United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R09-90/047
September 1990
&EPA Superfund
Record of Decision
J. H. Baxter, CA
-------
50272-101
I REPORT DOCUMENTATION
1 PAGE
1. REPORT NO.
EPA/ROD/R09-90/047
3. Redptenr. Acceeelon No.
TMeendSubWe
SUPERFUND RECORD OF DECISION
J.H. Baxter, CA
First Remedial Action - Final
5. Report DiU
09/27/90
7. AWhor(.)
8. Performing Orgutlnllon Rept No.
». Performing OrgtlntaMlon Nirne end Addree*
10. Pro|ect/T««k/Work UnH No.
11. Contnct(C) or Grtnt(G) No.
(C)
(O)
12. Sponeortng Organization Name and Addreea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Nom
16. Abefrect (Limit: 200 worde)
The J.H. Baxter site is in Weed, Siskiyou County, north-central California, and
consists of the 33-acre J.H. Baxter facility and the adjacent 870-acre Roseburg Forest
Products facility. These properties continue to be used for wood treatment operations
and lumber product manufacturing. The site is surrounded by pasture and woodland areas
with residential areas to the north and west. Man-made and natural wetlands exist within
the site boundaries, and Beaughton Creek runs through the eastern portion of the site.
Since 1937, wood treatment operations at the site have involved a variety of chemicals
including ammonical copper-zinc-arsenate, creosote, and PCP. Numerous waste products
have been generated including tank and retort sludges, process water, storage area
drippings, and spilled raw preservative compounds. Prior to 1983, when the State
ordered the J.H. Baxter facility to cease all waste disposal practices, onsite waste
management involved onsite disposal and discharge, spray irrigation of wastewater
onsite, storage in tanks and ponds, and discharge of wastewater into the bermed area
around a 500,000 gallon tank, once used for creosote storage and currently used for
process water storage. These disposal practices and leakage from storage tanks led to
soil and sediment contamination. Water that was collected by the lumber operations
(See Attached Page)
CA
17. Document Analysis a. Descriptor*
Record of Decision - J.H. Baxter,
First Remedial Action - Final
Contaminated Media: soil, sediment, gw, sw
Key Contaminants: organics (PAHs, dioxins), metals (arsenic)
c. COSATI Held/Group
18. AvsilsbHty Statement
1». Security Class (This Report)
None
20. Security Class (Thl« Psge)
None
21. No. of Page*
203
22. Price
(See ANSt-ZM.18)
See InttrucUonf an Revemt
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
-------
EPA/ROD/R09-90/047
j.H. Baxter, CA
First Remedial Action - Final
Abstract (Continued)
drainage system was discharged to Beaughton Creek until 1987, at which time a carbon
adsorption system was installed to treat the extracted ground water. The primary
contaminants of concern affecting the soil,. sediment, ground water, and surface water
are organics including PAHs and dioxins; and metals including arsenic.
The selected remedial action for this site includes excavation of 41,000 cubic yards of
contaminated soil, followed by biological treatment for soil with organic contaminants,
chemical fixation for soil with inorganic contaminants, biological treatment and
chemical fixation for soil with both inorganic and organic contaminants, and onsite
disposal of treated soil in lined cells; leachate collection and treatment; ground water
pumping, followed by biological treatment, chemical precipitation, and polishing, prior
to onsite discharge of treated ground water; implementation of institutional controls;
and long-term ground water, surface water, and air monitoring. All sediment in the site
drainage system with detectable levels of wood treatment chemicals will be excavated and
treated with stabilized soil. No remedy for the Beaughton Creek sediment is proposed
unless additional data indicate the need for further action. Surface water
contamination will be controlled through soil remedial actions that will reduce contact
between the contaminated soil and surface water. The estimated present worth cost for
this remedial action is $37,829,100, which includes an annual O&M cost of $1,207,600 for
30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for soil remediation
include arsenic 8 mg/kg (background), carcinogenic PAHs 0.5 mg/kg (10~6 risk level and
detection limit), and dioxin 1 ug/kg (detection limit). Chemical-specific goals for
ground water remediation are based on MCLs or non-zero MCLGs, State MCLs, the 10~5 to
10 risk range, or whichever is more restrictive, and include arsenic 5 ug/1 (10~5 to
10~6 risk range), PAHs 5 ug/1 (detection limit), and dioxin 0.000025 ug/kg (10~5 to 10~6
risk range).
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J.H. BAXTER SUPERFUND SITE
WEED, CALIFORNIA
RECORD OF DECISION
SEPTEMBER 25, 1990
-------
BAXTER RECORD OF DECISION
DECLARATION
1.0 SITE LOCATION AND DESCRIPTION
2.0 SITE AND ENFORCEMENT HISTORY
3.0 COMMUNITY RELATIONS
4.0 SCOPE AND ROLE OF RESPONSE ACTIONS
5.0 SUMMARY OF SITE CHARACTERISTICS
6.0 SUMMARY OF SITE RISKS
7.O DESCRIPTION OF ALTERNATIVES
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
9.0 SELECTED REMEDIES
10.0 STATUTORY DETERMINATIONS
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
FIGURES
TABLES
APPENDICES >
Appendix A - RESPONSE SUMMARY
Appendix B -. ADMINISTRATIVE RECORD INDEX
BAXRODF.TC
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DECLARATION
SITE NAME AND LOCATION
J.H. Baxter Site
Weed, CA
STATEMENT OF BASIS AKD PURPOSE
This decision document presents the selected remedial actions for
the J.H. Baxter Site in Weed, California, chosen in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act (SARA), and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on the administrative record
file for this site.
The State of California concurs with the selected remedies.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The response actions address the documented principle public
health and environmental threats from the site contamination.
Actions have been selected to address the contaminated soils,
groundwater, and surface water. The major components of the
selected remedies include the following:
Extraction of the contaminated groundwater
followed by biological treatment and chemical
precipitation, polishing, and disposal. The end
use of the treated groundwater will combine one or
more of the following methods: reinjection to
groundwater, release to subsurface drains or
trenches, industrial process use, and/or disposal
to percolation ponds.
Excavation of the organic contaminated soils and
biological treatment in lined treatment cells.
BAXROD.DCL ii
-------
Excavation of the inorganic soils and chemical
fixation followed by on-site disposal in lined
treatment cells for treated soils designated as
hazardous waste.
Excavation of the combined organic/inorganic
soils, biological treatment in lined treatment
cells, excavation, chemical fixation, and on-site
disposal into lined cells.
STATUTORY DETERMINATIONS
The selected remedies are protective of human health and the
environment, they comply with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and they are cost-effective. The remedies use
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and
satisfy the statutory preference for remedies that employ
treatment to reduce toxicity, mobility, or volume as a principal
element. The groundwater remedy involves treatment estimated to
take at least 30 years to reach remedial objectives; and the
organic and combined organic/inorganic soil remedies involve
treatment estimated to take approximately 10 years to reach
remedial objectives. Because this remedy will result in
hazardous substances remaining on-site above health-based
standards, a review will be conducted within 5 years of
commencement of remedial actions to ensure that the remedies for
groundwater, surface water and soils continue to provide adequate
protection of human health and the environment.
Signature *vn~* Date
Regional Administrator
BAXROD.DCL iii
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1.0 SITE LOCATION AND DESCRIPTION
The J.H. Baxter site, also known as the Baxter/International
Paper/ROjseburg (B/IP/R) site, is composed of properties
previously owned by International Paper and predecessor
companies, and is currently owned by J. H. Baxter & Company and
Roseburg Forest Products. The properties have been historically
used and continue to be used for wood treatment operations and
lumber product manufacturing.
The site is located on the northeastern margin of the city of
Weed, siskiyou County, California (Figure 1-1). Weed is located
in the southeastern margin of Shasta Valley, about 10 miles west-
northwest of the peak of Mount Shasta, and approximately 40 miles
south of the Oregon/California border (Figure 1-2). The city is
situated at the crossroads of Interstate Highway 5 and
Highway 97, which connect the Shasta Valley area with nearby
cities in Oregon and northern California.
The site is bordered on the west and north west by residential
areas of Weed including Siskiyou Union High School, to the north
by Angel Valley Subdivision and Lincoln Park, to the east by
mixed-woodlands, and to the south by irrigated pasture.
Beaughton Creek runs through the eastern portion of the site and
forms the northern boundary of the site (Figure 1-3). Land use
in the site area consists of industrial activities carried out by
J.H. Baxter, Roseburg Forest Products, and Morgan Wood Products.
Land use adjacent to the site consists of pasture, mixed-
woodland, wildlife habitat, and residential development.
Regional physiographic features include Shasta Valley, along with
Mount Shasta, Mount -Shas'tina, and Black Butte. The site is
underlain by coalescent fans of pyroclastic, mudflow, glacial,
and fluvial deposits off the northwestern flank of Mount Shasta
and Mount Shastina. The water table is shallow, 0-10 feet below
ground surface, emergent in some areas of the site, and exhibits
fluctuation with variable recharge conditions due to rainfall and
snow melt.
The study area sits at an elevation of 3,400 feet above sea
level. The site receives most of its average 27 inches of
precipitation during the winter as rain and snow. Temperatures
in the area are generally quite warm in the summer (daytime
average of 90°F) and cold in the winter (daytime average of
32°F). Prevailing winds are from the north at 320 degrees and
from the southeast at 120 degrees. Winds can gust to speeds in
excess of 50 miles per hour from the south.
The wood treatment plant and its numerous structures and
surrounding grounds comprise approximately 33 acres. Roseburg
Forest Products owns approximately 870 acres adjacent to the J.H.
Baxter facility. Wood treatment operations on the J. H. Baxter
BAXRODF.01 1-1
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" 7 4 i N"
.
V^Wecd ' '
B/IP/fl 8lt» - Wt»d. CA
U.S. EPA
LOCATION MAP
_>
-------
B/IP/R - WMd, CA
U.S. EPA
REGIONAL LOCATION MAP
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HIGHWAY 97
BEAUGHTON CREEK
B/IP/RSIT
ANGEL VALLEY
SUBDIVISION
LIBERTY
AVENUE
Wood Resident*
ERWOOD
TREATMENT
PROPERTY
ROSEBUHG PROPERTY
LSIDE DRIVE
SISKIYOU UNION HIGH SCHOOL
B/IP/P WEED. CA
SITE LOCATION MAP
-------
property consist of a retort building with two pressurized wood
treating vessels (retorts), a kiln for wood drying, storage shed
for treated lumber, an incisor building to prepare wood for
treatment, a chemical mixing building, chemical storage tanks, a
500,000-gallon tank once used for creosote and currently used for
process water storage, treated wood storage areas, drip pads in
front of the retort, a poleyard, office building, and abandoned
wastewater impoundments. The two cement-lined impoundments had a
capacity of 163,537 and 81,480 gallons each.
Lumber operations on the Roseburg property include several
sprinkler decks for irrigating logs, dry log-storage decks,
sprinkler system recovery ponds, a lumber mill and veneer plant,
processed wood storage yard, and a wood-fuel power plant.
Notable features on Roseburg1s property include an excavation and
french drain system placed on site in 1983. The excavation
exposed contaminated groundwater and the french drain system
intercepts and redirects groundwater downgradient of the eastern
half of the wood treatment property. Neither the french drain
nor the excavation were constructed as part of any remedial
effort. Prior to the winter of 1987-88, water collected by the
french drain was discharged to Beaughton Creek. During the
summer of 1988, Roseburg installed an activated carbon treatment
plant to treat extracted groundwater. The treated water is
either pumped into the log deck sprinkler system or discharged
into Beaughton Creek. The National Pollutant Discharge
Elimination System (NPDES) permit for the discharge has expired
and Roseburg has applied to the North Coast Regional Water
Quality Control Board (NCRWQCB) for renewal of the permit.
Man-made and natural wetlands exist within site boundaries. Only
man-made wetlands have been affected by contamination. These
wetlands consist of irrigated pasture, Roseburg excavation pond,
and wet areas created by discharges from the Roseburg power
plant. The former Baxter spray field, used for disposal of
wastewater, also exhibits wetland characteristics. Of these
wetlands, the Roseburg excavation pond and the Baxter spray field
will be affected by the proposed remedy. The disposal options
for treated groundwater present opportunities for increasing
wetlands in the vicinity of the site through surface discharge
options.
BAXROD.01 1-5
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2.0 SITE AND ENFORCEMENT HISTORY
Wood treatment operations using chemicals to preserve lumber
products were initiated at the site in 1937. The complete
history of chemicals used in the early years of operation is not
known. Tanalith and Minalith were used in treatment processes
until the mid-1950's. Tanalith is a mixture of sodium fluoride,
sodium dichromate, arsenic, and dinitrophenol. Minalith is a
mixture of diammonium phosphate, ammonium sulfate, sodium
tetraborate, and boric acid. FCAP, a fluoride-chrome-arsenic-
phenol mixture, is reported to also have been used. In the late
1960's, the use of chromated zinc chloride was removed from the
on-site wood treatment process. Ammoniacal copper arsenate (ACA)
was also used as a preservative.
Reports indicate that pentachlorophenol (PCP) was used for wood
treatment at least as far back as the 1950's, and was used until
1982. During the period of use, PCP was applied to wood in an
oil-based mixture. Commercial grades of pentachlorophenol
manufactured during this period contained various isomers of
chlorinated dibenzo-dioxins and dibenzo-furans.
Additional chemicals used by J.H. Baxter Company from the
beginning of its wood treatment operations in 1962 through the
current operations of the treatment facility include ammonical
copper-zinc-arsenate (ACZA), creosote, 50/50 (a 50:50 petroleum
creosote mixture), D-blaze, and pyresote. Pyresote, a flame
retardant, is a mixture of zinc chloride, sodium dichromate,
ammonium sulfate, and boric acid.
Waste disposal, handling, and discharge practices over the 50
years of plant operations have resulted in site soil,
groundwater, and surface water contamination by chemicals
described in the previous paragraphs. Waste generated at the
site include retort drippings, tank and retort sludges, process
water, wastewater, drying area drippings, storage area drippings,
empty containers, and spilled raw preservative compounds. Prior
to 1983, when the facility was ordered to cease its waste
disposal practices by the North Coast Regional Water Quality
Control Board (NCRWQCB), waste management involved on-site
disposal and discharge, spray irrigation of waste water on site,
storage in ponds and tanks on site, and possible disposal of
sludges into a local landfill. Discharge of wastewater into the
bermed area around the 500,000 gallon tank was also reported.
Leakage from storage tanks may also have contributed to
subsurface contamination.
BAXROD.2 2-1
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The following is a chronology of important Baxter/IP/Roseburg
site activities and investigations by the potentially responsible
parties (PRPs), state agencies, and EPA.
March 1982
November 1982
December 1982
March 1983
March 1983
April 1983
May 1983
July 1983
NCRWQCB inspected J.H. Baxter and requested report
of waste discharge.
California Department of Health Services (DHS)
inspected J.H. Baxter and reported improper
handling and storage of wastes.
DHS required J.H. Baxter to begin a surface and
groundwater monitoring program.
Elevated levels of arsenic, creosote, and
pentachlorophenol were discovered by DHS and
NCRWQCB in site soils, surface water runoff, and
groundwater. Additional soil samples collected in
Lincoln Park also showed elevated arsenic. The
NCRWQCB issued Cleanup and Abatement Order to J.H.
Baxter to cease waste disposal practices.
J. H. Baxter installed two monitor wells at the
request of DHS and NCRWQCB. Results showed
elevated levels of wood treatment chemicals in
groundwater.
Siskiyou County Health Department temporarily
closed Lincoln Park to evaluate soil contamination
results.
NCRWQCB sampled soil, sediment, and surface water
within Lincoln Park, the drainage through the
park, and on Baxter property. Results showed that
a discharge was occurring and the NCRWQCB issued a
Cease and Desist order to J.H. Baxter.
J. H. Baxter sampled soil within its sprayfield
and reported elevated arsenic.
September 1983 DHS cited Baxter for violation of an interim
hazardous waste facility permit and the State
Hazardous Waste Control Laws.
BAXROD.2
2-2
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January 1984 NCRWQCB advised J.H. Baxter of continued noh-
compliance with existing orders.
February to NCRWQCB and DHS met with J.H. Baxter
September 1984 regarding remedial investigations and waste
discharge requirements.
October 1984 EPA proposed the J. H. Baxter site for the
National Priorities List (NPL).
July 1985 DHS held public meetings to discuss addition of
the site to the State Superfund List.
September 1985 The NCRWQCB issued Cease and Desist Orders to J.H.
Baxter, IP, and Roseburg requiring that the
companies submit a plan for investigating and
cleaning up groundwater and surface water.
December 1985 NCRWQCB issued Cease and Desist Order to J.H.
Baxter, IP, and Roseburg to implement
investigation work plan.
January 1986 Site formally included on State's Priority Ranking
List.
January 1986 EPA became the lead agency for site remedial
studies and enforcement.
January to EPA attempted to negotiate consent decree with the
September 1986 PRPs for conduct of the RI/FS.
September 1986 Consent Decree negotiations failed and EPA
prepared for EPA-sponsored RI/FS.
March 1987 EPA initiated a Remedial Investigation (RI). The
RI Report was released in January 1989.
\
Late 1987/ The California Department of Fish and Game
Early 1988 conducted a fisheries study of Beaughton Creek
above and below the site. The Fish and Game
reported that discharges from the site had
adversely affected aquatic life downstream of the
site.
BAXROD.2 2-3
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December 1988 NCRWQCB issued Cease and Desist Orders to J.H.
Baxter and Roseburg to address surface runoff
violations and TPCA compliance. Cleanup and
Abatement Orders issued to IP to implement
groundwater remediation program.
May 1989 NCRWQCB issued Waste Discharge Requirements to
J.H. Baxter, IP, and Roseburg for groundwater
biological treatment feasibility study.
June 1989 The Baxter/IP/Roseburg site was added to the NPL.
April 1990 EPA's Draft Feasibility Study and Proposed Plan
were released.
BAXROD.2 2-4
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3.0 COMMUNITY RELATIONS
EPA has encouraged public participation during the RI/FS process
and has met the requirements for public participation under
CERCLA Section 113 (K) (2) (B) (i-v) . Public participation has
occurred through the following activities:
April 1986
February 1987
Community interviews and meetings with local
officials and media regarding EPA's role on the
RI/FS.
Release of Fact Sheet requesting public comment on
the RI work plan. Document repositories
established in four locations near the site.
February 1987 EPA sponsored public meeting in Weed to discuss
community concerns with RI work plan.
April 1987
Release of EPA Community Relations Work Plan for
the site.
June 1988
April 1990
May 1990
Public Notice in two local newspapers and release
of draft Remedial Investigation Report for public
comment.
Public notice in two local newspapers and release
of draft Feasibility Study report and Proposed
Plan for public comment. Comment period extended
to 60 days.
A formal public meeting in accordance with CERCLA
Section 117 (a)(2) was held on May 7, 1990 to
discuss FS and Proposed Plan. No public
opposition voiced. Main concern expressed was to
maintain plant operations and economic viability
of community.
EPA has prepared the attached response summary which provides
EPA's responses to comments submitted in writing during the
public comment period, and to comments that were presented during
the May 7 public meeting (See Appendix A).
BAXROD.3
3-1
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4.0 SCOPE AND ROLE OF RESPONSE ACTIONS
The selected response actions address tcontamination in soil,
groundwater, and surface water caused by operations at the
Baxter/IP/Roseburg site. The response actions will be performed
to meet the final site treatment standards exhibited in
Table 4-1. These levels are based on Applicable or Relevant and
Appropriate Requirement (ARAR) considerations and health
protection criteria. The contaminant-specific ARAR
considerations for groundwater treatment and release of treated
water as process water on the log decks, to percolation/evapo-
ration ponds, and reinjection into the contaminated aquifer are
presented in Table 4-2. Health protection criteria for the soils
remedies are presented in Table 4-3.
For the site, arsenic, carcinogenic polycyclic aromatic
hydrocarbons (PAHs), pentachlorophenol, and dioxins have been
identified as the primary contaminants of concern. All of these
contaminants are known or suspected carcinogens and are present
in each medium at concentrations exceeding health standards.
Chromium, copper, zinc, benzene, and noncarcinogenic PAHs have
been identified as contaminants of less concern. These
contaminants are present at levels below health-based standards,
are not widespread, or are considered to be less toxic than the
primary site contaminants.
The selected remedies presented herein address the documented
potential threats from the site. Treatment of the contaminated
soil and groundwater will significantly reduce the potential for
future exposure to contaminated soil, groundwater, surface water,
particulates, and vapor. Because all remedies will reduce
contamination to either background, non-detection based on
current accepted analytical methods,1 or to a 10*6 risk level,
the point of compliance will be achieved when all contaminants
are treated to the standards identified in this ROD.
Soil Contamination
Contaminated soils have been divided into areas based on
contamination levels and types of chemicals present in the soils.
The remedy selected for soils is specific to each area and the
type of contamination present (Figure 4-1).
with regards to dioxins and furans in the soils, the remedy will
reduce contamination to levels specified by the Agency for Toxic
Substances and Disease Registry (ATSDR), consistent with
1 Non-detection based on EPA's Test Methods for Evaluating
Solid Waste (SW-846) procedures. Minor procedural modification
may be necessary to allow practical quantification of results.
BAXfcODF.4 4-1
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TABLE 4-1
CONTAMINANT CONCENTRATIONS AND
CLEAN-UP STANDARDS
Average Site
Contaminant Levels
SURFACE SOILS
Arsenic
Chromium
Copper
Zinc
Pentachlorophenol
Carcinogenic PAHsb
Dioxins
Furans
SUBSURFACE SOILS/
FIXED SOIL LEACHATE
Arsenic
Chromium
Copper
Zinc
Pentachlorophenol
Carcinogenic PAHs
Noncarcinogens PAHsc
Dioxins
SEDIMENT
Arsenic
Chromium
Zinc
Carcinogenic PAHs
Noncarcinogens PAHs
Pentachlorophenol
Tetrachlorophenol
(ppm)
240
130
9
6
0.0035
0.002
(ppm)
21
12
11
40
160
18
30
0.0035
(ppm)
60
33
170
Maximum Site
Levels
(ppm)
38,500
45,000
37,100
58,400
2,440
2,600
5.7
0.98
(ppm)
12,100
1,350
604
1,120
1,300
420
6,100
5.7
(ppm)
353
216
1,750
54
220
11
35
Clean-up
Standards
(ppm)
8
500
2,500
5,000
17
0.51"
0.001
0.001
Leachate
Limits (ppm)
5
5
25
250
1.7
0.005*
0.15
.001
(ppm)
8
18
26
0.5s
0.58
1.0"
1.0"
BAXRODF.4-1 p-1
4-2
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TABLE 4-1
CONTAMINANT CONCENTRATIONS AND
CLEAN-UP STANDARDS
Contaminant
Average Site
Levels
Maximum Site
Levels
Clean-up
Standards
GROUNDWATER/TREATED
WATER DISCHARGE LIMITS
Arsenic
Chromium
Copper
Zinc
Benzene
Pentachlorophenol
Carcinogenic PAHs
Noncarcinogens PAHs
Dioxins
(ppb)
37
13
170
8
2
360
635
12
(PPb)
1,740
122
37,100
23,000
170
210
6,000
251,800
13
(PPb)
5
8
11
90
1-
2.2'
5«
5s
0.000025a
Analytical detection limit.
Carcinogenic PAHs: Benzo(a)anthracene, Chrysene, Benzo(b)-
fluoranthene, Benzo(a)pyrene, Benzo(k)fluoranthene, Indeno-
(123-cd)pyrene.
Non-carcinogenic PAHs: Naphthalene, 2-Methylnaphthalene,
Acenaphthylene, Acenaphthene, Dibenzofuran, Fluorene,
Phenanthrene, Anthracene, Fluoranthene, Pyrene, Benzo-
(g,h,i)perylene.
BAXRODF.4-1 p-2
4-3
-------
TABLE 4-2
COMPARISON OF TREATMENT STANDARDS WITH
ARAR LEVELS FOR WATER (ppb)
Contaminant
Arsenic
Chromium
Copper
Zinc
Pentachlorophenol
PAHs-carcinogenic
PAHs-noncarcinogenic
Benzene
Dioxin
Federal
MCLGs
50
120
1,300
NE
0
NE
NE
0
NE
Federal
MCLs
50
50
1,000
1,000
200
NE
NE
5
NE
State
MCLs
50
50
1,000
1,000
NE
NE
NE
1
NE
State
AALs
74
51
4 1
26 7
2.2
NE
NE 14
0.7
NE
Risk
Level
0.15"
180a
,300b
,000b
180'
0.025*
,000b
10"
Site
Background
Level
<;L
8
7
90
0
0
0
0
0.0000019' 0
Site
Treatment
Standard
5d
8
11
90
2.2d
5d
5d
1
c
Risk level reflects a 1 x 10"6 risk level for carcinogens.
''Risk level reflects reference dose level for non-carcinogens.
eValue= 0.000025 ppb
^Analytical quantification limit
NE = None Established
MCLGs - Maximum Contaminant Level Goals
MCLs = Maximum Contaminant Levels
AAL = Applied Action Levels (California)
\
MAXHOD.4-2
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TABLE 4-3
COMPARISON OF EXCAVATION STANDARDS
RISK LEVELS FOR SOILS
(ppm)
l
ut
Soil Concentration Risk Level
Contaminant
Arsenic*
Chromium*
Copper*
Zinc6
Pentachlorophenol*
Tetrachlorophenol6
PAHs-carcinogenic*
PAHs-noncarcinogenic6
Dioxins*
Current
Workers
17
5,320
39,000
210,000
1,100
20,000
5.7
43,000
0.00072
Future
Children
0.89
570
4,200
23,000
74
2,800
0.51
100,000 1,
0.000051
Future
Adults
13
13,000
94,000
510,000
840
49,000
4.5
000,000
0.00058
Soil
Background
8.4
40.3
13
88.3
0
0
0
0
0
Soil
Excavation
Standard
8
500C
2,500C
5,000C
17C
2,800d
0.51
43,000d
0.001
Risk level reflects a 1 x 10"6 risk level for carcinogens
''Risk level reflects reference dose level for non-carcinogens
eExcavation standard reflects California Title 22 waste designation level for Chromium,
Copper, Zinc, and Pentachlorophenol
dEPA TCLP leachate concentration cannot exceed 1 ppm for PAHs and 1 ppm for
Tetrachlorophenol for groundwater protection considerations.
UAXKOD.4-3
-------
ANGEL VALLEY
SUBDIVISION
WEED RESIDENTIAL
AREA
B/IP/R Site Weed. CA
EPA
Approximate Extent ol
Contaminated Soils
Figure
4-1
-------
potential future residential exposure to these soils. For
arsenic and carcinogenic PAHs in soils, the remedy will
reduceuncontrolled contamination to background levels and non-
detect, respectively. Background at 8 ppm is the standard for
arsenic. For carcinogenic PAHs, 0.5 ppm, the analytical
detection limit, has been selected. These levels reflect a
1 x 10"5 risk level for arsenic and 1 x 10"6 risk level for
carcinogenic PAHs. Other soil contaminants will be removed and
treated to address EPA's Toxicity Characteristic Leachate
Procedure (TCLP) standard, and California CCR Title 22 total
threshold limit concentrations (TTLC) and soluble threshold limit
concentrations (STLC) standards. These standards are listed in
Tables 4-1 and 4-3. Non-carcinogenic PAHs will be excavated to a
level that limits the soil leachate concentration to l ppm total
PAHs in the leachate.
Near surface soils (i.e., all soils greater than 2 feet in depth
and to a depth of approximately 12 feet or to the top of
groundwater table) will be excavated to remove all soils
exceeding California Title 22 TTLC and STLC criteria for metals
and pentachlorophenol, leachable carcinogenic PAHs to 0.005 ppm,
and leachable non-carcinogenic PAHs to 0.15 ppm.
Groundwater Contamination
Contaminated groundwater extends from below the wood treatment
area towards the northwest approximately 1,000 feet. A separate
body of creosote product also exists below the wood treatment
property (Figure 4-2).
For arsenic, EPA's proposed standard for the affected aquifer is
5 ppb which reflects a 1 x 10"5 risk level and the practical
quantification limit for arsenic. Pentachlorophenol has a
proposed standard of 2.2 ppb which reflects the California
Applied Action Level and the practical quantification limit for
this contaminant. This level of 2.2 ppb considers
pentachlorophenol a carcinogen and represents the 1 x 10*6 risk
level as established by the State.
The 1 x 10"6 risk level for carcinogenic PAHs, as established by
the site Endangerment Assessment, is 0.025 ppb. This level
reflects EPA's goal for the aquifer. However, the analytical
quantification limit for PAHs in water is approximately 5 ppb,
which is EPA's current standard. Should analytical methods be
developed which reduce the quantification limit below 5 ppb, EPA
will reduce the carcinogenic PAH standard to the new level to be
more consistent with EPA's goals for the aquifer.
For benzene, the remedy will clean up the aquifer to 1 ppb
(benzene) which reflects a one in a one million excess cancer
threat. For non-carcinogenic PAHs, chromium, copper, and zinc,
the remedy will clean up to background levels to be consistent
BAXRODF.4 4-7
-------
l
o>
ANGEL VALLEY
SUBDIVISION
LINCOLN A VENUE
ROSEBURG LOG
DECKS
ROSEBLIRG EXCAVATION
POND AND FRENCH DRAIN
EXTENT OF GROUNDWATER
CONTAMINATION
D TREATMENT AREA
BAXTER PROPERTY
DIRECTION OF
GROUNDWATER
FLOW
WEED RESIDENTIAL
AREA
Approximate Extent of
Groundwater Contamination
B/IP/R Site Weed. CA
-------
with the NCRWQCB's Basin Plan. Dioxins were detected in the
oily-phase material extracted from contaminated groundwater, but
not in the groundwater itself, at a detection limit of about 1
part per trillion. Because detection at the i x 10"6 risk level
of 2 parts per quadrillion is currently not achievable,
thegroundwater and surface water remedy will treat dioxins and
furans to the currently available detection limit of 25 parts per
quadrillion. Eventually, it may be possible to detect dioxins
and furans at levels as low as our health-based clean-up goal of
2 parts per quadrillion (1 x 10'6 risk), and cleanup will extend
to this standard at that time.
All treated groundwater intended for release to reinjection
wells, percolation/evaporation ponds, or the log deck sprinkler
system initially will be treated to health-based standards
presented in this ROD. Final treatment standards will reflect
the aquifer clean-up standards.
Surface Water and Sediments
EPA is not proposing a remedy for Beaughton Creek sediments at
this time. Recent surveys of the creek indicate that the fishery
is recovering and a remedy may be more harmful to the fishery if
implemented. EPA proposes to continue to sample Creek sediments
and aquatic biota in coordination with California Fish and Game,
the Regional Board, Department of Health Services and the
Potentially Responsible Parties. Any detectable wood treatment
chemicals in sediments or fish tissue would warrant continued
investigations of the Creek, regardless of levels reported.
Should concentrations of wood treatment chemicals remain in
sediments at levels deemed by EPA and the State to pose a
significant risk to human health and the environment, a Beaughton
Creek remedy will be proposed and implemented. The criteria used
for the sediment remedy will be developed based on results of the
creek studies in coordination with the State.
To protect the creek, EPA is proposing to remove from site
drainages leading to the creek all sediment containing detectable
or above-background concentrations of site chemicals. Removal of
sediments to these standards is necessary to be consistent with
the NCRWQCB's Basin Plan.
BAXRODF.4 4-9
-------
5.0 SUMMARY OF SITE CHARACTERISTICS
Waste disposal, handling, and discharge practices over more than
50 years of plant operation have resulted in site soil,
groundwater, surface water, and sediment contamination. In 1983,
the North Coast Regional Water Quality Control Board (NCRWQCB)
ordered the facility to cease its waste disposal practices.
Prior to 1983, waste management involved on-site disposal in
unlined pits or bermed areas, discharge into ditches leading to
Beaughton Creek, spray irrigation of process water onsite,
storage in ponds and tanks onsite, and possible off-site disposal
of sludges into a local landfill. Discharge of wastewater into
the bermed area around the 500,000-gallon tank (No. 3 tank) was
reported to have occurred. Leakage from storage tanks may also
have contributed to subsurface contamination.
For the site, arsenic, carcinogenic PAHs, pentachlorophenol, and
dioxins have been identified as the primary contaminants of
concern. All of these contaminants are known or suspected
carcinogens and are present in each medium at concentrations
exceeding health standards. Therefore these contaminants are
considered principle health threats. Chromium, copper, zinc,
benzene, and non-carcinogenic PAHs have been identified as
contaminants of less concern and are considered low-level threat
contaminants. These contaminants are present at levels below
health-based standards, are not widespread, or are considered to
be less toxic than the primary site contaminants.
5.1 GROUNDWATER
Groundwater sample results showed the presence of a creosote and
arsenic plume, originating at the Baxter wood treatment area and
extending to the northwest into the Roseburg property towards the
Angel Valley subdivision (Figures 1-3 and 4-2). This subdivision
includes an estimated 108 households. Several domestic wells
used for household and yard watering are present in the
subdivision and are less than 2,000 feet downgradient of the
sources of groundwater contamination. EPA has notified all
residences in the area of the potential for groundwater
contamination. To EPA's knowledge, no-one is currently using the
domestic wells as a primary source of drinking water.
Arsenic at 1,740 ppb and creosote compounds at 233,000 ppb were
detected in Roseburg monitor well RMW1, which was located
immediately downgradient of the wood treatment property and 1,600
feet upgradient of the subdivision. A portion of this arsenic
and creosote plume is being captured by the Roseburg french
drain. According to the RI Report and December 1989 monitoring
data, wells downgradient of the french drain and adjacent to and
within the subdivision did not show the presence of site
contaminants.
BAXRODF.5 5-1
-------
5.2 SOIL
Results of surface soil samples collected across the wood
treatment property indicated widespread arsenic contamination (40
to 38,500 ppm) to a depth of at least one foot. The majority of
surface soil samples collected contained in excess of 100 ppm
arsenic. Arsenic contamination extended deeper (up to 5 feet)
below the retort, wastewater impoundments, and tank-bermed areas
of the property. Contamination of surface soils by creosote
(N.O. to 10,384 ppm) and pentachlorophenol (N.O. to 2,440 ppm)
was less widespread than the inorganic contamination, but much
deeper. Organic contamination below the tank berm, retort, and
wastewater vault areas extends to at least 30 feet below ground
surface. A subsurface creosote body of up to 15 feet in
thickness exists under the wood treatment property. The
remaining creosote body exists as lenses of 1- to 2-foot
thickness that continues through the Roseburg excavation and is
partially captured by the Roseburg french drain.
Surface soil samples collected on the Roseburg log deck to the
northwest of the wood treatment area contained slightly elevated
(up to 78 ppm) arsenic concentrations. The distribution of
contamination was toward the northwest, which is a primary wind
direction from the site. Elevated concentrations of site
contaminants were not detected in any of the subsurface samples
collected away from the wood treatment area.
Results of high-volume air particulate (air quality) samples
collected off site also showed elevated particulate levels and
arsenic concentrations to the northwest (23 to 183 ppm), as
compared to the background area (N.D. to 15 ppm).
In 1983, the California Department of Health Services sampled
soil from Lincoln Park and sediments within the drainage ditch
that flows adjacent to the Park and found elevated levels arsenic
and other chemicals related to wood treatment operations.
Lincoln Park was closed temporarily while local health officials
reviewed the soil data. EPA also sampled soil in Lincoln Park,
Angel Valley subdivision, and the site drainage ditch during the
overall site remedial investigation. EPA found elevated arsenic
and other wood treatment chemicals.in the ditch that flows
adjacent to the Park. The arsenic levels that EPA detected
ranged between 50 and 95 ppm, which is above the 8 ppm level that
EPA considers as naturally occurring in these soils.
Recently, EPA conducted a more extensive sampling effort of soils
in residential areas around the Baxter property, including
Lincoln Park, Angel Valley Subdivision, and the Liberty Street
area adjacent to the Baxter property. Results of this study
showed that wood treatment chemicals are not present in
residential areas at levels above background, with one exception.
Chromium was detected at 82 ppm in Lincoln Park, which is above
BAXRODF.5 5-2
-------
the background level of 40 ppm. However, this result is far
below the 1 x 10"6 risk level for direct contact to children,
which is 570 ppm.
5.3 SURFACE WATER AND SEDIMENTS
Beaughton Creek, the main surface water body for the site,
originates from springs located 3,000 feet upgradient of the
Baxter property. The stream flows directly through the site in a
northwest to west direction. All major and minor site
stormwater/surface runoff drainages eventually flow into the
creek, either on the site, or immediately downgradient of the
site.
Surface water analyses revealed that releases of site chemicals
were occurring from the Baxter wood treatment area. Elevated
arsenic (552 ppb) was detected in a sample collected from a
drainage that receives a portion of the runoff from the wood
treatment facility. Elevated arsenic was detected throughout the
drainage to its confluence with Beaughton Creek. Arsenic and
creosote in contaminated groundwater captured by the Roseburg
french drain were also being released to Beaughton Creek at the
NPDES #1 discharge point. This release was abated when Roseburg
installed a water treatment facility to remove organics from
water extracted from the french drain and then pumping the
treated waters into the their log deck sprinkler system
(Figure 5-1).
Over the years there have been several releases of wood treatment
chemicals into Beaughton Creek resulting in fish kills. The most
recent release in November 1987 was of creosote from NPDES II
discharge point. The California Department of Fish and Game
remains concerned over the impacts to the fishery and potential
effects upon anglers consuming the fish.
Remedial Investigation results indicated that sediments within
two channel segments contain elevated concentrations of wood
treatment chemicals at levels of environmental and human health
concern. These segments include a 50-foot long stretch of the
site drainage, immediately north of the Baxter property, and a
100-foot segment of Beaughton Creek at the confluence with the
Roseburg NPDES II discharge point (Figure 5-1).
Analysis of stream sediment samples indicated elevated arsenic
(113 ppm) within the drainage that receives runoff from the wood
treatment property. Sediment throughout the site area was also
contaminated with tetrachlorophenol (35 ppm), a compound
associated with pentachlorophenol. Stream sediment downgradient
BAXRODF.5 5-3
-------
..
'
MO * MfMtM
»«.« MfflMMM
J \«fr'*.v.,,M..
V. "«v«l,.y
"
"( i ^ "uffiViMM »
x( \ - o .- "-"" ^3&»-.
A - * ^ =a^r*.
". /^ -»*'/ '*^-A
SEDIMENT REMEDIAL AREAS
-------
of the NPDES #1 discharge was visibly contaminated with creosote
(1987 observation).
5.4 CONCLUSION
EPA's remedy for soil cleanup will involve approximately 41,000
cubic yards of soil. This includes 18,750 cubic yards of soil
contaminated with inorganics only, 12,500 cubic yards of soil
contaminated with organics only, and 9,380 cubic yards of soil
contaminated with both inorganic and organic chemicals. EPA
expects that up to 150,000 gallons of contaminated groundwater
may need to be treated each day for approximately 30 years. Soil
and groundwater treatment remedies should be adequate to prevent
surface water releases and a surface water remedy is not proposed
at this time. EPA will coordinate existing and future
environmental study results with the California Department of
Fish and Game to determine the necessity for any action regarding
sediments.
Site-related chemicals, the media affected, and the current
corresponding concentration ranges are given in Table 5-1. All
data used by EPA to develop the Feasibility Study, to select
remedial alternatives and to develop conclusions and clean-up
standards presented in this Record of Decision were based on the
following data quality requirements.
1. All data were collected under the guidance of a Quality
Assurance Project Plan developed under EPA protocols
and reviewed and approved by EPA Quality Assurance
Management staff.
2. All data were collected in accordance with procedures
presented in Sampling and Analysis Plans, one plan
developed for each discrete sampling episode. The
Sampling and Analysis Plans were developed in
accordance with EPA Region 9 guidance and were reviewed
and approved by EPA Quality Assurance Management staff.
3. With the exception of air quality samples, all soil and
groundwater samples were analyzed by an EPA Contract
Laboratory Program Laboratory using CLP analytical
methods. Air quality samples were analyzed by an EPA
CLP laboratory using non-CLP methods. CLP methods do
not exist for the analysis of air quality samples.
4. All analytical data collected by EPA, including air
quality samples, were subject to data validation in
accordance with EPA data validation procedures. Only
those data that met the data validation criteria for
this site were used in development of the Record of
Decision.
BAXRODF.5 5-5
-------
TABLE 5-1
SITE RELATED CHEMICALS IDENTIFIED IN ENDANGERMENT ASSESSMENT
AS POTENTIALLY POSING THE GREATEST THREATS
TO HUMAN HEALTH AND THE ENVIRONMENT
ui
I
0\
Chemical
Arsenic
Benzene0
Chromium
Copper
Ethylbenzene0
Media Affected*
Groundwater
Surface Water
Soils
Sediment
Groundwater
Surface Water
Soils
Groundwater
Surface Water
Soils
Sediment
Groundwater
Surface Water
Soils
Sediment
Groundwater
Surface Water
Soils
Frequency of
Detection
52/143
50/94
102/199
15/31
11/72
1/55
1/84
26/143
33/94
196/199
31/31
51/143
50/94
199/199
30/31
11/72
2/55
5/84
Concentration
<3 - 1,
<3
<0.46 - 38,
<6
<0.8
<0.8
<5.
<4.0
<4.0
<2.2 - 45,
<9.0
<5.0
<4.0
<1.8 - 37,
<1.8
<0.5
<0.8
<5.0
Range6
740 ppb
558 ppb
500 ppm
113 ppm
180 ppb
9 ppb
10 ppm
164 ppb
19 ppb
000 ppm
148 ppm
137 ppb
52 ppb
100 ppm
359 ppm
360 ppb
73 ppb
450 ppm
hAX>«
-------
TABLE 5-1
SITE RELATED CHEMICALS IDENTIFIED IN ENDANGERMENT ASSESSMENT
AS POTENTIALLY POSING THE GREATEST THREATS
TO HUMAN HEALTH AND THE ENVIRONMENT (cont.)
01
I
-sj
Chemical
Carcinogenic PAHs
Non-Carcinogenic
PAHs
Pentachlorophenol
Dioxins/d
Furans
Tetrachlorophenol
Media Affected*
Groundwater
Surface Water
Soils
Sediment
Groundwater
Surface Water
Soils
Sediment
Groundwater
Surface Water
Soils
Sediment
Soil
Soil
Sediment
Groundwater
Surface Water
Soils
Sediment
Frequency of
Detection
20/153
12/51
23/131
15/47
49/123
23/52
34/131
9/47
55/157
14/88
13/131
1/47
27/28
21/28
12/20
47/157
12/88
9/130
8/47
Concentration Range5
< 5
<0.074
<0.060
<50
<0.048
<0.060
0.06
<0.26
<3.2
<0.001
<0.001
0.003
<0.06
<0.290
- 6,000 ppb
15 ppb
2,600 ppm
54 ppm
-251,800 ppb
- 1,632 ppb
- 10,384 ppm
220 ppm
30 ppb
3.0 ppb
- 2,440 ppm
11.0 ppm
14.1 ppm
0.989 ppm
11 ppb
0.90 ppb
510 ppm
35 ppm
BAXRODF.5-1 p-2
-------
TABLE 5-1
SITE RELATED CHEMICALS IDENTIFIED IN ENDANGERMENT ASSESSMENT
AS POTENTIALLY POSING THE GREATEST THREATS
TO HUMAN HEALTH AND THE ENVIRONMENT (cont.)
Chemical
Media Affected*
Frequency of
Detection
Concentration Range
Zinc
Groundwater
Surface Water
Soils
Sediment
101/103
70/93
199/199
31/31
<5
<4.4
<4
<16
- 19,200
- 6,940
- 58,400
- 1,060
ppb
ppb
ppm
ppm
Ul
I
oo
"bnly the media with concentrations of chemicals exceeding health
criteria are presented here.
bLower value reflects the lowest concentration detected and
should be used as the lower limit for background. The upper
value in the range reflects the maximum concentration detected
during EPA's HI.
'Benzene and ethylbenzene are associated with a former
underground fuel tank and are not considered widespread
contaminants.
*TCDD equivalents: Dioxins: <0.001 - 5.71; Furans: <0.001 -
0.333.
Source: Baxter/IP/Roseburg Feasibility Study, April
1990.
BAXRODF.S-l/p-3
-------
5. EPA reviewed data collected by the State and
Potentially Responsible Party contractors for use in
defining nature and extent of contamination at the
site. Only the data that were documented with the
identity of the sampler, sampling date/ sample
location, sampling methods, identity of analytical
laboratory, analytical method, and original laboratory
results were incorporated into EPA's analysis.
BAXRODF.5 5-9
-------
6.0 SUMMARY OF SITE RISKS
EPA prepared an Endangennent Assessment to document the potential
risks associated with the actual or threatened releases of
hazardous substances from the Baxter/IP/Roseburg site. The
following paragraphs summarize the information found in this
document (U. S. Environmental Protection Agency, April 30, 1990.
Endanaerment Assessment. Baxter/IP/Rbsebura (BIPR1 Site. Weed.
California. Volumes 1 and 2, EPA WA 205-9L74).
6.1 HEALTH RISKS
The risk assessment identified chemicals of concern for human
receptors. The chemicals were selected primarily on the basis of
the concentration detected, or the known or suspected
toxicological properties of the substance. The wood treatment
inorganic (metal) chemicals of concern include arsenic, chromium,
copper, and zinc, with arsenic being identified as a high threat
contaminant. The organic chemicals of concern include
carcinogenic and non-carcinogenic PAHs, pentachlorophenol,
tetrachlorophenol, chlorinated dibenzo dioxins and chlorinated
dibenzo furans. Carcinogenic PAHs, pentachlorophenol, and
dioxins have been identified as high threat contaminants. The
organic compounds benzene, ethylbenzene, toluene, and xylene
(possibly present due to a former underground storage tank) were
also identified as chemicals of concern.
To assess risks, cancer potency factors (mg/kg/day)"' of
2.9 x 10'2 for benzene, 1.6 x 10"2 for pentachlorophenol,
1.56 x 10s for carcinogenic PAHs, and 2 for arsenic were used.
Reference Dose (RfD; mg/kg/day) of 5 x 10"3 for chromium (VI),
3.7 x 10"2 for copper, 2 x 10"f for zinc, and 4 x 10"1 for non-
carcinogenic PAHs were used. Assumptions used for soil exposure
assessment included an exposure frequency of 240 days/year,
ingestion rate of 100 mg/day, and a lifetime exposure of 70
years. Assumptions used to assess groundwater exposure included
ingestion of 2 liters of water per day for 70 years and exposure
at a frequency of 365 days per year.
The chemicals of concern were each detected in at least one
environmental medium (soils, air, groundwater, surface water,
and/or sediments) in the vicinity of the site. Several of the
contaminants (benzene, certain PAHs, PCDDs/ PCDFs,
pentachlorophenol) have been shown to be carcinogenic in animals
and have been classified by EPA as possible or probable human
carcinogens; arsenic is a known human carcinogen. The non-
carcinogenic contaminants have been observed to have toxic
potentials based on laboratory studies and effects on humans
under certain exposure situations.
BAXRODPD.6 6-1
-------
Table 6-1 presents the contaminants of concern with respect to
the media in which they are found. Table 5-1 depicts the
concentrations of the chemicals of concern upon which the risk
assessment was based.
The evaluation performed under the risk assessment indicated
that, under current land-use conditions, the principal exposure
pathways by which human receptors could potentially be exposed to
site contaminants are direct contact by workers at the Baxter
facility with contaminated soils, direct contact by children with
contaminated off-site soils (Lincoln Park and Angel Valley
subdivision), inhalation of fugitive dust emissions on and off
site, and direct contact with surface water and sediments near
Lincoln Park. Within the risk assessment, the exposure point
concentrations of site chemicals were estimated using measured
concentrations or models to estimate fugitive dust emissions.
Exposure was assessed for both an average case and a maximum
plausible case for each exposure scenario. For the average case,
geometric mean concentrations were used, together with what were
considered to be the most likely exposure conditions. For the
maximum plausible case, the highest measured concentrations were
generally used, together with high, although plausible, estimates
of the range of potential exposure parameters relating to
frequency and duration of exposure and quantity of contaminated
media contacted.
The risk assessment evaluated two main baseline (No Action)
scenarios: continued use of the property as industrial (wood
treatment) and future-use development of the property as
residential. A summary of risks posed by site chemicals for
current-use conditions assuming no cleanup has occurred is
presented in Table 6-2. A summary of risks posed by site
chemicals for future-use conditions, assuming no cleanup has
occurred is presented in Table 6-3.
As Table 6-2 illustrates, the highest current-use potential
health risk due to arsenic, PAHs, and dioxin is exposure by
workers at the Baxter Facility to the soil by direct contact
(Plausible Maximum Case risk of 8 x 10"2). Total maximum risk to
site workers from all contaminants and pathways is 1.4 x 10'1.
The maximum non-carcinogenic risks from direct contact with soil
by workers at the Baxter Facility exceeds a hazard index of 1.
Inhalation of arsenic-contaminated fugitive dust by adults living
in the area of Union Street poses a current-use maximum potential
excess cancer risk of 2 x 10"2. The corresponding maximum non-
carcinogenic risk from inhalation by Union Street adults does not
exceed a hazard index of 1.
Higher health risks are associated with future residential use of
the site (see Table 6-3). Children in direct contact with Baxter
soil have a maximum excess cancer risk of 1 x 10*1 due to
BAXRODPD.6 6-2
-------
TABLE 6-2
SUMMARY OF RISKS FOR CURRENT-USE CONDITIONS
AT THE BIPR SITE
POTENTIAL UPPER BOUND
EXCESS CANCER RISK*
NON-CARCINOGENIC6
HAZARD INDEX
CDI:RfD RATIO
POPULATION
AVERAGE
PLAUSIBLE
MAXIMUM
AVERAGE
PLAUSIBLE
MAXIMUM
CURRENT-USE
Workers at the Baxter Facility
Direct contact with soil 2x10"
Inhalation of fugitive dust 2x10"
Workers at the Roseburq Facility
Direct contact with soil 5x10"
Inhalation of fugitive dust 2x10'
Children Living in the area
Direct contact with soil
Angel Valley 1x10"
Lincoln Park 1x10"
Direct contact with surface
water and sediments 2x10'
Adults Livina in the area
Inhalation of fugitive dust
Liberty Street 4x10
Union Street 9x10'
4
8X10'2
6xlO'Z
5X10"
6X10"
6X10"
3xlO"4
9x10"
6X10
2X10"
J
<1
<1
*A IxlO"6 (one in one million) level is EPA's risk reduction target.
"RfD definition: RfD is reference dose toxicity level for non-carcinogens.
BAXROD6-2
6-3
-------
TABLE 6-3
SUMMARY OF FOR FUTURE-USE CONDITIONS
AT THE BIPR SITE
POPULATION
POTENTIAL UPPER BOUND
EXCESS CANCER RISK*
PLAUSIBLE
AVERAGE MAXIMUM
NON-CARCINOGENIC6
HAZARD INDEX
CDI:RfD RATIO
PLAUSIBLE
AVERAGE MAXIMUM
fUTURE-USE
Adults
Direct contact with soil
Baxter
Roseburg
Ingestion of groundwater
Children
Direct contact with soil
Baxter
Roseburg
Ingestion of groundwater
Inhalation of volatiles
released from groundwater
Direct contact with surface
water and sediments
2xlO"5
6xlO"5
9xlO"2
4x10'*
6x10"*
7xlO"Z
4x10
2x10"
6x10
4X10"
8X10'
-2
-1
1X10
6xlO"3
5x10"
3x10"
1X10"*
<1
<1
>1
<1
*A 1E-6 (one in one million) level is EPA's risk reduction target.
"RfD Definition: RfD is reference dose toxicity for non-carcinogens,
BAXROD6-3
6-4
-------
TABLE 6-1
CHEMICALS OF POTENTIAL CONCERN FOR THE BIPR SITE
01
I
Ul
Compound Soi 1
Baxter Roseburg Angel Lincoln
Property Excavation Valley Park
Arsenic x x
Bentene
ChroniiN x x
Copper x x
Ethyl- x
benxene
Care i no- x x
genie PAHs
Noncarcino- x x x
genie PAHs
PCMs/PCOFs x* x*
Pentachloro- x
phenol
Tetrachloro- x
phenol
toluene x x*
Xylenet x
Zinc xx* x
Groundwater Surface Water Sediment Air
Ontite Offsite Onsite iMiediately Down- Onsite/ Lincoln Down-
Off aite strean lamed. Park stream
Offsite
X XX XXX
X
X XX XX-
X XX XX
X
X X XX
XXX
X X
XX X
X X XX
X X
X
X XX XX
* Siitturface soil only
* Surface soil only
IA*tOD 6 1
-------
arsenic, PAHs, and dioxins. The future risk to children for
consumption of contaminated groundwater is 5 x 10'1. Total
maximum risk to children from all sources is 6 x lo*1. The
corresponding maximum non-carcinogenic risks from children in
direct contact with Baxter soil exceeds a hazard index of 1.
Adults in direct contact with Baxter soil have a maximum excess
cancer risk of 6 x 10'2 due to arsenic, carcinogenic PAHs, and
dioxins. The future risk to adults for consumption of
contaminated groundwater is 8 x 10"1. The total maximum risk to
adults from all sources is 8.6 x 10'1. The corresponding maximum
non-carcinogenic risk exceeds a hazard index of 1.
6.2 ENVIRONMENTAL RISKS
Wildlife habitat in the study area includes Beaughton Creek, its
tributaries, and woodland and pasture areas immediately adjacent
to these surface waters. Wildlife use of the site is expected to
be limited because of industrial and residential development. No
State or Federal threatened or endangered species are known to
reside on or in the vicinity of the site. No critical habitats
are known to exist in the vicinity of the site. Man-made and
natural wetlands occur within and adjacent to this site.
6.2.1 AQUATIC LIFE
The State of California has developed applied action levels
(AALs) for arsenic, chromium, copper, and zinc for the protection
of aquatic life. EPA has developed ambient water quality
criteria (AWQC) for the protection of aquatic life for these four
metals and for pentachlorophenol. In addition, EPA has
identified the lowest-observable-effect level (LOEL) for
acenaphthene and fluoranthene for which insufficient data are
available to derive AWQC. (AALs, AWQC, and LOELs are referred to
collectively as aquatic life toxicity values.) Table 6-4
presents a comparison of the surface water contaminant
concentrations detected during the RI with the AWQC and AALs.
The data presented in Table 6-4 show that surface water at the
site has the potential to affect aquatic life and may continue to
affect aquatic life in Beaughton Creek if the site is not cleaned
up. Arsenic at 558 ppb and zinc at 6,940 ppb exceed their
respective AALs of 74 ppb and 26 ppb, respectively. These
contaminants exceed aquatic life toxicity values greatest in the
area nearest the Baxter property, but the contaminants also
exceed their AALs at areas closer to the main channel of
Beaughton Creek. Potential impacts associated with these other
chemicals are expected to be greatest next to the Baxter
property, given the greater number and concentrations of
chemicals present in this area.
BAXRODPD.6 6-6
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TABLE 6-4
COMPARISON OF SITE SURFACE WATER LEVELS
WITH FEDERAL AWQC AND STATE AALs
(ppb)
Contaminant
Arsenic
Chromium
Copper
Zinc
Pentachlorophenol
PAHs
Abreviations: AWQC
AALs
Beaughton Site
Creek Drainage
Levels Levels AWQC
<5
<5
<5
65
0
0
= Ambient
= Applied
558 0.0022
19 11.
41 12.
6,940 110.
0 13.
179 0.0028
Water Quality Criteria
Action Levels (California)
AALs
74
51
4
26
2.2
0
BAXROD.6-41
6-7
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6.2.2 TERRESTRIAL WILDLIFE
Terrestrial wildlife may be exposed to chemicals of potential
concern in surface water and sediment by several pathways: (1)
ingestion of food that has accumulated chemicals from surface
water or sediment; (2) ingestion of surface water; (3) ingestion
of sediment while foraging or grooming; and, (4) dermal
absorption. However, evaluations of receptor-specific exposures
via some of these pathways are limited by the lack of appropriate
exposure assessment information. Therefore, the evaluation of
potential wildlife exposures and impacts at the Baxter site is
limited to an evaluation of potential impacts associated with
ingestion of surface water and contaminated food. Potential
exposures via either of these pathways are not expected to occur
on the Baxter property or immediately adjacent areas because
these areas provide little habitat for wildlife. Potential
exposures are more likely to occur in off-site areas where
habitat has been less disturbed. As a result, it is considered
unlikely that wildlife would be exposed to chemicals in the most
contaminated areas (i.e., immediately adjacent to the site) and
that exposures are more likely to occur in the less-contaminated
areas.
Potential impacts from ingestion of surface water in the less
contaminated areas are not expected to be significant. Use of
Beaughton Creek and its tributaries as a drinking water source by
big game, other terrestrial wildlife, and cattle adjacent to the
site is expected to be limited. The creek is unlikely to be used
as a drinking water source by the small mammals of the area
(i.e., rabbit, ground squirrel) because these animals generally
obtain much of their daily water from dietary sources; the
possible occasional use of these surface waters for drinking
water is not expected to result in significant exposure in these
species.
Many birds also obtain much of their daily water via the diet;
therefore, birds also would be expected to have limited drinking
water exposure to chemicals detected in surface water at the
site. For those bird species that do supplement dietary water
with surface water, some exposures could occur. However, none of
the chemicals of potential concern detected in surface water in
the less contaminated areas are expected to be acutely or
chronically toxic at the low level of exposure potentially
experienced by these species. Therefore, wildlife impacts
associated with ingestion of surface water from Beaughton Creek
are not expected to be significant.
Wildlife may be exposed to chemicals of potential concern in
surface water and sediment that have accumulated in food.
However, with exception of PAHs, none of the chemicals present in
surface water and/or sediment are expected to accumulate to a
significant degree in the aquatic food chain. PAHs can exhibit
BAXRODPD.6 6-8
-------
bioconcentration factors than can exceed a factor of 1,000, when
comparing ambient concentrations with animal tissue
concentrations. Exposure to wildlife feeding near Beaughton
Creek is expected to be insignificant given the low
concentrations (about 0.5 ppm in sediment) and infrequent
occurrence of PAHs in the creek in areas downstream of the Baxter
property (i.e., benzo(a)pyrene was the only PAH detected in
samples collected downstream of the Baxter property).
6.3 CONCLUSION
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment. The
current risk afforded by site chemicals that have been and
continue to be released into the environment represents a total
risk of 1.4 x 10"4 to current workers. Total future site risk to
children is 6 x 10'1 , while the total future risk to adults is
8.6 x 10'1. EPA's acceptable risk range is 1 x 10"4 to 1 x 10'6.
The risk to terrestrial wildlife appears to be low. Aquatic life
continues to be threatened by releases from the site.
BAXRODPD.6 6-9
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7.0 DESCRIPTION OF ALTERNATIVES
The following discussion presents a brief description of soil,
surface water, sediment, and groundwater remedial alternatives
that have survived the preliminary screening and have been
carried through a detailed analysis in the Baxter/IP/Roseburg
Feasibility Study (FS) report. To facilitate the analysis of
alternatives, the alternatives were categorized into six groups
based on media affected and contaminant type. These groups are
as follows:
o Soils contaminated with inorganics
o Soils contaminated with organics
o Soils contaminated with inorganics and organics
o Groundwater
o Sediments
o Surface water
Table 7-1 lists the alternatives subject to detailed analysis in
the FS.
7.1 SOIL REMEDIAL ALTERNATIVES
Contaminated soils have been divided into sub-unit areas based on
contamination levels and the types of chemicals present in the
soils. The sub-unit soil areas include the wood treatment
property soils, retort and drip pad area soils, No. 3 tank-
be rmed area soils, wastewater vault area soils, spray field
soils, subsurface creosote area soils, Roseburg excavation pond
and french drain soils. Proposed soil cleanup will involve
approximately 41,000 cubic yards of soil.
7.1.1 SOILS CONTAMINATED WITH INORGANICS
The sub-units contaminated with inorganics only are the Baxter
spray field soils, and wood treatment property soils. Total
volume of inorganic soils is estimated at 18,750 cubic yards.
Alternative 1 - No Action
Under this alternative, no remedial activity would be employed.
Continued groundwater and surface water monitoring would be
required. Contaminants would be left at the site untreated and
uncontrolled. No risk reduction would result. The alternative
would not comply with ARARs, water quality standards, or State
discharge limitations.
BAXRODF.7 7-1
-------
TABLE 7-1
LIST OF ALTERNATIVES CONSIDERED IN
BAXTER SITE FEASIBILITY STUDY
Soils Contaminated with Inorganics
- No Action
- Excavation and Off-Site Disposal
- Excavation, Fixation, and On-Site Disposal
Capping
Soils Contaminated with Oraanics
- No Action
- Excavation and Off-Site Disposal
- Excavation and Off-Site Incineration
- Excavation, Biological Treatment, and On-Site Disposal
Soils Contaminated with Inorganics and Orqanics
- No Action
- Excavation and Off-Site Disposal
- Excavation and Off-site Incineration
- Capping
- Excavation, Biological Treatment, On-Site Fixation, and On-
Site Disposal
Groundwater
- No Action
- Groundwater Extraction, Biological and Chemical Treatment
and Discharge to Percoloation/Evaporation Ponds or
Reinjection
Groundvater Extraction, Physical and Chemical Treatment, and
Discharge to Percololation/Evaporation Ponds or Reinjection
BAXROD.7-1 7-2
-------
TABLE 7-1
LIST OF ALTERNATIVES CONSIDERED IN
BAXTER SITE FEASIBILITY STUDY (cont.)
Surface Water
- No Action
- Treatment and/or Isolation of Contaminated Surface Soils
- Collection, Storage, and Treatment of Contaminated Surface
Water
Sediment
- No Action
- Excavation, Treatment, and Disposal
BAXROD.7-1 7-3
-------
Alternative 2 - Excavation and Off-site Disposal
The excavation and off-site disposal alternative would involve
excavation of contaminated surface soil containing arsenic
exceeding the 8 ppm clean-up standard1 (approximate 0 to 1 foot
interval, but potentially deeper at localized areas on the site),
placement of excavated soil in haul trucks, transport of soil to
an off-site disposal facility, and disposal of soil in a
contained land-disposal unit permitted to accept the waste. The
haul truck loads would be covered with tarps and the exterior of
the trucks decontaminated prior to leaving the site. Dust
suppression measures would be employed to control dust emissions
during excavation and hauling. At the facility, the soil would
be placed in a lined and controlled unit meeting RCRA standards.
Clean soil would be used to backfill the excavated area.
Alternative 3-Excavation. Fixation, and On-Site Disposal
This alternative would involve excavation of soil contaminated
with arsenic exceeding the 8 ppm clean-up goal (approximate 0 to
1 foot interval, but potentially deeper at localized areas of the
site), mixing of the soil with a fixation agent (such as Portland
Cement), and replacement of the fixed soil on the site. Fixed
soil containing arsenic, chromium, copper, and/or zinc at
concentrations exceeding the TTLC or STLC criteria will be placed
into lined cells. The purpose of the treatment is to stabilize
the contaminants and prevent mobilization. The stabilized soil
mass would eliminate fugitive dust emissions, prevent surface
water erosion of contaminated soil, and reduce leachability of
contaminants. EPA has performed treatability studies using site
soils. Results of these studies indicate that fixation with a
Portland cement mixture would be effective in reducing metals
leachability to clean-up standards (5 ppm for arsenic). Measures
would be taken to protect the surface of the fixed soil mass from
physical decomposition. Institutional controls would be put in
place to ensure that future land use practices are compatible
with the fixed soil mass. The risk posed by the site would be
reassessed at 5-year intervals to confirm that this remedy
continues to protect public health and the environment.
Alternative 4 - Capping
The capping alternative would involve consolidating contaminated
soils exceeding the 8 ppm arsenic clean-up standard in fringe
areas and placing the soils on a central portion of the site.
The surface of the capping area would be graded to the design
contours of the cap. A multilayer cap would be designed to meet
1 Inorganic contaminants are commingled. Through removal of
arsenic to 8 ppm, all lesser threat contaminants are expected to
be removed and treated.
BAXRODF.7 7-4
-------
RCRA cap permeability standards and would direct surface water
runoff around and away from it. if subsequent plans for the use
of the capped area include wood treatment activities, the surface
of the cap would need to be protected. Either an asphalt or
concrete cover would need to be placed on the cap to maintain its
structural integrity. As contaminants would be left in the
ground untreated, long-term cap maintenance, institutional
controls and site monitoring would be required for this
alternative to remain protective.
7.1.2 SOILS CONTAMINATED WITH ORGANICS
The sub-units contaminated with creosote organics are only the
wastewater vault area soils, subsurface creosote area soils, and
the Roseburg excavation pond and french drain area soils.
Total volume of organic soils is estimated at 12,500 cubic yards.
Alternative 1 - No Action
This No Action alternative would be the same as that described in
the No Action alternative for soils contaminated with inorganics.
Alternative 2 Excavation and Offsite Disposal
This alternative would be the same as Excavation and Off-site
Disposal for soils contaminated with inorganics. This
alternative would involve excavation of soil containing creosote
in the approximate 2- to 12-foot depth range (or to the top of
the groundwater table) on the wood treatment property, and 0- to
5-foot range on the Roseburg property, and transport of soil in
haul trucks to an approved landfill. Soil would be excavated to
meet the 0.5 ppm standard for carcinogenic PAHs2.
Alternative 3 - Excavation and Off-site Incineration
This alternative would involve excavation of soil in the
approximate 2- to 12-foot depth range (or to the top of the
groundwater table) on the wood treatment property, and in the
0- to 5-foot range on the Roseburg property, and transport of
soil in haul trucks to an off-site incinerator. Soil would be
excavated to meet the 0.5 ppm clean-up standard for carcinogenic
PAHs. This portion of the alternative would be identical to the
excavation and off-site disposal alternatives. At the
incineration facility, the soils would be processed for thermal
destruction, and the ash would be treated and disposed of as
hazardous waste.
2Carcinogenic and non-carcinogenic PAHs are commingled. The
excavation of carcinogenic PAHs to the proposed standard will also
remove non-carcinogenic PAHs below 1 ppm.
BAXRODF.7 7-5
-------
Alternative 4 - Excavation. Biological Treatment, and On-site
Disposal
This alternative would involve the excavation of hear surface
soil in the approximate 2- to 12-foot depth range (or to the top
of the groundwater table) on the wood treatment property, and in
the o- to 5-foot range on the Roseburg property. Soil would be
excavated to meet the 0.5 ppm clean-up standard for carcinogenic
PAHs. After excavation, soil would be placed in a controlled
land-treatment unit consisting of a shallow excavation
(approximately 10 feet deep), lined with clay and synthetic
material, (i.e., the cell would be constructed to meet RCRA liner
requirements). The synthetic liner would be designed to collect
leachate and prevent contaminants from migrating from the
treatment units into groundwater or surface water. The leachate
collected would be either returned to the land treatment unit or
treated in the groundwater treatment system.
We estimate that eight 1-acre lined treatment cells will be
required for this action. Soil from contaminated areas will be
excavated based on total allowable concentrations of
contaminants in soil. These total concentrations are 0.510 ppm
for carcinogenic PAHs, 0.150 ppm for non-carcinogenic PAHs, and
17 ppm for pentachlorophenol. Soil exceeding leachate limits of
0.005 ppm for carcinogenic PAHs, 0.150 ppm for non-carcinogenic
PAHs, and 1.7 ppm for pentachlorophenol will also be excavated.
The excavated soil will be treated biologically to reduce the
leachability of contaminants to the leachate concentration
standards of 0.005 ppm for carcinogenic PAHs, 1 ppm for non-
carcinogenic PAHs, and 1.7 ppm for pentachlorophenol. The cells
will be designed and constructed to prevent release of leachate.
Soil would be treated using natural microbial populations, the
effectiveness of which would be enhanced through the mixing of
nutrients and fertilizers into the soil. Biological treatment
would continue in these cells until the leachate collected
consistently shows PAH concentrations below 5 ppb for total
carcinogens and 1 ppm for total noncarcinogens.
The soil would be regularly tilled to mix the fertilizers, and to
aerate and expose the soil to sunlight. The soil would be
irrigated regularly to maintain a proper moisture level. The
soil would be sampled at specific intervals to monitor the rate
of biological degradation and to verify the achievement of the
action levels for contaminants, primarily for PAHs. Once the
action level is achieved and the soil considered treated, another
layer of soil would be placed over the treated soil in the
treatment unit. The next layer would be treated as described
above. When the soil layers reach near the level of the top of
the unit land surface (approximately 8 feet of treated soil), the
unit will be closed. Closure will be accomplished by placing an
elevated "soft" cover of clean soil material over the treated
BAXRODF.7 7-6
-------
elevated "soft" cover of clean soil material over the treated
soil. A vegetative cover will be established over the cover
soils. Leachate collection monitoring and institutional controls
will be necessary after remedy to completion to assure that the
residuals are not disturbed or removed. At completion of the
remedy, the approximately 12,500 cubic yards of treated soils
would be expected to contain low levels of PAHs.
The PRPs have conducted treatability studies using site soils.
Results of these studies show bioremediation to be an effective
alternative for reducing the creosote levels in soils to meet the
leachability standard. Institutional controls will be necessary
to ensure that the long-term soil storage units are maintained
and are not disturbed until residual concentrations of creosote
compounds are less than 0.5 ppm for total carcinogenic PAHs.
7.1.3 SOILS CONTAMINATED WITH ORGANICS AND INORGANICS
The site areas containing soils contaminated with both organics
and inorganics are the retort and drip pad areas and the No. 3
tank-bermed area. Total volume of combined organic and inorganic
soils is approximately at 9,380 cubic yards.
Alternative 1 - No Action
This No Action alternative would be the same as that described in
the No Action alternative for soils contaminated with inorganics.
Alternative 2 ~ Excavation and Off~site Disposal
This alternative would be the same as Excavation and Off-site
Disposal for soils contaminated with inorganics. Excavation and
treatment standards would be the same as for the inorganics and
organics in soils previously discussed. Excavation would occur
from ground surface to a depth of 12 feet or to the point where
groundwater prevents further excavation. Implementation of the
alternative would require demolition, relocation, and/or
replacement of the retort building, storage tanks, 500,000 gallon
tank, and associated structures and utilities.
Alternative 3 - Excavation and Off-site Incineration
This alternative would be the same as Excavation and Off-Site
Incineration for organic contaminated soils.
Alternative 4 - Capping
This alternative would be the same as Capping for soils
contaminated with inorganics.
BAXRODF.7 7-7
-------
Alternative 5 - Excavation. Biological, Treatment, Qn-site .
Fixation, and Onsite Disposal
This alternative would involve the excavation of contaminated
soils above clean-up standards (8 ppm for arsenic, 17 ppm for
pentachlorophenol. 0.001 ppm for dioxins, and 0.5 ppm for
carcinogenic PAHs3), coupled with soil biological treatment to
reduce or destroy organic contaminants (as described in the
organics section). Excavation would involve the approximate 0 to
12 foot interval of contaminated soils (or to the point where
groundwater prevents further excavation) and placement of the
soils in lined-treatment cells for microbial destruction of
organics. The biologically treated soil would be fixed with a
stabilization agent (e.g., cement) to control mobility of the
inorganics and residual organics (as described in the inorganics
section). reachability standards for the stabilized soil would
be 5 ppm for arsenic, 0.005 ppb for carcinogenic PAHs, and 1.7
ppm for pentachlorophenol. The treated and fixed soil would then
be placed back into lined cells meeting RCRA requirements and
handled in a manner protective of human health and the
environment. Treatment to reduce organic levels would be
required because pilot studies indicate that the organics cannot
be immobilized in the fixed mass.
7.2 GROUNDWATER REMEDIAL ALTERNATIVES
The shallow aquifer beneath the site is contaminated with arsenic
and creosote compounds. This shallow aquifer exists from near
ground surface (2 feet to 8 feet) to approximately 40 feet in
depth at its deepest point. Arsenic and creosote contaminated
groundwater extends from below the wood treatment area towards
the northwest approximately 1,000 feet in the direction of Angel
Valley subdivision. Approximately 6 acres are affected below the
Baxter wood treatment property and 15 acres below Roseburg's
property. A separate body of creosote product also exists below
the wood treatment property; The areas of groundwater most
seriously affected at the site include areas beneath the wood
treatment property, the Roseburg excavation pond, and its french
drain collection system.
Although the shallow aquifer below the site is not currently used
as a drinking water source, it is a Class I aquifer of high
quality and is a potential source that requires minimal treatment
for drinking water purposes. The community presently obtains its
water supply from wells drilled into deeper aquifers and from
springs located upgradient of the site. The shallow aquifer is
used locally for yard irrigation purposes.
3The principal threat contaminants are commingled. Through
removal of the principal threat contaminants to these levels, all
low level threat contaminants are expected to be removed.
BAXRODF.7 7-8
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Alternative 1 - No Action
This alternative would allow wood treatment chemicals to remain
in groundwater with the potential for off-site movement to wells
in the Angel Valley area. No risk reduction would result. The
alternative would not comply with ARARs or State discharge
limitations. The No Action alternative would not preclude long-
term groundwater monitoring. Risks posed by the site would be
reexamined at 5-year intervals.
Alternative 2 - Groundwater Extraction. Biological and Chemical
Treatment, and Discharge
This alternative would involve pumping the contaminated
groundwater using extraction wells and biologically treating the
water with naturally occurring microorganisms to remove organics
contaminants. Treatment would occur until carcinogenic PAH
concentrations were reduced to 5 ppb and pentachlorophenol to 2.2
ppb. All principal and low level threat contaminants will be
treated to their respective standards by this remedy. Final
reduction to clean-up standards will require the use of an
activated carbon or UV/ozonation destruction polishing step.
Inorganics would be removed from the extracted groundwater using
a chemical precipitation process. The addition of lime to the
extracted groundwater will cause metals to form a precipitate
which is filtered from the waste stream. A sludge is formed
which is dewatered in a filter press. Polishing of the lime
treated effluent using either activated alumina or ion exchange
techniques may be necessary to meet clean-up standards. The
required treatment standard for arsenic is 5 ppb and for zinc is
90 ppb. All principal and low level threat inorganic
contaminants will be treated to their respective standards by
this remedy.
EPA expects that up to 150,000 gallons of contaminated water may
need to be treated and discharged each day. Hater would continue
to be extracted from the contaminated aquifer until in situ
concentrations meet the clean-up standards. This is expected to
take at least 30 years to occur. The initial proposed area of
groundwater contamination containment will be the boundaries of
the wood treatment property during remediation. The point of
compliance at the end of the remedial action will be throughout
the aquifer below and adjacent to the site, where clean-up
standards addressed in this ROD will be attained.
The biological treatment process will produce a sludge waste
comprised of bodies of dead microorganisms, suspended solids that
have settled in the tanks, and a minor amount of metals that have
precipitated or adsorbed to the bodies of microorganisms. The
metals treatment process will produce a sludge containing
BAXRODF.7 7-9
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residual metals that will need to be handled as a hazardous
waste. If activated carbon is used, the spent activated carbon
will need to be handled as a hazardous waste. The activated
alumina and ion exchange processes will also produce a
concentrated waste that will require special handling and
disposal.
International Paper, Roseburg and Baxter have installed a full-
scale water treatment unit at the site which will be used for the
final remedy. Pilot tests and initial treatment results for this
facility indicate that it is capable of meeting the identified
standards.
Discharge of up to 150,000 gallons per day of treated groundwater
is an implementation requirement. Discharge water would be
initially treated to health-based standards listed in Tables 4-1
and 4-2. The proposed point of compliance will be the effluent
as it leaves the treatment plant. Several disposal alternatives
for treated groundwater may be used to release this volume of
water, including the following:
o Disposal to groundwater. Treated water could be
discharged by injection wells back to the aquifer.
Water treated to health-based standards can be injected
into contaminated areas to speed removal of
contamination from the aquifer.
o Disposal to subsurface drains or trenches. Water
treated to health-based standards could be discharged
to a grid system of pipes below the surface. These
pipes would contain holes to allow controlled
distribution of the treated water into the ground above
the aquifer. Again, this could speed removal of
contamination from the aquifer.
o Industrial process use. Water treated to health-based
standards could be used for industrial operations at
the site such as sprinkler system water, wood treatment
make-up water, and boiler water.
o Percolation/Evaporation Ponds. Water treated to
health-based standards could be distributed into the
ground above the aquifer with percolation ponds.
The groundwater pump and treatment alternative can be implemented
to address all Federal ARARs for the action. Institutional
controls to prevent access to the contaminated aquifer will be
necessary while the action is being implemented.
BAXRODF.7 7-10
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Alternative 3 - Groundwater Extraction. Physical and Chemica^,
Treatment, and Discharge
This alternative would involve all of the process steps included
in Alternative 2 of this section except that biological treatment
for organics would be replaced with either activated carbon
adsorption or UV-oxidation treatment. All other aspects
including clean-up goals, time frame for completion, and
residuals management would remain the same.
7.3 SURFACE WATER ALTERNATIVES
Prior to construction of surface water drainage berms and
ditches, water from the retort, drip pad, and tank berm areas
flowed to the northwest into the site discharge drainage. Runoff
of this area is presently being collected for storage in above
ground tanks and subsequent use as process water in the wood
treatment process. Runoff from the remaining portion of the wood
treatment property is uncontrolled, flowing either to the north
out the main gates or to the west along the railroad tracks.
Because surface soils in these areas are significantly
contaminated with arsenic and other chemicals, these actions do
not prevent precipitation from coming in contact with the soils,
thus creating contaminated surface water on the property and
which either runs off or infiltrates into the shallow aquifer.
Alternative 1 - No Action
The No Action alternative would not prevent precipitation from
coming in contact with contaminated soils. The action could
involve monitoring the surface water runoff to measure
contamination levels. No action would likely result in violation
of current NCRWQCB orders.
Alternative 2 - Treatment and/or Isolation of Contaminated
Surface Soils
Remedial alternatives presented in Section 7.1 for contaminated
soils would effectively remove, treat, and/or isolate
contaminated soils. These actions would prevent or greatly
reduce contact between precipitation/surface water and
contaminated soil, thereby preventing or minimizing future
surface water contamination.
Alternative 3 - Collection. Storage, and Treatment of
Contaminated Surface Water
Contaminated surface water would be collected and temporarily
stored for process water use or treatment and disposal in the
same manner as contaminated groundwater. This would require
installation of surface water control berms and ditches and
collection of water in sumps. Water would be pumped into storage
BAXRODF.7 7-11
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vessels for use as process water or for treatment and discharge.
Significant storage capacity in excess of 1,000,000 gallons of
water would be required to contain anticipated rainfall for the
most contaminated areas of the site. Clean-up standards for the
alternative would be 5 ppb for arsenic and 0.5 ppb for
carcinogenic PAHs for water released from the site.
This alternative would represent a temporary remedy for the site.
A continued threat for offsite release would remain as long as
contaminated soils remained in place. Only through removal or
treatment of soils and proper precipitation management on the
treated lumber storage areas could a permanent remedy for the
surface water problem be achieved.
7 .4 SEDIMENT ALTERNATIVES
The potential remedial alternatives for contaminated sedirents,
sediments in Beaughton Creek near NPDES #1 and site drainage
sediments, are limited to (1) no action and (2) excavation by
dredging followed by treatment and disposal actions.
Alternative 1 - No Action
This alternative would allow the contaminated sediments to remain
in place. Contaminated sediments would continue to be moved
downstream by the flushing actions of seasonal runoff for natural
degradation of organics and ultimate deposition of inorganics in
the bottom sediments of Lake Shastina.
Alternative 2 - Excavation. Treatment and Disposal
This alternative would involve excavation of contaminated
sediment. Excavated sediments could be incorporated into
treatment options being considered for surface soils. Soil with
less than 500 ppm of arsenic is not classified as a hazardous
waste so it could be transported for disposal at a municipal
landfill. Any sediment removal action would be coordinated with
the California Department of Fish and Game.
BAXRODF.7 7-12
-------
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
An evaluation and comparison of the alternatives are presented in
this Section. The comparison is based on the nine key criteria
required under the National Contingency Plan and CERCLA
Section 121 for use in evaluation of remedial alternatives by
EPA. The nine criteria are as follows:
o Overall protection of human health and the environment.
o Compliance with Applicable or Relevant and Appropriate
Requirements (See Tables 8-1 and 8-2 for ARARs
evaluated).
o Long-term effectiveness and permanence.
o Reduction of toxicity, mobility or volume.
o Short-term effectiveness.
o Implementability.
o Cost.
o State acceptance.
o Community acceptance.
8.1 ALTERNATIVE COMPARISON FOR SOILS
Table 8-3 presents a comparison of alternatives for soils
contaminated with inorganics only, Table 8-4 for soils
contaminated primarily with organics, and Table 8-5 for soils
contaminated with inorganics and organics.
8.2 ALTERNATIVE COMPARISON FOR GROUNDWATER
See Table 8-6 for comparison of alternatives for groundwater
treatment remedies.
8.3 ALTERNATIVE COMPARISON FOR SURFACE WATER
See Table 8-7 for comparison of alternatives for surface water
control and treatment remedies.
8.4 ALTERNATIVE COMPARISON FOR SEDIMENTS
Two stream segments at the site may warrant remedial action due
to the presence of wood treatment chemicals as determined during
the remedial investigation. These segments include a 150-foot
stretch of the drainage adjacent to the Roseburg power plant and
a 100-foot stretch of Beaughton Creek downgradient of the
Roseburg NPDES Number 1 discharge point.
A remedy for sediments within Beaughton Creek is not recommended
until additional aquatic biota studies can be performed on the
Creek. These additional data are important for evaluating the
BAXROD.8 8-1
-------
TABLE 8-1
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
BAXTER/IP/ROSEBURG SITE
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Comnent
09
I
M
Safe Drinking Mater Act
Underground Injection Control
Regulations
Solid Waste Disposal Act
(Resource Conservation and
Recovery Act)
Identification and Listing of
Hazardous Waste
Releases from Solid Waste
Management Units
Standards Applicable to
Generators of Hazardous Waste
Standards for Owners and
Operators of Hazardous Waste
Treatment, Storage, and
Disposal Facilities
40 U.S.C. §300
40 C.F.R.
Parts 144--147
42 U.S.C.
§§3251-3259.
6901-6987
40 C.F.R.
Part 264.1
40 C.F.R.
Part 264
Subpart F
40 C.F.R.
Part 262
40 C.F.R.
Part 264
Provides for protection of underground
sources of drinking water.
Defines those solid wastes which are subject
to regulation as hazardous wastes under
40 C.F.R. Parts 261-265 and Parts 124, 270,
271, and Subtitle C regulates treatment and
disposal of hazardous waste.
Establishes maximum contaminant
concentrations that can be released from
hazardous waste units in Part 264, Subpart F.
Establishes standards for generators of
hazardous waste.
Establishes minimum national standards which
define the acceptable management of hazardous
waste for owners and operators of facilities
which treat, store, or dispose of hazardous
waste.
A permit is not required for on-site CERCLA response
actions, but substantive requirements would apply for
reinjection into groundwater of treated water.
This law has been amended by the Resource Conservation
and Recovery Act (RCRA) and the Hazardous and Soil
Waste Amendments (HSWA).
Under CERCLA, SUOA requirements may be relevant and
appropriate under the circumstances of the release at
the site. RCRA Subtitle C regulates any solid wastes
containing arsenic or pentachlorophenol which pose a
threat to public health or welfare or the environment.
These are termed "hazardous substances," and disposal
regulations require treatment to specific standards for
proper disposal.
The maximum contaminant concentrations that can be
released from hazardous waste units are identical to
the HCLs.
Transportation and disposal of filter cake and spent
carbon and any other hazardous wastes thay may need
off-site disposal will comply with these requirements.
The substantive portions of these regulations will be
incorporated into the remedies identified in this ROD.
f> 1 /
-------
Standard, Requirement,
Criteria, or Limitation
TABLE 8-1
FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
BAXTER/IP/ROSEBURG SITE (cont.)
Citation
Description
Comment
Land Disposal
Clem Air Act
RCRA
Sections J004(d)
(3). (e)(3)
40 C.f.R. Part
268
42 U.S.C.
§§7401-642
Effective 11/8/88 disposal of contaminated
soil or debris from CERCLA Response action or
RCRA corrective actions is subject to land
disposal prohibitions and/or treatment
standards.
Regulates air quality and particulate
emissions during excavation.
Established a timetable for restriction of burial of
wastes and other hazardous materials. Applicable for
alternative involving off- or on-site disposal of
contaminated soiIs.
The substantive requirements Mill be met for Air
Pollution Control District rules for excavation
alternatives.
Hazardous Material*
Transportation Act
* Hazardous Materials
u> Transportation Regulations
fiati and Wildlife Coordination
Act
Executive Order on Protection
of yetl«
49 U.S.C.
$11801-1813
49 C.F.R.
Parts 107. 171-
177
16 U.S.C.
$§661-666
Exec. Order
No. 11,990
40 C.F.R.
§6.302(a) and
Appendix A
Regulates transportation of hazardous
materials.
Requires consultation when Federal department
or agency proposes or authorizes any
modification of any stream or other water
body and adequate provisions for protection
of fish and wildlife resources.
Requires Federal agencies to avoid to the
extent possible, the adverse impacts
associated with the destruction or loss of
wetlands and to avoid support of new
construction in wetlands if a practical
alternative exists.
Regulations required for transportation of hazardous
materials to the site and wastes from the site.
If an alternative developed would involve any
modifications of nearby streams.
If an alternative developed would involve any
modification or loss of wetlands.
*<» a »/p
-------
TABLE 8-2
CALIFORNIA APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
BAXTER/IP/ROSEBURC SITE
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Comment
California Air Resources Act
California Safe Drinking Water
Act
00
I
Porter Cologne Water Quality
Control Act
California Hazardous Waste
Control Laws
Health & Safety
Code. Div. 26
Sec. 39000
et seg.
17 CCR. Part
111, Chapter 1.
Sec. 60000
et seg.
Health t Safety
Code. Div. 5,
Part 1,
Chapter 7,
SEC. 4010 et
seg.
22 CCR. Div. 4.
Chapter 15, Sec.
64401 et seq.
Water Code.
Div. 7.
Sec. 13000 et
seg.
Health t Safety
Code, Div. 20,
Chapter 6.5.
Sec. 25100 et
seg.
Regulates both nonvehicular and vehicular
sources of air contaminants in California.
Regulations governing public water systems.
Drinking Water Quality Standards - Maximum
contaminant Levels (MCLs), Secondary Maximu
Contaminant Levels (SMCLs).
Establishes authorities of the State and
Regional Water boards to protect water
quality by regulating waste disposal and by
requiring cleanup of hazardous conditions.
Regulations governing hazardous waste
control; management and control of hazardous
waste facilities; transportation;
laboratories; classification of extremely
hazardous, hazardous, and nonhazardous waste.
The local Air Pollution Control District sets
allowable discharge standards. Emissions from
heavy equipment and excavation dusts will need
to comply with APCD standards.
CA regulatory agency is the Air'Resources
Board. Local regulatory agencies are the Air
Pollution Control Districts.
The State MCL of 1 ppb for benzene was
selected as a groundwater standard for this
site.
CA Regulatory Agency: Department of Health
Services, Sanitary Engineering.
The Basin Plan was used to establish surface
water discharge (imitations and sediment
clean-up standards.
These regulations were used to establish
hazardous waste clean-up levels, facility
closure requirements, and requirements for
siting and construction of a waste disposal
facility.
CA Regulatory Agency:
Services.
Department of Health
-------
TABLE 8-2
CALIFORNIA APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
BAXTER/1P/ROSEBURG SITE (cont.)
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Comment
California Toxic Pits Cleanup
Act (TPCA)
State Action Levels
Health I Safety
Code. Sec. 25250
et seg.
DNS Criteria
09
I
Ul
Criteria for Identification of
Hazardous and Extremely
Hazardous Wastes-Threshold
If sift Concentrations
22 CCR, Oiv. 4,
Chapter 30,
Art. 11.
Sec. 66693 et
seq.
Regulates the closure of surface impoundnents
containing hazardous waste.
Criteria setting chemical specific
concentration levels. Numerical limits
designed to protect human health from
chemical constituents in drinking water.
Recommended acceptable limits.
Action levels are drinking water exposure
criteria implemented throughout the state.
They are developed by OHS Sanitary
Engineering Branch to supplement Safe
Drinking Water Act standards.
Promulgated criteria to determine if a
material is hazardous. Includes Soluble
Threshold Limit Concentrations (STLCs) and
Total Threshold Limit Concentration (TTLCs).
Several units identified by the NCRWQCB are
present at the site. Several TPCA units
present at site.
The Applied Action Level of 2.2 ppb was used
to identify the clean-up standard for
pentachlorophenol.
CA Regulatory Agency: Department of Health
Services, Sanitary Engineering Branch.
TTLC and STLC criteria were used to identify
soil clean-up standards.
CA Regulatory Agency: Department of Health
Services.
BAXRODf.8 2/p 2
-------
Table 8-3 Sutmary Comparison of Alternatives:
Surface Soils Contaminated with Inorganics Only
No Action
Excavation and Offsite Disposal
Excavation, Fixation and On-site Capping
Disposal
1. Overall Protection of Human Health and the Environment
No Action would not address
remedial action objectives.
Continued releases of
contaminants would occur in
exceedence of health standards.
It Mould not be protective of
public health or the environment.
This alternative Mould be
protective through placement of
contaminated soils at at
controlled facility. Protec-
tiveness Mould be dependent on
the integrity of the facility
receiving the Hastes.
fixation of contaminated soils
Mould be protective through
reduction of mobility. Direct
contact and inhalation risk Mould
be reduced, surface Mater and
ground-Mater would be protected.
Capping would reduce direct
contact and surface water runoff
risk. Some reduction in
groundwater mobility Mould be
achieved but the action Mould not
be totally protective of
groundwater.
2. Compliance with ARARs
The No Action Alternative Mould
not comply with Federal or State
health protection standards.
0)
I
o\
Excavation and off-site disposal
could be implemented to address
ARARs. Treatment to reduce
arsenic teachability may be
required at disposal facility.
On-site fixation and disposal
could be implemented to address
ARARs. Initial fixation tests
indicate that teachability of
arsenic can be reduced to <5
mg/L. A cap over fixed soils
could be constructed to meet RCRA
ARARs.
A cap could be constructed to
address ARAR standards. A cap
could meet surface water
protection ARARs. A cap may not
allow compliance, with groundwater
ARARs (NCLs).
3. Reduction in Toxicity. Mobility, or Volume
No Action Mould not achieve any
reduction in TMV.
Excavation and removal Mould
reduce mobility at the site.
Long-term nobility reduction
Mould depend on stability and
treatment at disposal facility.
No reduction in toxicity or
volume Mould be achieved.
fixation Mould reduce
teachability and mobility at
site. No reduction in toxicity
but exposure potential Mould be
reduced. Volume of contaminated
media would increase.
Capping Mould reduce surface-
water runoff potential and air
dispersion. Some reduction in
groundwater mobility possible.
No reduction in toxicity or.
volume would be achieved.
A. Short-term Effectiveness
Not applicable. The alternative
does not involve an action.
Excavation could be performed to
be protective of workers and the
community. Worker protection and
runoff control would be
necessary. Transportation
accidents during shipment would
be a concern.
Excavation and fixation could be
performed to be protective of
workers and community. Greater
chance for worker and community
exposure due to increased
material handling could exist.
Capping Mould pose least risk to
workers and community during
implementation. Minima' amount
of contaminants would be handled.
-------
Table 8-3 Summary risen of Alternatives
Surface Soils Contaminated with Inorganics Only (continued)
No Action
Excavation and Offsite Disposal
Excavation, Fixation and On-site Capping
D i sposal
5. Long-tern Effectiveness and Permanence
No Action uould offer no long-
tern effectiveness. Site risks
uould remain indefinitely.
Excavation and off-site disposal
would remove long-term risk from
site. Overall risk uould be
dependent on the integrity of the
facility-receiving the waste.
Long-term effectiveness uould be
dependent on integrity of fixed
mass and ability of fixative to
prevent leaching of arsenic.
Long-term test results are not
available for the technology.
Long-term effectiveness for
protection of surface water uould
be dependent on maintenance of
the cap. This may not be a
permanent alternative if
groundwater contamination
continues.
6. Implemcntability
oo
I
Not Applicable. The alternative
does not involve an action.
Construction and transportation
aspects of excavation are easily
implemented. Capacity of
disposal facility to receive
waste could affect
implementation. RCRA land
disposal treatment standards
could affect implementation.
Construction and fixation aspects
are easily implemented. Adequate
space is avaible to treat and
dispose of soil. Land disposal
teachability standards appear
achievable. State land disposal
issues require resolution.
Construction of the cap is
readily implementabte.
7. Cost
Capital: SO
Annual DIM: $ 9.800
Remedy OM: $ 0
Present Worth: $132.400
Capital: $12.840,400
Remedy Ann. OM: $ 0
Post Ann. OM: $ 0
Present Worth: $12.840,400
Capital: $4.525.800
Remedy Ann. OM: $ 0
Post Ann. OM: $ 16,500
Present Worth: $4.748,800
Capital: $6,204,100
Remedy An OM: $ 0
Post An. O&M: $ 53,500
Present Worth: $6,926,900
B. Community Acceptance
Not acceptable.
9. State Acceptance
Not acceptable.
Acceptable.
The State would prefer an
alternative that dealt with
contamination at the site.
Acceptable.
Acceptable if action meets all
substantive RCRA requirements.
Not acceptable
Not acceptable as final action.
The State prefers treatment.
-------
labte 8-4 Summary Comparison of Alternatives:
Near Surface Soils Contaminated with Organics Only
No Action
Excavation and Offsite Disposal
Cxcavation, Bioremediation, and
On-site Disposal
Excavation and Off-site
Incineration
1. Overall Protection of Hunan Health and the Environment
No Action would not address
remedial action objectives.
Continued releases of
contaminants would occur in
exceedence of health standards.
It would not be protective of
public health or the environment.
This alternative would be
protective through placement of
contaminated soils at at
controlled facility. Protec-
tiveness would be dependent on
the integrity of the facility
receiving the wastes.
Bioremediation of contaminated
soils would be protective through
nearly complete destruction of
PAHs. Direct contact and
inhalation risk would be reduced.
Surface water and groundwater
would be protected.
Incineration would destroy PAHs
eliminating risk at site.
Emissions controls at incinerator
would be necessary to protect
health at incinerator site.
2. Compliance with ARARs
The No Action Alternative would
not comply with Federal or State
health protection standards.
Excavation and off-site disposal
could be implemented to address
ARARs. Treatment to reduce
teachability may be required at
disposal facility.
Construction of land treatment
cells and implementation of
bioremediation could be performed
to comply with ARARs. State and
federal closure requirements for
the long-term containment unit
will need to be addressed.
Incineration could be implemented
to address all ARARs.
3. Reduction in Toxicitv. Mobility, or Volume
I
9
No Action would not achieve any
reduction in TMV.
Excavation and removal would
reduce mobility at the site.
Long-term mobility reduction
would depend on stability and
treatment at disposal facility.
No reduction in toxicity or
volume would be achieved.
Bioremediation would
significantly reduce PAH levels
in soils. Significant volume and
toxicity reduction would be
achieved. Mobility of residuals
would be controlled through cell
liner and leachate monitoring
system.
Incineration would destroy 99.99X
of PAHs. Significant reduction
in toxicity, mobility, and VO(UM
would be achieved. Long-term
containment of ash as a hazardous
waste would not be necssary.
Short-term Effectiveness
Hot applicable. The alternative
does not involve an action.
Excavation could be performed to
be protective of workers and the
community. Worker protection and
runoff control would be
necessary. Transportation
accidents during shipment would
be a concern.
Excavation and bioremediation
could be performed to be
protective of workers and
community. A greater chance
exists for worker and community
exposure due to increased
material handling.
Excavation could be performed to
be protective. Emission control
equipment would be necessary at
incinerator site. Transportation
accidents would be a concern.
-------
Table 8-4 Summary Comparison of Alternatives:
Near Surface Soils Contaminated with Organics Only (continued)
No Action
Excavation and Offsite Disposal
Excavation, Bioremediation, and
On-site Disposal.
Excavation and Off-site
Incineration
5. Long-tern Effectiveness and Permanence
No Action would offer no long-
tera effectiveness. Site risks
Mould raaain indefinitely.
&. Irolementability
Not Applicable. The alternative
doe* not involve an action.
Excavation and off-site disposal
would remove long-tern risk from
site. Overall risk would be
dependent on the integrity of the
facility receiving the waste.
Construction and transportation
aspect* of excavation are easily
inplenented. Capacity of
disposal facility to receive
waste could affect
Implementation. RCRA land
disposal treatment standards
could affect implementation.
Long-term effectiveness would be
dependent on integrity of
containment cell to control
residuals. Long-term leachate
monitoring would be required.
Construction of biormediation
treatment cells and the
bioremediation process are easily
implemented. Adequate space is
avaibte to treat and dispose of
soil. Land disposal teachability
standards appear achievable.
Incineration offers significant
long-term effectiveness through
destruction of contaminants with
no need for long-term residuals
management.
Implementation of off-site
incineration would depend on
incinerator facility capacity to
accept the volume of soil. Other
aspects are implementeble.
'., r, cost
Capital: $ 0
Remedy OCN: * 9,800
Post OIN: * 0
Present Worth: * 132,400
Capital: »11.232.900
Remedy OM: $ 0
Post OM: $ 0
Present Worth: $11,232,900
Capital: $ 5,487,300
Remedy OM: * 224.700
Post OM: $ 13,600
Present Worth: % 7.370.800
Capital: S39.237.100
Remedy OM: I 0
Post OM: S 0
Present Worth: $39,237.100
8. Community Acceptance
Not acceptable.
9. State Acceptance
Acceptable
Acceptable
Acceptable
Not acceptable.
The State would prefer an
alternative that dealt with
contamination on site.
the
Alternative would be acceptable
if all requirements are met.
Alternative would be acceptable
if all requirements are met.
-------
Table 8-5 Summary Comparison of Alternatives:
Surface Soils Contaminated with Inorganics and Organics
No Action
Excavation and Offsite Disposal
Excavation. Bioremediation,
Fixation and On-site Disposal
Excavation and Off-site
Incineration and Disposal
Capping
1. Overall Protection of Hunan Health and the Environment
No Action would not address
remedial action objectives.
Continued releases of
contaminant* Mould occur into
air, surface Mater, and
groundwater in exceedence of
health standards. It would not
be protective of public health
or the environment.
2. Compliance Mith ARARs
The No Action Alternative Mould
not comply with Federal or
State health protection
standard*.
This alternative would be
protective through placement of
contaminated soils at at
controlled facility. Protec-
tiveness would be dependent on
the integrity of the facility
receiving the wastes and
treatment of soils performed at
the facility.
Excavation and off-site
disposal could be implemented
to address ARARs. Treatment to
reduce PAH leachability may be
required at disposal facility.
oo
I
" 3. Reduction in Toxicity. Mobility, or Volume
No Action would not achieve any
reduction in TNV.
Excavation and removal would
reduce mobility at the site.
long-term mobility reduction
would depend on stability and
treatment at disposal facility.
No reduction in toxicity or
volume would be achieved.
Bioremediation would destroy a
significant amount of organic
contaminants. Fixation of
residuals and containment in
cells would be protective
through reduction of mobility.
Thereby, preventing direct
contact and inhalation risk.
Surface water and groundwater
would be protected.
On-site bioremediation,
fixation and disposal of
residuals could be implemented
to address ARARs. Leachability
restrictions would need to be
met.
On-site bioremediation and
fixation in a contained cell
would significantly reduce
toxicity, mobility and volume
through destruction of PAHs.
The cell liners and leachate
collection system could
effectively prevent mobility at
the site.
Incineration would destroy
99.99X of organic contaminants.
Long-term containment of
residuals would be required due
to arsenic content.
Alternative provides best
protection for contact,
groundwater and surface water
runoff risks at the site.
Off-site incineration and ash
disposal could be implemented
to address all ARARs.
Incineration would remove from
site PAHs above action level
and destroy 99.99X of
contaminants removed.
Significant reductions in
toxicity, mobility, and volume
would be achieved for PAHs.
Ash would contain elevated
arsenic. Nobility will be
controlled at disposal
facility.
Capping would reduce direct
contact and surface Mater
runoff risk. Some reduction ir
groundwater mobility would be
achieved, but the action would
not be totally protective of
groundwater.
A cap could be constructed to
address ARAR standard!. A cap
could meet surface water
protection ARARs. A cap may
not allow compliance with
groundwater ARARs (NCLs).
Capping would reduce surface
water runoff potential and ai.
dispersion. Some reduction in
groundwater mobility possible
No reduction in toxicity or
volume would be achieved.
I. Short-term Effectiveness
Not applicable. The alternative
does not involve an action.
Excavation could be performed
to be protective of worker* and
the community. Worker
protection and runoff control
would be necessary.
Transportation accidents during
shipment would be a concern.
Excavation, bioremediation and
fixation could be performed to
be protective of workers and
community. A greater chance
for worker and community
exposure exists due to
increased material handling.
Excavation could be performed
to be protective of workers and
the community. The risk of
transportation accidents is a
concern. Emissions controls at
incinerator would be necessary
to be protective at the
incinerator site.
Capping would post least risk
to workers and community during
implementation. Least amount
of contaminants would be
handled.
-------
Table B-S Si/unary ^^..^jarison of Alternatives:
Surface Soils Contaminated with Inorganics and Organ!cs (continued)
No Action
Excavation and Offslte Disposal
Excavation, Bioremediation,
Fixation and On-site Disposal
Excavation, Off-site Capping
Incineration, and Ash Disposal
5. long-terra Effectiveness and Permanence
Mo Action would offer no long-
term effectiveness.
Contaminants Mould continue to
move into groundMater unabated.
Site risks Mould remain
indefinitely. This Mould not
be permanent remedy.
6. Inclementability
Not Applicable. The
alternative does not involve an
action.
09
I
7. Cost
Capital: * 0
Remedial C4M: t 9.800
Post OIN: S 0
Present Uorth: t 132,000
Excavation and off-site
disposal Mould remove long-term
risk from site. Overall risk
Mould be dependent on the
integrity of the facility
receiving the waste.
Permanance is dependent on
integrity of disposal facility
Construction and transportation
aspects of excavation are
easily implemented. Capacity
of disposal facility to receive
waste could affect
implementation. RCRA land
disposal treatment standards
could affect implementation and
treatment might be required.
Capital: SIO.946,900
Remedial O&M: $ 0
Post OtM: S 0
Present Worth: $10,946,000
Long-term effectiveness Mould
be dependent on residual PAH
concentrations in disposal
cells, the integrity of the
cells, and leachate
collection/monitoring systems.
This Mould be a permanent
remedy when leachate generation
potential no longer exists.
Construction of cells and bio-
remediation/fixation processes
are easily implemented.
Adequate space is avaible to
treat and dispose of soil.
Land disposal leachability
standards appear achievable.
Long-term stability of fixed
soil is unknown. Federal and
State closure requirements are
unknown.
Capital: S 6,6*8,500
Remedial O&M: S 194,700
Post O&M: $ 13,600
Present Worth: S 8,290,500
Incineration Mould provide
significant long-term
effectiveness through immediate
destruction of PAHs. No
residuals would remain
requiring long-term management.
This is be a permanent remedy.
Incineration may prove
difficult give volume of soil
to be burned, presence of
elevated arsenic, and capacity
of incinerators to handle the
volume. Dioxin incineration
may also be an issue.
Capital: $32,335.400
Remedial O&M: S 0
Post O&M: » 0
Present Worth: S32.235.400
Long-term effectiveness for
protection of surface water
dependent on maintenance of the
cap. This may not be a
permanent alternative if
groundwater contamination
continues.
Construction of the cap is
implementable. Construction
would require relocation or
replacement of wood treatment
structures and tanks.
Capital: * 3,155.800
Remedial O&M: S 0
Post O&M: t 33.500
Present Worth: t 3.608.300
8. Community Acceptance
Not acceptable.
9. State Acceptance
Not acceptable.
Acceptable.
The State would prefer an
alternative that dealt with
contamination on site.
Acceptable. Acceptable.
Alternative would be acceptable Acceptable.
tf all requirements are met.
Not acceptable.
Not acceptable without
treatment.
-------
Table 8-6 Summary Comparison of Alternatives:
Groundwater and Subsurface Soils Contaminated with Creosote
and Groundwater Contaminated with Arsenic
Ho Action
Groundwater Extraction, Biological
Treatment of Organic*, Chemical Treatment
of Inorganics.
Groundwater Extraction, UV or Carbon
Treatment of Organics, Chemical Treatment
of Inorganics.
1. Overall Protection of. Human Health and the Environment
No Action would allow continued Migration
of contaminants towards Angel Valley.
Groundwater concentrations exceeding
health standards would exist
indefinitely. The alternative offers no
protectiveness.
2. Compliance with ARARs
00
I
The No Action Alternative would not
comply with ARARs. Contaminants at
concentrations above health standards
would remain in drinking water source.
3. Reduction in Toxicity. Mobility, or Volume
The No Action alternative would not
achieve any reduction in toxicity.
Mobility, or volume. Increased votune of
contaminated groundwater is possible from
Movement of contaminants.
Extraction would contain the plume
preventing further downgradient movement.
Biological treatment would destroy
significant amount of organics. Metals
treatment to NCLs would provide
protection. The alternative would be
protective.
Treatment to achieve ARARs could be
accomplished. Discharge of treated water
to surface waters is necessary.
Modifications of State discharge
requirements would be required.
Extraction of groundwater would contain
the plume, stopping its mobility.
Organics treatment would reduce mass and
toxicity. Inorganics treatment would
reduce volune through concentration in a
filter cake. Proper disposal of filter
cake would control Mobility of arsenic.
Extraction would contain the plume. UV
treatment would destroy organics.
Activated carbon treatment would remove
organics but require further treatment.
Metals treatment to MCLs would provide
protection. The alternative would be
protective.
Treatment to achieve ARARs could be
accomplished. Discharge of treated water
to surface water is necessary to
implement. Modifications of State
discharge requirements would be required.
Extraction of groundwater would control
the plume stopping its mobility.
Organics treatment would reduce mass and
toxicity. Inorganics treatment would
reduce volume through concentrating in a
filter cake. Proper disposal of filter
cake would control mobility of arsenic.
n t \,
-------
Table 8-6 Summary Comparison of Alternatives:
Groundwater and Subsurface Soils Contaminated with Creosote
and Groundwater Contaminated with Arsenic (continued)
No Action
Groundwater Extraction, Biological
Treatment of Organic*, Chemical Treatment
of Inorganics
Groundwater Extraction, UV/Carboo
Treatment of Organics, Chemical Treatment
of Inorganics
4. Short-term Effectiveness
Not Applicable. No action is taken.
5. long-term Effectiveness and Permanence
09
I
M
CJ
No long-term effectiveness would be
achieved under No Action.
The extraction and treatment process can
be constructed and operated to be
protective of human health and the
environment. Overall effectiveness of
biological treatment to achieve treatment
standards will be assessed during pilot
studies. Side stream wastes can be
effectively handled.
Pump and treatment is expected to take
over 30 years to achieve Treatment
Standards. Total aquifer restoration
would require significantly longer time.
Once MCLs or action levels are achieved
the remedy will be permanent.
The extraction and treatment process
could be constructed and operated to be
protective of human health and the
environment. The overall effectiveness
of UV destruction is not known.
Activated carbon is highly effective in
removing organics. Side stream wastes
can be effectively handled.
Pump and treatment is expected to take 30
years to achieve MCLs. Total aquifer
restoration significantly longer time.
Once achieved, the remedy will be
permanent.
6. Implementability
Not applicable. No remedy implemented.
Alternative implenentable using standard
materials and equipment. Space for pump
and treatment systems available. Waiver
of State discharge prohibitions required
for discharge treated effluent to surface
water.
Alternative implementable using standard
materials and equipment. Space for
pump and treatment systems available.
Waiver of State discharge prohibitions
required for discharge to surface water.
Table 8-6 Summary Comparison of Alternatives:
Groundwater and Subsurface Soils Contaminated with Creosote
and Groundwater Contaminated with Arsenic (continued)
AltuD I
-------
Table 8-6 Summary Carperison of Alternatives:
Groundwater and Subsurface Soils Contaminated with Creosote
and Grounduater Contaminated with Arsenic (continued)
No Action
Groundwater Extraction, Biological
Treatment of Organics, Chemical Treatment
of Inorganics
Groundwater Extraction, UV/Carbon
Treatment of Organics, Chemical Treatment
of Inorganics
7. Cost
Capital: * 0
Annual OCM: » 9,800
Closure: * 0
Present Worth: $ 132,400
Capital: * A,315,800
Annual OM: * 1,163,900
Closure: $ 0
Present Worth: $17,419,000
Capital: $ 4,018,900
Annual O&M: $ 1.328.900
Closure: $ 0
Present Worth: $19,587,600
8. Community Acceptance
09
I
Not acceptable.
9. State Acceptance
Not acceptable.
Acceptable
Groundwater pump and treatment concept is
acceptable to the State.
Acceptable
Groundwater pump and treatment concept is
acceptable to the State.
Mi*cx> a 6/p t
-------
; TABLE 8-7
SUMMARY COMPARISON OF ALTERNATIVES:
SURFACE WATER CONTROL
No Action
Treatment and or
Isolation of Contaminated
Soils
Collection, Storage, and
Treatment of Contaminated
Runoff
1. Protection of Human Health and The Environment
Existing controls would
be effective in prevent-
ing some releases. Po-
tential for significant
releases would still
exist impacting aquatic
life. No Action would
not be protective.
09
i
M
Ul
Compliance with ARARs
No Action would not
completely comply with
ARARs for surface water
discharge or protection.
Removal, treatment, fix-
ation and/or capping of
contaminated soil could
greatly minimize or pre-
vent future surface water
contamination. Soil re-
medial alternatives would
provide protection of
surface water resources.
Soil remedial
alternatives would comply
with surface water ARARs.
Reduction in Toxicitv. Mobility, or Volume
Interim measures would
prevent some mobility and
reduce some volume.
Potential for releases
would still occur.
All soil remedial
alternatives would result
in significant reductions
in toxicity, mobility,
and volume.
Collection, storage, and
treatment would address
runoff problems, but not
soil source problems.
This alternative would
not prevent releases of
wood treatment chemicals
during intense precipita-
tion events. This would
be an interim measure.
Collection and treatment
could be performed to
comply with ARARs.
Collection and treatment
would reduce volume and
mobility of contaminants
in surface water. The
alternative would not
address source mobility.
BAXROD.8-7/P-1
-------
TABLE 8-7
SUMMARY COMPARISON OF ALTERNATIVES:
SURFACE WATER CONTROL (cont.)
No Action
Treatment and or
Isolation of Contaminated
Soils
Collection, Storage, and
Treatment of Contaminated
Runoff
4. Short-term Effectiveness
Intermim measures would
be only partitially
effective in protecting
human health and the
environment.
All soil remedial
alternatives could be
implemented to be
protective of surface
waters.
Collection and treatment
could be implemented to
be protective of surface
waters. Potential for
releases would still
remain.
09
i 5.
»-
0V
Long-term Effectiveness
Interim measures would
not provide long-term
protectiveness because
source soils would not be
addressed.
All soil remedial
alternatives would
provide long-term
effectiveness.
Leachability of arsenic
from fixed soil would be
a long-term concern.
Long-term monitoring
would be required for a
soil fixation
alternative.
This alterntative would
not provide long-term
effectiveness unless
source soils are
remediated. Potential
for release would remain.
6. Implementabilitv
No Action is
implementable.
All soil remedial
alternatives are
implementable
Collection and treatment
of runoff is
implementable.
3AXRO
"-7/P-2
-------
TABLE 8-7
SUMMARY COMPARISON OF ALTERNATIVES:
SURFACE WATER CONTROL (cont.)
No Action
Treatment and or
Isolation of Contaminated
Soils
Collection, Storage, and
Treatment of Contaminated
Runoff
7. Cost
Capital: $ o
Remedial O&M: $ 0
Post O&M: $ 9,800
Present Worth: $ 132,400
See Soil Remedial
Alternatives for Costs
Capital: $ 966,600
Remedial O&M: $ 59,700
Post O&M: $ 0
Present Worth: $1,447,300
8. Community Acceptance
Not Acceptable
Acceptable
Acceptable
9. State Acceptance
Not Acceptable
See discussion under soil
alternatives.
Acceptable only as an
interim measure.
BAXROD.8-7/p-3
-------
necessity of a sediment remedy. Fish have returned to the
affected stream segment since the November 1988 release of
creosote into the stream. The flushing action of spring stream
flows may have been effective in scouring the creosote and
contaminated sediments from the affected segment of the stream.
EPA will work with the California Department of Fish and Game and
the North Coast Regional Water Quality Control Board in the
development of studies necessary to evaluate restoration of the
Creek and any future remedial action.
Sediments within a short segment of the site discharge drainage
adjacent to the Roseburg power plant contain elevated arsenic.
These sediments will be excavated with a backhoe and handled in
the same manner as contaminated soils.
8.5 REMEDY SELECTION RATIONALE
A comparison of alternatives by the nine Selection Criteria and
rationale for selection of the site remedies are discussed in
this section. The criteria used in selecting each remedy are
summarized in Table 8-8.
8.5.1 SURFACE SOILS CONTAMINATED WITH INORGANICS ONLY
Alternatives Assessed
o No Action (No Action)
o Excavation and Off-site Disposal (Off-site Disposal)
o Excavation, Fixation, and On-Site Disposal (Fixation)
o Capping (Capping)
Criteria Assessment
Overall Protection of Human Health and the Environment. No
Action would not be protective of human health or the
environment; continued releases of wood treatment chemicals into
the environment would occur. Capping would be protective of
surface water and prevent direct contact and inhalation exposure.
Capping would be partially protective of groundwater, with
protectiveness limited by the high groundwater conditions at the
site. Off-site Disposal and Fixation would be equally protective
of human health and the environment.
Compliance with ARARs. No Action would not comply with Federal
and State ARARs. Capping of soils would not address groundwater
protection ARARs. Off-site Disposal and Fixation could be
implemented to comply with ARARs.
Reduction in Toxicity. Mobility, or Volume fTMV). No Action
would not achieve a TMV reduction. Capping would reduce surface
mobility, but not groundwater mobility. Off-site Disposal and
BAXROD.8 8-18
-------
TABLE 8-8
REMEDY SELECTION SUMMARY
Alternative
Selection Assessment
Surface Soils Contaminated with Inorganics Only
No Action
Excavation and
Off-site Disposal
Excavation,
Fixation and On-
Site Disposal
Capping
Not protective
Does not comply with ARARs
No TMV reduction
Not acceptable to community or State
Protective
Complies with ARARs
Reduces mobility
Not cost effective
Highest cost
Acceptable to community, State would prefer
on-site treatment
Protective
Complies with ARARs
Reduces mobility
As Effective as Off-Site Disposal
Least cost
Acceptable to community, preferred by State
Not protective of groundwater
Does not comply with groundwater ARARs
No long-term effectiveness
Higher cost than Fixation
Not acceptable to community or State
Near Surface Soils Contaminated with Oroanics Only
No Action
Excavation and
Off-site Disposal
Not protective
Does not comply with ARARs .
No TMV reduction
Not effective
Not acceptable to community or State
Protective
Complies with ARARs
No TMV reduction
Not cost effective
Acceptable to community
State would prefer on-site treatment
BAXROD.8-8
8-19
-------
TABLE 8-8
REMEDY SELECTION SUMMARY (cont.)
Alternative
Selection Assessment
Excavation,
Bioremediation,
and On-site
Disposal
Excavation and
Off-site
Incineration
Protective
Complies with ARARs
Significant TMV reduction
Cost effective
Acceptable to community and State
Protective
Complies with ARARs
Significant TMV reduction
Highest cost
Acceptable to community and State
Surface Soils Contaminated with Inorganics and Oraanics
No Action
Excavation and
Off-site Disposal
Excavation,
Bioremediation,
and Onsite
Disposal
Excavation and
Off-site
Incineration and
Disposal
Capping
Not protective
Does not comply with ARARs
No TMV reduction
Not acceptable to community or State
Protective
Complies with ARARs
No significant TMV reduction
Not cost effective
Acceptable to community, State would prefer
alternative that treats waste at site.
Protective
Complies with ARARs
Significant TMV reduction
Cost effective
Acceptable to community and State
Protective
Complies with ARARs
Significant TMV reduction
Potential capacity problems
Highest cost
Acceptable to community and State
Not protective
Does not comply with ARARs
No TMV reduction
Not cost effective
Not acceptable to community or State
BAXROD.8-8
8-20
-------
TABLE 8-8
REMEDY SELECTION SUMMARY (cont.)
Alternative
Selection Assessment
Groundwater and Subsurface Soils Contaminated with Creosote and
Groundwater Contaminated with Inorganics
No Action
Groundwater
Extraction,
Biological
Treatment,
Chemical
Treatment
Groundwater
Extraction,
UV/GAC Treatment,
Chemical
Treatment
Not protective
Does not comply with ARARs
No TMV reduction
Not effective
Not acceptable to community or State
Protective
Complies with ARARs
Significant TMV reduction
Cost effective
Acceptable to community and State
Protective
Complies with ARARs
Significant TMV reduction
Higher cost
Acceptable to community and State
BAXROD.8-8
8-21
-------
Fixation would reduce mobility through treatment and containment.
Neither alternative would reduce toxicity or volume.
Short-term Effectiveness. All alternatives could be implemented
to be protective of workers and the community during remedial
action. Transportation accidents resulting in spills of
contaminated materials would be a concern for the Off-site
Disposal alternative.
Long-term Effectiveness and Permanence. No action would not
offer any long-term effectiveness. Capping could remain
effective for preventing surface exposure as long as the cap was
maintained. Capping would not provide long-term protection of
groundwater. Off-site Disposal would transfer the long-term risk
to the receiving landfill. Effectiveness would depend on the
long-term viability of that facility. Long-term effectiveness
for Fixation would depend on the long-term maintenance and
monitoring of the fixed soil mass, and liner system used to
control leachate. Fixation would not preclude a subsequent
treatment or remedy should such become necessary.
Implementabilitv. There are no significant constraints with the
exception of health protection ARAR considerations for No Action
and Capping that would preclude implementation of the
alternatives. Off-site Disposal could be affected by the
treatment and disposal capacity of the receiving facilities.
Costs. For the action alternatives, Fixation would be the least
expensive alternative at $4.7 million. Capping would cost $6.2
million, while Off-site Disposal would cost $12.8 million.
Community Acceptance. No Action and Capping would not be
acceptable to the community. The Off-site Disposal and Fixation
alternatives appear to be acceptable.
State Acceptance. No Action and Capping would not be acceptable
to the State. The State would prefer a remedy that would treat
the waste at the site making Fixation the most acceptable
alternative.
Remedy Selection Rationale
EPA has selected Excavation, Fixation, and On-Site Disposal as
the remedy for soils contaminated with inorganics only. Although
the remedy is equally protective and effective as Off-site
Disposal, it is less costly and more acceptable to the State.
BAXROD.8 8-22
-------
8.5.2 NEAR SURFACE SOILS CONTAMINATED WITH ORGANICS ONLY
Alternatives Assessed
o No Action (No Action)
o Excavation and Off-Site Disposal (Off-site Disposal)
o Excavation, Bioremediation, and On-Site Disposal
(Bioremediation)
o Excavation and Off-Site Incineration (Incineration)
Criteria Assessment
Overall Protection of Human Health and the Environment. The No
Action alternative would not be protective of groundwater. Off-
site Disposal, Bioremediation, and Incineration could be
implemented to be protective of human health and the environment.
Compliance with ARARs. No Action would not comply with ARARs.
The remaining alternatives could be implemented to comply with
ARARs.
Reduction in Toxicitv. Mobility, or Volume (TMV). No Action
would not result in TMV reduction. TMV reduction for Off-Site
Disposal would depend on treatment, if any, at the facility
receiving the waste. Significant reduction in TMV would be
achieved through the Bioremediation and Incineration
alternatives.
Short-term Effectiveness. All action alternatives could be
implemented to be protective of workers and the community during
implementation.
Long-term Effectiveness and Permanence. No Action would not
achieve any long-term effectiveness. Long-term effectiveness of
Off-Site Disposal would be dependent on the integrity and
treatment, if any, of the disposal facility. Bioremediation and
Incineration would achieve significant long-term effectiveness
through destruction of contaminants.
Implementabi1ity. All action alternatives are implementable.
Incinerator capacity my affect the timing of the Incineration
alternative.
Cost. Bioremediation would be the least expensive of the action
alternatives at $7.4 million. Off-site Disposal is estimated at
$11.2 million and Incineration would be the most expensive
alternative at $39.2 million.
Community Acceptance. No Action would not be acceptable to the
community. All action alternatives would be acceptable.
State Acceptance. No Action would not be acceptable to the
State. All action alternatives would be acceptable, but the
BAXROD.8 8-23
-------
State would prefer an alternative that treated the waste on site
and not transfer it to another site.
Remedy Selection Rationale
All of the action alternatives would be protective, effective,
and implementable. Bioremediation and Incineration offer greater
effectiveness and permanence through a significant reduction in
TMV. Implementability of Incineration could be hampered by
available incineration capacity. Bioremediation would be the
least costly action alternative at $7.4 million making it the
cost-effective alternative. Off-site Disposal would cost $11.2
million while Incineration would cost $39.2 million.
Bioremediation would also be acceptable to the community and
State.
8.5.3 SURFACE SOILS CONTAMINATED WITH INORGANICS AND ORGANICS
Alternatives Assessed
o No Action (No Action)
o Excavation and Off-site Disposal (Off-site Disposal)
o Excavation, Bioremediation, Fixation, and On-site Disposal
(Bioremediation/Fixation)
o Excavation and Off-Site Incineration and Disposal
(Incineration)
o Capping
Criteria Assessment
Overall Protection of Human Health and the Environment. No
Action would not be protective. Off-site Disposal would transfer
the risk to another facility. Degree of protectiveness would be
dependent on treatment (if any) and integrity of the disposal
facility. Bioremediation/Fixation would destroy the organics and
contain the inorganics providing protectiveness at the site.
Incineration would destroy the organics and transfer the risk
related to the inorganics to another facility. Capping would be
protective of surface water and direct contact risk but would not
be protective of groundwater.
Compliance with ARARs. No Action would not comply with ARARs.
Off-site Disposal, Bioremediation/Fixation, and Incineration
could be implemented to address ARARs. Capping would not address
groundwater protection ARARs.
Reduction in Toxicity. Mobility or Volume (TMV). No Action would
not result in any TMV reduction. Off-site Disposal would reduce
mobility at the site, but depending on treatment, would not
reduce toxicity nor volume. Bioremediation/Fixation and
Incineration would reduce volume of soil contaminated with
organics. Fixation would reduce mobility of inorganics. Volume
of soil contaminated with inorganics would remain the same for
BAXROD.8 8-24
-------
all alternatives. Capping would reduce surface mobility, but not
groundwater mobility. Capping would not reduce volume of soils
contaminated with organics.
Short-term Effectiveness. The action alternatives could be
implemented to be protective of workers and the community during
remedial action.
Long-term Effectiveness and Permanence. No Action would offer no
long-term effectiveness. Off-site Disposal would transfer the
risks to another facility where long-term monitoring would be
necessary. Bioremediation/Fixation would be effective in
reducing long-term risks due to the organic component. Long-term
management of the fixed soils would be necessary. Incineration
would destroy the organic fraction but the risks afforded by the
inorganics would be transferred to another facility. Long-term
maintenance of the cap would be necessary to provide surface
protection. Groundwater would continue to be affected in the
long-term under the Capping alternative.
Implementability. All of the action alternatives appear to be
implementable. Capacities of the off-site landfill to receive
the wastes or the off-site incinerator to treat the waste could
affect implementation schedule. Groundwater protection ARARs
could prevent implementation of the Capping alternative.
Cost. Capping would be the least expensive alternative at $3.6
million. Bioremediation/Fixation would be the cost effective
alternative at $8.3 million because it offers significant TMV
reduction and protectiveness when compared to Capping. Off-site
Disposal would cost $10.9 million while Incineration is estimated
at $32.2 million.
Community Acceptance. No Action and Capping would not be
acceptable to the community. All of the action alternatives
would be acceptable to the community.
State Acceptance. No Action and Capping would not be acceptable
to the State. The State would prefer a remedy that treated the
contaminated soil at the site and did not transfer it to another
facility.
Remedy Selection Rationale
Excavation, Bioremediation, Fixation and On-Site Disposal has
been selected as the remedy for soils contaminated with
inorganics and organics because it reduces the organic
contamination, treats inorganic contamination, reduces TMV, and
provides protectiveness in a cost-effective manner.
BAXROD.8 8-25
-------
8.5.4 GROUNDWATER AND SUBSURFACE SOILS CONTAMINATED WITH
CREOSOTE AND GROUNDWATER CONTAMINATED WITH ARSENIC
Alternatives Assessed
o No Action (No Action)
o Groundwater Extraction, Biological Treatment of Organics,
Chemical Treatment of Inorganics (Biological Treatment)
o Groundwater Extraction, UV or Carbon Treatment of Organics,
Chemical Treatment of Inorganics (UV or GAC Treatment)
Criteria Assessment
Overall Protection of Human Health and the Environment. No
Action would not be protective of human health or the
environment. Biological Treatment could be equally protective at
ultraviolet light (UV) or granulated activated carbon (GAC) in
treatment of organics, but careful monitoring and operations
would be necessary to prevent system upsets that would reduce
organics destruction efficiency. The use of Biological Treatment
coupled with UV or GAC polishing may be necessary to ensure
protectiveness. Careful monitoring and maintenance of the UV or
GAC systems would also be necessary.
Compliance with ARARs. No Action would not comply with
groundwater protection ARARs. Biological Treatment and UV or GAC
treatment could be implemented to comply with ARARs.
Reduction in Toxicity. Mobility, or Volume. The No Action
Alternative would not result in a reduction in TMV. Biological
Treatment and UV Treatment would destroy organics and chemical
treatment would significantly reduce the volume of media
contaminated with inorganics. GAC Treatment would reduce th
volume of contaminated media, but would not destroy organics
unless the GAC was regenerated through thermal destruction of the
organics.
Short-term Effectiveness. Biological Treatment and UV or GAC
Treatment could be implemented to be protective of workers and
the community during implementation.
Lona-Term Effectiveness. Biological Treatment and UV or GAC
Treatment would provide significant long-term effectiveness
through extraction, removal, destruction of contaminants and
long-term containment of residuals.
Implementability. Both action alternatives are implementable.
ARAR considerations would preclude implementation of the No
Action alternative.
BAXROD.8 8-26
-------
Cost. The Biological Treatment alternative would cost $17.4
million to implement. The UV or GAC Treatment alternative would
cost $19.6 million to implement.
Community Acceptance. No Action would not be acceptable to the
community. Either action alternative appear acceptable to the
community.
State Acceptance. No Action would not be acceptable to the
State. Either action alternative would be acceptable to the
State if discharge limitations met ARARs and no direct discharge
to surface waters were allowed.
Remedy Selection Rationale
EPA has selected Groundwater Extraction, Biological Treatment of
Organics, Chemical Treatment of Inorganics as the remedy for
groundwater because existing data show it to be effective in
reducing contaminant levels to health standards and it is less
costly than the UV or GAC alternatives. EPA does recognize,
however, the Biological Treatment alternative may have to be
combined with a UV/Ozone or GAC polishing treatment to provide
additional assurance of effectiveness and protectiveness.
8.5.5 SURFACE WATERS
The surface soil remedies identified above will prevent further
releases of wood treatment chemicals from the site. The
reconstruction of the site following contaminated soil removal
will include surface water control and containment structures to
prevent releases during subsequent operation of the facility.
Additional on-site measures are not warranted. EPA is proposing
to excavate and remove from site drainages all sediment with
detectable levels of wood treatment chemicals. No remedy for
Beaughton Creek is proposed until additional data on the stream
indicate the necessity for such. If contamination is detected in
Beaughton Creek above levels deemed acceptable by the state and
EPA, remedial measures will be taken.
BAXRODF.8 8-27
-------
9.0 SELECTED REMEDIES
The following text presents the selected remedies for soils
contaminated with inorganics only, organics only, and with both
organics and inorganics; groundwater; and surface water. All
costs presented in this ROD are present worth costs. All
remedies will be performed to address either a 1 x 10"5 or
greater risk level, or background (non-detect) levels where
achievable for organics and inorganics in water. Remedies for
organics and inorganics in soils will address a 1 x 10"5 or
greater risk, level non-detection, health-based or other
regulatory standards.
9.1 REMEDY FOR SOILS CONTAMINATED WITH INORGANICS
REMEDY DESCRIPTION
For soils contaminated with inorganics only, EPA proposes to
excavate the soil, fix it with a cement-based compound, and
maintain the mixture onsite to prevent future exposure or
movement. In order for this remedy to be implemented, arsenic
leachate concentrations must be reduced below the 40 CFR 268 TCLP
level of 5.0 ppm. Fixed soil exceeding CCR Title 22 TTLC/STLC
criteria will be placed in lined cells. Fixed soil meeting
TTLC/STLC criteria will be placed back onto the site, possibly
forming the structural and operational base for wood treatment
operations.
Excavation would be performed using conventional earth moving
equipment. The base surface of the site would be graded and
prepared to accept the fixed soil mixture. If the stabilized
soil mass is intended to provide a base for wood treatment
operations, the design could include structural and stability
considerations. Included in the design would be surface runoff
control considerations. Because the fixed soils would contain
wood treatment chemicals, collection of leachate generated from
the fixed soils and long-term monitoring will be required.
Proper handling and disposal of leachate will be necessary. A
liner below the fixed soil will be required for soils containing
arsenic greater than 500 ppm, chromium greater than 500 ppm,
copper greater than 2,500 and zinc greater than 5,000 (California
Title 22 TTLC criteria). A liner also will be required if
leachable arsenic and chromium exceeds 5.0 ppm, copper 2,500 ppm,
and zinc 5,000 ppm. Deed restrictions will be required for all
areas where treated waste has been deposited. Long-term
groundwater and surface water monitoring would be required to
demonstrate protectiveness of the alternative.
The inorganic soils cleanup will reduce arsenic to its
background levels (i.e., 8 ppm for arsenic). Because the
contaminants are commingled, this remedy will also remove the low
level threat contaminants to below their proposed treatment
BAXRODF.9 9-1
-------
standards. For those isolated areas where chromium, copper, or
zinc are elevated in the absence of elevated arsenic, these
contaminants will be excavated to the California Title 22 TTLC
standards (Tables 4-1 and 4-3).
It is estimated that 18,750 cubic yards of soils contaminated
with inorganics will be fixed with this remedy. It is estimated
that remedial objectives will be achieved in approximately 9
months, if done continuously. Capital costs have been estimated
at $4,525,800. Operating costs, including groundwater sampling,
surface water monitoring, yearly inspection and maintenance, and
surface repair, have been estimated at $223,000. Total costs are
approximately $4,748,800.
REMEDY SELECTION RATIONALE
The selected remedy provides the best balance of the five NCP
balancing criteria (long-term effectiveness and permanence;
reduction in toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; and cost). This
alternative uses permanent solutions and an alternative
technology or resource recovery to the maximum extent
practicable. Cost for the technology is lower than off-site
disposal and is comparable to capping of the soils in place. The
alternative also provides the best long-term and short-term
effectiveness; and permanently and significantly reduces the
toxicity, mobility, or volume of hazardous substances through
treatment; and is readily implementable at the site. It is
protective of human health and the environment, complies with
federal and State ARARs, and is cost-effective.
The goals of the remedy for soils contaminated with inorganics
are to prevent surface water runoff of contaminated surface
soils, to prevent air emissions of contaminated dusts, and to
prevent contaminants from leaching into the groundwater, which is
a drinking water aquifer at this site. Based on information
obtained during the remedial investigation and on a careful
analysis of all remedial alternatives, EPA and the State of
California believe that the selected remedy will achieve these
goals through proper implementation and monitoring of the action.
The selected soil remedy will be coupled with groundwater
extraction and treatment to remedy groundwater already impacted
by the contaminated soils. The removal and treatment of
contaminated soils may significantly reduce the time required for
extraction and treatment of groundwater contaminated with
inorganics. The point of compliance will be all site surface
soils within the approximate 0 to 24 inch interval containing
inorganic contamination above the clean-up standards.
Periodic groundwater, surface water runoff, and air quality
monitoring and sampling of leachate will be required to determine
the effectiveness of this remedy and to verify achievement of
BAXRODF.9 9-2
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cleanup levels. Long-term operation and maintenance (O&M)
activities for the treated soil mass, institutional and
engineering controls, and their costs will also be required.
Such requirements and a specific monitoring program will be
defined more precisely during the RD/RA phase.
ARARs
The selected remedy will comply with all federal and State ARARs
as listed in Tables 8-1 and 8-2, and the treatment standards
stated in Table 4-1. Health-based ARARs pertaining to soil
contaminated with inorganics are not available for the site. The
soil contamination will therefore be reduced to health-based
standards discussed in Section 4.0 that no longer pose a threat
to surface water, groundwater, or air.
Soil will be excavated to background levels for arsenic, and to
California Title 22 TTLC levels for chromium, copper and zinc.
The soil will be treated to reduce leachability of arsenic and
chromium to 5 ppm (leachate), which represents the TCLP and STLC
limits for these metals. Copper and zinc leachability will be
reduced to 25 ppm and 250 ppm, respectively, which represent the
State Title 22 limits for these metals.
Treated soils will be placed as necessary in lined-treatment
cells designed to meet RCRA land disposal requirements. Assuming
that fixation of soil reduces arsenic leachate concentrations to
below the TCLP standard of 5.0 ppm, the land disposal
restrictions of Subtitle C of RCRA are not an ARAR for this
remedy. The treatment technology used will reduce leachability
of contaminants to below the land disposal requirements. Once
treated, the soil will no longer be a RCRA-characteristic waste
as long as leachability of the fixed soil meets the treatment
standards.
9.2 REMEDY FOR SOILS CONTAMINATED WITH ORGANICS
REMEDY DESCRIPTION
For soils contaminated with organics only, EPA proposes that the
soil be excavated and placed into lined land-treatment cells.
The liner would be necessary to prevent contaminated leachate
from moving into surrounding soil and the groundwater below. The
liner would be designed to collect and monitor leachate
concentrations; the collected leachate would either be placed
back on the land-treatment unit or treated in the groundwater
treatment system.
Soil would be treated using natural microbial populations, the
effectiveness of which would be enhanced through the mixing of
nutrients and fertilizers into the soil. The soil would be
regularly tilled to mix the fertilizers, and to aerate and expose
BAXRODF.9 9-3
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the soil to sunlight. The soil would be irrigated regularly to
maintain a proper moisture level.
The soil within the treatment unit would be sampled at specific
intervals to monitor the rate of biological degradation and to
verify the achievement of the treatment standards through
leachability tests for contaminants of concern, primarily PAHs.
This remedy will treat all principal and low level threat
contaminants to their respective treatment standards. Once the
treatment standard is achieved and the soil considered treated,
another layer of soil would be placed over the treated soil. The
next layer would be treated as described above. When the soil
layers reach the approximate level of ground surface,
(approximately 8 feet of treated soil) the unit will be closed.
Closure will be accomplished by placing an elevated "soft" cover
of clean soil material over the treated soil. A vegetation cover
will be established over the cover soils. Long-term leachate
collection and groundwater monitoring would be included as part
of closure requirements.
It is estimated that 12,500 cubic yards of creosote contaminated
soils will be excavated and treated with this remedy. The point
of compliance will be all site soils between 2 feet and the depth
below the surface where groundwater interferes with excavation.
This depth could vary between 5 feet and 12 feet depending on the
time of year excavation takes place. Below the groundwater
table, creosote above the excavation standards will be removed
through the groundwater extraction system, or treated in situ if
studies show this feasibility. It is estimated that the
treatment standards will be achieved in 10 years. Capital costs
have been estimated at $5,487,300. Operating costs, including
air monitoring, soil sampling, groundwater sampling, surface
water monitoring, yearly inspection and repairs, and
bioremediation (i.e., labor and materials), have been
approximated at $1,883,500. Total costs are approximately
$7,370,800.
REMEDY SELECTION RATIONALE
Bioremediation of creosote contaminated soils is the selected
remedy for this site. The selected remedy provides the best
balance of tradeoffs with respect to the five balancing criteria.
This alternative uses permanent solutions and alternative
technology or resource recovery technology to the maximum extent
practicable. The alternative is the least expensive of the
alternatives for soils contaminated only with organics, and is at
least equal to the other alternatives in terms of short- and
long-term effectiveness. The alternative employs treatment as
the principal element that will significantly reduce toxicity,
mobility, or volume of contaminated media, and is readily
implementable. It is protective of human health and the
i
BAXRODF.9 9-4
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environment, complies with federal and State ARARs, and is-cost-
effective.
The goal of this remedial alternative is to remove all soil
contaminated with creosote to protect groundwater, surface water,
and human health, and to treat the soil biologically to destroy
the toxic components of creosote. Residuals will be contained in
a lined cell which will afford long-term protectiveness. Based
on information obtained during the remedial investigation and on
a careful analysis of all remedial alternatives, EPA and the
State of California believe that the selected remedy will achieve
this goal. The selected remedy will be coupled with groundwater
extraction and treatment to address the effects of the current
contamination on the local aquifer. The groundwater remedy is
discussed in Section 9.4.
Residuals will remain in lined cells which will have leachate
collection systems, lysimeters, and monitoring wells to identify
leachate production and potential leaks from the cells.
Maintenance of the cells will be necessary as long as
contaminated leachate is detected. The leachate collected will
be handled, treated or disposed of properly. Lysinister and
groundwater monitoring of the cells will also be performed as
long as contaminated leachate is detected in the cells. All
maintenance and monitoring requirements will be identified more
precisely during the RO/RA phase.
ARARs
As noted above, this alternative would comply with all federal
and State applicable or relevant and appropriate requirements as
listed in Table 8-1.
The treatment standards selected for the soils contaminated with
organics are presented in Table 4-1. These treatment standards
were selected by the process below. There are no promulgated
treatment standards for soils contaminated with creosote
compounds. Soil will be excavated to a 0.5 ppm carcinogenic PAH
soil level which represents the 1 x 10"6 risk level and also the
analytical detection limit. EPA has determined that excavation
to this level is readily achievable. EPA is proposing to treat
the soil to reduce leachability of creosote compounds to a 5 ppb
leachate concentration (detection limit) for carcinogenic PAHs
and 0.150 ppm for non-carcinogenic PAHs. This level is based on
guidance provided in 40 CFR 268 Subpart B. The land disposal
restrictions of Subtitle C of the RCRA will provide guidance for
implementation of this remedy. Soils will be treated to reduce
total and leachable creosote concentrations to levels addressed
in 40 CFR 268, although these levels are not specifically ARARs
for the source of contamination. Once the soils are treated and
ieachate controlled, all substantive requirements of RCRA will be
addressed.
BAXRODF.9 9-5
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9 . 3 REMEDY FOR SQTTfS CONTAMINATED WITH BOTH INORGANICS AND
ORGANICS
REMEDY DESCRIPTION
This proposed alternative would involve the excavation of
contaminated soil and biological treatment to reduce or destroy
organic contaminants (as described in the section 'Remedy for
Soils Contaminated with Organics1). The treated soil would then
be fixed with a stabilization agent to control mobility of the
inorganics and residual organics (as described in the section
Remedy for Soils Contaminated with Organics'). The treated and
fixed soil would then be placed back into lined cells in a
manner protective of human health and the environment.
Treatment to reduce organic levels would be required because
pilot studies indicate that the organics cannot be immobilized in
the fixed mass when they exist in high concentrations. Residual
dioxin levels are expected to be fixed and immobilized in the
stabilized soil.
4
The organic and inorganic soils cleanup will reduce contaminant
levels to those stated in Section 9.1 - Remedy for Soils
Contaminated with Organics and Section 9.2 - Remedy for Soils
Contaminated with Inorganics.
An estimated 9,375 cubic yards of organic and inorganic soils
will be treated with this remedy. It is estimated that remedial
objectives will be achieved in approximately 10 years. Capital
costs have been approximated at $6,648,500. Operating costs,
including air monitoring, soil sampling, groundwater sampling,
surface water monitoring, yearly inspection and repairs, and
bioremediation (i.e., labor and materials), have been estimated
at $1,642,000. Total costs are approximately $8,290,500.
REMEDY
Biological treatment of soils to reduce creosote and
pentachlorophenol contamination followed by fixation of the
residuals to reduce leachability of inorganic and remaining
organic contaminants is the selected remedy because it provides
the best balance of tradeoffs with respect to the five balancing
criteria. This alternative will treat all inorganic and organic
principal and low level threat contaminants to their respective
treatment standards. This alternative uses permanent solutions
and alternative technology or resource recovery technology to the
maximum extent practicable. Although the alternative is more
costly than capping soils in place, it is significantly less
costly than other treatment alternatives. The alternative
provides the best long-term and short-term effectiveness,
permanently and significantly reduces the toxicity, mobility, or
volume of the hazardous substances through treatment, and can be
BAXRODF.9 9-6
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implemented at the site. The remedy employs treatment as a
principal element that significantly and permanently reduces the
toxicity/ mobility, or volume of hazardous substances. It is
protective of human health and the environment, complies with
federal and State ARARs, and is cost-effective. The costs of
this alternative are proportional to its overall effectiveness.
The goal of this remedial action is to treat and contain
contaminated soils contributing to surface water, groundwater,
and air contamination, and to protect human health and the
aquatic environment. The aquifer at the site is a potential
drinking water source and surface water is used by cattle and
wildlife, and supports a viable sport fishery. Based on
information obtained during the remedial investigation and on
careful analysis of all remedial alternatives, EPA and the State
of California believe that the selected remedy will achieve this
goal. Point of compliance for the remedy will be all surface and
near surface soils with inorganic and organic contamination above
the clean-up standards. Maintenance and monitoring at the
disposal cells including leachate collection, and lysimeter and
groundwater monitoring will be required to ensure protectiveness
of the remedy.
/
ARARs
As noted above, this alternative would comply with all federal
and State applicable or relevant and appropriate requirements
(ARARs) as listed in Tables 8-1.
Health-based ARARs specific to soils at the site exist for
arsenic (leachable), pentachlorophenol (leachable) and dioxins
(leachable and total). Health-based ARARs do not exist for PAHs,
but guidance presented in 40 CFR 268 and the results of the risk
assessment defining a 1 x 10"6 risk level were used for
carcinogenic PAHs. The treatment standards for the soils remedy
are presented in Table 4-1. Soils will be excavated to
background levels for arsenic, and to 0.5 ppm for carcinogenic
PAHs, 17 ppm for pentachlorophenol, and 1 ppb for dioxins. EPA
believes that these levels are achievable using standard
excavation technologies. Soils contaminated with these organics
will be biologically treated to reduce leachate concentrations of
carcinogenic PAHs to 5 ppb and pentachlorophenol to 1.7 ppm. The
carcinogenic PAH level is based on practical analytical detection
limits. The pentachlorophenol level is based on the CCR Title 22
STLC standard. EPA believes that these levels are achievable
using biological treatment. The biologically treated soil will
then be fixed to reduce leachability of inorganics, residual
organics, and dioxins. The treatment level for arsenic is 5 ppm
and 1 ppb for dioxins in leachate, which represent the TCLP
levels for these contaminants. Leachate levels for PAHs and
pentachlorophenol for fixed soil will remain at 5 ppb and 1.7
ppm, respectively.
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The land disposal restrictions of subtitle C of RCRA are not an
ARAR for this remedy. All contaminants will be treated to levels
below that governed by these restriction. Once treated, the soil
will no longer be a hazardous waste and thus not subject to RCRA
regulations. The fixed soil mass will contain hazardous
substances and will be maintained and managed to remain
protective of human health and the environment.
9.4 REMEDY FOR CONTAMINATED GROUNDWATER
REMEDY DESCRIPTION
For contaminated groundwater, EPA proposes extraction, biological
treatment, chemical treatment, and discharge. Groundwater will
be treated to achieve EPA clean-up goals prior to reuse or
release from the site. EPA proposes to use a biological
treatment process which passes contaminated groundwater through
plastic discs covered with naturally occurring microorganisms.
The microorganisms use the organic contaminants for food and
energy, converting them to carbon dioxide and water.
Arsenic and other inorganic contaminants will be removed from the
extracted groundwater using a chemical precipitation process. By
adding lime to the extracted groundwater, a sludge is formed that
settles to the bottom of the treatment tank. Solids created by
the treatment processes are filtered and removed for proper
disposal. The solids will contain elevated arsenic and other
site chemicals and will be handled as a hazardous waste.
Both treatment processes may need to be coupled with a final
treatment step to reach clean-up standards. This could involve
the use of activated carbon or UV/ozone destruction to remove any
remaining organic compounds and activated alumina or ion exchange
to remove remaining arsenic.
Groundwater treated to health-based standards will be disposed of
through various means. The disposal options include discharge to
groundwater, use by industrial processes, use for irrigation,
release to subsurface drains or trenches, and disposal to
percolation/evaporation ponds. EPA is proposing to use the log-
deck sprinkler system and reinjection into the contaminated
aquifer as the primary disposal methods of treated groundwater.
Point of compliance for these disposal options will be effluent
as it leaves the treatment plant. During the winter months, EPA
will use percolation/evaporation ponds to dispose of effluent.
EPA will require specific proposal from the potentially
responsible parties (PRPs) before approving any disposal option.
EPA is not including in this ROD direct discharge to Beaughton
Creek as a disposal option. EPA will work closely with the RWQCB
and the PRPs in identifying treated water disposal options
agreeable to all parties affected by this decision.
BAXRODF.9 9-8
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This groundwater alternative will reduce contaminants to their
corresponding clean-up standards. Dioxins and furans will be
reduced to currently available detection limits (i.e., 25 ppq for
both) . The clean-up goals for dioxins and furans are 2 ppq, but
this level cannot be detected with today's analytical methods.
For benzene and carcinogenic PAHs, clean-up goals will be reached
that correspond to a one-in-one million excess cancer threat
(i.e., 1 ppb for benzene and 5 ppb for carcinogenic PAHs). For
arsenic, the clean-up standard of 5 ppb reflects the 1 x 10 "5
excess cancer threat. For non-carcinogenic PAHs, zinc, and
chromium, clean-up will achieve background levels of 8 ppb for
chromium, 90 ppb for zinc and 5 ppb for non-carcinogenic PAHs
(detection limit) . Point of compliance for the remedy will be
the entire aquifer adjacent to and below the site. Definition of
plume extent and compliance with the groundwater standards will
be demonstrated through a network of monitoring wells and
piezometers. The remedy will treat all principal and low level
threat contaminants to their treatment standards.
An estimated 150,000 gallons of contaminated water will be
treated per day with this remedy. Remedial objectives will be
achieved in approximately 30 years. Capital costs have been
approximated at $4,315,800. Operating costs, including labor,
utilities, nutrients, inorganic chemicals, activated carbon, non-
exchange replacement, salt, analytical, sludge disposal,
supplies, and replacement parts have been estimated at
$13,103,200. Total costs are approximately $17,419,000.
At the time of development of this Record of Decision, the
existing pilot groundwater treatment plant had not been tested at
design capacity and the effectiveness of the facility, as
designed, in removal of organics, and inorganics had not been
demonstrated. EPA will allow the PRPs one year from the signing
of the Consent Decree to modify the facility and treatment scheme
to achieve the standards presented in Table 4-1. Specifics of
how the PRPs will be allowed to demonstrate performance of the
facility will be included in the Consent Decree.
REMEDY SELECTION
Groundwater extraction followed by treatment and release or reuse
of the extracted groundwater is the selected remedy for the site.
The selected remedy provides the best balance of the five
balancing criteria. This alternative uses permanent solutions
and alternative technologies to the maximum extent practicable.
As the groundwater extraction and treatment alternatives varied
only in the type of treatment to be employed, costs for all
action alternatives were approximately the same. The selected
remedy is more cost-effective with biological destruction of
contaminants, as the subsequent handling and treatment of
concentrated residuals (i.e., as would be necessary through
activated carbon treatment) is eliminated. This alternative
BAXRODF.9 9-9
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provides the best long-term and short-term effectiveness, .
permanently and significantly reduces the toxicity, mobility and
volume of hazardous substances through treatment, and can be
implemented at the site. The selected remedy employs treatment
as a principal element that significantly and permanently reduces
toxicity, mobility, or volume of the hazardous substances. It is
protective of public health and the environment, complies with
federal and State ARARs, and is cost-effective. The costs of
this alternative are proportional to its overall effectiveness.
The goal of this remedial alternative is to restore groundwater
to its beneficial uses, which is a potential drinking water
source for this site. Based on information obtained during the
remedial investigation and on a careful analysis of all remedial
alternatives, EPA and the State of California believe that the
selected remedy will achieve this goal. The selected remedy will
require contaminated soil removal and treatment to achieve this
goal in a timely manner. Due to the extent of subsurface
contamination, the selected remedy is expected to take at least
30 years to be accomplished. During this time, the system's
performance will be closely monitored on a regular basis and
adjusted as warranted by the performance data collected during
its operation.
Periodic groundwater monitoring will be required to determine the
effectiveness of the remedy and to verify achievement of the
clean-up standards. Long-term operation and maintenance (O&M)
activities, institutional and engineering controls, and their
costs will be required. Such requirements and a specific
monitoring program will be defined precisely as the Consent
Decree is developed.
ARARs
This alternative will comply with all Federal and State
applicable or relevant and appropriate requirements (ARARs) as
listed in Tables 8-1 and 8-2.
The groundwater remediation and treatment standards selected for
the groundwater remedy are presented in Table 4-1. These
standards were selected by the process described below. As per.
Section 300.430(e) of the NCP, Federal MCLGs, where promulgated,
were initially selected as the treatment standards. In the event
that the MCLG has been set at a level of zero, then the federal
MCLs, where promulgated, or the 1 x 10~5 to 1 x 10'6 risk range,
which ever were more restrictive, were selected. In the event
that a more stringent MCL has been promulgated by the State of
California, then the State MCL was selected as the treatment
standard. The selected remedy will achieve the treatment
standard in the entire aquifer below the site and in the effluent
discharged from the treatment unit if the effluent is used for
non-industrial purposes.
BAXRODF.9 9-10
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For arsenic, pentachlorophenol, benzene, and dioxins, the
treatment standard represents the 1 x 10"5 to 1 x 10'6 risk range
for these contaminants. For carcinogenic and non-carcinogenic
PAHs, the treatment standard represents practical analytical
detection limits. For chromium and zinc, the treatment standard
represents either background or the health based standards as
determined by the reference dose levels for each contaminant.
All of these contaminants were detected in groundwater at levels
exceeding their treatment standards.
The land disposal restrictions of Subtitle C of the RCRA are not
an ARAR for this remedy. The treatment technology used in the
selected remedy will treat contaminated groundwater to either
background or non-detectable levels. Once the groundwater is so
treated, it no longer contains hazardous waste and no longer is
subject to regulation under Subtitle C of RCRA.
9.5 REMEDY FOR SURFACE WATER
To prevent contamination of surface water, EPA proposes to treat
and/or isolate the contaminated soils as described in the three
contaminated soils remedies (i.e., inorganic, organic, and
combined inorganic and organic). These remedies will prevent or
greatly reduce contact between surface water and contaminated
soil, thereby preventing or minimizing surface water
contamination. Rationale and ARARs for the soils remedies are
discussed above.' EPA is not proposing a sediment remedy for the
perennial portions of Beaughton Creek or its tributaries until
further data and consultation with the California Department of
Fish and Game result in the need for further action.
9.6 CONCLUSION
All remedies identified in this Record of Decision will reduce
the residual risk for each contaminant in soil, sediment, and
groundwater at the site to the 1 x 10'5 to l x 10"6 risk range.
The greatest residual risk will relate to the background
concentration of arsenic in soil and groundwater which reflects a
1 x 10'5 risk.
/
The proposed remedies mentioned in the preceding sections may
need to be modified as a result of the remedial design and
construction process. The changes, in general, reflect
alterations made during the remedial design phase and will be
performed so that standards state in Table 4-1 can be met and
that the remedies will remain protective and effective.
BAXRODF.9 9-11
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10.0 STATUTORY DETERMINATION
The selected remedies are protective of human health and the
environment as required by Section 121 of CERCLA. Existing or
potential risks from exposure to soils, surface water, sediment
and groundwater will be eliminated, reduced, and controlled by
treating contamination, stabilizing contamination, and containing
contaminants. Remedial objectives will reduce excess cancer
risks to 10"6 when possible (if background levels of chemicals do
not exceed this risk level) , which is within the 10"* to 10"6 risk
range. Risks from non-carcinogens will be reduced to hazard
indices less than one. All principal and low level threat
contaminants will be addressed by the proposed remedies. During
the implementation of the remedies, engineering controls such as
dust control measures will be employed to ensure that no
unacceptable short-term risks or cross-media impacts occur.
The remedies selected will comply with ARARs. The remedies
selected will meet Safe Drinking Water Act MCLs and the
California DHS Applied Action Levels for drinking water.
The remedies for contaminated soil will comply with the RCRA Land
Disposal Restrictions (LDRs). Concentrations of contaminants
within leachate generated from the waste will comply with 40 CFR
268 requirements.
The remedy for groundwater will comply with the state well
installation regulations, water treatment facility siting and
operation regulations, and worker protection regulations.
The discharge of treated effluent will comply with ARARs and, to
the extent possible, TBCs.
During implementation of the remedies, the substantive
requirements of the Siskiyou County Air Pollution Control
District will be met.
The aforementioned protectiveness and compliance with
environmental requirements is achieved in a cost effective
manner. The alternatives chosen are the cost effective
approaches available to achieve the necessary degree of
protectiveness. Residual risk which will be related to
background levels will be 1 x 10"5.
The selected remedies use permanent solutions and alternative
technologies to the maximum extent possible, and satisfy the
i statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
The clean-up standards defined in this Record of Decision are
subject to re-evaluation with respect to effectiveness in
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protecting human health and the environment at the 5-year review
period.
10.1 fiOILS CONTAMINATED WITH INORGANIC^
The proposed remedy, fixation and on-site disposal, will be
protective through containment of the inorganics in the fixed
soil mass. This alternative will involve treatment to reduce
mobility. Toxicity and volume will not be reduced. Short-term
effectiveness will be maintained through strict environmental
controls. The alternative is implementable using standard
equipment and materials.
The "No Action" alternative would not be protective because
contaminants would continue to be released into surface water
runoff and in airborne dust.
Excavation and off-site disposal would be protective through
removal of contaminants. However, removal would not reduce the
overall toxicity, mobility or volume of contaminants.
Capping would be only partially protective of groundwater.
Mobility into groundwater would remain a concern.
10.2 SOILS CONTAMINATED WITH ORGANICS
The proposed remedy, excavation and on-site bioremediation, will
be protective and permanent through destruction of organics and
long-term containment of the residuals. Volume of contaminated
material will be decreased and mobility controlled through
containment in a lined cell. The alternative is implementable
using available equipment and materials and demonstrated
techniques. The alternative does not preclude mover.ent of
treated soils to an off-site disposal facility at a .ater time.
The "No Action" alternative would not be protective of human
health and the environment because the contaminants would
continue to be released from the site into the groundwater.
Excavation and off-site disposal would be protective of human
health and the environment through removal of contaminants.
However, removal would not reduce the overall toxicity, mobility,
or volume of contaminants.
Excavation and off-site incineration would be protective, would
reduce toxicity, mobility and volume, would be effective in the
short term and long term, and would be implementable. However,
the total cost of incineration is approximated at more than five
times the cost of bioremediation.
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10.3 SOILS CONTAMINATED WITH ORGANICS AND INORGANICS
The proposed remedy, excavation and on-site bioremediation
followed by fixation to contain inorganics and on-site disposal,
will be protective through biological destruction of organics and
long-term containment of the residuals. The volume, toxicity,
and mobility of organic contaminants will be reduced. The
mobility, but not the volume or toxicity, of inorganic
contaminants will be reduced. The alternative will be effective
and protective during the short term through the use of strict
environmental controls. The alternative is implementable using
available equipment and materials and demonstrated techniques.
The "No Action" alternative would not be protective because the
contaminants would continue to be released from the site into
surface water, groundwater, and in airborne dust.
Excavation and off-site disposal would be protective through
removal of contaminants. However, there would be no reduction in
toxicity, mobility, or volume.
Excavation and off-site incineration would be protective through
the nearly complete destruction of organics and the stabilization
of the inorganics in the ash. This alternative would reduce
organic toxicity, mobility, and volume. However, it would not
reduce inorganic toxicity or volume. This alternative would be
protective and effective in the short term through the use of
strict environmental controls. Furthermore, the total cost of
incineration is approximated at almost 4 times the cost of
bioremediation/fixation.
Capping would only be partially protective of groundwater.
Mobility into groundwater would remain a concern.
10.4 CONTAMINATED GROUNDWATER
The groundwater remedy, extraction followed by biological and
chemical treatment, will be a permanent solution because the
contaminants will be destroyed or removed from the groundwater.
The groundwater remedy is expected to take 30 years to achieve
treatment standards. Careful management of the process will be
necessary for it to be effective in the short term. The
alternative is implementable using readily available equipment
and materials.
The "No .Action" alternative would not be protective because
contaminants would continue to remain in the groundwater.
The "UV or Granulated Activated Carbon Treatment of Organics"
alternative offers the same risk reduction benefits as the
proposed remedy. Treatment with activated carbon has the
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disadvantage that the spent carbon containing the organics would
need to be regenerated or disposed of properly.
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11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
Surface soil clean-up standards for chromium, copper, zinc,
pentachlorophenol, and carcinogenic PAHs have been revised since
the issuance of the Proposed Plan. The revised clean-up
standards for chromium of 500 ppm, copper of 2,500, and zinc of
5,000 represent the California Title 22 TTLC waste designation
.levels for these elements. The revised standard for carcinogenic
PAHs of 0.5 ppm represents the 1 x 10"6 risk level for the
contaminants. The revised clean-up standard for
pentachlorophenol of 17 ppm reflects the California Title 22
hazardous waste designation level for the contaminant.
Leachate standards for copper, zinc, pentachlorophenol, and non-
carcinogenic PAHs were also modified since issuance of the
Proposed Plan. The leachate standards for copper of 25 ppm, zinc
of 250 ppm, and pentachlorophenol of 17 ppm reflect the
California Title 22 STLC waste designation levels for these
contaminants. The non-carcinogenic PAH leachate level was
revised to 1 ppm to be more consistent with criteria in 40 CFR
268.
Clean-up criteria for all contaminants in drainage sediments have
been revised to reflect analytical detection limits for organics.
The groundwater clean-up standard for arsenic was revised to
reflect a practical quantification limit of 5 ppb, which also
reflects a 1 x 10'5 risk level. The groundwater standard for
carcinogenic PAHs has been revised to 5 ppb, which also reflects
the practical quantification limit for PAHs.
Finally, EPA has eliminated direct discharge to surface water as
a disposal option for treated groundwater.
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APPENDIX A
RESPONSE SUMMARY
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SUMMARY OP COMMENTS
J. H. BAXTER 8UPERFUND SITE
PROPOSED CLEAN-UP PLAN
A discussion of significant comments and issues related to EPA's
Proposed Plan to clean up the J. H. Baxter site is presented
below. A more detailed discussion follows this synopsis of
significant comments.
Clean-up Goals - Rationale for Selection
EPA received several comments regarding the selection of the
proposed clean-up goals for the site, particularly in reference
to using the naturally occurring level, or "background", as the
clean-up standard.
When selecting clean-up goals, EPA considered a number of
factors, including health-based levels as determined by the
site's endangerment assessment and by state and federal criteria.
Background levels for the site were also considered. The site
has two basic types of contaminants: inorganic contaminants and
organic contaminants. The inorganic contaminants such as
arsenic, chromium, copper, and zinc occur naturally in the site
area and therefore have background levels. The organic
contaminants such as the components of creosote,
pentachlorophenol, tetrachlorophenol, and chlorinated
dioxins/furans do not occur naturally at the site and thus do not
have background levels.
For the inorganic contaminants, EPA selected health-based
criteria as the starting point for site cleanup. The clean-up
level identified for arsenic in soil is the background
concentration of 8 parts per million (ppm) at the site. This
corresponds to the health-protective level for arsenic of a 1 in
100,000 risk of cancer. The health-based level for chromium,
another carcinogen, was identified at 570 ppm. EPA will be using
500 ppm as the clean-up standard for chromium to be consistent
with the State of California's standards. Because copper and
zinc are considered less toxic than arsenic and chromium, the
clean-up standards are higher. It is important to note that all
of the inorganic contaminants are mixed together in the soil and
excavating and treating arsenic to background will essentially
treat and remove the other inorganic contaminants to background
levels. Because the proposed soil remedies will prevent movement
of the inorganic contaminants in runoff or wind-blown dust, they
will not threaten human health or the environment.
For the organic contaminants in soils, EPA's clean-up standards
reflect health-based criteria for each contaminant or the
analytical detection limit, if the health-based level cannot be
detected by current EPA accepted methods. The exception is for
BPPRSUMF A-l
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pentachlorophenol where the State of California's standard of 17
ppm, which is more stringent than the health-based criterion, was
selected. Like the inorganic contamination, the organic
contamination is also mixed in the soil. Excavating and treating
the carcinogenic components of creosote and the dioxins, which
have the most stringent clean-up standards, will essentially
remove the other organic contaminants as well. EPA will not
allow detectable levels of these contaminants in runoff from the
site.
EPA is proposing to pump contaminated groundwater to treat the
water at a facility at the site. EPA has selected health-based
standards as the goals for cleaning up the aquifer. EPA will
require treating the water to health-based levels before
releasing it for industrial or other uses. EPA will not be
releasing treated water to Beaughton Creek or its tributaries.
EPA will not allow reinjection into the groundwater of treated
water that will reduce the quality of the aquifer at the site to
below health-based standards.
Risk Assessment - Alternative Methods Proposed
The potentially responsible parties provided several comments
related to the risk assessment methods used by EPA. They
suggested an alternative approach that is less conservative than
EPA's and proposed les's stringent clean-up goals.
The risk assessment approach used by EPA at this site reflected
the approach EPA used at Superfund sites during the mid to late
1980's. EPA's approach incorporates conservative assumptions
because of future uncertainties related to land use and public
access to the site. The alternative approach suggested by the
commentors is not consistent with EPA's current risk assessment
methods and thus cannot be considered.
Surface Water Discharge - Impacts to Beaucrhton Creek
EPA received a few comments expressing concern over the impact of
discharging treated groundwater to Beaughton Creek. Beaughton
Creek supports a viable fishery. Aquatic life, anglers,
wildlife, and cattle could be affected by the discharge.
EPA has reconsidered the direct discharge water disposal option
and will not be including at a part of the final remedy. EPA's
disposal options for the treated groundwater are process water
use, evaporation/percolation ponds, and reinjection into the
contaminated portion of the plume.
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Long-term Management: of Treated Wastes - Whv is Ty« Necessary?
The inorganic contaminants exist in the soil in a concentrated
state, and due to physical constraints they cannot be destroyed
nor can their tbxicity be significantly reduced. The selected
treatment for the soils, which is fixation or solidification
through mixing with cement, is intended to prevent the
contaminants from continuing to leach from soils into groundwater
and to prevent water-borne and wind-borne movement of
contaminants. Because the contaminants will remain at the site
in the fixed soil mass, the treated soils should not be disturbed
or used for other purposes. Therefore long-term management will
be required. The most contaminated soils will be placed in lined
treatment cells constructed to capture any rain water that has
come into contact with the fixed soils and has possibly dissolved
some of the contaminants. This contaminated water or leachate
will remain within the cells. Long-term management of these
cells will be necessary to continue collection of leachate, to
maintain integrity of the cells, and to prevent disturbance of
the cells.
It may not be possible to completely destroy all of the organic
contaminants using biological treatment. Therefore, the
biologically treated soils will also be maintained in lined
treatment cells to prevent direct contact or reuse of the soils
as long as the organic contamination remains.
Effectiveness - Can EPA Achieve and Maintain Clean-up Goals using
the Technologies Identified?
The remedies selected by EPA have been effective either during
pilot studies at this site or at similar sites. EPA will
continue to evaluate progress at this site to ensure that the
remedies remain effective. Where necessary, EPA will modify the
proposed remedies or add new clean-up steps so that clean-up
standards are met.
Off-Site Contamination - What is EPA's Proposal?
EPA has performed extensive soils sampling in all areas around
the site and has only detected significant contamination in site
drainage areas on and off of the site. Where necessary, EPA will
remedy the drainage contamination. EPA did not detect
contamination in residential areas above health-based criteria
and EPA is not proposing an off-site soil remedy at this time.
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Schedule of Site Remedy - Can thg wood Treatment Plant Remain
Open?
EPA received a few of comments related to its proposal to allow
the wood treatment plant to remain open during site remedy. It
is not EPA's intent to close the wood treatment plant during site
remedy. EPA will determine a clean-up schedule that will allow
continued operations. The proposed groundwater collection and
treatment remedy will not affect or be affected by plant
operations. The majority of surface soils contamination can be
treated with minimal effects on plant operations. Only the
remedy of subsurface soils below and next to the plant structures
will potentially affect plant operations. EPA will include the
treatment of these subsurface soils as part of its negotiated
settlement with the responsible parties.
BPPRSUMF A-4
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RESPONSE SUMMARY
The Proposed Plan for the J.H. Baxter site was issued to the
public on April 27, 1990. The Proposed Plan described EPA's
preferred remedial alternatives for contaminated soils,
groundwater, surface water, and sediments at the site. At the
time of issuance of the Proposed Plan, EPA announced that the
public comment period would extend from May 1 through May 30,
1990. At the request of the potentially responsible parties
(PRPs), the public comment period was extended to June 30, 1990.
On May 7, 1990, EPA briefed citizens of the City of Weed on EPA's
Proposed Plan at a public meeting.
SUMMARY OF COMMENTS RECEIVED
During the public comment period, EPA received comments from
individuals within the local community, from public interest
groups, from the North Coast Regional Water Quality Control
Board, California Department of Fish and Game, the California
Department of Health Services, and from the potentially
responsible parties. Comments pertaining to elements of the
Proposed Plan and EPA's responses to the comments are summarized
below.
A. COMMENTS FROM COMMUNITY MEMBERS
Commentor: Mary Thomas
Date: May 9, 1990
1. Comment:
The commentor agreed with the proposed groundwater treatment
remedy, but was concerned about discharge of treated water to
surface waters or for irrigation.
1. Response:
EPA does not propose to release treated water to surface water or
as irrigation water that would contain chemicals at levels
harmful to humans, cattle, fish, or wildlife. All releases would
meet the stringent State and Federal standards for protection of
human health and the environment based on the discharge method
employed. EPA would also require monitoring of any releases to
ensure that protection of human health and the environment is
maintained.
BAXRESUM A-5
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2. Comment:
The commentor agreed with the proposed soil treatment remedy, but
requested clarification of the term "long-term management" of the
treated soils. The commentor requested that the treated soils be
capped after treatment.
2. Response:
The treatment remedy for soils contaminated with arsenic and
other inorganics does not remove the contaminants, but binds them
into a solid mass which prevents the contaminants from being
washed or blown away, or move into the groundwater. The treated
soils therefore must be placed in a location that will remain
undisturbed in perpetuity or until a follow-on remedy is deemed
necessary. The long-term storage unit which will contain the
treated soils will be capped by a soil layer so that wind, rain,
and surface water will not come in contact with the treated
soils. By stating that treated soils will require long-term
management, EPA is indicating that Federal, State, and local
records for the site must be amended through deed restrictions to
reflect that treated soils have been deposited on the site
property, and that the storage unit into which the soils have
been placed should not be disturbed.
3. Comment:
The commentor expressed a concern over the dust problem for the
site due to the high wind conditions for Weed and asked whether
the entire site should be capped.
3. Response:
EPA's proposed remedy for the site will involve the removal and
treatment of all contaminated surface soil and the maintenance of
the soil in a containment cell so that wind erosion is not
possible. Baxter would be required to reconstruct the property
so that release of contaminated dusts would not be possible. In
recognition of the current dust problem, EPA is considering
spraying the contaminated site soils with a non-toxic soil
particle binding agent that will minimize dust releases until the
final remedy is implemented.
BAXRESUM A-6
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Public Meeting Comments
Date: May 7, 1990
1. Comment:
How does Love Canal compare with the Baxter site? If the Baxter
site was discovered first, would there have been a similar public
reaction to the Baxter site?
1. Response:
There is very little similarity between the J.H. Baxter and Love
Canal Superfund sites. Love Canal primarily resulted from the
construction of houses over former hazardous waste lagoons. At
Love Canal there was a significant potential for daily direct
contact with the hazardous wastes and therefore a more serious
health threat was present. To EPA's knowledge, there are no
records of waste disposal within the community or of residential
construction over former waste disposal areas related to the J.H.
Baxter site.
2. Comment:
What is the long-term management of the treated and fixed soils?
2. Response:
EPA proposes to place the treated soils into a containment cell
designed to collect any contaminated liquids that may result from
moisture contact with the treated soils. A soil cap will be
constructed over the soils to prevent direct contact, surface
water erosion, and wind erosion of the soils. EPA, in
coordination with State and local authorities, will require
institutional controls (such as deed restrictions) that will
prohibit disturbance of the treated soil unit or cap. EPA will
also require monitoring of any liquids produced in the soil
containment unit and of the local groundwater to ensure that the
remedy is effective in containing the contaminants. Long-term
management will be necessary as long as the treated and fixed
soils remain at the site.
BAXRESUM A-7
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Commentor: Kenoli oleari (Salmon River Concerned Citizens)
Date: June 30, 1990
1. comment:
A discussion of historical difficulties and problems relating to
J.H. Baxter's unwillingness to cooperate and to comply with
clean-up orders should have been included in the Feasibility
Study (FS) and Proposed Plan.
1. Response:
A discussion on the regulatory history for the site was included
in the Remedial Investigation report and was not repeated in the
FS. Although the State and EPA experienced a lack of cooperation
by Baxter during the early stages of the RI/FS process, Baxter
has shown a greater willingness to cooperate in more recent
remedial studies and efforts. CERCLA requires that all
potentially responsible parties (PRPs) be given an opportunity to
participate in site cleanup. J.H. Baxter's obligations for the
cleanup will be established in EPA's Consent Decree orders and
Baxter will be required to meet its obligations or face a Federal
lawsuit under the Superfund law.
2. Comment:
EPA should take over responsibility for cleanup from Baxter.
2. Response:
Baxter, IP, and Roseburg have all shown good faith responses to
recent EPA and State requests for site remedial studies and
interim actions. As long as these parties remain responsive, EPA
will not take over the direct responsibility for cleanup. In
addition, it is EPA's policy that in the situation where viable
responsible parties are identified for a site, such as the Baxter
site, EPA will not take over responsibility for cleanup. EPA
will negotiate a Consent Decree with the viable parties which
defines the scope of cleanup. EPA will oversee the cleanup, and
sue any viable party who does not comply with the scope of
cleanup established in the negotiated Consent Decree. Provisions
and stipulated penalties provided in the Consent Decree are
designed to prevent the potentially responsible parties from
delaying or hindering the clean-up process. The Consent Decree
BAXRESUM A-8
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will require the site remedies to be implemented in a manner that
is protective of public health and the environment..
3. Comment:
Allowing Baxter to delay cleanup 3 to 5 years could expose the
public to additional health risks over an unreasonable time
period. A shorter clean-up period is requested to prevent this.
3. Response:
EPA must recognize the economic burden that implementing a remedy
may have either on the facility directly involved or the local
community supported by the facility. Implementing the remedy
during a relatively short period could result in the temporary or
permanent closure of the wood treatment plant, which is not one
of EPA's goals. By allowing the remedy to occur over 3 to 5
years in a phased approach, Baxter can remain in operation and
maintain current employment. The 3 to 5 year cleanup refers to
Baxter property soils below the facility buildings only. EPA ~
does intend to address the surface water runoff and dust
emissions problems early in the remedial process to minimize the
risks posed by these releases to the local community. The
potentially responsible parties have installed one groundwater
treatment plant on Roseburg's property and instituted a pilot
program at the Baxter property to extract and treat contaminated
groundwater. EPA will also review effectiveness of all remedies
every 5 years and modify the remedies as necessary to ensure that
they remain protective.
4. Comment:
A comprehensive program for offsite contamination investigation
is critical and must be included as part of the cleanup plan.
4. Response:
EPA recently completed extensive soil sampling of residential
areas adjacent to the Baxter property and determined that there
is no soil contamination in these areas resulting from wood
treatment activities. These results and the results of EPA's
remedial investigation indicate that the only significant offsite
contamination occurs in the drainage ditch that collects and
BAXRESUM A-9
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transports surface water from the Baxter property. EPA intends
to remove these contaminated sediments as part of the selected
remedy. EPA is currently working with the Department of Fish and
Game and the responsible parties in developing and implementing
studies to evaluate impacts of past releases on Beaughton Creek.
The Beaughton Creek studies will be implemented as part of the
ROD. Creek remedies determined from the study results will be
implemented as part of the ROD.
5. Comment:
Soil testing at the Weed High School is requested.
5. Response:
The Weed High School is hydrologically upgradient from the site.
Therefore, groundwater and surface water from the high school
flow towards the site area. Prevailing winds at the site flow
parallel to the high school indicating that it is not downwind of
the site. No soil samples collected between the high school and
the site showed contaminants from wood treatment chemicals. EPA
also tested the groundwater well the high school uses to irrigate
the playing fields and found the water to be free of site
chemicals. Therefore additional investigations of the high
school area are not warranted.
6. Comment:
Local health surveys are requested to evaluate frequency of x
disease in the community that may be a result of site chemicals.
6. Response:
Under the Superfund process, public health surveys are the
responsibility of the Agency for Toxic Substances and Disease
Registry (ATSDR) in Atlanta, Georgia. EPA suggests that you
contact ATSDR to discuss the process for requesting a public
health survey for the Baxter site area. Inquiries should be
addressed to: Director of Division of Health Assessments and
Consultation, 1600 Clifton Road, Atlanta, GA 30333.
BAXRESUM A-10
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7. Comment:
The plan fails to address synergism between contaminants.
7. Response:
Scientific data regarding synergistic health effects of multi-
contaminant exposures are currently in the early stages of
analyses and quite inconclusive. In selection of clean-up levels
to background concentrations for carcinogens, EPA has effectively
addressed potential synergistic effects for all contaminants.
8. Comment:
Facilitated transport of dioxins caused by solvents may have
resulted in widespread dioxin contamination.
8. Response:
Of the "solvents" mentioned by the commentor, pentachlorophenol
and tetrachlorophenol, like dioxins, are solids and thus cannot
act as a solvent. Benzene detected at the site was the result of
a leaking underground storage tank that was not part of the wood
treatment operation. In addition, the affected area is localized
and the soil concentrations are insufficient to facilitate the
transport of dioxins. The dioxin sampling performed at the site
did not indicate contamination above health-based criteria
offsite. Because dioxins tend to adsorb strongly to soil
particles, transport of dioxins in dust and sediment is the
primary transport concern. EPA is developing plans to prevent
contaminated dust release and surface water erosion of
contaminated site soils.
9. Comment:
The Feasibility Study and Cleanup Plan need to look at a broad
range of health effects and to investigate the quality and
applicability of studies they reference. Recent studies on
pentachlorophenol show it to be a highly toxic carcinogen.
BAXRESUM A-11
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9. Response:
The Endangerment Assessment used as the basis to establish clean-
up levels did consider all types of known health effects,
including reproductive effects. All studies used in the
assessment were published studies that had been subject to peer
review. It is beyond the scope of a feasibility study to
evaluate individual studies on technical merit.
Pentachlorophenol was treated as a carcinogen in this study.
10. Comment:
The choice of a "background level" for arsenic contamination
needs to be reevaluated because naturally occurring arsenic is
less toxic than the type of arsenic used at the wood treatment
facility. Cleanup of arsenic to nonr-detect levels is
recommended.
10. Response:
In performing the endangerment assessment, EPA assumed that all
arsenic present was in the most toxic form. Results of the
assessment show that cleanup to 8 ppm (or background) will be
protective of human health and the environment and additional
assessment is not warranted. It is not feasible to clean up
arsenic to non-detectable levels because it does occur naturally
in soils and rocks at the site and the surrounding region.
11. Comment:
Cleanup of pentachlorophenol, dioxins, and carcinogenic
polycyclic aromatic hydrocarbons (PAHs) to non-detect levels is
also recommended.
11. Response:
The Endangerment Assessment performed by EPA indicates that
clean-up of these chemicals to the levels presented in the Record
of Decision will be protective of human health and the
environment and further reduction is not warranted. For soils
clean up to background for arsenic and the 1 x 10"6 risk level
for carcinogenic PAHs has been chosen. For water, cleanup will
BAXRESUM A-12
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be performed to 5 ppb for arsenic (1 x 10'5 risk level) and non-
detect levels for all organics.
12. Comment:
The effectiveness of the fixation technology for inorganic soil
contamination is questioned.
12. Response:
Although EPA recognizes that the use of pozzolonic materials to
fix inorganic chemicals has a relatively brief history, the long-
term durability and stability of pozzolins are well known.
Treatability tests using cement as the binding agent showed that
the inorganics were immobilized in the fixed mass. Therefore
this technology was proposed. To ensure that the technology
remains effective, EPA intends to place the fixed soils in a
containment cell and monitor the cell for an extended period.
Should results of the long-term monitoring indicate that the
fixed mass loses effectiveness in preventing contaminant
mobility, EPA will consider an alternative technology at that
time.
EPA disagrees that the fixation alternative is too complicated to
be effective. The alternative involves the use of commercially
available fixative agents and standard earth moving and handling
equipment. The technology employed is extremely simple with
minimal opportunities for failure or "glitches".
The area selected for the fixed soil storage will be in a
geologically stable location and at least 10 feet above the high
groundwater table. EPA remains confident that the technology can
be implemented and maintained in a safe manner. Data to support
EPA's proposed remedy are provided in the Administrative Record,
maintained in Weed and San Francisco.
13. Comment:
The effectiveness of the biological treatment process proposed
for soils and water on the site is questioned and UV/Ozone
treatment is proposed.
BAXRESUM A-13
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13. Response:
The FS contained results of treatability studies for this site
which showed that biological treatment could be effective in
reducing creosote and pentachlorophenol contaminant levels.
Biological treatment has been employed at a number of wood
treatment sites to treat groundwater and soils. EPA reviewed the
results of a number of treatability studies before proposing
biological treatment.
As stated in the FS, biological treatment of water may have to be
coupled with a final polishing step using activated carbon or
UV/ozone to achieve the final treatment levels to remove or
destroy residual organic contaminants. EPA would prefer to use
UV/ozone as the polishing step because it does not involve
handling or disposal of large quantities of wast s as is required
for activated carbon. EPA also considered using JV/ozone as the
primary treatment technology, but it is more costly to operate
and is subject to significant fouling at high creosote
concentrations. EPA therefore proposed biological treatment as
the primary treatment technology.
EPA considered UV destruction of organics in soils but did not
propose this technology. The UV technology for soils requires
significant materials handling and processing to be effective and
soil can only be processed in small batches (e.g., 1 cubic yard).
Due to the large quantities of soil involved (about 20,000 cubic
yards), a technology that handles soils in large quantities is
important. Biological treatment requires significantly less soil
handling and processing, and can be performed on bulk soils.
Costs and time to complete the soil treatment effort also favor
biological treatment. Data to support EPA's proposed remedy are
provided in the Administrative Record maintained in Weed and San
Francisco. Appendix B of the ROD presents the Index to the
Administrative Record.
14. Comment:
A concern is expressed that much of the cleanup activity relies
on ongoing monitoring which requires cooperation of the parties
involved in site cleanup. Alternative cleanup technologies that
do not require intensive monitoring are suggested.
BAXRESUM A-14
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14. Response:
Any treatment technology employed at this site will require
monitoring due to the nature and extent of contamination present.
The technologies proposed by EPA reflect a required level-of-
effort for monitoring that would not be any different from a
required level-of-effort for any other technology. Because the
Superfund law includes substantial penalties for failure by the
responsible parties in complying with the monitoring efforts to
be specified in the Consent Decree, EPA is confident that the
required monitoring will be performed. All tests performed as
part of monitoring will reflect EPA accepted procedures.
Additional tests can be incorporated into the monitoring process
as necessary as determined through the 5-year review procedure.
15. Comment: /-
Regular public meetings and information transfer on the progress
of site cleanup will be important for the success of this effort.
15. Response:
EPA agrees that information will be regularly shared with the
concerned community. Public information repositories located in
Weed and San Francisco will be continually updated as new
information becomes available. In addition, fact sheets and
meetings will be used to keep the public informed on the progress
of site cleanup.
Commentor: Felice Pace (Klamath Forest Alliance)
Date: none provided
1. Comment:
The Proposed Plan indicated off-site contamination. Off-site
contamination should be considered part of the site and be
included within the Record of Decision.
1. Response:
EPA recently completed an extensive off-site soil sampling
program in areas adjacent to the site and no contamination above
BAXRESUM A-15
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naturally occurring background was detected in residential areas.
One sample in Lincoln Park indicated chromium at 82 ppm, which is
above the 40 ppm background level for this metal. However, this
level is far below EPA's 1 x 10"6 risk level for direct contact
by children, which is 570 ppm. Contaminated sediments within and
adjacent to the site will be addressed in the ROD and included in
the overall site remedy.
2. Comment:
Where possible, clean-up goals should be established at the
natural background level for the contaminant.
2. Response:
For soils, EPA has proposed background as the clean-up level for
arsenic, and levels near the analytical detection limits for
carcinogenic PAHs and dioxins. Arsenic, carcinogenic PAHs, and
dioxins are the primary contaminants of concern for the site and
will drive the cleanup. Available data indicate that all site
contaminants are commingled in soils. Therefore removal of
arsenic and carcinogenic PAHs to background levels or near
detection limits will also remove all site contaminants to near
background levels. For groundwater contaminants, EPA has
proposed clean-up levels as close to background as possible for
the carcinogens. Contaminants are also commingled in groundwater
and the treatment of water to remove the primary contaminants
will also remove other contaminants to detection limits.
Technological constraints may not allow clean-up or treatment to
background using available water treatment technologies at this
time, but the levels selected by EPA are considered protective of
human health and the environment. EPA will periodically
reevaluate the clean-up levels and response technologies and
modify both as necessary so that the lowest achievable clean-up
level, protective of health, can be met.
3. Comment:
Dangerous chemicals should not be discharged to surface water,
BAXRESUM A-16
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3. Response:
At this time,.EPA is not proposing direct discharge to surface
water as the disposal method for treated effluent. EPA has
identified process water use by Baxter and Roseburg, primarily
for use as spray water on the log decks, for disposal of the
treated groundwater during late spring through fall months.
Discharge of treated water to percolation/evaporation ponds will
used during the winter months. Disposal of treated effluent to
the surface water would be performed only in accordance with
State requirements, which at present do not allow discharge of
any treated effluent to surface waters.
4. Comment:
The Proposed Plan should contain a more thorough discussion of
risks posed by chemicals at the site.
4. Response:
A detailed discussion of site risks is presented in the
Endangerment Assessment. The purpose of the Proposed Plan is to
describe EPA's proposed site remedy. Other relevant information
such as that related to site risks is summarized in order to
maintain a condensed fact sheet format. The Endangerment
Assessment and other supporting documentation on site risks are
available in the site's information repositories located at the
College of the Siskiyous and at the Weed Library.
5. Comment:
An information repository in Yreka is recommended.
5. Response:
EPA once maintained an information repository in Yreka, but
removed it when EPA discovered it was not being used.
Information repositories remain in Weed and San Francisco.
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6. comment:
An explanation of why background levels cannot be feasibly
attained with currently available technology is necessary.
6. Response:
For surface and near surface soils where excavation for
subsequent treatment will be the first step in the site remedy
process, removal to background levels of arsenic is readily
achievable. The only limitation to excavation would be using
analytical chemistry results to define the boundaries of the
contaminated soil to be removed. All of the inorganic
contaminants can be analyzed to their background levels in soils
and therefore excavation to background is achievable. EPA
proposes to excavate the carcinogenic organic contaminants to the
non-detection level. The organic contaminants can be analyzed to
the 500 parts per billion level which are concentrations
considered protective of human health and the environment.
Soil excavation is proposed to go as deep as the top of the
groundwater table (or about 5 to 12 feet below ground surface
depending on the time of year). Although it is possible to
excavate soils that are within the groundwater zone, these soils
are saturated with water. The saturated soils lose the
structural properties of dry soils and become more difficult to
excavate and handle. Temporary dewatering of the proposed
excavation area may allow the excavation to extend deeper than 12
feet, but the difficulty of dewatering the aquifer further and
the need for shoring of the excavation, coupled with worker
safety concerns for excavations in saturated soils, would prevent
a deeper excavation.
For the deeper soils, pumping of contaminated groundwater is one
means of removal of contaminants from the subsurface soils. All
of the site contaminants have a stronger attraction to soil
particles than they do for going into solution, therefore the
contaminants tend to remain bound to the soil. Thus, removal of
the contaminants through groundwater extraction may not be
sufficient to remove the subsurface soil contaminants. Removal
of the subsurface contaminants can be enhanced through the
injection of flushing agents that detach the contaminants from
the soils and allow them to move in the groundwater towards the
extraction wells. The injection of nutrients into the
BAXRESUM A-18
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groundwater could also encourage bacteria to consume the organic
contaminants, also facilitating subsurface and aquifer cleanup.
Available technologies are adequate to allow treatment of
organics in extracted groundwater to non-detection levels (about
5 ppb). Removal of inorganic contaminants to background levels
in large volumes of water (it is estimated that up to 150,000
gallons per day may be treated at the site) is more difficult due
to technological constraints for this volume of water. Although
it is possible to treat the water to background levels in the
laboratory, technological and cost limitations required to scale-
up a laboratory treatment scheme to a full-scale treatment
facility could prohibit treatment of inorganics to background.
EPA will require treatment of extracted groundwater to those
levels achievable using the best available demonstrated
technologies and will require the potentially responsible parties
to modify the treatment plant as necessary to achieve levels
expressed in EPA's standards. EPA is confident that these
levels will be protective of human health and the environment for
treated water released from the site.
7. Comment:
The commentor asked for an explanation on why soil leachate
concentrations are proposed as acceptable when they are far
higher than the clean-up goals for groundwater.
7. Response:
EPA uses leachate tests to determine the ability of a contaminant
to move from a solid waste and to establish whether the waste can
be classified as hazardous. For the Baxter site, leachate tests
will be used to establish the level at which a treatment process
is effective and no further treatment is necessary. The leachate
standards that EPA has proposed take into consideration
groundwater protection factors. Under normal situations, the
volume of leachate generated by water passing through a waste is
significantly smaller than the volume of the aquifer or surface
water that may be affected. Contaminants within the leachate as
it moves through soil tend to leave the liquid and adsorb to soil
particles. Therefore the concentration of the leachate can
decrease as the leachate moves. Due to the relatively small
volume of leachate produced compared to an aquifer or surface
water body, EPA also assumes that people will not be directly
BAXRESUM A-19
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consuming leachate or coming in contact with sufficient
quantities of the leachate for it to be harmful. For these
reasons the leachate standards can be higher than the drinking
water or aquifer standards. It is also important to note that
while waste treatment is occurring at the site, the soils will be
contained in lined treatment cells. All leachate collected from
within these lined cells will be directed in pipes either back
onto the surface of the soil treatment area or into the water
treatment plant. EPA does not intend to allow the leachate to
reach or affect groundwater or surface water.
* * *
B. COMMENTS FROM STATE AGENCIES
Conunentor: Anthony Landis (California Department of Health
Services)
Date: June 19, 1990
1. Comment:
It is the position of the California Department of Health
Services that the California Environmental Quality Act (CEQA) and
the Safe Drinking Water & Toxic Enforcement Act (Proposition 65)
are site ARARs.
1. Response:
The National Contingency Plan (NCP) presents the criteria that
EPA uses in identification of Applicable or Relative and
Appropriate Requirements (ARARs). The NCP (40 CFR 300.400(g)(4))
states, "Only those state standards that are promulgated, are
identified by the state in a timely manner, and are more
stringent than federal requirements may be applicable or relevant
and appropriate. For purposes of identification and notification
of promulgated state standards, the term 'promulgated1 means that
the standards are of general applicability and are legally
enforceable." The NCP further states that EPA may select an
alternative that does not meet a state identified ARAR if "the
state has not consistently applied, or demonstrated the intention
to consistently apply, the promulgated requirements in similar
circumstances at other remedial actions within the state" (40 CFR
300.430(f)(C)).
BAXRESUM A-20
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EPA has determined that the requirements of CEQA are no more
stringent than the requirements for environmental review under
CERCLA, as amended by SARA. Pursuant to the provisions of
CERCLA, the NCP and other federal requirements, EPA's prescribed
procedures for evaluation of environmental impacts, selecting a
remedial action with feasible mitigation measures, and providing
for public review, are designed to ensure that the proposed
action provides for the short-term and long-term protection of
the environment and public health and hence perform the same
function as, and are substantially parallel to, the State's
requirements under CEQA.
Since EPA has found that CERCLA, the NCP, and other federal
requirements are no less stringent than the requirements of CEQA,
EPA has determined that CEQA is not an ARAR for this site.
EPA will continue to cooperate with DHS and other State and
federal agencies during the design phase of the remedial action
to clarify further environmental review and mitigation
requirements and ensure that they are fulfilled.
EPA has performed a thorough evaluation of Proposition 65 or the
Safe Drinking Water and Toxic Enforcement Act of 1986 (the Act)
and the regulations implementing it (CCR Title 22 Section 12000
et. seq.) and has determined that the Act is not an ARAR for this
site for the following reasons. To be an ARAR, Proposition 65
discharge limits would need to be more stringent than standards
adopted by EPA in the Record of Decision. EPA's clean-up goals
are based on a 1 in 1,000,000 (1 x 10"6) risk level for
carcinogens. However, in some instances analytical
quantification limits are higher, such as in the case of arsenic,
and EPA will be using a 1 x 10'5 risk level as the standard.
Risk levels promulgated under CCR Title 22 Article 7 (No
Significant Risk Levels), Section 12703, specify a 1 in 100,000
(1 x 10"5) risk level, which is less stringent than EPA's
standard.
CCR Title 22, Section 12701, paragraph (a) clearly allows EPA to
use discharge standards other than those presented in the
regulation. This paragraph states, "Nothing in this article
shall preclude a person from using evidence, standards, risk
assessment methodologies, principles, assumptions or levels not
described in this article to establish that a level of exposure
to a listed chemical poses no significant risk". EPA has
performed a risk assessment meeting the requirements of CCR Title
BAXRESUM A-21
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22, Section 12721, and has determined that EPA's standards pose
"No Significant Risk" as intended under this regulation.
EPA's identification of an alternative standard is also supported
by Proposition 65 Title 22 regulations. Section 12703, paragraph
(b) states,
For chemicals assessed in accordance with this section, the
risk level which represents no significant risk shall be one
which is calculated to result in one excess case of cancer
in an exposed population of 100,000, assuming lifetime
exposure at the level in question, except where sound
considerations of public health support an alternative
level, as for example, where a clean-up and resulting
discharge is ordered and supervised by an appropriate
governmental agency or court of competent Jurisdiction
(emphasis added).
As the lead agency for the Baxter site, EPA clearly can select
health-based standards using other standards and considerations
that are protective of human health and the environment.
EPA has discussed Proposition 65 issues with California Health
and Welfare Agency personnel (the Health and Welfare Agency is
the administering Agency for Proposition 65) and has been
informed that Proposition 65 was not intended to establish clean-
up levels or discharge limitations for hazardous waste site
remedial actions. They cited CCR Title 22, Article 4
(Discharge), Section 12401 (Discharge of Water Containing a
Listed Chemical at Time of Receipt) in making this statement.
Section 12401 (b) states:
Whenever a person otherwise responsible for the discharge or
release, receives water containing a listed chemical from a
source other than a source listed in subdivision (a),
[subdivision (a) specifies a drinking water supply in
compliance with all primary drinking water standards, which
is not the case for this site], the person does not
"discharge" or "release" within the meaning of the Act to
the extent that the person can show that the listed chemical
was contained in the water received, and "discharge or
release" shall apply only to that amount of the listed
chemical derived from sources other than water, provided
that:
BAXRESUM A-22
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(1) The water is returned to the same source of .water
supply, or
(2) The water meets all primary drinking water
standards for the listed chemical or, where there is no
primary drinking water standard, the water shall not
contain a significant amount of the chemical.
Therefore treated water that is sprayed onto the log decks or
directed to the percolation ponds, which both meets the standards
presented in 12401(b)(2) and will ultimately be returned to the
same source of water supply as stated in 12401(b)(1) does not
constitute a discharge or release under Proposition 65.
In summary, it is EPA's goal to return the site aquifer to its
greatest beneficial use and to reduce the residual risk at the
site to background levels. All discharges from the site will be
performed to standards identified in the Record of Decision that
are protective of human health and the environment and will pose
no significant risk. Because EPA goals and standards are
consistent with Proposition 65 and because Proposition 65 is no
more stringent that EPA's standards, Proposition 65 is not an
ARAR for this site.
Finally, the communication requirements of Proposition 65
duplicate or are not more stringent than FederaT standards and
are not an ARAR for this site.
2. Comment:
DHS requests to be included in all discussion related to cleanup
of Beaughton Creek.
2. Response:
EPA will include DHS in all significant discussions related to
cleanup of Beaughton Creek.
3. Comment:
DHS recommends a "worst first" remedial program that will address
current health threats as a priority. This should involve
removal of contaminated soils and sediments, temporarily
"capping" the site to prevent fugitive dust emissions, source
BAXRESUM A-23
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detection and elimination, and plume redefinition based on the
proposed clean-up levels.
3. Response:
EPA concurs with these recommendations. EPA is presently
developing plans to control dust emissions and runoff from the
wood treatment property. EPA is working with Baxter and
International Paper personnel in defining immediate source
control activities and the locations of additional site wells.
Commentor: Susan Warner (California Regional Water Quality
Control Board - North Coast Region)
Date: June 28, 1990
1. Comment:
The NCRWQCB does not concur with the FS assessment that Federal
Ambient Water Quality Criteria (AWQC) are not ARARs for the site.
1. Response:
EPA has reviewed this issue and, based on ARAR selection criteria
presented in the NCP, concurs that the Federal Ambient Water
Quality Criteria could be used as ARARs for the site remedy, if
the remedy involved discharge to surface water. However, EPA is
not proposing discharge to surface water, therefore AWQC are not
an ARAR for this site.
2. Comment:
The NCRWQCB does not concur with EPA's assessment that
Proposition 65 is not an ARAR and provides information indicating
that Proposition 65 is being enforced consistently throughout the
North Coast region.
2. Response:
Based on a review of the information provided by NCRWQCB and
criteria presented in the NCP for identification and use of
ARARs, EPA's assessment of Proposition 65 remains that it is not
an ARAR for this site. See also EPA's response to DHS comment
BAXRESUM A-24
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No. 1. Of the 11 documents provided to EPA as evidence of
Proposition 65 enforcement, 9 of the documents predate
Proposition 65 implementation and naturally cannot be used as
evidence for Proposition 65 enforcement. Two of the documents
relate to recent enforcement of waste discharge requirements at a
Louisiana-Pacific wood treatment facility in Mendicino County.
However, in the Louisiana-Pacific case (Order 85-88), the NCRWQCB
is allowing discharge of treated effluent from a wood treatment
operation to the waters of the State. This discharge
consideration is inconsistent with other portions of the North
Coast region, such as the Baxter site, where the NCRWQCB is
prohibiting discharge of treated effluent. In the second
Louisiana-Pacific case (Complaint No. 89-103), the only standard
identified is 50 micrograms per liter, the MCL for arsenic, which
is significantly higher than EPA's Baxter site standard of 1
microgram per liter (ppb). Neither the Baxter nor Roseburg
enforcement orders provided can be considered as examples of
Proposition 65 enforcement because they predate the Act.
Contaminated runoff containing Proposition 65 chemicals can still
be detected in surface water flowing from the Baxter property.
The Roseburg water treatment system was not designed or
constructed to address Federal or State water treatment facility
requirements, and it is not treating for arsenic, a primary site
contaminant and a Proposition 65 listed chemical. No evidence
was provided to EPA in these documents that demonstrates that the
discharge limitations of Proposition 65 are being enforced or
even met at other locations within the State.
3. Comment:
The NCRWQCB does not concur with the clean-up goals for
polynuclear aromatics and chlorophenolics in sediments.
3. Response:
EPA is amending the clean-up goals stated in the Proposed Plan
for sediments. EPA is proposing to excavate and remove all
sediments with detectable or above-background levels of wood
treatment chemicals in all surface water drainages associated
with the site, except Beaughton Creek. At the request of the
California Department of Fish and Game, EPA is not proposing to
excavate sediments within Beaughton Creek until after results
from additional Creek surveys become available.
BAXRESUM A-25
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4. Comment:
The NCRWQCB does not agree with the elimination of the option of
discharging to the Weed publicly-owned wastewater treatment works
(POTW) and retaining the option for discharge to surface waters.
4. Response:
The disposal option for discharge of treated effluent to the
local POTW was eliminated because at present the facility does
not have the capacity to accept or treat the effluent. Should
conditions at the POTW change that will allow acceptance of
treated effluent, EPA will then consider the POTW as a disposal
option. Discharge of treated effluent into Beaughton Creek was
retained as a potential option to allow disposal (as opposed to
shutting off the treatment system) during the winter months.
EPA's primary disposal option, which is use of the water on the
log sprinkler decks, is only feasible from mid-April through
October when the sprinkler system is operational. EPA is now
proposing the use of percolation/evaporation ponds and
groundwater reinjection as the treated water disposal option for
the winter months. Discharge to surface water will only be
considered when all other disposal options prove infeasible.
5. Comment:
The NCRWQCB states that discharge to surface water will require
amending the Basin Plan.
5. Response:
EPA recognizes that amending the Basin Plan would be necessary to
allow surface water discharge to Beaughton Creek. EPA stated
such in the FS Report. EPA will consider all other viable
disposal options before requesting an amendment to the Plan.
Commentor: Liese L. Schadt (California Regional Water Quality
Control Board, North Cost Region)
Date: September 11, 1990
BAXRESUM A-26
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1. Comment:
The Regional Board repeats its position that Proposition 65 is an
ARAR and comments on EPA's proposed arsenic and pentachlorophenol
standards as being equal to Proposition 65 standards.
1. Response:
See response to comments by Anthony Landis (California Department
of Health Services) and Sue Warner (Regional Board) on this
issue. EPA's proposed arsenic standard of 5 ppb is based on
EPA's risk assessment for this site. The proposed standard for
pentachlorophenol is based on the California Applied Action Level
for the contaminant. Based on guidance provided in CCR Title 22
Article 7 (No Significant Risk Levels), the Proposition 65 limits
for arsenic and pentachlorophenol would be 5 and 20 ppb,
respectively. These limits are equal to or greater than EPA's
proposed standards, and therefore Proposition 65 is not
considered an ARAR.
2. Comment
The Regional Board does not concur with EPA's clean-up standard
for chromium of 570 ppm in soils. The Regional Board requests
that the clean-up level reflect chromium's "high potential for
leaching from soils" and be established at its background level
for the site. The Regional Board requests that CCR Title 22 TTLC
and STLC tests be performed on soil containing pentachlorophenol,
stating that this compound is also leachable.
2. Response
As a result of a previous request of the Department of Health
Services, EPA has revised the clean-up standard for chromium in
soils to reflect its TTLC concentration of 500 ppm and for
pentachlorophenol its TTLC level of 17 ppm. For all site
contaminants that have a TTLC/STLC value (arsenic1, chromium,
copper, zinc, and pentachlorophenol), EPA will use the results of
both tests in assessing the cleanup of contaminated soils. If
1 For arsenic, EPA will use 8 ppm or background as the
excavation standard, and the TTLC/STLC criteria as treatment
standards.
BAXRESUM A-27
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any sample fails either test, the soil associated with the sample
will be treated and handled appropriately.
EPA does not share the Regional Board's concerns over the
leachability of chromium and pentachlorophenol at this site for
the following reasons. Data collected during the remedial
investigation, and by others, shows that samples with elevated
chromium concentrations were always detected in the presence of
elevated arsenic; samples with elevated pentachlorophenol
concentrations were always detected with elevated creosote
compound (carcinogenic PAH) concentrations. Through excavation
and removal of arsenic to background and carcinogenic PAHs to
less than 1 ppm, essentially all of the site chromium and
pentachlorophenol will also be removed for treatment. Should
elevated chromium and pentachlorophenol be detected at a site
location without elevated arsenic or PAHs, EPA will use the
TTLC/STLC criteria to assess the need for removal and treatment.
The TTLC criteria for chromium (2,500 ppm for chromium (III) and
500 for chromium (VI) do not support a major concern for
leachability of chromium. The TTLC values are based on
scientific data which reflect the leachability of the element
coupled with groundwater protection considerations. If the DHS
considered chromium highly leachable, then the TTLC criteria
would be lower. Use of the TTLC criteria for excavation and
treatment of soil is consistent with the definition of "no
significant risk" as used in Title 22.
Data collected during the remedial investigation, and more
recently provided by the potentially responsible parties, do not
support a concern that chromium is highly leachable at this site.
Data from the RI report show chromium in soils to range from 40.3
ppm (background) to 45,000 ppm, with an average chromium level of
130 ppm. Arsenic ranged from 8 ppm to 38,500, with an average
site level of 240 ppm. Groundwater concentrations ranged from 8
ppb to 122 ppb (average 13 ppb) for chromium and 1 ppb to 1,740
ppb (average of 37 ppb) for arsenic. These data show that
although the average chromium soil concentration is more than 50
percent of that of arsenic, the average groundwater concentration
is 33 percent of that of arsenic. The maximum groundwater
concentration of chromium is less than 10 percent of that of
arsenic.
Recent groundwater data collected 6/22/90 through 7/18/90 as part
of the groundwater pump and treat effort (see letter of August
BAXRESUM A-28
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27, James Grant to Jay Amin of IP) also do not reflect a high
leachability for chromium at this site. These data show current
chromium concentrations in groundwater to range from 1 ppb to 178
ppb (average of 37 ppb) and arsenic concentrations in groundwater
to range from 12 ppb to 6,189 ppb (average of 945 ppb). These
samples were collected from the most contaminated portion of the
groundwater plume and are higher than the RI report values which
include results from the less contaminated portion of the plume.
However the results do support the conclusion that chromium is
not a significant concern with regard to leachability. As stated
above, through removal and treatment of soil with arsenic above
background, chromium will also be removed and treated.
Therefore, threats to groundwater due to chromium at this site
will be alleviated.
3. Comment:
The Regional Board requests that the clean-up standards for
pentachlorophenol and tetrachlorophenol in sediments be reduced
to analytical detection limits.
3. Response:
EPA concurs and has reduced the clean-up standards for these
contaminants to analytical detection limits (about 5 ppb).
4. Comment:
The Regional Board reiterates that discharges to surface water
are prohibited under the Basin Plan.
4. Response:
The option of discharge of treated water to Beaughton Creek is no
longer proposed at this time.
5. Comment:
The Regional Board emphasizes that a program for monitoring the
leachate collection and removal system is needed to ensure
compliance with standards presented in the ROD.
BAXRESUM A-29
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5. Response:
EPA concurs with the comment. The Consent Decree will contain
language regarding the necessity of leachate collection and
removal, and the need to adhere to standards. Specifics on
leachate collection and monitoring will be incorporated into
remedial design and action documents.
6. Comment:
The Regional Board provided additional descriptions of
enforcement actions for inclusion into the ROD.
6. Response:
The additional descriptions were incorporated as appropriate.
Commentor: P. Bontadelli (California Department of Fish and
Game)
Date: July 2, 1990
1. Comment:
The discussion of specific clean-up goals should include health
concerns for people and wildlife.
1. Response:
The clean-up goals assessed by EPA included considerations for
human health and the environment. EPA will not allow discharges
to surface water, surface impoundments, or to groundwater that
exceed health-based standards or levels presented in the Record
of Decision. EPA proposes to excavate contamination from
drainage sediments to background levels to prevent any further
movement of contaminants into Beaughton Creek. EPA does not
propose to remove contaminated sediments from Beaughton Creek
unless results of proposed Creek studies identify the need for
such a removal.
BAXRESUM A-30
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2. Comment:
The Department of Fish and Game is concerned that the proposed
biological treatment method for treating groundwater is subject
to upsets and is difficult to monitor. The Department recommends
"additional organic removal steps" to be included in the
treatment process, particularly if discharge to the Creek is
being considered.
2. Response:
EPA has evaluated several "additional organic removal" or
polishing steps for the initially treated groundwater. EPA is
considering the use of either activated carbon or UV/ozone
destruction of residual organics as the probable polishing step.
EPA agrees that the final polishing steps will provide added
assurance of contaminant removal. However, EPA is not proposing
direct creek discharge at this time and therefore any upsets at
the treatment plant will not directly affect surface water
quality. EPA recognizes the State requirements for surface water
discharge and is considering other options for disposal of the
treated water.
3. Comment:
The Department recommends disposal of treated groundwater to
include industrial process use or indirect discharge through the
use of percolation ponds.
3. Response:
At present, EPA is proposing to use the log-deck sprinkling
system to dispose of treated water during the late spring through
fall months of operation. EPA will use percolation ponds and
direct reinjection for water disposal during the winter months.
4. Comment:
The Department believes that it is appropriate for the
responsible parties to compensate the Department for the loss of
trout fishery due to the past discharges of untreated
groundwater.
BAXRESUM A-31
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4. Response:
EPA concurs.
* * *
C. COMMENTS BY THE RESPONSIBLE PARTIES
Conunentor: J. Morgan III (J.H. Baxter & Company)
Date: June 21, 1990
1. Comment:
Baxter notes that Ammoniacal Copper Arsenate (ACA) should be
added in the Feasibility Study Report to the list of
preservatives formerly used at the plant.
1. Response:
Comment noted.
2. Comment:
Baxter notes that one of the retorts is used for ACZA and D-Blaze
treatment, and the other is used for creosote and ACZA treatment.
2. Response:
Comment noted.
3. Comment:
Baxter notes that the Baxter company was also involved in
sponsoring the bioremediation pilot study, the pump and treat
study, and the current monitoring program.
3. Response:
Comment noted.
BAXRESUM A-32
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4. Comment:
Baxter states that the direct discharge referred to on page 1-22
of the FS consisted of rainwater, not process water.
4. Response:
The direct discharge referred to on page 1-22 was a result of
releases of wastewater from the wastewater vaults and the spray
field, as noted by the NCRWQCB in their field notes from the
early 1980 time period.
5. Comment:
Baxter notes that it also was involved in contracting Sweet
Edwards & Associates to perform field work at the site.
5. Response:
Comment noted.
6. Comment:
Baxter questions the approach used by EPA that incorporates TCDD-
equivalence factors for evaluating the risk due to dioxins at the
site. Baxter offers the use of deed restrictions to preclude
residential use of the site. ,
6. Response:
The dioxins present at the site are a complex mixture of dioxin-
based molecules varying in the degree of chlorinization for each
group of molecules. The toxicity of dioxins is related to the
degree of chlorinization and the location of chlorine atoms on
the dioxin molecules. All dioxins are considered highly toxic
with the 2,3,7,8-TCDD form being the most toxic. EPA has
developed toxicity factors for the other chlorinated dioxins
based on the toxicity of TCDD. When the other dioxins are
present at a site, these factors are used to evaluate the risk of
the mixture of dioxins detected. The use of the TCDD equivalency
risk determination is standard practice for all sites where
dioxins are detected, regardless of whether TCDD is present in
the mixture.
BAXRESUM A-3 3
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In evaluating risks per land use scenarios, the risk assessment
method used by EPA does not allow reliance upon deed restrictions
for controlling public access to a site. EPA will consider
establishment of deed restrictions as a part of the final remedy.
7. Comment:
Baxter does not concur with the concept of treating soil
biologically and then containing the residual soils in a
controlled land disposal unit. Baxter believes that the lower
weight molecules will be destroyed and that the risk due to the
soils will be removed.
7. Response:
The biological treatment process will effectively destroy the
"lighter weight" creosote compounds (i.e., non-carcinogenic
PAHs), but these compounds are actually the less toxic of the
components of creosote. The higher molecular weight PAHs, which
are also the carcinogenic fraction of creosote, are more toxic
and difficult to destroy biologically. Much more treatment time
is required to treat these compounds biologically. The toxicity
of the difficult-to-treat PAHs is the reason EPA is considering
long-term management of the treated soil residuals in a
controlled land unit.
8. Comment:
Baxter has serious reservations about moving plant structures to
access the contaminated soils below the structures, and suggests
using in-place treatment of soils beneath the structures.
8. Response:
EPA's assessment indicates that a temporary or permanent
relocation of the wood treatment structures would be the most
effective means of accessing soils beneath the structures, which
are some of the most contaminated soils at the site. EPA is
willing to determine a time schedule for relocation of structures
that minimizes impacts upon wood treatment operations.
BAXRESUM A-3 4
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Commentor: ChemRisk (ChemRisk was contracted by the responsible
parties to perform an assessment of EPA's
Endangerment Assessment. ChemRisk's comments are
provided in a document entitled: "Technical Review of
the USEPA Region IX Endangerment Assessment for the
J.H. Baxter/IP/Roseburg Forest Products Superfund
Site, Weed, California)
Date: June 29, 1990
Comment 1:
ChemRisk states difficulties in identifying data sets used in the
EPA Endangerment Assessment and reports errors in calculations.
Response l:
EPA's review of the data sets did not identify any problems that
would result in a significant change in the conclusions drawn in
EPA's Endangerment Assessment. ChemRisk's assessment did not
significantly change EPA's primary health-based clean-up
standards, nor the standards based on ARARs or other health-based
criteria stated in the Proposed Plan.
Comment 2:
ChemRisk disagrees with the maximum exposure scenarios used in
determining worst-case risks.
Response 2:
The scenarios used in this Endangerment Assessment were based on
guidance for conducting endangerment assessments available at the
time of development and are therefore consistent with EPA's
endangerment assessment process.
Comment 3:
ChemRisk disagrees with the future-use condition scenarios used
to assess risks at the Site.
BAXRESUM A-35
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Response 3:
The guidance quoted in ChemRisk's comment refers to very rural
sites. The Baxter site does not fit this description. It is
located in a small but populated community with residences
currently located within 100 feet of the property. While there
are alternate residential building sites in the vicinity, there
is no reasonable assurance that the Baxter property would remain
industrial and could not be converted to residential use prior to
completing site remedy.
Comment 4:
ChemRisk disagrees with EPA's approach used to assess toxicity of
PAHs and offers an alternative approach.
Response 4:
The alternative approach referenced by ChemRisk is still in the
peer-review stage and has not yet been generally applied to
Superfund risk assessments.
5. Comment:
ChemRisk states that the Endangerment Assessment did not
incorporate the beneficial effects of current remediation
projects into the Risk Assessment.
5. Response:
The endangerment assessment guidance requires a risk assessment
of baseline conditions (i.e., conditions where no cleanup or
institutional controls have occurred). Therefore current efforts
were not included.
EPA does not agree that the current activities have reduced
overall site risk. At the time of development of this ROD, only
two activities at the site have been implemented to partially
control movement of contamination at the site. These two actions
are Roseburg's french drain water treatment unit and Baxter's
partial surface water control efforts. Both actions are
considered by EPA as temporary source control efforts that do not
address the primary problems at the site. Data on the
BAXRESUM A-36
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groundwater pumping study were not available to assess its
effectiveness relative to risk reduction.
EPA recognizes that Roseburg's activated water treatment unit
during the course of its operation has prevented the continuous
and sometimes catastrophic releases of wood treatment chemicals
that have occurred in the recent past. However, EPA does not
consider either the french drain nor its associated treatment
unit, in their current configurations, a part of the final
remedy. The current system captures contaminated water beyond
the primary source areas and EPA believes that capturing and
treating contaminants at the source would be more effective for
the site.
In addition, the Roseburg treatment system does not treat for
metals. Although water containing arsenic is currently pumped
into the log-deck sprinkler system, there remains a potential for
it being discharged to the Creek. Under the current treatment
scenario, should any of the pumps or the treatment unit fail,
contaminated water would be discharged to the Creek. Moreover,
if the french drain pumps are shut off or fail for a short-period
of time, the groundwater table will rise, flooding the entire
excavation area from the french drain to the cut bank. In the
past when this has occurred, the ponded water eventually seeped
and flowed to the west into the site discharge drainage which
flows past Lincoln Park. Because these possibilities remain
under the current operations at the site, EPA has elected not to
consider the actions under the baseline or future use scenario.
The primary surface water risk posed by the site is a result of
continued releases of water contaminated with metals in runoff
from the wood treatment property. Although Baxter has installed
partial surface water drainage control on a portion of the
property, EPA considers these controls to be inadequate to be
considered as a risk reduction action for the site. The controls
consist of a 6-inch ditch and berm, controlling runoff on a
portion of the property. The location and depth of the ditches
is adequate to control brief precipitation episodes. The ditches
and berms are inadequate to control the intense precipitation
events common to the site area. Contaminated runoff is observed
from the property during average precipitation events and for
these reasons EPA has elected not to consider these partial
controls under any of the risk assessment scenarios.
BAXRESUM A-37
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6. Comment:
The Endangennent Assessment has not incorporated the effects of
natural biological processes on the breakdown of contaminants.
6. Response:
Incorporation of natural biological processes is not included
under EPA's endangerment assessment methodology.
7. Comment:
ChemRisk disagrees with the fugitive dust modeling performed for
the Endangennent Assessment.
7. Response:
EPA's endangennent assessment methodology allows the use of the
most toxic form of a chemical (e.g., chromium VI instead of
chromium III) when data are not available to adequately determine
the form of the chemical in the environment. The modeling
performed by ChemRisk, although showing different results,
supports the conclusions of EPA's assessment that contaminated
dust poses unacceptable risks to the adjacent community.
Therefore, a discussion on the differences between the two
methods is not warranted.
8. Comment:
ChemRisk states that upper-bound estimates of geometric mean
concentrations should have been used instead of maximum
concentrations.
8. Response:
Current EPA guidance recommends that a 95% upper confidence limit
on arithmetic mean concentrations be used to estimate reasonable
maximum exposures. ChemRisk calculated geometric mean
concentrations which can frequently produce much lower values
than arithmetic mean concentrations. EPA's guidance allows for
use of geometric mean values only when the strength of site-
specific data indicates that the data are best described by a
log-normal distribution.
BAXRESUM A-38
-------
Commentor: D. Kerschner (Beazer Environmental Services)
Date: July 2, 1990
1. Comment:
EPA has not provided justification for selection of background
for the clean-up goals. Beazer also contends that EPA's
selection of clean-up levels is not consistent with the National
Contingency Plan (NCP). EPA should use ARARs in selection of
clean-up levels.
1. Response:
Cleanup of the site is primarily being driven by arsenic, a known
human carcinogen, and the carcinogenic PAH fraction of creosote.
For arsenic, the background soil concentration of 8 ppm and
groundwater concentration of 5 ppb (analytical quantification
limit) represent the 1 x 10"5 risk level. Clean-up goals for
carcinogenic PAHs set at 0.51 ppm for soils and 0.025 ppb for
groundwater represent the 1 x 10"6 risk level. However, for
carcinogenic PAHs the practical analytical quantification limit
is 5 ppb which is the groundwater standard. Selection of clean-
up standards within this risk range is consistent with the NCP
range of l x 10"4 to 1 x 10"6 for carcinogens. In addition,
arsenic and carcinogenic PAHs are commingled with all other site
contaminants. Removal and treatment of arsenic and carcinogenic
PAHs to the NCP risk range is expected to remove and treat the
remaining contaminants to essentially background levels. If soil
sampling indicates other contaminants present without elevated
arsenic or carcinogenic PAHs, the other contaminants will be
excavated and treated to health-based standards as outlined in
the Record of Decision.
EPA has selected background as the clean-up standard for
sediments because the NCRWQCB's Basin Plan, which is an ARAR,
does not allow the release of detectable levels of wood treatment
chemicals into the waters of the State. Meeting the requirements
of this ARAR can only be assured through removal of contaminants
to background or non-detect levels.
BAXRESUM A-39
-------
2. Comment:
Risk-based clean-up goals established for the site should be
based on the current industrial-use scenario.
2. Response:
The Superfund Endangerment Assessment process requires EPA to
consider current land use and future land use when performing the
risk assessment. Consideration of the site as a future
residential area is consistent with EPA policy, particularly
given the close proximity of current residences to the site.
3. Comment:
The Proposed Plan should recognize the potential technical
impractability of achieving the groundwater goals. The commentor
references the NCP (55 FR 46:8734) relative to groundwater remedy
uncertainties.
3. Response:
At present there are no data available that would indicate that
the groundwater goals are not achievable. The initial pump and
treatment studies have produced a reduction in contaminant
concentrations indicating the potential effectiveness of this
remedy. Excavation, fixation and containment of contaminated
surface soils is expected to greatly facilitate achievement of
groundwater goals for inorganics. Excavation or other source
control measures for the creosote contamination could also
improve the ability to meet the PAH goals. Natural attenuation
cannot be considered for the site because according to NCP
guidance (55 FR 46:8734), natural attenuation is "recommended
only when active restoration is not practicable, cost effective
or warranted because of site specific conditions (e.g., Class III
groundwater or groundwater which is unlikely to be used in the
foreseeable future)". The NCP also requires EPA to consider
current and potential groundwater usage in this assessment.
Because initial data show groundwater pumping capable of removing
contaminants, that the aquifer is Class I and currently used for
a water supply, the site does not fit the conditions necessary
for consideration for natural attenuation to address the
contamination.
BAXRESUM A-40
-------
Discussion of technical impractability is premature at this. time.
EPA will review the effectiveness of the selected remedies when
EPA performs its 5-year review. The NCP section referenced
requires EPA to seek additional actions that will enhance
recovery of contaminants, if such actions appear to be warranted
(e.g., soil flushing), or plume control through additional
pumping. EPA will implement such measures as necessary to allow
achievement of the goals. The NCP section referenced by the
commentor discusses uncertainty relative to achievement of goals
and the necessity for contingencies in groundwater remedies. The
NCP sections referenced do not present a framework for "technical
impracticability" determinations for inclusion in the Record of
Decision, however.
4. Comment:
The proposed remedy for surface soils contaminated with arsenic
in areas of the site without corresponding groundwater
contamination is not cost effective or consistent with the NCP.
The removal remedy is not warranted and the soils only should be
capped.
4. Response:
The Remedial Investigation groundwater data referred to by the
commentor are now more than 3 years old. Groundwater samples
from new wells installed adjacent to the southeastern edge of the
wood treatment property indicate that the arsenic plume extends
further to the east than is shown on the Remedial Investigation
figures. The direction of groundwater flow to the new wells is
from the eastern portion of the wood treatment property, which is
contaminated with arsenic. These contaminated soils are the only
identified source of the observed groundwater arsenic
contamination. With regard to the spray field soils, the only
monitoring well at the spray field is located at the downgradient
edge of the field. This well is contaminated and thus the source
of contamination must be the upgradient contaminated soils. A
revised arsenic plume map is provided which illustrates the
current extent of the plume. Based on the extent of groundwater
contamination, EPA has concluded that all contaminated soil is
contributing to the groundwater problem. The groundwater table
is very near ground surface throughout the wood treatment
property. Therefore, capping would not be protective of
BAXRESUM A-41
-------
ANEA COMTAMMa
AMSIMC
-------
groundwater, making excavation and treatment the remedy most
consistent with NCP requirements.
5. Comment:
EPA has underestimated the cost of the excavation-fixation-
redisposal remedy by not including some additional factors that
may be necessary. The FS states that RCRA closure requirements
will be included in the implementation of this remedy.
5. Response:
The FS states that the substantive requirements of RCRA will be
met for this alternative, not the specific requirements. The
proposed remedy includes the substantive requirements of RCRA
throughout such as site monitoring, decontamination, closure
plans, closure notifications, post-closure monitoring, etc. as
integral parts of the overall remedy. EPA is not required to
duplicate or perform the RCRA requirements separately for this
remedy. At the time of development of the FS, the necessity for
a liner had not been determined. The treated waste may not be a
RCRA waste. EPA included a contingency cost for a liner in the
overall remedy cost estimate for the situation should a liner
become necessary. If the treated waste meets RCRA treatment
standards, a liner may not be necessary for the long-term storage
of the treated soils.
6. Comment:
The proposed bioremediation remedies appear infeasible.
»
6. Response:
Pilot studies performed by IP and Mississippi State University on
bioremediation of soil and groundwater have produced results
indicating that the remedies will be feasible.
7. Comment:
Remedial Investigation Report: Near surface soil samples (i.e.,
samples of the 1 to 5 foot interval) should not have been
collected with a hand auger due to the problem of surface soil
BAXRESUM A-43
-------
falling into the sample hole and contaminating the near surface
sample.
7. Response:
To collect near surface samples EPA first augered down to the top
of the sample interval using a 4-inch hand auger. The actual
sample was collected with a separate 3-inch auger with sufficient
care to prevent material from above from affecting the sample.
8. Comment:
RI Report: The use of chloride as a surrogate for zinc chloride
is inappropriate.
8. Response:
In the interpretation of zinc data, EPA did not use the chloride
data as a surrogate.
9. Comment:
RI Report: EPA did not provide a basis for the assumption that
5 times t
the site.
9. Response:
5 times the background mean reflects contamination attributed to
This assumption is based on EPA guidance for background
assessment. This guidance reflects the variability in chemical
analyses and background levels.
10. Comment:
RI Report: Beazer disagrees that methylene chloride and bis-2-
ethylhexyl phthalate are contaminants for the site.
10. Response:
Neither of these chemicals are chemicals of concern for the site
BAXRESUM A-44
-------
11. Comment:
RI Report: Beazer states that PAHs in groundwater samples should
not be used as an indication of a creosote body.
11. Response:
EPA used a combination of visual evidence and chemical data to
map the creosote body.
12. Comment:
RI Report: Beazer states that it is not appropriate to discuss
health risks in the RI report.
12. Response:
The discussion of health risks in the RI report is according to
EPA guidance and appropriate for understanding the nature of site
contamination.
13. Comment:
Endangerment Assessment: Beazer makes several comments on the
scope of the Endangerment Assessment.
13. Response:
Substantive comments were addressed in the response to comments
made by ChemRisk The Endangerment Assessment was developed based
on guidance available at the time of its development. New
guidance will not substantially affect the conclusions of the
Endangerment Assessment and revision of the document is not
warranted.
14. Comment:
Beazer states that collection and treatment of surface water
runoff in the interim period until soils cleanup is complete is
unreasonable, unsupported and technically cumbersome.
BAXRESUM A-45
-------
14. Response:
Baxter presently has a 500,000 gallon tank for storage of
contaminated runoff. This storage will be augmented by an
additional 500,000 gallon tank. This storage capacity coupled
with a treatment capacity of 100 gallons per minute in the
adjacent water treatment plant is more than adequate capacity for
typical rain events at the site. Surface water berms and ditches
to control the typical runoff are also easily implemented at the
site, preventing runoff contaminated with arsenic exceeding MCL
concentrations from leaving the site. EPA recognizes that the
interim measures are inadequate to contain a catastrophic rain
fall event, but the benefits of the interim measures provide
significant protection of surface waters prior to implementation
of surface soil cleanup.
15. Comment:
Beazer notes a discrepancy for the action levels for benzene
between the Proposed Plan and FS.
15. Response:
The 10 ppb level for benzene is the 1 x 10"6 risk level as
determined by the Endangerment Assessment for this site. The 1
ppb level for benzene reflects the California MCL, an ARAR.
California MCLs are established at the 1 x 10"6 level as
determined through the State's risk analysis process. It is
important to note that benzene was detected in groundwater in a
well adjacent to a former underground storage tank. Benzene is
not a widespread contaminant at this site.
16. Comment:
There is no reference to the development of remedial goals for
leachate produced from treated soils.
16. Response:
Leachate values are based on regulatory levels and guidance
presented in 40 CFR 268 and in California Title 22 waste
determination regulations.
BAXRESUM A-4 6
-------
17. Comment:
EPA uses the terms "goals", "requirements, and "standards" when
referring to remedial clean-up levels for the site.
17. Response:
EPA will use the term "standards" when referring to clean-up
levels in all future documents related to this site.
* * *
BAXRESUM A-47
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
Page No.
12/27/88
J.H. Baxter Suporfund site
ADMINISTRATIVE RECORD INDEX
Part I of 11
DOC. * DATE FROM/ORGANIZ.
TO/ORGAN 1Z.
DESCRIPTION/SUBJECT
PAGES
170 05/19/70 J. M. Baxter S Co.
Work Order Request
RE: Pollution Control, (J. H.
Baxter S Co. Form)
186 01/23/73 N. Morgan, CA OOFG
Form: Request for Chemical
Analysis and/or Bioassay
Findings on Materials Submitted
(CA OOFG)
171 01/31/73 0. Fick. IPC
U. Rodriguez, CRWQCB
Ltr: Report on the Pond
Cleaning Operation at the IPC,
Ueed, Plant
177 02/05/73 J. Day, CA DOFG
Inspector N.
Dollahite, CA OOFG
Memo: IPC - Pollution of
Beaughton Creek, Siskiyou County
178 02/06/73 CA DOFG
J. Day, CA DOFG
Memo: IPC's Activities In and
Adjacent to Beaughton Creek,
Siskiyou County
A Preliminary Field Report on
Apparent Stream Damage
ISA 02/09/73 R. Hansen, CA OOFG
179 02/26/73 R. O'Brien,
CRUQCB-NCR
180 03/14/73 R. Nilsson, CA DOFG
Regional Manager, CA
OOFG
0. Joseph,
CRWOCB-NCR
N. Dollahite, CA
DOFG
Memo: Additional Chemical
Analyses from Beaughton Creek,
Siskiyou County
Ltr: Tentative Requirements -
I PC-Long Bell Mill, Ueed,
Siskiyou County
Memo: Monitoring of IPC, Long
Bell Division, Weed
181 03/19/73 0. Ahrenholi. CA
OOFG
J. Day. CA OOFG
Memo: Addendum to Report of
[PC's Activities on Beaughton
Creek, Siskiyou County, dated
Feb. 6, 1973
182
03/20/73
Redding Record
Search Iight
Newsclipping: International
Paper Co. Accused of Polluting
Water
183
03/31/73
Redding Record
Searchlight
Newsclipping: No ContMt Picas
Entered in Creek Ca*e
Paper Firm's Reply to Pollution
Charges Scheduled Tuesday
-------
Fj?e No.
12/27/88
J.H. Baxter Superfund Site
ADMINISTRATIVE RECORD INDEX
Part t of II
OOC. « DATE FROM/ORCAN1Z.
TO/ORCANIZ.
DESCRIPTION/SUBJECT
PAGES
185 09/18/73 R. leachman. CA DOFG :Environmental
Services, CA OOFG
Memo: Beaughton Creek
Investigation, Si ski you County
169 07/06/79 C. Rich, CA SSUMB
Files
Memo: Inspection of the Weed
Disposal Site in Siskiyou Co.
(47-AA-019)
172 01/10/80 0. Williams, J. H.
Baxter & Co.
Form: Supervisors Accident
Investigation Report, J. H.
Baxter & Co.
168 06/08/81 J. Flynn, IPC
EPA Region IX
Itr: Transmittal of EPA
Notification of Hazardous Waste
Site Forms
194 06/08/81 I. Hope, J. H.
Baxter t Co.
EPA Region IX
Ltr: Transmittal of EPA Form
8900-1 and a nap in compliance
with Sec. 103
-------
Page NI. 3
12/27/M
J.H. Baxter Supcrfuod Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE fROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
PAGES
222 01/26/84 J. Morgan III, J. H.
Baxter & Co.
D. Miller, Attorney
at Law
Ltr: Transmittal of Analyses of
Matched Samples at J. H. Baxter,
Weed, CA
220 03/13/84 8. Parsons, CA OOHS
0. Williams, J. H.
Baxter & Co.
Ltr: Transmittal of Sample
Results from 1-4 Nov., 1983
Inspection
173
04/01/84
Woodward-Clyde
Consultants
Rpt: Preliminary Investigation
of J. H. Baxter Weed Plant
190
04/01/84
CA DOHS
Evaluation of Organic Chemical
Contaminants in the Groundwater
Supply for the City of Weed, CA
(Mar/Apr 84)
10
192 04/13/84 8. Parsons, CA OOHS
A. Shah, CA DOHS
Memo: Transmittal of Final
Mitre Model Study for J. H.
Baxter & Co.
219 05/04/84 G. Anderson, ANATEC
S. Warner, CWQCB-NCR
Rpt: Transmittal of Results
Water Sampling. J. H. Baxter
1S8 06/25/84 0. Small. CA DOHS
Form: Site Inspection Data
Sheet
Facility Inspection of J. H.
Baxter t Co.
216 07/25/84 8. Ouan. CA DOHS
R. Sato, Office of
the Attorney General
Memo: Laboratory Results and
Sampling/Analysis Data, J. H.
Baxter
22
215
08/14/84
CA DOHS
Form: Sample for Chemical
Analysis
213 09/14/84 R. Bayuk, MO, Dept
of Public Health,
County of Si ski you
R. Zuanziger, Dept
of Public Health,
County of Si ski you
Memo:- Well Sampling - Water
Analysis - J. H. Baxter
174
09/24/84
T. Baily.
Woodward-Clyde
Consultants
J. Morgan, J. H.
Baxter t Co.
Ltr: Groundwater Table Level on
the Baxter Property
Installation of French Drains
-------
J.H. Banter Superfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. « DATE FROM/ORGAN!2.
TO/ORCANI2.
DESCRIPTION/SUBJECT
PACES
212 10/17/84
T. Banathy, Dept of
Health. County of
Si ski you
S. Warner, CUOC8-NCR Memo: Water Sample Results
211 10/26/84
J. Morgan, J. H.
Baxter & Co.
0. Joseph, CWOCB-NCR
Ltr: Transmittal of Analytical
Results from Uells in Weed Area
189 10/30/84
S. Warner.
CRWQCB-NCR
C. Johnson,
CRUOCB-NCH. File
Rpt: Compliance Inspection
Report
J. H. Baxter ft Co.
210 11/28/84 8. Parsons, CA OOHS
T. Baker, Oept of
Public Health,
County of Si ski you
Ltr: Sample Results from Weed
High School Well on J. H. Baxter
Property
U
201 03/01/85 H. Slorme, Roseburg
FPC
Rpt: Monitoring Report by
Roseburg Lumber Company
200 03/20/85 J. H. Baxter ft Co.
Samples Collected at the J. H.
Baxter ft Co. Site
Soluble Metal Analytical
Results
202 05/21/85 F. Reichmuth,
CRWQCB-NCR
C. Johnson, R.
Klamt, CRWOCB-NCR,
File
Ltr: Comparison of Replicate
Samples from the J. H. Baxter
Site, Weed, CA
208 06/13/85 A. Wet(man,
CRWOCB-NCR
F. Reichmuth, C.
Johnson. CRWQCB-NCR.
File
Ltr: Analysis of
Self-monitoring Data from
Roseburg Lumber Co. 7/84-4/85
209 06/21/8S J. Hawley, CH2M HILL
J. Chaney, North
Coast Labs
Rpt: Sample Analysis of Water,
for North Coast Labs
10 07/06/85
J. Killingsworth, J.
V. Kitlingsworth ft
Assoc.
Testimony of Frank Salzler
217 07/15/85 R. MeJunk in, CA OOHS
Rpt: Laboratory Report for
Total Metal Analysis at J. H.
Baxter
103 09/12/85 H. Seraydarian, EPA
Region IX
J. H. Baxter
Ltr: Failure to comply with
(HSUA) requirements. Re: J. H.
Baxter i Co.. Weed Treating
Plant
-------
ije Ho.
12/27/88
J.H. Baxter Supcrfund Sue
ADMINISTRATIVE RECORD INDEX
Part I of I I
DOC. * DATE FROH/ORGANIZ.
TO/ORCANIZ.
DESCRIPTION/SUBJECT
PACES
176 11/U/85 «. Cray. CA DOFC
Rpt: Incident Report
RE: Alter, Change and Divert a
Stream Without Notification to
OOFG
205 12/01/85 J. H. Baxter & Co.
Sampling/Analysis Data, French
Drains, Pizzometers & Wells, J.
H. Baxter & Co.
214 12/10/85
Charts of Sampling Analysis. J.
H. Baxter & Co.
193
12/13/85
C. Flippo, EPA
Region IX
Files
Form: CERCLA 103(c)
Notification Form on J. H.
Baxter Plant, Weed, CA
12/16/85 H. Seraydarian, EPA
Region IX
A. Baxter, J. H.
Baxter
Ltr: Notification of
potentially responsible party
status, request for information
(see response Ur of 6 Feb 86)
12/16/85 H. Seraydarian, EPA
Region IX
P. O'Neil, IP Co.
Ltr: Notification of
potentially responsible party
status, request for information
12/16/85 H. Seraydarian, EPA
Region IX
J. Stephens,
Roseburg Forest
Products
Ltr: Notification of
potentially responsible party
status, request for information.
165 12/20/85 C. Flippo, EPA
Region IX
Files
Site Visit to the J. H. Baxter
Wood Treating Plant. Weed. CA
158 01/21/86 S. Warner,
CRWOC8-NCR
F. Reichmuth,
CRWOCB-NCR, S.
Agarwal, SWRCB, File
Ltr: RCRA CUE Inspection of the
JH8 Plant, Weed, Si ski you County
199 02/05/86 M. Blame, Roseburg
FPC
CUOCB
Ltr: Transimttal of Monitoring
Report by Roseburg FPC
133
C?/12/86
Sweet. Edwards and
Assoc., Inc.
Roseburg Forest
Products
Rpt: Weed Facility Status
Report
166
03/10/86
C. Von Birgen, M.
Jonas, COM
C. Flippo, L. Nash,
EPA Region IX
Memo: Review of the J. H.
Baxter Weed Facility Status
Report. Sweet. Edwards I Assoc.,
Feb. 86
-------
Pag* «io.
12/27/88
J.H. Baxter Suocrfund Site
ADMINISTRATIVE RECORD INDEX
Part 1 of 11
DOC. * DATE FROH/ORGANIZ.
TO/ORCAMIZ.
DESCRIPTION/SUBJECT
PAGES
207 05/13/86 J. Hawley, CH2H HILL D. Williams, J. H.
Baxter & Co.
Rpt: Water Sampling Data. J. N.
Baxter & Co.
160 06/04/86 S. Warner,
CRUOC8-NCR
J. Adams, SUSCB
Memo: Comprehensive Monitoring
Evaluation Report for J. H.
Baxter FaciIity
228 06/04/86 L. Woods, CA OOHS L. Nash, EPA Region
IX
ROC: Air Quality Monitoring at
J. H. Baxter Site
204 06/13/86 0. Williams, J. H. F. Reichmuth,
Baxter t Co. , CUOCB-NCR
Memo: Water Sampling Program
82-142 (1/1/86-6/13/86)
27
4 07/01/86 J. Wactor, EPA
Region IX
M. Fjordbeck, SLC8AT
Ltr: Notification that EPA will
conduct the RI/FS, meeting
advisory for discussion of
comments on Rt/FS workplan.
5 07/21/86 J. Morgan III, J. H. J. Wactor, EPA
Baxter Region IX
Ltr: Description of proposed
fencing, fencing specs attached
167 07/24/86 T. Erler, K/J/C
L. Mash, EPA Region
IX
Plan: Sampling and Analysis
Plan for Selected Beneficial Use
Wells in Vicinity of BIPR Site,
Weed, CA (K/J/C 6090)
159 08/14/86
C. Lichens. E * E,
Inc.
L. Nash, EPA Region
IX
Memo: Preliminary Angel Valley
Sampling, Field Oversight
08/28/86 H. Seraydarian, and
J. Wactor, EPA
Region IX
J. Morgan III, J. H.
Baxter
Administrative Order on consent
under CERCLA
09/03/86
J. Wactor. EPA
Region IX
S. Goldberg, Steptoe
I Johnson, and J.
Gould, SLCBAY
Ltr: Transmittal of J. H.
Baxter and Roseburg Forest
Products fence Consent Order
8 09/08/86 J. Gould, SLC8AT
J. Wactor, EPA
Region IX
Ltr: Comments on fencing order,
signature of concurrence on
changes
175 09/15/86 T. Erler. R. Casias. L. Nash, EPA Region
K/J/C IX
Rpt: Monthly Progress Report
Regarding Activities Performed
in Vicinity of BIPR Site. Weed.
CA
26
-------
fag* "o-
12/27/38
J.H. Baxter Superfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
OOC. * DATE FROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
PACES
10/09/86
J. Uactor, EPA
Region IX
S. Goldberg, Steptoe
& Johnson
Ltr: Change from wood to metal
fencing
203 10/17/86 M. Btontne, Roseborg
FPC
CWOCB
Rpt: Monitoring Reports by
Rosvburg FPC
218
10/28/86
8. Flock, J. H.
Baxter & Co.
T. Sheoord
Notes: Baxter Permit 18771 218
Request for Statement to "Site
Specific Soil Problems"
206 01/09/87 D. Williams, J. H. F. Reichmuth,
Baxter & Co. CUOCB-MCR
Memo: Water Sampling Program
82-142 (5/2/86-1/9/87)
36
134 01/13/87 S. Uarner, CRWOCB
I. Nash, EPA Region
IX
Ltr: Commencement of field work
at Weed site, time frame for the
RI/FS and site mitigation
135 01/23/87 J. Uondolleck, COM
EPA Region IX
Plan: Work Plan for RI/FS at
B/IP/R site. Weed, CA. Vol. I
(technical)
275
124 02/01/87 EPA Region IX
Residents, weed, CA
Fact Sheet on Release of work
Plan Outline to the public
136 02/19/87
J. Grove IV. EPA
Region IX
F. Reichmuth, CRUOC8
Ltr: Transmittat of Final
Version of RI/FS Work Plan for
8/IP/R site
137
02/19/87
J. Zelikson, EPA
Region IX
T. Landis, CA DOHS
Ltr: Transmittal of Final
Version of RI/FS Work Plan for
B/IP/R site
138 02/19/87 EPA Region IX
C. Goqgin, State
Clearinghouse
Ltr: Notification of a Proposed
Superfund Project
143 02/23/87 Office of Governor,
State Clearinghouse
L. Nash, EPA Region
IX
Acknowledgement, State of
California, Project Notification
and Review System, Office of the
Governor
139 03/04/87 K. Black, COM
EPA Region IX
Plan: Sampling and Analysis
Plan for RI/FS B/lP/« site,
weed. CA (final)
-------
?»9' "c.
12/27/88
J.H. Batter Supcrfund Site
ADMINISTRATIVE RECORD INDEX
Part I of 11
DOC. *
DATE
FROM/ORGAN! Z.
JO/ORCANI2.
DESCRIPTION/SUBJECT
PACES
UO
03/05/87
P. Marshall, CA DOHS
L. Nash, EPA Region
IX
Ltr: Comments on "Work Plan for
RI/FS for B/IP/R Site (Jan. 23,
87)"
U1
03/06/87
CA ARB
L. Nash, EPA Region
IX
Ltr: Recommendations on the
Proposed Superfund Project: J.
H. Baxter
142 03/06/87 N. Botts, COM
EPA Region IX
Plan: Ouality Assurance Project
Plan for RI/FS B/IP/R site,
Weed, CA
SO
198 03/12/87 M. Blomme, Roseburg
FPC
101 03/26/87 J. Easton, CRUQCB
144 03/26/87 J. Parnell, CA OOFC
CUOCB
All Regional Board
Executive Officers.
CA UOCB
C. Van Vleck.
Resources Agency
Rpt: Monitoring Reports with
Bioassay's by RFPC
Memo: Procedures to comply with
the "cease discharge"
requirement in the Toxic Pits
Cleanup Act (TPCA)
Memo: Contamination in
Beaughton Creek and the affected
Aquatic Resources by the J. H.
Baxter Site
145 04/01/87 COM
146 04/01/87 N. Richards, CON
EPA Region IX
I. Nash and H.
Burke, EPA Region IX
Rpt: B/IP/R Field Report for 30
the Grounduater and Surface
Water Sampling and Analysis
Program April 87
Plan: Community Relations Plan 30
8/IP/R site, Weed, CA - April 87
147
04/20/87
H. Carlyle, Jr.,
Office of Planning
and Research
L. Nash, EPA Region
IX
Transmittal Sheet Attached
comments as the State Process
Recommendation
111 04/30/87 J. Morgan Ml, J. H.
Baxter
H. Burke, EPA Region
IX
Ltr: Comments on the Community
Relations Plan for the J. H.
Baxter/IP/Roseburg Site in Weed,
CA
149 OS/08/87 K. Black. CON
EPA Region IX
Plan: Surface Soils Sampling
and Analysis Plan for Rl/FS
B/IP/R site. Weed, CA
150
-------
Page No.
13/27/88
J.H. Baxter Supcrfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE FROM/QRCAMI2.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
PAGES
150 05/11/87 F. Reichmuth, CRUOCB J. Grove IV, EPA
Region IX
H8 05/19/87 COM
EPA Region IX
Ltr: Comments regarding State
Toxics Cleanup Act, as applies
to the Weed site
Rpt: Field Report for May 87
Surface Soil Sampling at the
R/IP/R site. Weed, CA
U
110 OS/22/87 L. Nash, EPA Region H. Burke, EPA Region
IX IX
151 05/22/87 S. Warner, CRUOCB
L. Nash, EPA Region
IX
Memo: Response to cornnents
submitted by J. Morgan, J. N.
Baxter & Co., on the B/IP/R
Community Relations Plan
Ltr: Review of Sampls
Description for bore hole
drilling from OAPP
152 06/09/87 COM
EPA Region IX
June 87 Surface Water/Sediment
Sampling and Analysis Plan for
RI/FS 8/IP/R site weed, CA
85
153
06/12/87
L. Levenson, EPA
Region IX
S. Warner, CRUOCB
ROC: Summary of TreatabiIity
Study, meeting
154
06/15/87
R. 01 sen and J.
Hopkins, COM
J. Wondolleck, EPA
Region IX
Memo: B/IP/R site TreatabiIity
Studies for Surface and
Croundwaters
128 06/18/87 COM
EPA Region IX
Field Report for June 1987
Surface Water/Stream Sediment
Sampling at the
Baxter/IP/Roseburg Site, Weed,
CA
13
163 06/18/87 R. Crooks, CA OOHS EPA Region IX
Rpt: Inspection Report
RCRA Major/Generator Inspection
26
164 06/18/87 R. Crooks, CA OOHS
Rpt: Hazardous Waste Management
Report
Interview of Oerrell Williams
162 06/22/87 R. Crooks, CA OOHS
Rpt: Hazardous Watt*
Surveillance and Enforcement
Report
J. H. Baxter t Co.
-------
r.-jr «?.
12/27/38
J.M. Baxter Supcrfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE FROM/ORGAN1Z.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
PAGES
155 06/25/87 COM
I. Levenson, EPA
Region IX
Rpt: Amtnenckneot to Approved
QAPP for RI/FS Air Investigation
B/IP/R Weed. CA
185
104 07/02/87 L. Hogg. CA DOHS
L. Levenson, EPA
Region !X
Ltr: Transmittal of 1985 Part A
from J. H. Baxter & Co.
94 07/06/87 J. Zelikson, EPA L. Hope, J. M.
Region IX Baxter
Ltr: Request for "Information
Regarding Potential Releases
fron Sol'd Waste Management
Units"
156 07/09/87 K. Black, COM
EPA Region IX
Rpt: Final July 87 Subsurface
Sampling/Monitoring Well
Installation. Sampling Analysis
Plan for RI/FS
Z5C
161 07/28/87 R. Crooks, CA OOHS
Activity: Compliance Evaluation
Inspection (CEI)
J. H. Baxter ft Co.
123 08/07/87 J. Grove IV, EPA
Region IX
F. Reichmuth, CRWOCB
Ltr: Implementation of the
Toxic Pits Control Act (TPCA)
and Proposition 65 at the J. H.
Baxter Site
197
08/19/87
J. Hawley, CH2M HILL
M. Blomme, Roseburg
FPC
Rpt: Water Monitoring Reports by
CH2M Hill on Roseburg FPC
23
100 08/31/87 G. McCimis, Land
Treatment Group.
Miss. Forest
Products utilization
Laboratory
J. Arnin, IP Co.
A Laboratory and Field
Demonstration Study for IP Co.
Under 'cover letter Doc. 099
dated 09/04/87
16
105 09/03/87 J. Morgan III, J. H.
Baxter ft Co.
J. Zelikson, EPA
Region IX
Ltr: Refusal to Submit Solid
Waste Management Unit
Information
99 09/04/87 A. Molnar, L. Levenson, EPA
Kennedy/Jenks/Chilto Region IX
n
Cover Letter for Document #100
dated 08/31/87
-------
Page No. "
12/27/88
J.H. Bailer Supcrfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE FROM/ORGAN!?.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
PAGES
98 09/10/87 S. Warner, CRUOCB
M. Blomrae', Roseburg
Forest Products
Ltr: Request for plans
and report concerning Toxic
Pits Cleanup Act (TPCA)
195
09/10/87
D. Ui11iams, J. H.
Baxter & Co.
B. U i11i ams, J. H.
Baxter & Co.
Memo: Water Sampling Program
82-H2. j. M. Baxter & Co.
5C
129
09/16/87
COM
EPA Region IX
Field Report for July 1987
Subsurface Sampling/Monitoring
Uell Installation at the
Baxter/IP/Roseburg Site
14
107 09/18/87 J. Wondolleck
108 09/18/87 K. Black
L. Levenson, EPA
Region IX
L. Levenson, EPA
Region IX
Memo: Additional Soil Sampling
Needs, J. H. Baxter Site
Memo: Summary Field Activity
Report for Subsurface
Sampling/Monitoring Uell
Installation at the
Baxter/IP/Roseburg Sit*
121 09/2 V87 S. Warner, CRUOCB
122 09/21/87 S. Warner, CRWOCB
D. Williams, J. H.
Baxter
L. Levenson, EPA
Region IX
Ltr: Monitoring Wells, and use
of Purge-water in Chemical
Makeup/Recycle System
Ltr: Interim Response Measure
with an "Operable Unit", consent
orders, and Regional Board
orders
92
09/30/87
L. Levenson, EPA
Region IX
J. Morgan, J. H.
Baxter
Ltr: Use of tank to store
purge-water
126
10/01/87
COM
Field Report for October 1987
Surface Water/Ground Water
Sampling at the
Baxter/IP/Roseburg Site
25
102 10/08/87 S. Warner, CRWOCB
F. Reichmuth, and B.
Wolstortcroft. CRWOCB
Assessment of the Oct. 1, 1987,
letter from Hayes, Re: Baxter
and Applicability of TPCA
32
127 10/08/87 COM
EPA Region IX
Final - October 1987 Surface
Water and Ground Water Sampling
and Analysis Plan for Rl/fS
120
-------
ragc No.
12/27/88
J.M. Boxer Superfund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE FROM/ORCANI2.
TO/ORCANIZ.
DESCRIPTION/SUBJECT
PACES
97 10/09/87 Z. Warner, CSUOCB
89 10/19/87 J. Allen, Ph.d., CA
30HS
196 11/18/87 M. Blornne, Roseburg
FPC
96 11/19/87 S. Warner. CRWOC8
N. Hayes, PM & s
K. Takata, EPA
Region IX
CUOCB
E. Reichmuth,
CRWOCB, and File, J.
H. Baxter
Ltr: Applicability of the Toxic
Pits Cleanup Act (TPCA) at the
Weed, CA, Plant
Ltr: Transmittal of J. H.
Baxter/IP Co./Roseburg Site
ARAR's
Ltr: Reports on Monitoring
Status on Samples & Bioassys
Spill of pyresote at the J. H.
Baxter Company
93
11/29/87
K. Black, J.
Uondolleck, and H.
Richards. COM
EPA Region IX
Aquifer Testing Program for
RI/FS. Baxter/IP Co./Roseburg
Site
96
120
12/01/87
S. Warner, CRUOC8
91 12/23/87 J. Zelikson. EPA
Region IX
L. Levenson, EPA
Region IX
J. Morgan, J. H.
Baxter
Ltr: Transmittal of
Self-monitoring Submittals from
J. H. Baxter and Roseburg
Facilities
Ltr: Request to use tank for
storage of purge-water.
(u/attachment)
106 01/20/88 J. Wondolleck
L. Levenson, EPA
Region IX
Memo: Sampling and Analysis
Request for Croundwater, Surface
Water and Soils Sampling
H
125 02/01/88 COM
Field Report for February 1988
Surface Water/Croundwater
Sampling at the
Baxter/IP/Roseburg Site
22
119 02/02/88 EMTRIX. Inc.
Vadose Zone Characterization
Work Plan
95 02/11/88 0. Evans. CRWOCB
M. Blomme', Roseburg
Forest Products
Ltr: Procedures and Precautions
to be followed by Roseburg
Forest Products when releasing
contaminated stortMter
-------
U/27/83
J.H. Baxter SupcHund Site
ADMINISTRATIVE RECORD INDEX
Part I of II
DOC. * DATE
FROM/ORGANIZ.
TO/ORGANIC.
DESCRIPTION/SUBJECT
PAGES.
90 02/12/83 L. Levenson, EPA J. Morgan, J. H.
Region IX Baxter
Ltr: EPA Rl, j. H. Baxter
Facility, Weed, CA (creosote)
soil borings end drum storage
of contaminated soil
117 02/17/88 L. Levenson, EPA
Region IX
118 02/17/88 L. Levenson, EPA
Region IX
C. Stacey, CA DOFG
0. Palawski, USFUS
Ltr: Threatened or Endangered
Species at J. H. Baxter
Superfund Site, Weed, Si Ski you
County, CA
Ltr: Threatened or Endangered
Species at J. H. Baxter
Superfund Site, Weed, Si ski you
County, CA
116
02/19/88
L. Levenson, EPA
Region IX
P. Marshall, CA DOHS
Ltr: ARAR's at the J. H.
8axter/IP/Roseburg Site
115 02/20/88 M. Blomne', Roseburg
Forest Products
0. Evans, CRUOC8
Ltr: Detailed Plan on
Procedures and Precautions
Roseburg FPC will follow when
discharging at 001
109 03/04/88 0. Fuller. COM
113 03/11/88 A. Haylor
File
B. Kor, CRWOCB
Memo: Boring on Baxter Facility
with ENTRIX
Ltr: Status of Fishery
Resources in Beaughton Creek,
need for Fish Contamination
Studies and a Contingency Plan
for Temporary Pollution
Abatement
112 04/11/88 P. Marshall, CA DOHS
130 0^/28/88 L. Levenson, EPA
Region IX
L. Levenson, EPA
Region IX
8. Parsons, CA DOHS
Ltr: Transmittal of Part of
California Code of Regulations
Ltr: -Storage of Rl/FS Soil
SampI ing Residue
10
131 05/02/88 J. Morgan III, J. H.
Baxter
L. Levenson, EPA
Region IX
Ltr: Transmittal of Information
from Lopat Enterprises. Inc.
concerning their Fixation
Process for Heavy Metals in Soil
38
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Page No. 1
06/11/88
DOC. t DATE
J. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
FROM/ORGANIZ.
TO/ORGAMIZ.
DESCRIPTION/SUBJECT PAGES
12 02/06/86
S. Goldberg,
Steptoe &
Johnson, JHB
Attorneys
C. Flippo. EPA
Region IX
13 05/28/40
14 //
15 12/28/62
16 05/08/83
17 09/27/63
18 07/05/68
t
19 09/17/74
20 02/27/75
American Lumber £
Treating Co.
0. Lewis, J. H.
Baxter
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
Cover Ltr: JHB 13
Response to 16 Dec 65
Information Request
from EPA Region IX,
Response *1000000 JHB
(p. 1 of 76), R.O.C
5/19/88 attached
Schematic Plan of 1
Treating Building,
American Lumber £
Treating Co.,
Response tlOOOOOl JHB
Oil Spillage Control 1
System Blueprint,
response 11000002 JHB
Piping diagram, 1
Retort Mo. 1 only,
sheet 1 of 2,
Response 11000003 JHB
Piping diagram, 1
Retort Mo. 2 only,
sheet 2 of 2,
Response §1000004 JHB
Proposed 1
rearrangement ~ Weed
plant piping, tort
No. 1, sheet 1 £ 2,
response §100C 3 JHB
Pump pit for Weed 1
Retort, schematic,
response §1000006 JHB
General Arrangement 1
Layout of tha Oil
Spillage Control
System, response
§1000007 JH§
Oil Spillage Control 1
System schematic,
sheet 3 of 4,
response §1000008 JHB
-------
* Ho.
11/88
J. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. » DATE
FROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
21 05/05/75
22 //
23 //
24 05/31/83
25 //
26 //
27 02/07/86
A. Jacobs, J. H.
Baxter
A. Jacobs, J. H.
Baxter
J. H. Baxter
R. Funkhouaer, IP C. Flippo, EPA
Co, Region IX
Oil Spillage Control
System schematic,
sheet 2, response
1000009 JHB
Copies of site
photos, response
11000010-29 JHB
Aerial photo,
response ft1000030 JHB
Schematic Flow
Diagram of Process
Piping, response
§1000031 JH§
Site phots, response
1000032-75 JHB
General Arrangement
Layout of Oil
Spillage Control
System, response
1000076 JH§
Cover Ltr: IPC
Response to 16 Dec 86
Information Reguest,
response 12000000 IPC
(p. 1 of 332)
28 12/10/85 B. Kor, CRWQCB
R. Funfchouser, IP Ltr: Trans«ittal of
Co. copies of 3 Regional
Board Cleanup Orders,
and copies of file
reference materials,
response «2000001-117
I PC
29 12/31/77
30 05/16/84
D. Coleman,
Coleman
Consortium
Piemme & Bryan
Inc.
IP Co.
J. Rosenthal, IP
Co.
Preliminary Report:
Lands of
International Paper
Co., response
2000116-175 IPC
Ltr: Transmittal of
analytic results,
response 12000176-181
IPC
20
1
1
44
1
117
57
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Page No. 3
J6/11/88
J. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. I DATE
31 11/26/85
FROH/ORGANIZ.
S. Berdine, IP
Co.
32 06/12/78 R. Hood, IP Co.
33 07/11/85 CRWOCB
34 / /
35 / /
36 05/04/60 IP Co.
»
37 07/31/62
38 //
TO/ORGANIZ.
S. Bhagwat. B.
Funkhouser, and
A. Lindaey, IP
Co.
L. Brown, B.
Rexses, and 6.
Stark, IP Co.
IP Co.
DESCRIPTION/SUBJECT PAGES
Memo: Transmittal of 18
memos regarding Jan
1973 drawdown of IP &
OG pond incident,
responses
t2000182-199 IPC
Memo: Reminder to 16
track use of
chemicals,
Instructions for
Spill Control Plan,
and Water Pollution
Control Act Sections
on Designation and
Removability of Haz.
Substances, response
2000200-215 IPC
Regional Board 100
Meeting, 11 Jul 85,
with Executive
Officers Summary
Report, response
1216-316 IPC
Land acreage map, 1
response 12000317 IPC
Hap sections of 11
International Paper
Co. property,
responses 1318-328
IPC
Hap: Plot of Land 1
transferred to Wood
Preserving Division,
response 12000329 IPC
Hap: Survey of T41H, 1
R5W, Sec. 1, response
12000330 IPC
Aerial photo: 1
Roseburg Excavation
response 12000331 IPC
-------
P'
No.
1/88
J. H. BAXTER £ CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. t DATE
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
39 04/30/83 J. H. Baxter
40 01/14/86 J. Gould, SLCBAY, J. Flippo, EPA
Attorneys for Region IX
Roseburg
41 01/14/86 SLCBAY
42 01/14/86 SLCBAY
43 01/14/86 SLCBAY
44 01/14/86 SLCBAY
45 01/14/86 SLCBAY
46 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
Hap: Monitoring 1
sites, response
2000332 IPC
Cover Ltr: Roseburg 359
Forest Products Co.
Response to 16 Dec 85
EPA info request.
Includes Docs. 140-88
and 1132. Cover Ltr
w/Environaental
Operating Procedures
Manual, 13000000-356
(File 1)
Waste Water 12
Recirculation Svste*
File letters and
notes, response
13000360-371 RFPC
(File 2)
Aerial photos, 4
response 13000372-375
RFPC (File 3)
Proposed solid vaste 36
disposal sites file,
response 3000376-411,
RFPC includes use
pereit, laps,
discharge
requirements (File 4)
Solid Vaste Disposal 0
Sites File, misc.,
response*
3000412-620 RFPC
(File 5)
Hater Pollution File, 260
1977-78, «isc.,
response 3000621-880
RFPC (File 6)
Hazardous Materials 87
File, response
3000881-967 RFPC
(File 7)
-------
Page No.
06/11/88
. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II PRP Responses to EPA
Information Requests
DOC. DATE
FROM/ORGANIZ.
TO/ORGAMIZ.
DESCRIPTION/SUBJECT PAGES
47 01/14/86 SLCBAY
48 01/14/86 SLCBAY
49 01/14/86 SLCBAY
50 01/14/86 SLCBAY
51 01/14/86 SLCBAY
52 01/14/86 SLCBAY
53 01/14/86 SLCBAY
54 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
Pond Elevations File, 4
maps, response
3000968-971 RFPC
(File 8)
Chemical Pollution 4
File, letter,
response 13000972-975
RFPC (File 9)
Hater Pollution File, 305
1969-73, aisc.,
response
3000976-1280 RFPC
(File 10)
Creosote Tank 9
Treating File, 1953,
isc., response
3001281-1289 RFPC
(File 11)
Deck Run-off Pond 24
File: Diagrams of
Solid Waste Disposal
Sites, PCB site info.
response
3001290-1313 RFPC
(File 12)
Chemicals used on 29
plant file, letters
and tables, response
3001314-1342 RFPC
(File 13)
Powerhouse Chemicals 7
File, material safety
sheets and
descriptions for
Balanced Polymer*
and 'Corrogen*,
response
3001343-1349 RFPC
(File 14)
Accidental Spills and 178
Discharges file,
1974, Misc.,
Responses
3001394-1561 RFPC
(File 16)
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No.
0_..1/88
J. H. BAXTER & CO. SUPERFUNO SITE
Adainistrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. DATE
FRON/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
55 01/14/86 SLCBAY
56 01/14/86 SLCBAY
57 01/14/86 SLCBAY
58 01/14/86 SLCBAY
59 01/14/86 SLCBAY
60 01/14/86 SLCBAY
61 01/14/86 SLCBAY
62 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Regipn IX
EPA Region IX
EPA Region IX
Solid Waste Perait 3
Data file.' 1981, site
photos. Response
3001562-1564 RFPC
(File 17)
Solid Waste Perait 270
file, 1982, Misc.,
Response
3001565-1834 RFPC
(File 18)
Roseburg 104 347
Subsjittals file,
Response
3001835-2181 RFPC
(File 19)
Perait Package to 44
Dallas file, Misc.,
Response
13001350-1393 RFPC
(File 15)
Rpt: Annual Report 200
of Water Monitoring
Data at Weed, CA -
1974, Response
3002182-2342 RFPC
(File 20)
Rpt: IP Co., Weed, 174
CA., Monitoring
Report for Jan. 1978,
Response
3002343-3002518 RFPC
(File 21)
Rpt: IP Co., Weed, 45
CA, Monitoring Report
for D«c. 1977,
Response
3002519-2564 RFPC
(File 22)
Rpt: Excessive Smoke 5
Stack Emissions at
the Weed, CA, Plant,
Response
3002565-2570 RFPC
(File 23)
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'age No.
6/11/88
J. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. t DATE
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
63 01/14/66 SLCBAY
64 01/14/86 SLCBAY
65 01/14/86 SLCBAY
66 01/14/86 SLCBAY
67 01/14/86 SLCBAY
68 01/14/86 SLCBAY
69 01/14/86 SLCBAY
70 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
Ltr: Treatment of 5
Storm Water Runoff.
Response
3002571-2576 RFPC
(File 24)
Ltr: Status Report - 22
EOS - West, Response
3002577-2599 RFPC
(File 25)
Ltr: Testimony 73
Relative to proposed
NPDES Permit - Heed,
CA, Response
3002600-3002673
(File 26)
Ltr: Enforcements of 142
Environmental
Regulations, Response
3002674-2816 RFPC
(File 27)
Ltr: Extension of 84
Waste Water Discharge
Permit, Response
3002817-2901 RFPC
(File 28)
Ltr: Transmittal of 74
Tentative Revised
Permit for the IP
Co., at Heed, CA,
Response
3002902-2976 RFPC
(File 29)
Ltr: Transmittal of 133
Hater Monitoring
Report, Response
3002977-3110 RFPC
(File 30)
Cyclone Oust 71
Emissions Data, 1978
file, Response
3003111-3182 RFPC
(File 31)
-------
4 a
36,
o.
.88
J. H. BAXTER £ CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. DATE
FROM/ORGANIZ.
TO/OR6ANIZ.
DESCRIPTION/SUBJECT PAGES
71 01/14/86 SLCBAY
72 01/14/86 SLCBAY
'73 01/14/86^ SLCBAY
74 01/14/86 SLCBAY
75 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
76 01/14/86 SLCBAY
77 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
Cyclone Dust Emission 18
Data, Response
3003183-3201 RFPC
(File 32)
Oil Storage info at 10
Heed, CA, Response
t3003202-3212 RFPC
(File 33)
Ltr: TransBittal of 37
1977-1982 Semi-Annual
Solid Haste Disposal
Monitoring
Requirements, IP Co.,
Weed, CA, Response
3003213-3250 RFPC
(File 34)
Request Bids for 24
Construction of
Structure for Storage
of Herbicides,
Response
3003251-3275 RFPC
(File 35)
Misc. documents 21
concerning Air
Pollution Cyclone
Filters, Response
3003276-3297 RFPC
(File 36)
Environmental 14
Compliance - Air,
Heed, CA, Response
3003298-3312 RFPC
(File 37)
Proposed ammendments 17
to Chapter 1, Part
III of Title 17,
California
Administrative Code,
Re: The Emission of
Toxic Air
Contaminants,
Response
3003313-3330 RFPC
(File 38)
-------
Page No.
06/11/88
J. H. BAXTER & CO. SUPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. t DATE
FROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
78 01/14/86 SLCBAY
79 01/14/86 SLCBAY
80 01/14/86 SLCBAY
81 01/14/86 SLCBAY
32 01/14/86 SLCBAY
83 01/14/86 SLCBAY
84 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
Status of Emissions 34
from Factory
Cyclones, Response
3003331-3365 RFPC
(File 39)
Ltr: NPDES Permit 5
Modification,
Response
3003366-3371 RFPC
(File 40)
Misc. documents 22
concerning Water
Analysis, Response
3003372-3394 RFPC
(File 41)
IP Co., Weed, CA, 77
Monitoring Report for
December 1979,
Response
13003395-3472 RFPC
(File 42)
Purchase Order to 2
Test and Analyze
Water Samples,
Monitoring Program,
1981 file, Response
3003473-3474 RFPC
(File 43)
Permits, Monitoring 232
Procedures, and
Sampling Reports
Hater Pollution,
1975 file. Response
3003475-3707 RFPC
(File 44)
Ltr: Transmittal of 274
Tentative Waste
Discharge
Requirements
Water Pollution,
1974 file, Response
3003708-3982 RFPC
(file 45)
-------
No.
/88
10
J. H. BAXTER & CO. SKPERFUND SITE
Administrative Record File Index
Part II -- PRP Responses to EPA
Information Requests
DOC. *
DATE
FROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
85 01/14/86 SLCBAY
EPA Region IX
86 01/14/86 SLCBAY
87 01/14/86 SLCBAY
88 01/14/86 SLCBAY
'2 01/14/86 SLCBAY
EPA Region IX
EPA Region IX
EPA Region IX
EPA Region IX
Permits, Monitoring 377
Procedures, and
Samples
Water Pollution,
1973 file. Response
13003983-4360 RFPC
(File 46)
Vater Monitoring Data 60
for 1978, Response
*3004361-4421 RFPC
(File 47)
Environmental Status 68
Reports, Response
13004422-4490 RFPC
(File 48)
Hater Monitoring 139
Reports for 1981,
Response
13004491-4530 RFPC
(File 49)
Maps: Maps, 25
Blueprints, and
Aerial Photos, Weed,
CA Area,
10/70-4/30/85,
13004531-4557 RFPC
(File 50Available
for Review at U.S.
EPA Region IX)
-------
Page Mo. 1
10/14/88
OOC. t DATE
J. H. BAXTER fi CO. SUPERFUND SITE
*««d. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROM/ORGANIZ.
TO/OR6ANIZ.
DESCRIPTION/SUBJECT
No. ol
'PAGE*
02/64/80
01/18/83
04/05/83
04/19/83
08/15/83
8 05/04/84
9 06/08/84
10 06/08/84
E. Gross,
American Hell
Drilling & Puep
Service
J. Havley, CH2M
Hill
03/24/83 CRWOCB-NCR
S. Warner,
CHWQCB-NCR
S. Warner,
CRHQCB-NCR
D. Dragan, CH2M
Hill
12/02/83 D. Ssall, DHS
G. Anderson,
ANATEC
A. Platt, EPA
Region IX
D. Ssall, DHS
J. Morgan* J. H.
Baxter Co.
C. Johnson,
CRVOCB-RCR
C. Johnson,
CRWQCB-NCR
J. Morgan, J. H.
Baxter Co.
B. Parsons, DHS
S. Varner,
CRVQCB-NCR
E. Parbas, DHS
FORM - Water Well
Drillers Report re:
William & Mary Collier
FORM - Specific
Analysis re: Water
Saaples
RPT - Executive
Officer's Sussary
Report re: Wast*
Discharge Requirements
for J. H. Baxter and
Cospany
MEMO - Inspection of
J. H. Baxter, Mar. 1,
1983
MEMO - Inspection of
J. H. Baxter, Weed,
Mar. 21-22, 1983
LTR - Transeittal re:
Description of Field
Soil Sampling
MEMO - ISD and General
Inspection and
Sampling at J. H.
Baxter and Co.,
Sisklyou County
Transaittal of Results
Foras - HRS, FIT
Quality Assurance Teas
ROC - Phone Call re:
City Wells which
supply vater to Weed
in addition to a
spring
21
-------
.1
Page No.
18/14/88
DOC. f DATE
J. H. BAXTER & CO. SUPERFUND SITE
Weed, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. of
PACES
11 66/28/84 C. Andrews,
Woodward-Clyde
12 97/16/84 C. Andrews,
Woodward-Clyde
13 98/91/84 Voodward-Clyde
14 19/18/84 CH2M Hill
IS 91/17/85 R. Casias,
Woodward-Clyde
16
17
91/22/85
82/06/85
R. Casias,
Woodward-Clyde
T. Bally,
Woodward-Clyde
18 64/81/85 Woodward-Clyde
J. Morgan, J. H.
Baxter Co.
D. Joseph,
NCSWQCB
D. Williais, J.
H. Baxter Co.
D. Joseph,
NCRWQCB
D. Joseph,
NCRWQCB
J. Morgan, J. H.
Baxter Co.
LTR - Suggested
ethods for
accomplishing
additional site
characterization and
cleanup
LTR - Weed, CA, Wood
Treating Facility re:
Arsenic Data
Sueeary -
Hydrogeologic
Activities at the J.
H. Baxter Weed
Facility
Specific Analysis -
Water
LTR * Transeittal re:
Proposed Scope of Work
for Reconnaissance
Level Groundwater
Saspling
LTR - Transeittal re:
Drawings to accoepany
reconnaissance
sampling proposed for
J. H. Baxter
LTR - Purpose of
proposed study to
define the areal
extent of the PAH
pluae
Sueeary - Level
Groundwater Sampling
Activities at the J.
H. Baxter Ve«d
Facility
-------
Page Ho. 3
10/14/88
DOC. * DATE
J. H. BAXTER & CO. SUPERFUND SITE
»««d, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. o
"PAGE. ,
19 11/12/85
20 11/22/85
21 12/29/85
22
23
24
25
26
27
28
12/20/85
91/01/86
91/16/86
01/16/86
02/09/86
02/12/86
02/21/86
Sweet, Edward* &
Assoc., Inc.
C. Flippo, EPA
Region IX
C. Flippo, EPA
Region IX
C. Flippo, EPA
Region IX
T. Brode, EPA
Region IX
J. H. Baxter Co.
C. Flippo, EPA
Region IX
F. R«ich«uth,
CRVQCB-NCR
S. Chang
Sweet, Edward* £ Roseburg Forest
Assoc., Inc. Product*
D. Williams, J. F. Reichmuth,
H. Baxter Co. CRWOCB-HCR
FORM - Boring Log, NE
of Roseburg's
Powerhouse
MEMO - Hoies not
connected to the
city's water supply
system
MEMO - Clarification
aa to what i« the
Sampling Point
Identified in lab
report* a* the "acraen
hou*e*
MEMO - ROC re: Dan
To*i, owner of the
water supply *y*tea in
the Carrick Addition
HAP - Composite Map
fro» U.S.G.S, Veed
Quadrangle, CA
RPT - RCRA Inspection
Report
Analytical Recult* -
Water level* in the
four aonitoring well*
and seven boring*
MEMO - Trancaittal re:
Laboratory Report
RPT - Ve*d Facility
Status Report,
Preliminary
HEHO - Water Saepling
Program 82-142
23
-------
Page No.
10/14/88
DOC. t DATE
J. H. BAXTEB « CO. SUPERFUND SITE
Weed, California
ADMINISTRATIVE BECORD INDEX
Supplement No. 1
FROH/OBGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. of
PAGES
29
S. Heare, EPA
Region IX
31
32
33
34
35
36
37
38
97/61/86
61/23/87
64/36/87 D. Williaas, J.
H. Baxter Co.
66/16/87 J. Wondolleck,
EPA Region IX
Siskiyou County
Health Dept.
L. Levenson, EPA
Region IX
66/18/87 P. Marshall, DHS L. Levenson, EPA
Region IX
68/11/87 K. Kitchingean, J. Grove, EPA
EPA Region IX Region IX
68/11/87 K. Kitchingaan, J. Grove, EPA
EPA Region IX Region IX
69/23/87 1C. Kltchlngaan, J. Grove, EPA
EPA Region IX Region IX
69/24/87 K. Kitchingaan, J. Grove, EPA
EPA Region IX Region IX
69/25/87 K. Kitchingean, J. Grove, EPA
EVA Region IX Region IX
MEMO - J. H. Baxter - 7
Veed, CA re: inclusion
on the NPL
PLAN - Vork Plan for 3
RI/FS, JHB/IP/Roaeburg
Site, Veed, CA, Vol. I
(Technical)
FORM - Underground 4
Storage Tank Closure
Application
MEMO - Transaittal of S
Surface and
Groundvater Data fro*
March Sampling Event
LTR - Tranaaittal of 13
Report (w/o enclosure)
MEMO - Review of 28
Analytical Data re:
RAS Metals
MEMO - Review of 46
Analytical Data re:
RAS VOA and SV » SAS
PCP t
Tetrachlorophenols
MEMO - Review of 35
Analytical Data re:
Volatiles and
Seeivolatilea
MEMO Review of 14
Analytical Data re:
BAB Metal*
MEMO - Review of 33
Analytical Data rat
Volatile* and
8a*lvolatilaa
-------
Page Bo.
10/14/88
DOC. DATE
J. H. BAXTER 6 CO. SUPERFUND SITE
weed, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROH/ORGANIZ.
TO/08GANIZ.
DESCRIPTION/SUBJECT
Ho. of
PAGES -
39 11/04/87 K. Kitchingaan,
EPA Region IX
40 11/13/87 K. Kitchingman,
EPA Region IX
41 11/13/87 K. Kitchingman,
EPA Region IX
42
44
45
46
11/18/87 EPA Region IX
43 12/03/87 K. Kitchingaan,
EPA Region IX
12/11/87 K. Kitchingaan,
EPA Region IX
12/11/87
01/11/88
K. Kitchingaan,
EPA Region IX
D. Oavald, CH2H
Hill
47 91/18/88 D. Oavald, CH2H
Hill
48 01/26/88 K. Kitchingaan,
EPA Region IX
49 01/26/88 K. Kitchingaan,
EPA Region IX
J. Grove/ EPA
Region IX
J. Grove, EPA
Region IX
J. Grove, EPA
Region IX
J. Grove, EPA
Region IX
J. Grove, EPA
Region IX
J. Grove, EPA
Region IX
B. Curnow, EPA
Region IX
L. Levenaon, EPA
Region IX
MEMO - Review of 15
Analytical Data re:
RAS Metals
MEMO - Reviev of 6
Analytical Data re:
Aniona, and TDS - SAS
MEMO - Review of 19
Analytical Data re:
Dioxin & Furana
Rational Priorities 16
Llat - J. H. Baxter
Co.
MEMO - Review of 8
Analytical Data re:
Inorganica (RAS
Hetala)
MEMO - Review of 10
Analytical Data re:
Hetala (5/19-5/21)
MEMO - Review of 6
Analytical Data re:
Hetala (5/20)
RPT - Quality 38
Aaaurance Report re:
J. H. Baxter Site
RPT - Quality 64
Aaaurance Report re:
J. H. Baxter Site
HEHO - Review of 24
Analytical Data re:
Organic*
MEMO - Review of 48
Analytical Data re:
Organic*
-------
Page do.
16/14/88
DOC. DATE
J. H. BAXTER « CO. SUPERFUND SITE
feed. California
ADMINISTRATIVE RECORD INDEX
Supplement Ho. 1
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. of
PAGES
56 81/28/88 K. Kitchingean, B. Curnow, EPA
EPA Region IX Region IX
51 61/28/88 K. Kitchingean, B. Curnow, EPA
EPA Region IX Region IX
52 81/28/88 K. JCitchingean, B. Curnov, EPA
EPA Region IX Region IX
53 82/18/88 K. Kitchingaan, B. Curnow, EPA
EPA Region IX Region IX
54 03/17/88 S. Siepson, EPA D. Binghae, EPA
Region IX Region IX
55 04/08/88 K. Kitchingean, B. Curnow, EPA
EPA Region IX Region IX
56 04/12/88 K. Kitchingian, B. Curnow, EPA
EPA Region IX Region IX
MEMO - Review of 27
Analytical Data re:
Metala
MEMO - Review of 26
Analytical Data re:
Metala
MEMO - Review of 37
Analytical Data re:
Metals (8/4/87-9/8/87)
MEMO - Review of 22
Analytical Data re:
Dioxins £ Furan*
MEMO Request for 19
Data Review re: TOC
Dioxins
MEMO - Review of 11
Analytical Data ret
Total Metal*
MEMO - Review of 5
Analytical Data re:
COD, TOC, Oil and
Grease
57
04/21/88 6. Ricoll, ICF
58
59
05/06/88 D. Oswald, CH2M
Hill
95/19/88 A. Raylor, DOFG
B. Kor,
CBVQCB-MCR
RPT - Quality
Assurance Report -
RAS, Metals and
Chloride re: J. H.
Baxter Site
RPT - Quality
Assurance Report re:
J. H. Baxter Site
LTB - DOFG concurs
with proposed Order
88-74
14
24
13
-------
Page So.
18/14/88
DOC. t DATE
J. H. BAXTER ft CO. SUPERFUHD SITE
Ve«d. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. o;
"PAGEi
66
95/28/88 L. Woods, DHS
61
62
63
64
65
66
67
95/29/88 L. Wood*, DHS
65/25/88
95/25/88
66/08/88
06/09/88
K. Kitchingman,
EPA Region IX
B. Kor,
CRHQCB-NCR
86/61/88 CD»
S. Hear*, EPA
Region IX
J. Morgan, J. H.
Baxter Co.
66/20/88 J. Clifford, EPA
Region IX
L. Levenson, EPA
Region IX
L. Levenson, EPA
Region IX
B. Curnov, EPA
Region IX
Roseburg Forest
Products
U.S. EPA
L. Levenson, EPA
Region IX
J. George*, I.P.
LTR - Report on the
industrial hygiene
survey conducted at
the Baxter Hood
Treatment Facility,
Weed, CA on Nov.
19-20. 1985
LTR - Report on the
industrial hygiene
survey conducted at
the Baxter Facility,
Nov. 19-26, 1985
HEHO - Revie* of
Analytical Data re:
Dioxins
Order No. 88-74
Requiring Roseburg
Forest Products to
Cease and Desist from
discharging vastes
contrary to order No.
86-46 and the Toxic
Pits Cleanup Act
RPT - Preliminary
Draft RI Report for
Baxter Site. Heed, CA
MEMO - Eligibility of
J. H. Baxter Site for
listing on the BPL
LTR - Additional
Information Concerning
Responsible Parties
and Contamination
History at Heed Site
LTR - EPA is
continuing to propose
the J. B. Baxter Site,
Heed, CA to the
Superfund lational
Priority List
15
600
-------
Pag* Bo.
18/14/88
DOC. » DATE
j. H. BAXTER fi CO. SUPERFUND SITE
Veed, California
ADHIMISTRATIVE RECORD INDEX
Supplement Ho. 1
FBOM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. of
'PAGES
68
69
70
71
72
73
96/29/88 J. Clifford, EPA V. Martinell, J.
Region IX H. Baxter Co.
96/29/88 J. Clifford, EPA J. Stephens,
Region IX Roseburg Forest
Products
06/22/88 J. H. Baxter Co. CRVQCB-NCR
96/23/88 D. Evans,
CRVQCB-NCR
96/23/88 D.' Evans,
CRVQCB-NCR
96/24/88 K. Kitchingman,
EPA Region IX
H. Bloaee,
Roseburg Forest
Products
D. VilliaM, J.
H. Baxter Co.
B. Curnow, EPA
Region IX
LTR - EPA is
continuing to propose
the J. H. Baxter Site,
Veed, CA to the
Superfund National
Priorities List
LTR - EPA is
continuing to propose
the J. H. Baxter Site,
Veed, CA to the
Superfund National
Priorities List
RPT - Toxic Pits
Cleanup Act
Hydrogeologic
Assesssent Report for
the J. H. Baxter Veed
Treatment Facility,
Veed, CA
LTR - re: abandoning
three monitoring veils
located on Roseburg's
property in Veed, CA
LTR - re: abandoning
two monitoring wells
located on J. H.
Baxter's property in
Veed, CA
MEMO - Review of
Analytical Data re:
Hetals
799
74 96/39/88 K/J/C, Inc.
75 96/30/88 P. Fahrenthold, L. Uvenson, EPA
Fahrenthold t Region IX
Assoc., Inc.
Bioreaediation 125
Demonstration Study/
Veed, CA, J. H. Baxter
Superfund Sit*
LIB - Btviw of IX 17
port r«s Baxter Site
-------
Page lo.
10/14/88
DOC. DATE
J. H. BAXTER & CO. SUPERFUND SITE
Ve«d. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROM/ORGANIZ.
TO/OBGAMIZ.
DESCRIPTION/SUBJECT
No. of
"PACES
76 87/86/88 J. Morgan, J. H.
Baxter Co.
77 07/87/88 B. Kor,
CRWGCB-NCR
78
79
86
81
82
83
84
97/67/88 P. Marshall, DHS
07/08/88 D. Critchfield,
I.P.
07/27/88 L. Levenson, EPA
Region IX
08/02/88 J. Morgan, J. H.
Baxter Co.
08/09/88 D.' Evans,
CRWQCB-NCR
09/08/88 B. Kor,
CRVQCB-NCR
09/08/88 B. Kor,
CBVQCB-MCR
L. Levenaon, EPA
Region IX
A. Strauss, EPA
Region IX
L. Levenson, EPA
Region IX
L. Levenson, EPA
Region IX
Members of the
JHB/IP/R
Interagency/PRP
Group
L. Leveriuon, EPA
Region IX
J. Morgan, J. H.
Baxter Co.
J. Stephens,
Roseburg Forest
Products
J. Morgan, J. H.
Baxter
LTR - J. H. Baxter
Comments on Draft RI
Report for Weed, CA
Site
LTR - Comments on
EPA's Preliminary
Draft RI Report re:
Baxter Site
LTR - Consents on
Draft RI Report re:
Baxter Site
LTR - Comments on
Draft RI Report
LTR - Summary of
Interagency/PRP
Meeting, 7/27/88,
Further EPA Activities
LTR - Transmittal of
copies of invoices
from Entrix concerning
soil sampling
LTR - Response to
correspondence re:
control of
contaminated
stormwater runoff
LTR - Comments re:
EPA's Preliminary
Draft RI for the Weed.
CA, wood products
complex
LTR - Comments re:
EPA's Preliminary
Draft RI for the Weed,
CA, rood products
complex
12
ie
-------
Pag* So.
19/14/88
18
DOC. * DATE
J. H. BAXTER & CO. SUPERFUND SITE
Weed, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 1
FROH/OBGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT
No. of
PAGES
85
86
87
88
89
69/68/88
69/36/88
69/36/88
B. Kor,
CRWQCB-NCR
69/69/88 K. Black, COM
69/19/88 J. Morgan,
J.H.Baxter
L. Levenson, EPA
Region IX
L. Levenson, EPA
Region IX
D. Critchfield,
I.P.
D. Evans, NCWQCB
D. Evans,
CRWQCB-NCR
D. Evans,
CRWOCB-NCR
LTR - Comments re:
EPA'a Preliminary
Draft RI for the Weed,
CA, wood products
complex
PLAN - Final September
1988 Groundwater,
Soils and Sediment,
Sampling and Analysis
Plan for RI/FS
LTR - re: J.H.B.
Compliance vith Cease
and Desist Order Mo.
88-87 and Long Term
Capital Improvements
for Weed, CA, Plant
LTR - Potential I.P.
Pilot Study Proposal
re: JHB/IP/Roseburg
Site, Weed, CA
LTR - Runoff
Collection Proposal
re: JHB/IP/Roseburg
Site, Weed, CA
156
17
-------
Page No.
04/26/90
AR NUMBER
DATE
(yy/imi/dd)
J. H. BAXTER t COMPANY SUPERFUNO SITE
Weed. California
ADMINISTRATIVE RECORD INDEX «
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 1 no date Bioremediation Croup
Mississippi Forest
Products Laboratory
AR 2 88/07/08 James L Grant t
Associates, Ine
International Paper
Company
Bioremediation Demonstration
Study, Phase II- Field Site
Studies
Comments on draft Remedial
Investigation report by COM.
w/TU to Leo Levenson
AR 3 88/09/00 Camp, Dresser t McKee,
Incorporated
Field Report for September,
1988 Grounduater, Soils I
Sediment Sampling, WA
*167-9L47.7. Contract
«68-01-6939
AR
AR
AR
AR
4
5
6
7
88/09/22
88/10/10
88/10/12
88/10/19
Laurence t Associates
Curtis 1 Tome* ins. Ltd,
Lawrence t Associates
Thomas Baity
Woodward- Clyde
Consultants
Joe Morgan
J H Baxter t Company
Chain of Custody Record
Report on 14 soil samples
Illustration of tank site
Ltr: Summary of review of
laboratory results of soil
samples collected at tank site
I comments
AR 8 88/10/20 Joe Morgan
J H Baxter I Company
AR 9 88/10/21 Richard Becker, Jeffrey
Wong
CA Department of Health
Service
David Evans
CA Regional Water Quality
Control Board - North
Coast Region
David Evans
CA Regional Water Quality
Control Board - North
Coast Region
Ltr: Response to CRWQCB-NC ttr
of 10/7/88
Ltr: Response to request of
9/22/88 re: assistance in
assessing human health
significance of dioxins in
liver tissue of fish from
Beaughton Creek
AR 10 88/11/00 Environmental Protection
Agency
Superfund Program Proposed
Plan: Libby Groundwater Site.
Lincoln County, Montana, W/TL
to Lao Levcmon 12/13/88
AR 11 88/11/00 CMP. Dresser t McKea,
Incorporated
Field Report for November,
1988 Groundyater Sampling. UA
*1o7-9U7. Contract
68-01-6939
-------
Page Ho. 2
04/26/90
AR NUMBER
DATE
(yy/mm/dd)
J. H. BAXTER I COMPANY SUPERFUMO SITE
Weed, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 13 88/11/04 Leo Levenson
Environmental Protection
Agency, Region IX
AR 13 88/11/07 John Uondolleck
Camp, Dresser & MclCee,
Incorporated
AR 14 88/11/10 John Uondolleck
Camp, Dresser & MclCee,
Incorporated
AR 15 88/11/18 ICF Technology
Incorporated
David Evans
CA Regional Water Quality
Control Board North
Coast Region
Tom Huetteman
Environmental Protection
Agency, Region IX
Leo Levenson
Environmental Protection
Agency, Region IX
Ltr: Garments on Joe Morgan's
Ur of 10/28/88 re: soil
sampling results for proposed
tank pad & dry kiln areas
Memo: Analytical request,
grounduater verification
sampling
Memo: September 1988
Grounduater, Sediments &
Background Soil Sampling
Results, w/data
Analytical results. Table 1A,
invalidated data for Water
Samples for SAS phenols &
PAHs, u/memo to Betsy Curnow &
Leo Levenson 11/21/88
AR 16
88/11/21
ICF Technology
Incorporated
Quality Assurance Report,
u/memo to Betsy Curnow
11/28/88
AR 17
88/11/21
ICF Technology
Incorporated
Analytical results. Table 1A,
invalidated data for Water for
RAS metalks. w/meno to Betsy
Curnow I Leo Levenson 11/22/88
AR 18
88/11/21
ICF Technology
Incorporated
Analytical results Table 1A,
invalidated data for soils for
RAS Metals, u/memo to Betsy
Curnow I Leo Levenson 11/22/33
AR 19
88/11/22
James L Grant I
Associates, Inc
J H Baxter I Co, Int'l
Paper Co, Roseburg Forest
Prod.
Grounduater Remediation
Program
AR 20 88/12/01 CA Regional Water Quality
Control Board - North
Coast Region
J H Baxter I Company
CRWOCB-NC Order H88-151: To
cease & desist fro*
discharging wastes contrary t-
Order 163-29 A the Toxic Pits
Cleanup Act, M/TL to Jo*
Morgan 12/12/8*
-------
Page Mo.
04/26/90
AR NUMBER
DATE
(yy/nm/dd)
J. H. BAXTER t COMPANY SUPERFUNO SITE
Weed. California
ADMINISTRATIVE RECORD INDEX
Supplement NO. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 21 88/12/01 ICF Technology
Incorporated
AR 22 88/12/01 CA Regional Water Quality
Control Board North
Coast Region
Roseburg Forest Products
Quality Assurance Report,
M/mem> to Betsy Curnow 12/6/88
CRUOC8-NC Order 88-152. w/TL
to Nike Blornne 12/12/88 (pages
2 t 4 are missing)
AR 23 88/12/01 CA Regional Water Quality
Control Board - North
Coast Region
Alt 24 88/12/01 .Betsy Curnow
Environmental Protection
Agency, Region IX
International Paper
Company
Benjamin Kor
CA Regional Water Quality
Control Board North
Coast Region
CRWOC8-NC Cleanup I abatement
Order H88-1SS, w/TL to Oavid
Critchfield 12/12/88
Ltr: Comment on Preliminary
CRWOCB-NC Cease t Desist
Orders K88-151, 88-152 t
Preliminary Clean-up &
Abatement Order K88-155
AR 25 88/12/08 Joe Morgan
J H Baxter t Company
AR 26 88/12/09 Oavid Evans
CA Regional Water Quality
Control Board North
Coast Region
Oavid Evans
CA Regional Water Quality
Control Board - North
Coast Region
Jot Morgan
J H Baxter Wood
Preserving
TL: Results of soil sampling
for J H Baxter'* proposed new
tank fan*
Ltr: Summary of responses to
Itr of 9/1/88 I discussion of
11/17
AR 27
88/12/12
ICF Technology
Incorporated
Quality Assurance Report,
w/memo to Betsy Curnow
12/13/88
AR 28 88/12/12 Bert Bledsoe, John
Matthews
Robert S. Kerr
Environmental Protection
Research Laboratory
AR 29 88/12/20 John Matthews, Bert
Btedsoe
Robert S. Kerr
Environmental Protection
Research Laboratory
Aft 50 89/01/10 ICF Technology
Incorporated
The Record
Memo: Trip Report
Leo Levenson
Environmental Protection
Agency, Region IX
Memo: Review of Interim Report
Bioreacdiatton Demonstration
Study"
Quality Assurance Report,
W/SMO to Mtsy Curnow,
1/11/89
-------
Page NO.
04/26/90
AR NUMBER
DATE
(yy/irm/dd)
J. M. BAXTER t COMPANY SUPERfUNO SITE
Weed. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 31
89/01/11
ICF Technology
Incorporated
Quality Assurance Report,
w/memo to Betsy Curnow,
1/13/89
AR 32 89/01/17 David Evans
CA Regional Water Quality
Control Board - North
Coast Region
AR 33 89/01/21 John Wondolleck
Carp, Dresser & McKee,
Incorporated
David Critchfield
International Paper
Company
Carolyn Thompson
Environmental Protection
Agency, Region IX
Ltr: Request for submittal of
report of waste discharge for
groundwater remediation
program I list of requirements
Memo: Review comments on IPC's
proposed Crounduater
Remediation Demonstration
Project (Grant proposal dated
11/22/88)
AR 34 89/01/31 James I Grant I
Associates, Inc
AR 35 89/01/31 Mary Bishop, James Grant
James L Grant &
Associates, Inc
J K Baxter I Co, Int'l
Paper Co, Roseburg Forest
Prod.
Jay Amin
International Paper
Company
Work Plan for Test Pits to
Investigate the Roseburg
French Drain
Ltr: Progress report of
activities on Weed Pilot
Corrective Action Program
during January 1989
AR 36
89/02/00
Static Water Level
Measurements, w/Meoo to
Carolyn Thompson 3/2/89
AR 37 89/02/03 Patricia Port
United States Department
of the Interior
Bruce Blanchard
United States Department
of the Interior
Preliminary Natural
Resources Survey, u/o
attachments
AR 38 89/02/19 (illegible)
AR 39 89/02/23 John Matthews, Bert
Bledsoe
Robert S. Kerr
Environmental Protection
Research Laboratory
Aft 40 89/02/28 James I Grant ft
Associates, Inc
Carolyn Thompson
Environmental Protection
Agency, Region IX
Carolyn Thompson
Environmental Protection
Agency, Region IX
ROC: Bioremediation of soils
Memo: Review t Planning
Meeting at Robert S Kerl
Environmental Research
Laboratory on 2/13/89, w/lt»t
of attendees
Croundwater laved!atIon
Oeawwtretfon reject, M/TI ta
Donald Critdifiald
-------
Page No. 5
04/26/90
AR NUMBER
DATE
(yy/nm/dd)
J. H. BAXTER I COMPANY SUPERFUND SITE
Weed, California
ADMINISTRATIVE RECORD INDEX *
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 41 89/02/28 Mary Bishop, James Grant
James L Grant i
Associates, Ine
Jay Amin
International Paper
Company
Ltr: Progress report on
activities on the Weed Pilot
Corrrective Action Program
during February 1989
AR 42
AR 43
89/03/01 John Uondolleck
Camp, Dresser & McKee,
Incorporated
Carolyn Thompson
Environmental Protection
Agency, Region IX
Document number AR 42 is not
used.
Memo: Summary of conversation
t meeting u/Harry Rectenwald
re: restoration of Beaughton
Creek
AR 44
89/03/07
ICF Technology
Incorporated
Quality Assurance Report,
M/memo to Betsy Curnow,
3/10/89
AR 45 89/03/07 John Uondolleck
Camp. Dresser I McKee,
Incorporated
Carolyn Thompson
Environmental Protection
Agency, Region IX
Memo: Comments * concerns on
"Work Plan for Test Pits to
Investigate the Roseburg
French Drain"
AR 46 89/03/08 Ken Black
AR 47 89/03/08 John Uondolleck
Camp, Dresser ( McKee,
Incorporated
AR 48 89/03/10 Miss Forest Prod Util Lab
Mississippi State
University
AR 49 89/03/29 Camp, Dresser t McKee,
Incorporated
John Wondolleck
Camp, Dresser & McKee,
Incorporated
Carolyn Thompson
Environmental Protection
Agency, Region IX
J N Baxter Company
International Paper
Company
Memo: Comments on Grounduater
Remediation Project by James L
Grant
Memo: Comments t concerns on
Grounduater Demonstration
Project by James L Grant
Final Report (Laboratory
Phase) Bioremediation
Demonstration Study
Figure 1 - Map of Test Pit
locations, u/TL to David Evans
3/30/89
AR SO 89/03/31 Carolyn Thompson
Environmental Protection
Agency. Region IX
EPA contents on Janes L Grant
Groundwater Demonstration
reject, w/TL to David
Critchfield
AR 51
09/03/31
Nary Bishop, Jm
Ja«M L Grant *
Associate*, Ine
Grant David Critchfield
International Paper
Company
TL: final report for
Grounduater Remediation
Project
-------
Page No.
04/26/90
AR NUMBER
DATE
(yy/wn/dd)
J. H. BAXTER I COMPANY SUPERFUNO SITE
Weed. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 52
AR 53
89/04/06
89/04/11
Randall Ross
Robert S. ICerr
Environmental Protection
Research Laboratory
Bert Bledsoe, John
Matthews
Robert S. ICerr
Environmental Protection
Research Laboratory
Agenda Meeting regarding
Crounduater Remediation
Demonstration Project
Memo: Review comments of the
Crounduater Remediation
Demonstration Project", w/memo
to Carolyn Thompson 4/25/89,
w/o attachments
AR 54 89/05/10 Ed Cargile
CA Department of Health
Service
AR 55 89/05/16 Nary Bishop, James Grant
James L Grant t
Associates, Inc
Dorm Diebert
CA Department of Health
Service
Jay Affltn
International Paper
Company
Memo: Evaluation of J H Baxter
Treated Wood Facility, We«d
Grounduater Remediation
Demonstration Project
Ltr: Progress report on
activities at the Weed Pilot
Corrective Action Program
during April 1989, u/ltr to
Gary McGimis 3/30/89 I TL to
David Evans
AR 56 89/05/24 CA Regional Water Quality
Control Board - North
Coast Region
J H Baxter I Co, Int'l
Paper Co, Roseburg Forest
Prod.
CRWOCB-NC Order #89-75 Waste
Discharge Requirements I
Monitoring Program H89-75,
^/attachments i TL to Joe
Morgan 6/8/89
AR 57 89/06/19 James L Grant I
Associates, Inc
AR 58 89/06/30 Mary Bishop, James Grant
James L Grant I
Associates, Inc
Jay Anin
International Paper
Company
Figure 1: Proposed Building
Location of pilot grounduater
treatment system, u/TL to
Carolyn Thompson
Ltr: Progress report of
activities on the Weed Pilot
Corrective Action Program
during June 1989
AR 59 89/07/05 David Evans
CA Regional Water Quality
Control Board North
Coast Region
Joe Morgan et al
J H Baxter t Co, Int'l
Paper Co, ftosetourg Forest
rod.
Ltr: Response to James L Grant
Itr of 6/19/89 ra: proposed
location for Crounduater
to-Raaadtation Project
Traataant Plant
-------
Page No.
04/26/90
J. H. BAXTER i COMPANY SUPERFUND SITE
Weed, California
ADMINISTRATIVE RECORD INDEX
Supplement No. 2
AR NUMBER
DATE
(yy/irm/dd)
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 60 89/07/11 James I Grant &
Associates, Inc
AR 61 89/08/02 David Evans
CA Regional Water Quality
Control Board - North
Coast Region
AR 62 89/08/03 Mary Bishop, James Grant
James I Grant &
Associates, Inc
AR 63 89/08/U John Uondolleck
Camp, Dresser t McKee,
Incorporated
Ed Cargile
CA Department of Health
Service
Jay Am in
International Paper
Company
Carolyn Thompson
Environmental Protection
Agency, Region IX
Groundwater Remediation
Demonstration Program Report
Ltr: Response to CAOOHS'
comments of 5/15/89 re IPC's
proposed pump t treatment
program
Ltr: Progress report on
activities on the Weed Pilot
Corrective Action Program
during July 1989
Memo: field Trip Report
observations of Subsurface
Borings I Monitor Well
Installation, u/TL to David
Evans 8/23/89
AR 64 89/08/15 David Evans
CA Regional Water Quality
Control Board - North
Coast Region
David Critchfield
International Paper
Company
Ltr: Comment on memo from Gary
McGimis to Jay Amin, 8/U/89
re: results of chemical
analyses for soil samples
(document is dated Aug. 15,
1899)
AR 65
89/08/21
James Strandberg
Woodward-Clyde
Consultants
Benjamin Kor
CA Regional Water Quality
Control Board North
Coast Region
Ltr: Important issues
discussed in Meeting re:
Runoff control
AR 66
89/08/29
Woodward-Clyde
Consultants
J H Baxter & Company
Final report: Interim
Remediation to Control
Rainfall Runoff, w/TL to
Benjamin Kor 10/17/89 I
9/21/89
AR 67
89/08/29
Woodward-Clyde
Consultants
J H Baxter t Company
Interim Remediation to Control
Rainfall Runoff
AR 68 P9/09/01 David Evans
CA Regional water Quality
Control toard - North
CoMt Region
David Critchfield
International Paper
Company
Ltr: Cements on Progress
Report by Ja*M I Grant dated
8/3/89 re: Grounduater
fteaadiatlon Pilot
Deasratratlon Project
-------
Page MO.
04/26/90
AR NUMBER
DATE
-------
Page Ho.
04/26/90
Aft NUMBER
DATE
(yy/im/dd)
J. N. BAXTER C COMPANY SUPERFUND SITE
Weed. California
ADMINISTRATIVE RECORD INDEX
Supplement No. 2
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 79 90/03/22 Kent Kitchingman
Environmental Protection
Agency, Region IX
AR 80 90/03/26 James L Grant I
Associates, Inc
Mary Masters
Environmental Protection
Agency, Region IX
J H Baxter t Company
Memo: Superfund Site Draft
Feasibility Study for Internal
Review
Quarterly Report, Quarterly
Monitoring Report, Fourth
Quarter. 1989. w/TL to Oarretl
William
AR 81 90/03/26 John Matthews
Robert S. Kerr
Environmental Protection
Research Laboratory
AR 82 90/03/27 James L Grant t
Associates, Inc
Mary Masters
Environmental Protection
Agency, Region IX
J H Baxter i Company
Carments on preliminary
draft feasibility study
Well Installation Report,
Groundwater Remediation
Demonstration Program, W/TL to
David Critchfleld
AR 83 90/04/03 Liese Schadt
CA Regional Water Quality
Control Board - North
Coast Region
AR 84 90/04/03 Liese Schadt
CA Regional Water Quality
Control Board North
Coast Region
AR 85 90/04/12 Janes L Grant t
Associate*, Inc
Mary Masters
Environmental Protection
Agency, Region IX
Mary Masters
Environmental Protection
Agency, Region IX
J H Baxter 4 Co, Int'l
Paper Co, Roseburg Forest
Prod.
Ltr: Comments on Preliminary
Draft Feasibility Study for
Baxter/IP/Roseburg site,
3/3/90
Ltr: Initial comments on
Preliminary Draft Feasibility
Study of 3/3/90
Start-up Operation Manual for
Pilot Grounduater Treatment
System
-------
J.H. BAXTER & COMPANY SUPERFUND SITE
Weed, California
ADMINISTRATIVE RECORD INDEX
SUPPLEMENT NO. 3
This Index lists the documents contained in Supplement No. 3 to
the Administrative Record for the J.H. Baxter & Company Superfund
Site in Weed, California. The documents are listed in
chronological order which is consistent with the arrangement of
the documents in the bound volumes of the Administrative Record
Supplement itself.
The documents contained in the Administrative Record have been
considered by the U.S. Environmental Protection. Agency in
identifying remedial activities appropriate for use at the J.H.
Baxter & Company Superfund Site.
-------
GUIDANCE DOCUMENTS
The following is a list of U.S. EPA Guidance Documents
consulted during development and selection of the Response Action
for the J H Baxter & Company Superfund Site at Weed, CA. These
documents are included in the Compendium of CERCLA Response
Selection Guidance Documents (Volumes 1 - 35), which is available
for public review at the Superfund Records Center, EPA Region 9,
San Francisco.
-------
Pag* No. 1
09/24/90
Doc
No Vol Titlt
INDEX-
COHPENOIUH OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nuifcer
** RI/FS GENERAL
2002 3 GUIDANCE fOR CONDUCTING REMEDIAL
INVESTIGATIONS AND FEASIBILITY
STUDIES UNDER CERCLA
10/01/88 - OSUER/OERR
Final 390 1
OSUER #9355.3-01
2005 4 POLICY ON FLOOD PLAINS AND
UETLANO ASSESSMENTS FOR CERCLA
ACTIONS
08/01/85 HEDEMAN. JR., U.N./OERR Final 9 2
OSUER #9280.0-02
2010 4 SUPCRFUND FEDERAL-LEAD REMEDIAL
PROJECT MANAGEMENT HANDBOOK
12/01/86 - OERR
Draft 179 1
OSUER *9355.1-1
RI/FS - Rl DATA OUAL1TY/S1TE I WASTE ASSESSMENT
2100 9 A COMPENDIUM OF SUPERFUND FIELD 12/01/87
OPERATIONS METHODS
OERR
2101 9 6 DATA QUALITY OBJECTIVES FOR
REMEDIAL RESPONSE ACTIVITIES:
DEVELOPMENT PROCESS
2102 A DATA QUALITY OBJECTIVES FOR
REMEDIAL RESPONSE ACTIVITIES:
EXAMPLE SCENARIO: RI/FS
ACTIVITIES AT A SITE
((/CONTAMINATED SOILS AND
GMJUNOUATER
03/01/87 COM FEDERAL PROGRAMS
CORP.
03/01/87 COM FEDERAL PROGRAMS
CORP.
Final 550 1
Final ISO 1
Final 120 1
OSUER *9J5S.O-U
OSUER *9355.0-7B
OSUER *9355.07B
-------
Pag* No. 2
09/24/90
Doc
Ho Wot Tltla
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date
Authors
Status Pages Tier Attachments
OSUER/EPA Mutter
2106 6 HELD STANDARD OPERATING
PROCEDURES MANUAL tt-SITE ENTRT
01/01/85
OERR/HRSD
Final
29
OSUER H9285.2-01
2107 7 FIELD STANDARD OPERATING
PROCEDURES MANUAL 06-UORK ZONES
04/01/BS - OERR/HRSD
Final
19
OSUER 09285.2-04
2108 7 HELD STANDARD OPERATING
PROCEDURES MANUAL IB-AIR
SURVEILLANCE
01/01/85 - OERR/HSCD
Final
24
OSUER H928S.2-03
2109 7 FIELD STANDARD OPERATING
PROCEDURES MANUAL «9-SITE SAFETt
PLAN
04/01/85 OERR/HRSD
Final
26
1) SAMPLE SITE SAFETY
PLAN AND OSHA SAFETY PLAN
2) EMERGENCY OPERATION
CODES REAL TIME MONITOR
3) RESPONSE SAFETY
CHECK-OFF SHEET
OSWER W2B5.2-05
2112 8 QUIDELINES AND SPECIFICATIONS FOR 06/01/87
PREPARING QUALITY ASSURANCE
PROGRAM DOCUMENTATION
2113 8 LABORATORY DATA VALIDATION 07/01/88
FUNCTIONAL GUIDELINES FOR
EVALUATING INORGANICS ANALYSES
ORD/QUALITY ASSURANCE Final 31
MANAGEMENT STAFF
EPA DATA REVIEW WORK Draft 20
GROUP BLEYLER, R.VIAR
AND CO./SAMPLE MCHT.
OFFICE
2 1) MEMO: GUIDANCE ON
PREPARING OAPPs DATED
6/10/87
-------
P*9« No. 3
09/24/90
Ooc
o Vot Tltlt
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSWER/EPA Number
2114 8 LABORATORY DATA VALIDATION
FUNCTIONAL GUIDELINES FOR
EVALUATING ORGANIC ANALYSES
2115 a PRACTICAL GUIDE FOR GROUND-WATER
CAMPLING
02/01/88 BLEYLER, R./VIAR AND
OC./SAMPLE HCMT. OFFICE
- EPA DATA REVIEW
ORKGROUP
09/01/85 - BARCELONIA, M.J., ET.
AL./ILLINOIS ST. WATER
SURVEY
Draft 45 2
Final 175 1
EPA/600/2-8S/104
2116 8 PRACTICAL GUIDE FOR GROUND-WATER
SAMPLING
07/01/85 BARCELONA, M.J.. ET.
AL./ILLINOIS ST. WATER
SURVEY
2117 a SOU SAMPLING QUALITY ASSURANCE
USER'S GUIDE
05/01/84 BARTM D.S. I MASON, B.
J./U. OF NEVADA, LAS
VEGAS
Final
2118 9* TEST METHODS FOR EVALUATING SOLID
WASTE, LABORATORY MANUAL
PNY8ICAL/CHEMICAL METHODS. THIRD
EDITION (VOLUMES 1A. 1B, 1C, AND
11)
2119 11 USER'S GUIDE TO THE CONTRACT
LABORATORY PROGRAM
11/01/86 - OSWER
12/01/88 OERR/CLP SAMPLE
MANAGEMENT OFFICE
Final 3000 1
Final
-------
Page Ho. 4
09/24/90
Doc
No Vol Tltlt
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nunfcer
RI/FS OTHER TECHNOLOGIES
2300 16 A COMPENDIUM OF TECHNOLOGIES USED
IN THE TREATMENT OF HAZARDOUS
UASTES
09/01/87 - ORD/CERI
Final 49
EPA/625/8-87/014
2303 17 EPA GUIDE FOR IDENTIFYING CLEANUP
ALTERNATIVES AT HAZARDOUS WASTE
SITES AND SPILLS: BIOLOGICAL
TREATMENT
/ / PACIFIC NORTHWEST
LABORATORY
Final 120
EPA-600/J-8J-06J
230S 18 HANDBOOK FOR
STABILIZATION/SOLIDIFICATION OF
HAZARDOUS WASTE
06/01/86 CULLINANE JR., N.J.
ET.AL. /U.S. COE/UES
final 125 1
EPA/540/2-86-001
2319 22 TECHNOLOGY SCREENING GUIDE FOR
TREATMENT OF CERCLA SOILS AND
SLUDGES
09/01/88 OSUER/OERR
Final 130 1
EPA/540/2-88/004
ARMS
3001 25
CMCLA COMPLIANCE AND OTHER
ENVIRONMENTAL STATUTES
10/02/05 PORTER, J.U./OSUER
3002 25 CERCLA COMPLIANCE WITH OTHER LAWS 08/08/88 - OERR
Final 19 1
Draft 245
1) POTENTIALLY APPLICABLE OSUER H9234.0-2
OR RELEVANT AND
APPROPRIATE REQUIREMENTS
OSUER *9234.1-01
-------
Page No. S
09/24/90
Ooc
No Vol Title
IMDEX-
COHPENOIUH OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nuifcer
IMUR QUALITY
4003 26 QUALITY CRITERIA FOR WATER 1986
05/01/87 OFFICE OF WATER
REGULATIONS AND STANDARDS
Final
325
EPA/440/5-86-001
1005 1 INFORMATION ON DRINKING WATER
ACTION LEVELS (SECONDARY
REFERENCE)
04/19/88
FIELDS. JR.,
T./OSUER/ERO
Final
17
1) MEMO: RELEASE FROM
LAWFULLY APPLIED
PESTICIDES 2) MEMO DBCP
CONTAMINATION 3)
GUIDANCE FOR ETHYLEHE
01 BROMIDE IN DRINKING H20
RISK ASSESSMENT
5001 27 CHEMICAL. PHYSICAL I BIOLOGICAL
PROPERTIES OF COMPOUNDS PRESENT
AT HAZARDOUS WASTE SITES
5002 27 FINAL GUIDANCE FOR THE
COORDINATION OF ATSDR HEALTH
ASSESSMENT ACTIVITIES WITH THE
SUPERFUMD REMEDIAL PROCESS
09/27/85 - CLEMENT ASSOCIATES, Final 320
INC.
05/14/87 PORTER, J.W./OSWER/OERR Final 22
2 1) SAME TITLE, DATED
4/22/87
OSWER «9850.3
OSUER #9285.4-02
5003 27 GUIDELINES FOR CARCINOGEN RISK
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24. 1986, P.33992)
09/24/86 - EPA
Final 13 2
-------
Page Mo. 6
09/24/90
Doc
No Vol Ittlt
- INDEX-
COMPENDIUM OF CERCU RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nurtoer
5004 27 GUIDELINES FOR EXPOSURE
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24, 1986. P. 54042)
5005 27 GUIDELINES FOR HEALTH ASSESSMENT
OF SUSPECT DEVELOPMENTAL
TOXICANTS (FEDERAL REGISTER,
SEPTEMBER 24, 1986. P. 34028)
5006 27 GUIDELINES FOR MUTAGENECITY RISK
ASSESSMENT (FEDERAL REGISTER,
SEPTEMBER 24, P. 34006)
5007 27 GUIDELINES FOR THE HEALTH RISK
ASSESSMENT OF CHEMICAL MIXTURES
(FEDERAL REGISTER, SEPTEMBER 24.
1986. P.54014)
5008 28* HEALTH EFFECTS ASSESSMENT
DOCUMENTS (58 CHEMICAL PROFILES)
VOL. 28: ACETONE, ARSENIC,
ASBESTOS. BARIUM. BENZO(A)PTRENE,
CADMIUM, ETC.
5009 51 INTEGRATED RISK INFORMATION
SYSTEM (IRIS) (A COMPUTER-BASED
HEALTH RISK INFORMATION SYSTEM
AVAILABLE THROUGH
E-MAIL-BROCHURE ON ACCESS IS
INCLUDED)
09/24/86 - EPA
09/24/86 - EPA
09/24/86 - EPA
09/24/86
EPA
09/01/84 ORD/CHEA/ECAO
- CHEA
Final
Final
Final
Final
FINAL
Final
14 2
14 2
8 2
13 2
1750 2
EPA/540/1-86/001-058
-------
go No. 7
09/24/90
Doc
No Vol TltU
-INDEX-
COMPENDIUM Of CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nuifeer
9010 31 INTERIM POLICY FOR ASSESSING
RISKS OF "DIOXINS" OTHER THAN
2,3.7,8-1000
01/07/87 THOMAS, l.M./EPA
FINAL 50
1) INTERIM PROCEDURES FOR
ESTIMATING RISKS
ASSOCIATED WITH EXPOSURES
TO MIXTURES: 10/86
$011 31 W8LIC HEALTH RISK EVALUATION 09/16/88 - OERR/TOXICS INTEGRATION FINAL
DATAIASE (PMRED) lUSER'S MANUAL BRANCH
AND TWO DISKETTES CONTAINING THE
DIASEIII PLUS SYSTEM ARE
INCLUDED)
9013 31 SUPCRfUNO EXPOSURE ASSESSMENT 04/01/88 - OERR
Final 160 1
OSWER W285.5-1
9014 31 SUPttFUNO PUBLIC HEALTH
EVALUATION MANUAL
000 32 ENDANGERMENT ASSESSMENT GUIDANCE
(SECONDARY REFERENCE]
10/01/86 OERR
Final $00 1
11/22/8$ PORTER, J.U./OSUER Final 11 2
OSWER #9285.4-1
OSWER W850.0-1
* COfT ANALYSIS
4000 32 REMEDIAL ACTION COSTING
PROCEDURES MANUAL
10/01/87 JRI ASSOCIATES/CH2M
HILL
Final $6 1
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Pagt No. 8
09/24/90
Doc
No Vol Title
INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tier Attachments
OSUER/EPA Nutter
OOMNUNITV RELATIONS
7000 32 COMMUNITY RELATIONS IN SUPERFUND: 06/01/88 OERR
A HANDBOOK (INTERIM VERSION)
Final 168 2 1) CHAP. 6 OF THE COM. OSWER 49230.0-03B
REL. HANDBOOK 11/03/88
ENFORCEMENT
8000 32 ENDANGERMENT ASSESSMENT GUIDANCE
8001 32 INTERIM GUIDANCE ON POTENTIALLY
RESPONSIBLE PARTY PARTICIPATION
IN REMEDIAL INVESTIGATIONS AND
FEASIBILITY STUDIES
11/22/85 - PORTER, J.U./OSUER
OS/16/88 - PORTER, J.U./OSUER
Final 11 2
Final 37 2
OSUER 09850.0-1
OSUER H9835.1A
M SELECTION OF REMEDY/DECISION DOCUMENTS
9000 32 INTERIM GUIDANCE ON SUPERFUND
SELECTION OF REMEDY
12/24/66 PORTER. J.U./OSUER
Final 10 2
OSUER W355.0-19
NEW ADDITIONS
9002 33 INTERIM FINAL GUIDANCE ON
PREPARING SUPERFUND DECISION
DOCUMENTS
9005 33 GROUND WATER ISSUE: PERFORMANCE
EVALUATIONS OF PUMP-AND-TREAT
RENEDIAT10NS
06/01/69
/ / -KEELEY, J.F.
InterlM
OSUER #9355.3-02
EPA/540/A-89/005
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09/24/90
Doc
No Vol TltU
-INDEX-
COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Date Authors
Status Pages Tl«r Attachments
OSUEft/EPA Nunber
9009 33 NATIONAL OIL & HAZARDOUS
SUMTANCES POLLUTION CONTINGENCY
GUIDANCE, PART 300, 40 CFR CH. 1
(7/1/85 EDITION), pp. 664 - 755
9010 33 SUPERFUNO AMENDMENTS I
REAUTNORI2ATION ACT OF 1986
(SARA)
9011 1 RISK ASSESSMENT GUIDANCE FOR
SUPERFUND - VOLUME 1, HUMAN
HEALTH EVALUATION MANUAL (PART A)
07/01/85
10/17/86 99TH CONGRESS OF U.S.
12/01/89
92
130
INTERIM
FINAL
EPA/SAO/1-89/002
9012 2 RISK ASSESSMENT GUIDANCE FOR 03/01/89
SUPERFUND VOLUME 2,
ENVIRONMENTAL EVALUATION MANUAL
9013 INTERIM GUIDANCE ON 03/01/89
ADMINISTRATIVE RECORDS FOR
SELECTION OF CERCLA RESPONSE
ACTIONS
9014 INTERIM GUIDANCE OH COMPLIANCE 07/09/87
WITN APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
INTERIM
FINAL
INTERIM 85
INTERIM 9
EPA/540/ 1-B9/OOU
OSUER 9833.3A
OSUER 9324.0-OS
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Date Authors
Status Pages Tier Attachments
OSUER/EPA Ninfcer
9015 CERCLA COMPLIANCE WITH OTHER LAWS
MANUAL: PART II CLEAN AIR ACT
AND OTHER ENVIRONMENTAL STATUTES
AND STATE REQUIREMENTS
08/01/09
INTERIM
fINAL
OSUER 9234.1-02
9016 APPLICABILITY OF LAND DISPOSAL
RESTRICTIONS TO RCRA AND CERCLA
GROUND WATER TREATMENT
RE INJECT ION SUPERFUNO MANAGEMENT
REVIEW: RECOMMENDATION HO 26
12/27/09
OSUER 9234.1-06
9017 REGION 9 ENVIRONMENTAL PROTECTION
AGENCY DRINKING WATER STANDARDS
AND HEALTH ADVISORY TABLE
06/01/09
28
9019 SUPERFUNO LOR GUIDE §7:
DETERMINING WHEN LAND DISPOSAL
RESTRICTIONS (LDRa) ARE "RELEVANT
AND APPROPRIATE" TO CERCLA
RESPONSE ACTIONS
12/01/09
OSUER 9347.3-08FS
9020 RISK ASSESSMENT GUIDANCE FOR
SUPERFUND HUMAN HEALTH RISK
ASSESSMENT: U.S. EPA REGION IX
RECOMMENDATIONS
12/15/09
INTERIM
FINAL
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CONPENDIUH OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
Ooc
io Vol Tltl* Date Authors Status Pages Tier Attachments OSUER/EPA Nufcer
9021 A GUIDE TO DEVELOPING SUPERFUND OS/00/90 4 OSWER 9JJ5.J-02FS-1
RECORDS OF DECISION
9022 GUIDANCE ON REMEDIAL 06/01/85 FINAL OSWER 9355.0-068
INVESTIGATIONS UNDER CERCLA
9023 GUIDANCE ON FEASIBILITY STUDIES 06/01/85 FINAL OSWER 9355.0-05C
UNDER CERCLA
9025 GROUND WATER POLICY REGION 9 OS/00/89
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Page No. 1
09/25/90
AR NUMBER DATE
yy/mm/dd
j. H. Baxter I Conpany Superfund Site
Weed. California
« ADMINISTRATIVE RECORD INDEX
Supplement No. J
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 86 no date Mississippi Forest
Products Laboratory,
Bioremediation Croup
AR 87 72/04/26 David Joseph
California Regional
Water Quality Control
Board - North Coast
Environmental
Protection Agency
Region IX
Bioremediation demonstration study
phase II field site studies,
Weed, California Superfund site
(undated)
Order * 72-22 waste discharge
requirements for Coast Wood
Preserving co
AR 88 81/03/26 David Joseph
California Regional
Water Quality Control
Board - North Coast
Order f 81-61 requiring Coast Wood
Preserving to cease and desist from
discharging wastes contrary to
requirements prescribed by order *
72-22
AR 89 83/03/24 David Joseph
California Regional
Water Quality Control
Board - North Coast
Order i 83-29 waste discharge
requirements of J H Baxter and co
AR 90 83/05/26 David Joseph
California Regional
Water Quality Control
Board - North Coast
Order * 83-62 requiring j H Baxter
4 co to cease and desist from
discharging wastes contrary to
order f 83-29 and 83-39
AR 91 85/07/25 California Regional
Water Quality Control
Board - North Coast
AR 92 85/07/25 David Joseph
California Regional
Water Quality Control
Board - North Coast
Louisiana-Pacific
Corporation
Order §85-88, waste discharge
requirements for Louisiana-Pacific
Corp, Ukiah Operation
Order f 85-101 wsste discharge
requirements for Coast Wood
Preserving
AR 93 85/12/05 Benjamin Kor
California Regional
Water Quality Control
Board - North Coast
Order f 85-161 requiring J H Baxter
ft co to cease and desist from
discharging wastes contrary or
order f 83-29
AR 94 85/12/05 Benjamin Kor
California Regional
Water Quality Control
Board - North Coast
Order f 85-183 requiring Roseburg
Forest Products to cease and desist
from discharging wastes contrary or
order ff 84-107
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Page No. 2
09/25/90
AR NUMBER DATE
yy/nn/dd
.J. N. Baxter & Company Superfund site
Weed, California
ADMINISTRATIVE RECORD INDEX *«
Supplement No. 3
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 95 86/05/01 California Regional
Water Quality Control
Board - North Coast
AR 96 87/01/08 Benjamin Kor
California Regional
Water Quality Control
Board North Coast
Roseburg Forest
Products
Order 186-46, waste discharge
requirements for Roseburg Forest
Products Company
Cleanup and abatement order 1 87-9
for Louisiana-Pacific Corp., ukiah
operation \
AR 97 89/08/24 Benjamin Kor
California Regional
Water Quality Control
Board North Coast
AR 98 89/09/15 Frank Reichmuth
California Regional
Water Quality Control
Board North Coast
A Kelly Stalker
Louisiana-Pacific
Corporation
Complaint * 89-103 for
administrative civil liability in
the matter of Louisiana-Pacific
corp., Ukiah operation
Ltr: Comments on Louisiana Pacific
Corporation. Ukiah Industrial
complex storm water recycling
project by Peregren Environmental
Croup
AR 99 90/05/07 Environmental
Protection Agency -
Region IX
AR 100 90/05/07 Joe Morgan
J. H. Baxter i Company
AR 101 90/05/07 David Critchfleld
International Paper
Company
Environmental
Protection Agency
Region IX
Environmental
Protection Agency
Region IX
Baxter/IP/Roseburg Superfund site
community meeting. College of the
Siskiyoua, Weed, CA
nts on RI/FS and proposed plan
fact sheet
Comments on RI/FS and proposed plan
fact sheet
AR 102
AR 103
90/05/07
90/05/07
Arend The
resident
City of Weed
blank
Environmental
Protection Agency
Region IX
Environmental
Protection Agency
Region IX
Comments on RI/FS proposed plan
fact sheet
ity meeting evaluation
AR 104
90/05/09
Mary Thomee
City of
resident
Environmental
Protection Agency
Region IX
Comments on RI/FS and proposed pier.
fact sheet
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Page He. 3
09/25/90
AR NUMBER
DATE
yy/mm/dd
J. N. Baxter 4 Company Super fund Site
Weed, California
ADMINISTRATIVE RECORD INDEX *
Supplement No. 3
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 105 90/OS/2S Felice Pece
Klamath Forest
Alliance
AR 106 90/06/19 Anthony Landis
California Department
of Health Services
AR 107 90/06/21 James L Grant I
Associates,
Incorporated
Environmental
Protection Agency -
Region IX
Mary Masters
Environmental
Protection Agency -
Region IX
J. H. Baxter i Company
Ltr: Comments on plan to cleanup
soil and groundwater
Ltr: Review of draft feasibility
study I proposed plan for J H
Baxter site w/2 review memos by Ed
Cargile, 6/19/90
Quarterly monitoring report, first
quarter, 1990
AR 108
90/06/21
AR 109
90/06/21
AR 110 90/06/21
AR 111 90/06/28
Joe Morgan III
J. H. Baxter t Company
Mary Bishop James
Grant
James L Grant t
Associates,
Incorporated
Timothy Lovseth Mary
Bishop
James L Grant t
Associates,
Incorporated
Susan Warner
California Regional
Water Quality Control
Board - North Coast
Mary Masters
Environmental
Protection Agency -
Region IX
Jay C.
International Paper
Company
Darrell Williams
J. H. Baxter I Company
Nary Masters
Environmental
Protection Agency -
Region IX
Ltr: Coonents on draft FS
Ltr: Progress report on Weed Pilo
Corrective Action program during
5/90
TL: First quarter 1990 rpt:
ground-water quality assessment
program w/encl
Ltr: Issues remain to be resolved
from revised draft FS dated
4/27/90, memo from John Wondolleck
of COM and Itr from Mary Masters
dated 5/16/90
AR 112 90/06/29
ChemRisk
J. H. Baxter I Company
Technical review of USEPA Reg 9
endangerment assessment for
Baxter/IP/Roseburg Superfund Site,
CA
AR 113 90/06/29
International Paper
Company
Nary Masters
Environmental
Protection Agency
Region IX
Ltr: Comments on draft FS and
Endangenaant Assessment (by J N
Baxter A Co., International P-v»
and tOMburg Forest Products)
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Page No.
09/25/90
AR NUMBER
DATE
yy/ron/dd
j. H. Baxter i Company Superfund Site
Weed. California
AOMIMISTRATIWE RECORD INDEX *
Supplement No. 3
FROM/ORGANIZATION
TO/ORGANIZATION
DESCRIPTION/SUBJECT
AR 114 90/06/30 Kenoli Oleari
Salmon River Concerned
Citizens, Berkeley, CA
Mary Masters
Environmental
Protection Agency -
Region IX
Ltr: Comments on feasibility study
t cleanup plan for the Baxter
Superfund site w/attaehment
AR 115 90/07/02 David Kerschner
Beazer East,
Inc./Environmental
Services
Mary Masters
Environmental
Protection Agency -
Region IX
Ltr: Comments on the proposed plan
for the J H Baxter Superfund site
M/enclosures
AR 116 90/07/02 Pete Bontadelli
California Department
of Fish t Game
Dan NcGovern
Environmental
Protection Agency -
Region IX
Ltr: Comments on draft FS u/details
of recommended sampling program for
sediment and fish
AR 117
90/07/30
Richard Ueming
Chen* is*
Danny Adams
International Paper
Company
Ltr: Review of groundwater
investigations conducted at J H
Baxter Superfund site w/marginalia
4 attached table* 1 - 3
AR 118 90/07/31 Cameron McDonald
Ecology I Environment,
Inc.
William Lewis
Environmental
Protection Agency -
Region IX
Ltr: Results of sampling of
residential areas adjacent to
Baxter/IP/Roseburg sites for
arsenic I/or chromium in soil
u/appendices a - c
AR 119 90/08/10 Jagdish Rughani
Mississippi Forest
Products Laboratory,
Bioremediation Croup
Environmental
Protection Agency -
Region IX
Weed groundwater mikie results,
final report for operating period
7/12/90 7/19/90 w/marginalia
AR 120 90/08/10 Danny Adams
International Paper
Company
Mary Masters
Environmental
Protection Agency -
Region IX
Ltr: Summary of information on both
soil and groundwater remediation
and proposed clean-up levels
«/table 1
AR 121
90/08/U
Richard Veming
Chen* isle
Danny Admmi
International Paper
Company
Ltr: Clarification of inaccuracies
in preliminary review of
groundwater data collected during
4th quarter, 1989 I 1st quarter,
1990 -/tables 1 - 3
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Page No. 5
09/25/90
AR NUMBER DATE
yy/nw/dd
AR 122 90/08/K
j. H. Baxter A Company Superfund Sit*
Weed, California
ADMINISTRATIVE RECORD INDEX
Supplement Mo. 3
FROM/ORGANIZATION
Danny Adams
International Paper
Company
TO/ORGANIZATION
Nary Masters
Environmental
Protection Agency -
Region IX
Hazardous Wl
Inflation R^
(JSt-g^A Regiorj
Philadelphia, |
DESCRIPTION/SUBJECT
Ltr: Response to request for
groundwater clean-up goals and
supplement 8/10/90 Itr re proposed
initial clean-up goals for
groundwater A soils u/attch
Li
AR 123 90/08/15
Mary Bishop James
Grant
James I Grant I
Associates,
Incorporated
Jay C.
International Paper
Company
Ltr: Progress report on Weed Pilot
Corrective Action program during
7/90 u/attch
AR 124 90/08/21
Mary Masters
Environmental
Protection Agency
Region IX
Dan Shane
Environmental
Protection Agency -
Region IX
Comments on results of
off-site soil sampling
AR 125 90/08/22
Nary Masters
Environmental
Protection Agency
Region IX
Liese Schadt
California Regional
Water Quality Control
Board - North Coast
Ltr: Response to CRWOCB's comment
on FS and Clarification of EPA's
position: California Safe Drinking
Water and Toxic Enforcement Act is
not ARAB
AR 126 90/08/27
James L Grant t
Associates,
Incorporated
International Paper
Company
Laboratory data sheets for 6/22
6/19, 1990 influent/effluent water
quality data for Weed gw treatment
facility M/TL to J Amin, 8/27/90
AR 127 90/09/11
Liese Schadt
California Regional
Water Quality Control
Board - North Coast
Mary Masters
Environmental
Protection Agency -
Region IX
Ltr:
Decision
its on draft Record of
AR 128 90/09/U
AR 129 90/09/14
Liese Schadt
California Regional
Water Quality Control
Board - North Coast
JJ Loss ing, M Bishop
James L Grant I
Associates,
Incorporated
Mary Masters
Environmental
Protection Agency -
Region IX
Jay Amin
International Paper
Company
Ltr: Comments on draft Record of
Decision (ROD) M/attached table
showing chemical concentrations in
groundMater
Ltr: Progress report describing
activities on the Weed pilot
corrective action program, August
1990 M/attachmmntB
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