EPA/ROD/R10-94/081
November 1994
EPA Superfund
Record of Decision:
Northwest Transformer South
Harkness Street, Everson, WA,
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Northwest Transformer South Harkness Street
Superfund. Site
Final Remedial Action Plan
RECORD OF DECISION
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September 29, 1994
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
1200 SIXTH AVENUE
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Northwest Transformer South Harkness Street superfund site
Final Remedial Action Plan
Record of Decision
Table Of Contents
Record of Decision Declaration
state Concurrence
Decision summary
site Name, Location and Description
Vicinity Map
site History and Enforcement Actions
Highlights of Community Participation
site Characteristics .
summary of site Risks
Description of the Selected Remedy
Notice of Additional State Requirements
Groundwater Monitoring
Five-Year Review
Documentation of Significant Changes
Responsiveness Summary
Additional Figures and Tables
Figure 2: Site Map
Figure 3: Sampling Grid System
Figure 4: Residual PCB Concentration Map
Figure 5: Residual TPH Concentration Map
Table 1: Summary of Waste Disposal Quantities
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5
6
7
8
11
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Record of Decision Declaration for the
Northwest Transformer South Harkness Street site
Everson, Washington
statement of Basis and Purpose
This decision document presents the selected remedy for the
Northwest Transformer South Harkness street site in Everson,
washington, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of '1980
("CERCLA") as amended by the Superfund Amendments ,and
Reauthorization Act of 1986, and to the extent practicable, the
National contingency Plan ("NCP"). This decision is based on the
Administrative Record for this site, updated in August, 1994.
The attached index identifies the items which comprise the
Administrative Record upon which the selection of the Remedial
Action is based.
The Washington Department of Ecology concurs with the
selected remedy. A signed statement to that effect is included
on page 3.
, Description of the Selected Remedv
The selected remedy under CERCLA authority is no further
action. (
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In order to verify that groundwater in the vicinity of the
site remains uncontaminated now that response activities are
complete, groundwater monitoring must continue until the CERCLA
five-year review is performed, at which point EPA will determine
whether continued monitoring is necessary.
Notice of Additional State Reauirements
Although not part of the EPA selected remedy, the state of
Washington requires, pursuant to the Model Toxics Control Act
(MTCAi WAC 173-340), filing of institutional controls in the form
of deed notices that inform future property owners of the
presence of Total Petroleum Hydrocarbons and Polychlorinated
Biphenyls remaining on site above MTCA cleanup levels. The State
will be responsible for enforcing this requirement, if necessary.
Declaration statement
No further remedial action under CERCLA is necessary at this
site to protect public health or the environment, because a
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previous Removal Action eliminated the risks posed by the site,
as measured by EPA's CERCLA guidance.
EPA has determined that its response at this site is now
complete. Therefore, this site now qualifies for inclusion on
the Construction Completion List.
While the Removal Action eliminated the need to take further
action and the threat of direct contact exposure, some hazardous
substances remain on site in soils. To ensure that these
. contaminated soils do not contaminate the groundwater, a review
will be conducted within five years of this date to ensure that
the remedy remains protective of groundwater.
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Date
Chuck Clarke
Regional Administrator
u.s. Environmental Protection Agency, Region 10
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RECORD OF DECISION
NqRTHWEST TRANSPORMER.SOUTH HARKN~SS STRE;ET SITE
EVERSON, WASHINGTON
~iqnature and:sunnort ~qencv Accentance of the. Remedy
The state of washington con6urs with the selected remedy
under ClmCLA, No Fur'ther Aotion.
Although ~ot part of the EPA selected remedy, the.state of
Washington requires pursuant to the Model Toxics control Act
(MTCA: WAC 173-340) filing-of institutional controls in the fo~
of deed notices that inform future property owners of the
presence o~ Total Petroleum Hydrocarbons and Polychlorinated
Biphenyls ~emainin9:on site above MTCA cleanup levels. The state
will. be responsible for enforcing this requirement, if necessary.
1NAHE(v~gf (u4iM. [ q~:,h
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Record of Decision
Northwest Transformer South Harkness Street site
Decision summary
site Name. Location and Description
This Record of Decision describes the selected remedy for
the Northwest Transformer South Harkness Street site (the
"site"). The site is located in the City of Everson, in Whatcom
County, Washington.. .
The Northwest Transformer Service Company ("the Company")
operated a transformer reclamation, storage, and manufacturing
facility at 107 South Harkness st. from 1958 until 1987. The
facility encompassed approximately 0.5 acres and consisted of a
structure (three interconnected buildings) and a concrete parking
lot. The site was added to the National priorities List ("NPL")
on February 20, 1990.
The site is located in downtown Everson, Washington (see
Figure 1, next page). A single-family residence is located south
of the site, which is also adjacent to a restaurant and a small
office building. Beyond the residence is a city playground and
park. .
There are approximately 400 residents, two parks and
school within 1 mile from the site. The town of Nooks~ck
approximately 0.75 miles to the northeast and the town of
is approximately 5 miles northwest of the site with rural
land comprising most of the surrounding area.
The main Nooksack River channel is located approximately
1,000 ft southwest of the Site, and flows to the northwest in
this area. The town and site are within the 100-year floodplain
of the river and have been flooded several times in recent years.
The site is generally level, with an average slope of less than 1
percent to the west. Ground surface elevations at the site are
about 75 to 80 ft above mean sea level.
one
is
Lynden
farm
,
Groundwater is very shallow in the vicinity of the site,
approximately four feet below the ground surface. The direction
of flow is toward the river. The groundwater is not used as
drinking water. The city water supply comes from groundwater
wells located in a different aquifer across the river to the
south.
No wetlands, endangered species, or national historic places
were identified at or near the site.
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Northwest Transformer (5. Harkness St.) Site
Vicinity Map
Figure 1
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site Historv and Enforcement Actions
Based on inspections conducted by the united states
Environmental Protection Agency ("EPA") in 1977 and 1979,
Polychlorinated Biphenyls (IPCBs") were discovered in the
building and parking lot on-Site. EPA fined the Company for
violations of PCB requirements set forth under the Toxic
Substances Control Act (ltTSCA") in 1981. In 1985, EPA conducted
a CERCLA Removal ActiQn at the Company's salvage yard, located
about a mile outside Everson at the intersection of Mission and
East Pole roads, to reduce hazards associated with high levels of
PCBs and solvents at this yard. After the Removal Action, the
Mission/Pole yard was shut down and all operations were
reportedly transferred to the site. The site was proposed to the
NPL in 1987 and added to the list on February, 21, 1990. '
since the site comprises a small area of property and the
contaminant levels found in previous investigations were low, EPA
determined that a focused Remedial Investigation ("RI") approach
should be taken initially to characterize the Site and determine
whether any off-site pathways needed to be addressed. Of
particular concern was the condition of the old building on-Site
and the question of whether contaminants had migrated off-site
and impacted the Nooksack River (located about 3/4 mile SW qf the
site), and/or if PCB-contaminated oil burned in the building for
heat resulted in significant emissions or deposition of hazardous
substances.
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On December 26, 1991 EPA notified over 100 potentially
Responsible Parties ("PRPs") of their potential liability and the
need for action at the site. A steering committee representing
sixteen generator PRPs (customers of the Company who sent
transformers to the site and the Mission/Pole yard) signed an
Administrative Order on Consent ("AOC") on June 17, 1992,
agreeing t.o perform a focussed RI and Feasibility Study (UFS")
and, if necessarYi a Removal Action. EPA approved the RI
Sampling Plan in December, 1992, and field investigations started
during the first week of January, 1993. '
Other significant milestones of this project included:
4/93
PRPs submitted results of Field Investigations,
including the Preliminary Air Pathways Assessment,
draft Pipeline and Sediments Assessment, and site
structure Assessment;
6/93
PRPs submitted Removal Action Assessment and draft
Engineering Evaluation and Cost Analysis ("EE/CA") of
Removal Action Alternatives;
8/93
EPA published EE/CA and Proposed Plan ,for Removal
Action for public comment;
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9/93
10/93
11/93
6/94
6/94
8/94
8/94
9/94
Public Meeting held to discuss Proposed Plan for
Removal Action;
EPA signs Removal Action ~emorandum;
PRPs begin Removal Action field work;
Removal Action completed; validated sampling results
provided to EPA;
EPA certified completion of Removal Action Tasks,
completed draft Risk Assessment and determined that no
FS was necessary;
RI Report submitted to EPA;
Proposed Plan for No Further Action under CERCLA issued
for Public Comment;
No comments received; Record of Decision prepared.
Hiqhliqhts of Community Participation
The public was notified of the placement of the site on the
NPL on February 21, 1990 by a fact sheet and pUblic notice. A
fact sheet and public notice were also provided when notice ,
letters were sent by EPA to the PRPs in December 1991, (when the
Removal Action was proposed by EPA in August 1993, and several
times during performance of the Removal Action.
A public comment period was held from August 16 to September
15, 1993 on the proposed Removal Action. The public was notified
at that time that if the Removal Action was fully successful and
no further contamination was detected, EPA may issue a Record of
Decision requiring no further action. Public comments were
considered and EPA addressed these comments in a responsiveness
summary." Two fact sheets were issued during the Removal Action
to inform the public of the results of the action and EPA's
future plans for the site.
During planning for and implementation of the Removal
Action, the PRPs and EPA worked closely with the City of Everson
to ensure that community concerns were addressed.
EPA issued the Proposed Plan for the Final Remedial Action
Plan describing the decision to take no further action, on August
" 24, 1994. A public comment period on the RI Report and Proposed
Plan was held from August 26, 1994 until September 26, 1994. A
fact sheet and two public notices were issued by EPA and an
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article about this matter was printed in the Bellingham Herald.
No public comments were received by EPA.
site Characteristics
A.
Pre-Removal Action site Condition
Results from the RI Field Investigations were provided to .
EPA in April, 1993. A full priority pollutant scan was done but
no contaminants of concern were found in groundwater at the site.
However, the investigations confirmed the presence of hazardous
substa~es, pollutants and contaminants in the building
structure, the concrete floor slabs, and the soil underlying the
building and the parking lot, at levels including:
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PCBs up to 89 parts per million ("ppm") in soils and
structural materials; .
Xylenes up to 2,800 ppm in soils;
Carcinogenic pOlyaromatic Hydrocarbons up to 62 ppm in
soils;
Total Petroleum Hydrocarbons ("TPH") up to 250,000ppm.
in the floor residue and up to 63,000 ppm in soils
beneath the structures.
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The possibility of significant contamination of the Nooksack
River and/or sediments was determined to be unlikely due to the
earlier sampling along the river and sampling at the site and in I
the storm drains. The investigations also found that the drain
lines from the building were connected to the storm drain (which
directly discharges into the river) from 1958-1971, but that from
1972-1988 the drain lines were connected to the sanitary sewer
and went to the City wastewater treatment plant. The air pathway
was also ruled out as a pathway of significant concern since no
evidence of dioxin and/or furan contamination was found at the
site or in samples taken from down-wind locations near the site~
The building on-site was examined by a structural engineer,
who confirmed that the structure was unsound and deteriorating.
Further deterioration of the building, particularly during
winter, was determined to be a potential threat that could
release hazardous substances to the environment.
Following initial RI field investigations, the PRPs
performed a Removal Action Assessment and prepared an EE/CA of
Removal Action Alternatives for the site. The Removal Action
Assessment concluded that removal of the building and parking lot
would reduce the risk of building collapse and facilitate further
Site investigations. As part of the EE/CA, the PRPs identified-
Applicable or Relevant and Appropriate Requirements (IARARs") for
Removal and Remedial Action at the site. The removal action
goals and the preferred alternative in the EE/CA were designed to
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meet remedial action cleanup requirements, if possible, by
removing and disposing of all PCBs in excess of 10 ppm, and if
practicable, all PCBs in excess of 1 ppm.
While EPA evaluated the preferred alternative proposed by
the PRPs, EPA required the PRPs to re~ove and dispose of the
contents and nonstructural components of the site buildings,
including certain drums of investigation-derived residual
materials stored on-site. Potentially hazardous debris was
disposed of at the Chemical Waste Management Hazardous Waste
Landfill in Arlington, Oregon during May of 1993. Drums
containing other building contents and investigation-derived
residual materials were sent to off-site treatment, storage, and
disposal ("TSD") facilities. The quantities, types and disposal
location of wastes disposed during this action (and in the
subsequent Removal Action) are described in Table 1 at the end of
this document.
After review of the EE/CA, EPA agreed with the PRPs'
evaluation that Removal Action would facilitate completion of the
RI and that the preferred alternative could potentially achieve
remedial action cleanup goals. EPA prepared and issued a
Proposed Plan for a non-time critical Removal Action in August,
1993, and held a public comment period on this proposal. After
the comment period, EPA prepared a Responsiveness Summary
addressing the public comments.
- During the comment period, 'the Washington State Department,
of Ecology ("Staten) determined that the removal of additional
soil beneath the parking lot, contaminated with TPH and PCB,
would be necessary to meet state cleanup standards governing
final remedial action for the site. The PRPs agreed to remove
the additional soil in an effort to meet CERCLA and Washington
Model Toxics Control Act ("MTCA") requirements for the site.
EPA signed and issued a Removal Action Memorandum October 8,
1993. This decision memorandum specified that the cleanup goal
for the site was to remove and dispose of all PCBs in excess of 1
ppm and all TPH in excess of 200 ppm, to the extent practicable,
in an effort to make the Removal Action the final remedial action
for the site. Details of the cleanup action are provided below.
B. Scope and Role of the Removal Action
The goal of the Removal Action was to eliminate the risk of
the on-site building collapsing, to provide additional data for
the RI and Risk Assessment, and to address cleanup of the site in
accordance with final remedial action requirements, if possible.
The Removal Action was performed from November, 1993,
through June, 1994, and included the foliowing actions (see
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Figures 2 through 5 a~d Table 1 at the end of this document or
the Remedial Investigation Report for more detailed information): .
The building and floor slab were demolished and
disposed of at permitted TSCA, Resource
Conservation and Recovery Act (nRCRAn), and/or
demolition debris facilities (as appropriate).
Soil below the buildings and the parking lot
containing greater than or equal to 1 ppm PCBs was
excavated, removed and disposed of to the extent
practicable. Over 98% of PCBs were removed. .
Soil containing 1 or more ppm but less than 100 ppm
PCBs was disposed of at the Chemical Waste Management
Hazardous Waste Landfill in Arlington Oregon.
Soils shown to contain greater than or equal to 100 ppm
PCBs were incinerated and disposed of at the Aptus
hazardous waste incinerator in Aptus, utah.
Over 95% of the TPH found at the site was removed.
TPH-contaminated soils were disposed of in ~ccordance
with the PCB concentrations in the soil. Soils that
contained TPH but no PCBs above the cleanup level were
also taken to the Chemical Waste Management Landfill in
Arlington Oregon;
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Demolition debris that was shown not to cont~in
hazardous substances was disposed of at the Columbia
Ridge Solid Waste Landfill.
Soil sampling was performed at the base of the
soil excavations to determine whether the Removal
Action was successful and to obtain soil data for
EPA's subsequent baseline Risk Assessment.
Following completion of soil excavation and
confirmation sampling activities, the excavations with
back-filled with clean soil and gravel and then covered
with an asphalt cap. The cap was designed to allow the
site to be used for local parking and/or storage.
Based on the confirmation samples, the Removal Action was
successful and met ARARs and Removal Action goals to the extent
practicable.
C.
Current (Post-Removal Action) Condition
The confirmation samples collected after the Removal Action
were used in conjunction with ~xisting data to complete the Risk
Assessment and RI. The Risk Assessment showed that current and
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future potential risks posed by residual contamination at the
site are within the acceptable risk range of 10-5 or less.
The site now consists of two asphalt parking lots and an
alley covering about four feet of clean soil. In the deeper
soils at most locations PCB concentrations are less than 1 ppm.
Two locations. show evidence of low-level PCB contamination at
depth beneath the clean soil and cap (7 ppm at 6 feet below
ground surface and 28 ppm at 12.5 feet below ground surface).
Samples taken from soils outside the area of the Removal
Action in the yard of the adjacent residence and park contained
one PCB value at 1.2 ppm and one TPH value of 330 ppm. The other
samples were below the cleanup action levels and most samples
were non-detect for PCBs. Some samples also conta.ined levels of
arsenic which appear to be slightly elevated (8 ppm). However,
since those results were isolated and well below the State's
background cleanup level of 20 ppm, EPA determined that no
further action was necessary.
Summarv of site Risks
The Baseline Human Health and Environmental Risk Assessments
were completed subsequent to the Removal Action. Due to the
success of the Removal Action, the assessments support the
conclusion that no further action is necessary at the site to
protect public health or the environment. The baseline Risk
Assessment is included in the RI Report. (
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There is no risk of long-term direct contact exposure from
materials on-site, since all contaminated soil was removed down
to a depth of at least four feet, covered with clean soil and
paved with asphalt. No risk was found from ingestion of
groundwater, since no constituents of concern were detected in
the groundwater. In addition, there are no known uses of the
groundwater in this vicinity for drinking water.
In an effort to be conservative and provide useful estimates
of the reasonable maximum exposure ("RME"), the risk estimates
were done in two ways. One assumed lifetime exposure to the
maximum detected concentration in the remaining surface samples
taken from outside the area of the Removal Action, from the yard
of the residence adjoining the, Site, and from the adjacent park.
A second estimate was done by combining the values from all
samples remaining from the surface down to 3 feet below ground
surface, using multiple samples from a single location in order
to better represent lifetime exposure. using both methods, the
lifetime excess risk from exposure to arsenic and/or PCBs in the
event of no further action was found to be 10-5 or less.
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Human health hazards and risks for the site were evaluated
for residential land use in the Risk Assessment. The RME
assumptions included ingestion and dermal exposure to the 95%
Upper Confidence Limit concentration of a chemical of potential
concern for 350 days/year for 30 years. An excess lifetime
carcinogenic risk of 2 in 1,000,000 was estimated from the PCBs
(Aroclor-1254 and Aroclor-1260). The RME scenario for exposure
to the 8 ppm arsenic resulted in a carcinogenic risk estimate of
3 in 100,000. Using the same exposure parameters, risks from
background arsenic concentrations in soil would also result in a
risk of 3 in 100,000. No site related non-carcinogenic chemical
hazards were identified. .
TPH was present in soils at the site at elevated
concentrations ( however, the TPH was characterized as heavy
transformer or mineral oil and did not contaIn benzene,
ethylbenzene, toluene, xylenes or other contaminants at levels
which are considered of concern in the Risk Assessment. Since
those compounds were all below health-based levels of concern and
since no TPH or related constituents have been found in
groundwater samples, TPH is not considered a contaminant of
potential concern to human health at the Site~
Based on the conservative nature of the exposure point
concentrations f.or PCBs and arsenic, as well as conservative
estimates of exposure and carcinogenicity, actual site risks are
likely to be considerably less than the calculated values.
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No significant ecological impacts were identified(during the
RI. Since contaminants have been removed and/or capped at the
site, there is no significant pathway for ecological exposures at
the site.
When the site was listed, the other main area of potential
environmental concern was the Nooksack River in the vicinity of
the sewer outfall. The highest detected PCB concentration in
sediments at that location (0.16 ppm) was evaluated using the
August 1990 EPA Guidance on Remedial Actions for Superfund sites
with PCB contamination. The guidance states that the Department
of Interior has concluded that PCB concentrations of 1-2 ppm will
be generally be protectiv~ of wildlife such as migratory birds.
since the highest detected concentration at the outfall was below
that value and because the site itself is now paved, exposures to
ecological receptors to contaminated areas are considered very
low and quantification of potential risks from the sediments was
not considered necessary. .
OSWER Directive 9355.0-30 (April 22, 1991) states that at
sites where the cumulative site risk is less than 10-4, response
action is generally not warranted unless there are adverse
environmental impacts, exceedences of Maximum contaminant Limits
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(IIMCLs"), or for other site-specific reasons. Because there are
no adverse environmental impacts, exceedences of MCLs, or other
site-specific reasons which would dictate otherwise, there was. no
need to perform a FS or satisfy ARARs, and no further action is
necessary at the site.
Description of the Selected Remedv
The selected remedy under CERCLA authority is no further
action.
In order to verify that groundwater in the vicinity of the
site remains uncontaminated now that response activities are
complete, groundwater monitoring must continue until the CERCLA
five-year review is performed, at which point EPA will determine
whether continued monitoring is necessary.
Notice of Additional State Requirements
Although not part of the .EPA selected remedy, the state of
Washington requires, pursuant to the Model Toxics Control Act
(MTCAi WAC 173-340), filing of institutional controls in the form
of deed notices that inform future property owners of th~
presence of Total Petroleum Hydrocarbons and Polychlorinated
Biphenyls remaining on site above MTCA cleanup levels. The State
w~ll be responsible for enforcing this requirement, if necessary'
(.
. Groundwater Monitorinq
As stated above, in order to verify that groundwater in the
vicinity of the site remains uncontaminated, groundwater
monitoring using the wells on and near the site will continue
until a five-year review is performed by EPA, at which time EPA
will determine whether continued monitoring or other action is
necessary.
Five-Year Review
section 121 of CERCLA requires a five-year review of any
remedy that results in hazardous substances, pollutants or
contaminants remaining at the site. Since hazardous substances,
pollutants or contaminants will remain at the Site, at least one
five-year review will be conducted by EPA. The purpose of the
five year review will be to determine if there is any evidence of
groundwater contamination at the site. If no evidence of
contamination is found in the period between this Record of
Decision and the first five-year review, EPA will evaluate at
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that time whether additional monitoring and/or reviews are
necessary.
Documentation of Siqnificant Chanqes
No changes were made from the Proposed Plan.
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Record of Decision
Northwest Transformer South Harkness street site
Responsiveness summary
A public comment .period regarding the Proposed Plan for No
Further Action and the deed notices to necessary to satisfy state
MTCA requirements, was held from August 26, 1994 through
September 26, 1994. A fact sheet and two public notices were
issued by EPA and an article was published in the Bellingham
Herald describing the Proposed Plan and how and when to submit
comments to EPA. .
No public comments were received by EPA. Therefore, no
Responsiveness Summary addressing public comments has been
prepared by EPA.
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Confirmation Soil Sample Grid Boundary
and Corresponding Identification Number
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-------
TABLE 1
Page 1 of 2
NORTHWEST TRANSFORMER (S. HARKNESS ST.) SITE
SUMMARY OF WASTE DISPOSAL QUANTITIES(a)
Material Description
Quantity
Waste Manifest Nos.
l,
Soil
Soil with <100 ppm PCBs disposed in TSCA/RCRA cell
(L-13) at the Chemical Waste Management of the
Northwest landfill near Arlington, Oregon (Arlington
lahdfill)
Soil with ~100 ppm PCBs disposed at the Aptus, Inc.
incineration facility in Aragonite, Utah
Soil with <1 ppm PCBs disposed at the Columbia Ridge
Subtitle D solid waste landfill near Arlington, oregon.
(Columbia Ridge ~ndfill)
3,075.72 tons(b)
26-117
119-125
14.4 tons(d
118
-32.5 tons
109534-109536(<1)(0)
Demolition Debris
Building demolition debris disposed in TSCA/RCRA cell
(L-13) Arlington landfill(!) .
Parking lot pavement demolition debris disposed at the
Columbia Ridge landfill
428.63 tons(&)
173.44 tonsCl\) ,
1-25
93074-93077
103182-103184(cI)
103186-103188'cI)
109534-109536(<1)(0)
Uquids
Excavation water with <5 ppb PCBs disposed at the City 31,160 gall II 18974(<1), 18990'<1),
of Bellingham wastewater treatment facility 189871<1), 19000<<1), I
19004(<1) \9635(
Investigation~erived residual water with <5 ppb PCBs -1,300 gal 19064 ( 93064
the Rollins Environmental Services, Inc. inCineration
facility in Deer Park, Texas
Soil and ash residue containing ~loo ppb PCBs disposed at -0.44 tons(n) 93064
the Rollins Environmental Services, Inc. incineration
. facility in Deer Park, Texas
G Light ballasts containing PCBs disposed at the Chemical 0.1 tons 09303
Waste Management of the Northwest landfill in Arlington,
Oregon
Acid liquid containing methylene chloride, formic acid, -15 gal(n) 93062
methanol, and phenol disposed at the Aptus, Inc.
incineration facility in Aragonite, Utah
09/26/94 I:\PI'OWER\SHS\RI-RA \EPA-ROD.TSi
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TABLE 1
Page 2 of 2
NORTHWEST TRANSFORMER (S. HARKNESS ST.) SITE
SUMMARY OF WASTE DISPOSAL QUANTITIEs
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