United States
Environmental "Protection
Agency
Office ot
'Emergency and
Remedial Response
EPA/HOD/R10-88/011
•December 1988
Record of Decision:
Commencement Bay/
Near Shore, WA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
.EPA/ROD/RlO-88/011
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Commencement Bay/Nearshore, WA
^•irst Remedial Action
5. Re
r
Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
TO. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Tacoma Tar Pits site covers approximately 30 acres within the Commencement Bay -
Nearshore/Tideflats'site in Tacoma, Pierce County, Washington. The tar pits lie between
the Puyallup River, the city, and Wheeler - Osgood Waterways. These bodies of water are
not used as a water supply, but support extensive fish and shellfish populations.
Currently there is concern for the site's impact on surface water quality and many local
industries that use ground water, from onsite wells. ' In 1924, a coal gasification plant
"~^egan operations, and continued until 1956, at which time they were terminated due to
.he availability of natural gas. During these years, waste materials from the coal
gasification process were disposed of onsite. Contained in the waste materials, were a
wide variety of organic compounds and heavy metals. From 1965 to 1966, the plant was
dismantled and demolished. Most of the metal structures were removed from the site;
however, all demolition debris and below grade structures were left in place, including
tanks and pipelines containing tars. In 1967, a metal recycling company began operating
at the site. Recycling of automobile batteries introduced acid, heavy metals, lead, and
PCBs to the soil. Several studies conducted by EPA and the Washington State Department
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Commencement Bay/Nearshore, WA
First Remedial Action
Contaminated Media: soil, sw
(benzene, PCBs), PAHs, metals (lead)
c. COSATI Field/Group
-ailability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
Page
ifo
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R10-88/011
Commencement Bay/Nearshore, WA
First Remedial Action
16. ABSTRACT (continued)
of Ecology between 1981 and 1983 found contaminants derived from the coal gasification
process. The primary contaminants of concern affecting surface water and soil include:
benzene, PAHs, PCBs, and lead.
The selected remedial action for this site includes: excavation of all contaminated
soils exceeding 1 percent total PAHs and all surface soils exceeding a 10~~° lifetime
cancer risk level with stabilization of all excavated soils in a polymer/cement mixture;
capping of the stabilized matrix with asphalt; channeling and managing of surface
waters; ground water monitoring; and removal and treatment of ponded water. The
estimated present worth cost for this remedial action is $3,400,000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site
Cowntncemtnt Bay - Nearshore/Tldeflats, Tacoma Historical Coal
Gasification site: Commonly known as Tacoma Tar Pits Site - Tacoma, Pierce
County, Washington
Purpose
This decision document presents the selected final remedial action for
the site, developed In accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorlzatlon Act of 1986 (SARA), and consistent
with (where not precl.ied by SARA) the National Contingency Plan (NCP, 40 CFR
Part 300). The State of Washington has been consulted and has verbally
concurred with the selected remedy. Formal concurrence of the state 1$
expected shortly after this decision document Is signed.
Basis for Decision
The decision is based upon the administrative record for the site, as
obtained from th« files of tnt U.S. Environmental Protection Agency (EPA) and
the Washington State Department of Ecology. This record includes, but is not
limited to. tht following documents: -
* Remedial Investigation Report for the Tacoma Tar Pits. Tacoma, Washington
(September 1987)
Feasibility Study of the Tacoma Historical Coal Gasification Site, Final
Rtport (October 1987)
• Risk Assessment of the Tacoma Historical Coal Gasification Site - Final
Report (July 1987)
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• Decision Summary of ftemedlal Alternative s*1«ctlon (a.t±a.cn«d>
• Responsiveness .Summary (attactved .as Appendix II)
• A complete 11st of documents contained in the Administrative Record i^^
Included as Appendix I
• Staff summaries and documents
Description
This record of decision addresses source control of on-site contamination
through excavation of contaminated soils and stabilization of these
contaminated soils in a polymer/cement matrix. The stabilized matrix will be
capped to reduce surface-water Infiltration. Management of migration Is
addressed by diversion of surface-water runoff. On-s1te shallow groundwater
contains detectable concentrations of contaminants. However, because
contamination has not been detected off-site and as the remedial action is
expected to prevent further contamination, groundwater extraction and
treatment is not considered as appropriate at this time. Should monitoring
indicate contamination migration, further treatment may be necessary, to
address the shallow groundwater.
The remedial action is designed to: . " '
9 Excavate and treat all contaminated soils considered to be Extremely
Hazardous Wastes (EHW) defined for this site as exceeding 1 percent total
polynuclear aromatic hydrocarbon;
• Excavate and treat (stabilize) all surface soils <<3 feet) containing
contaminants that exceed a 10~6 'lifetime cancer risk level;
• . Reduce surface water infiltration and potential human exposure to
stabilized soils by capping the stabilized matrix with asphalt;
• Reduce surface water transport of contaminants by channeling and managing
surface waters; ind
• Provide for continued groundwater monitoring to evaluate the
effectiveness of the remedial action and the need for groundwater
extraction and treatment;
' Remove and treat ponded water to achieve "cleanup goals.
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Dae 1 tana t Ian
Const-stint «1t!h OE'RCLA, as amended by SARA, and the NCP, it Is determined
that the $«l'8Cttd.remedy as described above Is protective of human health and
the environment, attains federal a-nd State requirements which are applicable
or relevant and appropriate, and is cost-effective. This remedy satisfies the
preference expressed in SARA for treatment that reduces toxlcity, mobility,
and volume. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
Date Regionarl Administrator
Environmental Protection Agen
EPA - Region 10
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rrtatmtnt will be sufficient to reduce contaminant levels In the soils,
and surface waters to or below cleanup standards. Numeric values for. these
cleanup standards and the criteria used In performance standard development
are presented In Table 1. Treatment should be permanent, and should
effectively reduce the toxlclty and mobility of the contaminants. Performance
levels are not to be exceeded during the operational life of the remedial
action.
Although Table 1 contains cleanup standards for groundwater the remedial
action does not currently provide for groundwater extraction and treatment. ^
Source control measures are expected to reduce contaminant concentrations in
the local groundwater system. Ground water monitoring performed during
Implementation and following the remedial action will aid In determining the
effectiveness of the remedial action. If cleanup_Jejvels are not achievedjtt_
thejj_te__&fiujJJAry In the aquifers within a reasonable period of t1mt following
completion of the remedial action, an alternative remedial action will bt
evaluated and Implemented which may Include groundwater extraction.
Continued monitoring of surface waters will also be performed to ensure
cleanup levels are met during and following Implementation of the remedial
action. Treated water discharge shall at ail times be of quality consistent
with U.S. and Washington State laws.
Institutional controls such as daed restrictions to prohibit excavation
. or drilling will be developed, consistent with the final design, to ensure
that tht remedial action will continue to protect human health and the
environment.
In compliance with SARA the effectiveness and performance of this final
remedial action will be reassessed at regular Intervals, not to exceed 5 years.
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DECISION SUMMARY
REMEDIAL ALTERNATIVE SELECTION
FINAL REMEDIAL ACTION
TACOMA TAR PITS
TACOMA, WASHINGTON
n
•o
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Table I. Cleanup Goal Perform Standards
Maximum Allowable Contaminant Concentrations
Tacoma Tar Pits Site
Groundwater (sand
Contaminant or
Contaminant Class
Lead
benzene
PCBs
PAHs(l)
Soils
(•g/kg)
I66<2)
56<3)
l.0<3)
l.0(3)
Surface Mater,
Boundary (ug/l)
i
3.2(4)
53(5)
02(4)
5 - 30(6)
Surface Mater
On-Slte (ug/l)
|?2(7)
5.300(7)
2(7)
2I9<7)
and fill aq
(ug/l)
50
(I)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
Included are benzo(a)pyrene, benzo(a)anthracene. ben2o(b)fluoranthene.
benzo(k)fluoranthene, dlbenzo(a,h)anthracene, and lndeno(l,2.3-c.d)pyrene.
Acceptable dose.
I0~6 Risk Level.
Chronic freshwater ambient water quality criterion. Performance based on detection limit
Acute freshwater ambient water quality criterion * 1/100.
Estimated range of chronic freshwater ambient water quality criterion based on marine
criteria.
Estimated acute freshwater ambient water quality criterion.
Drinking Mater HCL.
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TABLE OF CONTENTS
I INTRODUCTION ,
II SITE DESCRIPTION AND LOCATION 3
III SITE HISTORY 5
A. SIte Operations/Disposal History 5
8. Regulatory History - Previous Investigations 6
C. The Remedial Investigation 7
0. The Risk Assessment 16
IV ENFORCEMENT 19
V COMMUNITY RELATIONS 20
VI ALTERNATIVES EVALUATION - FEASIBILITY STUDY 25
VII . SELECTED REMEDIAL ALTERNATIVE (No. 13) 30
A. Description of the Selected Remedy 30
B. Statutory Determinations 34
APPENDIX
I. INDEX TO ADMINISTRATIVE RECORD
II. RESPONSIVENESS SUMMARY
III. APPLICABLE AND APPROPRIATE REQUIREMENTS
II
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LIST OF TABLES
Tablt 1 Pathway Specific MASC Values
Table 2 Cleanup Goal - Performance Standards
Table 3 Summary of Remedial Alternatives
Table 4 Detailed Evaluation Criteria
Table 5 Summary of Detailed Evaluation
LIST OF FIGURES
Plate 1 Site Location Map
Plate 2 Distribution of Coal Gasification Wastes
Plate 3 Subsurface Lithology and Tar Occurrence
Plate 4 Total PCS Distribution in Surface Soils and Tars
Plate 5 Lead Distribution in Surface Soils and Tars
Plate 6 Total PAH Concentrations In Fill Aquifer
Plate 7 Total PAH Concentrations In Sand Aquifer
Plate 8 Approximate Extent of Remediation
Hi
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I INTRODUCTION
The Tacoma Tar Pits site Is part of the Commencement Bay -
Nearshore/Tldeflats Superfund site located within the Tacoma Tideflats
Industrial area near Commencement Bay. A coal gasification plant was in
operation on site from 1924 through 1956. A metal recycling facility has Seen
operating on the site from 1967 to the present. Preliminary Investigations
were conducted at this site between 1981 and 1983 to determine if contaminants
were present on site at levels that were a potential threat to human health
and the environment.
As a result of the preliminary Investigations and the detection of a
variety of contaminants in both soils and water, the U.S. Environmental
Protection Agency (EPA) identified the need for further Investigations
performed according to guidelines established by the Comprehensive .
Environmental Response. Compensation, and Liability Act of 1980 (CERCLA) as
amended In 1986 by the Superfund Amendment and Reauthorlzatlon Act (SARA).
The purpose of this Decision Summary Is to summarize:
. The nature and extent.of contamination
The pathways of contaminant migration
Rates of contaminant transport
Risk associated with potential on-s1te and off-site exposures
The method for establishing site cleanup standards
Tht method of remedial alternative development
Tht methodology for evaluation of remedial alternatives
The results of the detailed evaluation of alternatives
The preferred remedial alternative
The enforcement irarus of the site
The opinions ana ••::fc:anc3;'of tne preferred alternative by the
community.
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Decision Summary 1$ designed to present technical Information needed
to support tht Record of Decision.
Stv*ral companies have either previously owned land at the site or
currently own or operate on land at the site. Collectively these companies
are termed Potentially Responsible Parties (PRP). With guidance ana overs';nt.
by the EPA and Washington State Department of Ecology (Ecology), several PRPs
have undertaken and completed a Remedial Investigation (RI), a Risk. Assessment
(RA), and a Feasibility Study (FS> for the Tacoma Tar Pits site. EPA and
Ecology have found these documents to be acceptable although EPA has prepared
an addendum for each document addressing issues that the studies have
inadequately or incompletely addressed.
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II SITE DESCRIPTION AND LOCATION
The Tacoma Tar Pits site covers an area of approximately 30 acres within
the Commencement Say - Nearshore/Tldeflats site, an area of approximately
9 square miles which Includes Commencement Say, seven urban waterways,
shoreline areas along the southeast side of Commencement Say, and the Puyalluo
River delta. The site lies between the river and the City and Wheeler-Osgood
Waterways. As shown In Figure I, the site Is bordered by Portland Avenue and
St. Paul Avenue on the north, by East River Road on the east, by East 15th
Street on the west, and by Burlington Northern Railroad tracks to the south.
A variety of industries are located on or adjacent to the site. The study
area currently contains a metal recycling facility (Joseph Simon and Sons), a
natural gas transfer station (Washington Natural Gas), a rail freight loading
yard (Union Pacific Railroad), a meat packing plant (Hygrade Food Products),
and a railroad switching yard (Burlington Northern Railroad).
The site currently contains two ponds, a small tar pit, and various
surface-water drainage ditches. The metal recycling facility contains
stockpiles of scrap metal and shredded car interiors. The area is generally
flat with local variations in relief of 2 to 5 feet. The present topography
has resulted from modifications to the land surface by dredging, filling, and
grading activities. Ground elevations generally range from *3 to «-12 feet
(Mean Sea Level), with higner elevations resulting from stockpiles of shredded
»
car interiors and scrap metal.
The study area is located near several major surface water bodies
Including the City and Wheeler-Osgood waterways, the Puyallup River, and
Commencement Say. Although none of these water bodle-s are used for water
supply, the bay and river jo support extensive fish and shellfish
3 of 36
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of
talng w.r.1, contaminated. reSU,t,n, ,„ ad,ers, b1olog,eil .„,„,
I" Mdltlon to concerns on t*. .It.-, ..pact on !urface wtir ,„.„
conta.ln«,on of th, ,oca, «,round«ter r9SOurce „ a,so of concern Many'
.oca! ,n,uStr,8s use ground.ater from on-.lt. «,,s ,„ Ipltt of thf fa£{ f
POta^.e .ater fro™ ,„. c,t, of Tacoma 1, .,.„.»„. fc|t of tftes, ^ i
scr«n,d at d.pths of ,r,at,r than 400 fe.t. No «t,r supply „,,, Bere
ld,ntm,d ,n th. upp.rTOSt aqutf,rs ,nv.st,gat,< py «. „ and
«ter SUBp,y «,,s- ire ,ocate<1 ,„ tft,
4 Of 36
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Ill SITE HISTORY
A. Site Operations/Disposal History
In 1924 a coal gasification plant was constructed on the site. The plan-
was also sold In 1924 and continued to operate until 1926 when the property
was sold again to Washington Gas and Electric Company. Waste materials frcm
the coal gasification process were disposed of on site. These materials
Included coal tar liquors, coal ash, and coal tars. These substances by
definition contain a wide variety of organic compounds and heavy metals. Many
of these organic compounds are toxic and several are considered to be
carcinogenic. These compounds Include aromatic hydrocarbons (i.e., benzene,
toluene), polynuclear aromatic hydrocarbons collectively known as PAH's (i.e..
naphthalene, benzo(a)pyrene), as well as numerous other classes of
hydrocarbons and cyanide. Heavy metals which are relatively common in such
waste streams Include arsenic. mercury, and lead.
In 1956, the plant's production of coal gas was terminated due to the
availability of natural gas. At this time. Washington Gas and Electric
Company merged with Seattle Gas Company to form Washington Natural Gas
Company, a distributor of natural gas. Although coal gas production ceased,
the plant remained intact until 1965. At that time, dismantling of the plant
began. Demolition was completed by 1966. Most metal structures were .amoved
from the site; however, all demolition debris and below grade structures were
left In place. Such structures included tanks and pipelines containing tars.
In 1967, a metal recycling company (Joseph Simon and Sons) began
operation at the site. A small portion of the property (0.3 acres) was
retained by Washington Natural Gas Company. Fill material consisting of scrap
5 of 36
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Iron, car bodies, soil, and shredded car Interiors were used to fill the
western and southern portions of the site. This facility recycled a variety
of metals largely from automobiles and transformers. Automobiles were
disassembled and materials sorted and processed. The recycling of automobile
batteries Introduced both add and the heavy metal lead to the soil. Prior :o
scrapping, transformers were drained of their oil. During the time period in
question, these oils typically contained polychlorlnated blphenyls (PC8s).
The Hygrade property originally was owned and operated by Carstens
Packing. Little has been changed since the original construction of the
Carstens Packing complex In the early 1900's. Hygrade purchased the plant and
property from Carstens Packing in 1979. In about 196S, the eastern half of
the Union Pacific Railroad property was filled, a freight house constructed,
and the surrounding area paved.
The area east of East River Street remained undeveloped until after
1970. The area has been filled and leveled for possible warehouse
construction.
B. Regulatory History - Previous Investigations
In 1981, EPA analyzed aerial photographs of the site as part of their
evaluation of the Commencement Bay tidal flats area and found evidence of a
pond that potentially contained waste materials. In 1981, the Washington
State Department of Ecology (Ecology) conducted an inspection of the Joseph
Simon and Sons property, noting runoff contained a considerable amount of oily
material. A tar sample was collected from the tar pit and was found to
contain 4 percent PAHS and 240 ug/1 phenol.
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In 1982. the EPA Fit Id Investigation Team (FIT) conducted a ptrtmrttr
Inspection of the site, and the results -were used together with historical
Information to complete a EPA Potential Hazardous Waste Site Preliminary
Assessment. This assessment concluded a potential hazard to the environment
existed due to the presence of oils, grease, phenols. PAHs. heavy metals, and
unknown chemicals.
Following the FIT investigation, the EPA requested that the property
owners conduct a preliminary investigation to assess the severity of
contamination, this study consisted of a data review, a hydrogeologlc
Investigation, and the collection and analysis of soils, surface waters,
groundwaters, and tars. The report from this study was Issued In May 1983.
In addition to contaminants derived from the coal gasification process, lead
and PCBs were detected.
In September 1983, another site Inspection was performed by EPA and
Ecology and in the same year, the EPA Issued a final report entitled, "Tacoma
Tar PH Scope of Work," which contained Investigative work elements necessary
to complete a RI. In 1984, the EPA prepared a Final Work Plan and In
September 1984, initiated RI activities. Shortly after the EPA investigation
was initiated, agreement was reached with several PRPs and a Consent Order was
signed allowing these PRPs to conduct the 3I/FS. The PRP investigations
commenced in November 1984.
C. The Remedial Investigation
The purpose of the RI was to determine the types of waste materials that
were present on site, the composition of these wastes, the extent to which
waste materials were distributed over the site, and the extent of migration of
toxic compounds from the waste materials. In addition to defining the nature
7 of 36
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and extent of contamination, the RI was designed to characterize site geology
and hydrology to evaluate mechanisms and rates by which toxic compounds ma
transported from the site to potential receptors. The RI also examined the
potential for airborne transport of site contaminants. The RI was performed
in several phases with intermediate reports reviewed by EPA and Ecology. The
final RI document was submitted to the EPA In September 1987. EPA and Ecology
have prepared an addendum to this report to identify and discuss issues that
were not fully addressed or investigated by the RI.
1. Site Contaminants
Based on the results of previous Investigations, a variety of waste
materials were anticipated to be present on-s1te. These materials Included:
Organic compounds derived from coal tar Including PAHs, volatile
organlcs, aliphatic hydrocarbons, cyanide, sulflte, phenols, and
heterocycMc compounds of sulfur, oxygen, and nitrogen.
Ash from coal carbonization
Coal residue
Shredded car Interiors containing metal, oil, grease,- plastics, and
synthetics fibers
Animal fat or animal byproducts
Heavy metals
PCBs
Pesticides, herbicides, and rodenticides.
To maximize the efficiency of the RI, the investigation 'was divided into
ten subtasks comprised of:
Project management
Rtstarch of available records
Site features investigation
Hazardous waste investigation
Hydrogeoloqic investigation
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Surface-water Investigation
Air quality Investigation
Biota Investigation
Bench and pi lot tests
Public health and environmental concerns
No bench or pilot studies have been performed to date, these being left
until the Remedial Design is commenced, and the final task was redirected :o
evaluate contaminant transport pathways. With these exceptions, the RI was
executed in its entirety.
2. Soil
The RI Included the drilling of 32 soil borings, excavation of 13 back.ioe
pits, and analysis of soil samples for a variety of toxic contaminants.
Organic compounds and other tar-related contaminants were found in soils at
.locations known to contain coal gasification wastes. In most locations where
organic contaminants were detected, there existed physical evidence (i.e.,
staining, odor) of tar materlal-s.
Coal Gasification Hastes
Coal tar and other coal gasification wastes are known-to be present in
three site locations: the tar pit. the North and South Ponds, and in an area
of tar bolls. Coal tar most likely occurs in a thin layer within these
historic waste emplacements. Coal tar in the ponds is 1 to 3 feet thick ana
is approximately 2 feet thick beneath the tar pit., The total estimated volume
of tar is 5000 yd3.
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Tar and soil contaminated with tar art widely distributed over the s:te
as a result of coal gasification plant operations. Figure 2 shows the
principal areas of waste discharge. These areas Include:
The plant property - possible spills and waste
Areas receiving overland flow
Areas where wastes and wastewaters were ponded
Areas receiving runoff from ponds.
Surface areas of tar contamination are confined to the three areas listed
above. The vertical extent of a relatively "pure" tar is estimated to be on
the order of several feet. However, during the soil Investigation, evidenca
of tar contamination was observed at greater depths. The vertical migration
of tar appears to have been affected by gravitational pull as black oily
layers were observed .jst above silty layers. The deepest penetration of tar
was observed at a location adjacent to the ponds where a slight tar odor was
detected at a depth of 50 feet. Figure 3 shows cross sections of the site
with the location of this soil boring (18). The location'of the cross .
sections can be found on Figure 1.
The presence of tar at depth is In part a function of the underlying
stratigraphy. In locations where less permeable confining zones (aqultards)
are present, evidence of tar at depth Is not found. At the borehole 18
location, this upper aquitard appears to be very thin or absent. A lower
aqultard between the sand aquifer and the lower aquifer also appears absent at
this location.
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PCBs
PCSs are widely distributed in the fill material across the site, with
concentrations In surface soil ranging from the method detection limit to 204
mg/kg. PCBs appear to be confined to the fill material overlying the upper
aqultard. Figure 4 shows the areal extent of PCS contamination as defined by
the RI.
Metals
Metals concentrations are generally elevated in the fill material with
significantly lower concentrations at depths of 8 to 10 feet, coinciding with
the top of the upper aqultard. Highest concentrations are present In areas
where shredded car interiors are stockpiled. Lead was the most widely
distributed heavy metal, with concentrations highest in the northern portion
of the site (greater than 10,000 mg/kg). Tars generally contained less than
200 mg/kg of lead, while most surface soils contained concentrations of 2000
to 8000 mg/kg. Figure 5 shows the extent of lead contamination In surface
soil.
3. Surface Hater
Surface runoff patterns at the site are complicated by the variety of
surface materials (I.e., asphalt, car interiors, scrap metal) and the lack of
topographic relief. Surface waters In the eastern portion of the site flow
primarily to the 8NRR ditch on the south side of the property, and then are
diverted northeast towards the Puyallup River. Surface water in the western
portion of the site flows westward toward the North and South ponds.
Monitoring of surface water flow was performed at 15 surface water
monitoring stations. Surface water quality was determined on several
occasions at five of these stations. Heavy metals, cyanide, and organic
contaminants were detected in surface waters on-site.
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Surface water quality Is characterized by near-neutral pM (6.5 to 7.2)
with conductivities ranging from 270 to 525 umhos/cn. Trace concentrations of
barium, Iron, manganese, and zinc were detected In most surface water
samples. Aluminum, arsenic, cadmium, chromium, copper, lead, mercury, and
nickel were Intermittently detected in low concentrations. Cyanide was
detected at one sampling station.
Analytical data indicates a variety of organic compounds are present in
s
surface waters. These compounds include aromatlcs compounds (benzene,^
toluene, xylene), PAHs (naphthalene, pyrene, acenapthene), nltrophenols, anc
PC8s.
4. Groundwater
The local groundwater system was investigated by construction of soil
borings. Installation of 23 groundwater monitoring wells, the sampling of
these 23 wells, and sampling of 6 wells Installed during a prior
Investigation. Information on subsurface conditions obtained by tht soil
.
investigation program was also used to define local geologic conditions. The
results of the groundwater Investigation showed that three shallow
water-bearing strata (aquifers) exist-at depths of less than 50 feet. In
order of Increasing depth, these aquifers are referred to as the fill, sand,
and lower aquifers respectively. In some locations these three "aquifers" are
separated by finer clay minerals. In these locations, flow between these
aquifers would be reduced. However, in sow locations this "confining" layer
Is absent and waters from one aquifer are in direct contact with waters from a
deeper aquifer (see Figure 3), allowing waters from these two aquifers to mix.
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The presence of ground-water monitoring devices In th>r«t s.ute'»urficit .zones
allowed estimations of directions of groundwater flow. Results indicate that
in the shallowest zones (fill and sand aquifers) tides strongly affect the
direction of groundwater flow and, therefore, water movement. However, the
system Is extremely complex, and therefore, only estimates of the quantity anc
rates of water movement are possible. As there are only a limited number of
groundwater wells investigated In the deepest aquifer, the direction of
groundwater flow cannot be accurately estimated.
Fill Aquifer Hater Quality
Water quality in this aquifer Is characterized by near-neutral pH (6.1 to
7.2) with conductivity ranging from 300 to 860 umhos/ca. These conductivities
suggest levels of total dissolved solids of about 500 mg/1. Trace
concentrations of aluminum, barium, iron, manganese, and zinc were detected in
most fill aquifer samples. Mercury, arsenic, and lead were detected in
groundwaters from some wells.
A variety of organic compounds were detected In groundwaters of the fill
aquifers. These include benzenes, phenols, and PAHs. For most wells, total
PAH and benzene concentrations range from 5 to 30 ug/1, although samples from
some wells indicate waters containing significantly higher concentrations.
figure 6 shows the area! dlstr-.jtlon of total PAH compounds in the fill
aquifer for four rounds of groundwater sampling.
Sand Aquifer Hater Quality
Groundwater in the sand aquifer is characterized by pH values ranging
frooi 5.0 to 7.0, with conductivities (720 to 7250 umhos/cm) higher than the
overlying fill aquifer. Concentrations of trace metals in this aquifer are
similar to those observed in the fill aquifer. Cyanide was detected in the
one well, and organic compounds were detected in 9 of U wells sampled.
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1180
Site Location '/.
Tacsma Tar -;:s
"accma. A;as.~.;r
Fgure *
-------
IIL.I I
CUNG(MIM«llOH
t«*l> COHti MIMA IIO« !(•• IMAM »•» M« '•».
tO«CIHIH»llOI«
Figure 5 - Lead Distribution In
Surface Soils and Tars
-------
1 1 1.1 NU
^>
V;
-.Cb
/ . t 1
/ ) ,,
• •4 *l t^»«l*
' •» /""
nbk! s/ ' * r
-7
;/ ,
Figure 2 - Distribution of
Coal Gasification Wastes
-------
Figure 6 - Tola! PAN
Concentration In Fill Aquifer
-------
\.
\
O.
< "Vj
€•*•!•
/ > V
>h N <
!•* ««J«f .U*I*J M«.tA !•
IA Ml* »*UlUI «>»J 1} IAMO I
Figure 7 - Total PAH
Concentration in Sand Aquifer
-------
Figure 3 - Subsurface
Lllhology and Tar Occurence
-------
( )
i-cu* UM^i
• rCtt LaiikMiiKiiun I • S nig /kg
) I'CU Cuiu«n»«iiun 1 Au
fLU Loui.. nil (lion LUMIIW
60 ii^g 'ky
N
M »'. U 1(1 If
>•• ••««• «>«J »•»• M II*) • tw. « 44
I*<4U »«lltl4«4 II I*WI> (1*11(1
Figure 4 - Tolal PCB
Distribution In Surface
Soils A Tars
-------
Organic compounds detected include btnztnts, phenols, an,d Hst s-hrt l*r to the
fill aquifer. Although very high PAH concentrations *ec«
-------
6. Contaminant Migration
Aj£
Contaminants of concern at the site could potentially be transported
tfit sfti by -wind. Therefore, the RI considered the potential for nwvement of
small particles by ttiis mechanism. There are two methods to estimate wind
dispersion. The concentrations in the air can be measured directly or the
quantity of participates can be estimated using established mathematical
methods. The RI team utilized the latter of these approaches. Results
suggest that PCBs and lead are the pollutants of greatest concern. Results
also Indicate that on-slte workers would be the only humans at risk from
exposure to these contaminants. The site poses no risk to the surrounding
community by wind blown dispersion of contaminants.
Surface Hater
Surface-water flow rates and contaminant concentrations were used to
calculate fluxes of contaminants leaving the site via the surface-water
*
pathway. A single surface-water monitoring station was selected and fluxes
calculated for compounds that had been detected at that location. Fluxes are
available for selected metals, benzenes, and PAHs.
Ground Water
The estimation of rates of transport for contaminants via the groundwatsr
system is limited by the current lack of understanding of local groundwater
hydrology. Due to the complicated nature of the system, values have a low
*
degree of confidence and should be used with caution. Fluxes for metals,
benzene, phenols, and PAHs were calculated for fill and sand aquifers.
Contaminant fluxes are generally low.
IS of 36
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0. The Risk Assessment
The purpose of the risk assessment was to determine the magnitude and
probability of potential harm to humans and the environment and to determine
site performance standards (cleanup levels). The RA evaluations were based on
the results of the RI and methodology currently In use by the EPA. These
methods establish guidance for the estimation of levels to which hazardous
waste sites should be remediated.
The RA evaluations consisted of four study elements: exposure, toxlclty.
risk characterization, and selection of "How Clean Is Clean" levels or site
performance standards. The methodology used In the RA under the above study
elements includes the identification of exposed populations and exposure
pathways, the selection of indicator contaminants for carcinogens and
threshold-acting chemical constituents, computation of acceptable doses for
these target chemicals, and the quantification of risks.
The major contaminants at the site are coal tar pitch residuals, PCSs,
and trace metals. From data generated by the RI, three organic constituents
and one trace metal were selected as indicator chemicals representing the
overall level of site contamination. These indicator contaminants were
selected based on their toxlclty, concentrations in site waters and soils, and
tendency to be transported from the site. The selected Indicator compounds
are benzo(a)pyrene, PCSs, benzene, and lead. The RA evaluations were
performed for these indicator chemicals and the exposure pathways appropriate
to the target population. Soil ingestlon, inhalation of airborne partlculates
and vapors, and dermal contact were all considered pathways for exposure.
The target receptors (exposed population) considered for the RA were the
on-slte workers. Since :he site is within a heavily industrialized area,
wildlife or fish populations were not considered as target receptors except
16 of 36
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for the ivlan .population wlriseh occasionally uses thi ;pon;d artAS on the site.
Tht "Ho* Clean Is Clean"1 levels dieftn>e;d as maximum allowable
concentrations (MASC) for on-si'fee -soils were determined from simple .nodels
which quantify the transport of contaminants from the source (on-site sol's)
to the receptor (on-site workers). In addition to transport factors, the
models account for the contaminant intake rate which will not induce an
adverse affect to target receptors. This latter parameter, defined as the
\
\
Acceptable Oose (AO), was estimated from EPA-apprdved hazard assessment data
for carcinogens and threshold acting chemicals.
MASCs were calculated from these predictive models and the uncertainty
associated with these values was quantified using probabilistic sampling
techniques. The MASC values for the target contaminants were then reported as
the concentration of the contaminant In soil associated with a specific.
probability of exceeding the acceptable level for that constituent.
For lead, the MASC was computed for two AO values corresponding to the,
promulgated maximum contaminant leve-1 (MCL) and the recommended maximum
contaminant level (RMCL). The AOs for lead were derived from drinking water
standards. For the carcinogens (benzene, benzopyrene, PCS), the MASCs were
reported for two risk levels, 10" and 10"°, and for two exposure periods
(lifetime and short term). The lifetime exposure period assumes that a site
worker would be in contact with site soils for a 70-year period. The
short-term exposure period assumes continuous contact with deeper soils or
tars for a t-month period during construction or excavation activities.
Thi MASC values computed for the individual and cumulative pathways are
summarized In tabular form in Table I. Included in the table are the
comparable MASC values associated with a 10 percent probabi11ty of exceeding
17 of 36
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Table 1. Pathway Specific NASC Values
Cliemital
U.«l
1 eu,l
UAI'
I'CB
Benzene
Exposure
Period
Daily
Daily
Lifetime
Short Term
Lifetime
Short Term
,
Short Tern
Risk level
0, AD from MIL
0; AD from RHCL
I0«
10 6
10 4
10 6
I02
10 6
«°J
I06
1
IOJ
10 6
Ingest ion
NASC
<«g/kg)
91
226
16
0.2
1132
11.3
3.6
0.04
3,013
30.1
444,000
4,440
Dermal
NASC
98
242
2.4
0.02
93
0.93
0.7
0.01
588
5.9
1.637,000
16,370
Inhalation
NASC
(«g/kg)
2,500
6,250
2,673
26.7
158,800
1,588
947
9.5
782,353
7,824
5,654
56.5
Cumulative
NASC
(mg/kg)
57
139
2.2
0.02
87
0.9
0.6
0.01
524
5.2
5,613
56
C253I
-------
Contaminant or
Contaminant Class
lead
benzene
PCBs
PAH*(I)
Table 2
Maximum
Soils
(mg/kg)
I66<2)
56(3)
1.0<3)
».0(3)
. Cleanup Go|flterformance Standards
Allowable CoWnnant Concentrations
Tacoma Tar Pits Site
Surface Hater,
Boundary (ug/l)
3.2<4>
53(5>
02(4)
5 - 30(6)
Surface Hater
On-Slte (ug/l)
)72(7)
5.300(7)
2(7)
2.9(7>
Groundwater (sand
and fill aquifers)
(ug/l)
50
(I)
(3)
(4)
(5)
(6)
(7)
(8)
Included are benzo(a)pyrene. benzo(d)anthracene. benzo(b)fluoranthene,
benzo(k)fluoranthene, dlbenzo(a.h)anthracene. and lndeno(I,2,3-c,d)pyrene.
Acceptable dose.
I0~6 Risk Level.
Chronic freshwater ambient water quality criterion. Performance based on detection limit
Acute freshwater ambient water quality criterion x 1/100.
estimated range of chronic freshwater ambient water quality criterion based on marine
criteria.
Estimated acute freshwater ambient water quality criterion.
Drinking Hater MCL.
-------
thi acceptable dose for *aeH 'target chemical and each pathway, and the
cumulat1v
-------
IV ENFORCEMENT
A RI and FS was conducted by Joseph Simon & Sons, Inc., Washington
Natural Gas Company, Hygrade Food Corporation, and Burlington Northern
Railroad Company pursuant to an "administrative order on consent" enterea insc
and Issued by EPA on November 1, 1984. EPA is now prepared to implement the
settlement procedures set forth in Section 122 of CERCU, 42 U.S.C. §9622. and
offer these same parties the opportunity to perform the selected remedial
action pursuant to a consent decree. EPA Intends to commence a negotiation
period with the PRPs shortly after the signing of the ROD. The Department: of
Interior and the State of Washington have been invited to participate In the
negotiations. If for any reason, agreement cannot be reached with these
parties, EPA will initiate alternative action to Insure that the remedial
action proceeds. Finally, EPA is still considering the possibility of
Identifying additional parties who may be potentially responsible for
conditions at the site.
19 of 36
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V COMMUNITY RELATIONS
Community Interest for the Tacoma Tar Pits Superfund site has not been
actively demonstrated to either EPA or Ecology. It must be considered that
this site is actually a small unit within the larger Superfund site,
Commencement Say - Nearshore/Tldeflats and that, the Tacoma Tar Pits is located
within a heavy Industrialized area with no private residences nearby. In
fact, the community relations plan for the Tacoma Tar Pits Is contained within
the plan for Commencement Bay and South Tacoma Channel Superfund sites. Under
a cooperative agreement with EPA In 1983, Ecology was delegated as the lead
agency In conducting investigations for the Nearshore/Tldeflats, Ruston/VasJron
Island, and Tacoma Municipal landfill sites. EPA retained Its role as the
lead agency for the Tacoma Tar Pits, ASARCO Tacoma Smelter, South Tacoma
Swamp, and Well 12A sites. The Tacoma-Plerce County Health Department,
(Health Department) through another Interagency Agreement with Ecology.
conducts community relations support activities for the Nearshore/Tldeflats
and Ruston/Vashon Island sites.
The Commencement Say and South Tacoma Channel Superfund sites are located
within the City of Tacoma, on the south central portion of Puget Sound, Pierce
County. Washington. Tacoma Is one of the oldest cities in the Pacific
Northwest, dating back to 1341. The population of Tacoma, the second largest
city In Washington nest to Seattle, is 153,501 (U.S. Department of Commerce,
1980), and 485,667 people live In Pierce County.
20 of 36
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Manufacturing, wholesale and retail trade, and services are the primary
Industries In the Tacoma area (Washington State Employment Security, 1985),
arlth t large portion of the labor force employed in the manufacturing sector
.Surrounding areas are characterized with densely populated forests which
supply the lumber necessary to local industry. Manufactured goods are
primarily wood and paper products, and chemicals. The Port of Tacoma is tne
state's largest export port, and auto Import port. It is the fourth largest
auto Importer on the West Coast. During the years 1980 to 1986 the county's
population has grown 9.3 percent, and non-agricultural employment increased by
15.2 percent (Washington State Employment Security, 1987). Clearly, Tacoma's
economy has been growing steadily In recent years.
Both present and historical industrial activities have released hazardous
chemicals and other production by-products into Commencement Say, the South
Tacoma area aquifers, and the surrounding environment. These products Include
metals (arsenlt, lead, zinc, copper, cadmium, hydrocarbons (PAHs), chlorinate^
butadienes, and pesticides. Hazardous substances have been found In sediments
in the waterways, cadmium and arsenic have been documented Is soil's near the
Ruston area, PAHs and PCBs have contaminated groundwater aquifers In the South
Tacoma area, and fish and shellfish in Commencement Say have been found with
elevated levels of organics and other clorinated compounds in their tissues.
ChtoHcal contamination of Commencement Bay and the South Tacoma Channel
area prompted the site's nomination to the National Priorities List (NPL) in
October, 1981. In April, 1983 t^e EPA announced an agreement with Ecology to
conduct a RI/FS for the Commencement Say Superfund s-1te. The RI, which was
completed in 1985, characterized the .nature and extent of contamination in :ne
21 of 36
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Nearshore/Tldeflats area. The FS, which evaluates and alternatives of cleanup
action for this area of the Tacoma Superfund Sites Is now underway. Ris for
the Tacoma Municipal landfill, South Tacoma Swamp, Tacoma Tar Pits, and South
Tacoma Channel, and FSs for the South Tacoma and Tacoma Tar Pits have been
completed. An on-site RI for the ASARCO Tacoma Smelter began in September,
1987. These investigations are being conducted by private consulting firms.
Community Involvement
Tacoma area residents became acutely Involved in Commencement Bay ana
South Tacoma.Channel environmental issues prior to their nomination to the NPL
In October 1981. Over one hundred people attended an April 1981 public
meeting at which several federal, state, and local governmental agencies met
to explain the area's contamination and hazardous waste problems, and describe
what would be done about the situation. Concern about these problems was
moderate, with groups such as-the Audubon Society and Hashington Environmental
Council the most active. Most people's comments at that time centered around
the perception that not enough was being done to correct the problems, at
that time, Commencement Say and the South Tacoma Channel were given
considerable press and media attention.
In the years following Commencement Say and South Tacoma Channel's
nomination to tht NPL, the level of citizen concern appears to be less than it
was In 1981. EPA, Ecology, and other agencies have conducted several
Investigations, sampling-analysis surveys, and cleanup activities at many of
22 of 36
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the Individual areas within tn« Commencemtnt Bay and South Tacoma Superfund
sites. These Investigations have served as demonstrations that Tacoma's
hazardous waste problems are not being Ignored, and have provided a bette?
understanding of the nature of the problem and Its risfc to human health and
the environment.
The Health Department by Interagency Agreement with Ecology has been the
lead agency for Implementing a Superfund Community Relations Plan was
completed for the Commencement Say site. In response to Input at a public
meeting held in 1983, the Health Department developed a Citizen Advisory
Comalttee (CAC) to help implement the Community Relations Program during
investigations and remedial action at these Superfund sites.
Community Relations activities conducted by the Health Department have
Included: Coordinating and holding public meetings for Informational purposes
and at various stages of the spedftc site investigations and cleanup,
briefing local governmental officials on the status of area Superfund
investigations, hazardous waste presentations to grade school children,
presentations to environmental groups and interested parties upon request, and
tours of Commencement Say. Additional activities have included the production
and distribution of oamphlets and fliers (including translation for Asian
communities) to Tacoma and Pierce County communities, and preparing project
updates, fact sheets, and press releases.
23 of 36
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Specific Activities: Tacoma Tar Pits
On three separate occasions over the past two years EPA has met with the
CAC to update the group as to the progress with the Investigations and to
indicate EPA's future plans. The CAC as well as a larger group of interested
citizens and special interest groups have been recipients of news letters and
project updates. The most recent mailing was Issued the first week In
November 1987. Approximately 200 copies of the Proposed Plan and Project
update (Fact Sheet) for Tacoma Tar Pits were sent out using the Commencement
Say mailing list. On November 18, 1987, EPA held a public meeting at the
Pierce County Health Department to accept comments on the preferred
alternative for remedial cleanup at the Tacoma Tar Pits site. Despite wide
coverage by newspaper, radio, and a local television station, only two private
citizens came forward to comment on the proposed plan. These comments are
addressed in the Responsiveness Summary. Copies of the Administrative Record
have been maintained at the Tacoma Public Library. Although no comments other
than those from the Potentially Responsible Parties (PRP) wert sent by the
close of the public comment period, EPA shall continue to make the effort to
keep the public Informed and provide an opportunity for participation. This
aspect of the community relations effort addresses the overriding concern
expressed by citizens that information must be both accurate and timely as
opposed to the Information they formerly received solely through the media.
•
Tht other major concern expressed is that they do not see the agencies taking
corrective action on so called priority sites. Tht high level of community
relations activities and proceeding forward with the ROD leading to remedial
action are the best measures to deal with these concerns.
24 of 36
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VI ALTERNATIVES EVALUATION - FEASIBILITY STUDY
The purpose of the FS was to develop and evaluate possible alternatives
to perform site cleanup. Available technologies were screened for
applicability and assembled into alternatives ranging from no action to
permanent treatment of all contaminants. A total of 19 preliminary
alternatives were developed, nine of which Included options for groundwater
extraction and treatment. Technologies considered In these alternatives
included dust control, capping, stabilization, excavation with off-site
landfllllng, electric pyrolysls, Incineration, and 1n situ vitrification for
the soils. Groundwater extraction with wells or subsurface drain pipes was
Included, as was pumping of pond water. Water treatment options Included
activated carbon adsorption and filtration or stabilization. Ten of the
preliminary alternatives, including no action, were retained after Initial
screening for health protection and cost.
* '
Site conditions were evaluated and clean-up levels established based o.^-
lifetlme cancer risk levels of one per ten thousand (10" ) and one per 1
million (10 ). Alternatives containing foil excavation were evaluated for
both of these risk levels.
Table 3 contains a brief description of the 10 candidate alternatives.
These alternatives were subjected to detailed analysis. According to
regulatory guidelines, the detailed analysis of each alternative included:
Refinement of the alternative with emphasis given to defining established
ntthods of handling or treating wastes.
Evaluation In terms of engineering implementation, reliability,
anticipated performance and safety.
An assessment of the extent to which the alternative is expected to
effectively prevent or reduce the threat to public health and welfare and
the environment.
25 of 36
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An analysis of any advtrst environmental Impacts and methods for
or eliminating thtst Impacts.
Detailed cost estimation, Including costs associated with long-tirm
operation and maintenance associated with the alternative.
The degree to which each alternative conforms to federal and state
requirements and regulations.
Concerns of the community.
Table 3. Summary of Remediation Alternatives
Alternative
1 No soil or water remediation Is performed. Continued groundwater
monitoring. Every five years, the site Is relnvestlgated to
determine the disposition of contamination. No other actions are
conducted.
4 Source control of contaminated pond water. On-s1te land use
restrictions are imposed to prevent future exposures to soil.
Potential exposures to contaminated groundwater are controlled by
water use restrictions.
5 Source control by treating contaminated surface water, management of
migration of soil contamination by capping with a soil base and an
asphalt surface, monitoring of groundwater, land-use restrictions
and water-use restrictions on the site.
6 Treatment of pond water. Use of an impermeable cap to manage
contaminant migration, and institutional controls including land-use
and water-use restrictions.
9 Stabilization of surface soils exceeding one per 10,000 cancer risk
to create an impermeable surface, treatment of the pond water by its
use in the stabilization process, control of surface water
infiltration by constructing drainage ditches, land and water use
restrictions, and site monitoring.
9b Groundwater extraction and treatment used in conjunction with
alternative 9.
13 Similar to Alternative 9, except that surface soils with
contamination exceeding the one per one million cancer risk. levels
for PCBs, PAHs, and benzene are stabilized.
13b Groundwater extraction and treatment used in conjunction with
alternative 13.
15 Permanent treatment of the contaminated surface soils by
Incineration and stabilization. Pond water is treated by its
Incorporation into the stabilization process. Clean backfill
material is placed on the unpaved areas. Incineration residues are
stabilized with the lead-contaminated wastes. The stabilized
material is placed to form an impermeable cap. Groundwater
monitoring and land and water use restrictions.
ISb Groundwater extraction and treatment used in conjunction with
alternative '5.
26 of 36
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15 Surface-water treatment; excavation of surface and subsurface soils
contaminated above the one per 10,000 risk level for PAHs;
dewaterlng of soils as necessary for excavation and treatment of *^
water, backfilling and compaction; grading of the site and
construction of a drainage ditch to prevent surface-water ponding;
repavlng of areas necessary for metal recycling operations; land and
water use restrictions.
16b Groundwater extraction and treatment used in conjunction with
alternative 16.
18 Surface water in ponds Is treated with water obtained from
dewatering of soils. All contaminated soils above the one per 1
million risk level are removed and landfllled off-site. Clean soil
Is backfilled into the excavation pit. The soil Is then compacted
and graded so that surface water flows to a drainage ditch and dees
not pond. Ground water is monitored and temporary water use
restrictions are imposed.
18b Groundwater extraction and treatment used In conjunction with
alternative 18.
19 Organic contaminants in soils above the one per 1ml11 Ion risk level
are destroyed by incineration. Soils containing lead and other
heavy metals are stabilized; contaminated surface water Is used in
the soil stabilization process. The slurry Is spread over the site
and allowed to solidify into an impermeable surface. Ground water
Is extracted and treated until analyses indicate that the
groundwater meets the cleanup levels.
The ten candidate remedial alternatives were rated according to the
concerns listed above as grouped Into the fallowing five criteria:
Technical feasibility ' ;
Institutional requirements
Pub!1c health impacts
Environmental Impacts, and
Cost analysis
Table 4 contains factors wnich contribute to each of these five criteria.
27 of 36
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Table 4. Detailed Evaluation Criteria
TECHNICAL FEASIBILITY "
Performance
Effectiveness
- Useful life
Reliability
Operation and maintenance requirements
Possible failure modes
Implementabillty
Constructabillty
T1n»
Safety
Worker
Neighborhood
INSTITUTIONAL REQUIREMENTS
Conformance to Applicable or Relevant and Appropriate Requirements (ARARs)
Community Concerns
ENVIRONMENTAL IMPACTS
Beneficial effects
Final environmental conditions
Improvements In biological community •
Improvements in resources-
Adverse effects
Construction and operation
Mitigative measures
PUBLIC HEALTH IMPACTS
Minimization of chemical releases
Exposures during remedial action
Exposures after remedial action
COST
Capital cost
Operation and maintenance costs
Present worth
28 of 36
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Each of the candidate alternatives was rated for the above factors
according to a high/moderate/low scheme. A high rating Indicated that the.
alternative meets or exceeds objectives for cleanup. A moderate rating
Indicates the alternative only partially addresses the clean-up objectives,
while a low rating indicates that clean-up objectives are not met for this
criteria. The ratings for each factor In general categories are then
combined. These ratings for the 10 candidate alternatives are presented in
Tables. As Alternatives 9, 13, 15, 16, and 18 contained options for
groundwater treatment, these alternatives have two sets of ratings. The
alternatives Including groundwater treatment are numbered with the Symbol b
(I.e. 9b).
From this evaluation a preferred remedial alternative was selected. The
selection considered the degree to which site performance standards would be
attained, the degree of clean up performed as required by regulations, and the
degree to which routes of contaminant exposure are eliminated or controlled.^
29 of 36
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I able 5.
of Detailed evaluation
technical In
feasibility Coi
No. Haling .
1 Hi ah
<. High
*H»
6 High
V High
Vb High
11 High
lib Nigh
IS Nigh
lib Nigh
16 Nigh
I6b Nigh
Itt Nigh
(fib Nigh
19 High
Hole: NmAtitd cleanup alternative* with idv
ial ilul tonal
Iullit-T.lt lOlli
Nut ing
low
low
low
M odor oie
H.gr.
HI ai>
HI at>
Higii
HI at*
HI an
mail
HI aii
n i ai>
mat)
HI*
Syii«x>! b indicate
lefMCta Baling
Moderate
Moderate
Moderate
Moderate
Moderate
Nigh
Moderate
mgh.
Moderate
Nigh
Nigh
Nigh
High
Nigh
High
ground-water e>tr«cilon and
Pub! ic Heal Ih
Impacts Bating
low
Moderate
High
High
High
High
Higii
High
High
Nigh
High
High
High
High
High
treatment has been included.
Cost Analytic
(Present Worth.
Million Oollart)
0.0
1.0
1.7
i.a
1.)
4.2
3.4
4.3
a.t
9.0
93.1
9S.fi
I3S.I
1)3.6
242.9
-------
i
N
I
APMtOXIMAIE
SCALE• O ^ ..,.,. i ; ',;'
-------
VII SELECTED REMEDIAL ALTERNATIVE ('No. 13)
Tht preferred remedial alternative (No. .1.3.) Is a combination of source
control measures, measures to control contaminant release, and also measure!
to reduce human exposure to contaminants. This alternative consists of the
excavation of the most severely contaminated soils, stabilization of these
soils using a technique which Immobilizes contaminants, capping of the
stabilized material, treatment of surface water, continued groundwater
monitoring, regulatory controls on water usage for both surface and
groundwater, and restrictions on site access.
A. Description of the Selected Remedy
1. Soil Excavation
Surface soils exceeding the 10 lifetime cancer risk level, and all
soils regardless of depth which are classlfl?-! as Extremely Hazardous Wastes
(EHH) under state law are to be excavated. Soils classified as EHM are
defined as those soils exceeding 10,000 mg/kg (1 percent) PAH. Soils beneath
the tar pit and ponds are known to contain PAH In excess of 1 percent. The*'
soils will be excavated to a depth required to show PAH concentrations less
than 1 percent. When the Remedial Action Is undertaken, this state standard
may be reevaluated for technical feasibility as allowed under §121(d)(4)(8) of
SARA.
Soils and sediments from other areas will be excavated to a depth not to
exceed 3 feet in all locations where soils exceed concentrations defined to
havt a 10~6 lifetime cancer risk. This 10"* risk level translates to 1
mg/kg for PCS, 1 mg/kg for PAHs, and 56 mg/kg for benzene (Table 2). Surface
soil contaminated with lead above the 166 mg/kg level Is also excavated and
stabilized. The approximate area designated for excavation is shown in
Figure 3.
30 of 36
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Tht total miniated voiunw of material to bt excavated 's 45,000 cudic
yards. BacJchoes, bulldozers, and front end loaders will be used to excavate
soils. Oust control measures such as wetting of soils will be used during
excavation to prevent wind dispersion. Sediments from the ponds are excavated
later In the remedial action as waters must first be removed from the ponds. .
Operations at the metal recycling facility will be temporarily relocated wnen
the area which Is currently paved Is remediated.
2. Soil Stabilization
To reduce the ability of contaminants to migrate from the soils prior to
replacement on site, the excavated soils will be chemically treated or
stabilized. Laboratory experiments will be performed to ensure that the
stabilization process effectively Immobilizes contaminants. Following this
activity, a larger scale "pilot study" will stabilize a larger volume of
contaminated material from the site. This pilot study will determine the
effectiveness of the stabilization process.
As excavation proceeds, the contaminated material Is moved to a hopper
which screens out material larger than 6 Inches In diameter and feeds the
material to a grinder or crusher. The grinder pulverizes the material to
produce particles smaller than S to 10mm In diameter. The material is then
fed to a mixing vessel where silicate polymers, cement, and water from the
site ponds Is added. The waste will need to be thoroughly mixed prior to this
step.
The proportions of polymer and cement to be added will be determined by
laboratory scale studies. The final composition of the stabilized material
may vary depending on the composition of soil encountered during excavation.
It Is estimated that 200 to 400 pounds of cement and-polymer will be added per
ton of contaminated soil, along with 10 to 25 gallons of water.
31 of 36
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3. RfalacemtfTt of StaiblllMd Sot!
T;ht ehfi*l!oal 'Stabilization process should significantly reduce the
J toxlclty *nd leach-afeinty of site soils. Therefore, this material will be
placed back Into the locations from which It was excavated. The stabilized
soil will be dense and relatively Impermeable to rainfall or surface water.
To further reduce the flow of surface water through this stabilized material,
an asphalt cap will be placed over the stabilized soil. An asphalt sealer
will be used as part of this capping procedure.
Prior to placement of the stabilized mixture, the site surface will be
graded to form a 3 percent slope toward the 8H railroad tracks to the south.
A furrow will be dug along the edge of these tracks and along the western side
of the existing ponds to provide a drainage ditch. Clean fill material may be
.needed In the areas of the ponds to bring the surface up to grade. The
mixture will then be spread over the area Indicated In Figure 3. Th-ls process
will proceed from the tar pit area toward the ponds. The material will be
laid as a continuous layer and will be allowed to cure for up to 1 month.
Tht reagent composition Is formulated to provide a high-strength surface
capable of supporting trucks and'other vehicles. In order to protect the
stabilized surface from heavy equipment wear, a 2-inch layer of asphalt will
be placed over It. The surface will be periodically Inspected and, if
necessary, repaired.
Land use restrictions will be imposed to prevent or require stringent
*
control of future excavation on the site, to prevent future use of surface
water and shallow groundwater, and to prevent site access by personnel other
than site workers.
32 of 36
-------
4. Groundwater Extraction and Trtatimnt
At this time, It Is not expected that groundwater extraction and
treatatnt will be necessary. An expanded groundwater monitoring network
utilizing to the extent practicable those wells shown in Figure 8 will be
designed, and regular groundwater monitoring will be performed. To accompiis?
this, it is likely that additional wells will need to be installed. If
concentrations are determined to be statistically representative of levels
exceeding site performance standards, the need for groundwater extraction and
treatment will be evaluated in a subsequent study.
At the current time, the groundwater system has been Insufficiently
characterized to completely design groundwater extraction and treatment
systems for the fill, sand, and lower aquifers. Exact locations and depths of
extraction wells cannot be specified nor can anticipated rates of groundwater
extraction be estimated. Therefore. If groundwater extraction Is deemed
necessary, additional characterization of the hydrogeologlc conditions of the
site will be necessary as part of the system design.
5. Performance of the Selected Alternative
The proposed cleanup option was selected due to the fact that it provides
a treatment alternative which reduces the mobility and toxlclty of the
contamination, will bt protective of human health and the environment, attains
ARARs, and Is a cost-effective method of site cleanup. The benefits of this
alternative are discussed below. First and foremost, human exposures to
contaminated soils are prevented, thereby addressing the most significant
health concern. Pond water is treated, and surface water Infiltration is
prevented by the impermeable cap. Thus, potential exposures via water sources
are controlled. Permanent treatment can be provided through the
33 of 36
-------
Imjebnization of contort numbs* T'h» cost of this alternative, estimated to be
about $3.4 million, Is slgn-lflca'ntly less than other alternates which offer
a comparable level of protection.
As required by Section 121 of CERCLA for Remedial Actions where wastes
remain on-slte, the performance of the remedial action will be refnvestlgatea
every 5 years to ensure that the remedial action has been effective, that
increasing levels of contaminants are not being released to the environment,
and that human health and the environment are protected. If as a result of
this frequent reassessment, the remedial action Is shown to have decreased
performance, the nature and extent of additional actions will be considered.
B. Statutory Determinations
The selected remedial alternative meets all statutory requirements,
particularly those of CERCLA as amended by SARA. The highest priority Is- the
protection of human health and the environment. The use of stabilization
permanently treats/fixes contaminants. Therefore, the landfill closure and
post-closure care requirements are satisfied with respect to control of soil
contamination releases. In addition, tar sludge beneath the site with PAH
concentrations in excess of 1 percent are removed and treated. PCS materials
exceeding 50 ppm are permanently immobilized, consistent with the Toxic
Substances Control Act (TSCA) regulations. Permanent treatment, as preferred
under SARA, is used.
ARARs pertaining to surface water are satisfied because contaminants in
existing surface water are removed to nondetectable levels, future off-site
discharges of surface water should meet discharge limits because the
surface-water runoff does not flow Into contaminated materials.
34 of 36
-------
Tht release of additional contaminants to the froufldwtt«r 1$ ntdweeti :by
the placement of an Impermeable cap, and tht control of surf ace-wattr rwof**
Additionally, the permanent Immobilization of wastes satisfies groundwater
protection regulations. Therefore, presently uncontamlnated groundwater *i!l
be clearly protected, consistent with groundwater protection and
nondegradatlon regulations. Existing contaminated groundwater within the site
remains untreated; however, land use restrictions will ensure that the
groundwater Is not extracted or used. Action levels of contaminants in
groundwater have not been consistently exceeded at off-site locations.
Groundwater monitoring Is conducted at the site boundaries In accordance with
Resource Conservation and Recovery Act (RCRA) closure requirements to ensure
that contaminated groundwater does not migrate beyond the site boundaries.
Impacts to the community are minimized through the use of this
alternative. Some operations at the metal recycling facility may be suspended
during the Implementation of this alternative; however, following remediation^
activities may resume and should not be'restricted.
The cap which Is produced from the stabilized soil and asphalt will be
able to support driving and operation of light equipment. Large structures
may be placed if support piling is included. Land use restrictions will
ensure that placement of any such support is done In such a way that 1) any
contaminated soil brought to the surface during placement is handled in
accordance with RCRA and state hazardous waste regulations, and 2) the
Integrity of the cap In maintained.
Tht selected remedy will also meet all substantive laws and regulations
of other ARARs. These are listed and their application is briefly described
In the FS.
35 of 36
-------
T'ht law and regulations of concern Include:
Resource Conservation and Recovery Act (RCRA. 42 USC 6901); RCRA
regulations (40 CFR 261 to 280); Washington State Dangerous Waste
Refutations (WAC 173-303); Minimum Functional Standards for Solid Waste
Handling (MAC 173-304).
The selected remedy prevents further spread of groundwater contamination
and constitutes a Corrective Action Program as specified in 40 CFR 264
and WAC 173-303-645(11).
Safe Drinking Water Act (SOWA, 42 USC 300); Primary Drinking Water
Standards (40 CFR 141).
Clean Water Act (CWA, 33 USC 1251); National Pollution Discharge
Elimination System (NPOES, 40 CFR 122); NPDES Permit Program (WAC
173-220).
The final selected remedy meets the requirements of cost-effectiveness as
this alternative provides for permanent treatment, and contaminant release
minimization for a cost significantly less than other alternatives exhibiting
a similar level of protection. The estimated present worth of the selected
remedy Is $3.4 million, while alternatives 15, 16, 18. and 19, provide similar
levels of protection for costs of $8.1, S93.1, $133.1, and $242.9 mill Ion,
respectively. Additional cost of these Is the result of the.use of more
costly technologies such as incineration (15, 19) or the excavation of larger
volumes of soils coupled with off-site landfill ing (16, 18).
36 of 36
-------
APPENDIX I
INDEX TO ADMINISTRATIVE RECORD
-------
AUIINlSIHAIIVt kttUKU OF 1AH PITS SITE
l)GC«
Flit:
Type/Description
Date • Pages
Author/Orgsnixat ion
Addreaaee/Organisation
OOOOOOOI. Pro i>u(ici luuJ Information
Research material re; Tacoma Tar Pit
and Washington Natural Ca« fro* 1924
to 196?
Wl/82
Kwacl Boateng. Ecology and John Oaborn, EPA
Environment, Inc. (E6£)
UOOOUOO;.
luiid Inloimatlon
OOOOOOOJ. fit: bii|.ci(und lltfoimallon
Miscellaneous data re: Tacoma Caa Plant 1965
Including Washington Natural Caa Rellre-
•ent Requlaltlon
Feralt to Appropriate Public Ground • 9/29/67
Uatara of the State of Uaahlngton
10
Unknown
Unknown
llygrade Food Product* Corp. State of Washington. Oep
Water fteaourcea
UUUOUUU'. . |-ic ^u|iui|und liiiuraatton
OOOOOOOS. Pie Su|.crfund lufonaatlon
0000000). Pie Super fund Intonation
0000000ft. Pre Super fund Information
OOO00009. PrelUlnary Site Investigation
OOOOOOIO. I'rullalu.iry Site Investigation
OOOOOOU. Preliminary Site Inveatlgatlon
Washington Cua «nd Electric Coayany
dlagraa of Tacoaiii Cas Plant, newspaper
articles
Material Hat and atorea Issued to
contractpr
Letter re Inforauitlon on old Tacoaa
Manufactured Cas Plant
"CoMenceaent Bay - Nearshore/Tldef lats
Drainage Systesi Investigation
HesM> re prellsilnary field Investigation,
ISCOM "Tar fit," alts history search,
attached diagrams, prallalnary assessatent
fora, enforcement pr<-" to map
Letter re Joseph Simon and Sons, Inc.,
and alt* Investigation of study area
Utter re alte Investigation of Tacoma
Tar rita by PW»
Washington Caa and Electric The News Tribune, face
Public Library PI lea
8/23/56
11/5/82
3/30/82
8/10/02
9/1/82
2
3B
12
T. Hllllgan, Waahlngton
Natural Caa
T. Hogan, Washington
Natural Cas
Unknown
Robert Posi* EPA
Tscoaa-Plerce County Health Wsthlngton DOC
Dept.
Hussein Aldls, Ecology and John Osborn^ BPA
Environment
Roy Kussman of McCavIck, Robert Poss, EPA
Cravea, Besle A> HcNerthney
0. Bell, Burlington Northern Robert POSs, EPA
-------
UK*
Type /Uc »c r 1 i»t I on
Date
Autlior/Organliat Ion
Addreaiee/Organltat Ion
00000012. Preliminary Site Investigation
OOOOOOU. Preliminary Site Investigation
.OOOOOOH.. Preliminary Site Investigation
OOOOOOU. Preliminary Site Invcstlgstlon
OOOO0016. Preliminary Site Investigation
v.
OOOOOOU. Preliminary Site Investigation
00000016. PrellMlnary Sit* Investigation
00000019. Preliminary Site Investigation
00000020. Preliminary Site Inveatlgetlon
00000021. Preliminary Site Investigation
Letter re Union Pacific Involvement In 8/31/H2
Initial site Investigation
Letter re Involvement of Washington 10/1/82
Natural Gas In preliminary alte Investi-
gation
Letter re preliminary alte Investigation JO/25/82
with attached comments of EPA on proposal
by Kannedy/Jenks Engineers
Utter re Tacoma Tar Pits Investigation 11/9/82
consent order
Letter re participation of llygrade Food 11/11/82
Producta In alte Investigation of
Tacoma Tar Pita
Letter re participation of Hygrade 11/12/82
•Food Products In site Investigation
of Tacoma Tar flta, and responae to
Administrative Order
Letter re participation of Joaeph Simon 7/JO/82
4 Sons In site Investigation of
Tar Pits
Hemo re asslstsnce for Tacoata Tar Pita 1/24/8)
alte lovestlgetlon In sample analyals
Letter with attached map and diagram re 2/4/8)
proposed locations of well* and sampling
altes at Tacoma Tar Pita
Draft report entitled "Soil end Ground 5/83
Water .Contamination Assessment of
Commencement Bey Tar Pits"
00000022. Preliminary Site Investigation Letter re Washington DOE'a comments'
oo draft report on soil and groundwater
contamination by Kennedy/Jenks
Engineers .
7/18/83
Jeff Aaay, Union Pacific
Railroad Co.
Robert Poaa, EPA
Timothy llogan. Uoniilngton Robert Poaa, EPA
Natural Gas
Robert Poss, EPA
Roy Kusomann of HcCavlch,
Craves, Heale 6, HcHcrtlmey
Oouglaa fcnlke. Douglaa B.
EhIke & Assocs.
Oouglaa Eh Ike, Oouglaa B.
EhIke & Assocs.
Robert Poss, EPA
Judy Schwarz, EPA
Mike Cook. Burlington
Northern
Cheryl Koshuta, EPA
Timothy Hogan,
Washington Natural Caa
Cheryl Koshuta, EPA
Philip Simon, Joseph
Simon & Sons
BUI Schmidt, EPA
James Oragun, Kennedy/Jenkn Judy Schwars, EPA
Engineers, Inc.
Kannedy/Jenka Engineer* on
behalf of Burlington Northern
Railroad. Hygrade Food Product»,
Joacph Simon & Sons
Jim Oberlander, WUOE
Judy Schwars, EPA
-------
Doc*
File
Tyue/Deacrlpi Ion
Dale
Author/Organltntton
Aijdreaace/Urganljmt Ion
0000002). Preliminary Site Inveatlgatlon
00000020.
OO000029.
000000)0.
Letter re axidtf leal Ion uf propoaal
for toll and groundwater contamination
•aaeaaaent of CoMBCiiceaent Day Tar Pita
9/30/82 2
OOO00024. Prellailiiitiy Silt lovaettgatlon
0000002S. Technical Directive
Document
00000026. Work ul»n/ii»algna>eiita/
aaenUhenii
OOOOOOi;. Work |>lan/a»algnajenla/
Work plau/aselgniaenta/
amendment*
Work plan/aaalgraaenta/
aaenditcnta
Work plan/aiialgiuaeiita/
a*enda>enlii
000000)1. Murk plan/aaal'giutenta/
000000)2.
Work plan/aaatgiwcnt*/
aa>cii
-------
UM:«
HI.
1'ypc/OescrlptIon
Dale
Author/OrganI tat Ion
Add7e»see/Qrganl«i-t I'1
OOOOOOJ J. WuTTplan/u&sigiiiiieiitii/
OOOOOOJ. work
Hoik
OOOOOOJ6. Work
OOOOOOJ/.
O000003H. Murk plan/assignments/
Work |iJaii/.jL
00000039. Work
00000040.
00000041.
OOOOO042.
l.ftier/proposal re proposed •cope
01 work to address data gaps in
Remedial Investigation/feasibility
Study for Tacoma Tar Pit*
liwusiigailun Meports,
Folder 1, drafts and comments
Keuedlal Investigation Reports,
Folder 1, drafts and comments
Kewetltal Investigation Reports,
Folder 1, diaftn and comments
'Letter r« EPA's couments on proposed
scope of work and schedule for Remedial
Investigation/Feasibility Study
Letter and attached report entitled
"Supplement Work Plan and Quality
Assurance* Plan for Remedial
Investigation
Letter re final workplan for well
Installation and sampling program
Work assignment 95-0611.1
Work plan approval for well
Installation and sampling by CH2HH111
Report entitled "Technical Work Plan
Remedial Investigation/Feasibility
Study, Tacoma Tar Pits"
Letter with attached schedule re
revlaed project schedule for Tacoma
Historical Coal Gasification site
Tacoma Tar Pits RI - draft Information
package
Letter re review of Applied Ceotechnology'* 6/21/85
package
Vol. 1. Preliminary Draft RI, Tacoma
Tar Pits
8/85 2
10/4/85 21
9/5/86 3
9/5/86 1
9/2/86 9
3/10/87 2
5/28/85 56
3
6/28/85 149
OOOOOOA3. KctueJIul Investigation Reporta, Vol. 2, Preliminary Draft MI appendices,
Folder 1, draft and comments Tacoaa Tar Pita
6/28/85 I'll
Hark Adams, Applied Ceo-
technology
Udyne Crotheer, tl'A
Wayne Crotheer, EPA
Hark Adams.
Ceotechnotogy
Hark Adams, Applied Ccotech- Wayne Crotheer, k'PA
no logy
Joan Stoupa, CII2H1I11I
Wayne Crotheer, tPA
Wayne Crotheer, KPA
Wayne Sellman, EPA
Harding Lawson Associates CII2HH111
Spyros Pavlou, tiwlrospliere Wayne Crotheer, EPA
Company
Applied Ceotechnology
Unknown
John Catts, Harding Lawson Wayne Crotheer, EPA
Assoclatea
Applied Ceotechnology on
behalf of Washington Natural
Caa, Joseph Simon, Hygrade
Food Products, Burlington
Northern Railroad
Applied Ceotechnology on
behalf of Washington Natural
Gas, Joseph Simon & Sons,
llygrade Food Products,
Burlington Northern Railroad
-------
Type/Descrlpl toil
Author/Organ! it a i Ion Addresaee/OrganUatl
GOOOU044.
OOOuO045.
UUOOOU46.
UGUOG047.
(MJOOO04U.
000000*.*.
OUOOGU50.
00000051.
00000052.
00000053.
Kcuicdlul Investigation Reports,
Kildci 1, duds and c
Letter r.e Washington UOt'a c
on preliminary K!
Ceotechiiolutsv
nta
by Applied
7/23/B5
Megan White, WUUE
Wayne Cirotheer. EP
Kt.-M.-dia I Invest igat luii Reports,
Folder 1, tliaft* and coaMenta
Kciuudi.il Investigation Reports,
Folder I, diafi* and coauaents
KcuicJI.il Invest igai luii Reports,
Foldei I, diail* and conoents
Igal ion Ktjjorts,
anJ coumenta
I,
KuuicJIal Invcil Igat tun Keporta,
l'o|ji:i I. >liaitt> and
luve^tigatlun Keporta,
1, Jiafts Mini conuocnts
Keucili.il Invest (gallon Reports,
2, iliallb unJ
Kc-ueillal luvcKt(gallon Report*,
Folder 2, diafts and contents
Kcuetllal Investigation Keporta,
Folder 2, drafts and coa*enta
Letter re couioenis on preliminary Rl
aubvltted by Applied Ceotcchnology
and FS progresa report submitted by
Howard, Needlea, el ul.
Letter re EPA cuuacnts un prell*(nary
Rl cubaltteU by Applied Ceotechnology
Heap/at tacruients re coauenta on draft
Rl report by Wilson (t-PA), Sceva (EPA),
E&E, Watson (tPA)
Letter re Washington OUt's coawents on
final draft Rcawdtal Investigation .
report a prepared by Applied Ceotechnology
Letter re algnlflcant data gap in
Remedial Investigation Report by
Applied Ceotechnology
Letter re EPA coawents on final draft Rl
Draft final report - supplemental ground
water investigation, RI/FS, Tacoam Tar
Pita
Final report - euppleaental groundwater
Inveatlgation, RI/FS, TacoM Tar Pita
Final draft - Vol. 1, Remedial
Inveatlgation Report, Tacoaa Tar Pita
6/tt/«5 4
Ceotechnology
4/I4/86 13
4/16/86
4/U5 2
Ceotechnology
5/86 9
Ceotechnology
5/7/87 46
7/7/87 45
3/66 189
John Catta, Harding Lawson Wayne Crotheer, EP
Assoca.
Wayne Crotheer, tPA
John Osborn, EPA
Megan Willie, WUOt
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Harding Lawson Assocs. for
QI2MII111
Harding Lawaon Aasocs. fur
CH2MH11I
Applied Ceotechnology on behalf
of Washington Natural Gas,
Joaeph Slaon & Sona, Hygrade
Pood Producta, Burlington Northern
Railroad
Hark Adaaa, Applle
Wayne Crotheer, EP
Wayne Grotheer, EP
Mark Adaaa, AppUei
Mark Adama, Applle-
-------
Typc/Dcsi:rl|it Ion
COOOOOiA.
OOOOOOS5. Ktsk a^e
study, Foldci 1
KciBcdial Invi si igat iun Reports, Final drait - Vol. 2, Kenedlal
Kuldci 2, dibits and coCMBCnts Investigation Reports Appendices,'
Xacoita Tar Pits
Frogre«a report - feasibility study
Draft - Interlu dellverables Klsk
Aaaessaent and Feasibility Study
for the Tacoua Historical Coal
Gasification site
Letter re review of Intel I* RA/FS
dellverables, Tacoaa Tar Pits
Author/Organization
Addressce/Organliatlon
6/U5
OOOOOOS6. Klsk
study, Folder 1
OOOOO057. Klsk
study, Koldur 1
000000 ;•«. Klsk dsscs:;o.eni/ieatiiblllty
study. Folder 1
OOOOOOSV. Klsk assesswent/iuattiblllty
uludy. Folder 1
00000060. Klsk as*esiu,ciil/feasJblUly
study. Folder I
00000061. Klsk
study. Folder 1
OOOOOO62. Kick a««essiii^iit/fe«itiblUty
«tudy. Folder 1
00000063. Kick •••e«cueut/ie«iibtltty
study. Folder 1
3/B/B6
3/18/U6
3/26/86
Letter re Uaslilngton OOC'c cotMent
oo loterla RA/FS deliverable prepared
by Enviroapliere Cocpany
Letter re EPA coMent on draft RA/FS
Letter r Cnvlrosphere's response to
coa«enta on contaalnant selection <
and risk level* RA/FS. laCOM Historical Coal
Gasification Site & attached letter, 3/19/86,
Pavlou to Crotheer, re response to
review coawents on InterU RA/FS
dellverables - Iscoaia Historical Coal
Gasification
Letter and attachaentt re EPA coauenta 6/10/86
en draft risk assessment
Draft - RA/FS of the Tacoaia Historical 4/86
Coal Gasification Site
Letter and attachments re Washington DOE's 7/15/86
cosMMnta on draft Risk AasesssMnt
66
71
Applied Ceotechnology on behalf
of Washington Natural Caa,
Joseph Simon & Sons, llygrade
Food Products, Burlington
Northern Railroad
Howard, Needles.Tauuen &
Bergendoff, Mackey Salth
Envlrospliere Company on
behalf of Washington Natural
Gaa, Joseph Simon & Sons,
Hygrade Food Products,
Burlington Northern Railroad
John Catts, Harding LJWSOII
Associates
Megan White, WDUE
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Envlrosphere
David Bradley. WDOK
Applied Ceotechnolog
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Spyros Pavlou,
Envlrosphere
Spyros Pavlou,
Envlrosphere
Spyros Pavlou,
Cnvlroaphere
Washington Natural
Caa, Simon fc Sons,
Hygrade Food Products,
Burlington Northern
Railroad
Spyros Pavlou,
Envlrosphere
-------
Uucf
Flic
OOOUOUb<.. Risk Js
study, Fuldti 1
Type/Description
(MKJOU06:>. Kisk J
study, Fuldcr 1
Hly
. Risk
study, Foldci I
UOUUUUo?. Risk assusswcni/.leaslblllty
study. Folder I
OOOO006b. Risk assessment/feasibility
study, Foldci I
OOOOOOb*. Risk asse^mci,i/feasibility
Study, Foldei 1
OOOUO070. Risk a»sc>:.u<.-i,l/ieaaltlllly
vtudy, Folder 1
OUOUUOU. MUk
Study, foldci 2
00000072. Kick Assessment /HeuedUi
Study (BA/RI/FS) Curr«>-
pondvnce
OOOOOO?3. RA/Hl/FS Cor
Letter with coonaents of Harding Lawson
Associates on RA/FS prepared by
Envlrospliere
Letter and aliucluucnt s re Envirosphere's
response to couuicnts by EPA and Washington
on RA
Date
« Pages
8
tt/21/86 10
Letter with attacluueni re Washington OOE
coaaenta on Chapter Kour Fcastbliity Stud
9/2/U6
for Tacosia Historical Coal Gasification Site
uay
^t
Letter with attachaents re EPA c
FS
He»o with attachMents re cooiment* fro*
Office of Tomic Substances on RA eubalcted
Letter and uttacliaents re Envlrosphere
response to EPA/Uachlngton UOE co««ents
draft PS by Envlro*phere
Draft - Rlak A««e*«*ent and Feasibility
Study of the Tacoaa Hlatorlcal Coal
Caalflcatlon Site
Final Report - Klsk Assessment of the
lacoaa Historical Coal Gasification
Site
Heao re request for authorization
nts on 9/17/06
10/I6/U6
11/13/86
Letter re questlona and co
proposed KI/FS
:nts on EPA
19U6
7/U7
196
9/19/83
12/7/83
Author/Organltatlon Addre s see/Organ1za t loTi
John Calls, Harding Lauson Wayne Crolheeir, EPA
Associate*
Spyros Pavlou, Envlrospliere Wayne Grolheer, EPA
David Bradley, WlXJt
Wayne Crolheer. EPA
Terry O'Bryan, EPA
Spyros Pavlou,
Envlrospliere
Envlrospliere on behalf of
Washington Natural Cal,
Joseph Slaon & Sons,
llygrade Food Products,
Burlington Northern
Railroad
Envlroaphere on behalf of
Washington Natural Caa.
Joseph Slaon & Sons,
llygrade Food Products,
Burlington Northern
Railroad
Cene Lucero, EPA
Wlllla* Francis,
Burlington Northern
Railroad
Wayne Crotheer, EPA
Spyroa Pavlou,
Envlroaphere
Patricia Stora), EPA
Wayne Crolheer, EPA
Lee Thoaas, EPA
to proceed with RI/FS
Robert Poss, EPA
-------
Doc*
Hie
Type/Description
Date
' Pages
Author/Organization
Addressee/Organitetlon
00000074. RA/KI/FS Correspondence
OO00007S. KA/kJ/rS Correspondence
OOQOOQlb. RA/kl/rS Correspondence
00000077. RA/MI/FS Correspondence
00000070. RA/KI/FS Correspondence
000000/9. HA/kl/KS Conc*|>ond«nce
00000080. KA/kl/FS Correspondence
00000081. KA/kl/iS Correspondence
00000082. KA/HI/ni Correspondence
OOOOOOai. KA/kl/rS Correspondence
00000084. RA/MI/rS Correspondence
OOOOOOflS. RA/M/FS Correspondence
00000086. RA/R1/FS Correspondence
Memo and attachment re defining main 2/21/84
points of surface water discharge end
•onltorlng water quality & flow for Rl
Letter re proposed consent order 8/2/8<>
No. 1084-06-00-106
Letter re conaent order No. 8/13/84
1084-06-08-106 for RIFS
Letter re RI/FS request for consent 8/21/84
for ecceea to Joseph Simon & Sone eltes
Oeclalon memorandum re EPA'a decision 8/24/U4
to proceed with RI/FS
Site safety plan for HI 9/9/8 Decision to Proceed with
IPA'e RI/FS
James Mitchell, Tacoma-
Plerce County Health Dcpt.
John llamlll, EPA
2 Jeffrey Leppo,
Bogle fc Catea
2 David llelneck, EPA
W/iyne Crotlieer, EPA
Environmental Research
Group, Inc., Donald
Woods - Clll
James Everts, EPA
James Evert a, EPA
James Everts, KPA
James Everts, EPA
Wayne Crotheer, EPA
Charlea Blumenfeld,
Bogle & Catea
James Everts, EPA
Doug Pierce, Tecom*-
Pierce County Health Pep
Charles B lumen (eld.
Bogle 4 Catea
David Helneck, EPA
Jeffrey Leppo,
Bogle &. Catea
Jim Everts, EPA
Unknown
James Beard, Douglaa
Khlke & Assocs.
Charles Brown,
Burlington Northern,
Inc.
diaries Illumenfelil,
Hog 11- *• C.ilcs
Timothy Hogan,
Washington Natural C«s
.lames Evcrta, EPA
James Everts, EPA
Timothy Hogan,
Washington Natural Caa
-------
Doc*
flit
Type/Description
Date
• Pages
Author/Organliatton
Addressec/Qritariiiat toil
00000007. RA/Rl/FS Correspondence
00000088. RA/M/FS Correspondence
00000089. HA/R1/FS Correspondence
00000090. RA/HI/FS Correspondence
00000091. RA/RI/FS Correspondence
00000092. RA/RI/FS Correspondence
00000093. RA/RI/FS Correspondence
00000091. RA/Rl/rS Correspondence
00000095. RA/RI/r'S Correspondence
00000096. RA/R1/FS Correspondence
00000097. RA/MI/FS Correspondence
Letter end attachments re consent
accees to property
for
Letter re access by EPA to property of
Nygrede Food Products
Letter re rejection of Consent Order by
BPA end possibility of reopening of
discussions ebout e privately- flnenced
9/18/84
9/21/84
9/28/84
Letter In response (o proposal re
reopening of dlscustlons (or a prlvately-
flnenced RI/»S
Concent for access to property with
•tteched ««ps
\
Heao re eddendusi to decision mtmo .
re EPA's decision to proceed with Rl/FS
He*o re concurrence on Issuance of
C«rcla 106<«) edailnlstratlve order
on consent
Letter end attachment re need for
additional soll-bortngs at Tar Pita
alte and lapse t of deleya In submitting
proposed second and third round testing
procedure
Letter re response to proposal for
second and third round sampling
parsMtera and request certein inforeuitlon
re poaslble data gaps in Rl/FS
Utter re review of applied Ceo techno logy
progreaa report No. 4 and second and
third round asmpllng plan
Letter re aecond end third round
sampling
10/10/84 I
9/20/84 6
10/16/84 2
11/1/84 1
5/8/85 4
5/9/85 2
5/11/85 3
5/85 1
Wayne Crotheer. EPA
James Beard of Douglas
B.M. EhIke & Assocs.
Charles Blumenfeld, Bogle
fc Gates
James Everts, El'A
City ol Tacoma
Wayne Crotheer, EPA
Francis Biros, EPA
David Helneck, EPA
Wayne Crotheer, EPA
Robert Cower, City of
Tacomai Property right-
of-way Itanager
David Iteinec*. CPA
Ernesta Barnes, EPA
Cliarlc* BI>MMn««ld.
Bogle k Caces
CPA
James Everts, EPA
Ernesta Barnes, EPA
Charles Blumenfeld,
Bogle & Gates
Hark Adams, Applied
Technology
John Catta, Harding Lawson Wayne Crotheer, CPA
Aasoclatea
Wayne Crotheer, EPA
Hark Adams, Applied
Geotechnology
-------
Ooc»
flit
Typc/OeacrlptIon
Date
Pages
Author/OrganItatIon
Addrcasee/Orgonliatlon
GOOOOOya. HA/HI/t'S Correspondence
00000099. RA/ftl/FS Correspondence
00000100. KA/R1/FS Correspondence
OOOOO101. RA/Rl/K* Correspondence
0000010*. RA/H1/FS Coi redpondence
00000103. KA/RI/FS Correspondence
OOOOOlOt. RA/RI/FS Correspondence
0000010). RA/RI/FS Correspondence
00000106. RA/RI/FS Correspondence
00000107. RA/RI/FS Correspondence
00000106. RA/RI/FS Correspondence
00000109. RA/RI/FS Correspondence
00000110. RA/RI/FS Correspondence
Cover letter (wltliout attachments) re • 6/26/85
EPA guidance relating to1 Rl/FS
Letter and attachment* re revlaed 7/22/85
project schedule and additional
date need* re RI/FS
Letter end attachments re revlaed W1W66
schedule (or completion of RI/FS
Letter re disapproval of propoaed 5/30/86
•odtflcetlona to work plan for RI/FS end
end ettached letter fro* Applied
Ceo techno logy re additional two deep
we lie
Letter re requeet for Installation
of two edditional deep wells
Letter re edditional Monitoring well*
Letter re two additional Monitoring
wells
Letter re additional stool tor Ing well*
Letter re two deep Monitoring wells
Letter and attached eiapa re EPA 8/8/86
requeet to Burlington Northern for eccess
to property
Letter re EPA request to Union Psclflc
Railroad for accese to property
Letter end ettached Mpa re CPA*s request 8/19/86
to Union Pacific Railroad fur ecceaa
to property '
Letter end etteched sups re consent for 9/2/66
eccese to Union Pacific MaIIroad'a
property
12
5/7/U6
7/15/86
1/13/86
6/16/86
6/6/86
J
3
3
2
1
David llelneck. CPA
David Ik I neck, El'A
Tlsuthy Hogan, Washington
Natural Cas
Timothy Hogan, Washington
Natural Cos and Charles
Bliwenfeld, Bogle & Gates
Hark Adssia, Applied Ceo-
technology
Charles Flndley, EPA
Charles Flndley, EPA
Charles Flndley, EPA
TIsMthy Hogan, Washington
Natural Cas and Charles
Blumenfeld, Bogle & Cstes
Osvld Hslneck, EPA
David Helneck, EPA
Jeffrey Assy, Union
Pacific Railroad
Jeffrey Assy, Union
Psclflc Railroad
diaries Bluswnfeld,
Bogle & Gates
Charles Blueienfold,
Bogle 4> Gates
Osvld Helneck, EPA
Wsyne Crotheer, EPA
Wsyne Crotheer, EPA
Charles Blumenfeld,
Bogle & Gatea.
Timothy Hogan,
Washington Natural Gee
Timothy Hogan,
Washington Natural Caa
Charles Flndley, EPA
Michael Cook, Burllngtc
Northern, Inc.
Jeffrey Assy, Union
Pacific Railroad
David llelneck, EPA
David llelnlck, EPA
10
-------
Doc*
File
Type/liescriptton
Date
Pages
Author/OrganliatIon
Addressee/OrganliatIon
OOOuOlll. KA/HI/IS Correspondence
00000112. RA/KI/tS Correspondence
0000011). RA/KI/KS Correspondence
000001U. RA/Hl/tS Correspondence
OOOOOI1&. KA/KI/YS Cuircspoudence
00000116. RA/HI/FS Correspondence
00000111. RA/RI/FS Correspondence
00000118. RA/H1/FS Content Order*
Latter re content for access to Union
Pacific Railroad property
Letter re aelection of drilling sub-
contractor lor installation of two
Monitoring wells/attached proposal and
bid Infoniatlon
Letter re EPA request for conaenC for
•cceta to Burlington Northern property
\.
Letter re EPA'a request to Burlington
Northern for consent for access to
property
Letter snd attachment* re revised list of
of final csndldste alternatives, Tacoma
Historic*! Ossification site
Letter re delay in submlttal of Bl
Letter re EPA comment on revised list
of csndidate alternatives
Administrative Order on consent
«10oVOt-Oa-106 with sttsched work
plan Rl/FS
9/12/86 I David He I neck, EPA
9/18/86 K John Calls. Harding
Lawaon Associates
9/23/06 1 David lie I neck. EPA
10/1/86 1 David He Ineck, EPA
W7/87 3 Hatthew Scliulx,
Envlrosphere
00000119. Contract Management Documents EPA Summary Evaluation He port (SER)
with sttschocnts of description of
activities snd performance, SER
00000120. Contract Management Documents
00000121. Contract Management Documents
Statement of Work, Tacoma Tar Pits
Site Well installation and stapling
Letteri Progress report on work for
new wells on Tar Pita site
6/19/87 1 Hark Adams, Applied
Ceotechnology
5/87 ) Wayne Crotheer. EPA
11/1/81. 1) Ernest B. Barnes, EPA
Jeffrey Assy, Union
Pacific Railroad
Wayne Crotliecr, F.PA
Hel Burda, Burlington
Northern
John CattSi Harding
Lawaon & Aaaocs.
00000122. Contract Management Documents Bid documents for groundwater monitoring
well Installation
Wayne C.rotheer, EPA
Wayne Crotheer, EPA
Hatthew Schtiltt,
Envlrosphere
Joseph Simon & Sons, Inc.,
Washington Natural Cas
. Company, Burlington
Northern Railroad, Hygrade
Food Producta
10/28/06 12 Wayne Crotheer, EPA
6/10/06 2 Wayne Crotheer, EPA
8/11/66 2 Kathleen Nleaon, CII2HIII1I Wayne r.rotheer, EPA
9/2/06 41 Harding Lawson Ascucs.
11
-------
Uucf
Type/Description
UOOGOUb. Quality A^s
UUUUO12'/. Quality
c Project Plan Letter re cowuients on draft QAPP
cu Project Plan Quality Assurance Pioject Plan
Remedial Investigation Feasibility
Study -
UU000128. Quality Assurance Project Plan Quality Assurance Project Plan
Remedial Investigation Feasibility
Study
0000012V. Quality Assurance Project Plan Letter re clarification HI/FS/QAPP
OOOO0130. Quality Assurance Project Plan Letter re Cere la Adalnlst'ratlve Order
No. 1084-06-08*106 (Quality Aaaurance
lor sampling data)
Date I Pa^es
9/21/tit
9/26/86 A9
53
2
3
OOU00267.
00000131.
00000132.
OOOO0133.
OOOO0134.
00000135.
OOO00136.
OUOO0137.
Quality Assiuance Project Plan
Quality Assuunce Project Plan
Quality Assurance Project Plan
Quality Assurance Project Plan
Public Health Asseasaent
Kclerence materlaU or listing
of guidance ducuwcntd
Coiwunlty relations and news
releases
Letter re soil resistivity survey
and soil borings with attacliaents/aap
Quality Assurance Project Plan/Remedial
Investigation/Feasibility Study
Letter ra coswents on QAPP; bid document,
technical workplan
Uorkplan; Quality Assurance Project. Plan/
KeMdlal Investigation/Feasibility Study
Heajo re preliminary health assessoent,
TacoM Tar Pita aita (SI'86-219)/Health
Assessment and Consultation Report
Re TacoM Tar Pita RI/FS--consistency
with SARA requirements
Guidances for administrative records'
located in EPA regional files
News releases "For Immediate Release,"
Commencement Day and the Tar Pit*
12/5/U4
2/85
8/22/86
9/2/86
12/17/86
3/12/87
7/15/83
60
18
Author/Organltatton
Uayite Crotheer, EPA
Harding Lawson Associates
Addressee/Organiiatto!
John C. Catta. Hard!
Lawson Associates
CH2MJII11
llarulng Lawson Associates CH2MI111, EPA
Kathleen Nleson, CII2MMI11
David llelneck. EPA
Hark Adams, Applied
Ceotechnology, Inc.
Applied Ceotechnology,
Inc.
Wayne Crotheer. EPA
John Catts, Harding
Lawson Associates
Director, Department of
Health & Human Services
Wayne Crotheer, EPA
EPA
DOt
Wayne Crotheer, EPA
Charles Blumenfeld,
Bogle & Gatesf Timot
J. Hogan, Washington
Natural Gas
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Kathleen Nleson, CH2J
CH2MI1I1, EPA
Joel Mulder, EPA
12
-------
Doc*
Kile
Type/Description
Date « Pages
Author/Organization
Addressee/Organization
JUOOUljy. Community I el at lull* anil news
release*
IUUOUKU. Couuiunity relations anil news
-JUUOU138. Cuuuuunliy ic-l.ii Ions antl news Letter re citizen advisory committee with 8/30/83 3
with attached list of member:)
Letter .to all interested citizens re . "
investigation of soil and groundwater in
South Tacoma
Heao and attached connunlty relations 2/27/87
plan
Fact aheet and letter to all Interested 9/U/» 3
citizens
News release re EPA work on Tacoaui Tar lU/24/ti^ 3
Pits
News releases re property ownera agreement H/1'./B'. 1
to perCor* Superfund Investigation
Superfund citizens advisory cosalttee 7/22/86 11
agenda, with attacliawnts including graphs
and ataps
HKIOOH1. Ciiiuoiuii11y relations and new*
re Icaues
OOOO1<«2. t.'uibiutinl ly 11: |ji l.'Hi and news
releases
•JUU01A3. Community telationa and neus
icleases
UOOU!<•<•. Community relations and news
releases
. Community relations and news
releases
OOOUK6. Newspaper articles
JOOOK7. Newspaper articles
DOOOU8. Newspaper articles
t. Newspaper articles
tUOOlSO. News paper ai tides
JUU01S1. Newspaper articles
>OOO1S2. Itcwspapcf articles
PCb cleanup press release
Bright Future for Gas Industry Forecast
Here
Natural gaa pipeline already halfway here
Industrial leaders
Ca* covpany la SO years old this Month
Terrible! Tide flats to tar pita
Toxins found in Tar Pita
Cunk delays spur work
3/23/87 2
7/23/83
7/23/83
5/1 7/8*.
Doug Pierce, Environmental
Health Division, Tacona-
Plerce County Health Oept.
Phil Wong. EPA
Judy Schwarz, EPA
Wayne Crotheer, EPA
Wayne Crotheer, El'A
Wayne Crotheer, EPA
Tacona-Pierce County
Health Oept.
I). Cohen, EPA
Tacona Public Library files
Tacoaia Public Library II lea
Tacoaa Public Library files
Taco»a Newa Tribune, Tacoma Public
Library filea
The Newa Tribune, Tacoaa, WA
Pierce County Herald,
Puyallup, WA
The News Tribune, Tacoma, WA
Jlat Krull, WOOE
Interested clticena
Daphne ClMell, Superf
CoeMunlty Relations
Coordinator
Intereated citizen*
13
-------
Uuc«
Hie
Type/Pescript ton
Date
Page*
Author/Organization Addreaaee/Organization
OOOOOJiJ.
0000015*.. Newspaper aitlclea
OOOOOliS. lie.il.ibl Illy ntudles
OOOOO1&6. Trealdbllliy kluJU-a
OOOOOliJ. Trejijbilliy »ibdle»
OOOOOliU. Ireatdblllty »ludle»
0000015*.
sludle*
OOOOOlfcl. Irealablllty «tudltt»
00000162. TrealdbllUy atudlea
0000016). Treatablllty atudlea
OOOOGltfc. Pllut/U-ncli ctuJle*
EPA act to apenil S'tlO.OOO on Tar Pita
Tar Pit* faca cleanup
r« SITE (Superfunil liuiovatlv*
Technology Evaluation) program,
noailnatlon of Super fund aitea
Superfund Innovative technology
•valuation program; description of
technology proceaa deaonstrated -
electric pyrolyzer
Ueatlngliouae Electric Pyrolyzer general
Information re UM at Tar Pit alte
Letter re Ueetlughouae prograai
participation with electric pyrolyzer
Hejao re teleconference with Heglon 10,
Ueatloghoute and OEKA on deaonstratlbn of
the pyrolyzer at lacoaa lar Pit alte
Statua of EPA evaluation of alt*
ooalnatlona for the SITE prograai.
Attached i SITE operation* plan
Heao re anawera to Incineration tough'
queatlona for the electric pyrolyzer/
Tacoava Tar flta alte de*onatratlon.
Attached* Incineration tough ajuactlona
Meao re Coordination Meeting for
Ueatlnghouaa pyrolyzer/Tacoaia Tar Pita
SITE deajonatratlon. Attached agenda
and Hat of partlclpanta.
Latter re comment » on aoll atablllzatlon
pilot atudy propoaal with attached a>eaoa
fro* Hegan White, UOOE, and fro*
Nlka Gallagher
1/21/K7
i/W»7
2/6/87
3/87
4/6/87
3/18/87
2/5/87
11
Jeff Weatheraby, The Neva
Tribune, TacoM, UA
Pierce County Herald, Puyallup,
UA
Ja«ea Evert. EPA
EfA
K. P. Ccpco, Hanager,
Weatlnghouaa electric
pyrolyzer
Linda Caler, EPA
EPA
Linda Caler, EPA
Linda Caler, EPA
David Bradley, WOE
Donald C. White, EPA
Konald D. Hill, EPA
John Klngacott. EPA
Tla Prlncefleld. EPA
Wayne Crotheer, EPA, kuae
Sepco, Ucatlngoouaa,
Noraa Lewie, OHO
Wayne Crotheer. EPA
M
-------
Doc*
Flic
Type/De»crlptlon
Date
Page*
Author/Org*nliatIon
Addrca*ee/Orgenltatlon
OOOOOI6). Applicable or relevant and
appropriate requirement*
OOOOOUt. Lab reports/raw data
00000167. Lab reports/raw data
00000118. Lab rcpur l»/raw data
OOOOOIb*. L*b icpui (WidW data
00000170. Lab report s/raw data
UOOOOII1. Lab reportt/raw data
00000172. Lab reports/raw data
O0000173. Lab itpui li/i ju data
OOOO01K. Lab it-poi t*/iaw data
GOOOOI7). Lab i upui la/raw data
OOOOO176. Lab repui is/raw data
Latter with enclosed Hating of atate 5/18/87 8
ARARS
OlyBfila Environmental Laboratory data 9/11/81 8
•UMMry with attached Inspection report*,
new* rcleaaa
Latter re laboratory analyala notice for 6/K/U1 13
Tacoaa Tar Pit* with attached water
•••pica and lab report
Letter re laboratory analyala notice for 6/H/bJ 11
for lacoata Tar Pita with attached water
aaaplaa and •eJlaent aaaplc*
Latter and attached toxiclty report 9/9/tf) 2
Organic traffic report* and chela of 10/29/Bt 29
cuitody record*, Ce*e No. 3^.67
Utter with attached lab re*ulta (location 1/8/85 77
of lab reault*. EPA regional file)
Utter re Tar Pit* KI/FS *14i8a0.002 1/8/8) <*a
with attached te*t recult* (teat reault*
located at EPA regional file)
Organic analyela data aheet (located 2/13/tti 51
at EPA icglonal file)
Utter with ettachcd teat reault* and 1/28/8) 53
quality control data (lab reaulta at EPA
EPA regional file)
Utter with attached analytical reaulta 2/5/85 53
•U6a0.002 (l*b reculta located at EPA
regional file)
Utter regarding EPA contract 68-01-6851 2/6/8) 3O7
with attached data report (data at EPA
regional file)
David Bradley, WDOE
G. Freeaun. WDOE
Robert A. Poaa, EPA
Hobert A. Poaa, EPA
H. L. Cook, Burlington.
Northern Railroad
EPA
Analytical Technologic*.
John U. Strand, Analytical
Technologic*, Inc.
EPA
John W. Strand, Analytical
Technologlea, Inc.
John U. Strand, Analytical
Technologic*, Inc.
Ullllaa) H. Vlck. Science
Application* International
Corp.
Dr. Spyroe Pavlou,
Envlroaphcra
Michael L. Cook,
Burlington Northern
Railroad
Philip Slaran, Joaeph
Slawn & Son*
EPA
Science Application*,
Inc.
Applied Ceotechnoiogy,
Inc.
Applied Ceoteclutology
Applied Ceotechnoiogy
Applied Ceotechnoiogy
John Oaborn. EPA
15
-------
Hie
IVpe/Deicrlut Ion
Date ' t Pagee
Author/Organisation
Addre**ee/Organl«atioq
OOOOU177. l.al* rcporti/iaw data
00000178. |.afc recoil 4 /i aw «J«ta
00000179. Lab report s/ruw data
OUOOOIUO. lab ic|iurl*/iaw
00000181. Lab reporlc/i.iw
00000182. Lab reports/raw data
00000183. l.db repurt»/i.iw data
00000184. L*b reports/raw data
0000018S. Lab repon»/uw data
00000106. Lab report */i aw data
00000187. Lab report«/r reports/raw data
Latter regarding Tar fit* Rl/FS with
attacncd teat result* and quality control
data (lab reault* located at EPA
regional IIU)
Tranaalttal a«ex> with enclosed cop lea
of rough field luga (mm lar Pit* eoll
boring «UflB0.002
Letter with attached tejt reaulta and
Quality control data «148tt0.002
(lab report* located at EPA regional file)
Report of evaluation of ca»e J467,
Tacoaia Tar Pita data
Letter with enclosed data cheeta. Maple
IP-HC1-WI. (Data aheeta located at
EPA regional file*)
Letter with attachment deta «14880.002
Letter with attached teat reaulta and
quality control data *U8U0.002 (Ub
reporta at EPA regional fllea)
Report of evaluation of the caee 3461,
Tecoaia Tar Pita date. (Data at EPA
regional fllea.)
Organic* analyata deta (data at EPA
regional fllea)
Tranaailttal ajaaw with attached aap
•howtng extent of coal tare
Tacoaa Tar Pit aaeiple Identification
with attachment*. (Data at EPA regional
ftlea.) Caae * i;S9.
Letter with attacluMiite re
ana ly ale. (Data at EPA regional file)
2/11/8* 2)
2/19/85 18
2/18/8) S4
3/I/U4 8
3A/85 23
3/6/8$ 2
J/15/8S 32
3/25/85 15
320
3/27/8S 2
4/12/85 27
7/8/85 6
Jaaaa ttcutUy, Analytical
Technologlee. Inc.
Hark Adaaia, Applied Ceo-
technology. Inc.
John U. Strand, Analytical
Technologic*, Inc.
C. Muth, EPA
John U. Strand, Analytical
Technologic*, Inc.
John U. Strend, Analytical
Technologic*
John W. Strand, Analytical
Technologlce
Gerald Huh, EPA
EPA
John C. Catta, Harding
Law*on d A**oc.
Sharon lfcid*on Djork,
Analytical Technologic*,
Inc.
Applied Ceotachnology
Wayne Crotheer, EPA
Hark Ada**, Applied
Ceotechnology, Inc.
Hark Adaaa, Applied
Ceotechnology, Inc.
Applied Ceotechnology
Applied Ceotechnology
Wayne Crotheer, EPA
Hark Ada**, Applied
Ceotechnology
16
-------
Uoc*
Kile
Type/DenerIptIon
Date
Author/Ofganliat tun
Addreaaee/Organ!tatIon
OOOOO109. L*b reports/raw
00000140. Lab reports/raw data
00000191. Lab reporta/i*w data
OOOOOI92.
OOOO0193. l.ab reports/raw data
O0000194. Lab ftporii/raw data
0000019). L*b reports/law daCa
O0000196. Lab repuiis/raw data
00000197. Lab reports/raw data
00000194). Lab reportj/raw data
00000199. Lab report a/raw data
Latter with attachmenta re aample
enelyaes. (Data at EPA regional Hlea)
7/8/85
12
ra quality assurance of Caa« 3467
(organic*) with attached comments re
laboratory performance. (Date at EPA
rational flic.)
Letter with attached aaaiple result* and
quality control data. (Data at EPA
regional file.)
Letter with attached sanple reaulta.
(Data at EPA regional file.)
Hemo re quality aaaurance of Caae 3.759
(VOAa end BNAs) with attached
coMMnta on data qua 11 fleet lone. (Date
et EPA regional file.)
Letter with attached staple analyeee.
(Data et EPA regional file)
Letter with attached caaiple analyaea.
(Data et EPA regional file)
Letter with attached aaeiple analyaea.
(Data at EPA regional file.)
7/10/85 12
7/ll/bi
7/11/ttS
7/15/8S
7/li/ttS
7/22/U5
1)
12
10
(.4
Heew with ettechewnte re quality aaaurance 8/2/85 1
of caee Mi) (Inorganlca end Anione).
(Data at EPA regional file.)
Heew re quellty eeaurance of* caae 3759 a/16/85 9
(organlce) with ettechawnta re dete
qualification
Sa«vle nua^era. location, depth and date, a/13/85 15
with attachmenta re quellty aaaurance
of Caae 3467 (Inorganlca)
Sharon Hudaon Bjork,
Analytical Technologies,
Inc.
Lynn Cullcord, Andrew
Haffery, Ecology e>
Environment, Inc.
Sharon Hudaon Bjork,
Analytical Technologies
Sharon Hudaon Bjork,
Analytical Technologies
Roger HcClnla, Andrew
liafferty. Ecology &
EnvlroiUMnta, Inc.
Analytical Technologies
Sharon Hudaon Bjork, Ana-
lytical Technologies, Inc.
Analytical Technologies,
Inc.
Roger HcClnla, Andrew
Haflerty, Ecology 4
Environment, Inc.
John Rydlng, Andrew
liafferty, Ecology e>
Envlronmente, Inc.
1 Cathy llelnrlch, John
Osborn. EPA
Hark Adams, Applied
Ceotechnology
John Oaborn, EPA
Hark Adams, Applied
Ceotechnology
Hark Adama, Applied
Ceotechnology
John Oaborn, EPA
Hark Adams, Applied
Ceotechnology
Hark Adams, Applied
Ceotechnology
Hark Adams, Barbara
Trljo, Applied Ceo-
technology
John Oaborn, EPA
John Oaborn, EPA
Roger HcClnnla,
Andrew Haflerty,
Ecology 6> Environment,
Inc.
17
-------
Uoc*
Type/Uesci Ipiloii
Date
* Pages
Author/Orgaiilitat ion
Add res see/Oman tzatt
OOD00200. l.dti
OOOO020I.
HeaM> rts quality assurance of casa
3630 (organic*) with attached coat
re data qualifications. (Data at
EPA regional file.)
•nit
dutu
OOOO02O2. l.ab reports/riiw da en
GOOO0203. l.jb reports/raw data
0000020urls/raw data
OOO00208. Lab reports/raw data
OOOO0209. Lab reportb/raw data
00000210. Lab reports/raw data
O0000211. Lab reporta/raw data
Hemo re quality assurance of cane 3630
(inorganic*) with attached coaMeiita re
data qualification. (Data at EPA regional
file.)
Saaple project analysis resulta «IEC-0770.
Well at llygrade Pre-chlor 1 nation Cap.
(Data at EPA regional file.)
Letter with attached analytic data
Letter with attached aaaple analyses
and quality control data. (Data at EPA
regional file.)
Letter with attached aaaple analyse* and
and quality control data. (Data at EPA
regional file.)
Work Aaalgnatent For*.
tlon of work
Attached descrlp-
Letter with attached aaaple analyses
and quality control data. (Data at
EPA regional file.)
Latter with attached staple analyses
and quality control data. (Data at
EPA regional file.)
Latter with attached preliminary
calculation of particulate cutter
aajiaalona.
Latter with attachaenta re aaaple
analyaec. (Data at EPA regional file.)
Lattar with attached aaa>pla analyaea and
and quality control data. (Data at
EPA regional file.)
U/23/US 29
8/23/tiS 7
9/10/85 6<.
9/2<./B5 12
10/21/tii 6
11/1/U5 <.
8/8/66 2
H/H/HS 16
11/13/8$ 9
11/13/85 8
11/12/85 21
11/14/85 8
Lynn Cull ford, Andrew
Hafferty
Moger HcClnnls, Andrew
Uafferty, Ecology &
Environaent, Inc.
EPA Lab
Hark A. Adaaja, Applied
Ceotechnology
Sharon Hudson BJork,
Analytical Techn9loglea,
Inc.
Tlalr K. Augaburger,
Analytical Technologies,
Inc.
CII.H Hill
Prepared for EPA
Tlalr K. Augsburger,
Analytical Technologies,
Inc.
Tlair K. Augaburger,
Analytical Technologlea,
Inc.
Walter J. Ruaaell. Air
Quality Consulting Services
Analytical Technologlea,
Inc.
Tiair K. Augaburger,
Analytical Technologies, Inc.
tPA
Jolw Osborn, EPA
Wayne Grotheer, EP*
Applied Ceotachnolo
Inc.
Applied CeotechnoIo
Inc.
Applied Ceolechnolo
Inc.
Applied Caotechnolu:
Inc.
Wayne Crothaar, EPA
Applied Ceotechnoiof
Inc.
Applied Ceotachnoloi;
Inc.
18
-------
Doc*
Type/Petcrlptton
Date
Author/Organization
Addreaaee/Organliatlon
00000212. Lab report»/raw data
UO00021). Lab imports/raw data
00000214. lab report*/ruw data
OOOOOm. I lib ivpoils/raw data
OOOOO216. lab ruporlk/raw data
00000217. Lab reyoili/raw data
UOOUima. Lab ivpoii»/raw data
OOOOOm. l.ab rc|>oits/ruw data
O0000220. l.ab repurts/law data
O0000221. Lab report»/iaw data
00000222. Lab iepdt*/raw data
0000022). Lab reporti/raw data
00000224. Lab report*/raw data
0000022). Lab reports/taw data
00000226. Lab report«/raw data
00000227. Lab rcpurt»/raw data
L«tt«r with attached •••pie analyae* 11/21/05 it
and quality control data. (Pat* at EPA
Mglontl flic.)
Lattar with attachment! re iMipla analyce*. 11/21/tii 21
(Data at EPA regional (lie.)
tatter with attachment* re aaaipl* analyie*. 11/21/U& 1?
(Data at EPA rational file.)
Lattar with attached «a«ple teat raaulta 1985 23
maid.002. (Data at EPA regional file.)
Utter with attached quality control 1/13/U6 40
deliverable*. (Data at EPA regional file.)
Latter with attached *a»ple reaulta and 8/22/06 a
quality control data.
Llat of raault quailflerc for non- 10/23/06 8
nuaarlc raaulte with taaple project
analyal* raaulta
Llat of raault qualifier* for non- 12/21/b6 7
ouawrlc raault* with attached aaaipla
project analyala reaultu. Sanpla No. •
864MSSO-4..
Saaipla project analycl* re*ulta. 3/31/87 10
Sa<4>la Mo. 67060020-29.
Llat of raault qualifier* fur non- . 4/9/87 11
miMrlc raaulta with attached aaaipla
projact aculyala. Sample No. 87M0020-29.
Sedlatant aaayle teat reaulta. No date 10
Sadlawot aaaiple taat raaulta. No data 10
water aaajpla teat reaulta No data 10
Water aaaplo.taat raaulta No date 10
Tabla ragardlng Material categorlea N,o date 1
Plaid loga of boring 10/26/84 6
Tlalr K. Augaburger, Applied Caotechnology.
Analytical Technologic*, Inc. Inc.
Analytical Technologic*
Analytical Technologies
Applied Caotachnology
Applied Caotachnology
John W. Strand, Analytical Applied Ceotechnology
Technologic*
Michael Illggln*. Hark King. Hark Adama. Applied
Analytical Technologic* Ceotechnology
T. J. Hogan, Uaahlngton
Natural Caa
EPA
LPA
EPA Lab
EPA Lab
Unknown
Unknown
Unknown
Unknown
Unknown
Harding, Lawaon Aaaoclatea
Wayne Crothaer, EPA
19
-------
Woes'
File
Type/PescriptIon
OO000228. Haps »"J plioio*
00000129. Haps anJ pliuios
000002)0. Maps and photos
000002Jl. Naps and pliolus
000002)2. Haps and ^lu.tua
000002)1. Naps and phutoa
000002 )<.. Haps olid pliuluM
000002)5. Hap* and pliutos
000002)6. Hapa and
000002)7. Hap* anil
OOOO02)0. H*p« and pliulo*
000002)9. Kipi anU plioto*
Tacos* C«* Coapany building
location*. (Hap located at EPA
Ilia)
Aarial photograph. (Hap located at
IPA rational flla.)
Station piping, Tacoaia plot plan.
(Hap located at CPA regional HI*.)
Tacoaa station piping regulation*,
header*. (Hap located at EPA regional
Ilia.)
TacMU atatlon piping building and
piping detail*. (Hap located at EPA
rational ftla.)
TacoM atatlon piping building and
piping detail*. (Hap located at CPA
regional 111*.)
Building location drawing, Tacoata
atatlon. (Hap located at EPA regional
Ilia.)
TacoM atatlon regulator building*,
plan and elevation. (Hap located at
EPA regional file.)
TacoM atatlon regulator building*,
datallc. (Hap located at EPA regional
Ilia.)
Station piping, lacoaia atatlon piping
detail*. '(Hap located at EPA regional
Ilia.)
Tacoota atatlon piping detail*. (Hap
located at EPA regional II le.)
Station piping, Tacoaa detail*. (Hap
located at EPA regional Ilia.)
U»tf f Page*
9/10/2) 1
Autnor/Organliatloo
By!leaky Engineering and
Hanagcaent Corp.
1 Unknown
6/20/56 1 Washington Natural Ca* Co,
6/22/56 7 Washington Natural Ca* Co.
6/25/56 1 Washington Natural Cat Co.
7/2/56 1 Washington Natural Ca* Co.
7/5/56 1 Washington Natural Cat Co.
7/6/56 1 Washington Natural Ca* Co.
AU(lrea«ec/Organization
7/9/56
7/14/36 1
Washington Natural Ca* Co.
Washington Natural Ca* Co.
7/16/56 1 Washington Natural Ca* Co.
7/17/56 1 Washington Natural Ca* Co.
-------
UK-
Type/DCscript Ion
Uau
Author /Organliat Ion
Addre**ee/0r*anliatlon
00000240. Hap* JiiJ
00000241. Haps and photos
000002<. 2. Maps and pliutua
0000024). flaps and photos
00000244. Hau» anJ fhcios
00000245. Haps and photon
OOOO024L. Hapa and photo*
000002*.;. Hap« and photo*
00000240. Hap» jnd photo*
00000249. tUpn and photo*
00000250. Hap* and photo*
00000251. Hapa and photo*
000002)2. Hap* and photo*
0000025). Hap* and |>hoto*
00000254. Hap* and photo*
00000255. Hap* and photo*
Tacoaa •tat ton valve and piping ccheaatlc. 10/16/61
(Map located at EPA regional office.)
riant atatlon valve and piping schematic. 10/16/61
(Map located at EPA regional office.)
Property of Washington Natural Ca* Co. ' )/24/64
plane. (Hep located at EPA regional file.)
Olagran chowlng plat boundary of old 2/JO/65
Tacoau Ca* Coapany property. (Map located
at EPA regional file.)
Property of Uachlngton Natural Ca* Co. 3/7/6U
plant. (Hap located at EPA regional file.)
Hap (located at EPA regional file) No date
Drawing (located at EPA regional file) No date
Surface drainage and curlace water •••pie 1/64
location*
Proposed well location* 1/64
Hap, SUfc. Sec. 3 IWP20N. ft E W.H. No date
(Located at EPA regional file)
Diagram, «pur track agreement. • • No date
Dlagrea) (located at EPA regional'(lie) No date
Olagreai of Investigation *t*tlon*. No date
(Located at EPA regional file.)
Map. MEk. Sec 4 IWP 20 N. B.)E W.N. No date
(Located at EPA regional file.)
Dlagraa) (located at EPA regional file) No date
Aerial photograph (located at EPA regional No date
file)
1 Ujthlngton Natural Cac Co.
1 Washington Natural C*» Co.
1 Washington Natural Caa Co.
1 Washington Natural Gas Co.
1 Washington Natural Caa Co.
1 Plan Book. City of Tacooa
1 Unknown
1 Harding, Lawaon Assoc*.
I Harding, Law*on A**oc*.
1 Plan Book, City of Tacona
1 Unknown
Unknown
Applied Ceotechnology, Inc.
Plan Book, City of Tacona
Unknown
Unknown
-------
Ic
Author/OrganlzatIon
Addressee/Organitat1»
Ma|C. and
OO000257. H-ius JiiJ
OOO00250. Mao* autl |.liotu:i
OOOOOii*. Hajtii and
O0000260. Hap* and
00000261. CorrespoinJuiice, miscellaneous
00000262. Corrci|)OiiJi.-iice, miscellaneous
O0000263. Coi rcij)ondciite, miscellaneous
O0000264. Oilier tlocuiuuiita «ntl Info.
OG00026). Oilier JOCUUK.IIIS and info.
00000266. Oilier documents aiiU Info.
OOOOO26H. Contract u.iiidgcuent
Aerial pholo (located at EPA regional file) No dale
No date
O0000269. Contract ludiiageaeut documents
O0000270. Contract Hdiiage«eiit doctwent*
000002H. Cqniiaci
document «
00000272. Contract ManageMent docuaenta
of CoMunceoent Bay, Tar
Pita, alte location anil vicinity map
Site location taa|>, location and
vicinity nap
Aerial photos (located at tPA Regional
file)
Super fund cites aiap
Neawranda with attacliaenta regarding
probleas with CLP data froa the EAL Corp.
Latter with attached copies of water
resource peralt and certificate of
ground water right
'Letter re recycling of tar by Burlington
Northern
Letter with attached Hat of Super fund
altea and aerial photos
File review checklist for llygrade Corp.
and atte data
Site data Inspection report
Technical atatua report re work assignment
4095-0611.0 (CU2H1I111)
Technical atatua report re work assignment
409S-0611.0 (CliJMJill)
Technical atatus reprot re work aaalgnstent
4095-0611.0 (CH2HU111)
Technical atatua report re work assignment
1095-0611.0 (CH2MHU1)
Technical atatua report re work assignment
4093-0611.0 (CH2HH111)
1
No date 1
No date 19
No date
3/25/U6
6/9/H3
2/20/«<>
10A/U3
A/6/83
2A/B7 5
10/13/86 2
11/12/06 2
12/15/06 2
1/15/07
2/12/07
Unknown
Kennedy Jenks, Engineers
Harding LawMon Assoclatus
Unknown
Unknown
Joyce Crosaon, EPA
Frank L. Kirk, llygrade
Food Products Corp.
H. L. Cook, Burlington
Northern Railroad
Judi Schwarx, EPA
Jim Everts, EPA
Judl Schwarz, EPA
Phil Wong, EPA
Timothy Ji
Washington Natural t
Thomas A. Tobln
WDOE, Mike Blun, Paul Hltchle
S. J. llahn, EPA
S. J. llahn, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
22
-------
Doc*
File
00000273. Contract aaitageaent document*
00000274. Contract nanageaent docunenta
00000275. Contract aanageuent docuaenta
00000276. Contract nanageaent docuaente
000002)7. Contract aanageaent docuaenta
00000278. Contract aanagcaent docuoenta
00000279. Contract nanageaent docuaenta
00000260. Contract aanageacnt docunenta
00000201. Contract aanageaent document*
00000282. NPL llctlng and couuienta
00000203. NfL Hating and consent*
00000264. Maps unJ photo*
00000265. Rl*k Aaaeatment/Feaalblllty
Study folder 2
Type/Description
Date • Pagea
Author/Organisation
Technical atatua report re work aaalgnnent
«095-0611.0 (CH2MHI11)
Technical atatua report re work aaalgmaent
409S-0611.0 (CII2HII111)
Technical atatua report re work aaalgnaent
«09S-061L.O (CII2MII111)
Technical atatua report re work aaalgitment
'095-0611.0 (CH2MH111)
Technical atatua report re work aaalgnaent
«09S-0611.0 (CM2HH111)
BPA Suanary Evaluation Report (SER)
with attached description of activitlea
and perforaance (CII2MJIH1)
Award Fee Perforaance Event Report Part*
1 Mid 2 (CH2HH111)
EPA Suanary Evaluation Report (SER)
(OI2HH111)
Breakdown of Harding Lawaon Aaaoclatea1
budget eatlaate
Federal Reglater. Vol. 47, No. 251, NPL
propoaed rulea and Hating of altea
Federal Reglater, Vol. 48. No. 175, NPL
3/16/67 2
4/17/87 2
5/1J/87 2
6/17/67 2
7/13/67 2
3/16/87 3
7/13/87 2
7/7/67 1
No date 1
12/30/62
9/8/83
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
Wayne Crotlieer,
Wayne Crotheer,
Wayne Crotheer,
Unknown
EPA
EPA
EPA
EPA
EPA
Addreaaee/Organl
liat
Aerial photograph* at Tacoaa Tar Pita.
Two container*, 26 alldea aach. (Slide*
located at EPA Regional 111*.)
Letter re Review and Coaaenta on "Rlak
Aaaaaaaent of the lacoaa Htacorlcal Coal
Gaalflcaclon Site" Final Report dated
July 1987
6/14/67
John Catta, Harding
Lawaon Aaaociatea
Wayne Crotheer,
23
-------
Type/Uescr tpt ton
Hate
Author/Organi»ation
Addressee/Organization
00000286. Risk Assessment/Feasibility
Study Folder 2
OOOOO287. Risk Assessment/Feasibility
Study i'oliicr 'l
Letter re Review and Coawenta on Rick 8/17/07
Assessment (Filial) and Feasibility Study
(draft); with attached memo from David
Lincoln/SEA to Joan Stuupa/SCA re Review
of Tacoma Coal CasslfIcation Hick Assess-
ment (8/U/87)
Letter re Review and Comments on "Feasl- 8/17/87
blllty Study of Tacoua Historical Coal
Gasification Site," dated July 1987
Joan Stoupa,
CH2M Hill
John Catta, Harding
Lawuoii Aaaoclatea
Wayne Crotheer, EPA
Wayne Crotheer, EPA
UUU00288. Risk Assessment/Feasibility
Study Folder i
00000289. Risk Aj^i-biiu. i,i/KcatiJtillty
Study Foldci 'L
00000290. Risk A
Study Folder 'I
UUOUO2V1. Risk AstiessweiK/Feasibility
Study Foldci 'I
OOOO0292. Reaiedlal Invuiillgatlon
Report, Folder ), Final
Heato re Review of Risk Asaessaient
(July 1987) and comment» on previous
drafts
Letter re Coooents on druit Feasibility
Study (July 1987)
8/2i/a;
Meato re coawenta and evaluation of tech-
no log lea proposed in the feasibility study
for permanent aite remediation; attached
article froai Journal of EnviroMentai
Engineering. "Evaluating Asphalt Cap
Effectiveness at Superfund Site*." (June,
1987)
Letter re Review and Consents by EPA and
UOOE on draft Feasibility Study submitted
August 3, 1987} attached partial copies of
caau letter to 1) Douglas Ehlke, 2) Charleu
Bluawrfeld, Bogle & Gates, 3) Tim Hogan,
Washington Natural Caa
Vol. 1 Remedial Investigation, Final
Report, Tacosui Tar Pita, Tacoata,
Washlngtoi).
9/1/87
9/U/87 11
»/87
251
Dana Oavoll, Health
& Environmental
Assessment, EPA
Megan Wlilte, WUOK
John Barich, Bob
Stamiea, ESD, EPA
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Lee Marshall, EPA
Wayne Crotheer, EPA
Michael Cook,
Burlington Northern
Railroad
Applied Ceotechnology
Inc., on behalf of
Washington Natural Gas,
Joseph SiaKMi *• Sons,
Hygrade Food Producta,
Burlington Northern
Railroad.
24
-------
Hie
OOO00293. Lab Reports/Raw Data
00000244. Lab.Ri-r- us/Raw Data
00000295. Ub Reports/Raw Data
00000296. Ub Reports/Raw Data
OOO00297. Lab Reports/Raw Data
OOUO0298. Lab Ri-poris/Rau
00000299. Lab RepoiIs/Raw Oat*
00000300. Lab Repot Is/Raw Data
OOO00301. Lab Reports/Raw Data
00000302. Ub Report*/Raw Data
0000030}. Lab Report*/Raw Data
Type/Description
Date I Pave6
Data Package: Ca*e '346? located at
EPA Hanclie* ter Lab.
Data Package: Caae »3467 located at
EPA Manchester lab.
Data Package i Case «3467 located at
EPA Manchester Lab.
Data Package*: Case »3759 located at
EPA Manchester Lab.
Data Package: Case «3579 located at
EPA Manchester Lab.
Data Package: Case 13630 located at
EPA Manchester Lab.
Oats Package: Case «3759 for sample
Nos. MJ0969 through MJ0980 located at
EPA Mancheater Lab.
Data Package: Case »3467 for sample
Nos. MF0901 through MJ0908 located at
EPA Manchester Lab.
Shipping
Date;
11/06/84
Shipping
Date:
n/06 /a'.
Shipping
Date:
11/07/U4
Shipping
Date:
01/07/85 &
01/08/85
Shipping
Date:
01/08/Bi
Shipping
Date:
12/07/84
Sampling
Date:
l/K/85 -
1/16/85
Sampling
Date:
10/26/84
_, u __ •*-•«•• «rW«*«r«T*'*M^«*SI
Versar Lab EPA Mancheater
Rocky Mtn. Lab EPA Manchester
Cambridge Lab EPA Manchester
EAL EPA Manchester
Versar Lab EPA Manchester
Wilson Lab EPA Manchester '
Harding Lawson EPA Manchester !
Associates, Ecology &
Environment
Harding Lawson EPA Manchester L
Associates. Ecology t>
Environment
form* re parameter hazards for
•ample number* 67060020 through' 87460029
SUMS t Ion for* for parameter hazards
for ssmple No. 8S2206SO.
Summation forms for parameter hazards
for ssmple Nos. 86434550 through 86434554
87
85
86
10 EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Ub
25
-------
Type/Description
Date • Pages
HHMJO104. Lab KCJ.UI
UOOOJui Lab
li.ua
D..IJ
OOOUJU6. l.ul> Kcpori*/K.iw D.ii.i
jooo3U7. Ub
JOO0308 Couuunity Relations and
news
IOOOJU9 Remedial Invest IK.U lun
Reports I- older 3, Final
W003IO
•OU0311 HUk
study, Folder 2
000)12 Klsk
atudy, Folder 2
UOOJl) Kick Asstadaent/ltaslbl llty
vtudy, Folder 2
300314 Proposed Plan for
Action
OO0315 Propoaeil PUn lor Kewedlal
Action
Saaple analysis results for sanple
Nos. 85220650 through 85220663.
Saaytle analysis results for saaple
Nos. 0S23O450 through 8523045S.
Saople analysis results for sample
Nos. 86434550 through 86434554.
Sample analyala results for cample
No*. 67060020 through 87060029.
EPA fact aheet: Super fund Project
5/29/85
6/3/H5
10/23/86
2/4/87
11/10/87
— ^— 1«\- —
21
V
5
10
5
EPA
EPA
LPA
EPA
EPA
Lab Region X
Lab Region X
Lab Region X
Lab Region X
Author/Organization AJdrosee/OrganizatlOn
Update
Addendu* to Heaedlal InvestIgation
(Rl) Report
Addendum to Rlak Amieasaent
Addenda* to Ihe Feasibility Study
Fca«lblllty Study, Final Report
Cover latter re: .attached response
to coewenta on tlie Feasibility Study
Proposed Plan for Remedial Action
Meax> re a Proposed Rested la 1 Action
No dale *•
No date 4
No date 2
J/ttt
10/22/8? 42
11/4/U7 17
11/13/07 1
EPA
EPA
EPA
Envlrosphere Coopany
Spyros P. Pavlou,
Envlrosphere Coatpany
EPA
Joel Mulder. ATSUR, EPA/
CDC Liaison
Record
Record
Record
Washington Natural Gal
Company, Joseph Si lion S
Sons, 1 nc. j Hygra dil t FiiS
Products Corp., BurUnfE
Northern Railroad Coupifi
Wayne Urntheer. EPA
Lee Marshall, EPA
26
-------
Type/UeacrlptIon
H)UOJI4. Proposed Plan lot Ucacdial
Action
1000317 Proposed I*I.in lor Remedial
Action
•J003I8 Proposed Plan lor Remedial
Action
30031V Proposed I'I an lor Remedial
Action
UOU32U Proposed Tl
Act lull
lui IU:iucdial
JOO321 Proposed I'Jjn lor Remedial
Action
IO0322 Notice- Letters -ind Responses
UMJ323 Notice Letters .11.d Responses
Notice Letters .inJ Responses
XMM2S Notice Lutl^is aitj
Nutlet: Letters and Kespouseb
Presentation lor I'roposeJ flan tor
KeaedUl Action: I'ublic hearing
transcript.
»
L«tt«r re: I'ublic hearing on proposed
plan.
Htmo rei A1SUK review of Proposed
Plan.
Heao ret Coaaents on Proposed Plan
Letter re attached letter concerning
NPL listing and state requirements
tor selection of reaedy
Letter re notice letters to property
owner* and utilities, and attached
cocatents on Proposed Plan
Heno re: notice to responsible parties
with attached list of potentially respon-
sible party attendance at 7/62 meeting.
Letter re: response to notification
of potential responsibility.
Letter of notification re potential
responsibility and request/ for atten-
dance at Meeting. \
Letter of notification re potential
responsibility and request for atten-
dance at Meting.
Letter of notification re potential
responsibility and request for atten*
dance at aceting.
Date I Pages
U/ltt/«7 19
11/13/B? 1
Author/Organization Addressee/Organization
11/30/87 2
U/WU7 3
3/20/82 2
5/WB2 1
7/20/82 2
7/20/82 2
7/20/82 2
Lee Marshall, EPA
Tlaothy Brlnceileld. fcPA
TlBOthy J. llogan,
Washington Natural Can
Joel Mulder. ATSUK, EPA/
CDC Liaison
Chief, Health Sciences
Branch Office of Health
Assessment, ATSOR
Lee Marshall. EPA
Charles R. Blumenfeld,
Bogle & Cates
John K. Spencer, EPA
T. J. llogan, Washington
Natural Gas
Robert A. Poss, EPA
Robert A. Poss, EPA
Janes M. Everts for
Robert A. Poss, EPA
Lee Marshall, EPA
tee Marshall, EPA
Joel Mulder, ATSOR,
EPA/CDC Liaison
Timothy J. tlogan,
Washington Natural Cas
Lee Marshall, EPA
William A. Sullivan, Jr.
EPA
Ms. Kathy L. j
U.S. EPA, Washington, 6,
timothy J. Hogan, WaJhlh
Natural Gas
Phillip Simon, Joseph Si
& Sons
Frank Kirk. Hygrade Pood
Products Corp.
27
-------
Type/Description
Dale * Pages
Author/Of ganizat loi>
Addressee/Organization
Nut Ice U-iin:i .ui.l ((espouse:* Letter re: request to undertake site 7/30/82 I
Investigation.
Robert A. POM, EPA
Timothy Hogan, Washington
Natural Gas
0328 Notice Letters and Responses
0329 Notice l.ericrs iiiul ((espouses
0330 Nut Ice I.etteis iind Responses
U33I Nut Ice l
.m.l Responses
0332 Notice Letters .nij Responses
'J333 Notice Letter:; .iiiJ Responses
J33<« Notice Leliur.s
J335 Notice Letieru .nij Kcspouses
1336 Notice Letters ..uJ Kespouses
1337 Notice Letters und
UJb Hut Ice Lelterti
-------
Uoc*
Kile
Type/Doscriptlun
Hate f Pages
Author/Organlzat ton
AclJressce/Organliatlon
OOOOOJ39 Notice Letter* ai.J Responses
Letter re previous notification of
potential responsibility and EPA review
of study by Kennedy/Jeuks Engineers.
11/08/63 2
Robert A. Poss, EPA
Jeff S. Asay. Union
Pacific Railroad
JOOOO340 Notice Letter* and Responses
k)OOG3<>l Notice Letters di.J Responses
JOOO342 Nut Ice Letters uiiJ Responses
DOO03O
Reports, Folder 3, Final
Letter re previous notification of 11/06/83 '2
potential responsibility and EPA
review of atudy by Kennedy/Jenka
Engineers.
Utter re previous notification of 11/08/63 i
potential responsibility and EPA
review of atudy by Kennedy/Jeiiks
Engineers.
Letter re previous notification of 11/08/43 I
potential responsibility and EPA,
review of atudy by Kennedy/Jeiiks
Engineers.
VoltuM 2, Rested la 1 Investigation Final 9/87
Report.
Robert A. Poss, EPA
Robert A. Poss, EPA
Robert A. Poas, EPA
260 Ceotechnology, Inc.
Frank L. Kirk, Hygredc
Food Producta Corp.
Phillip Slaon, Joseph
Slaon & Sons, Inc.
Hike Cook, Burlington
Northern Railroad
Prepared for Washington
Natural Gee Corp., Joaep
Slawn & Sona, Inc., Hygr
Food Product* Corp.,
Burlington Northern Rail
Coapany.
29
-------
OOCUCIffS DELETED FKOM TAB PITS ADMINISTRATIVE RECORD
DOC.
FILE
00000006. Pre-Superfund Information
00000121. Contract management doc.
00000134. Contract management doc.
00000160. Contract •anagmenc doc.
0000012). Control udiiagcaent doc.
SUBJECT/TITLE
Rcquett for authorisation to retire
Contract Pricing propoeal. 9/S/66, 4 pp.,
tollman, CH2Mllll/Huor«. EPA
Technical atatue report 6/17/67. 42 pp.,
CH2MH1II/Catt*. Herding Uw*oo ieeoce.
Technlcel etetue report 7/13/07, 5 pp.,
CHttMlll/Catte, Harding Laweon Aiaoce.
CahlbU li Breakdown of IILA'e budget
eatlaate, 5 pp., Harding Uw*on Ataoci.
REASON REHOVED
Duplicate of Doc. 12
Confidential buatneaa Information
Several ISH Included under Doc. eoOOOOm.
They wre eeparated and given individual
document number* (*ee Doc. •00000266-00000277).
Same reason for removal a« for Doc. •00000194 above.
Confidentlj| buclneaa Information
30
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APPENDIX u
R'ESPONSTVCNiESS SUMMARY
TACOMA TAR PITS
TACCMA. WASHINGTON
This community relations responsiveness summary is divided into the
following sections:
Section A
Section 8
Section C
Section 0
Overview. This section discusses the EPA selected alternative
for corrective action, and public reaction to this alternative.
Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concerns
raised during remedial planning activities at the Tacoma Tar
Pits.
Summary of Comments
and EPA's Responses
Received During the Public Comment Period
to the Comments. Both written and oral
EPA's responses to these comments
comments are categorized.
are also provided.
Remaining Concerns. This section describes remaining commun
concerns that EPA should take Into consideration In conducting
the remedial design and remedial action at the Tacoma Tar Pits
site.
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sufficient Importance a me'spons* **,$ ^srattlsflitss jprepareid. Vierbal cowments
centered around the proven efffect1ven«'s.s Of tut TtablHistten process and the
need for groundwater e-xtracti'on awd treatment.
Written comments were received from tt» above named PtPs during the
public comment period. Concerns included the-nee'd to identify additional
and the extent of excavation and treatment.
The lack of public concern may, in part, be a result of the fact that t
site is located within a heavily industrialized area, with no adjacent
residential community.
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A. OVERVIEW
A group of Potentially Responsible Parties (PRPs) including Washington
Natural Gas Company, Joseph Simon and Sons, Inc., Hygrade Food Products. Inc.
and Burlington Northern Railroad Company, with oversight by the EPA and
Ecology performed the RI/FS at the Tacoma Tar Pits site in Tacoma,
\
Washington. ^
In 1924. a coal gasification plant was built on the site. This plant
operated until 1956 during which time, waste materials from the coal
gasification process were disposed of on-slte. Demolition of the plant began
in 1965 and was completed by 1966. During the dismantling and demolition
procedure, some waste materials and process equipment were left in place. In
1967, the property was purchased and metal recycling operations were
initiated. Th'ls operation introduced a variety of organic and heavy metal
contaminants to soils on site.
The selected remedial alternative resulted fro* modification, primarily
in the-areas of quantity of material to be stabilized and site boundary
definition, of the remedial alternative recommended by the above named PRPs.
These modifications were required by EPA and .Ecology. This modified remedial
action Includes excavation and stabilization of contaminated soils and capping
of the stabilized soil matrix. This alternative is described in more detail
In the Decision Summary and the Feasibility Study.
This Responsiveness Summary describes concerns which the community has
expressed in regards to problems at the site and the recommended cleanup
alternative. Very few public comments were made at the public hearing on
November 18. '987. and one comment was received from the PRPs during the
public meeting. The Puyailup Indian tribe provided written comments following
the close of the public comment period. Because their comments were of
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i. BAC-KGROUNO ,ON COMMUNITY INVOLVEMENT
T'hert ha:s -not been much specific community Interest In the Tacoma TaH
Pits site, except for the directly affected businesses. Most community
involvemeint has focus«d on the greater Commencement Say site, of which this f;
r-
a part. The .directly affected businesses agreed to conduct the remedial
Investigation and feasibility study In 1984.
The news media covered EPA's 1984 remedial Investigation start and
subsequent responsible party takeover of the Investigation.
The Commencement Bay Citizens Advisory Committee has discussed the site
several times with the site manager. The most recent discussion was on
September 10, 1987, when the Agency presented the draft RI and FS results.
The focus of their concerns have been cleanup levels on and off the site, the
basis for those levels, and who would pay the cost of cleanup.
1) Citizens have requested to know the proposed cleanup levels on and
off..the site and the basis for those levels.
EPA Response: The specific levels proposed were explained In detail, and
are explained elsewhere in this document. The levels are based on
applicable, relevant and appropriate requirements in federal and state
law.
2) Citizens have requested to know who would pay the cost of cleanuo.
EPA Response: Responsible parties are conducting the RI/PS. The agency
will seek to have them pay for cleanup as well as for EPA's own costs.
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2. A concern was raised with regard to tht effectiveness of the
stabilization process for Immobilizing contaminants.
Agency Response - Although the cement/polymer stabilization process is a
proven technique for immobilization of heavy metals, this technique has
not been conclusively proven to be effective In immobilizing organic
contaminants in coal tars. Therefore, both laboratory and bench scale
treatabllity studies will be performed during the design phase of the
remedial action to ensure the process will be effective and permanent.
During laboratory scale studies, the proper mixture of components and
additives will be determined such that maximum contaminant Immobilization
is achieved. During bench scale studies, the leachabllity of the
stabilized matrix will be evaluated following adequate curing and aging.
As an option to stabilization of all contaminated soils, the sol Is/tars
containing the highest tar content (EHW) may be considered for an
alternate type of treatment/disposal (I.e., Incineration) if the
stabilization process is found to be ineffective .for the waste matrix.
The volume of this EHW would, be relatively small and this would
significantly reduce the average organic carbon content of the soil to be
stabilized.
3. A question was raised regarding the property to the east of East River
Street, and whether contaminants existed beneath this property.
Agency Response - Historical'Information suggests that tars were not
directly placed in this location. However, overland flow of wastes or
wastewaters from the coal gasification plant did occur In this location.
When groundwater monitoring well AGI-1D was constructed, visible evidence
of tar-related materials was observed. Therefore, some degree of soil
contamination is present east of East River Steet.
Hrltten Comments from the PRPs
4. The record should reflect that additional potentially responsible parties
beyond the undersigned have been identified for the Tacoma Tar Pit site.
These additional potentially responsible parties should be promptly notified
of their potential liability associated with the site pursuant to Section 122
of CERCLA so that they may have a meaningful opportunity to participate in
decisions regarding the remediation of the site.
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Agency Rgsiponsie - !EP.'A **nd ecology agree that to the extent additional
r-espofi'sibie parties *nt idftfltifle.d,, such parties should be notified
con'S iste-nt *ith fht retirements of SARA. The £PA will perform this
activity In a timely fashion.
5. Several attempts have teen made to clarify the extent of material tha:
will be excavated and treated under the proposed remediation plan. Your
letter of December 1, 1987, states that PAH contaminated material containing
In excess of I percent PAH must be excavated and treated In order to satisfy
the "State requirement that all extremely hazardous wastes are removed from
the site or treated...". The PAH contaminated materials have remained
undisturbed at the site for over 30 years. There Is no applicable state
requirement nor is there any relevant and appropriate requirement under the
State's Waste Management laws or the regulations thereunder that mandates
removal and treatment of all extremely hazardous material at the site. These
points are further clarified under the State's newly enacted laws dealing with
Hazardous Waste Sites—Cleanup Operations, Senate Bill No. 6S05. Section 29'
of the new law amends the Hazardous Waste Management laws, chapter RCW 70.105,
with the addition of the following language:
A person conducting a remedial action pursuant to an approved settlement
agreement or the department conducting a remedial action or the department
conducting a remedial action under Chapter 70. RCW (Section 1 though 25 of
this act) is exempt from the procedural and substantive requirements of this
chapter, (emphasis added).
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If this severely contaminated material is left In place, the total
quantity of contaminants left in contact with local groundwater would be
significantly increased and the effectiveness of the site cleanup may be
significantly decreased. The statutory mandate in CERCLA, as amended by
SARA, for treatment of contaminants to the maximum extent practicable is
also mat by the stabilization of all EHW found at the site during
remediation.
All EHH materials snould be treated in a similar fashion. Materials
classified as EHWs left beneath the site in areas other than the pit,
ponds, and tar boil area would interact with the environment in a fasnion
similar to EHW's at these three locations if these locations were merely
capped. This is consiaered unacceptable and all on-site EHW should oe
dealt with ;1n a consistent fashion.
. i
6. Written comments from the Puyallup Indian Tribe received after the dose
of the public comment period.
On December 17, '987 £PA received a letter from Thomas Oeming for the
Puyallup Tribe of Indians dated 5 December 1987. The letter was postmar
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C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES TO THE COMMENTS
Comments from members of the public, primarily several PRPs, regarding
the selected remedial alternative are summarized below. Comments are grouped
into those generated during the public meeting and those received in writing
during the formal public comment period.
\rhe public comment period ran from November 6, 1987, to December 6, 1987,
11 \' -
(30'days). A public meeting was held at Pierce County Health Department on
Wednesday evening November 18, 1987, to explain the results of the site
Investigations and to discuss the recommended remedial alternatives.
Comments Made During the Public Meeting
1. A concern was raised regarding the extent of contamination of local
groundwater and why no action was to be taken to clean up this resource.
Agency Response - The RI results show that the two upper zones of
groundwater (aquifers) contain waters that are contaminated. The thiri
aquifer appears to be free of -contamination. The shallow ground wateifl
not currently used as a potable resource, nor Is It expected to be user
as a resource in the future due to salinity, low yield and the
characteristically high dissolved solids. Local groundwater supply wells
are completed at depths^much greater than the vertical extent of
contamination. Therefore, groundwater extraction and treatment is not
included within the selected alternative. However. If monitoring
suggests that contaminants are being discharged off-site at
concentrations exceeding performance standards, a hydrogeologic
investigation of design study for groundwater extraction and treatment
will be initiated.
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Agtncv Response - A review of 8IA map dated 1977 Indicates that the site
Is not located within the reservation boundary set forth and recognized
at that time. Although the question of lands claimed or under legal
dispute cannot be answered by this ROD action, EPA Is required by SARA to
consider environmental Impacts and natural resources (and has in this
Instance) when selecting remedial action, whether the site is located on
reservation property or not.
Comment - alternative #13 Is not consistent with the federal trust
responsibilities and thus must be reevaluated to assure complete cleanup.
Also, the remedial alternative fails to adequately remedy groundwater problems,
Agency Response - without addressing the legal Issues of federal trust
responsibilities and whether they apply at this site, 1t should be
emphasized again that EPA has selected a remedy that Is protective of
public and environmental health. The remedy selected meets the
standards, criteria, and other requirements of SARA and the NCP,
including technical feasibility, institutional considerations, and
cost-effective cleanup. As indicated above, water quality considerations
will be protected by the remediation In conjunction with the enhanced :
groundwater monitoring. Measures for additional remediation will be
considered on an as needed basis.
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C. 5UMMASY Of COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES TO THE COMMENTS
Cowntnts from members of the public, primarily several PRPs, regarding
the selected remedial alternative are summarized below. Comments are grouoes
into those generated during the public meeting and those received in writing
during the formal public comment period.
The public comment period ran from November 5, 1987, to December 6, 1987.
(30 days). A public meeting was held at Pierce County Health Department on
Wednesday evening November 18. 1987, to explain the results of the site
investigations and to discuss the recommended remedial alternatives.
Comments Made During the Public Meeting
1. A concern was raised regarding the extent of contamination of, local
groundwater and why no action was to be taken to clean up this resource.
Agency Response - The RI results show that the two upper zones of
groundwater (aquifers) contain waters that are contaminated. The third
aquifer appears to be free of contamination. The shallow ground water,
not currently used as a potable resource, nor Is It expected to be used
as a resource in the future due to salinity, low yield and the
characteristically high dissolved solids. Local groundwater supply wells
are completed at depths much greater than the vertical extent of
contamination. Therefore, groundwater extraction and treatment is not
included within the selected alternative. However, if monitoring
suggests that contaminants are being discharged off-site at
concentrations exceeding performance standards, a hydrogeologic
investigation of design study for groundwater extraction and treatment
will be initiated.
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He attempted to resolve this Issue by agreeing to modify Alternative 13
to Include treatment of all tar and sludge beneath the ponds and the pit which
exceeded 1 percent PAH. This practical solution was offered not because of
our recognition of the need to remove or treat extremely .hazardous waste, out
rather as a recognition that the structural integrity of the stabilized
material may require treatment of unstable tar and sludge In any event.
EPA's proposed plan should be clarified by deleting any reference to
excavation and treatment of extremely hazardous waste and. Instead, refer to
the excavation and treatment of the tar and sludge beneath the ponds and the
pit which exceed 1 percent PAH concentration. The clarification does not in
any way detract from the level of protection afforded human health and the
environment by the selected alternative yet it provides a higher level of
certainty that the quantities of material and estimated cost described in
Alternative 13 are accurate.
Agency Response - It is the EPA's and Ecology's opinion that all material
classified as EHM (>1 percent PAH) should be removed from the site
regardless of location. This material should be excavated in the
vicinity of the tar pit. ponds, and tar boil until levels less than I
percent PAH are reached. Historical data suggests that a tar layer may
be present under portion of the site other than these areas. In most
areas, this tar may be present at depths of less than 3 feet, in which
case, it would be excavated under the "shallow soil" criteria. If,
however, tar material exceeding l percent PAH is found to be present at
depths of greater than 3 feet, this material should be removed and
treated in addition to the shallow soils.
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APPENDIX III
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
The Superfund Amendments and Reauthorlzatlon Act of 1986 (SARA) includes
provisions for the selection and preference of remedial actions. Excavar'on
and off-site land disposal options are least favored when on-site treatment
options are available. Emphasis Is placed on alternatives which permanently
treat or Immobl1Ize contamination.
Requirements for cleanup of waste sites are Identified in terms of
Applicable or Relevant and Appropriate Requirements (ARARs). Applicable
requirements are those standards or requirements which specifically address a
hazardous substance, pollutant, or contaminant, remedial action, location, or
other circumstance at a CERCLA site. For example, discharges of water to the
navigable waterway are regulated under the National Pollution Discharge
Elimination System (NPOES) program of the Clean Water Act. Relevant and
*
Appropriate requirements are those that apply because conditions at the site
sufficiently resemble conditions for which the requirements were developed.
The Federal Resource Conservation and Recovery Act (RCRA) is an Example of a
law that is "relevant and appropriate" to the Tacoma Tar Pits site. This law
Is not applicable because the site was never given interim status nor issued a
permit for handling solid waste. Nevertheless, the site sufficiently
resembles a landfill as defined In 40 CFR 260 that waste handling standards
may apply. While SARA requires that all ARARs be met. or in limited
drcuflHtances waived, the procedural requirements of such laws are waived for
actions conducted entirely on site. Thus permits are not required.
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State'standards must be attained during remedial action under SARA if
such standards were promulgated under state law that is more stringent than
federal requirements, were identified to EPA In a timely manner, and are
legally applicable or relevant and appropriate to the contaminants of
concern. Most importantly, SARA requires that cleanup of a site ensure thar
the public health and environment are protected. It also requires that
\
alternative remedies must be weighed In the selection process. ^ '
ARARs which may apply to this site are listed In the Feasibility Study
and are presented here again with situations to which they may pertain. The
specific provisions of ARARs that may be pertinent to a particular alternative
are discussed when the alternatives are evaluated.
Federal Laws and Regulations
Resource Conservation and Recovery Act (RCRAX42 USC 6901), Subtitle C:
Part S permit. The use of certain treatment systems, In particular
waste Incinerators, requires the preparation of a Part B permit
application. Information on the site such as geotechnlcal and
hydrological conditions must be Included along with intended uses of
the site.
Groundwater Protection (40 CFR 264, Subpart F). Pertains to
groundwater monitoring, hazardous constituents, concentration 1imi:s,
points of compliance, and corrective action. A program of
groundwater monitoring must be implemented to detect the presence of
contaminants at the point of compliance, which is usually at site
boundaries.. If concentrations of particular compounds are detected
above designated limits more extensive monitoring Is necessary and
corrective actions may be required.
Closure and Post-Closure (40 CFR 264. suboart G). Post-closure care
must be proviaeo -or at least thirty years and includes monitoring.
reporting, and mainrsnance of waste containment systems. Covers and
similar structures -nust not be disturbed unless special conditions
arise. A local '=nd use authority must be notified of the presence
of remaining con r-.-n; nation and the locations of waste facilities.
Also, the ars'/ic.: -.se of :ne site and restrictions on the future use
of the site TIUS: :* "?corded in rhe property deed.
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D. REMAINING CONCERNS
Several Issues concerning .design parameters have been discussed but h
not yet been totally resolved. These will be addressed in the subsequent:
design pnase of this project and include:
Treatablllty of relatively pure coal tars by the stabilization process or
alternative treatment/disposal methods
Criteria to be used to evaluate the effectiveness of the stabilization
process during laboratory and bench scale studies
The number of additional monitoring wells needed to establish a
groundwater monitoring networ< In lieu of groundwater extraction and
treatment. ,,•
Criteria for determining the necessity for groundwater extraction and
treatment be evaluated.
Performance of remediation to minimize possible disruptions to on-site
operations.
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Designation of Dangerous Waste (DM) and Extremity Hazardous Wast* (EHHXWAC
17-303-081 to 103); '
Tht state definition of a hazardous waste incorporates EPA
designation of hazardous waste which is based on the compound being
specifically listed as such, or on the waste exhibiting the
properties of reactivity, ignitabi11ty, corrosivlty, or Extraction
Procedure (EP) toxicity. Ecology distinguishes hazardous waste as
Extremely Hazardous Waste (EHW) or Dangerous Waste (DM). The
distinction is based on the properties of persistence,
concentration, careinogenlcity, mutagenicity, teratogenicity,
concentration of certain compounds, and toxicity. Residues,
contaminated soils, water, or other debris from the cleanup of
spills of compounds listed on the "moderately dangerous chemical
products list" (WAC 173-303-9903) In excess of 400 pounds are
designated as OH. If the spilled compounds are listed on the
"acutely dangerous chemical products list" (WAC 173-303-9903),
soils, residues, water, or other debris In excess of 220 pounds are
considered EHH. Materials containing greater than 1 percent PAH. are
considered EHH when the total quantity exceeds 220 pounds. However,
wastes which were not designated as hazardous waste at the time of
disposal are not considered OH or EHH. EPA and Ecology have
determined that the EHH requirements are relevant and appropriate
for the Tacoma Tar Pits site.
Incinerators (HAC 173-303-670):
In addition to Federal regulations, incinerators must comply with
the emission standards determined by the air pollution control
authority. In this case, the Puget Sound Air Pollution Control '
Authority.
Groundwater Protection (HAC 173-303-645):
Groundwater protection requirements for waste management facilities
are generally comparable to Federal regulations. The point of
compliance, the determination of dangerous constituents which are
monitored, and the compliance concentrations, however, are
determined by Ecology on a case-by-case basis.
Hater Quality Standards (MAC 173-201):
Surface water bodies are classified according to the water quality
and uses of the water. Tht surface waters near the site are
classified as follows:
Class 8 (good) - Puyallup River, Inner Commencement Say
Class C (fair) - Commencement Say - City Waterway
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Criteria are established for fecal conform bacteria, dissolved
oxygen, total dissolved gas. temperature, pH, and turbidity. In
addition, concentrations of contaminants must be belcw levels which
may adversely affect human health, the environment, or uses of the
water body.
The criteria and classifications of the State Water Qual
Standards do not apply within a dilution zone defines oy
Within the dilution zone, fish and shellfish' must not ae
aesthetic values diminished.
NPO£S Permits (administered by the state under WAC 173-216):
ity
Ecology.
'
\
Discharges of water to\ off-site navigable waterways may require an
NPOES permit. The concentration limits of contaminant discharges
are determined on a case-by-case basis.
Hater Pollution Control and Discharge Standards (90.48. 90.52. and 90.54 RCW):
Waters of the state of Washington, which include surface water and
groundwater, are to be protected to maximize their beneficial use.
Materials and substances which might enter these waters must receive
prior treatment with known, available, and reasonable methods.
Protection of Upper Aquifer Zones (HAC 173-154):
Upper Aquifers and Upper Aquifer zones must be protected to the
extent practicable to avoid depletions, excessive water level
declines, or reductions in water quality In order to preserve the
water for domestic, stoclcwater, and similar uses, and preserve
spring and stream flow.
State Water Code (90.03 ECU) and Water Bights (90.14 ROO:
These laws specify the conditions and extracting surface water or
groundwater for nondomestic uses. Basically, water extraction must
be consistent with beneficial uses of the resources and must not be
wasteful. Groundwater extraction wells, which may be used to
control the migration of contamination via groundwater. must como'y
with the substantive requirements necessary to obtain a water rignts
permit. Water rights laws may pertain if groundwater is extracted
for treatment.
Hater Well Construction (13.104 RCH and MAC 173-360):
Minimum standards exist for water well construction, construction
reports, and examination and licensing contractors and operators.
These standards may apply if extraction wells are installed.
Submissions of Plans and Reports (WAC 173-240):
ecology must "eview plans for wastewater treatment facilities.
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Landfills (40 CFR 264. Suboart N). Provisions pertaining to the
capping, monitoring, closure, and post-closure care of the site. A
final cover must be .placed which minimizes the migration of llquli
through the landfill, requires minimal maintenance, promotes
drainage, and minimizes degradation of the surface, accommodates.
settling and subsidence without the loss of effectiveness, and has a
permeability less than the underlying materials. The cap must be
Inspected and maintained, and groundwater monitoring conducted.
Incinerators (40 CFR 264. Subpart O'XRCRA. Subtitle C. Section
3003). Provisions pertaining to the testing, performance standards,
operation, monitoring, and closure of Incinerators, including mobile''
Incinerators. Wastes to be burned must be chemically analyzed; trial.
burns must be performed; the incinerator must be operated to achieve
a destructlonland removal efficiency (ORE) of 99.99 percent for
Principal Organic Hazardous Constituents (POHCs); air emissions must
be monitored, hydrogen chloride must be controlled to the less
stringent of 99 percent removal or 1.3 leg per hour, and partlculate
emissions must not exceed 180 mg per dry standard cubic meter, and
upon closure all wastes and waste residues must be removed. A Part 3
permit application must be submitted and approved prior to the use of
an Incinerator, except for test burns.
Clean Mater Act (CMAX33 USC 1251):
National Pollution Discharge Elimination System (NPOESX40CFR 122).
These regulations govern point source discharges into navigable
waterways such as the Puyallup River. Limits on the concentrations
of contaminants which may be discharged are determined on a
•case-by-case basis.
Federal Mater Quality Criteria:
Mater quality criteria are established which are limits on the
concentration of compounds of fresh and marine waters. These
criteria may apply to discharges into off-site surface water. The
action levels include water quality criteria for on-site and boundary
surface waters.
Safe Drinking Hater Act (SOHAK42 USC 300):
Drinking Mater Standards (40 CFR 141). Maximum contaminant levels
(MCLs) must be attained for sources of drinking water. The MCL for
lead (50 ppm) was included in the action levels. Drinking water
regulations are relevant and appropriate to the lower aquifers at the
site.
Departatnt of Transportation. Parts 171 to 173:
Transport, packaging, labeling, placarding,.and manifesting of
hazardous waste shipments. These regulations apply to the off-site
shipment of contaminated soils and perhaps spent activated carbon.
Waste materials nust be identified. loaded in non-leaking containers,
labeled and placarded as appropriate for the contents, and manifested^
to verify that the shipments reaches Its Intended destination.
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Air Quality. General Emission Standards (WC 171-4QQ-Q4Q<53)-:
Contaminant air emissions from any sources must not b,t detrimental
to tht health, safety, or welfare of any person and must not damage
any property or business. Emissions from incinerators must satisfy
this requirement.
Air Emissions. New Source Review (MAC 173-400 and 173*403);
Emissions of toxic air contaminants from new sources undergo a
review process in which the contaminants are identified, the best
available control technology (BACT) is determined, estimates are
made of the maximum ambient air concentration (MAAC), and an
acceptable ambient level (AAI) established. Based on these
findings, a new source may be approved or disapproved. New source
review applies to hazardous waste incinerators.
Incinerators (MAC 173-303-670):
The state regulations regarding incinerators are comparable to
Federal Regulations. In addition, regulations of the local air
pollution control authority pertain. In tht Tacoma area, the Puget
Sound Air Pollution Control Authority (PSAPCA) has Jurisdiction.
According to PSAPCA regulations, partlculate emissions are limited
to 0.01 grains per standard dry cubic feet of air (gr/sdcf) compared
to O.OS required under federal regulations. Also, BACT must bt
used. Because Tacoma is a containment area for partlculate matter,
emissions must be less than 50 pounds per hour. Exceedence of this
level requires the "purchase" of emission offsets at 1.1 tlmts the
emission rate. ...
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Toxic Substances Control Act (TSCA)-(IS USC 2601 )x :
Records, reporting, storage, handling. Incineration, and landrrrn
of PCB-containinq wastes. (40 CFR 761.60-.79). These regulation*
apply-to di;-nsal or incineration of excavated PCB-contaminated
materials. -8 materials which are disposed of prior to February '7,
1978, are considered to be in service and do not require excavation
for disposal. Incineration of excavated PCS-containing materials
must destroy 99.9999 percent of the ?C3s. The incinerator must oe
approved and be operated under specific conditions. Materials
containing less than 50 ppm PCBs may be disposed in a sanitary
landfill.
Excavated materials containing PC8s at concentrations of 50 pm or greater
when disposed must be placed in a chemical waste landfill. Several conditions
must be met by a chemical waste landfill approved for PCS disposal: The
landfill must be located in impermeable formations; synthetic liners may be
required if the permeability of the underlying soil is judged to be excessive;
the landfill must be located above historic groundwater levels and away frcm
floodplains. shoreiands. and groundwater recharge areas; flood protection" must
be provided; it must be located in areas of low to high relief to minimize
erosion; surface waters and groundwater must be monitored at least for PC3s,
chlorinated organlcs, specific conductance, and pH; a leachate collection and
monitoring system must be installed; the landfill must be operated with proper
record-keeping and handling, and incompatible or ignitable wastes are not
allowed; fences must be placed around the site, site roads must be maintained,
and hazardous conditions due to spilled or windblown materials must be
prevented.
State Regulations:
Tht state of Washington can develop its own hazardous waste regulations,
provided they are at least as stringent as Federal regulations. For the most
part, state hazardous waste regulations oarallel the federal regulations.
Therefore, the comparable state regulations are not repeated. There are some
notable differences. However, which are alscussed below.
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