chloroform NO - 0.007 1 /4
chromium. totol NO . 0.0095 1 /4
nickel. totol NO - 0.004 1 /4
zinc. cflSSOlved NO - 0.0509 1 /4
zinc. totol NO . 0.0042 1 /4
MW-J7B (Baclcgroutd)
borium. dissolved 0.0086 . 0.0237 4 /4
barium. totol 0.01 . 0.0222 4 I 4
chromium. totol NO - 0.0108 2 / 4
lead. dissolved NO - 0.0047 1 / 4
nickel. dissolved NO . 0.0048 1 / 4
nickel. totol NO - 0.0054 2 I 4
zinc. dissolved NO . 0.0066 1 / 4
Zinc. totol NO - 0.0043 1 /4
MW-I9B
1. 1. I-trichloroethane 0.001 . 0.006 4 / 4
1.1-dichloroethene ND - 0.001 3 I 4
barium. dissolved 0.0074 - 0.0096 4 I 4
barium. totol 0.0073 - 0.0091 4 14
chloroform NO - 0.001 1 I 4
lead. totol NO - 0.0036 1 I 4
zinc. dissolved NO . 0.0098 1 I 4
-------
Table 3
Summary 01 Laboratory Results
Deep ~ound Water
Operable Unit B
Concentrations exprEmed In PPM .
~I I Concentration I Frequency of
Analyte Rance Detec1lon
MW-2QBR
1.1.1-trichloroethane 0.0005 - 0.001 4 14
1.l-d1c::h1oroethene NO - 0.1DJ3 2 14
batIum. dIssoIwd 0!XJ77 - 0.0109 4 14
barium. total 0.0072 - 0.0145 4 14
chloroform NO - 0.1XXJ2 1 14
ctvomum. dissoIYed NO - 0.0066 1 I 4
chromum. total NO - 0.0114 3 14
lead. total ND - 0.0191 2 14
nickel. total NO - 0.0071 1 14
MW-22C
1. 1. I-trichloroethane 0.004 1 I 1
1.1-dlchJoroethene 0.cm6 1 I 1
barium. dIssoIwd 0.0132 1 I 1
barium. total 0.0193 1 I 1
chloroform 0.002 1 I 1
chromium. total 0.435 1 I 1
copper. total 0.0251 1 I 1
nickel. total 0.24 1 I 1
MW-24B
1.1. I-trichloroethane 0.1DJ3 1 I 1
antimony. total 0.0388 1 I 1
barium. dissolved 0.0103 1 I 1
barium. totol 0.0484 1 I 1
chromium 4.38 1 I 1
copper. totol 0.096 1 I 1
lead. totol 0.003 1 I 1
nickel. dissolved 0.177 1 I 1
nickel. total 2.16 1 I 1
zinc. totol 0.0089 1 I 1
MW-25B
1.1.1-trichloroethane 0.1DJ3 1 I 1
barium. total 0.0082 1 I 1
chloroform 0.0002 1 I 1
chromium. totoJ 0.0068 1 I 1
MW-26C
barium. total 0.005 1 I 1
chromium. totol 1.72 1 I 1
copper.olSSOlved 0.0064 1 I 1
copper. totol 0.0526 1 I 1
nickel. total 0.901 1 I 1
NO - not detected.
./Qb No. 00737.012.005
«(GW_HIT.Xl.w)deep I 9/14/93 I el)
~I I Concentratton I Frequency of
AnaIyte Range Detectton
MW-2IBII
barium. di=!lled 0.0135 1 I 1
barium. total 0.13 1 I 1
chromum. total - 0.441 1 I 1
copper. total 0.0378 1 I 1
lead. total 0.0036 1 I 1
nickel. dissoIYed 0.0038 1 I 1
nickel. total 0.246 1 I 1
zinc. total 0.0145 1 I 1
MW-298
1. 1. I-trichloroethane 0.0001 1 I 1
barium. dissolved 0.0171 1 I 1
barium. total 0.0211 1 I 1
chromium. totol 0.0065 1 I 1
nickel. dissoIYed 0.0038 1 I 1
nickel. total 0.0044 1 I 1
MW-.1IC
1.1.1-trlchloroethane 0.005 1 I 1
1.1-dichloroelt1ene 0.0008 1 I 1
barium. dissolved 0.0402 1 I 1
barium. totol 0.0813 1 I 1
chloroform 0.0003 1 I 1
chromium. total 0.397 1 I 1
lead. dissolved 0.0024 1 I 1
lead. total 0.0156 1 I 1
nickel. dissolved 0.0198 1 I 1
nickel. total 0.199 1 I 1
zinc. total 0.0633 1 I 1
DIT
1. 1. I-trichloroethane ND - 0.038 8 I 10
1.1-dichloroethene ND - 0.0118 8 I 10
barium. dissolved ND - 0.0088 4 I 6
barium. total ND - 0.0106 4 I 5
benzo(a)anthrocene ND - 0.00072 1 I 4
benzo(a)pyrena ND - 0.00048 1 I 4
benzo(b)ftuoronthene ND - 0.00038 1 14
benzo(g.h~)peryIene ND - 0.00029 1 I 4
benzo(k)ftuoranthene ND - 0.00014 1 I 4
chloroform ND . 0.011 2 I 10
chrysene ND - 0.00057 1 I 4
dibenzo(a.h)anthracene ND - 0.000069 1 I 4
ftuoronlt1ene ND - 0.0011 1 I 4
jndeno
-------
Table 4
SUmmary of Laboratory ResuUs
Surface Water
Operable Unit B
Concentrations expressed In
AnaJvte
Statton
Cold 08eIc
1.U-Trlchloroethane
1.l-D1chloroe!hene
1.l-otchloroe1hane
2A~
Anttmonv
MenIc
BarIum
Benzo(a)onthracene
Benzo(a)pyrene
Benzo(b)ftuoran!hene
8enzo(g.hJ)petylene
Benzo(k)ftuoran!hene
BromacD
Cadmum
Carbon tetrachloride
Cl'vorRum
Chrysene
Copper
Dlbenzo(a.h)anthracene
Dicamba
Diuron
Flucran1hene
Auorene
Indeno(l,2.3-cd)pyrene
lead
Mercury
Methylene chloride
Nickel
Propham
Pyrene
Silver
Simazine
total 1.2~ic:hloroe1hene
Total carcinogenic HPAH
Zinc
NO - not detected.
Job No. 0673HJ12.()Q5
«(GW_HITJCl.WlSW I 9114193 I 01)
ND - 0.085
ND - o.ooe
ND . 0.002
NO - 0.013
ND
ND - 0.0026
ND .0.0765
ND - 0.!Xm98
NO - 0.CJ1XX)63
ND .0.00025
NO - 0.!XXXI67
ND - 0.CXXXJ96
ND - 0.0011
ND - 0.0016
ND-O.Ol
ND - 0.0112
ND - 0.000076
ND - 0.0422
ND - 0.000017
ND - 0.0046
ND - 0.055
ND - 0.0046
ND - 0.00037
ND - 0.000081
ND - 0.0116
ND
ND -0.011
ND
ND - 0.0013
ND - 0.00075
ND - 0.00028
ND . 0.0016
ND - 0.0002
ND - 0.000634
ND-0.142
ffequenc;y of
Detection
18/41
8141
10/41
9/19
0/51
2/51
43/51
5/35
5/35
9/35
3/35
5/35
4/19
5/51
2/21
1/51
9/35
15/35
1135
3/19
10/19
13/35
3135
5/35
8/51
0/51
1/41
0/51
1/19
14/35
5/51
3/19
1/41
10/35
32/51
Station Analyte .
BunI BtIdge 0eeIc
2.4-D
Antimony
Arsenic
Barium .
Benzo
-------
: Table 5
. SUmmary of Laboratory Results
Sediment
Operable Unit B
Concentrations expressed In
FreQUenCY of . Frequency of
StatIon Anatvte Detection Station Anatvte Detection
Cold CNeIr BlIfII Blfdge CIw8t
2~ NO - 0.036 2/~
Acenaphlhene NO - 0.048 1/~ Acetone NO - 0.028 5/6
Anttv~ NO-0.12 2/~ Anttmonv NO 0/6
Anttmonv NO. 10.8 1JJ/3O MenIc - 0.77 - 58.1 6/6
ArsenIc NO -6.9 ~/3O BariI.rn 66.4 - 96.7 6/6
Bartun 58.1-166 30/30 Benzo(a)c:Jnttvac:ene NO - 0.034 5/6
Benzo(a)c:Jnttvocene NO-l.l 16/30 Benzo(a)pyrenEI ND .0.05 5/6
Benzo
-------
TABLE 6
OUB SOIL AND GROtJNDW ATER CLEANUP LEVELS
-
Compounds of Concern RAO Source Soil Cleanup Groundwater
Level (ppm) Cleanup
Level (ppm)
Total HPAHs MTCA MethOd A residential 1 N/A
Total PCBs MTCA Method A residential 1 N/A
Metals: MTCA 250 N/A
Lead Method A residential 20 N/A
Arsenic Method A residential 32 N/A
Antimony Method B residential 2960 N/A
Copper Method B residential 16,000 N/A
Zinc Method B residential
-
Compounds of Concern RAO Source Groundwater Clean Up Level
(ppm)
Volatile Organic EPA Maximum Contaminant
Level (for drinking water)
TCA 0.2
DCE 0.007
Chloroform 0.1
-------
6.4.1 Subsurface Soil
6.4.1.1 Fog Chamber Dump
Trench Area 1: Solid waste debris was observed in the.Fog Chamber Dump Trench Area 1 from 1.5 to
12 feet below ground surface (bgs) in the general disposal area and as deep as 22.5 feet bgs in an isolated
area. Types of waste observed included: 5-gallon buckets. concrete rubble. paint cans. scrap metal. lead
batteries. wood debris. paper, plastic and burned material. Approximately 1.5 feet of clean fill covered with
vegetation overlies the disposal area and' access is restricted by fencing. Compound$ of concern found in
Trench Area 1 soils include antimony. arseniC; copper. lead. HPAHs. and PCBs. The highest levels of
chemical coDtamination generally corresponded to observed areas of debris (pcBs concentrations). Figure
3 shows the concentrations and distributions of contaminantS and the estimated area of contamination in this
waste unit.
Trench Area 2: The solid waste debris was observed in the Fog Chamber Dump Trench Area 2 between
1.5 feet to 10 feet bgs and generally included non-process waste such as car tie rods, wires. cables, chain
links, and concrete debris. Compounds of concern found in Trench Area 2 soils that exceed state cleanup
levels included antimony. arsenic. copper, lead. zinc. and HPAHs. The compounds of concern found in
Trench Area 2 subsurface soils were found between 1.5 feet and 3.5 feet bgs. Figure 4 shows the
concentrations and distributions of contaminants and the estimated area of contamination in this waste unit.
6.4.1.2 Cold Creek Fill Area
Compounds of concern identified in the Cold Creek Fill Area include arsenic and PCBs and were found
between 0 and 10 feet bgs.
6.4.2 Groundwater
Groundwater wells were installed in the shallow perched water table and the deep aquifer and have been
monitored on a quarterly basis since the fall of 1991. The quarterly groundwater analytical results conducted
during the QUA and QUB RIs. are summarized in Table 3. Monitoring well locations are shown in Figure
2.
Naturally occurring metals were found in both the shallow water table and the deep aquifer hydraulically
upgradient and downgradient monitoring wells, but the concentrations of these metals are generally below EPA
Maximum Contaminant Levels (MCLs) and MTCA groundwater cleanup levels where available. Where
MCLs were not available, the MTCA groundwater cleanup levels were used to evaluate contaminant
concentrations. Since groundwater samples from wells located hydraulically upgradient of the Site contained
, similar levels of metals to the downgradient wells, it is concluded that the Site has not contributed metals
contamination to the shallow perched groundwater or deep groundwater.
diac2\bpaln>doub.2
-------
............
.... .... ..., :~~;~:~03C 19'
.... -.jPCBS 19'
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UNIMPROVED ROAD
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rENCE
170'
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POWER POlE
TEST PIT LOCATION
I!I rCOI-TPOI"
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o
STRUCTURE
KEY
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I-L YTI DEPTH VALUI: WAL 'nlA I
ALL UNitS IH IAGflCO (''''')
FIGURE 3
AND METALS AND ESTIMATED AREA OF CONT AMINA TION
FOG CHAMBER DUMP TRENCH AREA 1
BPA ROSS COMPLEX OUB ROD
Dames & Moore
-------
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DISTRIBUTION OF HPAHS AND METALS
FIGURE 4
AND ESTIMATED AREA OF CO NT AMINA TED SOIL
FOG CHAMBER DUMP TRENCH AREA 2
BPA ROSS COMPLEX OUB ROD
40
80
120
,
SCALE IN fEET
L M'" ..............1
-------
Chlorinated volatile organic compounds, 1,1,I-trich1o~ (TCN,.I,I,-dichloroetheoe (DCE), and
. 1, l-dich1oroethane (DCA) were the omy volatile organic 'Compounds found consistently over time at low
concentrations, below the MCLs, in three to six shallow monitoring wells. The OUB groundwater cleanup
levels are shown in Table 6.
Only TCA and DCE concentrations found in one shallow well, MW-4A, over time were slightly above
the MCLs for these compounds which are 0.2 parts per million (ppm) and 0.007 ppm, respectively. The
average TCA concentrations over 8 rounds of sampling was 0.26 ppm. Low levels of bromacil and diuron
have been found consistently in isolated areas in the shallow water table (MW-6A, MW-7A, MW-18A) but
are below available MTCA regulatory levels (diuron, 0.032 ppm).
Low concentrations of TCA and DCA were detected consistently in up to eight deep monitoring wells
in the western portion of the Site. The concentrations found were well below the EPA MCLs for these
compounds. DCE was detected at low concentrations in six deep wells and only one deep well, MW-13B,
contained DCE concentrations slightly above the MCL (0.007 ppm). The average DCE concentrations over
8 rounds of sampling was 0.011 ppm.
.Individual HPAHs, di-n-butylphthalate, chloroform (shallow wells), pentachlorophenol, neburon, and
isophorone were also detected inconsistently over time during 8 quarters of monitoring in the shallow perched
water table andlor the deep aquifer. These compound concentrations were below MCLs (ranging from 0.0001
ppm to 0.001 ppm) and were found either in one quarterly round or in two nonconsecutive rounds and are
therefore considered to be anomalous.
6.4.3 Cold Creek Surface Water and Sediment
Surface water and sediment quality was monitored over time in Cold Creek, at a location upstream and
upgradient (of the Site) and at locations downstream of the Site to evaluate the potential contribution of
contaminants from the Site. The surface water and sediment sampling locations are shown on Figures 5 and
6, and the laboratory analytical results are summarized on Tables 4 and 5.
Metal concentrations detected in downstream surface water samples were similar to the upstream metal
concentrations. TCA, DCA, DCE, HPAHs, and herbicides were found inconsistently overtime in the
upstream sample. locations as well as the downstream monitoring locations. The results suggest that one or
more upgradient off-site sources may be contributing contaminants to the creek.
Stormwater nlDoff samples collected on-site and near Interstate S contained the same types of
contaminants found in the creek, but at higher concentrations. This indicates that stonn runoff from the Site
as well as from off-site road surfaces contributes organic and inorganic compounds to the creek.
Low concentrations of TCA, DCE, DCA, and bromacil were found in seeps to Cold Creek, which is
representative of and consistent with the characterization of the shallow perched groundwater table.
cliac2\bp;1\roc1aub.2
-------
1
;
I ~
BB-SW3
N
fA.
450
900
L ..... ... 08"'-Oa.oo1
SCALE IN FEET
COtO CR££K
1
Ir
I
, I
JuuL
p\J------
1
1350
.
FIGURE 5
SURFACE WATER SAMPLING LOCATIONS
BPA ROSS COMPLEX OUB ROD
-------
1
I
! 0
f !
I
. ~L
N
A
450
900
1350
,
L .... .. 01"'.011-001
SCALE IN FEET
FIGURE 6
SEDIMENT SAMPLE LOCATIONS
BP A ROSS COMPLEX OUB ROD
-------
Cold Creek sediments were found to contain metals concentrations increasing slightly in a downstream
direction from the Site, suggesting inorganic contaminant contributions from surface runoff from the Site and
surrounding areas in the w.atCrshed. The results of the organic analyses indicate that HPAH levels in the creek
sediments increase in a d~wnstream direction adjacent to the Site at levels significantly above background
concentrations, which suggests that these compounds have accumulated in creek sediments over time from Site
sources or from the rai1road that parallels the creek.
6.4.4 Burnt Brid~e Creek Surface Water and Sediment
Surface water and sediment quality was monitored over time in Burnt Bridge Creek, at an upstream
location (upgradient of the Site) at the Site, and at locations downstream of the Site to evaluate the potential
contribution of contaminants from the Site. The surface water and sediment sampling locations are shown on
Figures S and 6, and the laboratory analytical results are summarized on Tables 4 and S.
Burnt Bridge Creek was identified as one of the major carriers of pollutants to Vancouver Lake in 1977.
The pollutants identified in the lake include excessive organic and inorganic nutrient loading and
bacteriological pollution. The main sources identified were non-point source runoff and sewage from
throughout the basin. The RI results of surface water and sediment monitoring in Burnt Bridge Creek indicate
that surface water and sediment quality hydraulically upgradient contained organic and inorganic compound
concentrations equal to or higher than the downstream locations. Since the downstream samples are
representative of potential contaminant contribution from the Site and the results indicated that contaminant
concentrations equal or are less than the upstream concentrations, the results indicate ~at the Site is not
significantly contributing to the contamination present in Burnt Bridge Creek. These results support the area
wide findings that Burnt Bridge Creek is subject to a wide array of point and non-point sources.
7.0 SUMMARY OF SITE RISKS
CERCLA response actions for OUB at the BPA Ross Complex site as described in this Record of
Decision are intended to protect human health and the environment from current and potential future exposure
to hazardous substances in soil, groundwater, surface water, and sediment at the Site. To assess these risks,
human health and ecological risk assessments were conducted as part of the remedial investigation to
characterize the magnitude of risks associated with exposure to contaminated surface soils and to prioritize
areas within OUB for remedial action. The human health baseline risk assessment included the evaluation of
subsurface soils and on and off-site deep groundwater. Surface soil risks were previously addressed in the
OUA ROD. The ecological baseline risk assessment included the evaluation of surface water and sediment
in Cold Creek. Burnt Bridge Creek was not included in the risk assessment since it was concluded that the
Site was not significantly contributing contaminants to the creek. Human and ecological receptors included
the following:
. A hypothetical on-site residential child and adult using on-site deep groundwater as a drinking water
source (potential future scenario);
dioc2\bprl\rocloub.2
-------
. A hypothetical off-site ~idential child and adult living hydraulically downgradieut of the Site who
could be exposed to groundwater contaminants via hypothetical deep drinking water wells (potential
future scenario);
. An on-site worker exposed to conmmin~t~ soils for a limited time during excavation, construction,
or demolition activities (potential industrial scenario), and;
. Aquatic species inhabiting the surface water and sediment of Cold Creek. Potential surface water and
sediment exposures to humans were considered insignificant. .
The hypothetical future on-site resident scenario for exposure to subsurface soils associated with the Fog
Chamber Dump Areas and the Cold Creek Fill was not included in the risk assessment because of BPA's
future land use plans. The BPA facility will be at this location into the foreseeable future, therefore, the on-
site resident scenario is not considered a realistic scenario. The Cold Creek FlIl area has physical construction
limitations that will preclude residential development. The constr:uction of residences over the trenches was
not considered realistic. This constraint is also incorporated into BPA's long range plan for the Site.
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 compounds of potential concern, (2) exposure assessment,
(3) toxicity assessment, and (4) risk characterization.
7.1 COMPOUNDS OF CONCERN AND USE OF DATA
Compounds of concern were selected from a broader list of chemicals detected based on comparison with
natural and area background soil concentrations, prevalence, and toxicity as provided for in the Washington
Model Toxies Control Act (MTCA), and EPA regional and national guidance (EPA 1988, EPA 1991). Of
potential concern identified by the compounds of concern selected for inclusion in the risk assessment are as
follows:
Soils
. metals: antimony, arsenic, barium, cadmium, chromium, copper, lead, mercury, nickel, silver, and
zinc
. HPAHs: total HPAHs including benzo(a)anthracene, cbrysene, pyrene, benzo(b)fluoroanthene,
benzo(k)fluoranthene, benzo(g,h,i)perylene, flouranthene, dibenzo(a,b)anthracene, indeno(l ;2,3-
cd)pyrene; benzo(a)pyrene was individually evaluated.
. Pesticides/herbicides: 2,4-D; 2,4,S-T; diuron; cblorpropham; and carbofuran
4iac7\bp>\rodoub.2
-------
. pentachlorophenol
. Total PCBs
. Total PCDDslPCDFs (Oo1y for the Fog Chamber Dump Trench Area 1)
On-Site Deep Ground Water
. VOCs: l,l,l-trichloroethane (TCA); l,l-dichloroethene (DCE); and chloroform
Off-Site Deep Ground Water
. VOCS: DeE and chloroform
Surface Water/Sediment (ecological exposures only)
. Metals: antimony, barium, cadmium, chromium, copper, lead,and zinc
. Polycyclic Aromatic Hydrocarbons (low and high molecular weight)
. VOCs: TCA, DeE, and DCA
. Pentachlorophenol
. Pesticideslherbicides: 2,4-D, bromacil, dicamba, diuron, propham, and simazine
These compounds of concern were carried throughout the baseline risk assessment and were considered
in the Feasibility Study. Because of the general prevalence of these compounds at OUB and known
toxicological properties, quantitative evaluation of these compounds was expected to account for greater than
95 percent of all potential Site risk. Accordingly, these compounds of concern were used in the risk
assessment in calculation of exposures and characterization of risk.
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 risk assessment was conducted for all chemical data sets based on the 95 percent upper
confidence limit (UCL) of the average concentrations. The 95th 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 HEALTH RISK ASSESSMENT
This section summarizes the exposure assessment, toxicity assessment and the risk characterization
associated with the compounds of concern evaluated in the human health risk assessment.
dioc2\bpalroolauh.2
-------
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 contaminated areas; defines potentially exposed populations;
identifies exposure pathways; and 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 associated with current land use activities,
comprising the baseline sceaario, both on and around the site. In addition to on-site worker and off-site
residential sceaarios and in compliance with EPA Region 10 guidelines (EPA, Region 10, 1991), a ,
hypothetical on-site residential scenario, addressing potential exposures to deep groundwater ofpot.ential future
residents is included in the quantitative risk assessment. This scenario is included because an existing on-site
well is designated as an emergency drinking water well. However, it is not likely, given the presumed
continued land use designation of the BPA Ross Complex as a power distribution facility, that groundwater
at the site will ev~r be used as a drinking water source.
The area surrounding the Site exhibits,a variety ofland uses. These include residential (south, southwest,
and southeast), light commercial/industrial (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 use.
7.2.1.2 Potentially Exposed Populations
The human receptor groups that were evaluated in the baseline risk assessment included on-site workers
and hypothetical on-site residents and off-site residents using hypothetical off-site deep wells as drinking water
sources. Table 7 provides a description and summary of the various human receptor groups (both on- and
off-site) considered for the baseline risk assessment.
Occupational Receptors
The Cold Creek Fill and Fog Chamber Dump Trench Areas 1 and 2 are historical subsurface waste
disposal areas and are not active operational areas of the facility. Therefore, the most plausible exposures to
on-site workers would occur during excavation or construction/demolition activities, and only for a limited
period of time. Exposures are not expected for workers on a routine basis, which would require consideration
of lifetime or long-term exposure duration.
dilc2lbpa\rocloub.2
-------
Table 7
Selection 01 Potential Exposure Pathways by Receptor
BPA Ross Complex RI, QUB
Route, Medium, and
Potential Receptor Point of Expolure
[[["[[[':';':':':':':':':':':':';';':':':','.',",'.'.'.'.'.',",'.'."'.',
Hypothetical On-Site and Off-Site Incidental Ingestion of solis
Residents
Selected for
Quanlllallve Bal's for Selection or Exclusion
Evaluallon? On-Ille/Off-Ilte?
",:,:,:,:,:,:".:.:.;.:.;.:.;.;.".:.:.;.;.:.:.:.:.:.;';':':'N~:':':';':':':':':':'''':':'OU'B':;~I'I';':~;';':~~r;;~'~;;;bl';':t~':';;;:d;'~t;:"';';':';'''':';';':';'[[[»;.:.:.;.,.:<.".:.;.:.;.:.;.:.;.".".:.;.:.".:.".;.;.;.:.
Ross compiex"woikers'''''' ......... . Incidental Ingestion of soils during work Ves This pathway assumes that workers could be exposed to solis during excavation
ae!lvites. or construction ae!ivItles.
Dermal contact with soils during work Ves This pathway assumes that workers could be exposed to solis during excavation
actlvites. or construe!lon ae!lvltles.
Dermal contae! with soils
'Ingestlon of groundwater
No
Ves
Inhalallon of organic vapors during
showering or bathing.
Incidental Ingestion, dermal con toe! or
Ingestion of fish/shellfish from surface water
or sediment from Cold Creek.
Ves
No
Ingestion of groundwater by off-site
residents.
Ves
Inhalation of organic vapors by off-site
residents during showering or bathing.
Inhalation of vapor-phase chemicals
emitted from site.
Ves
Ingestion of groundwater.
Ves
OUB solis are not accessible to residents.
Assumes that residents draw from and use deep groundwater as domestic
drinking water supply.
Assumes that residents draw from and use deep groundwater as domestic
drinking water supply.
Cold Creek Is not a viable pathway for wading. swimming or fishing.
Assumes that downgradlant residents draw from and use deep groundwater as
domestic water supply.
Assumes that downgradlant residents draw from and use deep groundwater as
domestic water supply.
No
Considered highly unlikely, because Intensive field Investigation has shown no
evidence of volatile organics near OUB soli surfaces.
No
I
Workers are assumed to have access to groundwater as a drinking water
source during work activities. Site Is served by City of Vancouver water system
and on-site well Is auxtllary for emergency use only.
Workers are not expected to work In Cold c'reek area.
Incidental Ingestion or dermal contact of
surface water or sediment from Cold Creek
during work activities.
Inhalation of wind-borne particulates or No Not expected to represent a plausible pathway.
-------
Residential Receptors
Although currcndy DO residents inhabit the Site nor are they foreseen. in the future, for the purposes of
the Baseline Risk Assessment (RA) hypothetical residents were assumed to .inhabit the Site and to have access
to the deep (Troutdale) groundwater underlying the Site as represented by the Dittmer auxiliary well, an
existing well designed to supply emergency drinking water to the complex. Due to insufficient yield, pecched
shallow water was not considered a drinking water resource and therefore was not included in the baseline
risk assessment.
Consistent with the ~UA baseline risk assessment, two residential receptor -age-classes- were evaluated,
consisting of -children- (defined as nnging from birth to age 6) and 8adults- (defined as nnging from age
6 to 70). This distinction is useful to effectively address the different types of behaviors affecting potential
exposures within human populations. This is consistent with numerous studies of human behavior as well as
physiological characteristics which suggest that children should be evaluated separately from adults. The on-
site worker was also considered as a potential receptor, since access to the Dittmer Well is a potential current
and future scenario.
The plausible off-site human 8receptors8 are residents living hydraulically downgradient of the Site who
could be exposed to groundwater contaminants via hypothetical drinking water well(s). These hypothetical
off-site resident receptors include an adult and child and were evaluated in the OUB risk assessment for
exposures to deep groundwater.
7.2.1.3 Identification of Exposure Pathways
As defined by EPA (1989a), complete contaminant exposure pathways evaluated as part of risk assessment
must satisfy the following elements:
. Sources from which chemical contaminants can be released to the environment;
. Environmental transport media (e.g., soil, water); .
. Points of potential human contact with the contaminated media; and
. Routes of contaminant entry into human receptors (typically via ingestion, dermal contact, or
inhalation). .
Groundwater pathways evaluated included ingestion of groundwater from wells located on- and off-site
or inhalation of contaminants released from the groundwater during bathing/showering, when the heated,
turbulent water is known to increase rates of volatilization and consequent potential for inhalation. Soil
pathways (on-site only) consisted of direct contact with or incidental ingestion of soils during hypothetical play
or work activities.
Table 7 depicts the rationale for selection of the potential exposure pathways for each of the three
receptor groups (off-site residents, on-site workers, and hypothetical on-site residents) including route, medium
and exposure point, and basis for selection. The following subsections provide a brief discussion of the
rationale for selection of each pathway by specific medium.
disc2\bpa\rodoub.2
-------
Subsurface Soil
The risk assessment has been designed to consider estimated risk: levels. at speci~c depths in order to
dctcnnine the most likely depths at which hazards or risks would occur. Three soil strata were defined for
the Baseline RA based on CXllminlltion of contaminant distribution data within individual OUB soil borings.
Soil stratum for both Fog Chamber Dump Areas consists of data points from the surface" extending to a depth
of 5 feet; the second stratum consists of data points from 6 feet to 15 feet; and the third stratum extends to
a depth of 60 feet. Cold Creek Fill soil stratum depths include 0 feet, 5 to 2S feet, and 30 to 60 feet bgs.
Although soil samples were taken at greater depths than 60 feet, it was reasoned that-if riskslhazards were
inconsequential at 60 feet or less it would be unnecessary to estimate risks for greater depths. This is
consistent with the OUB soil data, which suggest that conblmination levels are insignificant below this depth.
Groundwater
Deep aquifer (Troutdale) groundwater was presumed to be used in the future by hypothetical residents
living on-site. These exposures were represented by the Dittmer well, which is situated in an area of known
groundwater contamination. Off-site groundwater exposures to Troutdale groundwater were represented by
modeled concentrations for two hypothetical downgradient wells: one located southwest of the site in an area
of residential land use, the other west-southwest across Interstate 5 from the Site, the nearest likely area where
a well could be installed. The locations of the hypothetical off-site wells (HW-I and HW-2) are shown in
Figure 2. .
Shallow groundwater exposures were considered for human receptors but were regarded as implausible
based on site hydrogeology. The low potential yield of the shallow wells on the eastern portion of the Site
reduces the likelihood for a pathway for exposure of on-site workers or hypothetical residents. In addition,
shallow groundwater discharges into Cold Creek and the yield of the occurrence of residual contamination in
groundwater is limited in extent. Therefore, the ecological exposures from Cold Creek surface water and
sediments were also evaluated considering shallow groundwater seepage to the creek or upon past discharges
directly into the creek.
Surface Water/Sediments
Potential surface water and sediment exposures were considered insignificant and not plausible for human
receptors. Initial calculations concerning hypothetical surface water exposures to children during play
activities were performed, however, and indicated that risk levels would be negligible. In addition, risks from
surface water and sediment exposures were considered in the ~UA risk assessment and contributed negligibly
to overall risks as compared to other pathways. The aquatic life inhabiting the creek and its environs was
addressed as part of the ecological risk assessment only.
7.2.2 Toxicity Assessment
This section summarizes the toxicological basis for all compound-specific toxicity criteria required to
conduct the baseline risk assessment. These criteria, based on available quantified dose-response toxicity data,
dioc2\bpalroclcub.2
-------
are developed and reviewed within various offices ofEPA. Summaries of the basis from which toxicological
values were derived are presented below.
7.2.2.1 Non-Carcinogenic Effects
For DOn-carcinogenic chemicals, the reference doses (RiD) are used as benchmarks for toxic endpoints
of concern. The goal in developing a RID is to identify the highest nCH>bserved-adverse-effect level (NOAEL)
or the lowest-observed-adverse-effect-Ievel (LOAEL) from weU-designed human or animal studies.
Uncertainty factors from 1 to 1,000 are incorporated to adjust this level based on.the following considerations:
1) the duration of the experimental exposure, 2) effects elicited (if any), 3) extrapolation of the data to other
species (such as extrapolation from animals to humans), and 4) sensitive subgroups. Additional modifying
factors varying between 1 and 10 may also be incorporated in the derivation of the RID if additional
considerations are necessary. RID and slope factors for the BPA risk assessment were taken from EPA's
computerized Integrated Risk Information System (IRIS); Health Effects Assessment Summary Tables
(HEAS1); Drinking Water Health Advisories; or personal communication with EPA Region X Risk
Assessment staff.
The toxicological characterization of compounds of concern was generally confined to chronic (i.e.,
lifetime) rather than acute or subchronic exposures. This characterization is consistent with the contaminant
concentrations found on-site, EPA guidance (EPA, 1989), and exposures likely to occur on the Site.
7.2.2.2 Carcinogenic Effects
For carcinogenic chemicals, slope factors are estimated using a conservative mathematical model which
estimates the relationship between experimental exposure (i.e., doses) and the development of cancer (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 cancer in
excess of the normal background population incidence over a lifetime as a result of exposure to a chemical
either known or suspected to cause cancer. To estimate cancer 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-04). An excess lifetime risk of lE-04
indicates that, as a plausible upper bound, an individual has a one-in-ten-thousand chance of developing cancer
in a lifetime as a result of site-related exposure to a carcinogen.
For known or suspected carcinogens, CERCLA defines acceptable exposures are generally concentration
levels that represent an excess upper bound lifetime cancer risk to an individual of between lE-04 and lE-06,
using information on the relationship between dose and response (NCP, 1990).
Gioc2\bp:1ln>doub.2
-------
For non-carcinogeus, the measure used to describe the potential for toxicity in an individual is not
expressed as, a probability. The potential for non-carcinogenic 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 e~sure to toxicity is called a Hazard Quotient. The Hazard Index (HI) is the sum of more than one
hazard quotient for multiple substances BZJ.dIor multiple exposure pathways. Potential non-carcinogenic effects
may be of COncern if the In exceeds unity (i.e., In> 1).
7.2.4 On-Site Risk
Subsurface Soils
Table 8 provides the hazard quotient (HQ) values and cancer risk levels calculated for non-carcinogenic
and carcinogenic compounds (respectively) of ~ncern to workers potentially exposed during excavation or
construction in the Fog Chamber Dump Trench Areas 1 and 2 and the Cold Creek Fill subsurface soil
contaminants.
Fog Chamber Dump, Trench Area 1
The average total cancer risk estimate for exposure carcinogens to construction workers for Trench Area
1 was 7.4E'()5, which is within the "acceptable" upper bound risk range of l.OE-04 to l.OE-06; however, the
RME cancer risk estimate, 9.4E-04, was above the acceptable risk range (Table 8). At least 99 percent of
this exposure is accounted for by elevated total PCB concentrations found in subsurface soils (maximum and
95 percent UCL concentrations of 30,000 mg/kg and 1,700 mg/kg respectively). These values were the result
of two samples collected in this dump area. Of the two pathways considered (incidental ingestion and direct
soil contact), direct soil contact and consequent dermal absorption accounted for the majority of the total RME
exposure. For example, some 77 percent of the total projected exposure to total PCBs would be expected to
occur as a result of direct dermal contact. RME cancer risk estimates for construction workers by soil depth
stratification indicated that elevated risk associated with PCBs is localized between 0-5 feet (2.3E-03) and 6-15
feet (1.6E.()2) (Table 9). RME risk estimates associated with other carcinogens were also localized between
o and 15 feet and ranged between 1.0E-07 to 1.7E-05.
Fog Chamber Dump, Trench Area 2
NOne of the non-carcinogemc compounds of potential concern identified in Trench Area 2 exceed the HQ
target v~ue of 1.0 (Table 8). Based on data which has been stratified by soil depth (Table 9), however, the
HQ value for copper is sligh~y greater than 1.0 within the top five feet of the surface. About 70% of this
exposure would be explained by incidental soil ingestion (fable 9).
Average and RME total cancer risk estimates for the construction worker, 1.5E-07 and 2.5E-06, were
within the ~acceptable" upperbound cancer risk range (1.0E-04 to l.OE-06) (Table 8).
dioc2lbpo>\rodaub.2
-------
Table 8
Estimated Hazard Quotients and lifetime Cancer Risk from Subchronic Son
Exposures.VVo~erScenario
BPA Ross Complex QUB FS
Compound
¥.~....;.....,~.........:..-.;..":..;..:-;..;v.;';";Y»:-;"y'-';';"""''*;-''';-x..;....:........;..:.:-;,,;......,",y,:.;x.;";,;";"",~......"""--»,,,,,,,...,,,,,,,,,,,,,,,,,,,,,;..-»xw.;....~,...-.;..;..,,:..,,...x.:-......x.:.;.;-:.......:...;...;-;.;.;.;.;««-;-;-;.;.;w;.;.;.;.;..;...-:-;.»:...:-:...;.:....;.;.;.;.;.;.;.;......;....;.;v.;.;"-.;.;-;..,,.;.
Construction W~er
(average) (RME)
Fog Chamber Dump Trench 1
Hazard Quotient
Antimony
Barium
Cadmium
Copper
Ctvomium
lead
Mercury
Nickel
Silver
Zinc
Toluene
Xytene
2A.5-T
2.4-D
Carbofuran
Chlorpropham
Diuron
CarcinoQens
Arsenic
1.1.2.2-TCA
Pentachlorophenol
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo.(ghi)perylene
Benzo(k)fluoranthene
Chrysene
Dibenzo(ah)anthracene
Indeno( 123cd)pyrene
Total HPAHs
Total PCBs
Dioxin
Total Risk (except total HPAHs) =
Fog Chamber Dump Trench 2
Hazard Quotient
Antimony
Barium
Cadmium
Copper
Chromium
Lead
Mercury
Nickel
Zinc
Acetone
Methylene Chloride
Toluene
Xytene
S~.!?r,p~~p~.~~................
,',",',',',',',',',',',',','.:.',','
<0.01
< 0.Q1
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.Q2
<0.01
<0.01
0.09
<0.01
0.16
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<1.0E-Q7
<1.0E-Q7
<1.0E-Q7
<1.0E-Q7
< 1.0E-Q7
<1.0E-07
< 1.0E-Q7
< 1.0E-Q 7
< 1.0E-Q7
< 1.0E-Q7
<1.0E-Q7
<1.0E-Q7
7.4E-05
2.5E-Q7
1.2E-Q7
<1.0E-Qi -
< 1.0E-Q 7
< 1.0E-Q i
3.4E-Qi
<1.0E-Qi
< 1.0E-Qi
< 1.0E-Qi
<1.0E-Qi
1.2E-Qi
< 1.0E-Q7
1. 1 E-Q6
9.3E-Q4
7.0E-Q6
7.42E-05
9.40E-&
<0.01
<0.01
<0.01
0.05
<0.01
0.02
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
'."".',','.-.'.'.'.....:,',:.:.'.'.'.'.',.','.'.:.',',',',",' .
0.01
<0.01
<0.01
0.33
<0.01
0.25
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Job No. 06737-()1Z-005
«(QUBFS793.Xl.w)1bI8 I 9/13193 I 91)
Demes 8< Moore
-------
Table 8 .
Estimated Hazard Quotients and Ufetime Cancer Risk from $ubchronic Soil
Exposures, Worker Scenario
BPA Ross Complex OUB FS
Compound
Construction Worker
(average) (RME)
w»;«';o:.:...~.:.;v;.\.:«..:.;.:....:.:.:.;.;.:.;.;«.:.;.;.,;.:.;.;..;.;.x.;.:.;.;.;.;.;.;.;.;.x.;.;y;.:y:.;«..:.;.;.;.;..:.;.:.;.;.;.:...;.:..:.;.:-;.;.;.;.;.;.:.:.;.;y;.~:..:..:..:......:«..:.;y»»x,.;.w;w>....:o;":":":v.",wx......:,,:,,"x.;.:..:.:.:..:.;.:.:-;';';';';':';';';';':"';';';':":';';';':*:':":';':-:":«';':«0;,;,;.;.;.,:.;.;..
Carcinoaens
Arsenic
Methylene chloride
Benzo(a)anttYacene
Benzo(a)pyrene
Benzo(b)ftuoranthene
Benzo(ghi)perylene
Benzo(k)ftuoranthene
Chrysene
Dibenzo(ah)anthracene
Indeno(123cd)pyrene
Total HPAHs
Total PCBs
Dioxin
<1.0E-07 2.8E)7
<1.0E-07 <1.0E-07
<1.0E-07 <1.0E)7
< 1.0E-07 2.4E-07
< 1.0E-07 < 1.0E.Q7
< 1.0E-07 <1.0E.Q7
<1.0E-07 <1.0E-07
< 1.0E-07 <1.0E-07
<1.0E.Q7 < 1.0E.Q7
<1.0E-07 <1.0E.Q7
< 1.0E.Q7 4.5E.Q7
<1.0E-07 1.6E.Q7
< 1.0E.Q7 1.7E.Q6
1.54E.Q7 2.46E.Q6
Total Risk (except total HPAHs) =
Cold Creek AU
Hazard Quotient
Barium
Copper
Chromium
Lead
Mercury
Nickel
Zinc
Acetone
MIBK
Toluene
Xylene
Chlorpropham
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Carcinoaens
Arsenic
Pentachlorophenol
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)ftuoranthene
Chrysene
Dibenzo(ah)anthracene
Indeno(123cd)pyrene
Total HPAHs
Total PCBs
< 1.0E.Q7
<1.0E-07
< 1.0E.Q7
<1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
1.5E.Q7
<1.0E.Q7
<1.0E.Q7
< 1.0E.Q7
< 1.0E-Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q7
< 1.0E.Q 7
< 1.0E.Q7
. 9.7E.Q8
5.4E.Q7
Total Risk (except total HPAHs) =
9.12E.Q8
8.17E.Q7
:,;,;,;,;,;,;,:,;",:,:,;,:,;,;,:,:,;,:,;,;,:""[[[",.",;,,',';';'.':',',';',','"
",.'.','.'.'.. ",''', "','.',',,,.,',',
".,.,.""..,..,.."., ,
,.. ". . ,... .......".....
-------
Table 9 .
Estimated Hazard Quotients and Ufetime Cancer Risk For SpecHic SoD strata.
Worker Scenario
BPA Ross Complex OUB FS
Compound Depth (average)
,"',',,,,,,,"""',"',"""',,,"',","""""""',',',',"',',"',"'.',,,,.,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,""'A"'.....'.......'.........'.......'.."",,,,,,,,,,,,,,,,,,,,,,,,,,""'''''''''''''''''''''''''"o''>h'''''''''''''''N'oI'o'''.......................".''''''''''''
Fog Chamber Dump Trench 1
Hazard Quotient
Antimony 0-5' <0,01
6-15' <0,01
16-25' <0.01
Barium 0-5' < 0.Q1
6-15' <0.01
16-25' <0.01
Cadmium 0-5' <0.01
6-15' <0.01
16-25' <0.01
Copper 0-5' 0.01
6-15' <0.01
16-25' <0.01
Chromium 0-5' <0,01
6-15' <0.01
16-25' <0.01
lead 0-5' 0.01
6-15' <0.01
16-25' <0.01
Mercury 0-5' <0.01
6-15' <0.01
16-25' <0.01
Nickel 0-5' <0.01
6-15' <0.01
16-25' <0.01
Silver 0-5' <0.01
6-15' <0.01
16-25' <0.01
Zinc 0-5' <0.01
6-15' <0.01
16-25' <0.01
Toluene 0-5' (U) <0.01
6-15' <0.01
16-25' (U) <0.01
Xylene 0-5' <0.01
6-15' <0.01
16-25' (U) <0.01
2,4,5- T 0-5' <0.01
6-15' (U) <0.01
16-25' <0.01
2.4-D 0-5' <0.01
6-15' (U) <0.01
16-25' (U) <0.01
Carbofuran 0-5' <0.01
6-15' (U) <0.01
16-25' (U) <0.01
Chlorpropham 0-5' <0.01
6-15' <0.01
16-25' (U) <0.01
Diuron 0-5' <0.01
6-15' <0.01
," ,16.; ~~:..~~?..""" ".." '," <0.01
,'.' '.','.".".'.",',"-',','.','.'.',',".'.""'.' '.'". '.'.',"','',".'."
Job No. 0673HJ12-005
«(OUBl'S793JCLWl1bI9 I 9/13/93 I el) Page 1 01 4
Workers .
-~-"~,~~~~~~t~~,,._~~
0.28
0,05
<0.01
<0.01
0.01
<0.01
0,01
0.01
<0.01
0.15
0.08
<0.01
<0.01
<0.01
<0.01
0.28
0.13
<0.01
<0.01
<0.01
<_0.01
<0.01
<0.01
<0.01
0.01
<0,01
<0.01
0.01
<0.01
<0.01
<0.01
<0.01
<'0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
',".'.'.',""",' '.'.' '.'.'.'.'
""""".',',"'.','.'."'.','.",',','.','.'.'.'.'.',',',',',",'.'.",'.
-------
Table 9 .
Estimated Hazard Quotients and Ufetime Cancer Risk For Specific Soil Strata.
Worker Scenario
BPA Ross Complex OUB FS
Workers
Compound
Depth
(average)
(RME)
'''''''''','''~'.'.''''''v.h''''''''''''''''''''','''.'.'''J'o'''''''''''''''.'.'.'.....''''",",....................._............'.tV'o."',V""""'''\N~vv.N.'''''''''''''''''.............'........,.'.....'.'...'.'...'.'.''''''''',''''''''',',','.''''''''''''''''''''''''''',''''''''','",',y...,..'.............',',',',',,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,"','...........
Carcinoaens
Arsenic 0-5' <1.0E-07
6-15' <1.~7
16-25' <1.0E-07
1.1.2.2-TCA 0-5' (U) <1.~7
6-15' < 1.0E-07
16-25' (U) < 1.0E-07
Pentachlorophenol 0-5' < 1.0E..Q7
6-15' (U) < 1.0E..Q7
16-25' (U) <1.0E..Q7
BenzoCa}pyrene 0-5' <1.0E-07
6-15' <1.0E..Q7
16-25' CU}
-------
Table 9
Estimated Hazard Quotients and Ufetime Cancer Risk For Specific SOU Strata.
Worker Scenario
BPA Ross CompleX-OUB FS
Workers
Compound
Depth
(average)
(RME)
,"""""""""'''''''''''''''"''''''''''''''''''''''.'.",',","0","""'",""""""""''''0"'''''''''''''''''''''"''''''''''''''''0'",,,,,,,,,,,,,,,,,,,",,,,,,,",,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,"'....",""',',"',"'o">h',',"""""',',"','o',",',",',','.....',','...,.....,.........,,,,,,,,,,,,,,,,",,,,,,,,,,,,,"....'.""V'o',""""',"'...............',',",,,,,",",""'.....''''
Carcinooens
Arsenic 1-5' <1.0E-07
7-11'
-------
Table 9
Estimated Hcizard Quotients and Ufetime Cancer Risk For Specific Soil Strata.
Worker Scenario
BPA Ross Complex OUB FS
Workers
Compound
Depth
(average)
(RME)
"""""",",",,,,,,,,,,,,,,,,,,",,,,,",",",,,,,",,,,,,,,,',,,',",",",,,,,,,,,,,,,,,,,,,",",",,,,,",,,,,",",",,,,,",",,,,,,,'''''.
Corcinoaens
Arsenic
"',-"'''',,,,,,,,,,,,,'.".......v.'''''''''''''O",'''.'.'o''''',".'.','......o,,,,,,,,,,,,,,,,,,,,,,"'N'o'.',".'...'.'."."."'.".'.""'.,.,,'o'.'o'",,,,.,,,,,,"',',,,,,","',"'.'.'.'N',"',',"',',""""',,,,,',"'.V'.........,.......',",'.......".
0' <1.0E'{)7 1.0E-06
5-25' <1.0E.{)7 <1.0E.{)7
3O-iJJ <1.0E.{)7 9.8E-08
0' < 1.0E.{)7 1.5E.{)7
5-25' <1.0E.{)7 1.7E.{)7
3O-iJJ <1.0E.{)7 <1.0E'{)7
0' <1.0E.{)7 3.2E'{)7
5-25' < 1.0E.{)7 5.0E'{)7
3O-iJJ < 1.0E.{)7 < 1.0E.{)7
0' 1.1 E.{)7 2.7E-06
5-25' < 1.0E.{)7 l.7E.{)6
3()..60' < 1.0E.{)7 1.4E.{)7
',",',",',',',',',',',',',',',',',','.',','1'.",',','"'','".",",",',",",','."','.'."',',',',".'.".'.',','.'.',"".,,,,,,,,,,,,,,",,,,,,,,,,,,-,"',,,,,,,"'...'.',".','.".".'.'.','''''.'''''.'.','.',',','.-.-,'.'.'.".".'.'"''',','''.'.".'.".".'.'.'.'.'.'.'.""".".".".".'.'.'.".'.".".'.'.'.'.'.'.'.'.'.'.".'.'.'.'.'.".'.".".'.".'.'.'.'.'.".".".".".'.','.'.'.".'.'.".".".".'.'.'.'.".".'.'.'.'.'.".'"".'.".'.'.'.'.".'.'.'.'.'.','.'.'.'.'.'.'.','.".',".".'.'.'"
Benzo(o)pyrene
Totol HPAHs
T otol PCBs
Job No. 00737.()12.005
«(OUBFS793JQ..W)tb19 I 9/13/93 I eI)
Paged old
-------
Cold Creek Fill Area
None of the Don-<:arCinogenic compounds of potential concern exceed or approach the HQ target value
of 1.0 (Table 8). Dep~-stratified risk levels are also below 1.0 (Table 9).
CalcuIated average .and RME -risk values for surface and subsurface soils at the Cold Creek Fill do not
indicate elevated risk: levels from sub-d1ronic exposures to soil by construction workers (average and RME
cumulative carcinogenic risk levels of 9.1E-08 and 8.2E-07, respectively).
On-Site Deep Groundwater
Table 9 provides the hazard quotient (HQ) values and cancer risk levels calculated for non-carcinogenic
and carcinogenic compounds, respectively, of potential concern for hypothetical on-site residential receptors
(adult and child) and on-site workers potentially exposed to contaminants in groundwater. Results are reported
based on the cumulative average and 95 percent upper confidence limits for each contaminant and RME
exposure scenarios by compound and receptor.
Table 10 indicates that the HQ values calculated to address non-carcinogenic exposures of TCA, DCE,
or chloroform were below the target value of 1.0, which suggests that measured concentrations are weu below
levels of toxicological cOncern.
The estimated cancer risk estimates for the three on-site receptors were within the "acceptable"
upperbound cancer risk guideline of 1.0E-04 to 1.0E-06. Calculated cancer risK levels for the hypothetical
on-site residential child, for cumulative average and RME values were I.liE-OS and 4.4E-05, respectively.
Calculated cancer risk levels for hypothetical on-site adults, representing cumulative average and RME values
were 4.6E-06 and 5.0E-06, respectively. Calculated cancer risk levels for on-site workers, representing
cumulative average and RME values were 4.1E-07 and 1.2E-06, respectively. Most of these calculated risk
levels are virtually completely accounted for by the presence of DCE in groundwater. These calculated risk
levels for the other suspected carcinogen, chloroform, for on-site residents were in the 1.0E-07 range (less
than I percent of the total). Of the two pathways considered, drinking water ingestion accounted for at least
97 percent of the total exposure; inhalation was Dot found to be a significant factor.
7.2.4.1 Evaluation of Off-Site Risks
Off-Site Deep Groundwater
The calculated total cancer risk levels for the hypothetical off-site residential adult and child based on
exposure to hydraulically downgradient deep groundwater from the off-site hypothetical well #1 (HW-l) is
provided on Table 11. The risk assessments are based on modeled concentrations for DCE and chloroform
based on current conditions. The total cancer risk estimates for the off-site hypothetical adult is 1.38E-05 and
for the child is 1.34E-05, which is within the "acceptable" cancer risk range of 1.0E-04 to 1.0E-06.
diac2lhpalrodoub.2
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Table 10
Estimated Hazard Quotients and Ufetime Cancer Risk From On-Site Groundwater, Hypothetical
On-Site Residents and Workers . .
BPA Ross Complex OUB FS
Hypothellcal Adult Hypothetical ChIld . Worker
compound (average) (RME) (average) (RME) (average) (RME)
:-:';*;'X"«W:-:«;.;.;~~:.;«Y»;';';
Hazard Quotient .
l.1.1-TCA < 0.01 0.01 0.01
l.l-DCE 0.01 0.02 0.03
Chloroform < 0.01 0.02 0.02
CarcinoQens
l.l-DCE
Chloroform
0.03
0.09
0.08
<0.01
<0.01
<0:01
<0.01
<0.01
<0.01
Total Cardnogeric Risk =
4.9E-06 4.5E-05 1.6E-05 4.4E-05 4.0E'{)7 1.2E~
<1.0E.{)7 6.2E.{)7 1.5E.{)7 6.0E.{)7 < 1.0E.{)7 <1.0E.{)7
5.0E-06 4.6E-05 1.6E-05 4.4E-05 4.1 E.{)7 1.2E~
:-:.:.:.:.:.:.:o:.:-:.;.:.:.:.:-;.;.»:.:.:.:.:-:-:.m«(o:«-~":««-»»:«-»:'>:-»:««-:.:-:-»:.:-:-:«-:.:.;.:-:«-:-:-:-:.;.;.:-:.;.:«-:.:.:.:.:.:.:.:.:.:.:«.»:.:.:.:-:-:-:.:-.-.:.:-:-:-:.;.;.:o:.:.;.:.;.:-:-:-x-:.:.»:-»."-:.;.:-:-:-:'»:-:-:-:-:':';'XV:':';';':':-:-:':-:-:';':':':':':';':':':':':';';.:.:.:.:-:.:.:.:.;.:.:-[[[':-:':
Table 11
Estimated Hazard Quotients and Ufetime Cancer Risk to Off-Site Groundwater,
Hypothetical On-Site Residents (a)
BPA Ross Complex QUB FS
Compound
Hypothetical Adult
(RME)
Hypothetical Child
(RME)
.',','.'.','.',',',','.',','.'.',',','.',',',',',,,,.',',',',','.',',"',',','."',','.'.'.',""'"
'.'.'.'.'.',',','.'.'.',',',',',','
'.' '.',','.',','.','.','.",",' '.'.'
"",',',','.',','...',',',','.',','.'.',',',',','.........'.','.'
HVDOthetical WeI1lHW.1\
Hazard Quotient
l.l-DCE
Chloroform
Total Carcinogenic Risk =
0.01 0.03
0.01 0.04
1 .35E.{)5 1.31 E-05
3.11 E.{)7 3.ooE.{)7
1 .38E.{)5 1.34E-05
Carclnoaenlc Risks
l.l-DCE
Chloroform
..-.:-:.:.:':.:.:.:':':':':':':-:'x-:-:-:':.:..:.;-:«-»>=.;..:«-:-»:~:-:'»:-:':':':.:.:':';':':':..:.:.:':':':..:';':.:.:.:.:-:':..:-:-:':':':,:,:-:-:..:.:,:.:,:,:.;,:.»:,:,:,:.:-:-:.:-;..-.:.:,:,;.:-:-:-:.:,:.:,x,:,:,:,:-:.;.;':':':':';':':':':-:':':';':':';':':':.:,:.:..:,:-:-:,:«-»:.:.x..:,x,;..:,:-:.:-:-:-:':-;';':';':-:-:':':':-:';-:':':':,:,:.;,;
HVDOthetical WelllHW.2\
Hazard Quotient
l.l-DCE
Chloroform
0.00
0.01
0.02
0.04
Carclnoaenlc Risks
l.l-DCE
Chloroform
9.02E-06
3.ooE'{)7
8.71E-06
2.90E'{)7
Total Carcinogenic Risk =
9.32E-06
9.ooE-06
'.'.'''''.'..,'.'.'.'.'.'.'.'.',',','.'.'.'.'.',',',',','"".,.,.,.",.,.,.""",,,,',"',',"'...','.'.','.'.',',',',',','.'.'.'.',',',','.'.'.'.',',','.','.'.'.','.','..,'
'.',','.....'..,',',','.','...'.','.'.','.','.'.','.',','''''.',','.','.'.',',','.'."
'.'.',',','.','.','.'.'.',','.','.',',','.','.','.','.',','..,','..,'...',','.'.','......
Footnote:
(a) Modeled downgradient groundwater concentrations calculated to be
0.003 mg/I for chloroform and 0.0018 mg/l for 1.I-DCE for HW-l. and
-------
..
The total cancer .risk eStim~ for the hypothetical off-site adult and cbild associated With exposure to
hydraulically downgr8&eot deep groundwater from the off-site hypothetical well #2 (HW-2) is also provided
in Table 11. Assumptions made to model groundwater contaminant concentrations downgradicot of the Site
were conservative. Total cancer risk estimates for the:off-site hypothetical adult and cbild is 9.3E-06 and
9.0E-06, respectively. The concentrations are within the acceptable cancer risk range of 1.0E-04 to 1.0E-06.
7.2.5 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 conmminant concentration
data for soils and ground water; 3) the inclusion of concentrations at a level one-half the detection limit for
many chemicals; and 4) the use of a number 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-cancer risk estimates must be carefully interpreted, particularly
when evaluating non-carcinogenic 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 risk assessment are inexact, all are
designed to be conservative and therefore, are protective of all receptors considered.
7.3 ECOLOGICAL RISK ASSESSMENT
The purpose of the ecological risk assessment was to characterize ecological hazard or risk to terrestrial
or aquatic receptors. Aquatic life was considered the most conservative receptor since they cannot easily
avoid contaminated water as compared to terrestrial life. Conditions protective of aquatic receptors were
presumed to be protective of terrestrial wildlife that could use Cold Creek as a drinking water source. 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 and focused on potential exposures to aquatic life inhabiting the surface
water and sediments of Cold Creek. A reasonable maximum exposure (RME) was used to address potential
ecological exposures.
The toxicological properties of the surface water and sediment indicator compounds were reviewed, and
benchmark values were derived to address chronic toxicity to aquatic life. EPA Ambient Water Quality
Criteria (A WQC), which have been established for the general protection of aquatic life, represent a high
quality body of aquatic regulations based solely on toxicity data acquired from numerous diverse studies on
specific aquatic contaminants. Chronic A WQC were used when available as benchmark values for surface
water in the ecological risk assessment. Where chronic toxicity A WQC values were not available, they were
estimated based on acute toxicity data. Since numerical freshwater sediment quality criteria have not been
established, dose-response data from various studies were used to address sediment toxicity for the protection
of sediment-dwelling organisms. The ecological hazard for exposure to sediment included normalizing the
organic benchmark values to an assumed total organic carbon (rOC) content of one percent.
dis<2Ibpalrodoub.2
45
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7.3.1 Risk Characterization
Aquatic ecological risks were estimated for each chemical in which ~e dowastream average concentration
in water and sediment (Stations SW-4 and SED-4) exceeded the upstream (Stations SW-I and SED-I) average
conccntrations. Tbe ecological hazard quotient (HQ) for aquatic life (~tors) was estimated as the average
water and sediment concentration from Cold Creek divided by the Ambient W~ Quality Criteria or
appropriate toxicological benchmark value (Table 12).
All of the remaini~g individual HQ values fall below 1.0, the threshold level of concern. Aquatic
organisms in Cold Creek are therefore not likely to be at risk as a result of exposure to the average
concentrations in water and sediment identified at Station SW-4 and SED-4.
di8c2\bpalrvdaub.2
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Table 12
Hazard Quotients for Aquatic Receptors
Downstream UnfiUered Water (N= 6) and FiUered Water (N=4)
BPA Ross Complex QUB RI (Downstream I: Site 4)
Chemicals evaluated are those for which the downstream maximum exceeded the upstream maximu-n
Concentrations in ug/L.
Freshwater
Chronic
Crtterton
(0)
Average
Downstream
Concentration
(SW-4)
Maximum
Upstream
Concentration
(SW-1) (b) .
Hazard
Quotient
"""""""""""'"'" ",",",",',"........'....',".'.","....",",'."','.",",',".."."",",",",",",",",",",",',',',.....'.",.' ......
. "...",',",-,".....'...........'..',..... . ....,....", ...... .. .....',v...... ,',", ',..."""" ,'.......' """""-,"",",",,,,,,,""""","',',",',"',",',"........... h'" ""',,,,,".' .......
Trace metals. total
Aluminum NA 961 1760 NA
Arsenic 48 1 4U 0.03
Barium NA 29 SOU NA
Ovomium (assumed hexavalent) 11.0 4 6W 0.38
Cobalt NA 2 3U NA
Iron NA 2471 2580 J NA
Magnesium NA 9693 10300 NA
Manganese NA 363 200 NA
Potassium NA 2363 2390 NA
Sodium NA 6827 7200 NA
Vanadium NA 14 10 NA
Zinc 106 33 34 0.31
Trace metals. dissolved
Aluminum NA 11 121 NA
Arsenic 48 1 U 2V 0.02
Barium NA 13 14 NA
Chromium IV 11.0 0.2 U 6U 0.02
Cobalt NA 3U 3U NA
Iron NA 177 143 NA
Magnesium NA 10423 10.300 NA
Manganese NA 115 7 NA
Potassium NA 2393 2.390 NA
Sodium NA 7168 7200 NA
Vanadium NA 8 9 NA
Zinc 106 3 9 0.03
POlycydic Aromatic Hydrocarbons (PAH)
HPAH (high molecular weight)
Benzo(a)pyrene 0.2 6.50E-03 0.01 U 0.03
Benzo(a)onthrocene 0.2 1.00E-02 0.01 U 0.05
Chrysene 0.2 I.BBE-02 0.021 0.09
Benzo(b)fluoronthene 0.2 1.97E-02 0.012 0.10
BenzoCk)fluoranthene 0.2 6.33E.Q3 0.01 U 0.03
Benzo(g.hJ) perylene 0.2 1.1 8E-02 O.02U 0.06
Ruorene 0.2 l.ooE.Q2 0.01 U 0.05
lndeno(1.2.3-cd)pyrene 0.2 I.33E.Q2 O.02U 0.07
Ruoranthene 159.2 7.25E-02 0.016 0.00
Pyrene 79.6 3.57E.Q2 0.032 0.00
Misc. BNAs
Propham 264 0.9 1 U 0.00
. .~'. . ,', .~ . . .'.'.~'.'. ...... ...~'... .'.v,',"','... ,". ,,,',",',',',',"'."""'.". . .', ,',".',", ,,,,,,,,,,,,......................,..........,,,.. ',',',',"',"'.....',",',',".-. ,',",', .'.'.'.'.'.'.'.',-,""'.'.'.'.'.'.'.'.'.'.'...'.'~.'. .'. .',-,'.'.'." .'. . . ,", ,", ,', . . . ,', .. ,',-."'.'.',',',', ,','.'. . .'. . . . . ,", ,",",', ,',',', . ,", . . . . . .'. '''''''''''''''''''''''',",'''''0', .'. . ,',",',',',',',',",',',',"""',',',',',',',',"',',',', .
fOOTNOTES
NA . not cppticable. generally becaJS8 neither freshwater acute nor c:tYonc AWOC', e>is! for fI'is ~
(a) Origin arid derivation of fhe>ellOluesae shown on Table 7.13,
(b) ~ean contcrnincnt dala repr...."edbySlationC.SlNI.
Job No. 00737-012-005
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8.0 REMEDIAL ACI'ION OBJECI'IVES
. -
Remedial action is required to protect human health and the environment at the Fog Chamber Dump
Trench Area 1 and Trench Area 2. The following findings of the remedial investigation and:baseline risk
assessment support the need for remedial action in these areas:
. At the Fog Chamber Dump Trench Area I, there is a 2.3E-03 risk to on-site wodcers associated with
exposure to subsurface soils. PCBs were detected at concentrations of 30,000 ppm at six to fifteen
feet below ground surface. This contributes significantly to the risks associated with Fog Chamber.
Dump Trench Area 1. High levels of metals (lead, arsenic and copper) were detected in various
locations.
. In Fog Chamber Dump Trench Area 2 soils containing up to 16,000 ppm of lead were identified as
well as significantly elevated levels of other metals (copper, arsenic, zinc and antimony)
The results of the RI indicated that Bumt Bridge Creek, Cold Creek and the Cold Creek Fill Area do not
pose unacceptable risks to human health or the environment, therefore no action is necessary at these areas.
The results of the RI also indicated the presence of low levels of TCA, DCE and chloroform in the
shallow perched water table and the deep aquifer. The shallow perched water table at the site is not
considered a usable source of drinking water due to insufficient yield; therefore, it was not included in the
baseline risk assessment. The occurrence of DCE and chloroform in the deep groundwater-does not pose an
unacceptable risk to human health or the environment' and does not require remediation. However, the MCL
for DCE is slightly exceeded in one on-site deep monitoring well and the deep Troutdale aquifer is used
extensively as a drinking water resource. Therefore, BPA win continue to monitor groundwater contaminant
concentrations on-site in both shallow and deep monitoring wells.
. The specific goals and objectives of the remedial action at the Fog Chamber Dump Trench Areas 1 and
2 are:
. To prevent direct contact with contaminated soil;
. To prevent future disturbance of contaminated soil;
. To prevent surface water infiltration, and;
. To create an area at Fog Chamber Dump Trench Area I that can be used by BPA for storage of
heavy equipment.
9.0 DESCRIPTION OF ALTERNATIVES
Six altematives were initially evaluated for soil remediation at the Fog Chamber Dump Trench Areas 1
and 2. The approximated volume of soil that requires remediation include 2,160 cubic yards in Trench Area
1 and 16,666 cubic yards in Trench Area 2. The general response actions initially considered for soil
remediation alternatives for Operable Unit B included:
dilc2\bp>lrodoub,2
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o Alternative A -,. No Action. - .
. 0 -Alternative B - Limited Excavation and Off-Site Disposal.
o Alternative C - In-Situ Vitrification
o Alternative D - Capping with Institutional Controls.
o Alternative E - Ex-Situ Treatment and Disposal. and
o Alternative F - Institutional Controls
9.1 ALTERNATIVE A - NO AC110N
The No Action alternative is required by the National Contingency Plan (NCP) and serves as a baseline
against which other soil remedial alternatives can be compared. Under this alternative. no remedial activities
would take place. This alternative does not protect the public health or mitigate un9~le environmental
risks associated with the contamination.
9.2 ALTERNATIVE B - UMITED EXCAVATION WITH OFF-SITE DISPOSAL
Contaminated areas that exceed clean up levels would be excavated. Debris and soil would be sorted into
separate waste streams. The material would be disposed in an approved off-site landfill. Confirmatory
sampling would be conducted following excavation to ensure that the contamination has been removed.
Although an attempt to remove all contaminated material above the cleanup levels would be performed, it is
likely that residual contamination would remain due to the nature of the waste disposal in the dump areas.
9.3 ALTERNATIVE C - IN-SITU VITRIFICATION
Contaminated soil would be treated using in-situ vitrification, a thermal treatment technology which
oxidizes organic contaminants and physically binds inorganic contaminants into a glass-like substance that is
resistant to leaching. Gaseous emissions generated during processing are confined and drawn through the
hood for cooling, scrubbing, filtering, and chemical treatment. Vitrified material would be left in place and
any subsidence above the vitrified mass would be refilled with clean fill. The surface would then be paved
or revegetated.
9.4 ALTERNATIVE D - CAPPING WITH INSTITUI10NAL CONTROLS
This alternative involves the placing of a cap over the contaminated area. The cap would control erosion.
eliminate human contact and minimize the infiltration of water into the contaminated material. Institutional
controls would restrict access and limit future land use. For the Fog Chamber Dump, Trench Area 1, an
estimated area of 8,025 square feet will be capped. Three cap designs for Trench I were evaluated including:
1.) Resource, Conservation and Recovery Act (RCRA) cap with clay layer and soil surface; 2.) Minimal
Functional Standards (MFS) cap; and 3.) crushed rock surface. A RCRA cap is used to contain RCRA
hazardous waste. The subsurface soil contamination in Trench I would not be a RCRA hazardous waste
because it was disposed prior to 1980 and it would not be moved or -actively managed-. Although a RCRA
cap would not be required, it is included in the evaluation as the most restrictive cap and therefore provides
a basis for comparison.
diae2\bpa1roclouh .2
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A Minimum Fuoctioaal Standard (MFS) cap is designed to satisfy the State of Washington public health
and safety requirements (RCW 70.95.075) for solid waste landfills. The intent of the MFS cap is to'iDinimize
surface watec and groundwatec contamination associated with coDmmin..ted subsurface soil. The cap design
inclu.des the use of a liner over the waste material with sand and geot.extile fabric overlain by crushed rock.
the crushed rock surface cap design is the least restrictive of the three options and does not meet RCRA
or MFS cap design criteria. This design overlies a crushed rock surface over the waste material. This cap
can be used when contaminated material poses a low risk through human contact, surface water infiltration,
and groundwater contamination.
Only one cap design was evaluated in the FS for the Fog Chamber Dump, Trench 2. Evaluation included
a RCRA cap with a clay layer and soil surface (Option 1). The most restrictive cap design alternative was
selected for cost evaluation purposes only.
9.5 ALTERNATIVE E - EX-SITU TREATMENT AND DISPOSAL
All contaminated areas would be excavated and debris and soil would be separated similar to Alternative
B, Limited Excavation with Off-Site Disposal. Separated metal objects would be sent off-site for recycling,
and solid waste that was not a hazardous waste would be disposed at an off-site solid waste landfill.
Hazardous waste would either be disposed off-site at an approved landfill, or incinerated off-site and disposed
in an approved landfill.
9.6 ALTERNATIVE F - INSTITUTIONAL 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 and land use restrictions would limit future land use and prohibit
disturbance of soil.
9.7 ALTERNATIVES RETAINED FOR DETAILED EVALUATION
The following alternatives were retained for detailed analysis based on the results of the initial
screening.
Fog Cluunber Dump - Trend Area 1
. Alternative A - No Action,
. Alternative B - Limited Excavation with Off-Site Disposal
. Alternative D - Capping with Institutional Controls
4i1c2lbpa\rodoub.2
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. Altcmative E - Ex-Situ Tfeatment .and Disposal
. Altemative F - Institutiooal Controls
Fog Chamber Dump, Trench Ana 2
. Alternative A - No Action
. Alternative B - Limited Excavation with Off-Site Disposal
.
Alternative D - Capping with Institutiooal Controls
. Alternative F - Institutional Controls
Alternative C - In-Situ Vitrification was screened out for further analysis in both the Fog Chamber Dump,
Trench Areas 1 and 2 because of the difficulties involved in implementation and prohibitive costs. Alternative
E, Ex-Situ Treatment and Disposal. was also screened out for further analysis in Trench Area 2 due to the
prohibitive costs.
10.0 COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives for each waste unit were 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 hum' an health and the environment
and compliance with ARARs. The chart illustrated in Figure 7 shows the relationship between the screening
criteria, the nine evaluation criteria, and the role of the criteria during remedy selection. The following
sections present the comparison of alternatives.
diac2\bpa\rodoub.2
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Screening Criteria
Nine Evaluation Criteria
Role of Criteria During
Remedy Selection
Effectiveness
I
......a
ImP1:en~~bmty- - ~
.1; . ..,,-,,~~~~,_._._,,_J
Overall Protection of Human
Health and Environment
"Threshold" Factors
I
--,
I
Compliance with ARARs
-_.-
.-.-
Long-Term Effectiveness
and Permanence
Reductions In Toxicity, Mobility,
and Volume through Treatment
Short-Term Effectiveness
'.Prlmary Balancing" Factors
>1
...-..
>1
.....,.._..~"
I
-----. ...
-," J
Implementa.blllty
. ~ 'v''''''''':'-'' --~ -~_.
,~_J
I
I
State Acceptance
"Modifying" Considerations
.........."
---....._~. ~_.~ .........-~........
Community Acceptance
""PooW~~.s:..t;~I"""'..-rtMC .
Figure 7
-------
10.1 COMPARA'nVE ANALYSIS FOR FOG CHAMBER DUMP, TRENCH AREA 1
Target Contaminants: PCBs. Metals.- HPAHs
Soil Volume: 2.160 cubic yards .
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. Since Alternative A is not protective, it will not be further evaluated.
Alternative B, Limited Excavation with Off-Site Disposal, offers a higher level of overall protection than
Alternatives A, D and F through the removal of contaminated materials from the Site. Contaminated materials
would be transported to an approved landfill for disposal.
Alternative D, Capping with Institutional Controls, offers a level of overall protection higher than
Alternative A through both the construction of a cap arid site restrictions des.igned to prevent exposure to
contaminants.
Alternative E, Ex-Situ Treatment and Disposal offers the highest level of protection as compared to
Alternatives A, D, and F by removing contaminants from the site, treating the material off-site and disposing
of the material in an approved landfill.
Alternative B, limited Excavation with Off-Site Disposal, is similar to Alternative E through the
excavation and removal of contamination. The majority of the contaminated soil would be removed; however,
due to the nature of the disposal, it is likely that residual contamination would remain.
Alternative F, Institutional Controls, offers a slightly greater level of protection than Alternative A
through site restrictions designed to prevent exposure to contaminated material. However, Alternative F is
not as protective as Alternatives B, D and E.
10.1.1.2 Compliance with ARARs
Compliance with ARARs is a consideration of how the alternatives comply with other regulations
explicitly applicable to the site and with those sufficiently relevant and appropriate to warrant inclusion.
Alternative B, limited Excavation with Off-Site Disposal and E, Ex-Situ Treatment and Disposal, would
be required to meet transport and handling ARARs and would comply with the Southwest Air Pollution
dioc2\bpa\rodoub.2
-------
Control Agency's (SW APCA) general standards for maximum air emissions during the actual excavation and
treatment. MTCA cleanup ,levels would be met.
Alternative D, Capping with Institutional Controls, would comply with the Minimal Functional Standards
(MFS) ARARs for capping land~lls since high levels of contamination would be left in place and would
comply with the MTCA. .
Alternative F would co~ply with MTCA requirements to prevent contact and exposure.
10.1.2 Primary Balancin2 Criteria
10.1.2.1 Long-Term Effectiveness and Permanence
This criterion evaluates the long-term effectiveness aDd permanence of alternatives in maintaining
protection of human health and the environment after remedial action objectives have been met.
Alternative B, Limited Excavation with Off-Site Disposal, and Alternative E, Ex-Situ Treatment and
Disposal, have a high degree of long-term effectiveness and permanence. These alternatives minimize the
risks associated with contaminated soils by their removal from the Site. Due to the distribution of the waste
disposal activities in the dump areas, it is likely that residual waste would remain. Residual risk to the on-site
worker would not represent an unacceptable cancer risk.
Alternative D, Capping with Institutional Controls, would be slightly more effective than Alternative F
but less effective than Alternative B. Under this alternative, contaminants would be left in place and a cap
would be installed over them. This cap would prevent exposure to the contamination. The permanence of
Alternative D would depend on the effectiveness of institutional controls and on long-term maintenance of the
cap. Residual risk to the on-site worker would not represent an unacceptable cancer risk.
Alternative F, Institutional Controls, controls long-term risks by minimizing the potential for disturbance
of contaminated materials. This alternative requires the facility to maintain the institutional controls and
ensure that restrictions are enforced.
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. Although these alternatives do not meet
MTCA's preference for treatment, in the case of landfills, excavation of waste often creates more
environmental harm than good.
Alternative E, Ex-Situ Treatment and Disposal, is the only alternative that includes treatment. Following
excavation, solid debris would be separated from soil and debris would be further sorted into four waste
-------
stream categories: non-hazardous waste, hazardous waste, material requiring disposal, incineration or
treatment, and recyclable material. This alternative includes an incineration - component of various waste
stream categories which offers greater reduction through treatment as compared to Alt.ematives B, Cor D.
10.1.2.3 Short-Term Effectiveness
This criterion addresses the effects of the alternative during the construction and implementation phase
until remedial action objectives are met.
Alternative B, Umited Excavation with Off-Site Disposal, and Alternative E, Ex-Situ Treatment and
Disposal, present more potential for increased short-term risk to the community, workers, and the environment
due to the potential exposure to dust generated during excavation as compared to Alternatives D or F. These
risks can be effectively controlled using standard dust suppression methods, personncl protectivc equipment
and through the implementation of a health and safety plan. Additional risks would include physical hazards
associated with construction and transportation risks related to the transport of contarojnAtM material to
appropriate landfills. These risks would be eliminated after the implementation of the alternative which is
expected to require eight weeks. This time frame is longer than Alternative F, but less than Alternative D.
Measures to control the risks would be implemented prior to excavation.
Alternative D, Capping with Institutional Controls, would present a lower short-term risk than
Alternatives Band E. The 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 could be
effectively controlled. Time to implement this alternative is approximately three months.
Alternative F, Institutional Controls, would not present additional short-term risk because contaminated
materials would not be disturbed. Site restrictions would be implemented in about two weeks and deed and
other hind use restrictions would be implemented thereafter.
10.1.2.4 Implemcntability
This criterion addresses the technical and administration feasibility of constructing, operating, and
maintaining a remedial action alternative.
Alternative E, Ex-Situ Treatment and Disposal, is the most difficult to implement due to the need for
excavating, sorting transporting, and incinerating or disposing of landfilled soil and debris. Alternative B,
Limited Excavation with Off-Site Disposal, is less difficult to implement as compared to Alternative E since
the excavated material would not be sorted.
Alternative D, Capping with Institutional Controls, is readily implementable as compared to Alternatives
B, Limited Excavation and Off-Site Disposal and E, Ex-Situ Treatment and Disposal since labor and
equipment for installation of the cap are readily available and capping technology is common and widely used.
ditc~\bpa\rocIoub.'2
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AlterDative F is the easiest to implement as compared to Altcmative B, D, and E since obtaining deed
and land-use restrictiODs require only edmini!:trative procedures.
10.1.2.5 Cost
Cost is another criterion by which candidate alternatives are compared. Costs in this case are measured.
as total present worth costs. . The prescot worth costs which include both capital and operation and
maintenance costs for the remedial alternatives at the Fog Chamber Dump, Trench Area 1 for 2,160 cubic
yards of contaminated soil is as follows: ..
Alternative
Present Worth
Cost
Alternative B - Limited Excavation with
Off-Site Disposal
$2,087,270
o Assumes 2,160 cubic yards excavated with
residual contamination left in place.
Alternative D - Capping with Institutional Controls
Option 1: RCRA Cap, Clay Layer with Soil
Surface
$240,000
Option 2: MFS Cap
$150,000
Option 3: Crushed Rock Surface
$130,000
Alternative E - Ex-Situ Treatment and Disposal
o Assumes 2,160 cubic yards will be
excavated
o Assumes all material is hazardous
(includes incineration)
$3,590,000
o Assumes 50 percent is bazardous
(includes incineration)
$1,930,000
Alternative F - Institutional Controls
$30,000
o Assumes fencing and signs
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10.1.3 Modifvint! Criteria
Modifying criteria are used in the final evaluation of the remedial altematives, and include input from
Ecology and from the public.
10.1.3.1 State Acceptance
The State of Washington concurs with the selected remedy and comments received from Ecology have
been incorporated into this Record of Decision. . -
10.1.3.2 CommuDity Acceptance
Based on the comments received during the public review period and at the public meeting, the public
accepts the preferred alternative.
10.2 FOG CHAMBER DUMP TRENCH AREA 2
Target Contaminant: HPARs and metals
Soil Volume: 16,666 cubic yards
10.2.1 Threshold Criteria
10.2.1.1 Overall 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. Since Alternative A is not protective, it will not be further evaluated.
Alternative B, Limited Excavation with Off-Site Disposal, offers a higher level of protection as compared
to Alternatives A, D, and F by removing contaminants from the site and disposing of the material in an
approved landfill; however, residual contaminants would likely be left in place due to the nature of the waste
disposal in this area.
Alternatives D, Capping with Institutional Controls, offers a greater level of protection as compared to
Alternative A through construction of a cap and site restrictions that are designed to prevent exposure to
contaminants .
Alternative F, Institutional Controls, offers a greater level of protection as compared to Alternative A,
through site restrictions designed to prevent exposure to contaminants. However, Alternative F is not as
protective as Alternatives Band D.
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10.2.1.2 Compliance with AR.ARs
Altemative B, Umited Excavation with Off-Site Disposal, would be required to meet transport, handli~g,
and disposal ARARs. AltcmativeD, Capping with Institutional Controls would have to comply with ARARs
for capping landfills and MTCA requirements but would not meet the soil cleanup levels identified for the site
under Alternatives C and E.
Alternative F will comply with MTCA requirements to prevent contact; however, it would not meet the
soil cleanup levels identified for the site under Alternatives B, C, and E. . -
10.2.2 Primarv BalanciOl~ Criteria
10.2.2.1 Long-term Effectiveness
Alternative B, Excavation with Off-Site Disposal, has the highest degree of long-term effectiveness and
permanence. This alternative reduces the risks associated with contaminated soils by excavating and
transporting soils off site to an approved landfill. Due to the nature of the disposal area, it is likely that
residual contamination will be left in place. Residual rislcs to the on-site worlcer will not represent an
unacceptable cancer risk.
Alternative D, Capping with Institutional Controls, has a lower degree of long-term effectiveness as
compared to Alternative B; however, a high degree of effectiveness and permanence can be achieved through
design and operations and maintenance. Residual rislcs to the on-site worker will-not represent an
unacceptable cancer risk.
Alternative F, Institutional Controls, is more effective than the No Action alternative. Site restrictions
would minimize the potential for disturbance of contaminated soils as long as the controls are maintained and
enforced. This alternative will not represent an unacceptable cancer risk to the on-site worker.
10.2.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment
No alternative includes treatment.
10.2.2.3 Short-Term Effectiveness
Alternative B, Limited Excavation with Off-Site Disposal, and Alternative E, Ex-Situ Treatment with Off-
Site Disposal, may involve short-tenn risk to on-site workers, the community, and the environment from
exposure to dust generated during the excavation of soil. These rislcs can be effectively controlled using
standard dust suppression methods, personnel protective equipment and through the implementation of a health
and safety plan. Additional rislcs would include physical hazards associated with construction and
transportation risks related to the transport of contaminated material to appropriate landfills.
d8c2lbpalntcloub.2
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Alternative F, Institutiooal Controlsr would not result in additiooal short-tenD risks since no remedial
activities would take place and contaminated materials would not be disturbed. It would take approximately
one wedc for iDstaIJation of site restrictions and about three months to implement deed restrictions and land-
use restrictions.
Alternative D, Capping with Institutiooal Controls, would involve a lower short-term risk to on-site
workers, the community, and the environment from exposure to dust generated during capping activities as
compared to Alternative B and .E since contaminated soil would not be disturbed. Alternative D can coDtrol
the risk within 3 months. .
10.2.2.4 Implementability
Alternative B is the most difficult to implement due to the need for limiting screening and sorting,
transporting, and treating and disposing of landfilled materials.
Alternative D, Capping with Institutional Controls, is less difficult to implement than Alternative B due
to readily available capping materials and the cap is compatible with BPA future use of this area.
Alternative F is easier to implement than Alternatives B and D due to the need to only obtain deed and
land-use restrictions which are readily available.
10.2.2.5 Cost
The estimated cost of each soil cleanup alternative, based on the present worth costs capital including
capital and operation and maintenance costs and for remediating 16,666 cubic yards of contaminated material
in the Fog Chamber Dump Trench Area 2:
Alternative
Present Worth
Cost
Alternative B - Limited Excavation with
Off-Site Disposal
$3,098,785
Alternative D - Capping with Institutional
Controls (RCRA Cap)
$120,000
Alternative F - Institutional Controls
$5,000
o Assumes the use of signs
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10.2.3 Modifvin2 Criteria
10.2.3.1 State Acceptance
Tbe State concurs with the selected remedy and comments received from Ecology have 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.,
11.0 SELECI'ED REMEDY
11.1 KEY ELEMENTS OF SELECTED REMEDY FOR FOG CHAMBER DUMP TRENCH AREA 1
Based upon consideration of the requirements of CERCLA and state requirements, the detailed analysis
of the alternatives using the nine criteria, and public comments, the most appropriate remedy for the Fog
Chamber Dump, Trench Area 1, is MFS Capping with Institutional Controls (Alternative D). This alternative
provides protection of human health and the environment and can be implemented at a lower cost than any
of the other alternatives. The Fog Chamber Dump, Trench Area I, contains soil contaminant concentrations
above state cleanup levels between 1.5 feet and up to 20 feet deep. The MFS cap was selected because the
cap design provides protection of human health by eliminating the potential for contact and minimizes surface
water infiltration that could lead to groundwater contamination. Contaminated soils in Trench Area 1 are not
a RCRA hazardous waste; therefore, the RCRA cap design option was not selected. The crushed rock surface
cap does not satisfy MFS regulations and therefore, cannot be selected. Institutional controls will be used to
restrict access to this area by fencing, deed, and land use restrictions; implementation will eliminate the
potential for future disturbance of contaminated material. The Ross Complex Site Manager is responsible for
ensuring that the institutional controls are maintained at the Site.
Major components of the selected remedy includes:
o A MFS cap that consists of a impervious liner over a 1.5 foot layer of clean fiU material directly
overlying the waste. The cap will consist of a protective layer of sand, followed by a geotextile
fabric overlain by crushed rock.
o Institutional controls that consist of a fence with signs to restrict access and deed and land use
restrictions .
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11.2 KEY ELEMENTS OF SELECTED REMEDY FOR FOG CHAMBER DUMP TRENCH AREA 2
Based upon consideration of the requiremcots of CERCLA and state requirements, the detailed analysis
of the alternatives using the nine criteria, and public comments, the selected remedy for the compound of
concern in the Fog Chamber Dump, Trench Area 2, is Institutional Controls. This alternative provides
protection of human health and the covironmcot and can be implemented at a lower cost than any other of the
alternatives. The Fog Chamber Dump, Trench Area 2, contains soil contaminant concentrations that exceed
state. cleanup levels between 1.5 feet and 3.5 feet deep. SoUd waste such as wires and cables coated with lead
were encountered in the waste matcria1. Contaminant concentrations are considered to be associated with solid
waste rather than from waste generated by industrial processes. While the risk assessmcot determined that
this area did not pose an unacceptable risk under the current land use scenario, there are metal concentrations
that exceed MTCA cleanup levels significantly in the soil at isolated locations associated with debris.
Approximately 1.5 feet of clean fiU material overlies the waste material and contains a vegetative cover.
BPA's intended use of this area is for training purposes. Since the subsurface contamination is limited in
extent and does not represent a risk to human health or the covironment through direct contact or to ground
water, Alternative F, Institutional Controls, is the selected alternative for the Fog Chamber Dump Trench 2.
Institutional controls will be used to restrict land use activities through deed and land use restrictions that may
disturb subsurface contamination. lfa need arises to excavate in this area in the future, BPA will sample the
soils and properly dispose of contaminated soil in accordance with state and federal regulations.
11.3 KEY ELEMENTS FOR THE COLD CREEK FILL
Based upon the results of the RI it was detennined that the existing conditions at the Site were protective
of public health and the environment, therefore no further action is required for the Cold Creek Fill Area.
The Cold Creek Fill Area is an engineered fill that has been continually filled, compacted and graded overtime
with soil obtained from construction projects on the Complex. The upper sequence of the fill contains clean
fill material obtained from recent construction activities on the Complex. Soil contaminant concentrations
above the clean up levels were found in limited isolated locations between 5 and 25 feet bgs but were not
laterally extensive. Migration of contamination is unlikely in this area since the types of contaminants are
relatively immobile and soils in this area contain low permeability characteristics due to engineered controls.
Access to this area is restricted by fencing on the north and south sides and is topographically restricted on
the west side which serves as a barrier for egress and ingress. Furthermore, BPA's intended future use of
this area is for construction material and equipment storage as defined in the long term plans for the site.
Accordingly, no further action is required for the Cold Creek Fill Area.
11.4 KEY ELEMENTS FOR SITE GROUNDWATER
Based upon the results of the RI, consideration of the requirements of CERCLA, and public comments, .
BPA will continue to monitor for the presence of volatile organic compounds in the shallow perched water
table and the deep aquifer. The residual occurrence of volatile organic does not constitute an on-site or off-
site risk to human health and the environment. Since a groundwater contaminant source was not identified
by the RI, groundwater will continue to be monitored to detennine if the concentration will go up, down, or
remain sf:able. The additional groundwater monitoring is for five years and the chemical parameters,
dioe2\bp>\J'Odoub.2
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monitoring wells, and schedule are provided below. BPA may petition for discontinuing, narrowing, or
reducing the sample frequcncy after two years, depending on thc results. EPA, BPA and Ecology will jointly.
evaluate the aata to determine what, if any, continued monitoring or additional action may be n~.
Biannual Monitorin2
TCA, DCE, Chloroform
Monitorin2 Wells
MW-4A, MW-13B, MW-14B, MW-16B
Biannual monitoring (twice/year) will include both a wet and dry sca.Son. The approximate costs for
groundwater monitoring is $15,000 per year.. .
11.5 KEY ELEMENTS FOR COLD CREEK AND BURNT BRIDGE CREEK
Based upon consideration of the requiremcnts of CERCLA, state requirements and public comments, DO
further action is required for surface water and sedimcnts in Cold Creek and Burnt Bridge Creek.
12.0 Sf A TUTORY DETERMINATION
BPA and EPA's primary responsibility under CERCLA, is to ensure that the selected remedy will protect
human health and the environment. Additionally, Section 121 of CERCLA, as amended by SARA, establishes
several other statutory requirements and preferences. These specify that, when complete, the selected remedy
must comply with applicable and relevant or appropriate environmental standards established under federal
and state environmental laws unless a waiver is justified.
The selected remedy must also be cost-effective and utilize permanent solutions or resource recovery
technologies to the maximum extent practicable. The remedy should represent the best balance of tradeoffs
among thc altematives with respect to pertinent criteria. Finally, the statute includes a preference for remedies
that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal element.
The selected remedies for the contaminated soil at the Fog Chamber Dump Trench Areas 1 and 2 meet
the statutory requirements.
12.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy for the Fog Chamber Dump, Trench Area I will protect human health and the
environment through isolating the contaminants and through restricting surface water infiltration from the site.
Engineering controls will be utilized during the cap installation that will eliminate the potential for exposure
to dust. There will be no adverse effects on human health and the environment caused by construction and
implementation of the selected remedy. The cap will provide long-tenn effectiveness through operation and
maintenance activities.
diac2lbpaln>doub.2
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#
The selected remedy for the Fog Chamber Dump Trench Area 2 is considered protective ofbuman bealth
and the environment since use of the area win be restricted, 1.5 feet of clean fill material overlies the waste,
and the contamina~ts contain low mobility characteristics. Land use and deed restriction will prohibit future
disturbance of this area.
12.2 COMPLIANCE WITH ARARs
Tbe selected remedy of capping with institutional controls in the Fog Chamber Dump, Trench Area 1 and
institutional controls in the Fog Chamber Dump, Trench Area 2 will comply with the -ARARs presented in
the following list.
. Requirements of Washington Model Toxics Control Act (Initiative 97) for clean up of hazardous waste
sites, Chapter 70.105 RCW, as codified in Chapter 173-340 WAC;
. Requirements of State of Washington Public Health and Safety Requirement, RCW 70.95.075 as
codified in Chapter 173-304 WAC for solid waste landfills, and;
. General emission standards under WAC 173-400-040 for visible emissions, fugitive emissions and
emissions of air contaminants which are detrimental to persons or property.
12.2.1 Other Criteria. Advisories. or Guidance To-Be-Considered ITBC)
-
No other criteria, advisory, or guidance are considered necessary for implementation of the selected remedies.
12.3 COST EFFECTIVENESS
The selected remedies are the most cost effective alternative because they protect human health and the
environment, attain ARARs, and meet the objectives established for the remedial action in a way that is
proportional to their costs. The cost of the other alternatives evaluated were substantially higher and
s~gnificantly disproportionate as compared to the cost and benefits of the selected remedy at the Fog Chamber
Dump, Trench Area 1 and Trench Area 2.
12.4
tITlLIZA TION OF PERMANENT SOLUTIONS
TECHNOLOGIES
AND ALTERNATIVE TREATMENT
The selected remedy represents the maximum extent to which permanent solutions can be utilized in a
cost-effective manner at the BPA Ross Complex. The selected remedy provides the best balance of trade-offs
in terms of long-term effectiveness and permanence, reduction in toxicity, mobility, volume achieved through
treatment, short-term effectiveness, and cost.
diK2lbpolrodoub.2
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..
12.5 PREFERENCE FOR TREATMENT AS PRINCIPAL ELEMENT
The size of the trench areas and the nature of the contamination preclude a .;emedy in which cont~minants
could be excavated and treated safely and effectively. Therefore, because ~ent was. not found to be
practicable, the selected remedies do not meet the statutory preference for treatment.
13.0 DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes pertaining to OUB since the Proposed Plan was released for public
comment on June 25, 1993.
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ATIACHMENT I
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARy
. OPERABLE UNIT B
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 subsurface soil remediation and continued groundwater
monitoring for Operable Unit B at the Ross Complex located in Vancouver, Washington. The Site was listed
on the National Priorities list (NPL) in November 1989 based on the presence of volatile organic 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 Federal Facility Agreement signed by BPA, EPA, and the Washington
Department of Ecology (Ecology) on May 1,1990, BPA conducted a Remedial InvestigationIFeasibility Study
(RI/FS) to determine the nature and extent of contamination at the site and to evaluate alternatives for the
clean up of contaminated areas.
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
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
diac2lbpalrodouh.2
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 RIfFS.
Fact sbeet 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 Operable Units A and B, discussed OUA RI and risk
-------
.
August
A Proposed Plan for Remedial Action of ~UA was mailed to the public. The plan
described proposed remedial actions and selected remedies .for ~UA soils.
.
September 1992
A public meeting was held to present the findings of the RIlFS for Operable Unit A
and the selected remedial alternatives outlined in the Proposed Plan for Operable
Unit A.
.
May 1993
Fact sheet No.9 described the results of the RI for Operable Units A and B, that
groulidwater was not a public threat and gave advance notice af the upcoming July
1993 public meeting.
.
June 1~3
Proposed Plan for OUB Remedial Action of OUB was mailed to the public. The
plan described proposed remedial alternatives and selected remedies for OUB soil
groundwater, surface water and sediment.
.
July 1993
A public meeting was held to present the findings of the RIlFS for Operable Unit B
and the selected remedial alternatives outlined in the Proposed Plan for Operable
Unit B.
The public was given the opportunity to participate in the remedy selection process in accordance with
sections 117 and 113(k)(2)(B) of CERCLA. The Proposed Plan for Operable Unit B, which summarized the
alternatives evaluated and presented the preferred alternative, was mailed to approximatefy 800 interested
parties on June 24, 1993. BPA provided public notice through display ads in the Columbian and Oregonian
on June 22, 1993 to explain the Proposed Plan, list the public comment period, and announce the public
meeting. Media coverage was also provided in the form of local newspaper articles which appeared on June
2 and 6, 1993 and cable television news coverage on Channel 25 on June 1, 1993 and July 9, 1993.
. .
A 3o-day public comment period was held from June 25, 1993 to July 26, 1993. Approximately 20
people attended a public meeting, which was held on July 8, 1993 at the Ross Complex, DOB Auditorium.
No verbal comments were received at the public meeting and three written comments are included in the
attached Responsiveness Summary.
1. The Washington State Office of Archaeology and Historic Preservation (OAHP) acknowledges that
the Ross Complex is eligible for listing in the National Register of Historic Place. The proposed
alternatives for cleaning up contamination will not affect buildings and structures at the Ross
Complex which are National Register eligible. In the event properties may be impacted by work
associated with this action, OAHP requests consultation.
Response: It is correct that these remedial actions will not impact structures that may be eligible for the
National Register. Should BPA's plans change, OAHP will be alerted.
2.
There is concurrence with the need for ongoing groundwater monitoring.
di
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Response: No response.
.
3. The funds used to publish the Proposed Plan for Operable Unit B would be better used to cleanup
the site.
Response:
Communication, with the involvement of the public, is an essential feature of the CERCLA
process. BPA is required by law to issue a proposed plan that is available to the public for
review and comment.
clioc2\hp>\rodoub.2
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.
ATTACHMENT II
ADMINISTRATIVE RECORD LISTING
-------
1
I
i
.i
j
!
ROSS
COMPLEX SUPERFUND ADMINISTRATIV~ RECORD - .
opERABLE maT B --
BONNEVILLE POWER ADMINISTRATION
VANCoUVER, WASHINGTON
.
. The information contained in the Administrative Record is
dup1icated in the information repositorY 10cated in the
Vancouver pub1ic Lihrary at 1001 East Ki11 p1ain B1Vd. The
officia1 Administrative Record wi11 c10se when the Record of
Decision is signed. Information wi11 continue to .be added
to the information repositorY at the vancouver puh1ic .
LihrarY. This fHe has heen set up foHewing EPA
guide1ines. DUp1ication wi11 not he made of information
alreadY in operable unit A.
------------------------------------------------------------
0.0
TABLE OF CONTENTS
0.1
ADMINISTRATIVE RECORD INDEX
SITE IDENTIFICATION (see operable Unit A)
1.0
2.0 REMEDIAL INVESTIGATION (RI)
2.1 work Plan
2.2 sampling and Analysis plan
2.3 Sampling and Analysis Data
2.4 RI Reports
3.0 FEASIBILITY STUDY (FS)
Re1evant/APpropriate Requirements Determinations
3.1
3.2
FS Reports
proposed Plan
supp1ements and Revisions to the proposed p1an
3.3
3.4
4.0 RECORD OF DECISION (ROD)
4.1
ROD
4.2
AInendments to ROD'
Explanations of Significant Differences
4.3
5.0
REMEDIAL ACTION
5.1
-------
6.0
7.0
8.0
9.0
5.2
5.3
5.4
5.5
Sampling and Analysis Data
Engineering Evaluation/cost Analysis
Action Memorandum
.
6.1
COORDINATION.
Verification
6.2
6.3
6.4
cooperative Agreements (See Operable unit A)
EPA Coordination
State of washington Department of Ecology
7.1
HEALTH ASSESSMENTS
U S Department of Energy
7.2
7.3
Interagency Agreement (IAG) DOE/ATSDR
ATSDR Health Assessments
Toxicological Profiles
8.1
BPA INTERNAL INFORMATION
Communications
8.2
Ongoing site Control
9.1
PUBLIC PARTICIPATION
Community Relations Plan(See Operable Unit A)
9.2
9.3
9.4
Public Meetings
Comments and Responses
Public Notices/Press Releases
9.4.1 Press Conferences/Releases
9.4.2 News Articles
10.0 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS
9.5
Fact Sheets
,
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...
..
..
FILE DOC. NO. TITLE/TYPE DATE PAGES AUTHOR/ORGANIZATION ADDRESSEE/ORGANIZATION
0.0 0001 TABLE OF CONTENTS
0.1 0001 Operable Unit B Index 1
1.0 SITE IDENTIFICATION
See Operable Unit A
2.0 REMEDIAL INVESTIGATION (RI)
2.1 0001 Draft Work Plan IOper Unit B) 5/15/92 Dames & Moore BPA
2.4 0001 Final AI Volume 1 Report 3/19/93 Vol 1 Dames & Moore BPA
2.4 0001 Final RI Report Appendices Vol 1 3/19/93 App 1 Dames & Moore BPA
2.4 0001 Final RI Report Appendices Vol 2 3/19/93 App 2 Dames & Moore BPA
3.0 FEASIBILITY STUDY (FS)
3.0 . 0001 Feasibility Study 2/12/93 Dames & Moore BPA
3.3 0001 Proposed Plan June 93 13 Mailed to Aoss Neighborhood/Employees
4.0 RECORD OF DECISION (ROD)
5.0 REMEDIAL ACTION
5.2.1 0001 Disposal of investigative wastes 5/11/93 76 M. Allen, Dames & Moore Tony Morrell, BPA
6.0 COORDINATION
6.1 Federal Facilities Agreement See Operable Unit A Joint Agreement
6.1.2 0001 Ltr Transmit Draft OUB RI 12/10/92 1 Anthonv Morrell, BPA EPA and Ecology
6.1.2 0002 Ltr Transmit Draft OUB FS 2/12/93 1. Anthony Morrell, BPA EPA and Ecology
6.1.2 0003 Ltr Transmit Final OUB RI 3/19/93 1 Anthony Morrell, BPA EPA and Ecology:
6.1.2 0004 Ltr Transmit Final OUB FS 5/14/93 1 Anthony Morrell, BPA EPA and Ecology
6.,1.2 0005 Ltr Transmit OUB Proposed Plan 5/14/93 1 Anthony Morrell, BPA EPA and Ecology
6.1.2 0006 Ltr Transmit Final OUB AI 5/25/93 1 Anthony Morrell, BPA EPA and Ecology
6.2 0001 Ltr extend RI comment period 1/5/93 1 Nancy Harney, EPA Tony Morrell, BPA
6.2 0002 Ltr w/comments Draft RI 1/22/93 47 Nancy Harney, EPA Tony Morrell, BPA
6.2 0003 Ltr respond EPA comments 2/1/93 2 Anthony Morrell, BPA Nancy Harney, EPA
6.2 0004 Ltr re groundwater modeling 2/1 0/93 2 Nancy Harney, EPA Tony Morrell, BPA
6.2 0005 Ltr with Final RI comments 4/16/93 24 Nancy Harney, EPA Tony Morrell, BPA
Administrative Record 10r Operable Unit B, Ross Complex, Vancouver, WA
Page 1
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-
6.2 0006 Ltr re future groundwater monitoring 3/26/93 7 Anthony Morrell, BPA EPA and Ecology
6.2 0007 Ltr re futu~e groundwater monitoring 4/13/93 2 Nancy Harney, EPA . Tony Morrell, BPA
6.2 0008 Ltr w/updates for OUB Final FS 6/29/93 1 EPA/Ecology ,
6.3 0001 Ltr appt Tim Nord-Toxics Cleanup 12/21/92 1 Carol Fleskes, Ecology David Dunahay, BPA
6.3 0002 Ltr w/comments Draft RI 1/11/93 4 Chris Poindexter, Ecology Anthony Morrell, BPA
6.3 0003 Ltr w/comments Draft FS 3/12/93 3 Chris Poindexter, Ecology Anthony Morrell, BPA
6.3 0004 Ltr re future groundwater monitoring 4/6/93 1 Chris Poindexter, Ecology Anthony Morrell, BPA
6.3 0005 Ltr re EPA's comments on prop plan 6/7/93 2 Chris Poindexter, Ecology Anthony Morrell, BPA
7.0 HEALTH ASSESSMENTS
8.0 BPA INTERNAL INFORMATION
9.0 PUBLIC PARTICIPATION .
9.2 0001 Ross Community Contact List 6/1/93 2 BPA
9.2 0002 Ltr Notice of 7/8/93 public meeting 6/23/93 1 David Dunahay, BPA Interested Public/Neighbors
9.3 1001 Public Meeting (7/8/93) Comment Log 7/16/93 48 Interested Neighbors BPA, Public Involvement
9.3 0002 Official Comment Log Close 7/26/93 Comments BPA
9.4 0001 Public Meeting ad (7/8/93) 6122/93 1 The Oregonian Metro/Northwest
9.4 0002 Public Meeting ad (7/8/93) 6/22/93 1 The Columbian Northwest
9.5.2 0001 Studies find BPA Site no threat 6/2/93 1 The Oregonian Clark County
9.5.2 0002 Study: Ground water safe 6/3/93 1 The Columbian Columbia Country
9.6 Fact Sheet No.9 Env Studies Done See AR9.6 OUA 0009
10.0 TECHNICAL SOURCES See Operable Unit A
EX.xls I
Administrative Record for Operable Unit B, Ross Complex, Vancouver, WA
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