PB95-963120
EPA/ESD/R10-94/090
March 1995
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Martin Marietta Superfund
Site, The Dalles, OR
9/23/1994
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EXPLANATION OF SIGNIFICANT DIFFERENCES
FOR
MARTIN MARIETTA SUPERFUND SITE
(.
THE DALLES, OREGON
SEPTEMBER 1994
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1.0 INTRODUCTION
1.1
SITE NAME AND LOCATION
Martin Marietta. Aluminum Reduction Facility
The Dalles, Oregon
1.2
LEAD AND SUPPORT AGENCIES
U.S. Environmental Protection Agency (EPA)
Oregon Department of Environmental Quality (ODEQ)
1.3
APPUCABLE STATUTES REQUIRING AN EXPLANATION OF SIGNIFICANT
DIFFERENCES (ESD)
Comprehensive Environmental Hesponse, Compensation, and Uability Act (CERCIJ\),
Section 117 (c), 42 U.S.C. ~ 9617 (c), as amended by the 1986 Superfund
Amendments Reauthorization Act, and National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 C.F.R. ~ 300.435 (c) (2) 0).
1.4
NEED AND PURPOSE FOR AN ESD
On September 29,1988, EPA, with ODEO concurrence, signed the Record of
Qecision (ROD) for remedial action at the Martin Marietta Superfund site ("Site") ,
located in The Dalles, Oregon. The significant circumstances that warrar\t the need for
this ESD are largely a result of several changes that occurred during the construction
phase of the remedial action.
1.4.1 MODIFICATIONS TO REMEDIAL ACTIONS ANTICIPATED IN THE ROD
The ROD identified consolidation of cathode wastes from the facility into a
landfill and on-Site treatment for cyanide and fluoride of the leachate generated from
the landfill. The ROD anticipated a gradual reduction in the volume of leachate
generated from the landfill from an average of 10 gallons per minute to a negligible
flow within fIVe years. However, since the signing of the ROD, the leachate flow rate
has not decreased significantly, potentially due to leakage of perched water into the
landfill through bedrock fractures beneath the landfill.
The ROD also required treatment of contaminated groundwater in .an area
known as the Unloading Area. Additional groundwater information has been collected
since the ROD, which raises questions regarding the necessity for treatment of
groundwater in the. Unloading Area.
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1.4.2 ADDITIONAL REMEDIAL ACTIONS NOT ANTICIPATED IN THE ROD
During the remedial action activities, three units of operation were taken out of
service: (1) the Uned Pond, (2) the Discharge Channel, and (3) the Recycle Pond.
Remedial actions for these units were not included in the ROD or the Scope of Work
(SOW), which was attached to the Consent Decree, because they were active
components of the Martin Marietta Aluminum Reduction facility at the time the ROD
was signed. However, the .Feasibility Study (FS) did discuss remedial actions for these
areas, when and if these units were temporarily or permanently taken out of operation.
Based upon the information obtained since the ROD, a number of changes
warrant an ESD but do not fundamentally alter the basic features of the remedy
selected for the Site. The following narrative will present the changes and describe the
differences in relation to the ROD. .
1.5
ADMINISTRATIVE RECORD
The ESD will become part of the Administrative Record for the Martin Marietta
Superfund site. The Administrative Record is available at the following two locations:
U.S. Environmental Protection Agency
1200 Sixth Avenue
7th Froor Superfund Records Center
Seattle, Washington 98101
The Dalles/Wasco County Ubrary
722 Court Street
The Dalles, Oregon 97058
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In addition, an information repository is maintained at:
Oregon Department of Environmental Quality
811 SW Sixth Avenue.
Portland, Oregon 97204-1390
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2.0 SITE BACKGROUND
2.1
SUMMARY OF SITE HISTORY AND CONTAMINATION PROBLEMS
The Martin Marietta Reduction Facility (MMRF) Superfund site (Site) is located in
The Oalles, Oregon, Wasco County, just west of the Columbia River and east of the
Union Pacific Railroad tracks, as shown in Figure 1. Operations were begun at the
Site by Harvey Aluminum, Inc. in 1958. Harvey Aluminum, Inc. became a wholly
owned subsidiary of Martin Marietta Corporation (MMC) in 1970. The MMRF
continued operations until 1984, when the plant was shut down. In September of
1986, MMC leased a portion of the MMRF to Northwest Aluminum Company (NWA) ,
which resumed primary aluminum operations in late 1986. In October 1991, MMC
sold the portion of the MMRF not affected by EPA's deed restrictions to NWA. The
NWA plant still produces aluminum by electrolytic reduction. of alumina.
During facility operation, waste constituents were stored, treated and disposed
of at the MMRF. Hazardous substances generated by the MMRF included fluoride,
sodium, sulfate, cyanide, and polynuclear aromatic hydrocarbons (PAHs). The waste
included spent potliner (cathode waste) from the alumina reduction cells. The cathode
wastes contain cyanide compounds which form during the reduction process.
. Fluoride compounds were also present in the waste generated from the alumina
reduction process.
A landfill located in the northern portion of the MMRF was used to dispose of I
primarily construction debris from the plant (Figure 2). Other materials disposed of in
this landfill included asbestos insulation, coke, pitch, and cathode waste. In 1980
. MMC installed a surface water drainage ditch and a leachate collection ditch and
sump to try and control runoff and leachate from this landfill. After the signing of the
ROD, this landfill was known as the aCERCLA Landfilla or -Landfilla.
In the spring of 1983, the presence of cyanide compounds was detected in the
ground water. EPA ranked the MMRF for inclusion on the National Priorities Ust
(NPL). The MMRF was proposed for inclusion on the NPL in October 1984. In 1987
the Site was formally listed on the NPL
In September 1985MMC and EPA entered into a Consent Order to conduct a
remedial investigation/feasibility study (RI/FS) for the Site. Twenty-three areas were
initially designated as potential contaminant source areas at the MMRF. The RI/FS
concluded that thirteen source areas and a portion of the shallow ground-water
bearing zone had contaminant concentrations that exceeded federal or state
applicable relevant and appropriate requirements (ARARs) or acceptable lifetime
non-cancer or cancer risk levels.
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On September 29, 1988, EPA signed a Record of Decision (ROD) that
addressed the potential sources of contamination as identified in the RifFS. Remedial
action objectives for the MMRF included both source control and ground-water
management for the protection of human health and the environment. Specific
objectives for source control at the Site included: .
2.2
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Minimization of the migration of contaminants from the source areas to
the ground-water system, surface water, or soils;
.
Protection of human health and the environment from potential adverse
effects caused by direct contact with contaminants; and
.
Protection of human health and the environment from potential adverse
effects due to exposure to airborne contaminants.
SUMMARY OF THE REMEDIAL ALTERNATIVE SELECTED IN THE ROD:
The ROD addressed source control of the on-Site contamination through
excavation and consolidation of contaminated soils into two former scrubber sludge
pond areas and into the existing Landfili.
The remedial activities required by the ROD included the following:
. .
. Consolidate the residual cathode waste material and underlying fill
material from the former Cathode Waste Management Area~ into the
eXisting Landfill; .
,
.
Consolidate the cathode waste material from the Unloading Area into the
existing Landfill; .
.
Cap the existing Landfill in place with a multi-media cap meeting
Resource Conservation and Recovery Act (RCRA) performance 'criteria;
.
Place a soil cover over the Scrubber. Sludge Ponds 2 and 3;
.
Plug and abandon nearby production wells and connect users to the City
of The Dalles water supply system; . .
Collect and treat leachate generated from the Landfill, and perched water
from east of River Road and from the former Cathode Waste
Management Areas;
.
*
Recover and treat contaminated groundwater from the Unloading Area;
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.
Prepare groun~~water quality monitoring and contingency plans to
perform additional recovery of ground water in the event that further
contamination is detected above ARARs or health-based standards;.and
.
Implement institutional controls, including deed restrictions and fencing,
to assure that the remedial action will protect human health and the
environment during and after implementation.
* Indicates remedial action was not fully implemented.
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3.0 DESCRIPTION AND EXPLANATION OF SIGNIFICANT DIFFERENCES
3.1
MODIFICATIONS TO LEACHATE COLLECTION SYSTEM
The Landfill Leachate Collection System (LCS) was constructed by MMC in the
summer and fall of 1990. Leachate collection commenced in December 1990. The
ROD anticipated that leachate from the Landfill would gradually decrease to negligible
levels within 5 years after construction of the Landfill due to the dry climate at the Site.
Construction of the Landfill cap was completed by MMC in April 1991. The initial
leachate volume decreased after cap completion from approximately 1,750 gallons per
day down to 570 gallons per day by late fall 1991. However, with the onset of wet. .
weather, leachate levels began to rise again, to as much as 3,100 gallons per day.
The source of the increased leachate flow was believed to be perched ground water
infiltrating through fractured basalt bedrock from south of the Landfill into the LCS.
The presence of ponded water on the Landfill surface in the southwestern portion of
the Landfill appeared to offer a continual source for recharge. Fluoride concentrations
of the leachate ranged from 1,490 - 2,440 parts per million (ppm). prior to completion
of construction of the Landfill cap. Free cyanide concentrations ranged between 0.01
- 4.7 ppm, and total cyanide concentrations ranged between 0.11 - 31.0 ppm. Current
post Landfill cap concentrations have decreased to dry season averages of 22.7 ppm
fluoride; 0.60 ppm free cyanide, and 15.7 total cyanide. Concentrations of fluoride,
free cyanide, and total cyanide during the wet season are more dilute. This indicates
that surface water infiltration to the LCS through the cap is unlikely, and that the cap is
functional. ,
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Based on the conclusion that the perched and ponded waters were the driving
force behind the infiltration to the LCS, several activities were undertaken by MMC
from the fall of 1992 through 1993, in response to the increased leachate flow. In
October 1992 a dewatering trench was constructed to prevent perched water from
flowing into the LCS while an underground pipe was installed to lower and divert .
ponded surface water around the Landfill. In addition, the surface-water drainage
system was modified to increase drainage. Despite these initial modifications to the
Landfill, infiltration of precipitation to the LCS continued to be a problem.
In March 1993 MMC conducted a dye tracer study to investigate potential
pathways and sources of the infiltration. The two pathways studied were surface
water runoff above the LCS percolating through the soils and entering the LCS
through fractures in the basalt and perched water flow in the vicinity of the LCS
infiltrating via basalt fractures.
Sased on the findings of the dye tracer study and a review of the Landfill
construction diagrams, MMC determined that the modified surface water drainage
system intersected a basalt ridge in the southern portion of the Landfill. The backfill
material in this area was sand. In the summer of 1993, MMC replaced the sand
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backfill with concrete, and expanded the surface water drainage system to include a
new surface water drainage ditch parallel to and upslope of the dewatering trench.
This ditch collects surface water runoff from the south and diverts it into the existing
surface water drainage pipe. In addition, the existing surface water ditch liner was
extended to prevent infiltration of surface water from the ditch.
. The above modifications to the Landfill surface water drainage system still had
minimal impact on the quantity of leachate generated by the Landfill. However,
cyanide and fluoride concentrations in the leachate have decreased since construction
of the Landfill, and ground-water quality in the vicinity of the Landfill has not been
impacted. The results of the dye-tracer studies and the leachate and ground-water
quality studies have all indicated that the source of the additional water is not a failed
landfill cap. Although leachate and ground-water quality have not been negatively
impacted, it is now expected that the volume of leachate will not decline to negligible
levels by April 1996, as per the ROD; Therefore, EPA has determined that an upgrade
of the current leachate treatment system is necessary to accommodate the excess
leachate volume caused by the infiltration of water into the Landfill.
3.1.1 LEACHATE TREATMENT VIA CYANIDE DESTRUCT SYSTEM
The ROD specified that the treatment system would include a chemical
oxidation unit for destruction of cyanide followed by a chemical precipitation unit to
remove fluoride to an approximate concentration of 9.7 milligrams per liter (mgjl). The
9J mgjL fluoride concentration is the alternate concentration limit (ACL) for ground I
water established purs.uant to the ROD. While the ROD did not specify ct performance
standard for the treatment of cyanide, the ROD did specify that the treated leachate
must meet the standards established pursuant to existing NPDES requirements prior
to discharge of the treated leachate to surface water. Therefore, the performance
standard for the treatment of free cyanide was established at 0.1 mgjl when an
NPDES permit was issued in 1989. . .
During the remedial design stage, MMC determined that treatment and
destruction of cyanide via chemical oxidation would not meet the "freeu cyanide
performance standard of 0.1 mgjl. Based upon bench-scale treatability studies, MMC
proposed and EP A concurred that destruction of cyanide by heating the cyanide and
water in a controlled reaction vessel to form an acid and base (UhydrolysisU) would be
the most technically feasible means of achieving the establi~hed performance
standard. EP A believes that this type of treatment system represents a process
modification for cyanide destruction and does not constitute a fundamental change in
technology. The hydrolysis treatment system, which is called the Cyanide Destruct
System (CDS), was constructed by MMC during Phase I remedial action construction
activities in 1989. Start-up and performance evaluation of the CDS was conducted
during Phase II construction activities in 1990. Currently, the CDS is treating leachate
at a nominal rate of 2 gallons per minute (gpm) and is meeting the 0.1 mgjl
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performance criteria. Due to the increase in the volume of leachate caused by
infiltration of surface water into the Landfill, EPA determined that the capacity of the
CDS should be increased. Therefore, the CDS will be upgraded to increase the
capacity to 10 gpm. EPA anticipates that a new CDS unit will be designed and
installed by the end of 1994. The cost of the new unit has been estimated by MMC to
be $153,000. The performance standard for the upgraded CDS will remain at 0.1 mgjl
"free" cyanide.
3.2
GROUNDWATER TREATMENT IN THE UNLOADING AREA
Recovery and treatment of groundwater in the Unloading Area was an element
of the selected remedy. The groundwater in this area contained elevated
concentrations of fluoride above the 9.7 mgjL ACL which was established for the Site
by the ROD. The ROD called for one recovery well to be drilled in the area of existing
monitoring well 5S (MW-5S). . .
As part of the actual remediation, contaminated soil in the Unloading Area was
removed. The purpose of the removal in the unloading area was to remove a
potential source to ground-water contamination, which was the potlining material
known to have been placed in the area. The soil and potlining material were removed
down to the basalt bedrock. Approximately 2,000 cubic yards of potlining material and
affected soil were removed and transported to the on-Site Landfill. Upon completion
of the removal, verification sampling was conducted for fluoride along the exposed
excavation faces, and the area was backfilled to the existing grade.
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Based upon removal of the potential source material, it was anticipated that the
concentrations in the ground-water at MW-5S would decrease over time. The sample
results from MW-5S have varied seasonally and were statistically analyzed in
September 1992 to determine if ground-water treatment was still necessary in the
Unloading Area. As shown in Table 1, sampling analyses of MW-5S indicate that
groundwater recovery and treatment is not currently necessary .at the Unloading Area
because the fluoride concentrations have statistically been at or near the ACL Based
on the evaluation of results in Table 1, EPA believes that active recovery and treatment
is no longer required in this area. However, the need for Mure recovery and .
treatment in the Unloading Area will be analyzed by EPA during the mandatory 5-year
review of the selected remedy. This analysis will incorporate an historical and
statistical evaluation of chemical concentrations in well MW-5S. EPA anticipates that
this. evaluation of well MW-5 and the mandatory 5-year review of the selected remedy
will occur in September 1995. ..
3.3
REMEDIATION OF FORMER OPERATING UNITS
Remediation of the Uned Pond, Recycle Pond, and Discharge Channel was not
required in the ROD because these units were part of the operating facility when the
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TABLE 1
SUMMARY OF FLUORIDE CONCENTRATIONS FOR WELL MW-5S
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SAMPLING DATE
FLUORIDE CONCENTRATION
. (mgjL)
-----------------
----
Sep-1991
Dec-1991
Mar-1992
Jun-1992
Aug-1992
Sep-1992
Nov-1992
Nov-1992 .
Feb-1993
Mar-1993
May-1993
Aug-1993
Dec-1993
Mar-1994
19.0
10.0
14.8
12.0
10.1
11.0
7.9*
7.7*
13.0
7.4
15.0
9.7
7.4
9.0
,
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mgjL = milligram per liter
* Duplicate samples were analyzed on this sampling date
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ROD was signed. Ho~ever, these areas were investigated as part of the RifFS. The
location of these units is shown in Figure 2. . Analysis of soil and sediment samples
collected from these operating units during the RI indicated the presenCe of elevated
amounts of fluoride and polyaromatic hydrocarbons (PAHs). The RI/FS concluded
that under existing conditions, the operating units would not pose an unacceptable risk
to human health and the environment Nonetheless, the FS evaluated remedial
alternatives for these areas when and if the units were taken out of operation.
10 1989 the Uned Pond was taken out of service by NWA. In 1991, upon
completion of this element of the remedial action, the Discharge Channel and the
Recycle Pond, which is now called the Storm Water Surge Pond, were returned to use
as part of NWA's modified wastewater treatment system. Consistent ~ the remedial
. alternatives evaluated by MMC in the FS, the following remedial actions were
conducted by MMC on the three former operating units since the signing of the ROD:
3.3.1 LINED POND
In 1980 the Uned Pond (Pond) was constructed to supplement the capacity of
the scrubber sludge ponds. The Pond was lined with a 45 mil Hypalon fabric. The
capacity of the Pond was 542,944 cubic feet. The Pond was used through 1984 when
MMC temporarily closed the plant. The Pond was reactivated in 1986 as part of
NWA's treatment operations.
. The Uned Pond was taken out of service in 1989. As part of Phase I activities I
under the Remedial Design/Remedial Action (RD /RA) Work Plan, the Un'ed Pond was
remediated in the fall of 1989. The remediation included removal of approximately
5,300 cubic yards of sludge and placement of the sludge into the Landfill. The
. Hypalon liner was also trimmed and removed for consolidation into the Landfill.
Verification sampling of soils beneath the Uned Pond was conducted to
determine if contamination had leaked into the underlying soil. .The verification
sampling indicated that the remaining chemical concentrations were below the
concentrations established in the ROD and the RD /RA Statement of Work. Regrading
of the Uned Pond area was completed on February 1, 1990. .
3.3.2 DISCHARGE CHANNEL AND RECYCLE POND
When the plant was built in 1958, the Discharge Channel was constructed as a
means to discharge water generated during plant operations. The Discharge Channel
was located in the east-central portion of the Site. Waters which entered the
Discharge Channel included rectifier cooling waters, roof scrubber waters, storm
runoff, landfill leachate, sewage treatment plant outfall, caste house cooling waters,
alumina unloading compressor cooling water, and cathode pad leachate discharge.
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The Discharge Channel was an open ditch that ran from the sewage treatment plant to
the Recycle Pond.
In 1974 the Recycle Pond was constructed to be used as a settling basin for
the solids from the secondary scrubber waters and to provide the capability to recycle
water back to the plant for reuse. The Recycle Pond was not lined. The only flow to
the Recycle Pond was from the plant through the Discharge Channel. The Recycle
Pond was located between River Road and Columbia River in the southeast portion of
the Site. The pond occupied approximately three acres and had a capacity of 8
million gallons. It contained approximately 16,000 cubic yards of saturated sediments.
The FS evaluated certain remedial actions to be taken 'should operation of the
Recycle Pond and the Discharge Channel no longer be required by the facility. In
1990, NWA modified their wastewater treatment system and removed the Recycle
Pond and Discharge Channel from their original wastewater treatment functions.
In the fall of 1991, the Recycle Pond and the Discharge Channel were
remediated by MMC as part of the RD/RA Phase II activities.
. The remediation of the Discharge Channel and Recycle Pond included the
following:
.
flushing of sediments in the upper portion of the Discharge Channel to
the Recycle Pond;
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removal of surface waters by discharging to the Columbia River under.
the existing National Pollutant Discharge Elimination System (NPDES)
permit criteria; .
.
dewatering of the sludge within the Recycl9 Pond followed by excavation
of the sludge from the RecyCle Pond and lower portion of the Discharge
Channel; and
.
consolidation of the sludge in the northern portion of Scrubber Sludge
Pond Number 3 (SSP3).
Approximately 28,000 cubic yards of sludge were excavated and consolidated.
A 6-inch layer of crushed rock was placed over the exposed areas of the Recycle.
Pond and Discharge Channel. The Recycle Pond has continued in use as part of the
process wastewater treatment system for the NWA plant. The Recycle Pond has been
renamed the Storm. Water Surge Pond and now serves as a surge basin for storm
water run-off. Storm water run-off collected in the Discharge Channel is diverted
during periods of heavy rainfall from NWA's NPDES outfall to the Storm Water Surge
Pond where it is metered back to the NPDES outfall to avoid exceeding NPDES
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discharge limits. A 2-foot thick soil cover was placed over SSP3. The SSP3 cover
was then graded and compacted after which it was tilled and seeded.
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4.0 SUPPORT AGENCY COMMENTS
ODEQ has been informed of these significant changes to the ROD and concurs
with this ESD. .
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5.0 AFFIRMATION OF STATUTORY DETERMINATION
Under CERCLA, EPA's primary responsibility is to ensure remedial actions are.
undertaken which protect human health, welfare, and the environment. In addition,
Section 121 of CERCLA, 42 U.S.C. 99621, establishes cleanup standards which
require that the selected remedial action complies with all applicable or. relevant and .
appropriate standards established under federal and state environmental law , unless
such requirements are waived by EPA in accordance with established criteria. The
selected remedy must also be cost-effective and must utilize permanent solutions,
alternative treatment technologies, or resource recovery technologies to the maximum
extent practicable. RnaJly, CERCLA regulations include a preference for remedies that
employ treatment that permanently and significantly reduce the volume, toxicity, or
mobility of hazardous waste. .
Considering the new information developed during the remedial action and the
resulting changes made to the selected remedy, EPA and ODEa believe that the
remedy remains protective of human health and the environment. Principal sources of
contamination such as the contaminated soil and sediment in the Recycle Pond, lined
Pond, Discharge Channel, and Unloading Area have been reduced or eliminated.
Treatment of landfill leachate complies with the CERCLA requirement for
cleanup remedies that employ treatment which permanently reduce the volume,
toxicity, or mobility of hazardous waste. The revised remedy remains cost effective in
that the need for pump and treat in the Unloading Area is not currently necessary.
Costs associated with the upgrading of the CDS are estimated to be les~ than
$200,000. .
I
The revised remedy complies with the NCP and other federal and state
requirements that are applicable or relevant and appropriate to this remedial action.
The requirements include RCRA and the NPDES regulations. under the Clean Water
Act. . . .
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6.0 PUBLIC PARTICIPATION ACTIVITIES.
This ESD, supporting information, and EPA's response to any comments from
the public will become a part of the Administrative Record for the ~ite. EPA invites the
public to view the Administrative Record at the information repositories listed in Section
1.5. For additional information regarding this ESD, please contact the Superfund Site
Manager for the Martin Marietta Reduction Facility site:
Howard Orlean
1200 Sixth Avenue, HW-113
Seattle, Washington 98101
(206) 553-6903
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Howard Orlean, Superfund Site Manager
( .
9//3/ ry
Date
Approved by:
U e~~~
Carol Rushin, Chief, Superfund Remedial Branch
r /;l3}q~
Date
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September 22, 1994
Catherine Krueger
Environmental Protection Agency
Region 10
1200 SW Sixth Avenue
Seattle, Washington 9810i
.. - ":-:. E i V E i'-
SEP 2 8 \994
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