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.
                                                                  2 of 36

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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
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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
                                                                 8 of  36

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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.
                                                                  11 of  36

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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.
                                                                 12 of  36

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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.
                                                                  13 of  36

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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

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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

-------
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

-------
     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

-------
     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

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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

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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.

-------
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.

-------
     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).

-------
    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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