United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-86/012
December 1987
SEPA
Superfund
Record of Decision:
Frontier Hard Chrome, WA
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REPORT JOCUMENTHION . - . EM/ROD/R10_8e/012 *
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Frontier Hard Chrome, WA
First Remedial Action
7. Author(s)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
12/30/87
6.
8. Performing Organization Rept. No.
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
19. Supplementary Notes
16. Abstract (Limit: 200 words)
The Frontier Hard Chrome (FHC) site covering approximately one-half acre, is located
in the City of Vancouver, Washington. Underlying ground water is used as the drinking
water supply for the City of Vancouver. Two well fields are within one mile of the FHC
site. The site has primarily been occupied by two businesses engaged in the chrome
plating industry. Pioneer Plating operated at the site from 1958 to 1970. The site was
then occupied by FHC until 1983. During Pioneer's operation and FHC's initial
operation, chromium plating wastes were discharged to the sanitary sewer system. In
1975, the City of.Vancouver determined that chromium in FHC's waste water was upsetting
the operation of its new secondary treatment system. FHC was directed by Vancouver and
the Washington Department of Ecology (Ecology) to cease discharge to the sewer system
until a treatment system was installed to remove chromium from their waste. At that
time, FHC began discharge of their untreated plating wastes to a drywell behind the
facility. In 1976, FHC was given a waste water disposal permit for discharge to the
drywell by Ecology. The permit also contained a schedule for completion of a treatment
system for their wastes. In 1982, Ecology found FHC in violation of the Dangerous Waste
Act for the illegal disposal for hazardous wastes. In 1983, Ecology ordered FHC to stop
discharge of chromium plating wastes to the drywell. Ecology discovered chromium in the
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Frontier Hard Chrome, WA
First Remedial Action
Contaminated Media: soil
chromium
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
83
22. Pric«
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Department of Commerce
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17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
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i.PO : 1983 0 - 381-526 (3393) OPTIONAL FORM 272 BACK (4-77)
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EPA/ROD/R10-88/012
Frontier Hard Chrome, WA
First Remedial Action
16. ABSTRACT (continued)
ground water at more than twice the drinking water standards and in soil and FHC
building structures.
The selected remedial action for this site includes: excavation of 7,400 yd^ of
chromium contaminated soils exceeding 550 mg/kg with onsite treatment using chemical
stabilization followed by onsite disposal of treatment residuals and placement of a
final site cover; and demolition of the FHC building. The estimated present worth cost
for this remedial action is $2,000,000.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. REGION 10
' SEATTLE, WASHINGTON 98101
DEC 2 3 1987
EftTi? HU-113
MEMORANDUM
SUBJECT: Record of Decision
Frontier Hard Chrome
FROM: Charles E. Findley, Director/ (j
Hazardous Waste Division I /
TO: Robie G. Russell
Regional Administrator
Attached is tne Record of Decision (ROD) for the Frontier Hard Chrome
Superfund site in Vancouver, Washington. The authority to sign this ROD was
delegated to the Regional Administrator on November 12, 1987.
Frontier Hard r^ome is a now-defunct chrome plating facility. During a
portion of their op itions fror.i Iy70 to 1983, chrome plating waste was
disposed of into a dry well, causing contamination of the groundwater and soil
on and near the site.
This ROD is for the source control/soils operable unit of the remedial
action. The proposal is for the stabilization of chromium in the soils,
placement back on site, and final capping. The groundwater operable unit ROD
will be developed when the final groundwater remedial action is decided.
A briefing on Frontier Hard Chrome is scheduled for December 23 at 10:00.
Attachment
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE
Frontier Hard Chrome
Clark County
Vancouver, Washington
PURPOSE
This decision document presents the selected remedy for the
soils/source control operable unit for this site. The remedy was
selected in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA),42 U.S.C. Section 9601 et seq. and to the extent
practicable, the National Contingency Plan, 40 CFR Part 300.
BASIS FOR DECISION
This decision is based upon the Administrative Record for
the site. The record contains, but is not limited to, the
following documents. The documents describe the site, the
actions taken at the site by the United States and the State olBP
Washington, the evaluation of remedial alternatives for the site
and the concerns of the affected community:
Remedial Investigation Report for Frontier Hard Chrome,
Volumes 1 and 2, August,1987
Feasibility Study Report for Frontier Hard Chrome,
Volumes 1 and 2, October, 1987
Summary of Remedial Alternative Selection
Community Relations Responsiveness Summary
Staff summaries and briefing documents
A complete list of documents contained in the Administrative
Record is included in this Record of Decision.
DESCRIPTION OF THE SELECTED REMEDY
This Record of Decision addresses an operable unit of the
Frontier Hard Chrome site. The operable unit is the control oJL.
chromium contaminated soils and structures at the site. This!
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operable unit does not address the remediation of contaminated
groundwater. This will be addressed by a separate decision
document..
The remedy selected consists of the chemical stabilization
of chromium contaminated soils at the Frontier Hard Chrome site.
This treatment alternative will reduce the mobility and toxicity
of the contamination at the site and will prevent further
contamination of the groundwater. This alternative will protect
public health by preventing the direct contact between the public
and the contamination found at the site.
Specific aspects of the remedy include: the excavation of
chromium contaminated soils; on site treatment of the excavated
materials by chemical stabilization; and replacement of the
treated materials. Implementation of the action will require
demolition of the building on the site. A final cover will be
placed over the site to further prevent leaching of chromium from
the soils and to control surface water run-off from
precipitation.
DECLARATION
The selected remedy is protective of human health and the'
environment, attains federal and state requirements that are
applicable or relevant and appropriate and is cost effective.
This remedy satisfies the preference for treatment that reduces
toxicity and mobility as a principal element. It is determined
that this remedy utilizes permanent solutions and alternative
treatment technologies to the extent possible.
The State of Washington was consulted and has concurred in
the selected remedy.
Date . Robie G. Russell
Regional Administrator
Environmental Protection Agency
Region 10
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SUMMARY OF REMEDIAL ALTERNATIVES
- Site Description
The Frontier Hard Chrome (FHC) site is located in the
southwestern part of the State of Washington, in the City of
Vancouver, Washington. FHC is in an industrial area of the city
directly across the Columbia River from the City of Portland,
Oregon. (See Figure 1)
The site is approximately one half mile from the Columbia
River and covers about one half acre. The area is within the
floodplain and has been extensively filled. The groundwater
table is within twenty feet of the ground surface and is affected
by the stage height of the river. The groundwater is used as the
drinking water supply for the City of Vancouver which has two
well fields within one mile of the site. (See Figure 2,3)
Site History
In approximately 1955, the site was filled with hydraulic
dredge material and construction rubble. The site has been-
primarily occupied by two businesses, both engaged in the chrome
plating business. Pioneer Plating operated at the site from 1958
to 1970. The site was then occupied by FHC until 1983. The
property has been leased to various other businesses since 1983,
During the operation of Pioneer and the initial operation
FHC, chromium plating wastes were discharged to the sanitary
sewer system. In 1975, the City of Vancouver determined that the
chromium in the wastewater from FHC was upsetting the operation
of its new secondary treatment system. FHC was directed by the
City and the Washington Department of Ecology (Ecology) to cease
discharge to the sewer system until a treatment system was
installed to remove chromium from their waste. At that time, FHC
began discharge of their untreated plating wastes to a drywell
behind the facility.
FHC was given a wastewater disposal permit for discharge to
the drywell in 1976 by Ecology. The permit also contained a
schedule for the installation of a treatment system for their
wastes. Between 1976 and 1981, several extensions of the permit
and schedule were granted as the deadlines were passed without
compliance.
In 1982, Ecology found FHC in violation of the Dangerous
Waste Act for the illegal disposal of hazardous wastes. Ecology
also discovered that the groundwater in the area was contaminated
with chromium at more than twice the drinking water standard.
FHC's wastewater permit was again modified with a new compliance
date. FHC again did not comply with the permit requirements for
economic reasons and in December, 1982, the FHC site was propc
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Vancouver
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. , Well Station
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E. Evergreen Blvd.
PROJECT SITE
LOCATION
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Well Station *4
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Frontier Hard Chrome Site Location
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for inclusion on the National Priority List under the
Comprehensive Environmental Response, Compensation and Liability
Act, or Superfund. The listing was finalized in September, 1983.
In 1983, Ecology ordered FHC to stop discharge of chromium'
plating wastes to the drywell. FHC was also required to prepare
a plan for the investigation of the groundwater. FHC closed down
all operations at the site. The company has not undertaken the
investigation.
In March, 1983, the EPA and Ecology signed a Cooperative
Agreement which gave the Ecology the lead in investigating the
FHC site under Superfund. Ecology began that investigation in
Fall, 1984. T*e Remedial Investigation (RI) led to a Feasibility
Study to determine the cost effective remedial action for the FHC
site. The Feasibility Study (FS) was completed in October, 1987.
Enforcement History
The regulatory and enforcement actions at the FHC site have
centered around the owners and operators of FHC, Walter Neth and
Otto Neth. The Neths purchased the property in 1955 and operated
a chrome plating business there. Under Superfund, they are
responsible parties and liable for the cleanup of the site. Past
negotiations between the responsible parties, EPA and Ecology
have not been productive. Since 1976, FHC has not complied fully
with any agency orders.
- Pioneer Plating, another operator of the facility, is
another potentially responsible party. The company went out of
business in 1974. No further information is available on Pioneer
Plating. Current operators of the facility may also be
potentially responsible parties.
Remedial Investigation
The Remedial Investigation (RI) process was begun in the
Fall of 1984. At that time Ecology selected a contractor to
perform the investigation. The actual fieldwork for the
investigation was started about one year later. The delay in
initiating the RI resulted from difficulties in project funding,
contracting, and obtaining access to the site. The RI primarily
involved the installation of groundwater wells to establish the
extent of contamination in the aquifer and borings on site to
determine the levels of chromium in the soil.
The initial results of the RI determined that there were
high concentrations of chromium in the groundwater beneath the
site more than 2000 tir.es the drinking water standard of 0.05
parts per million (ppr.: . The RI further determined that the
chromium had spread well beyond the boundaries of the site to
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southwest. There are several drinking water wells in the vicinity
of FHC, including wells used by the City of Vancouver. However,
the investigation found that these city drinking water wells were
not affected by the contamination from the FHC site. The Rl
confirmed that the wells were also not within the direction of
groundwater flow and likely would not become contaminated. The
surface and sub-surface soil of the site was also found to be
contaminated with elevated levels of chromium.
In mid-1986, it was determined that additional work was
necessary to fully characterize the site. The additional work
was needed because the aquifer beneath the facility was much more
complicated than anticipated. The initial investigation found
that the groundwater beneath the facility existed in two zones
labeled A and B, but that there was some hydraulic connection
between the two.
The initial RI also found that contamination from organic
solvents was present at the site but that their source could not
be determined from the existing information. The source appeared
to be independent of the chromium source.
Phase 2 of the investigation was begun in January 1987. The
work consisted primarily of additional groundwater monitoring
wells and comprehensive surface soil sampling of the FHC site;
The investigation was completed in the summer of 1987. It
confirmed that the groundwater in the two zones beneath the
facility was contaminated. The upper "A" zone is a sand and
gravel layer about twenty feet below surface elevation. It is
about ten to fifteen feet thick and sits upon a confining layer
of clay. The clay is about 35 feet below ground at the site and
is not continuous throughout the area. The clay layer is
generally less than five feet in thickness. Hydraulic connection
exists between the "A" and "B" zones but there are no distinct
vertical gradients. The drywell does not penetrate deeply into
the "A" aquifer or reach the clay. The "B" layer extends below
the clay to a depth of about 80 to 100 feet. (See Figure 4)
The upper "A" has higher concentrations of chromium
contamination than the "B" especially in the area of the drywell
where the contamination was introduced into the groundwater. The
level of chromium in the "A" layer groundwater exceeded 10 ppm,
total chromium. Approximately 90% of the chromium in the
groundwater was found to be hexavalent chromium. The
contamination in the "A" had spread off site. Movement of the
groundwater in the "A" is approximately 0.5 feet per day to the
south-southwest. (See Figure 5)
The "B" is also made up of sands and gravel and was found to
be more permeable than the upper aquifer. The groundwater
velocity in this layer is approximately 2.25 feet per day to the
south-southwest. The contamination of the "B" extends much
further than in the "A" and has reached the Columbia River. The
levels of chromium were less in the "B" aquifer. The highest
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travel A Monitoring Weil
Level B Monitoring Well
Ground Surface
0 l
5 H
VAOOSE ZONE: Fill
Localized Perch
Ground Water
<7
Aquifer Water Level
UPPSB
Low PermeaOHty L-ans: Silty Sandy Gravel
UPPER
ALLUVIAL ^
LOWER AQU1TARD :
Silt
Moderate to High Permeability: Sandy Gravels
LOWER ZONE
ALLUVIAL AQUIFER
FIGURE
Conceptusy^)
of Site Area Hydros!!
Frontier Hard C
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500 feet
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Inorganic Water Analysis
Level A Monitoring Wells
Hexavalent Chromium
Frontier Hard Chrome
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concentrations of chromium were in the range of 0.3 ppm. Both of
the aquifers were still above the drinking water standard of 0.05
ppm. (See Figure 6)
Organic contamination was confirmed in both layers. The
contamination is highest to the north (upstream) of FHC. It is
still not possible to identify the exact source of this
contamination. Lower levels of the organics are found in the
soils beneath the building on site and near the drywell. The
organics identified include trichloroethylene and
perchloroethylene. These were found in the groundwater at
concentrations on the order of 40 parts per billion but also as
high as 5 parts per million.
Chromium was found throughout the site in the surface and
sub-surface soils. This includes adjacent properties where
process cooling water had been discharged by FHC and where
wastewater had migrated through the subsurface soil from the dry
well. Levels of chromium in the soil range up to 17,000 ppm,
total chromium. Most of the chromium was found to be trivalent.
The most contaminated soils are in the area of the drywell. The
depth of the most contaminated soils ranges up to 20 feet below
grade. (Figure 7)
Surface water (in the form of standing puddles) on the site and
on adjacent properties was sampled. The levels of chromium there are
in the range of 0.01 to 0.9 ppm. The Columbia River itself was not
sampled but discharge to the river was modeled. The model showed that
no measurable increase of chromium would be detected in the river J^pr
the impact of the groundwater.
Air monitoring was conducted inside the FHC building during the
investigation. Chromium was found in the air. The levels in the
building were below the standard of 25 micrograms per cubic meter
established for occupational settings. Chromium was also found on th«
walls and surfaces of the FHC building where the plating operation
took place. The highest level found was 2300 micrograms per 50 squar«
centimeters.
Soil/Source Control Operable Unit
During the FS, EPA and Ecology agreed that some form of
soil/source control would be necessary. However, further
evaluation of the necessity and extent of a groundwater remedial
action was required. By agreement between the EPA and Ecology,
consideration of the FHC remedial action was divided into two
segments or operable units. The units consist of the soils at
the FHC site and the groundwater aquifer below. Though the units
are somewhat interdependent, the soil/source control unit can
proceed without consideration of the final selected alternative
for the groundwater.
This Record of Decision (ROD) discusses the soil/ source
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FIGUPZ 6
Inorganic Water Analysis
Level B Monitoring Wells Hexavalent Chromium
Frontier Hard Chrome
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control operable unit only. A groundwater ROD will be signed when
the EPA and Ecology have more thoroughly considered the options.
Feasibility Study
Endangerment Assessment
The endangerment assessment was conducted to evaluate the
risk to public health posed by the site and to assist in
determining the proper level of remedial response. The
endangerment assessment examines the particular hazardous
substances present at the site, the amounts of the substances
which are found, the routes of exposure or how people would
encounter those substances, and the levels of those substances
which are known to cause harm. The determination of this level
of risk provides an additional basis for the selection of a
remedial action.
Chromium is the hazardous substance of primary concern at the FHC
site. Chromium is present in tv forms, designated trivalent chromium
and hexavalent chromium. Of the two, hexavalent chromium is the more
hazardous. Hexavalent chromium is a potential carcinogen when
inhaled. The level of allowable chromium in the air is 25 micrograms
per cubic meter based upon an occupational exposure of eight hours per
day. For the protection of public health, the Maximum Contaminant
Level for chromium is set at 0.05 ppm in drinking water. Chromium was
found on the walls of the building but there is no standard method for
evaluating the risk posed by chromium on surfaces..
Nickel and lead are also found,at the facility. The
contaminant levels of these substances is much less than the
chromium. Remedial actions designed to mitigate the hazard from
the chromium would also deal with the lead and nickel.
The risk from exposure to inorganic contaminants from
direct contact and inhalation of airborne dust was investigated.
Exposure was measured using personal air monitoring samples
obtained from on site workers. Long term exposure was modeled
based on surface soil contaminant concentrations. It was
determined that the levels of exposure were well below the amount
allowed in standards for occupational settings. Chromium and
nickel at the site presently do not exceed the 10~7 cancer risk
for long term airborne exposures. Lead would also present
minimal risk at the site in that the levels do not exceed and are
not expected to exceed the National Ambient Air Quality
Standards. Though the levels of exposure were not zero, the
additional risk imposed by the dust was negligible. These
exposure estimates do not account for potentially higher short
term exposures to dust due to vehicular traffic and wind. This
increased risk was not quantified.
Organic solvents on the site pose some cancer risk through
the contamination of the groundwater. At the site, the excess
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cancer risk associated with the ingestion of water containing
solvents is approximately 10~2. In areas that are not within the
contamination plume, the estimated level of risk was found to be
less tharrlO , and zero at the City of Vancouver wells.
Surface water was examined near the site. Standing water in
puddles were sampled for the presence of chromium. Chromium was
found but at levels below the water quality criteria. Risk from
exposure to the surface water was considered minimal. Any
remedial action implemented which would address the soil
contamination would reduce the contamination of the surface water
on the site, further reducing any risk from this exposure. Risk
due to contamination of the Columbia River was modeled and found
to be negligible as the dilution of the river would not allow any
measurable increase of chromium.
The greatest risk presented by the site is through the
contamination of the groundwater and the drinking water supply
with chromium. The aquifer is contaminated in excess of the
drinking water standards. The groundwater in the area generally
is used for drinking water but existing drinking water wells are
not currently affected nor is it expected that they will be in
the future. The risk from drinking contaminated water is based
on the potential use of the water from the contaminated portion
of the aquifer. This threat to the potential drinking water
supply is expected to remain for over three hundred years if no
actions are taken to remedy the site.
Alternatives Assessment
The alternatives evaluated in the FS are directed at the
protection of public health and the environment. This ROD is
specifically to address the hazards associated with the soils on
the site. A ROD which addresses groundwater at the FHC site will
be issued as a separate document. This Source Control/Soils ROD
will deal with groundwater only in that the soils of the site
present a continuing source of chroaium to the groundwater and
presents further threat to the groundwater. This direct threat to
the environment would also be a threat to public health if the
contaminated portion of the aquifer is accessed for drinking
water. This ROD will not deal with the actual harm which the
groundwater represents. The soils remedial action will therefore
be evaluated on the ability of the alternatives to provide
protection from direct or indirect exposure to the soil of the
site and protection of the groundwater by eliminating the release
of chromium.
The process of the FS is placed into several phases. The
initial phase is the identification of potential remedial
measures and technologies. These alternatives are screened for
their site specific effectiveness and capabilities. The
alternatives which survive the screening and would be potentially
usable at this site are further evaluated with a detailed
examination of their effectiveness, implementability and the
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costs involved in implementation.
Under Superfund, the assessment of the alternatives must
take into-account the protection of public health and the
environment, short term and long term effectiveness, long term
maintenance costs and the uncertainty and risk associated with
land disposal.
Criteria have been established in policy which are used to
evaluate alternatives to insure that the process meets the intent
of the law. The criteria includes a preference for alternatives
which result in the permanent decrease in the persistence,
mobility, toxicity and volume of the hazardous material. The
long term and short term effectiveness of the remedial action
must also be considered. The assessment must consider the
technical implementability and community and state acceptance of
the alternative. The remedy selected must be protective of public
health and the environment. The remedy must meet or exceed the
applicable or relevant and appropriate state and federal
requirements and must be cost effective, that is, the least cost
alternative meeting the remedial objectives.
The range of potential alternatives initially considered is
shown in Table 1. Alternatives which did not pass the initial
screening were eliminated from further consideration. Specific
treatment technologies within the general alternative categories
shown in Table 1 were considered and evaluated.
The specific alternatives which passed the initial screening
include: soil excavation nd treatment; excavation and soil
stabilization; excavation and disposal at an offsite location;
excavation and disposal on site; removal of surface soils and
capping only (with offsite disposal); and no further action. The
no-action alternative must be evaluated throughout the
alternatives assessment. The alternatives and their ratings
against the various criteria appear in Table 2.
Selection of Remedy
The above evaluation identified several alternatives. The
alternatives meet the objective and criteria for selection to
varying degrees. The specific goals of the remedial action would
be the protection of public health by preventing the direct
exposure to chromium contaminated soils and dusts and the
protection of the groundwater by controlling the source of
contamination.
The no action alternative was the least cost alternative but
would not remove any of the chromium source to the groundwater
and would not mitigate the risk from direct contact with the
chromium. This alternative would not reduce the toxicity or
mobility of the contaminants nor would it reduce any threat to
public health or the environment. This alternative would include
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labte 1
Potential KernediI A I ternatives
Alternative
Ho ac t i on
Capping
Surface soil removal
Description
Monitoring of site only
Placing an impermeable cap over the site to
reduce contaminant leaching, direct exposure
to contaminated soils
Analys i s
Retained for consideration due)
to regulatory requirements
Retained for consideration
Soil H «. m it v ,i I / 0 i :. , .sal
treatment of soils (u bind t o n t a m i n a n t lu
prevent leaching into yioundwuter and . i: i (
exposure to contaminated soils
Excavation anri removal ot contaminated soils
with the disposal of the materials either
on-site or off-site in a secure landfill
(t e t u i ii i;
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Alt erna t i ves
No Action
Table 2
Summary of Remedial Alternatives
Capping RemovaI/Oisposa I RemovaI/treatment Stabilization
Description
no further action
moni tor i ng only
places impermeable
cap over site,
Iimi ted soiI
remove I
excavates contaminated onsite treatment
soil Mith land of soils ( soil
disposal off-site washing)
ons i te
stabilization of
soils
Cost ($1000)
P resent wor t h
238
405
3.500
7.500
2,000
Protect i on of
Public Health t
Env i ronment
a I IOMS direct
contact w/
contamination
allows further
GU contamination
prevent s publi c
contact w/ soils
a I Iows further GU
contami nat i on
Alternatives protect public health by preventing
the direct contact with chromium contaminated soils
Chromium is prevented from entering the groundwater
eliminating the source of contamination
ARARs
no attempt to
meet regulat ions
wouId not
RCRA
meet
off site di sposeI
would comply w/
RCRA
Placement of treated soils and
alternate closure would comply with
RCRA as appropriate standard
Short term
effectiveness
not effective
Alternatives would reduce the risk to the public from exposure to the soils
would not be
effective in GU
sour ce cont roI
All alternatives would eliminate immediate source
of groundwater contamination
ac t i on wouId be
complet ed within
three months
remed i a I ac t i on
would be completed
within three months
would take two
years to complet e
remed i a I action
remed i a I ac t i on
would be completed
within six mon t h s
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Table 2
(continued)
Alternatives
Ho Action
Cappi ng
Removal/Disposal
Soil Washing
Stabilization
Long
term
ef f ec t i veness
does noth i ng to
protect in the I ong
term, GU monitoring
onl y
does not total)
eliminate GU
cont am i nat i on,
cap ef f i c i ency
uould decline
over t i me
major source of
cont ami na t i on
to GU removed
f rom site
permanent I y
effectively
removes
contami nat i on
f rom site
long term
effect!venes s
of process not
well known, has
proved effective
i n apppIi c a t i on
Reduc t i on o f
t ox i c i t y,
mob iIi t y,
per s i s t enc e
Alternatives do not provide for the reduction of toxicity
mobility or persistence.
Treatment alternatives reduce the
mobility, toxicity of the
contaminants, alternatives would
alter the character of the
hazardous constituents
Technical
feasibility,
ImplementabiIi ty
Actions involve known technology and
are proven and easily implemented
Physical/chemical
characteristics of
metals are known.
Site specific
feasibility to be
tested, Large
volume of material
requires extended
time for action.
associated treatment
syst ems
S t abiIi za t i on
effective in other
locations, site
specific feas. to
be tested
Commun i ty,
State
Acceptance
These alternatives proposed at public
meeting by citizens as the only actions
necessary. Rejected as options by local
government
These alternatives not recommended by the public which
sees them as excessive, costly and unnecessary
recommended by the
state as most cost
effective source
control ernative
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continued monitoring to determine the continuing extent of
contamination. This alternative is not favored by state or local
governmental agencies but has been proposed by citizens attending
public meetings.
Capping would be the placement of an impermeable surface
over the site to prevent direct contact with the contaminated
soils. This alternative is closely linked to the limited removal
of contaminated soils at the surface only and are considered
together as the actions utilize the same approach to
contamination at the site. The cap might consist of asphalt or
concrete paving or could consist of a coating which would seal
the surface of the site. A cap would prevent the infiltration of
precipitation through the soil column which would reduce the
contamination source to the groundwater. The alternative would
not be as effective or reliable as other alternatives at removing
the source of groundwater contamination. This is because a large
source of chromium to the groundwater is in the clay soils which
are located in the saturated zone. Also, the effectiveness of
the cap would deteriorate over time. Capping only would not meet
the statutory preference for alternatives which would reduce the
mobility or toxicity of the hazardous substance. Capping the
site is an easily implemented and relatively low cost option.
This option is favored by citizens who have attended the public
meetings but is not favored by governmental agencies. This
alternative, and all subsequent alternatives, include as part of
the action long term monitoring of groundwater conditions.
Removal of the chromium contaminated subsurface soil from
the site with disposal off site was evaluated. This alternative
would effectively meet the direct contact goal and would remove
the source of groundwater contamination, however, this
alternative does not meet the criteria established which state
that preference should be given to alternatives that utilize
treatment for the reduction of toxicity and mobility of the
contaminants and do not rely upon land disposal. This would
apply to on-site as well as off-site disposal. This alternative
could be implemented within six months.
The soil treatment alternative would remove the chromium from
the surface and subsurface soil by excavation and chemical
treatment. Contaminated soils would be excavated and placed in a
treatment unit. The treatment process would remove the chromium by
washing it from the soil. The treated soil would then be placed back
on site. The chromium removed from the soil would require further
treatment to reduce the toxicity prior to disposal. The site
would then be capped. This alternative would both reduce the
direct contact hazard to public health and remove the source of
groundwater contamination. This alternative would also be
responsive to the statutory preferences for treatment
alternatives which provide a permanent response action. The soil
treatment would require about two years to implement following
design. The alternative would also require a system for treating
the contaminated solutions which would result from the soil washing.
Soil treatment is a relatively high cost option but would
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meet concerns for the mitigation of risk presented by the
chromium.
The "final alternative evaluated was soil stabilization, r
would utilize a chemical process which would transform the
contaminated surface and sub-surface soils into a mass which
would bind the chromium in the soil. As with the soil treatment
alternative, the soils would be excavated and treated on site.
The soil would be excavated and then mixed with chemicals to
immobilize the chromium and then be placed back on the site. The
site would finally be covered with an impermeable layer to assist
in the control of surface run-off from precipitation.
Stabilization would remove the threat to the groundwater and to
direct contact with the contaminated soils. The alternative
could be completed within 6 months not including testing and
design. The process would require testing during the design
process to insure the site specific feasibility of the process.
Soil stabilization meets the preference for treatment
alternatives and the permanent reduction of the toxicity and
mobility of the hazardous substances.
The soil stabilization alternative was selected as the
remedial action best meeting all of the criteria. The
stabilization was favored over the soil treatment alternative for
reasons including lower cost. The stabilization could alsa be
implemented in a much shorter time and would minimize the amount
of support activity required for remedial action, including
treatment of contaminated water resulting from the treatment
process. The site specific reliability of the stabilization la
somewhat less than the soil treatment in that the stabilizatioi"
is a more recently developed technique. The process of
stabilization though has proven effective at similar sites.
Summary of the Remedial Action
The treatment system would use a chemical binding agent such
as lime, polymers, fly ash or other, possibly proprietary
mixtures, to chemically bind the chromium to the soil. The
treatment would take place on the site. Surface and sub-surface
soil exceeding a concentration of 550 ppm chromium would be
excavated and put through the process. The stabilized soil would
then be placed back in the excavation. The total volume of soil
to be treated is estimated at 7400 cubic yards. The volume of
soil is expected to increase by approximately 20% due to the
treatment process. Implementation of the remedial action will
require the demolition of the building on the site. (Figure 8)
Only those soils in excess of 550 ppm are to be treated.
There is presently no standard which states a specific criteria
for allowable chromium in the soil. The level of 550 ppm at this
site was selected on the basis of tests performed at FHC. It was
determined that soils with a concentration of less than 550 ppj
would not release chromium to the groundwater at levels above)
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IL STABLJlA'nON
SUBSURFACE SOIL /
TO BE REMOVED
REMOVE AND STABILIZE THE SURFACE
AND SUBSURFACE SOILS (SS)
FRONTIER HARD CHROME
FEASIBILITY STUDY
FIGUPE 8
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drinking water standard of 0.05 ppm. Therefore the untreated
soils would not act as a source of contamination to the
groundwater. Additional testing will be conducted in the
Remedial Design process to refine the threshold level of chromium
which would be treated. '
Additionally, the site would be covered with a impermeable
cap which would minimize the amount of precipitation entering the
soil. This would further limit the amount of any leaching of
chromium which would occur. Also, risk from exposure to soils
and dust could be further lowered by reducing the levels of
chromium in the soils.
The selected alternative of soil stabilization complies with
requirements that the remedial action be protective of public
health and the environment, reduce the mobility and toxicity of
the hazardous substances and not rely on land disposal of
hazardous substances. Stabilization is also a permanent remedy
which does not require future actions other than monitoring of
the site and maintenance of the cover.
The alternative meets the preference for on-site treatment.
The action would be solely confined to the site.
Soil stabilization is the cost effective alternative meeting
the criteria and objectives for the site.
Compliance with Regulations ~
Superfund requires that all Applicable or Relevant and
Appropriate requirements (ARARs) be achieved at the site. Among
the potential ARARs for this site would be the drinking water
standards for contaminated groundwater beneath the site.
However, the soil stabilization remedy does not directly address
cleanup of the groundwater (though it does remove the source of
contamination.) Therefore, drinking water requirements are not
ARARs for the purposes of this ROD. As discussed, the
stabilization of the soils is an operable unit of the total
remedial action. Therefore, this Record of Decision for the
soils still complies with the law. The ROD which addresses the
groundwater remedial action will address the drinking water
standards as ARARs directly.
The implementation of this remedial action would comply with
all ARARS. There are no standards which would dictate a criteria
for chromium in the soil. The site specific determination made
at the FHC site was to treat soils in excess of 550 ppm chromium.
This determination was made relative to the drinking water
standard which would be applicable in the cleanup of groundwater
beneath the site. This level would also minimize direct contact
or exposure to chromium contamination at levels which could
possibly cause harm.
10
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Washington State has regulations dealing with the disposal
of solid and dangerous wastes. The stabilized soil would not be
classified as a dangerous waste as defined in those regulations
and would~not be subject to those regulations. The requirements
for the disposal of dangerous wastes under these regulations,
however would be appropriate standards. The disposal of the
stabilized soils as a solid waste would be applicable. All of
these requirements would be met by the selected alternative.
The Resource Conservation and Recovery Act, as amended by
the Hazardous and Solid Waste Amendments, (RCRA) is not
specifically applicable to the FHC site or the remedial action
(though it is relevant and appropriate.) The contaminated soils
of the site are not subject to regulation under 40 CFR Section
261 of RCRA. The stabilized soils would also not be a
characteristic waste (EP toxic) or listed waste under the
definitions in RCRA. Further, because of the nature of the
material as indicated, placement of the treated soils back on the
site would not create a new disposal unit under RCRA.
Placement of the stabilized soils on the site would not be
subject to the land disposal ban under RCRA. The rules do not
presently regulate materials which would be involved in this
operable unit of the remedial action. As regulations are
developed which would address directly the disposal of chromium
contaminated waste and debris, those regulations would be
relevant and appropriate to this remedial action.
RCRA is relevant and appropriate as a standard in the
requirements for the closure and long term care of the facility.
This operable unit of the remedial action at the FHC site would
meet the substantive requirements for an "alternate closure11
under proposed rules governing closure found in 40 CFR Section
264.310 Of RCRA.
Community Relations
There have been two public meetings for the purposes of
informing the local population about the activities at the site.
The initial meeting was held in 1984 at the commencement of the
RI. The second meeting was held on November 4, 1987 to discuss
the FS and the proposed alternatives.
Contamination from this site has resulted in the
contamination of the drinking water aquifer utilized in this
community. The present drinking water supply is not affected
though the potential industrial and commercial development of the
area may be. The public interest at this site has been limited.
The attendance at the meetings has been sparse. The
meetings were attended by the responsible parties and by people
directly associated with the operation of FHC. Adjacent property
owners were also in attendance at the meetings. A transcript of
the November public meeting was made and a responsiveness summary
11
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prepared. The responsiveness summary is attached.
Media interest in the site has been limited. The local
media was-in attendance at the November meeting. Much of the
media interest centered around the cost of the work which has
been conducted to date and the future costs.
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FRONTIER HARD CHROME SITE
RESPONSIVENESS SUMMARY
This appendix summarizes the major issues raised by the public and provides
agency responses to those issues. It is included as a part of this
decision document in accordance *ith the requirements of the National Oil
and Hazardous Substances Pollu: .n Contingency Plan, 40 CFR Part 300,
Section 67.
The responsiveness summary is divided into the following sections:
Section 1.0 Overview. This section discusses the preferred soil/source
control alternative for corrective action, and general
public reaction to this alternative.
Sect ion 2.0
Section 3.0
Section 4.0
Background on Community Involvement and Concerns. This
section provides a brief history of community Interest and
concerns regarding site activities.
Summary of Major Comments Received During the Public
Comment Period and Response to the Comments. Both verbal
and written comments are categorized by relevant topics.
EPA's responses to these major comments are also provided.
Remaining Concerns. This section describes remaining
community concerns that EPA should consider in planning the
cleanup activities at the site.
1.0 Overview.
The Washington atate Department of Ecology (Ecology), as lead agency
under a cooperative agreement with the U.S. Environmental Protection
Agency (EPA) conducted the Remedial Investigation and Feasibility
Study (RI/FS) for the Frontier Hard Chrome (Frontier) Site in Vancouver,
Washington. The site was the location of a chrome plating operation
from 1958 until 1983. During the period of 1976 to 1983 process
waste water containing chromium and other metals was discharged to an
on-s i te dry well.
During the FS process for evaluating potential site cleanup alter-
natives, the EPA and Ecology agreed that some form of soil/source
control would be necessary. However, they decided that further
evaluation of the need and extent of a ground water remedial action
is required. In order to allow initial cleanup to move forward, the
agencies agreed to split the remedial action selection process into
two phases, or operable units: a soil/source control remedy is
selected in this Record of Decision (ROD) document, and an approp-
riate action for ground water will be addressed in a subsequent ROD.
Potential cleanup alternatives for both soil/source control and
ground water were presented in the Feasibility Study, proposed plan,
-------
and public meeting. Ecology solicited and received public comment
regarding the entire range of alternatives. However, since this ROD
only addresses the soil/source control alternative selection, this
Responsiveness Summary will only address that portion of public
comment pertaining to soil/source control options. A subsequent ROD
and Responsiveness Summary will address the ground water cleanup
options and public comment regarding those.
The soil/source control cleanup alternative chosen in this ROD would
remove surface and subsurface soil exceeding 550 ug/g chromium. The
soil would be treated with a stabilization material, and be replaced
on-site. The existing on-site structures would be removed and
disposed in accordance witn applicable state and federal regulations.
Institutional controls would be necessary to restrict access to
ground water within the contaminated plume and to protect the integ-
rity of stabilized soils. This alternative is described in more
detail in Chapter 6 of the Feasibility Study and in the text of this
ROD .
This Responsiveness Summary describes concerns which the community
has expressed in regard to the recommended soil/source control
cleanup alternative, the purpose of the public participation process,
and health issues. The most vocal and interested individuals, the
site owners and adjacent businesses, have felt that the site studfes
have been too costly ar- time consuming and that the site does not
present environmental or health impacts of enough significance to
warrant much remedial action. On the other hand, the City of Va.ncouver
public officials acknowledge that cleanup action of the magnitude
recommended by this decision document is necessary.
2.0 Background on Community Involvement and Concerns.
Throughout the Frontier studies, Ecology has conducted a community
relations program. This program involved identifying interested
parties and public concerns, and conducting activities to meet the
public's information needs and address concerns.
Interested Parties
Ecology and the Vancouver Public Works Department have been involved
with the Frontier site since 1975 when the metals in Frontier's
wastewater were first identified as a problem.
Since that time the news media has covered developments at the site.
This media coverage has included project background, status, budget
and funding, public meetings, and future plans.
Other than the news redia attention, there has been little public
concern shown. Part-«s who have expressed some interest or concern
include: respc-'sib.? . o c a I public agencies--such as the Vancouver
Department of Public -:-ts and the Southwest Washington Health
District; owners of -e-g-Doring wells--such as the Washington School
for the Deaf; n e i 9 n c : - g business owners and those who were directly^
involved with past : ijrrent ownership or operation of the Frontier^
-------
site.
Publi c Concerns
Since studies began at the Frontier site, the following concerns have
been raised.
o Chemical contamination of drinking uater sources from: chromium,
lead, nickel and chlorinated solvents that have been detected in
soil and water at Frontier and can affect human health. The
original designation of Frontier as a National Priority Site was
primarily a result of agency concern over the potential of
chromium contaminated ground water originating from the Frontier
site to contaminate Vancouver Well Fields 1 and 4.
AGENCY RESPONSE: Thirty-seven ground water monitoring wells
were installed during the Remedial Investigation (RI). The
direction of ground water flow and I ocation-specific changes in
ground water contaminant levels over time were determined from
periodic monitoring activities at each well location. Aquifer
pump testing was also conducted during the RI and all these data
were used to model the long-term migration of ground water
contamination. These studies have shown that it is very unlikely
that the site contaminants would impact existing drinking water
wells.
o Soil Contamination: Exposure to chromium and other heavy metals
could occur through direct contact with contaminated dust or
soil.
AGENCY RESPONSE: Sampling and analysis of surface and subsurface
soils was conducted to determine the distribution and levels of
soil contamination, and to evaluate potential health impacts
caused by the soil contamination.
o Project Expenses and Schedule: Vancouver public officials and
Vancouver area newspaper articles have focused on the expenses
of the project. They have suggested that the time a-- money
spent studying the problem could have been spent on eanup.
AGENCY RESPONSE: Rationale for the nature and extent of site
studies have been explained to the City officials and the media.
The requirements of the Superfund study process and the complex-
ities of the environmental contamination at the Frontier site
dictated the extent and cost of site studies necessary to
protect public health and the environment.
o Effect on Property Development: Ground water and soil contam-
ination have affected the current use of the site. The proposed
remedial measures will further limit development potential of
the site and probably of neighboring properties because of the
regulatory controls necessary to protect the stabilized soil and
restrict the development of the contaminated ground water. The
area is generally considered a prime location for industrial
deve I opment.
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AGENCY RESPONSE: It is acknowledged that development potential
of the site and property adjoining the contaminated plume may be
limited as a result of the contamination.
o Communicaions: Vancouver officials have expressed concern that
there be . I e a r channels of communication between Ecology and the
City, and that the City be notif;?d of any critical developments
and schedules.
AGENCY RESPONSE: Periodic communication has been maintained
with various City officials throughout the duration of project
activities. A separate briefing was provided to these officials
to describe study results, to discuss alternative plans for
remedial action, to receive comments, and to answer questions.
Community Relations Activities
Ecology prepared the initial Community Relations Plan in 1984. This
plan outlined community concerns, interested parties, and the scheduled
community relations activities. Prior to preparation of the plan,
Ecology interviewed local officials to identify concerns. Information
repositories for project documents were established at the main
branch of the Vancouver Public Li-orary and at the City of Vancouver
Public Works Department.
To explain the Remedial Investigation and the planned field work,
Ecology issued a fact sheet and held a public meeting in October
1984. The fact.sheet was distributed to the mailing list of local
officials and other interested parties. The meeting was announced
through a news release and a public notice. Thirteen citizens,
primarily the Potentially Responsible Parties (PRP's) and Vancouver
city officials attended the meeting.
Throughout the studies, Ecology notified the press at key points in
the project. In August 1987, a revised Community Relations Plan was
prepared for Ecology and the mailing list was updated. In preparing
the plan, four local officials were interviewed.
At completion of the Remedial Investigation and Draft Feasibility
Study, Ecology issued a Proposed Plan summarizing the results of
these studies and presenting the proposed alternatives for 1) con-
trolling the source of contamination and 2) correcting ground water
contamination problems. This proposed plan, as well as a news
release and public notice, also announced the public comment period
and the public meeting of November 4, 1987. This public meeting was
held to present the results of the Remedial Investigation and Feasi-
bility Study, to discuss alternative plans for remedial action, to
answer questions, and to receive written and oral comments. Thirteen
citizens and five news media representatives attended the meeting.
As the project developed, Ecology periodically briefed local officials
regarding project activities. A formal public officials briefing on
the results of the Remedial Investigation and Feasibility Study was
held prior to the public meeting November 4, 1987. The briefing was
-------
attended by about 11 local officials.
3.0 Summary of Najor Comments Received During the Public Comment Period
and Agency Responses to the Comments.
The public comment period occurred from October 29 to November 19,
1987. A transcript of the public meeting proceedings is provided as
Appendix 8 to this decision document. Written comments were received
from the City of Vancouver Public Works Department and are included
as Appendix A.1 to this responsiveness summary.
Comments from the public, (e.g., the site owners, site tenant,
neighboring businesses and City of Vancouver public officials)
obtained during the puo. c comment period are summarized below.
Comments are grouped under the following headings: human health and
environmental concerns, alternative preferences, public participation
process, and general.
In summary, comments from the City of Vancouver Public Works Department
favor the agency recommended alter-native for source/soil control.
The City has also suggested that the subsequent Record of Decision
regarding ground water cleanup should include consideration for a
limited extent of ground water treatment. The site owners, tenant,
and neighboring businesses favor only limited action toward
soil/source control, possibly to cover part of the site surface with'
a paving material and do nothing more. That position is predicated
on the notion that risk to the environment and public health is not
significant enough to warrant much cleanup action, and that residen-
tial development of the area is very unlikely.
Human Health and Environmental Concerns
1) A general issue was raised by the Potentially Responsible
Parties to suggest that any major cleanup actions proposed for
the site are not warranted because impact to the environment or
to public health is not imminent. The health significance of
contaminated soils, ground water, and migration of ground water
contaminants to the Columbia River were questioned.
.AGENCY RESPONSE: Based upon the data and information generated
in the RI, the City of Vancouver Well Fields 1 and 4 are located
upgraditnt from the Frontier Hard Chrome site. There is no
indication that the pumping capacity, drawdown, or extent of any
cone of depression from these two well fields influences the
movement direction of the contaminant plume of Cr»6 emanating
from the FHC site. The studies show that the contaminant plume
does not presently and is not expected in the future to impact
existing drinking water wells. Continued monitoring well
observations in the FHC vicinity will be conducted to ascertain
any changes in contaminant levels or gradient of the ground
water. There is concern however, that there could be serious
implications to public health if drinking water wells were to be
installed within the area of the ground water contaminant plume.
For this reason, certain land use restrictions, or institutional
-------
controls will be defined and applied to restrict access to the
contaminant plume. Additionally, some form of institutional
control(s) may be implemented to ensure that future land use
activities will not interfere with the stability or integrity of
stabilized soils. These institutional controls may be required
regardless of future decisions about ground water cleanup needs.
Contaminated subsurface soils are not expected to cause any
direct public health impacts. High concentrations of chromium
occur in these soils, however and serve as a supply of continual
contamination to the ground water. A response regarding health
concerns per-taining to surface soils is provided in part 2 of
this section. Based upon data and information gathered and
presented in the Rt and FS, -here appears to be no adverse
effects on the public health or on water quality as chromium
contaminated ground water discharges into and is diluted by the
Co Iumb i a River.
However, the agencies jurisdiction to respond with site cleanup
is not predicated solely on actual or demonstrated risk to the
public or the environment. While actual environmental damage
has been documented, we are very fortunate that actual or
current public health risk is insignificant. However, substan-
tial risk would be certain if the contaminated ground water is
used for drinking. We are allowed to conduct a site response-
sol e I y on that potential risk, if necessary.
2) A question was raised by the current site tenant regarding what
if any occupational health risks may be present at the site.
AGENCY RESPONSE: The potential for human health hazard associated'
with inhalation of contaminated surface soils (i.e., dust) were
evaluated in two ways. A limited number of direct measure-merits
were obtained from personal air monitors worn by workers using
the FHC building and site. Direct measurements collected from
workers showed no concen-trations of chromium or nickel over
occupational standards.
Nodeling of air concentrations of chromium, nickel, and lead was
conducted to assess the expected long-term health impact associated
with contamination found at the FHC site. This modeling work
showed that the long-term risk associated with inhalation of
re-suspended contaminated soil at FHC is minimal. The model
could not evaluate the short-term inhalation hazard; however,
based on the direct measurements and long-term modeling con-
ducted, it is not expected that the short term inhalation hazard
is significant.
Alternative Preferences
1) The general tone of the public meeting comments favored the
"no-action" alternative for the site cleanup. The "no-action"
preference for ground water remedy was based primarily on the
feeling that it would be very unlikely for someone to be inter-
-------
ected In installing drinking water well in the contain- i noted
ground water plume since the area could be adequately served by
the City of Vancouver public water system. A specific comment
from the Potentially Responsible Parties suggested preference
for a form of the "SO" or "surface only1* alternative as identi-
fied 1n the Feasibility Study (FS). The comment proposed that
blacktop (i.e., asphalt) could be used to pave the site and
Isolate surface dust.
AGENCY RESPONSE: The contaminated ground water does not currently
impact existing drinking water wells because the wells are
located upgradient of the contaminated plume. However, the
studies conclude that under the "no-action" alternative, serious
health impacts from drinking the contaminated ground water could
occur for 200 to 300 years. At this time we cannot predict the
future public demand of this ground water over the next 300
years. More importantly, the ground water is regulated under
both federal and state laws as a drinking waiter resource because
of its potential use as drinking water.
The surface soil removal alternative (SO) which involves removal
and disposal of the upper 18" of soil contaminated over 550 ppm
Cr; replacement of the soil with clean fill; cleaning and
sealing of the building; and monitoring of ground water was not ~~
selected since it does not eliminate the major portion of soil
contamination which acts as a continued source of chromium to
the ground water. Capping of the site surface with an imper-
meable cap was not evaluated In detail In the FS since an
impermeable cap would not prevent leaching of chromium from
subsurface soils to the ground water. Chromium is present in
these soils at high concentrations, particularly within the
silt/clay layer at a depth of approximately 15 feet. These
soils are in contact with ground water and act as a continual
source of chromium to the ground water.
2) Written comment from the City of Vancouver favored the agency
proposed alternative and also suggested that some degree of
ground water extraction and treatment should be conducted. A
copy of the correspondence is provided as Appendix A.1 to this
Responsiveness Summary.
AGENCY RESPONSE: The soil/source control preferred alternative
as described in the FS report and this decision document is
consistent with the wishes of the City of Vancouver, except that
it does not provide for treatment of the groundwater. A subse-
quent Record of Decision will address the extent of ground water
remedial action needed for this site.
Public Participation Process
1) The Potentially Responsible Parties (PRP's) asked what steps are
involved in the cleanup selection process. It was asked: who
makes the decision, how and when is the decision made, and does
-------
the public really have any influence to the decision?
AGENCY RESPONSE: EPA and Ecology have encouraged the public to
comment on the proposed alternatives for the site by providing a
public comment period and by holding a public meeting. However,
the final decision is to be made by EPA. Although it is an
agency process once the comment period is closed, the decision
must be responsive to pub', ic concerns. Comments from the public
meeting on November 4, 1987 and from the comment period of
October 29 to November 19, 1987 are summarized in this Respon-
siveness Summary. This document is part of the decision-making
process and is an integral part of the Record of Decision to
show how the agencies have responded to public concerns. The
Record of Decision on the soil alternatives Mill be finalized
and available by December 31, 1987, and a separate Record of
Decision on the ground water alternatives will be finalized and
available in spring 1988.
2) A point was made that the community interest in the site is
limited to the site owners, tenants, and nearby businesses. The
public, (i.e., Vancouver residents) were obviously absent from
public meetings about the site and therefore appeared uncon-
cerned .
AGENCY RESPONSE: We acknowledge this comment.
General Issues
1) Strong opinion was voiced by the PRP's that the site should not
have qualified for nomination to the National Priorities List
(NPL). It was felt that information pertaining to the vulnera-
bility of the nearby municipal water supply wells had been
misrepresented and that unfairly influenced the sites' nomina-
tion to the NPL.
AGENCY RESPONSE: The Frontier Hard Chrome site was nominated to
the NPL based upon the potential of a public water supply well
serving greater than 10,000 people of becoming contaminated with
hexavalent chromium. Additionally, the fact that an industrial
supply well showed a concentration of hexavalent chromium (Cr+6)
exceeding the Drinking Water Standard for Cr»6 also was a factor
inMPL nomination.
2) Concern was raised regarding the long-term reliability of the
stabilized soil mixture as identified in the preferred alter-
native.
AGENCY RESPONSE: Several stabilization technologies will be
explored as part of the remedial design process. The long-term
stability and effectiveness - f these technologies will be
assessed through leach and strength testing as part of this
design phase. It is expected that the stabilization technology
-------
selected will provide long-term immobilization of metals in the
soil and produce a substance of adequate load-bearing capacities.
4.0 Remaining Concerns
Several issues have been addressed but are not yet completely resolved.
These issues include:
o What mechanisms are available for implementing and enforcing
institutional controls to restrict access to the plume of
contaminated ground water and protect the integrity of stabilized
soils? The availability of existing institutional controls is
being researched in order to define the need and appropriate
authorities for-additional land use controls.
o How will storm water runoff be drained from the site area? An
estimate of site storm water runoff volume will be calculated,
and that information applied to select and design an appropriate
storm water drainage system.
o What processes are appropriate for disposition of water encoun-
tered during excavation of source soils? This will be addressed
as part of the remedial design process.
o To what degree is cleanup of the contaminated ground water
appropriate? This will be addressed during the Record of
Decision for ground water cleanup in the spring of 1988.
o How would the governments resolve potential problems if business
operations are dislocated as a result of remedial operations.
Agency legal counsel are evaluating the legal implications of
remedial operations upon business activities.
-------
IHUKI TO AONINISTRATIVK BBCORD FOR FRONTIRR HARD CHROME
Doc. I File
00000001. Pre Supcrfund correspondence and
enforceienl actions
uOOOOOOZ. Pre Superfund correspondence and
enforcement actions
Pre Superfund correspondence and
enforceienl actions
Pre Superfund correspondence and
enforr.eient actions
OOOOOOOS. Pre Superfund correspondence and
enforcement actions
Pre Superfund correspondence and
enforcement actions
00000001. Pre Superfund correspondence and
enforceient actions
OOOOOOOR. Pre Superfund correspondence and
enforceient actions
Pre Superfund correspondence and
enforceient actions
00000010. .Pre Superfund correspondence and
' enforcement actions
00000011. Pre Superfund correspondence and
enforcement actions
Date
Letter re discharge of procession
waste water
Letter re review of uater use and
disposal probleis and recommenda-
lions for solutions
Letter re use of cooling tower vs.
well
Letter re schedule for installa-
tion of temporary plumbing sjatei
Letter and attached drawings of
flow diagram and plot plan re
temporary systei for effluent
disposal
1/22/16
4/22/16
6/1/16
6/9/16
Letter re inspection of temporary
waste facilities
Letter re status of installation of
temporary plumbing system
1/16/16
1/21/16
Letter re proposed plumbing changes 9/9/16
Letter re proposed plumbing changes 9/21/16
Meio re meeting recap, Frontier Hard 2/21/11
Chrome/DOR/City of Vancouver on
2/16/11
I Pages Author/Organitation
2 Richard H. Alien,
City of Vancouver
2 Bryan M. Johnson, Seton
Johnson i Odell, Inn.
Bryan N. Johnson, Seton
Johnson i Odell, Inc.
Bryan H. Johnson, Seton
Johnson I Odell, Inc.
Bryan H. Johnson, Seton
Johnson I Odell, Inc.
Richard H. Aiken,
City of Vancouver
Valdemar Setnn, Seton
Johnson I Odd), Inc.
Doug Hartin, Seton,
Johnson I Odell, Inc.
Doug Martin, Seton,
Johnson I Odell
Jerry Keesee,
City of Vancouver
Letter re discharge of industrial
waste to sanitary sewer system and
ground
-------
I'oc. I File
Type/Description
Dale I. Pages Aulhor/Organir.alion
Addressee/Organisation
00000012. Pre Supcrfund correspondence and Memo re meeting recap, Frontier 4/26/71
enforcenent actions Hard Chrome and Citj of Vancouver
00000011. Pre Superfund correspondence and
enforceaenl actions
UOOOOOH. Prc Super-fund correspondence and
enforcement actions
00000015. Pre Superfund norreflpondence and
enforcement actions
00000016. Pre Superfund correspondence and
enforcement actions
00000011. Pre Superfund correspondence and
enforcement aclions
00000018. Pre Superfund correspondence and
enforcement actions
00000019. Pre Superfund correspondence and
enforcement actions
000000020. Pre Superfund correspondence and
enforcement actions
00000021. 'Pre Superfund correspondence and
enforcement actions
00000022. Pre Superfund correspondence and
enforcement actions
Letter re recommendations for ii- 2/10/18
provemenl in waste water disposal
system
Statement describing proposed pol- 5/2/11
lution abalemenl program (including
one page of handwritten notes)
Letter re progress on completion of 10/11/11
Phase I of pollution abalcment
program
Letter re reasons for lack of prog- 11/21/78
rcss on pollution control program
Letter re progress on and proposed 3/3/80
schedule lor completion of vaste
treatment system
Letter re escape of nickel from 12/23/80
Niklad 1731 system
Letter re estinate of water usage 3/23/81
per day
Letler re compliance by Frontier 5/3/82
Hard Chrome with stale discharge
permit
RCRA inspection report 1/31/82
Letter re compliance by Frontier 5/3/82
Hard Chrome with Stale Discharge
Permit and chronology of corres-
pondence between City, VDDR and
Frontier Hard Chrome
Hugh James, Jerry Calkins,
Tom Rcclcston, meeting
attendees
Herb S. Nissen, Frontier
Hard Chrome
2 Tom Rolby
3 Frontier Hard Chro»»
2 Herb Nissen, Frontier hick Aiken, City of
Hard Chrome Vancouver
I Herb Nissen, Frontier Orald Calkins, VPnR
Hard Chrome
2 Herb Nissen, Frontier Orald Calkins, ul)i;K
Hard Chrone
J. R. Uuchene, Allied- R. Tyler, Frcnl.i-r Har-l
(elite Products Div. Chrome
Herb Nissen, Frontier Hike H^rti-us, UDOR
Hard Chrome
Thomas D. Boyer, City of Howard Steeley, VUOR
Vancouver
3 Rric Rgbers, HDOB
File
I Thomas D. Boyer, City Howard Steeley, MOOR
of Vancouvii
-------
Doc. I
lie
Type/Description
JaU JLPaiei Author/prganitaUpn ___
Addressee/Organ ir.{
00000021. Pre Super fund correspondence and
enforcement actions
00000024. Pre Superfund correspondence and
enforcement actions
00000025. Pre Superfund correspondence and
enforcement actions
00000026. Pre Superfund correspondence and
enforcement actions
00000021. Pre Superfund correspondence and
enforcement actions
00000028. Pre Superfund correspondence and
enforcement actions
00000029. Pre Superfund correspondence and
enforcement actions
000000)0. Pre Suptrfund correspondence and
enforcement actions
00000011. Pre Superfund corrrKpondence and
enforcement actions
Letter and revised version of State 5/18/82
Haste Discharge Permit 15012
Letter, eiplanation and information 5/21/82
sheets re proposed waste treatment
facility and financing of same
Letter re heiavalent chromium conta- 5/24/82
ination of (round water
Letter re request for modification 6/2/82
to Slate Haste Discharge Permit
Letter re proposed sair'ing plan 1/22/82
Tor Frontier Hard Chrome
Letter re comprehensive (round water 8/20/82
stud; for Frontier Hard Chrome
Demo re 1/11/82 analysis of Frontier 12/21/82
Hard Chrome sample I81-H99
Nemo re Frontier Hard C.hromn chrono- 1/7/83
l<*«y
Homo with Attached draft Order and 1/11/83
Recommendation for Enforcement action
re recommendation for issuance of
Cease Discharge Order to Frontier
Hard Chrome
8. Y. Asselstine, VDOB Herb Hissen, Frontier Hard
Chrome
Herb Nissen, Frontier Howard Sleeley, Yl'OE
Hard Chrome
Howard Sleeky, HDOE
2 Herb Hissen, Frontier
Hard Chrome
I D. A. Hjers, Batlelle
Pacific Northwest Labs
2 Fric H. Fibers, VPOK
Nerley HcCall, VDOR
Jon Heel,
Herb Hissen, Frontier Hard
Chrone
Howard Sleeley, VboR
I!, -ud Steeley. KbOE
Herb Missrn, Frontier Hard
Chrome
Rric fibers, «Kk
6 Howard Sleelej, HIi'iK Jnhn S^n^r. K>-\
',.. n,
00000012. Pre Superfund correspondence and
enforcement actions
00000011. Pre Superfund correspondence and
enforcement actions
Recommendation for enforcement 1/1/81
iction against Frontier Hard Chrome
Nemo re recommendation for issuance 1/5/83
of regulatory order under RCH
90.48.120 to Frontier Hard Chrome
Rric B. Rgbcrs, VDOB Enforcement Officer, UDOE
Eric Rghers, VuOE
Howard Steeley, VPOE
00000014. Pre Superfund correspondence and
enforcement actions
Letter and attached UDOE Order re
lack of compliance with order by
Frontier Hard Chrome
5/26/81
Charles I. Douthwaite, R. DcVilt Jones
Washington Attorney
General'E Office
-------
Doc._l__ Pi. Li
Jate |_P»g.es Author/Organiration
Addresser/Organiration
00000035. Pre Superfund correspondence and
enforcement actions
00000036. Pre Superfund correspondence and
enforccacnt actions
00000037. Pre Superfund correspondence and
enforcement actions
00000038. Pre Superfund correspondence and
enforcement actions
Washington DOB Order, Docket 1/21/83
IDR83-II7 re discharge of waste water
by Frontier Hard Chroie
Letter re waste water plans and 1/11/83
specifications and attached comments
Letter re proposed program in
applying for permits
2/4/83
Letter with attached Notice of Com- 2/24/83
pliance with Order, Docket 10883-118
re termination of all commercial
chrome operations and discharge of
water
2 Bruce A. Cameron, WDOB Herb dissert, Frontier Hard
Chrome
C. Jonathan Heel, WUOR Herb Niseon, Frontier Hard
Chrome
John Harland, Seton, Herb Niscen, Frontier Hard
Johnson I OdelI Chrome
Otto Neth, Frontier Hard Gail R'ps, WU'IR
Chrome
00000039. Pre Superfund correspondence and
enforcement actions
Nemo of notes from meeting re status 4/15/83
of projected course of action for
Frontier Hard Chrome
2 Phillip H. Von*, El'A Heeling attendees
00000040. Pre Superfund correspondence and
enforcement actions
00000041. Pre Superfund cnmfipnndenrp and
enforcement actions
00000042. Pre Superfund correspondence and
enforcement actions
00000043. . Pre Superfund correspondence and
' enforcement actions
00000044. Pre Superfund lab analyses and
data
00000045. Pre Superfund lab analyses and
data
00( Pre Superfund lab analyses and
data
Nemo re Frontier Hard Chrome status 4/18/83
&n a Superfund site
Letter re decline in chromium levels 6/14/83
in well water and continued monitoring
2 Carl V. Taller, WD08 D. Rodney (lurk, WUOR
Draft Complaint for Injunctive
Relief and Cost Recovery against
Frontier Hard Chroie and Otto Neth
Haps and diagrams of Frontier Hard
Chrome
Vater well report - State of
ton
Vater well report - State of
Washington
Data summary re two water su
7/21/83
4/26/73
3/19/73f
9/5/75
13
R. DeVitt Jones,
Attorney
Charles K. Douthwaite,
Assistant Attorney
General - State of
Washington
I N. Johnson, Hansen
Drilling Co.
I HDOE - Water Quality
Laboratory
Charles X iii.hwai tr:,
Assistant Attorney General,
State iif Washington
-------
Doc. I File
Type/Description
00000041. Pre Superfund lab analyses and
data
00000048. Pre Superfund lab analyses and
data
00000049. Pre Superfund lab analyses and
data
00000050. Pre Suprfund lab analyses and
data
00000051. Pre Superfund lab analyses and
data
00000052. Pre Superfund lab analyses and
data
00000053. Pre Superfund lab analyses and
data
Data suiiary re two water saiples 9/12/15
froi Frontier Hard Chroie
Bicerpt froi consultant report re 1981
City of Vancouver's veil field with
attacked lab reports and charts of
predicted perforiance re Vancouver
Station 4
Lab report re ckroie in water saaples 6/11/82
froi wells I and 5, Station 4
Data suiiary - letals re saiple 4/10/82
froi Frontier Hard Chroae
Data sunary re Saiple 182-1499 5/4/82
froi Frontier Hard Ckroie
Heio re 96-hour bioassay inforia- 5/11/82
tion ot water saiple froi Frontier
Hard Ckroie
Data skeet for static basic acute
fink toiicity test re Frontier Hard
Ckrnie
5/19/82
II
KDOB - Vater Quality G. Calkins, H. Steeley,
Laboratory V. Heini and lab files
Chandler Bills, Robinson
I Noble, Inc.
Susan M. Coffey, Coffey Larry Gruber, City of
Laboratories Vancouver
VDOK - Rnvironiental
Laboratory
H. HnCall Horhous
G Freeian, HDOE--01yipia Nike Norkous, Rric P-Rbers.
Rnvironiental Laboratory Howard Steeley
Don Rjosness, VDOg
G. Freeian, ₯DOg--Oljppia
Bnvironienl.al Laboratory
Nickael Horhnus, VDOR
00000054. Pre Superfund lab analyses and
data
00000055. Pre Superfund lab analyses ind
data
00000056. Pre Superfund lab analyses and
data
00000057. Pre Superfund lab analyses and
data
Request for analysis re saiple with 1/31/82
laboratory 182-1499
Letter witk attacked well water, 1/1/82
effluent and river water saiples
analysis results and data suiiary
skeets re saiples 82-2126, 82-2889,
82-2890, 82-2891 and 82-3091
Data sunary sheets re saiple 2/25/83
113-0431
Laboratory report re two water 3/30/83
saiples taken froi wells nuibers
I and 6
Hike Horbooa, VDOB
VUOg
Bonald B. Perry, FNC Howard R. Steeley, MbOR
Corp.
G. Freeian, NDOB--Olyipia Howard Sleeley, Jon Neel
Bnvironiental Laboratory
Van Waters i (togcrs
of Univar
1. Tyler and H. Nissen,
Frontier Hard Ckroie
-------
DOC. \ pile.
00000058. NPL listing and conents
00000059. NPL listing and conentB
Tjpe/Pescriptipn lale__ I. f>8rs Author/Organ.! tali on. AddrpsEeo/i)rganir.aUi>n
I
00000060. NPL listing and conents
00000061. Reiedial action mter plan
00000062. Site inRpection reports
00000061. Site inspection reports
00000064. Site inspection reports
00000065. Site inspection reports
00000066. Site inspection reports
00000067. Site inspection reports
i
00000068. Site inspection reports
00000069. Site inspection reports
00000070. Site inspection reports
National Priorities List Site infor-
mation re Frontier Hard Cbroie
Bicerpt fron Federal Register,
Vol. 47, (251, re aiendienls to
National Oil and Hatardous Substance
Conlingencj Plan; the National
Priorities List - Proposed Rule
Eicerpt froi Federal Register,
Vol. 48, (175, re aiendients to
National Oil and Hatardous Substance
Contingencj Plan; National Priorities
List - Final Rule
Reiedial action easier plan for
Frontier Hard Chroie
Inspection report re Frontier
Hard Ohrdie
Inspection import re Frontier
Hard f.hrme
Inupprlion repoil re Frontier Hard
Chroir
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier
Hard Chroie
Inspection report re FHC
Potential hazardous waste site -
site inspection report
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
U.S. BPA/Reiedial
Response Prograi
12/30/82 9 BPA
9/8/83
9/26/83
8/13/75
9/16/76
9/22/76
1/13/77
3/19/81
6/7/82
8/27/82
3/31/82
4/28/82
18 RPA
57 CH2HHMI
I Herri Calkins, YDOB Howard. V?rn an-l fil"s
I U. Calkins and T. Rolby Howard, Rich and h!"s
I Calkins and Rolby, VUOR Howard, ki<-h iM fil"s
I Cerrj Calkins, VDOE Howard, Rich and files
I Hnrhous and Gregory, Jii <>., fine, Brett,
KD08 Howard and files
1 Rgbers and Steeley, NDOR Dist. 14 and filrs
10 Thoias Tobin, BI'A
Norhous and Bgbers,
VUOR
Rgbers and Steeley,
upng
Howard, Dist. 14 and
files
Dist. 4, Jii 0., Jii
and files
-------
l)oc. I le
Tjjie/DescnjilHHL
00000071. Site inspection reports
OOOOOOTZ. Site inspection reports
00000071. Site inspection reports
00000071. Site inspection reports
OOOOOOT5. Site inspection reports
00000076. Site inspection reports
00000077. Site inspection reports
00000078. Site inspection reports
00000079. Site inspection reports
. Site inspection reports
00000081. Site inspection reports
00000082. Site inspection reports
00000081. Site inspection reports
00000084. Site inspection reports
00000085. Site inspection reports
Inspection report re FHC
Inspection report re Portco
6/7/82
6/7/82
Inspection report re State School 6/16/82
for the Deif
Inspection report re Frontier Hard 1/10/81
Chroie
Inspection report re Frontier Hard 4/17/84
Chroie
Inspection report re Frontier 8/1/84
Hard Chroie
Inspection report re Frontier Hard 3/25/86
Chroie
Inspection report re Frontier Hard 6/24/86
Chroie
Infip- ion report re Frontier Hard 7/2/86
Chrnip
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
I Bgbers and Steeley,
VUOB
I Bgbers and Steelej,
VDOB
I Bgbers, VDOB
I
8/6/86 I
12/11/86 2
12/17-18/86 3
1/7/87 I
1/15/87 2
1/20-21/87 I
Dist. |4 and files
Dist. 14 and files
Disl. 14 and files
I Fibers and Sleeley, VDOB Dist. 14 an-l files
I Nile Blui, VDOg File
2 H. Blui and G. Stuipf, File
VDOg
2 Nike Blui, VDOg File
Nike Gallagher, Bob File
Goodian, Sue Sins, VDOB
Nike Gallagher, Ravi File
Krishnaiah, Sue Sins,
VDOB
Hike Gallagher, VDOR File, Rob
VDOg
Hegan Vhite, VDOg
File
Nike Gallagher, VDOB File
Nike Gallagher, VDOg File
Nike Galh«her, Dave File
Bounlrj, Sue Sins, VDOg
Sue Sins, VDOg
File
7
-------
Doc. I File
00000086. Site inspection reports
00000087. Site inspection reports
00000088. Site inspection reports
00000089. Site inspection reports
00000090. Site inspection reports
00000091. Site inspection reports
00000092. Action iciorandui
00000093. Reiedial Invesligatinn/Feasibilit;
Study corrrspondoncc
00000094. Reiedial Investigation/Feasibility
Study correspondence
00000095. Reiedial Investigation/Feasibility
Study correspondence
00000096. Reiedial Investigation/Feasibility
Study correspondence
00000097. ieiedial Investigation/Feasibility
Study correspondence
Reiedial Investigation/Feasibility
Study correspondence
00000099. Reiedial Investigation/Feasibility
Study correspondence
Type/J)mription
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Inspection report re Frontier Hard
Chroie
Action ieio re request for approval
to proceed with UI/FS
re potential conflict of
interest
Hi'iio rn inli>rii evaluation nf
anre hy pairs I Hooro
Letter re reconnaissance of
Frontier Hard Chronc site
Letter re concern over schedule
slippage on RI/FS
Neio re performance probleis with
Daies I Hoore
Letter re performance probleis with
Dates i Hoore
Letter re performance probleis with
Daies I Hoore
1/28/87
1/29/87
2/9-12/87
2/10-20/87
2/18-19/87
6/2-1/87
1/10/84
12/12/81
2/5/85
5/1/85
5/14/85
9/21/85
5/21/85
5/28/85 '
1
1
1
2
2
2
5
1
1
1
2
2
1
Author/prganUationAddrcsscr/Urgiinir.ation
Sue Sins, VDOB
File
Hike Gallagher, VDOB File
Sue Sins, VDOB
Sue Sins, VDOR
File
File
Hike Gallagher, VDOR File
Sue Sins, VDOB
File
Charles R. Findlcy, RI'A Rrnesta B. Barnes. HA
J. Michael RlacKwell, RK-H Hall, ₯I>OK
liaies I Noorc
Rob Goodnan,
Kenneth Trotnan, Paies i Bob Gnf-lian, VlmK
Hoore
Charles Findley, BPA Lynda L. Brothers, VDOR
Rick Hall, VDOS
Lynda Brothers, VUOR
Lynda L. Brothers, VDOB J. H. fllankwell, Daies I
Hoore
Lynda L. Brothers, VDOE Charles Findloy, RI'A
-------
Doc_._{
'He
T;pe/Description
Author/Organitalion
Addressee/Organ] n
00000100. Reiediil Investigation/Feasibilit; Meio re pre-drilling meeting on-
Slud; correspondence site with Dues i Noore
7/10/15
00000101. Reiedial Investigation/Feasibilit; Letter re description of activities IO/H/85
Slud; correspondence of Vashington DOB in vicinilj of
JanUen plant
00000102. Beiedial Invesligation/Feasibilit; Letter will attached agenda, sunir; 5/1/16
Stud; correspondence table and diagram re additional data
requirements necessar; to coiplele
Rl as discussed at leeting of 4/22/86
00000101. Reiedial Investigslion/Feaiibilil; Letter re confiriation of discussions 7/9/86
Stud; correspondence between BPA and VDOB re tasks to be
performed by VDOB in completion of
BI/FS
00000104. Reiedial Investigation/Feasibility Letter re additional information re
Stud; correspondence site activities requested earlier
OOOOOIOS. Reiedial Investigation/Feasibility Letter re status and revisions of
Stud; correspondence Rl activities and aiendient to
ulli-site cooperative agreement
00000106. Beiedial Invesligalion/Peasibil''! Letter re discharge of puip test
10/27/86
11/3/86
11/19/86
Stud; correspondence
00000107. Reiedial Investigation/Feasibility
Stud; correspondence
00000108. (leiedial Investigation/Feasibility
Stud; correspondence
water to sanitary sewer. Attached
table re water qualit; results froi
deep aquifer near proposed puip lest
well over time
demo re possible implementation
of Bipedited Reiedial Action
Letter re formal response to Super-
fund comprehensive accomplishment
plan proposal
0000010). Remedial Investigation/Feasibilit; demo re meeting with BPA to discuss
Stud; correspondence Bipedited Reiedial Action strateg;
00000110. Reiedial Investigation/Feasibilit; Letter re confirmation of dis-
Stud; correspondence cussions re proposed implementation
of Bipedited Remedial Action
12/18/86
12/21/86
12/24/86
1/21/87.
Negan Vhite, VDOB
Bob Goodman, VDOB
dathryn N. Lombardo,
Dames i Moore
2 Nona Lewis, BPA
David Rountr;, VDOB
David Rountr;, VDOB
Negan Vhite, «l)OB
2 Pkillip N. Vong, BPA
2 Jerr; Jewell, VDOB
2 Dave Rountr;, VDOB
I James Bverls, RPA
File
Dick Sigmon, Jantten, Inc.
Bob Goodman, VUOB
Robert Goodman, VDOB
Phil Vnng, BPA
Phil Vong, BPA
Tom Royer, City of
Vancouver
Phillip Mi I lam, BPA
Jim Bverts, BPA
File
Jerr; Jewell, VDOB
9
-------
(ioc._J _ PjJ? __________________________
J)ale _ |_Pages Author/Organitalion ______ A'lJrf:ss':e/')rganualion
00000111. Remedial Invesligalion/Peasibilily Lelter re Vashinglon DOB's decision 2/11/8?
Study correflpondence not to participate in expedited
reiediat action
00000112. Reicdial Investigation/Feasibility Letter re progress on RI/FS
Study con, :.pondence
2/24/81
00000113. Keiedial Investigalion/Peasibility Letter re Expedited Remedial Action, 3/11/87
Study correspondence ROD target date, PS uorkplan and
ulti-site cooperative agreement
aicndient application
00000114. Reiedial Invesligation/Peasibility Letter re disposal of drill
Sludy correspondence cultings obtained during well
installation at Circle Land Fill
4/13/87
00000115. Reiedial Investigation/Feasibility Leller approving disposal of drill 4/28/87
Sludy correspondence cultings at Circle C landfill
00000116. Reiedial Investigalion/Peasibililj Letter re: surface water as exposure 5/4/87
Study correspondence pathway in feasibility study report
2 Jerry Jewell, VDOB
Jaies Rverts, RPA
I Phillip I]. Hillan, RPA Jerry Jewell, VDOP.
2 Jerry Jewell, VDOB
I'hillip G. Hillan, BI'A
I Hegan Vhile, VDOB
Gary Bickelt, SV Vashinglon
Heallh Districl
I Gary Rickell, SV Hegan Vhil.e, VDOP.
Vashinglon Health District
I Dave Rnunlry, VROR
Cretrhen lireenawall,
Danes I Hnnre
DOOOOII7. Real-dial Investigation/Feasibility I.eller re plans by Cily of Vancouver 5/5/87
Study correspondence to install slnri drainage syslei
around Fronlier Hard I'hrome site
00000118. Reiedial Invesligalion/Feasibility Leller nolifying Danes I Hoore and 7/1/87
Sludy correspondence Vashinglon DOB of Bovay's concern
re delivery date for preliminary
draft of feasibility study
00000119. Reiedial Investigation/Feasibility Letter and attached leio re approach 7/7/87
(Study correspondence for handling organic groundwater
contaiinalion in feasibility study
00000120. Remedial Invesligation/Feasibilily Letter re schedule information on 7/13/87
Study correspondence delays in delivery of draft
feasibilily sludy report
,
. Reiedial Investigalion/Peasibilily heno re inlerim progress reporl on 7/28/87
Sludy correspondence feasibilily sludy
1 David Rountry. VDOR
Roberl P.. Siilh,
Rovay Northwest, Inn.
3 David Bountry, VDOB
Grt-l.rhrn lirernawalt,
laies I
Kevin Frc^ian, Danes
t Honre
Gretchen Greenawall,
Danes i Hnore
2 David Rounlry, VDOB Phil Vong, EF'A
I David Rounlry, VDOB File
-------
One. I
ile
Tipe/Description
_Pag;ei Au tbq r/ Ur ganitaI jo n
Addrcfisec/'Hgani
00000122. Reiedial Investigation/Feasibilit;
Stud; leetings between state,
BPA and contractor
00000123. Rciedial Investigation/Feasibility
Stud; leetings between itate, BPA
and contractor
Heeling linutes re technical and 6/27/85
anageient review of Eeiedial
Investigalion with attacked iap of
proposed loniloring well localions
Agenda and list of deliverables 9/19/85
for project status report leeling,
Washington DOR uncontrolled
hazardous waste siles, Fronlier
Hard Chroie
00000124. Reiedial Investigation/Feasibility Meeting linutes of technical and 9/20/85
Stud; leetings between state, BPA lanageient review of reiedial
and contractor investigation
OOOOOI2S. ieiedial Investigation/Feasibility
Stud; leetings between state, BPA
and contractor
00000126. Reiedial Investigslion/Feasibilil;
Stud; leelingg between slate, RPA
and contractor
00000127. Reiedial Investigation/Feasibility
Stud; leetings between state, BPA
and contractor
Heeling linutes re technical ind 11/25/85
lanageient review of reiedial
invpstigalion and handwritten notes
re lab results froi testing of
saiples for chroie
Heio re leeting lo discuss reiedial 5/9/86
investigation data gaps
6/23/86
re conference call held to
discuss soil saipling inside and
outside of building at site
00000128. Reiedial Investigation/Feasibility Heio re leeling lo discuss schedule 6/21/86
Stud; teelings belween stile, RPA couitienl, eiplanalion of future
and contractor work activit; and eiplanalion of
results of past work activit;
00000129. leiedial Investigation/Feasibility Handwritten notes re Frontier Hard
Stud; leetings between state, RPA Chroie leeting - Washington DOR.
and contractor Oljipia
00000130. Rpiedial Investigation/Feaiibilit;
Stud; leelings between state, EPA
and contractor
9/3/86
Heio re conference call to discuss 2/5/87
proposed Ripedited Reiedial Investi-
gation
Hegan Hhite, VDOB
2 Hegan Vhile, VDOB
3 Nona Lewis, BPA
File
Fil-
File
Pkil Vong
File
II
-------
Doc. I Fije _ . _ .. TJP?lP?.s-c-rJp]'i0.n
._??]_§_ I.
Author/OrganUation Addresscr/Urg.inir.alion
00000131. Reiedial investigation/Feasibility
Stud} leetings between state, BPA
and contractor
00000132. Reiedial Investigation/Feasibility
Sludj leetings between date, BPA
and contractor
00000133. Veils: water level msureients
00000330. Hells: water level icasureienlB
00000134. Hells: water level leasureients
00000135. Veils: water level msureients
00000136. Veils: water level e
00000131. Veils: water level
OOUOOI38. Veils: water level leasureients
00000139. Veils: water level leasureients
00000140. 'Veils: water level teasureients
OOOOOMI. Veils: water level teasureients
00000142. Veils: water level leasureients
Heeling linutea re feasibility study 5/26/87
Neio, reeling notes and agenda
feasibility stud; tasks nuiberi 3
and 5
Transitttal sheet and sunary of
water levels, 11/4/85 through
5/1/86
Groundwater elevations table -
Round 1
Heio re water level leasuretents
taken on 6/24/86
Transiitlal sheet and waler level
easurcient fort
firnund water elevations lahie -
Hoiin>l 2
Ground water elevations table -
Round 3
Heio re water level msureienU
taken 6/24/86 ('.ound I)
Meio re water level leasureients
taken 1/2/86 (Round 2)
Heio re water level leasureients
taken 1/8/86 (Round 3)
Ground water elevations table -
Round 4
Heio re water level leasureients
taken 1/24/86 (Round 4)
5/21/81 6 Dave Rountry, VDOR
6/16/85
6/24/86
6/26/86
1/2/86
7/2/1)6
7/8/B6
7/14/86
1/14/86
1/11/86
1/24/86
7/29/86
Kalhryn H. Loiibardo,
Daies t Hoore
Rathrin H. Loibardo,
Dairs t Hnore
H"Jan White and Hike
Gallagher, VDOK
Hike i;.illagher, VDOB
2 Hike Gallagher, VDOR File
Hike Gallagher, V|)i)R
2 Hike Gallagher, VDOB File
2 Hike Gallagher, VDOB File
2 Hike Gallagher, VDOK
2 Hike Gallagher, VbQg File
-------
Doc. I ile
TI pe/Des c r ijiUpn
AddreGsep/Urgan'i
00000143. Veils: water level leasureients
00000144. Veils: water level leasureients
00000145. Veils: water level leasureients
OOOOOM6. Veils: water level icasureients
Ground water elevations table -
Round 5
Heio re water level teasureients
taken 8/6/66 (Bound 5)
Ground water elevations table -
Round 6
Heio re water level leasuretents
taken 9/18/86 (Round 6)
8/6/86
8/11/86
9/18/86
10/13/86
OOOOOM7. Veils: water level leasureients Sunarj of water level elevations
00000148. Sampling plans, technical
standards and lonitoring wells
00000149. SaiplinK plans, technical
standards and ionitorin| wells
OOOOOISO. Sampling plan;), technical
standards and loniloring wells
00000151. SaiplinK plans, technical
standards and lonitoring uelli
00000152. Saipling plans, technical
standards and lonitoring wells
00000151. Saipling plans, technical
standard)! and lonitoring Hells
Letter re water saiple froi Indus- 8/14/84
trial well at FHC plant in Vancouver,
Vashington
Heio and specification sheets re 1/31/85
testing device for field testing
of heiavalent chroiiui
Hem, inp, field survej fon and. 6/I8/8S
chain of custody record re ground
water Mapling of eiisling wells
in vicinil; of frontier Hard Chroae
Heio re saipling of eiisting wells 6/Z6/85
around Frontier Hard Chroiiui on
6/19/85
Letter, field paraaeters table and 6/27/85
handwritten notes re initial saipling
on 6/19/85 of eiisting wells in
vicinitj of Frontier Hard Chroie
Heio and two well completion
diagrais re suhiiltal of variance
for installation of lonitoring
wells b; Dates i Moore at
Frontier Hard Chroie site
8/16/85
2 Hike Gallagher, V008 File
2 Hike Gallagher, VDOB File
I Vashington DOB
I Hike Blua, VDOK
Ken Trotian, Dates t
Hoore
Hegan Vhite, Vashington
D08
Kenneth H. Trotian,
Daiea I Hnore
Gabe Nahigian, FHC
Corp.
3 Harlan Rorow, Dams I Greg Glass, Danes I
Hoore Honre
SNT, ['.incs \ M
Kile
Rob Condnan, VDOR
4 Hike Gallagher, VDOK Rill Killer, VDOE
M
-------
Dor. I
File
Type/Description
_Dale !_Pagei AuthoryOrganmtion
AddroKf.'-e/Organi ration
00000154. Saipling plans, technical
standards and lonitoring wells
00000155. Snipling plans, technical
standards and innitoring wells
00000156. Saipling plans, technical
standards and lonitoring wells
OOOOOI5T. Saapling plans, technical
standards and loniloring wells
. Saipling plans, technical
standards and ionilor ing wells
00000159. Sampling plans, technical
standards and lonitoring wells
00000160. Saipling plans, technical
standards and innilnring wells
00000161. Saipling plans, technical
standards and lonitnrint wells
00000162. Saipling plans, technical
standards and aonitoring wells
00000163. Saipling plans, technical
standards and lonitoring wel.lt
I
00000164. Saipling plans, technical
standards and lonitoring wells
Heio granting variance Tor installa- 8/ZO/85
lion of lonitoring wells by Dues
i Moore at Frontier Hard Chroie site
Handwritten ieao re Field Change 10/15/85
Order II at Frontier Hard Chroie
reiedial investigation
Heio re saipling of water puddle 12/23/85
outside Coi Cable Co., Vancouver, HA
Letter re abandonient of lonitoring . 1/2/86
well B85-2 at Frontier Hard Chroie
Heio re Frontier Hard Chroie Data 6/6/86
Review
Untitled diagrais re sampling wells
Handwritten leio re analysis of 9/5/86
soil and groundwater saiples
Ncio and description of procedure 9/21/86
re chroiiui desnrption iHotheri
procedure for Frontier Hard Chroie
site
Handwritten »ein re volatile on 9/Z4/86
analyses at Frontier Hard Chroie
Heio re standards for cheiicals of. 10/3/86
concern at Frontier Hard Chroie
Handwritten ieio re prioritizing 10/14/86
of wells and soil boring for
ling purposes
I Rill Niller, VDOB
Nike Gallagher
2 Nike Gallagher, VDOg Joanne Chance
I Hegan Vhite, HDOR
I Renee Fuentes, EPA
I Ncgan Vhite, WDOK
3 Negan Vhite, HDOE
I Negan Vhite, VDOK
Z Hegan Vhite, VDOR
Fih
I Michael J. Gallagher, Kal.hj Uabariln,
VDOK Honrr
Nona Lewis, KI'A
FHi; Teai
1 Hannah Pavlik, Danes i R.ithy l.imkanlo,
Noore t Hoore
FIIC Teai
Dave Rountry, VDUB
Dave RounUy, VDOK
-------
Doc. I
Pije Tjpe/liescriptio.n
"»!?.... l._?»g?s Author/Organiialion
00000165. Saipling plans, technical
alandardE and lonitoring yells
00000166. Saipling plans, technical
standards and monitoring wells
00000161. Saipling plans, technical
standards and monitoring veils
Remo and scheiatic 'shallow' 12/16/06
monitoring well coipletion diigrai
re subiittal of variance for in-
stallation of lonitoring wells
by Daies I Hoore/Hokkaido Drilling
I Development Corp. at Frontier Hard
Chroie site
Letter re Frontier Hard Chroie site 12/12/86
puip test discharges
2 Hike Gallagher, KDOR Bill Miller, VDOK
Heio granting variance for installa-
tion of lonitored wells by Daies t
Moore/Hokkaido Drilling i Develop-
ment Corp. at Frontier Hard Chroie
site
1/5/87
Thnias D. Bojer, City
of Vancouver
Bill Miller, V.DOR
Kenan While, HUOE
Hike Gallagher,
00000168. Saipling plans, technical
standards and tonitoring veils
Handwritten note re drilling and
possible abandonment of puip test
well
1/28/87
Dave/Hike
00000169. Saipling plans, technical
standards and innitoring wells
Handwritten ieio re injection
urll and water rights periit at
Frontier Hard Chroie site
7/2/81
I HP (tan Vhite, HDOR
Pile
00000170. Saipling plans, technical
standards and lonitoring wells
00000171. City of Vancouver's sever system
00000172. .City of Vancouver's sewer -7
-------
Doc. ? Pile
Date LPages Aulhor/Organiiation
00000175. Citj of Vancouver's sewer systei
00000176. City of Vancouver's sewer systei
00000177. Citj of Vancouver's sewer systei
00000178. Quality assurance project plan
(QAPP)
00000179. Quality assurance project plan
00000180. Vork plans: reiedial investigation
Letter re city's planning efforts 7/28/87
for stori water drainage project
near the Frontier Hard Chroie
Superfund site
Letter re Frontier Hard Chroie site 8/18/87
and sewer construction. Attached
saiple results and tap showing location
of two saipling sites
Preliminary City of Vancouver, VA, 8/87
Proposal and Specifications for Sani-
tary Sewer Construction, Rast First
and 1 Streets
Quality assurance project plan, 7/12/85
Frontier Hard Chroie, Vancouver,
Vashington, for the Vashington Slate
Department of Ecology
Revioinns fur the QAPP, Frontier Ho date
Hard Chroie
J David Rountry, VDOR
Hcan re RI/FS. At.lacherf VMR
Statement of Vork and Appciidii
regarding possible consultant tasks
for HI
00000181. Vork plans: reiedial investigation
Reiedial Investigation Initial Vork 1/15/85
Plan. Attached tap of Frontier
Hard Chroie vicinity showing known
eiisting wells and generalired geo-
graphic area of interest for reiedial
investigation
00000182. Vork plans: reiedial investigation Reiedial Investigation Vork Plan 7/12/85
00000183. Vork plans: reiedial investigation Reiedial Investigation Vork Plan, 11/17/86
Phase 2
Donald I. Skaggs, City
of Vancouver, VA
28 City of Vancouver, VA
Don Skaggs, City of
Vancouver, VA
David Rounl.ry, VDOR
95 Danes i Hoore
VDOE
2 Author unknown
10/5/84 |5 Uuane R. Goodnan, VUOR H|)OK cnntrart'.r f«r
HI/KS
27 Haies 1 Moore prepared
lor VDOR
36 Daies I Hoore, prepared
for the VDOR
57 Daies I Hoore, prepared
for the VDOR
-------
Dor. ] ile Tjpe/DescriptiojL
Author/Organiralion . Adnr«ii:/iirgan«:-:
00000184. Reiedial investigation drafts 1
cottonls
00000185. Reicdial investigation drafts i
concnU
00000186. Reiedial investigation drafts i
cottents
00000187. Beiedial investigation drafti I
coiients
00000188. Reiedial investigation drafts I
coiients
00000189. Reiedial investigation drafts 1
coiients
00000190. Reiedial inveetigation drafts I
coitents
00000191. Reiedial investigation drafts I
coiients
00000192. Reiedial investigation drafts i
coiients
0000019]. I Reiedial investigation drafts t
conents
COOOOI94. Reiedial investigation drafti i
couents
00000195. Reiedial investigation drafts I
coiients
Agenda leeting - VDOR. Attacked 11/25/85
itratography, geologic crosi-sections,
water level contour laps, laboratory
analysis, boring logs and drui inventory
Letter re the draft Phase I reiedial 5/12/86
investigation
Reio re conents on draft Reiedial 10/28/86
Investigation Report, Phase 1,
by Daies I Moore
Neio re coiients on Phase IB! 11/18/86
prepared by Dates I Moore, dated
October, 1)86
Neio re potential reiedial techno- 3/23/81
logies
Letter re need for additional iteis 4/10/87
to include in the Rl report
Meio re coiients on draft Reiedial 7/11/87
Investigation Report by Dates I Hnore
Hover ieto re draft Rl report, 6/27/87
Section 6, attached review
cmients froa Kcgan While and Hike
Gallagher
Letter re final set of review coi- 7/14/87
ents for the Rl draft report
Bipanded outline, Phase I - Reiedial No date
Investigation Report
Reiedial investigation, Frontier 5/87
Hard Chroie, draft report, Vol. I
Reiedial investigation, Frontier 5/87
Hard Chroie, draft report, Vol. 2 . ,
50
I Hegan flute, HDDS
5 Nike Gallagher, VDOR
6 Negan Uhite, UDOK
2 Hegan Mhite. VDOK
I David Rountry, VDOK
6 Hike Gallagher, VDOB
II Dave Rountry, VDOK
3 Dave Rountry, VDOB
5 Author unknown
282 Dates 1 Hoore
612 Dates I Hoore
Kathy l.otbardn, limes t
Hoore
Dave Rountry, VI1UR
Dave Rnunl.ry, VDOR
Dave Rountry, Vl>i>R
Gretchen Greenaw.ilt,
Dates i Hnore
Dave Rounlr;, VI.'DE
Grelchen (ire'-r iwall.,
bates I Hoore
iiri>lrhen lireenawalt,
eK i Hoore
17
-------
Dug. I Fj|e Type/Description
Aulhor/Organitalion
Addressee/Organisation
00000196. Remedial investigation report,
final
0000019?. Remedial investigation report,
final
00000198. Yorkplans: feasibility study
00000199. Norkplans: feasibility study
00000200. Vorkplans: feasibility study
00000201. Feasibility study, drafts and
comments
00000202. Feasibility study, drafts and
comments
00000203. Feasibility study, drafts and
comments
00000204. Feasibility study, drafts and
comments
00000205. Peasibility study, drafts and
comments
00000206. Peasibility study, drafts and
comments
Remedial investigation, Frontier 8/87
Hard Chrome, final report, Vol. I
Remedial investigation, Frontier 8/87
Hard Chrome, Final report, Vol. 2 ,
Draft Identification of Preliminary 3/26/85
Remedial Technologies
Feasibility Study Vorkplan.
Attached schedule.
10/2/86
Final Horkplan Feasibility Study 3/19/87
7/87
7/87
Feasibility Study, Frontier Hard
Chrome, draft report, Vol. I
Feasibility Study, Frontier Hard
Chroae, draft report, Vol. 2
Frontier Hard Chrome Feasibility
Study, Process Network. Document
is located in VDOK - Haurrtous
Haste I'li'itnup Program file
Nemo re comments on PS tasks 3 and '
5 prepared by Bovay Engineers for
the FHC site dated 5/15/8?
Letter presenting compilation of
ecology review comments re Peasibi-
lity Study draft Tasks 3 and 5.
Attached revised Statement of
Vork
Cover ieio re preliminary review of 6/18/8?
attacked PS Chapter 2. Attacked com-
ments re Task 2 - Identification ai.l
Screening of Remedial Technologies
Z33
683
M
13
48
412
32?
4/22/R7 Unknown
Revision I
5/1/87
5/28/87 3
. 6/4/87
Dames i Noore
Dames 1 Hnore
Bovay Northwest, Inc.
Bovay Northwest, Inc.,
prepared for HOOB
Danes I Moore, prepared
for HUOg
Bovay Northwest, Inc.,
prepared for Dames I Moore
Bovay Northwest, Inc.,
prepared for Danes i Moore
Dames I Moore
hVgan Vhile, HOUR
David Rountry, ₯1)0B
Gretchen Greenawalt,
Danes I Moore
56 Dave Rountry, VD08
Gretchen Ureenawalt,
Dames ( Moore
-------
I File
T y pe/D esc r i p t ion
Dati
Pages
AfldrKSsee/'JrgariiMUinn
»:07. Feasibility stud;, drafts and
conents
208. Feasibility study, drafts and
conents
0209. Lab reports/raw data
0210. l,ab reports/raw data
0211. Lab reports/raw data
D212. Lab reports/raw data
0213. Lab reports/raw data
|)2I1. Lab reports/raw data
0215. Lab reports/ran data
I
0216. Lab reports/raw data
D2I7. Lab reports/raw data
Cover ieio re attached Table 2-1, 6/25/81
Reiedial Technology Screening
Soimy and review conents
Handwritten conents on FHC draft 8/14/87
FS dated July, 1987
Report re analysis for total ckroie 6/18/15
and keiavalent ckroie, log
IA8506IO-B
Report on water saiple analysis, 6/28/85
laboratory 190292
Report re analysis for total 10/21/85
ckroiiui and heiavalent ckroiiui,
Log IA85IOIO-C
Cover letter re attacked priority 12/4/85
pollutant analyses of ground water
obtained froi V85-IA
Transtitlal sheet re attacked table 12/6/85
showing regaining portions of soil
saiples, archived at Laucks Laboratory
Handwritten report relayed by pkone 12/11/85
re total chrotiui and heiavalent
ckroiiui
Handwritten note re saiple results 12/26/85
relayed by pkone
Letter re attacked analytical 1/16/86
results for saiples collected froi
two Coi Cable drinking water foun-
tains and two surface saiples
Report re analysis for chroiiui 1/26/86
and heiavalent ckroiiui,
Log IA860I24-I
7 Dave Rountry, VDOR
41 Negan Unite, VbOR
Gretcken Greenawalt,
Dates I Noore
Dave Rountry, VHOK
I Susan H. Coffey, Cnffey City of Vancouver
Laboratories, Inc.
J. H. Owens, Laucis Ken Trolian, Dates i
Testing Laboratories, Moore
Inc.
Susan H. Coffey, Coffey City of Vancouver
Laboratories, Inc.
10 Katkryn M. Loibardo, Robert Goodian, VDOR
Dates i Moore
Kathryn N. Loibardo,
Dates i Moore
2 Author unknown
I Megan Vkite, VDOR
2 Ratkryn M. Loibardo,
Date- Noore ,
Bob Goodian, VDOR
Bob Goodian, VDOR
Megan Vkite, VUOR
I Susan N. Coffey, Coffey Larry Gruber, City of
.Laboratories, Inc. Vancouver
19
-------
Uoc. I File
Type/Description
i__ LJH*J?_S. Author/prganUation Addressee/Organitalion
00000218. Lab reports/raw data
00000219. Lab reports/raw dala
00000220. Lab reports/raw data
00000221. Lab reports/raw data
00000222. Lab reports/raw data
00000221. Lab reports/ran data
00000224. Lab reports/raw data
Report re analysis for chroiiui 1/26/86
and heiavalent chroiiui,
Log »A86i2io-B
Report re analysis for chroiiui 1/29/86
and heiavalent chroaiui,
LOK IA860I21-B
Letter re attached analytical re- 2/6/86
suits of drinking water saiples
collected frni Richardson Metal
and IV Crafts on 1/21/86
Report re Washington Inorganic Cheii- 2/6/86
cal analysis, Log IWOI23-D
Draft suiiary of water analysis, 4/86
basic water paraielem, Round 2
Transiittal sheet with attached 4/17/86
drui inventory for second ground
water snnpling event. (1/6/86 -
1/15/86)
Transniltal sheet re attached water 6/20/86
level elevations obtained at three
Cascade Tempering wells and analytical
results of water saiples coll- -led
on two occasions froi CT-I
Susan M. Coffey, Coffey
Laboratories, Inc.
Susan H. Coffey, Coffey
Laboratories, Inc.
Kathryn M. Lnibardn,
Dates a Honre
Coffey Laboratories,
Inc.
Author unknown
Kathryn N. Utbardo,
Dales i Moore
Xathryn H. Lonbardo,
baies i Moore
Larry Uruber, City of
Vancouver
Larry firuber, I'.ity of
Vancouver
Bob Goodnan, VDOR
Nori Kran, City of
Vancouver
Bob Cioodnan,
Hark Allans, Applied
Geolerhnology
00000225. Lab reports/raw dala
00000226. Lab reports/raw data
00000221. Lab reports/raw data
Transiittal sheet re attached Round 8/14/86
3 - groundwater saipling: analytical
results
Report on filters, wipes, soil and 8/28/86
water, Laboratory 198139.
Lab analysis report re solids' total
per cent. Attached environmental
laboratory dala suiiary of
Attached data report result
1/16/87
Ralhryn N. Loibardo,
Dates I Moore
20 Barbara Gleason,
Laucks Testing Labora-
tories, Inc.
4 RPA Region I lab
Hike liallaeher, VDOK
Kathy Loibardo,
llaies I Hunre
-------
Hoc. | 'ile
00000228. Lab reports/riw data
00000229. Lab reporte/raw data
00000210. Lab reports/raw data
00000231. Lab reports/raw data
00000232. Lab reports/raw data
00000231. Lab reports/raw data
00000234. Lab reports/raw data
00000235. Ub reports/raw data
00000236. Lab reports/raw data
00000217. Lab reports/raw data
00000238. Haps, diagrais, photos
00000239. Haps, diagrais, photos
Handwritten ieio providing suiiary 2/13/87
of analytical results of water sniping
obtained during 72-hour deep-aquifer
puip-test
Date l_Pagcs
I
Transiittal sheet re attached
results of cheiical analysis,
Phase 2, reiedial investigation,
including tables and soil boring
and well location laps and surface
soil saiple laps
Cheiical analysis report for soil
saiples
4/29/87 41
No date
Suiiary of results, field screening Ho dale
for Cr6»
Volatile organic paraieters, water: 4/2/86
Round I
Volatile organic paraieters, water: No dale
Round 2
Suniary of results, field screening No dale
for Cr6«
Cheiical analysis table for soil No dale
and water saiples
Cheiical analysis table for soil No dale
ind water saiples
Volatile organic paraieters, water: No dale
Round 1
Naps re Division of Highways.
Original laps located at VDOB
Hatardous Haste Hanageient files
No date
Preliminary plans for proposed Rasl Nn dale
Pirsl Slreet and T Street. Ori-
ginal taps located at HDOR,
Hatardous Haste Nanageient files
Aulhor/Organualinn
Dave Rnunlry, VDOB
Grelchen i]reenaw,ilt,
bains i Hoore
2 Laucks Testing Labora-
tory
I Author unknown
8 Author unknown
8 Author unknown
I Author unknown
I Laucks Testing Labora-
tory
I l/aucks Testing Labora-
tory, Inc.
5 Author unknown
Vashin(lnn Stale Depart-
lenl of Trsnsporlation
I Aulhor unknown
Addrr'ssec/nrgaifi
Pal Basley, r.iiy of
Vancouver
Jack Ma1snn, Bovay
Northwest, Inn.
21
-------
Hoc. | File
Type/Description
00000240. Haps, diagrans, photos
00000241. Naps, diagrais, photos
00000242. Haps, diagrais, photos
00000243. Haps, diagrais, photos
00000244. Naps, diagrais, photos
00000245. Naps, diagrais, photos
00000246. Naps, diagrais, photos
000002(1. Haps, diagrais, photos
6/87
Ho date
7/29/58
No dale
Preliiinarf taps and diagrais re
Bast First Street and T Street.
Original taps located at WDOR
Hazardous Haste Hanageienl files
Dr.iuing re geologic fonation.
Original iap located at VDOB
Hatardous Haste Hanageient file
Hap of Vancouver freeway to Sleret
avenue. Original lap located at
WD08 Hazardous Waste Hanageient
file
Hap re Clark Count;, Washington,
northeast 1/4 section, 35 T 2 N,
RIB V.N. Original lap located at
WDOB Hazardous Waste Hanageiont
file
Hap of Vancouver freeway to Sl»ret
Avrnue. Original iap located at
V[)i)E Hazardous Vastn Hana^oient file
liiagran of sanpling locations in-
side building. Original taps
located at VDOR Hazardous Waste
Hanageient filns.
Diagrai of saiple results for total
chroiiui (parts per lillion) in
upper screened tone, First Round.
Original lap located at WDOB
Hazardous Waste Hanageient file
Diagrai of saiple results for total Ho date
chroiiui (parts per lillion) in
lower screened tone (First Round).
Original laps located at WDOK
hazardous waste tanageient file.
7/29/58
Mn date
Ho date
Aut.hpir/j)rganjialion
4 City of Vancouver
essee/Or gam?, at ion
Author unknown
Washington State Highway
Coiiission
I Clark County Hap
Service, Clark County
courthouse
t Washington State Highway
I Dates i Hoore
I Author unknown
I Author unknown
-------
lor.. I le
IlP? /.Oiler IP t'on
LF?^.3. Author/Organ!nation _ Addrns'snc/Org.-infrj
00000218. Maps, diagrais, photos
OOOOOZ49. Maps, diagrais, photos
00000250. Haps, diagrais, photos
000002SI. Maps, diagraas, photos
00000252. Naps, diagram, photos
00000253. Naps, diagram, photos
00000254. Haps, diagrais, photos
00000255. Haps, diagrais, photos
Diagrai of saiple results for heia- No date
vilent chroiiui (parts per lillion)
in upper screened tone, First Bound.
Original laps located at VDOR
Hazardous Vaste Hanageient files.
Diagrai for saiple results for No date
beiavalent chroiiui (p.p.i.) in
loner screened tone, First Round.
Original laps located at VDOR
Hatardous Vaste Management files,
Veil location tap. Original tap No date
located at VDOg Hazardous Vaste
Hanageient file.
Diagrai of well location!;. Origi- No date
nal laps located at VDOR Hazardous
Vaste Management files.
Hap re well locations. Original No date
ap located at VDOR Hazardous Vaste
HanagciPnl files
Diagm of geologic crocs sort inn, Ho dale
A-A' (viewing norl.h), total chroiiui
concentrations (p.p.*.). Original
ap located at VDOR Hacardous Vaste
Hanageient Files.
Diagrai of geologic cross section No date
A-A' (viewing north), heiavalent
chroiiui concentrations (p.p.i.).
Originil laps located at VDOR
Hazardous Vasle Hanageient files.
Diagrai of geologic cross section No date
B-B' (viewing east), keiavalent
chroiiui concentrations (p.p.i.).
Original taps located at VDOR
Hatardous Vaste Hanageient files.
Author unknown
Author unknown
Author unknown
Author unknown
Author unknown
Daies I Hoore
Daies I Hoore
Daies 1 Hoore
-------
toe. I File
Tjpe/DeBjerijition
Autbor/Organitalion
AMressop/Organitatinn
00000256. Naps, diagrais, photos
0000025T. Nape, diagrans, photos
00000258. Haps, diaKrais, photos
Diagrai of geologic cross section Mo date
A-A1 (viewing north), total ckroiiu*
concentrations (p.p.i.j. Original
ap located at MOB Hazardous Haste
Hanageient file.
Diagrai of geologic cross section No date
A-A1 (viewing north), heiavalent
chroiiui concentrations (p.p.i.).
Original tap located at HDOE
Hazardous Vaste Hanageient File.
Diagrai of geologic cross section No date
B-B'(viewing east), heiavalent
chroiiui concentrations (p.p.i.).
Original iap located at VDOB
Hazardous Vaste Nanageient Files.
Dates I Honre
Danes I Moore
Daies i Moore
00000259. Naps, diagrais, photos
00000260. Haps, diagrais, photos
00000261. Haps, diagrans, photos
00000262. Coaiunity relations plans and
public participation
00000261. Couunity relations plans and
public participation
Site iap, Frontier Hard Gimme, 4/21/87 7
with attached geologic cross section;;
Suttnry of Frontier Hard Hhroie Ho date 2
photographs at tUiOK site file
Aerial photographic analysis of . 8/85 I)
Frontier Hard Chroic, Inc.
Neio re leeting of March 30, 1984, 4/4/84 3
to establish a coiiunity relations
prograi for the Frontier Hard
Chroie cooperative agreeient
Coiiunity relations plan for reie- 6/84 19
dial investigation at Frontier Hard
Chroie
t Moore
VLOK
EPA
Carol Thoipson,
VUOg
Carol R. Thnipson,
VD08
Kile
00000264. Couunity relations plans and
public participation
00000 Conunily relations plans and
nnhli r nnrt i ri nulinn
Letter providing notice of public 10/16/84
eeting to be held October 24,
1984, to eiplain reiedial investi-
gations. Attached fact sheet
Hnio re October 24 public ineti 11/14/84
Carol Thoipson, Bob
Goodian, Vl'UE
I Carol Thoipeon, VU08
Al I inl.erested citir.ens
File
-------
roc. I
00000266.
00000261.
00000268.
00000269.
00000270.
PTle
Coiiunitj relations plans and
public participation
Conunity relations plans and
public participation
Coiiunily relations plans and
public participation
Conunily relations plans and
public participation
Couunity relations plans and
public participation
Tyje/pescription
000002TI. Newspaper articles
00000212. Newspaper articles
00000213. Newspaper articles
00000274. Newspaper articles
00000215. Newspaper articles
00000276. Newspaper articles
00000211. Consent Tor access
News release: Field Vork
at Frontier Hard Chroie to Begin
News release: Frontier Hard Chroie
Update, December 5, 1986
Frontier Hard Chroie Couunity Rela-
tions Plan, Final Draft
Hailing list, Frontier Hard
Chroie
Reiedial Action subcontract between
Dates I Hoore and Urban Regional
Research, attachient I, re couunily
relations services
A me with no cheese; closed chroie
fin blared a long, hard paper trail
Firi owner objects to state pollu-
tion investigation
C.hroiiui daiaje check starts
8/21/85
12/5/86
7/22/87
No dale
6/9/87
2/20/83
10/25/84
8/23/85
00000278. Consent for access
llamdouB-waste sites, Rcology 1985
Deparlienl lists ten of thei in
Clark County
Hells drilled in hazardous waste No date
tests
Veils dug to tonitor pollution " V87
Letter re State of Washington vs. 4/30/84
Frontier Hard Chroie, Inc.
Attached request for entry upon land
for inspection and other purposes
Letter re attached list of property 7/9/85
owners in vicinity of Frontier Hard
Chroie facility
22
Author/Organir.ation
Vashinglon DOB
Washington 008
Dates t Hoore
Author unknown
Kevin J. Freeian,
Dates i Hoore, and
Jane Preuss, Urban
Regional Research
John Harrison, The
Columbian
John Harrison, The
Coluibian
John Harrison, The
Columbian
Bruce Yestfall, The
Coluibian
Ron Linde, The
Oregonian
Bruce Vestfall, The
Coluibian
Charles I. Douthwaite,
Office of the Attorney
General
K. beVilt Jones,
Attorney at Law
Stephan H. Testa, Daies Rob Goodtan,
i Hoore
25
-------
Fl!c_
Type/Description
00000279. Consent Tor access
Handwritten consent for access to
property to Washington DOR and
their contractors
9/23/85
John Riser, Richardson
Hetal Work, Inc.
Addressee/Organif.ation
WltuB
. Consent for access
Consent for Access to Property , 12/9/86
to drill and install one lonitoring
well
1 Gerald N. Alciander
WDOg
00000281. Consent for access
00000282. Consent for access
00000281. Consent for access
Consent for Access to Property 12/22/86
to drill and install one lonitoring
well
Letter re access to Burgett
property, Vancouver. Attached
access agreenent.
7/21/8?
Access agreement to drill and No date
install one, possibly two, lonitoring
wells
I Bill Rrusinski, Mashing- WlM.'g
ton School for the Deaf
Kathleen I). Hii, .
Office of the Attorney
General
Frank Kite and Bob
Goodian, Wl)0g
Walter Clayton,
Attorney at l.au
VDOE
00000284. Correspondence between Stale
and PRP (after 1981)
Letter re State of Washington vs.
Frontier Hard Chroie, Inc.
5/18/81
R. DcVitt Jones.
Attorney at Law
Charles R. bnuthwait*,
Office of the Attorney
General
00000285. Correspondence between State
and PRP (after 1983)
Letter re Halter Beth/Frontier Hard 11/16/84
Chroie and the drilling of wells
Charles K. Douthuaite,
Office of the Attorney
General
K. L'eWitt Jnncs.
at 11w
00000286. Correspondence between State
and PRP (after 1981)
00000281. Correspondence between State
and PRP (after 1983)
j
Letter re Washington 008 investiga- 4/22/85
tion into contamination at Frontier
Hard Chroie/Nelh site
Letter re dry well on Heth site 5/1/85
which had been sealed by ceient cap
Charles R. Douthwaite,
Office of the Attorney
General
R. DeVitt Jones, Attorney
at Law
Hr. DeWilt Jones,
At Lorney al ;,aw
Charles R. Douthwaite,
Office of the Attorney
General
00000288. Correspondence between State
and PRP (after 1983)
Letter indicating dry well was a
a concrete suip
5/3/85
R. DeVitt Jones, Attorney
at Law
Charles R. Doulhwaite,
Office of the Attorney
General
-------
Doc. j
Tjpe/DesjiMpUpn
Jlalo
Author/prganitatipn
OOOOOZ89. Correspondence between State
and PRP (after 198])
00000290. Correspondence between State
and PRP (after 198))
00000291. Correspondence between State
and PRP (after 19R1)
00000294. Correspondence between State
and PRP (after 1983)
00000295. Correspondence between Slate
and PRP (after 1983)
00000296. Correspondence between State
and I'RP (after 1983)
00000291. Correspondence between State
and PRP (after 1983)
00000298. Correspondence between State
and PRP (after 1983)
00000299. Correspondence between State
and PRP (after 1983)
Cover letter with attached letter 10/18/85
re negative iipact of National
Priority Listing on property
value at 113 T Street, Vancouver,
Vsshinglon '
Letter re negative iipact of 10/18/85
national priorities listing on
property value at 133 T Street,
Vancouver, Washington
Letter re Halter Heth's denial of 10/24/85
access to Washington DOR contractors
to investigate soil contamination.
Attached schematic drawing of
proposed soil saiple locations
Letter requesting leeting with 11/8/85
a representative of RPA to discuss
burden on property by further
testing and digging
Letter in response to questions re 11/14/05
the history of chroie plating facili-
ties in the area
Halter Neth, Frontier
Hard Hhroie
Nona Lewis, EPA
Letter re hydrological studies in
the area and ground water rontanina-
tion
12/23/85
Notice Letter to Frontier Hard Chroie 12/31/85
re release or potential release of a
hazardous substance
Letter requesting saiple analysis
reports
Letter re iipediient to lawful
sale of property and sharing
of data generated froi sampling on
site and consensual access to the
Neth properly
3/3/86
3/26/86
Halter Neth and
Otto Neth, Frontier
Hard Chrnne
Charles K. Douthwaite,
Office of the Attorney
General
Rob Goodnan, VDOE
R. D-Hilt Jones,
Attorney at Law
2 Halter Neth, Frontier Bob Goodmn,
Hard Chroie
3 Halter Neth, Frontier Charles Findlry, RI'A
Hard Chroie
2 R. DeYitt Jones, Attorney Bob Doodmn,
at Law
2 John D. Littler, HDOR Otto Neth. Frontier
Hard Chroie
R. DeVill Jones,
Attorney at Law
Kathleen D. Nil, Office
of the Attorney General
Rob Gnodaan, HDOR
R. DeHitt Jones,
Attorney at Law
-------
Hoc. I File
Type/Description
J)ale IJPates. Aulhor/Organualion AMressor/urganualion
00000300. Correspondence between State
and PRP (after 1981)
00000301. Correspondence between State
and PKP (after 1983}
00000302. Correspondence between State
and PRP (after 1983)
00000303. Correspondence between Stale
and PRP (after 1983)
00000304. Correspondence between State
and PRP (after 1983)
00000305. State cooperative agreements
00000306. State cooperative agreements
00000307. State cooperative agreement!
. State cooperative agreements
00000309. State cooperative agreements
Letter re property owners' coopera- 4/7/86
tion with Washington DOB and the
eipiration of the consensual access
agreement
Letter sumaming meeting between 5/23/86
property owners and representatives
of the Department of Ecology and
BPA and request for consent for access
to property. Attached form for consent.
Letter indicating tenants' consent 5/26/86
for access to property for further
testing with listing of conditions of
entry
Letter re consent for access to pro- 5/30/86
perty and conditions proposed.
Attached Consent for Access to
Property form
Letter re entry onto property and . 6/9/86
clarification of Condition P for
entry
Cooperative agreement between the 198.1
Vashington Uepartient of Bcology
and the United States Knvironmental
Protection Agency
BPA Assistance Agreement. Attached 6/12/84
special conditions.
3 R. DeVitt Jones,
Attorney at Law
Letter re Frontier Hard Chrome
cooperative agreement and special
conditions
4/2/84
Letter re special conditions in- 5/18/84
eluded in the Cooperative Agreement
Letter re acceptance of special
conditions by BPA to the
agreement
6/7/84
Kathleen D. Mil,
Office of the Attorney
General
3 Kathleen 0. Mil, Office DeVitt Jones, Attorney
of the Attorney at Law
General
3 K. DeVitt Jones,
Attorney at Law
Kathleen D. Hit, Office
of the Attorney General
3 Kathleen D. Hii, Office R. DeVilt Jones, Attorney
of the Attorney at Law
General
k. DeVitl Jones, Attorney Kathleen D. Mil, 01 fin-
al Law of the Attorn"y 'i-'r.fnl
52 Vashington DOR
5 Frederick L. Meadows,
BPA; Donald V. Nobs,
VDOB
2 Lynda L. Brothers, VDOB Milliaa H. Hedeman, EPA
5 Villiai Hedeman, BPA Lynda Brothers,
2 Lynda Brothers, VDOB
Kill us N. lledeman, ETA
-------
Doc.
Tjp.e/l)_escrij)li on
00000)10. Stale cooperative agreements
00000311. State cooperative agreements
00000)12. Slate cooperative agreements
00000)1). State cooperative agreements
00000)14. State cooperative agreements
Letter re aiendieot request to
cooperative agreement
12/17/85 I Bob Goodian, VDOB
He in re amendments to the Washington 12/31/85
multi-site agreement. Attached
letter requesting amendments from
VDOR.
EPA Assistance Amendment. Attached l/H/86
special conditions.
Letter serving as a request for the 3;
transfer of funds within the multi-
site cooperative agreement.
Attached Federal Assistance Applica-
tion form.
Special Conditions Cooperative agree- 3/86
ment |V00028)-Ol, Vashington Multi-
Site
( Kathi Davidson, EPA
4 John Littler, Hlu.'R
7 EPA
lath; Davidson, RPA
Oddvar E. Aurdal, EPA
4 Charles Findley, EPA Phillip Johnson,
I'hnrl-s R. hndlpy, RPA
00000)15. State cooperative agreements
00000316. State cooperative agreements
00000)17. State cooperative agreements
00000)18. State cooperative agreements
Letter re approval of request to 3/28/86
amend Vashington Multi-Site Coopera-
tive Agreement. Attached amendment.
Memorandum re request for reissuance 4/4/86
of funds. Attached amendmenl and
letter re approval of request to
amend Vashington Multi-Site Cooperative
Agreement
Special conditions re amendment 7/24/86
application for Frontier Hard Chrome
RI/FS project
Nemo re amendment to cooperative
agreement »V-00028)-OI. Attached
update of special conditions and
June 27, 1986, request for an
amendment to the K 'dial
Investigation Feasibility Project
8/7/86
4 Charles E. Findley, EPA John Litlkr, VPOE
) Charles Pindlej, RPA Russell H. Vpr, F.I'A
4 EPA
(Uthrin H. Davidson,
EPA
Arv Aurdal, EPA
-------
Jale
Author/Organiiation Addrcssep/OrgankaUon
. Stale cooperative agreements
00000320. State cooperative agreements
00000321. State cooperative agreements
00000322. State cooperative agreements
00000)2). State cooperative agreements
00000)24. State cooperative agreements
00000)25. Telephone conversation records
00000326. Reference materials or listings
of guidance documents used
00000321. Other documents
Letter re advance match amendment 8/I8/8S
for RI/PS project. Attached RPA
assistant amendnent form and
special conditions
Letter re status of Rl activities, 11/3/86
budget, and schedule
Letter re approval of transfer of 12/31/86
funds among sites in the Multi-
Site Cooperative Agreement.
Attached amendment and special
conditions.
Letter re budget eitension needs. 1/10/87
Attached Nulti-Site Coopera-
tive Agreement Amendment Application.
Letter re review of amendment to 6/S/87
Hulti-Site Cooperative Agreement,
V-000283-01-H. Attached letter
re approved increase of funds.
Attached Assistance Aiendient
conditions.
Hemo re proposed cooperative agree- No date
ments with the State of Vashington
' the Frontier Hard Chrome site
(U811652-01-0). Attached
special conditions
Handwritten report re call from 11/22/85
George Bullitt of Coi Cable concer-
ning chromium poisoning of employees
Guidances for administrative records No date
10 Charles Findlej, BPA Philip Johnson, VDOB
Frontier Hard Chrome Hatardous Vaste
Site Health and Safety Plan,
final
4/24/85
2 David Bounlrj, VDOB
4 Randall Smith for
Charles Pindley, EPA
2 Steve Hunter, KDOB
9 Steve Hunter, WUUB
6 Lee H. Thomas, BPA
I Megan Vhite, VDOB
BPA
42 Radian Corp., prepared
for Dames t Moore
I'hil Unng, KPA
Philip Johnson, VDOB
Phil Nil lam, P.I'A
BPA
Frederick L
, R1A
-------
Doc. i file
Jate_ t Pales Author^Oirganualion ______ Addr'essee/0rga*n| in
00000328. Other docutents
00000329. Other documents
00000310. Hells - water level leasureients
Unifori Hamdous Haste Hani feet 12/4/85
foris for Frontier Ciroie Project
Unifori Hazardous Vaste Manifest 6/5/87
fori
Grounduater elevations table, 6/24/86
Round I
3 Nike Blui, VDOB
I Sue Sims, VDOB
Z
-------
DOCUHBNTS DBL8TBD FROM FRONTIER HARD CHROHB ADHINISTHATIVB R8CORD
P°CJ_L_ P-'.-'A Tipe/Description _Reason ReBoved
00000292. Correspondence between State and Letter re Notice of Potential Liability Duplicate of Doc. (00000293
PRP (after 1983) for activities at Frontier Hard Chroie
00000293. Correspondence between State and Letter re Notice of Potential Liability Not relevant
PRP (after 1983) for activities at Frontier Hard Chroie
-------
APPE-DLX A.I
CITY OF VANCOUVER, WASHINGTON
City Haii 2'.0 East 13m St. - P. 0 Box 1995
Vancouver, Washington 98668-1995
November 5, 1987
of Ecology
and Square
Dave Rountry
Washington Department o
Mail Stop PV-11, Woodland Soua
Olympia, Washington 98504-8711
Subject: Frontier Hard Chrome
Superfund Clean-up Proposals
Dear Mr. Rountry:
After reviewing the Remedial Investigation and Feasibility Study
Reports and attending DOE presentation of the material held
November 4, 1987, the following comments are submitted for
consideration and a matter of record:
1. Clean up action j_s necessary.
2. Clean up remedies should begin at the earliest.possible time
to:
a) Eliminate further spread of contaminants and limit clean
up costs.
b) Remove the superfund contaminant problem as an obstacle
to economic development.
3. All highly contaminated soil (>550 ppm) should be either
removed or stabilized, but in either case the pit should be
refilled in a manner that results in a compacted and strong
base to carry normal surface loads and satisfy building
foundation needs.
4. The cap for the pit area should be an impermeable surface
and the adjacent parking and roadways should be paved along
with the installation of a storm drainage system to collect
all surface water in the immediate area of 1st and Y Street
and pipe the water away to an acceptable discharge point.
Water treatment eff;rt appears necessary only :o a limited
extent. Treatment ;-ould be given to the water currently
-> perched aquifer below the dry well
:;p.taminated and is exhibiting a yellow
: treatment work could be geared to allow
:'.±r into the sanitary sewer.
resting on top of
area that is high',
color. This limi'
discharge of this «.
-------
Letter to Dave Rountry
November 5, 1987
Page two
6. The city is strongly opposed to any water being injected
into Aquifer B. This Aquifer B is near drinking water
standards in much of the plume area. Disposal of treated
effluent could only act to further degrade water quality.
In such an injection option a malfunction of the treatment
device could result in highly contaminated effluent being
injected in a currently uncontaminated area of Aquifer B.
To even allow such a possibility is comparable to allowing
a water system cross-connection.
I wish to thank you for the effort given to correct this problem
in our community. I also wish to make my staff available to
assist with your final design elements, particularly with regard
to the paving and storm drainage considerations. Please contact
me at (206) 696-8187, or scan 559-8187, should you have any
questions.
Sincerely,
DHN OSTROHSKI, P.E.
"Director of Public Works
-------
APPENDIX B
FRONTIER HARD CHROME
PUBLIC HEARING
DATE TAKEN: November 4, 1987
TIME: 7:00 p.m.
PLACE: 605 North Devine Road
Vancouver. Washington
COURT REPORTER: TERESA RIDER FOSTER, RPR
RIDER & ASSOCIATES
COURT REPORTERS
P.O. Box 245
Vancouver. Washington 98666
-------
APPEARANCES
FOR THE DEPARTMENT OF ECOLOGY:
FOR THE EPA:
MS. LYNN BERNSTEIN
MR. DAVE ROUNTRY
MR. MIKE GALLAGHER
MS. CAROL FLESKES
MS. MEGAN WHITE
MS. PERRIN KAPLAN
MR. TIM BRINCEFIELD
MR. PHILIP HONG
ALSO PRESENT:
MR. BOB SMITH, Engineer
Bovay Northwest, Inc.
MR. KEVIN FREEMAN-
MS. JEANNE LAWSON
Dames & Moore
88 B I fl g.
NOV I 3 I98T
-------
1 MS. BERNSTEIN: Good evening, I'd like to start the
2 meeting now. I'm Lynn Bernstein from the Department of
3 Ecology, and on behalf of the Department of Ecology I'd like
4 to welcome you to the meeting of Frontier Hard Chrome.
5 We're going to explain several things tonight and
6 we're going to begin with explaining the Superfund process
7 and how it applies to the Hard Chrome facility. Also we'll
8 be explaining the remedial investigation, and we'll be
9 presenting the alternatives to correct the problems at the
10 site. We will also be answering your questions, which we
11 encourage, and we'd like to receive your comments on the
12 alternatives presented here tonight.
13 I hope everybody's received the packet that we had
14 out on the front table. If you haven't, please raise your
15 hand and Jeanne will pass them out.
. . . ....
16 In the packet you'll find a fact sheet that will
17 summarize most of what will be said here tonight.
18 The feasibility study and remedial Investigation
19 reports are also on the back table to be reviewed after the
20 meeting. Please note there is also a time schedule and
21 agenda In the packet. And it's a general guideline that is
22 flexible to respond to the progress of the meeting.
23 There'll be a specific time to talk about preferred
rs
24 alternatives and to ask questions. We'd like to separate our
25 clarifying questions first, and try and get those answered.
-'--;~'n';:''^rvv-';;*v~?;^v:^.i;«>^F.V-J:j;;-^^^^
-------
1 And then to make our comments after if more questions come uc
2 during the comment time feel free to ask them.
3 The entire meeting will be recorded by a court
4 reporter, and there will be a transcript of the meeting when
5 it's completed.
6 I would like to introduce the people here tonight
7 who are involved in the project, and we have Ecology staff
8 here who work as a team. I am Lynn Bernstein, and I do the
9 community relation on the site. We have Carol Fleskes, who
10 is a section head of our whole division for the industrial
11 site section. We have Mike Gallagher, who's a
12 hydrogeologist. We have Megan White who's our engineer. Ar
13 we have Perrin Kaplan back there who's our public informatic
14 person. We have Dave Rountry, who's the manager of the
15 project. And then from Dames & Moore, who's our consultant
16 contractor, we have Jeanne Lawson, who's in the back of the
17 room there who's our community relations specialist. And w
18 have Kevin Freeman, the project manager of Dames & Moore.
19 And from Bovay Northwest, we have Bob Smith, who's project
20 manager for those folks. And from EPA we have Phil Wong.
21 who's a project manager, who's been Involved with us.
22 And at this point I'll turn It over to Dave Roun1
23 from Ecology.
24 MR. ROUNTRY: Thank you, Lynn. I'd like to welc
25 you, and thank you for your attendance at the meeting
-------
1 tonight.
2 . The purpose of my discussion is preliminary to give
3 you a general background for the Superfund process as it
4 applies to Superfund sites in general, and specifically to
5 this Frontier Hard Chrome site; run down briefly what the
6 steps of that process are so that you'll understand how we
7 got to where we are today. Follow-up.on this overview of the
8 Superfund process with the a brief discussion of the Frontier
9 Hard Chrome history of operation, itself, and give you a
10 little better perspective gf how we entered Into the
11 investigation and study phase for this project.
12 The Superfund process starts with what we call a
13 preliminary assessment and site investigation. And these are
14 introductory steps to the evaluation of, the site to Identify
15 basically initial problems that may .lead us to more studies.
16 This provides us with a general base line of information from
17 which we can evaluate if the site is a problem and deserves
18 further consideration. . .,
19 Depending on the resulta of these activities, the
20 preliminary assessment and site investigation, we would move
21 to nominate this site to the National Priorities List. This
22 occurred for the Frontier Hard Chrome site, by applying a
23 hazard ranking system, a general grading system to evaluate
24 potential impacts of the site.problems to public health or
25 the environment. All sites are graded similarly, so that
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1 sites can be prioritized for government attention or for
2 cleanup actions.
3 It's at this point in the Superfund process on
4,
4 site"has been nominated to the National Priorities List, that
5 the potentially responsible party, that individual or
6 individuals that is potentially identified as being
7 responsible for the contamination, is invited to participate
8 in the design of the remedial investigation.
9 If the potentially responsible party declines at
10 that point, then the government would step in and conduct
11 site characterization studies themselves, which is the
12 purpose of the remedial investigation, to fully define and
13 characterize the problem, the scope of contamination at the
14 site.
15 Concluding these studies, we would move into a
16 feasibility study mode. Once the site Is fully characterize
17 there would be adequate information on which we could base
18 some decision or approach for a remedial or a cleanup desig
19 and selection of some remedial action for that site.
20 At the conclusion of the feasibility study, which
21 is the stage of the process that we are at now, we would
22 select a cleanup alternative. And of course the purpose fc
23 this public meeting is part of the public review and commei
24 process with Input from the public, Ecology will be in a
25 position to make a recommendation to EPA with respect to w
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should be the preferred alternative; what cleanup measures
should be taken at the site. As in most construction
projects, the construction would be preceded by engineering
and design. This is to fine tune the options, to identify
very specific technologies, conduct any final testing and
allow us us to proceed with the cleanup.
Cleanup, which is called remedial action. And this
involves carry out of that cleanup. Ones the site has been
cleaned to the satisfaction to meet the objectives, we would
move into an operation and maintenance phase, and the purpose
of this is to insure that the remedial action the cleanup
measures taken at the site would, In fact, take care of the
problems of contamination. That it would reduce Impact to
public health and the environment.
I'd like to move into a general discussion of the
history of the Frontier site operations-.
The site was the location of a chrome plating
operation from the mid-1950'a to 1983. There were two
ownerships Involved in this business during that time
period. During the latter part of this the site ownership
was called Frontier Hard Chrome. During the period of 1970
through 1976 waste or processed waste water from the chrome
plating operation was discharged to the city waste water
treatment plant. It was sometime in 1975 when it was
determined that the chromium content of that waste water was
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1 interfering with the biological processes of the waste water
2 treatment, and it was decided that that could no longer
continue.
4 The business operators approached the Department of
5 Ecology at that time and requested a waste discharge permit'
6 that they could then release that processed waste water to a
7 dry well on the site.
8 That dry well is basically a four foot in diameter
9 concrete pipe which was inserted In the ground to a depth of
10 approximately 10 to 12 feet.
11 The Department of Ecology did issue an interim typ
12 of a pretreatment of a waste discharge permit to the
13 operators. There was as condition of this permit, however,
14 that required pretreatment or treatment of that waste wa ~
15 prior to its discharge to the dry well. Plans and
16 specifications were requested in order that a treatment
17 system could be designed.
18 There were, during the'tlme period of the interim
19 permit, there were two extensions to allow, in order to all
20 the business to continue operating in that they were having
21 difficulty preparing engineering plans and specs for
22 treatment.
23 There were extensions provided that would allow
24 them to continue operation.
25 It was late in this time period, actually in 198
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I believe, Department of Ecology sampled waste water that was
being discharged directly to the dry well. The analysis of
that showed that chromium contamination would have classified
that waste as an extremely hazardous waste, as per the
requirements of the Washington Dangerous Waste Regulations.
It was approximately that same time water samples were
removed, taken from the PMC Corporation facility very nearby
the Columbia River, approximately a half a mile south,
southwest of the Frontier Hard Chrome facility.
Water samples taken from those locations showed
chromium concentrations in the range of approximately three
times the drinking water standards.
At. that point Ecology couldn't wait any longer for
designs, plans and specs for a treatment system, and there
were two regulatory orders issued to the facility, one
required that they discontinue discharge to that dry well
location, and secondly that they provide plans, a ground
water investigation plan to monitor conditions in the
immediate vicinity of the site to determine if, in fact,
there had been any impacts as a result of releases or
discharges to the dry well.
With the information gained during this process the
hazard ranking system was applied, hazard scoring system was
applied to the site. The site was assigned to the National
Priorities List. It was in April. 1985 that we actually
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1 began remedial Investigation or site characterization
2 studies.
3 I'd like to point out, here, that this is a
4 this particular case Department of Ecology is acting as the
5 lead. We are then called the site lead, as a state lead for
6 this project and some other projects EPA directs the work.
7 We, Ecology, are operating under a contract or a cooperative
8 agreement, specifically with EPA. obtain funding from them ir
9 order that we could procure a contractor to initiate the
10 remedial investigation.
11 And at this point I'd like to turn the floor over
12 to Kevin Freeman of Dames & Moore who will discuss the
13 results of their remedial investigation studies.
14 MR. FREEMAN: Thank you, Dave.
IS As Dave pointed out, I'm going to be talking to yc
16 about the remedial investigation phase of the RIFS
17 procedure.
18 The purpose of a remedial investigation at a
19 Superfund site is first and foremost to define the nature a
20 extent of the contamination at the site. And another very
21 important goal is to essentially provide sufficient level c
22 information on the technical Issues of the site to allow
23 feasibility study of potential remedial options to occur,
24 after the results of the remedial investigation are known.
25 So. when we start this process there's a couple <
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things that we do. The first thing is that we try to agree
we_ican't based on existing information to do a site history,
to define what we know about processes that are occurring on
site and waste management procedures to try to define what
the problems may be from a contaminant standpoint.
At that point we are really trying to define how
those contaminants could, through various pathways, enter the
environment and how those pathways could lead to exposures to
any local populous or sensitive environments in the area.
So, in order to do that we are really looking for
the kind of pathways that could lead to human exposure, or to
other kinds of environment exposures. The kind of pathways
we're looking for essentially are the possibility that the
contam.inants have entered the ground water, whether that
ground water is being used by anybody in the area, such that
they could be exposed to the contaminants in the ground
water, where the contaminants in any sense can become
airborne, such that any local populous or workers could
ingest the contaminants in the air, whether any of the
contaminants are in local surface water bodies in sufficie t
quantities to be of concern, and whether, for two reasons, we
look at whether the contaminants are in the soils at the
site.
On one hand we're Interested in whether any
incidental, although very unlikely types of exposures could
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1 occur through people ingesting any surface soils, eating
2 surface soils, particularly children, or whether and we
3 consider that to be a reasonably low probability event. BuTT
4 more"importantly from our standpoint in the soils in this
5 project, we're also concerned about whether the soils,
6 themselves, because of the nature of the contamination
7 involved here, could serve as what we call a secondary source
8 of contamination to the ground water. In other words, could
9 the soils bind up these contaminants, and at a later date
10 release those contaminants to the ground water.
11 So, those were the issues we were trying to ferret
12 out in this study.
13 This is a site map, and sounds like some of you ar
14 already quite familiar with the site, but just for those M
15 you who may not be.
16 The project site location Frontier Hard Chrome is
17 marked on this map by the star. One of the things that was
18 of concern were the locations of nearby wells, ground water
19 use sources in the project area, and I'd like to point those
20 out.
21 There was, as you've heard, there were wells at tl
22 PMC Corporation that were used for industrial purposes.
23 There was and there is a well, an irrigation well at the
24 Washington School for the Deaf. There were two Vancouver
25 well fields in the near field to the site area. To the nor
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1 of the site was Vancouver Well Station No. 1. and here we see
2 Vancouver Well Station No. 4.
3 So. the first thing we looked at was the
4 distribution of these contaminants in surface soils. And
5 what you see here is what's called a contour map. which shows
6 the distribution of the contaminants, and this is chromium in
7 the surface soils. Now, the contaminants we were looking for
8 primarily were what we call Inorganic contaminants. These
9 are essentially the metals and of course in a chrome plating
10 operation there's obviously chrome that is discharged in the
11 waste water stream. And secondarily we were looking fcr the
12 possibility of there being any lead or nickel contamination
13 associated with the project, site activities.
14 Far and away the contaminant of concern ended up
15 being chromium. The concentrations of the other potential
16 inorganics or metals at the site weren't that significant.
17 Chromium is the concern at that site.
18 And what you see here Is a map of chromium
19 contamination in surface soils at the site, primarily in the
20 upper 18 inches of the soil profile.
21 You can see that there Is this is the Frontier
22 Hard Chrome building, with the dry well out front. What we
23 found were high concentrations, the concentration here is in
24 parts per million, so the numbers, I'm not sure whether you
25 can read these numbers In the back, but essentially this say
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1 a hundred, a thousand up here, those are in parts per
2 million. Chromium in parts per million in the surface soli.
3 And you can see there's a high area around the front of tTTf
4 Frontier Hard Chrome building, and another high area out her
5 in the bog area, and we think that there was a discharge lin
6 that went out to that area at some time during facility
7 operations, and so this shows you where the high areas are i
8 terms of chromium concentrations on the site.
9 Try to keep this in mind when we discuss the
10 potential remedial actions, because it's based on this
11 information that we select remedial actions that are
12 appropriate for the site.
13 We mentioned we were also looking at subsurface
14 soils. This is a cross section through subsurface soil
15 the site. You can consider this to be a vertical slice
16 through the soil profiles, through the soils that exist in
17 the subsurface at the Frontier Hard Chrome site. What we s
18 on this site is this shows several things, one we do have
19 water, which isn't surprising in the Columbia River flood
20 plain. We have water from about here on down, this is the
21 water level. Up here we see perched ground water in the f
22 zone. Perched ground water means something that aits on
23 something that isn't part of the full ground water table.
24 have some water sitting on top of what we call an acquitar
25 that's a technical term that means a unit that doesn't
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1 transmit water vertically very easily, so water tends to move
2 slowly through that unit. So It's not surprising to see some
3 water sitting on top of it.
4 Below it we have a very complex system of soils.
5 but we were able to identify an acquifer system or a water
6 bearing system which had two distinctive transmisslve zones
7 in it or zones that would provide water at differing rates.
8 We called them the Level A zone and the Level B zone. And
9 what you see up here is the Level A zone, down here is the
10 Level B zone. They're separated by a discontinuance soil
11 environment which again has properties that make it difficult
12 for water to pass.
13 What that tended to do on site, then, is
14 essentially water that's coming vertically down, would tend
15 to move very slowly vertically, here, and more quickly in a
16 horizontal direction, until It could find a way down into
17 this lower zone.
18 This stratigraphy, or this subsurface soil profile
19 is very Important in terms of understanding what the
20 distribution of contaminants in the subsurface on site is and
21 I'd like to show you that next graph for that.
22 This is a more detailed graph, and X recognize that
23 you can't see all the numbers, here. What these vertical
24 lines represent are well installations. This is a west to
25 east cross-section across the site.
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1 I'd like to point out to you this is the Frontier
2 Hard Chrome building shown here. Over here is the dry we 11^
3 location. And over here is the bog.
4 Now. you might ask why is the bog there, we
5 mentioned this zone that didn't transmit water very readily"
6 it congregates over here in the bog. so that's why the water
7 can tend to pond over here.
8 So, you see here again the same stratigraphy we
9 talked about earlier. The numbers that's it's difficult for
10 you to read are chromium concentrations In the subsurface
11 soils.
12 Is what we see are very high concentrations of
13 chromium in this upper acquitard unit, this zone that doesn'
14 transmit water very readily, it tended in here were s
15 particles and organic soil particles that tended to grab on
16 to the chromium as it was deposited into the soils.
17 We have very high concentrations of chromium in
18 this area. Upwards, in one case, here, the chromium
19 concentrations are 17 thousand parts per million. So, ther
20 is significant soil contamination in the subsurface.
21 We also looked at water, what were the effects of
22 the disposal practices on ground water. We mentioned that
23 there was a Level A acqulfer zone, and a Level B acquifer
24 zone. We wanted to look at what the effects in ground watc
25 were in both of those zones.
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1 This is the Level A zone, and again this is called
2 a contour map. What this shows, what these lines represent
3 Internal to each one of these lines the concentra*'ons are
4 higher than the numbers shown on the line. So. for instance
5 this is .05 parts per million here, from this line to this
6 line the concentration of chromium increases from .05 parts
7 per million to .1 part per million.
8 Now, the interesting point on this particular
9 concentration diagram is we have very, very high
10 concentrations, very high Concentrations of chromium in
11 ground water beneath the dry well and In the immediate area
12 of the dry well here. The. numbers here exceed one hundred .
13 parts per million in ground water. The drinking water
14 standard la .05 parts per million. So, what that says.to you
15 is that we the ground water in the Level A acquifer
16 underneath this site exceeds drinking water standard
17 everywhere inside this outside line. This is high 14, here
18 is the PMC well, here.
19 We mentioned a Level B acquifer zone, this is the
20 deeper one. So, that was shallower ground water we saw
21 before, down around 20 feet. This is a deeper zone around
22 thirtyiah feet. What we see here, a similar type of profile,
23 but you'll notice that we don't have the same kind of high
24 concentrations of chromium in ground water.
25 The m-. Jor concentrations here, the highest
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1 concentration in this diagram is about .35 parts per
2 million. So. there's a significant difference in
3 concentration from the Level A acqulfer, to the Level B
4 acquifer. Remember in Level A we were looking at
5 concentrations in excess of one hundred parts per million.
6 But again, this is the .05 part per million contour line, anc
7 everywhere inside this line the Level B ground water exceeds
8 drinking water standard.
9 So, what does all this mean? Hell, from the
10 remedial investigation standpoint I'll summarize this way.
11 We did look, as I mentioned, we looked at air, the
12 concentrations of chromium in air. We looked at the.
13 concentrations of chromium in a couple of spots in surface
14 water that was ponded in the area. Those pathways for huaar
15 exposure do not appear to be significant. There doesn't
16 appear to be a high level of risk to the local people or
17 workers based on surface soils in terms of breathing in the:
18 contaminants or in the surface waters from these
19 contaminants. Surface water does tend to pond in this area
20 and drain into that bog. And by the way, I should point ou
21 if you want to take a look at the bog and whatnot, we do ha
22 a bunch of air photos around here where you can take a look
23 at some of these site features from the air. What is obvic
24 is there is significant concentration of chromium, both in
25 surface soils and in subsurface soils. And we have
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significant concentrations of chromium In ground water under
the site.
Now. we are concerned about the concentrations in
soil as they might lead to additional contamination to the
ground water. And what you'll see is. If you remember, there
was very high concentrations in the surface near that upper
acqultard level on the Level A. We'll have to do something
about that, we'll hear about that later. Remember, there's
high concentrations at the level of that high acquitard. In
the ground water, they exceed drinking water standards. So.
we have to do something about that. He have to look at that
and come up with remedial actions that-address that. And
those are the important parts of the work that we've done in
terms of the remedial investigation. .
And with that, I'd like to pass it on to Bob Smith
of Bovay, to tell you how we're going to address those
issues. Thank you. .--
MR. SMITH: Thanks, Kevin.
Again, my name.,is Bob Smith. I'm with Bovay
Northwest, we're the engineering consultant to the
feasibility study to Dames & Moore and the Department of
Ecology^ ...
And what I'd like to discuss this evening is the
engineering feasibility study process. The purpose of a
feasibility study process is to determine the most cost
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I effective action that may be required at a hazardous waste
2 site, for alternatives that meet the specific site objectives
3 for that site, and in the case of Frontier Hard Chrome w^
4 talking about public health and protection of the
5 environment.
6 The process begins by developing a list of
7 potential alternatives, using technologies that address the
8 contaminants on the site, that are specific for this
9 particular site.
10 Then we screen that long list of alternatives base
11 on their ability to reduce the contaminants, either their
12 mobility, they're toxicity or their volume.
13 During this process we estimate the costs of the
14 various alternatives, and we also use that in our screening
15 process.
16 And at the end we end 'ip with a handful of final
17 alternatives that are the most cost effective and meet the
18 objectives for that site and that really have application £
19 Frontier Hard Chrome.
20 An important part of the feasibility study proce:
21 is to develop specific cleanup objectives for this for
22 particular site. In the case of Frontier Hard Chrome we w
23 looking at protection of public health and the environment
24 protection from contaminants that would be found in the du
25 and on site soils. Me were looking at the inorganic
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1 contaminants, specifically the metals, in this case chromium,
2 a little bit of lead and nickel. We were looking at
3 protection from the organic contaminants, which are more
4 commonly called solvents. I think I'm going to switch to
5 this side, I think we have more people on that side.
6 We're looking at protection of the existing public
7 water supplies, and potential future water supplies;
8 protection of surface water, such as the Columbia River;
9 protection from ingesting vegetation, say maybe blackberries
10 that children or people might eat that grow on the site.
11 And an overall objective Is prevention of further
12 migration of contaminants, whether they be In the soil -or in
13 the ground water.
14 Part of the feasibility study process is completing
15 an Bndangerment Assessment. And an Endangerment Assessment,
16 purpose of an Endangerment Assessment is to estimate the
17 public health Impacts that might occur from the contaminants
18 that are on the site. For example if someone's drinking the
19 ground water at a particular concentration, or if they're
20 involved with the surface water, or if they're inhaling the
21 soil, the dust, maybe ingesting some of the soils on the
22 site, or possibly eating the vegetation, the blackberries and
23 that type of thing that grow on the site.
24 The Endangerment Assessment showed a very low risk
25 to public health and the environment, to the general public,
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1 as the site currently exists.
2 However, there were a couple of potential
3 exceptions to that. One being that if a new water supply
4 inadvertently developed in the high chrome concentration
5 area, we would certainly have a significant public health
6 impact.
7 Secondly, there's the potential for impact to
8 higher risk groups such as small children, maybe if this use
9 of the site was changed into housing or condominiums, if that
10 ever happened, you could expose children and things to highet
11 concentrations and potentially face some public health
12 impacts.
13 The final alternatives that were developed
14 basically fall into about three catagories. And I realize^
IS that if you read the report these three catagories aren't
16 specifically called out in the report, but for simplicity an
17 putting together the presentation, I like to present them
18 this way, and if you'd like to refer to the fact sheet on th
19 back, and to Table 1 and 2 on the back, you'll see the same
20 breakdown I'm discussing now, and will also give you a
21 cross-reference to which specific alternatives they are
22 addressed in the feasibility study.
23 The final alternatives fall into a no action
24 alternative, as one of them. And no action means that
25 there's no remedial cleanup or on the site, there's
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1 nothing done with this soils or with the ground water.
2 However, part of that would be in monitoring program to
3 monitor the plume, monitor the contaminants in the ground
4 water; are they moving to the river, are they moving to the
5 Vancouver wells, where are they going. And it would also
6 include some institutional controls to prevent housing from
7 being developed on the site, and that type of thing.
8 The second group of alternatives is what I'm
9 referring to as source control alternatives. And these
10 involve both surface soils, the top foot and a half, and
11 subsurface soils, which takes us down to about 20 feet below
12 grade.
13 The ground water control alternatives are grouped
14 into a couple of alternatives, one where we would remove
15 ground water, treat it and reinject it Into the deep
16 acquifer, the Level B acquifer, it would be treated to
17 drinking water standards and be reinjected. And the second
18 one, too, would be treat the ground water and discharge it tc
19 the Columbia River.
20 First I'm going to discuss the source control
21 alternatives. You might think of them as the soil control
22 alternatives.
23 This exhibit represents a range of alternatives,
24 from no action, and you'll notice there's some dollars
25 related to no action, this is the monitoring program. And
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1 these costs represent the present worth costs of a 15 year
2 program. And they range through doing things with surface
3 soil to handling surface and subsurface soils, whether the^^
4 are be removed and disposed of off site or treated in some
5 manner.
6 The alternative of removing surface soil only would
7 look something like this, on a site plan. And if you'll
8 notice, this little area here represents the area of soil
9 that approximately exceeds the 550 parts per million of total
10 chrome, there's a little area over here in the depression
11 area, that also exceeds it, and under this alternative those
12 soils would be excavated and removed and disposed of .off sit
13 and clean fill would replace them.
14 Also part of the alternative would be a cleaninj^i
15 washing of the Frontier Hard Chrome structures, itself.
16 A little further up the line as far as soil contrc
17 alternatives is the alternative I'm calling stabilize all
18 soils. And this alternative we would remove surface soils
19 and subsurface soils that have total chromium greater than
20 550 parts per million. These soils would be mixed with a
21 cement type of material, a lime, fly ash, and the idea here
22 is that we keep the contaminants in the soil column or in t
23 soil matrix, itself, and we replace it back into the
24 excavation, so we leave the contaminants on site but
25 basically tie them up so they don't leach and percolate an<
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1 migrate down into our ground water.
2 This alternative looks something like this on the
3 aite plan. You'll notice it's a much larger area, because
4 we're talking about that clay zone that Kevin referred to
5 earlier that's about 20 feet below surface. That's where the
6 high concentration of chromium is in the subsurface soils.
7 We're talking about a much larger area, this would be a pit
8 about 20 feet deep. The soils table would be taken over to
9 the area, mix them and blend them with the additives and
10 cement or whatever alternative we choose, if this is the
11 chosen alternative. And they would be replaced and impacted
12 back in the fill area. And also the area in the depression
13 that would be addressed.
14 A more expensive alternative is what I call here
15 the leach/treat all soil alternative. It's about three times
16 more expensive. It's a similar alternative to the
17 stabilizing alternative, except we'd excavate the surface and
18 subsurface soils, and basically wash them. We rinse it with
19 an acid rinse, and that takes the chromium out of the soil.
20 puts it in the liquid phase, and we have to treat the liquid
21 to remove the chromium, ^nd the "cleaner soils" are replaced
22 back in the excava m.'
23 That alternative looks very similar to the
24 stabilization alternative. Again, we're talking about the
25 same area for excavation, the same amount of material. And
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1 we'd have to have a little soil treatment area to handle the
2 materials and grade the materials and wash the soil.
3 Another alternative that has been investigated
4 the report is the remove and dispose all soils alternative.
5 And this alternative would excavate the soils greater than
6 550 parts per million, and the soils would be disposed of on
7 or off site in an appropriate land fill type situation. And
8 then clean fill would replace the excavation.
9 One item that you need to note here in regards to
10 all the alternatives that remove all soils is that we
11 encroach significantly into the Frontier Hard Chrome
12 building, and if that is a chosen alternative, we would have
13 to remove and dispose of the building, as well.
14 Moving on to the ground water cleanup alternatives
15 Again, in reference to ground water, there is af^"
16 alternative of no action, doing nothing with the ground
17 water, other than natural dilution. This alternative
18 would may be done in conjunction with a soil cleanup
19 alternative. In other words you may have a soil cleanup
20 alternative and do nothing with the ground water, that's wha
21 this refers to.
22 Two alternatives for removing and treating ground
23 water are to remove the ground water, pump it out to the
24 ground, treat it to essentially drinking water standards, ar
25 then reinject it into the Level B acquifer.
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When we remove the ground water we're talking only
about cleaning up the Level A acquifer, the shallow
acquifer. It is very, very expensive to even think about
cleaning up or pumping out and treating the Level B acquifer,
and for cost purposes relative to the incremental increase in
benefit, it has not been considered as a final alternative at
this time.
The second alternative for handling the Level A
acquifer zone is to remove the water, pump it out, treat it
to better than drinking water standards and discharge it into
the Columbia River, into a surface discharge. The
approximate costs for these alternatives are very similar.
The treat and relnject is about 12 million 9
hundred and some thousand dollars, again, over a 15-year
period.
The treat and discharge is about 12 million 866
thousand dollars, again, present worth over a 15-year period.
Any of the pump and treat alternatives of Level A
would be done in two phases. The first phase would Install a
series of withdrawal wells in the very highly concentrated
area Inside the ten part per million contour zone. And the
highly contaminated ground water would be pumped out, treated
and then either discharged to the Columbia or reinject into
the Level B zone.
A second phase would follow that, and you need to
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1 adjust your reference here, as far as scale. This is a much
2 larger scale map. We would expand the withdrawal well field
3 significantly, adding some additional wells and a much 1< r
4
4 area.' This contour line here represents drinking water
5 standards, in other words inside the area we exceed drinlcirvg
6 water standards, outside the area we currently meet drinking
7 water standards. So, we would pump and treat this water in
8 the Level A zone, and again treat it to drinking water
9 standards or slightly better for discharge to the Columbia
10 River.
11 The treatment technology exists for ground water
12 treatment. We're probably looking at an ion exchange proces
13 to remove the chromium. This is a standard water treatment
14 process, a proven process, it's been around for years and^
15 years, and basically it's like a water softener in your
16 home. It can handle the volumes of water we're talking
17 about, it can also meet the discharge requirements that we' i
18 talking about, the drinking water quality standards.
19 If we went to a surface water discharge, we've
20 explored some preliminary routes to get from Frontier Hard
21 Chrome down to the river for an outfall. There's a couple
22 different ways to go, either a pressure line or a gravity
23 line. These are alternatives that are being reviewed at th
24 time.
25 And what I'd like to do is turn the meeting over
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Dave Rountry, who will discuss their thoughts on some of
these final alternatives.
Dave?
MF. ROUNTRY: Thank you, Bob. Ecology and EPA have
chosen to divide the decision ma Icing process for the cleanup
approaches into two directions. And as Bob indicated the
logical way to split this has been to look at source control,
soils removal and to look at ground water cleanup.
This was done because Ecology la prepared to make a
recommendation to EPA after we've evaluated public comment
with respect to the source control cleanup. And very
Importantly we need to continue to make progress at this
site.
By handling a source control alternative decision
at this time it will allow some remedial action to move
forward. A decision regarding a cleanup approach, if that's
necessary for the ground water would be addressed at a later
time; in fact, this coming spring.
We're not prepared. Ecology is not prepared to make
a final recommendation to EPA at this time with respect to
any of the ground water cleanup alternatives. We need to
evaluate the Impact of our new, the state toxics law, and how
we satisfy the intent also of the federal law. EPA and
Ecology do need to be in agreement, in order that we can be
able to implement this in a cost effective manner. A concerr
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1 is that the Superfund requirements apply a ten percent cost
2 share measure to any remedial action that the state would
3 state's participation in costs of cleanup or remedial act
4 would be ten percent of the total cost, then EPA's cost would
5 be 90 percent. Of course this presumes that there would be*
6 no funding of the remedial action by the responsible parties.
7 This split decision process would provide for a
8 decision or a Record of Decision on EPA's part by December
9 31st of this year. And again, a decision would be handed
10 down by EPA with respect to an appropriate ground water
11 cleanup approach sometime In spring of 1988.
12 I'd like to talk a little bit about the source
13 control portion of the cleanup. You'll recall from Bob
14 Smith's talk the alternatives for source control range frt
15 surface soil cleanup option, clear to an option that would
16 involve surface and subsurface soil removal. Just to refres
17 your memory, these were the costs of the various source
18 control options, as presented by Bob.
19 This source control approach would be to meet an
20 objective to primarily reduce or stop further contamination
21 of soil contaminants to the ground water and secondly to
22 reduce a potential for health risks due to contact with
23 surface soils.
24 Ecology's preferred alternative at this point, an
25 what we are recommending for your consideration primarily i
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, 3'.
1 to stabilize, to remove and stabilize surface and subsurface
2 soil. This would effectively stabilize the contaminants
3 within the soil, it would effectively bind the chrome, so it
4 would not be available to the environment. It would reduce
5 further migration of chrome to the ground water.
6 It appears to be a cost effective approach, and
7 most importantly this approach is protective of public
6 health.
9 I'd like to review the alternatives for ground
10 water cleanup. The primary objective for ground water
11 cleanup is to reduce the risk to the public through the use
12 of any contaminated drinking water. But I'd like to back up
13 for just a second and remind you that the existing plume of
14 contaminated ground water does not currently and is not
15 anticipated in the future to impact current or existing
16 drinking water supplies. Nonetheless, both the federal and
17 the state ground water protection requirements identify
18 drinking water standards as an applicable cleanup standard
19 where there is potential for use of water for drinking water
20 source.
21 We're also committed through the Superfund laws to
22 implement a cleanup of the acquifer and a cleanup of the site
23 in general to the "maximum extent practicable".
24 The range of ground water alternatives that I'd
25 like to address briefly, and they're identified on this
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1 chart, cover, again a range of alternatives that are
2 practicable and they would meet drinking water standards.
3 You can see from this graphic that the different
4 is, difference in these cleanup alternatives is in the cost
5 and in the time to achieve drinking water standards. In the
6 far left column is a description of the alternative, the
7 total cost, then, and then the time to clean up the Level A
8 and the Level B portion of the acqulfer.
9 I should point out, too, that each of these
10 alternatives or reflect again the point made in earlier
11 presentations, that all of these alternatives would be
12 preceded by a source control cleanup alternative. There
13 hasn't been much logic that would lead ua to a decision to
14 pump and treat ground water or to pursue a ground water
15 cleanup without removal of the source of contamination of
16 chrome in the soils. It's very likely to and we'd anticipa
17 that because of the time period at a minimum to achieve
18 drinking water standards of IS years that during this time
19 period there would be a need for some zoning requirements o
20 some land use restrictions in the area of the contaminated
21 drinking water plume. The purpose being to restrict ground
22 water access or restrict construction of wells from access!
23 that ground water for drinking water purposes.
24 And secondly, there's potential that there would
25 need to be some restriction of any construction activities
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1 that might disturb or interfere with soil stabilization that
2 would have occurred previously.
3 So, we call these land use restrictions and zoning
4 ordinances institutional controls, and it's very likely that
5 institutional controls would be necessary as part of these
6 ground water alternatives and, in fact, including source
7 control.
8 EPA's preference, as far as a choice of a ground
9 water cleanup alternative, is to expedite this process, and
10 to implement a ground water extraction and treatment scheme.
11 one of these alternatives.
12 Ecology's preference at this point is to rely on a
13 source control measure, the benefits of that have already
14 been described. Again, both agencies are planning to
15 evaluate further the need for ground water cleanup to define
16 appropriate levels and a time frame for cleanup.
17 We will very much appreciate your comments
18 regarding these alternatives, plan to Include them in
19 consideration, in Ecology's consideration, so that we can
20 prepare a recommendation to the Environmental Protection
21 Agency, with a recommendation for final cleanup alternatives
22 at the site.
23 So, we would appreciate your help In moving us
24 towards that decision. I sincerely request your comments.
25 That's all I've got and I'd turn the floor over to
... ..... ,. j.,,,.,,.^...,,x,_......,< ,I.^,.,. .*--/-'^vv-..,.?^*,w.^.w.^.;.r,^
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1 our moderator again, Lynn Bernstein.
2 MS. BERNSTEIN: At this point, we encourage people
" ~ ^^»
3 to ask questions. We know that the site has got a lot of^^
4 media attention lately, and we want you to ask questions and
5 clarify any concerns you have now, and please hold your
6 comments until we've finished responding to the questions,
7 and then we'll have more formal time when you can come up to
8 the front and give your comments.
9 Once you ask a question, I'll repeat it to make
10 sure that I've got it straight and then I'll refer it to one
11 of our technical staff. If anybody wants to raise their
12 questions.
13 MR. JONES: Yes. I have a whole bunch of questions
14 I'd ask Mr. Rountry. Mr. Rountry, I have in hand the
15 document, a part of a document that is dated October of
16 1984. And this document says in part relating to the
17 Frontier Hard Chrome site, that chromium, including the mor«
18 toxic hexavalent form has been detected In industrial and
19 drinking water well three-tenths of a mile from the site.
20 Now, I want you to tell me here tonight, so it's on record,
21 and we can take it to Washington, D.C., where there was a
22 drinking water well that was contaminated to any extent by
23 chromium.
24 MR. ROUNTPY: Mr. Jones, I'm not able to answer
26 that question. I have been involved on the site for
'V-^V^-i^.VV^V/^'iVi^^
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. 35
1 approximately a year and a half. But there are folks here
2 with Ecology staff who have been working on that site, have a
3 more complete understanding. I would like to refer --
4 'MR. JONES: I'll refer to them and ask them to
5 point out, because we have Investigated this, and have found
6 no place where there has been any chromium pollutant beyond
7 the standards of the EPA in this community, and I want to
8 know where you were directing this, where the DOE was
9 directing this.
10 MR. ROUNTRY: I'd like to refer your question to
11 Mike Gallagher, a hydrogeologist of our team.
12 MR. JONES: I'd like to hear from Mr. Gallagher.
13 MR. GALLAGHER: What document do you have in your
14 hand, there, sir?
15 MR. JONES: I have in hand the information that
16 went in to the federal government. And this is a part of
17 it. It's a part of a National Priorities List site. And
18 some kind of a document was prepared and sent in. And we
19 have information that when it was first released that the
20 people in Washington, D.C. said they weren't going to put
21 this site on the priority, and then they sent in information,
22 and this information stated that drinking water well about
23 three-tenths of a mile from the site, and drinking water for
24 ten thousand Vancouver residents is drawn from the same
25 acqulfer.
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... 36
1 MR. GALLAGHER: That's correct.
2 MR. JONES: I want to ask a question about that.
3 How deep are the wells that Vancouver draws the water fror
4 MR. GALLAGHER: I believe approximately 80 feet.
5 MR. JONES: Have you tested 80 feet at the site?
6 MR. GALLAGHER: At the site, no. But we've
7 tested
8 MR. JONES: Why wouldn't you test at the same depth
9 if you were wanting to be fair about your analysis of the
10 condition?
11 MR. FREEMAN: Have you read the remedial
12 investigation report, sir?
13 MR. JONES: I have looked at it.
14 MR. FREEMAN: I think you'll find that the wellj
15 are producing from the same horizons. We do report that In
16 the report. And, you know, what we have found through the
17 course of this investigation is that those wells are what we
18 call upgradient of the contamination. Which is why at this
19 point in time we don't feel that those well fields are
20 threatened. It has nothing to do with their position in tht
21 column. It has to do with where they are relative to the
22 ground water gradient.
23 MR. JONES: Dave, I'm sorry, I don't remember you
24 last name: Dave, your first name?
25 MR. P'UNTRY: That's correct.
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I . , 37
1 MR. FREEMAN: My name is Kevin. Kevin Freeman.
2 MR. JONES: All right, Kevin. I want to know who
3 it was that released this information to the National
4 Priorities to get it to the priorities list that there was
5 any well in the area that showed chromium content, drinking
6 water well. Because that's what we're talking about, is
7 drinking water, isn't it?
8 MR. FREEMAN: I think that it may be I don't
9 have the document in front of me, but there may be a problem
10 in terms of the way it was stated. The fact is that a
11 drinking water acquifer has been contaminated with chromium.
12 And the purpose of this investigation was to determine -
13 whether there was threat to existing ground water supplies
14 based on that contamination. What the investigation has
15 shown, and what was not known then is that those wells are
16 upgradient from this source, but it was clearly a problem, a
17 potential problem, and it needed to be addressed, and was
18 appropriately addressed.
19 MR. JONES: You mentioned the word potential
20 MS. BERNSTEIN: Excuse me, sir.
21 MR. JONES: Have you checked with the city water
22 department to determine whether or not they have ever
23 detected any chrome, traces of chrome in their water supply?
24 MR. FREEMAN: Yes.
25 MR. JONES: And have they?
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1 MR. FREEMAN: No.
2 MR. JONES: So that we have a situation here, if I
3 can put it in proper perspective, ao that they close dowr
4 this'operation over three years ago, and here we are in 1987
5 and you're coming forward and proposing that millions of
6 dollars of public funds be spent when there isn't a single
7 incident of anyone who's health has been Impaired or where
8 the environment has been impaired.
9 MS. BERNSTEIN: Excuse me, air.
10 MR. GALLAGHER: I would object as to whether the
11 environment's been impaired. For instance, the acquifer the
12 is directly underneath Frontier Hard Chrome is a drinking
13 water acquifer, it is the same general acquifer that is par-
:!
14 of what the City of Vancouver taps out of Hell Field No
15 It's the same acquifer. That's the environment.
16 MR. JONES: Nobody is drawing any drinking water
17 from that acquifer.
18 MS. BERNSTEIN: Excuse me, sir.
19 MR. FREEMAN: The plain and simple fact is people
20 are drawing drinking water from that acquifer. And one of
21 the things that has to be addressed here, it may be a
22 misunderstanding on your part, but when water wells are
23 pumped and produced, they have an effect on the gradients,
24 the way the water flows in the site area. One of the
25 purposes of this investigation was to see whether the pump
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had a sufficient effect a high enough effect on the
gradients or the way water flows in the area to put those
drinking water supplies at risk. And there was no way to
know'that a priori, information had to be gathered to
determine that. Information has been gathered, the facts
have been reported to you, and you will not see anywhere in
that RI where it says that well field No. 1 or well field No.
4 are at risk.
MR. JONES: What you're saying, then, is that by
virtue of your testing, and the knowledge that you now have,
that there is no potential hazard to the city water supply
pumped from that area?
MR. FREEMAN: That's correct.
MS. BERNSTEIN: Excuse me, sir.
MR. JONES: Yes, dear.
MS. BERNSTEIN: This is for quick clarifying
questions, and I'd like other people to have the opportunity
to speak.
MR. JONES: I have a lot of more questions, and I'm
a citizen and a taxpayer. I thought this was a public
neeting where we could
MS. BERNSTEIN: Could I finish, please?
MR. JONES: You know, the only way that you can get
evidence I'm an attorney of 53 years practice in this
state, 36 of which was in the prosecutor's office. I know
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1 that what you have to do in the first instance is get
2 facts. And not speculation about oh, if something happens
3 somebody might be affected. I want to know from these pea
4 what testing they have done, and what they have actually
5 developed that is a hazard, existing hazard realistically.
6 Now, I want to develop that.
7 MS. BERNSTEIN: I would like to just explain our
8 process to you, how we're conducting this meeting. That
9 it's fine for you to ask questions, I'd like other people to
10 have the opportunity to speak. We have to be out of this
11 room at a certain time, so if you want to ask a few
12 clarifying questions, now. Could I please finish?
13 MR. WALTER NETH: I yield my time to him.
14 MS. BERNSTEIN: I would like to finish my
15 statement. First we'd like to ask questions, and then tnvre
16 will be an opportunity to give comments and during the
17 comment time, we'd like you to summarize your comments and
18 all the long written text, if you have a lot of comments wi
19 be included in the text, will be included in the transcript
20 of the meeting, and what we would like now is quick
21 clarifying questions, and then summarized comments, what yc
22 feelings are in summary, and then the complete text that yc
23 have will be included in the transcript.
24 MR. JONES: Well, I'm not entirely without some
25 knowledge about these things, because I've given a good de
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1 of time to making a study of the situation.
2 MS. BERNSTEIN: Could I
3 - MR. JONES: And I've also given a good deal of time
4 to making a study of whether or not there is a hazard
3 existing which requires any remedial action in the
6 expenditure of the amount of money that you've been talking
7 about here tonight. And I think as a citizen I'm entitled to
S that.
9 MS. BERNSTEIN: Could I Just ask that if anybody
10 has questions
11 MR. JONES: I'll defer, I'll shut up for a minute.
12 MS. BERNSTEIN: We can come back to you, but I want
13 to give everybody the opportunity to speak. And then we have
14 until 8:40 before we take comments.
15 MR. NISSEN: I'd like to ask a question, I guess,
16 of the group at large. Is there anyone in attendance here
17 tonight who does not have either a business or a vested
18 interest in this, in other words is there anybody that would
19 qualify as a disinterested citizen that came by to see what
20 was going on?
21 MR. ROUNTRY: I believe we're all interested in the
22 site.
23 MR. NISSEN: So there Is, in essence, no public
24 attendance at this meeting, is that correct?
25 MR. GALLAGHER: We're all public.
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1 MR. NISSEN: We are all salaried people on this
2 thing.
3 ~ MS. FLESKES: We are, but what about the rest of
4 you?
5 MR. NISSEN-. We're not.
6 MR. GALLAGHER: But you're public.
7 MR. NISSEN: We are the public.
8 MS. LAWSON-. I think what he's asking of anyone
9 sitting out here, is there anyone that's not an interested
10 party, either through business or I don't want to steal
11 your question from you, but it was an interesting question.
12 MR. NISSEN: Basically is there an interested
13 public citizen here who is concerned about his water supply?
14 I'm open. Does an ndy care is what I'm asking, in
15 Vancouver.
16 MS. BERNSTEIN: Anybody want to raise their hand?
17 Are there any other questions? Could you please
18 come up here by the microphone and give your name, please,
19 and ask your questions from here, by the microphone.
20 MR. GILMORE-. I'm Mike Gilmore, I'm the manager c
21 Angeles Metal Systems, who is the tenant of the facility at
22 this time. I'd really like to know who wrote this article
23 which department.
24 MR. ROUNTRY: Are you referring to a fact sheet
25 presented recently to the public?
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1 MR. GILMORE: That's correct.
2 MR. ROUNTRY: That was a joint agency publication.
3 Itcarries the letterhead of the Department of Ecology.
4 MS. BERNSTEIN: There has been a revised edition.
5 MR. GILMORE: Very similar. It says here the only
6 potentials to the workers who are occupying the building, to
7 those working on the facility. Directly below that is a
8 controversy to that statement, saying it's below industrial
9 standards. I'd like to know tonight, is there any risk of
10 our employees at this facility or not? And if so, what are
11 those risks?
12 MR. ROUNTRY: Mike, I know as foreman of Angeles
13 Metals, you're familiar with the occupational standards. Our
14 Endangerment Assessment conducted regarding the contaminants
15 at the site show that the contaminants do not exceed
16 occupational standards for risk to your people.
17 MR. GILMORE: But you said here in your statement
18 there's a potential risk, what is that potential?
19 MR. ROUNTRY: I'd like to refer your question to
20 Megan White, an engineer on our project team.
21 MS. WHITE: I think when we're talking about
22 potential there is when we were doing the Endangerment
23 Assessment to try to evaluate health risks on the site, air
24 samples were taken from inside the building and were
25 determined to be below occupational standards. And there was
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1 sampling conducted outside, and modeling of the soil
2 concentration in the surface to try and assess any potential
3 ait- exposure hazard outside of the building. And the
4 Endangerment Assessment showed that there was essentially
5 there was very little risk associated with either inside or
6 outside the building. However, there was the model was
7 not able to address a potential for short-term exposure, and
8 that's really why our source control alternative includes
9 removal of the surface soil to fix any potential that may
10 exist for short-term exposures.
11 MR. GILMORE: What are those short-term exposures
12 you're talking about, somebody eating the soil or eating the
13 bricks?
14 MS. WHITE: No, we did not the health assessmen
15 conducted did not show a potential problem due to soil
16 ingestion on the site. The potential for short-term
17 exposures would be. for instance, exposures due to trucks
18 moving on the site in excess.
19 MR. FREEMAN: In other words breathing.
20 MR. GILMORE: There's probably a hundred trucks a
21 day going by the site, as you know, as you're working thert
22 there is continuous workers on the site. And also you wert
23 there, there is monitoring machines on some of our employe
24 and they were on the buildings in the dusty areas and
25 outside. Now. if these all showed below, where's the
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potential?
MS. WHITE: Like I said, that's a very, very
conservative assumption, so it would be a conservative
approach to take in removing the contaminated surface soils.
And also those surface soils act as potential contaminants to
ground water, which is where our real concern is focused.
HR. GILMORE: Your recommendations at this time are
for us to evacuate the building, is that correct?
MS. WHITE: That's not my recommendation.
MR. GILMORE: The statement you've made here in
this paper, the liability leaves us in an awful bad spot with
our employees. Now, either somebody's got to correct the
statement saying the facility is safe for workers to be in or
it's not safe. It cannot be a possible.
MS. WHITE: I think at this point I'd like to hand
it back to you, Dave, because you have talked to
MR. GILMORE: Somebody's got to determine is this
place safe for employees or not? Now, here you've got a
contradiction in your paper, one line right below the other.
MS . KAPLAN: Read what' you' re concerned about.
MR. GILMORE: The only potential health risk at
this time may be to workers using the building. I'll jump
down a little bit. It says also there may be a health threat
to the workers on the site, because of potential for raising
chromium dust. However, the estimates show that the level o:
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1 hexavalent chromiums in the dust are below the current
2 occupational health standards.
3 '~ MR. ROUNTRY: Mike, I believe the last question,
4 asked was is this facility safe for employees to work in. tHe
S answer again to that question is yes.
6 MR. GILMORE: That's all I have. You wouldn't mind
7 writing me a letter to that, please?
B MR. ROUNTRY: I'd be glad to follow-up on that.
9 MR. NISSEN: I'm just curious, there's been a lot
10 of it's been substantially below, substantially above or
11 whatever, and specifically on this question, what kind of
12 levels did you find? Can you tell us how many milligrams pe:
»
13 cubic meter are the accepted Industrial exposure, and what
14 did you find relative to that limit. We've been throwing
IS around much lower, substantially lower, put a few number
16 out, so we can we need some numbers to deal with.
17 MS. BERNSTEIN: So, you want specific numbers with
18 actually in the building for occupational standard, to
19 compare to occupational standards, is that what you're
20 asking?
21 MR. NISSEN: You spent a million dollars studying
22 the problem, you should have some numbers.
23 MS. BERNSTEIN: You want the numbers from inside
24 the building, the whole site or what?
25 MR. NISSEN: You spent a million dollars already
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4 7
1 analyzing the thing over five years. You're talking about
2 spending at least another two million, plus God knows how
3 much for ground water. Now, If you spent a million dollars
4 you should have some concrete, cut and dried numbers, how bad
5 is it?
6 MS. BERNSTEIN: Could you just specify, I'm going
7 to ask Kevin
8 MR. NISSEN: In reference to Mike's questions. The
9 air.
10 MS. BERNSTEIN: Within the Frontier building?
11 MR. NISSEN: One of your primary concerns is
12 excavating all the soils to prevent air contamination.
13 MR. FREEMAN: We have several copies of the
14 remedial investigation report here tonight. There is a table
15 in the and I believe it's in section 5 of the report,
16 which has exactly what you're asking those levels
17 MR. NISSEN: Those two tomes over there? I don't
18 have time tonight to go through those. I'm just curious.
19 MR. FREEMAN:.. I don't have the numbers committed
20 I myself have a lot of numbers in my head right now and they
21 get mixed up. There is a table that gives the exact expenses
22 that we found in micrograms per cubic meter, I believe are
23 the units, and it's in section 5 of the report, and maybe
24 afterwards you and I can go back there, I'll show you where
25 it is, and we can look at it.
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1 MR. NISSEN-. The standard industrial limits, I
2 believe, are in milligrams per cubic meter, are they not?
3 "~ MR. FREEMAN: That's correct.
4 MR. WALTER NETH: You're measuring in micrograms,
5 and as we pointed out, you know, we have not raised this as a
,
6 major health related issue at the site. Our primary concern
7 is ground water.
8 MS. BERNSTEIN: Excuse me, sir, could I have your
9 name for the record?
10 MR. WALTER NETH: Yeah, my name is Herb Nissen, I
11 managed the site from 1976 to 1983 when I closed it down.
12 MS. BERNSTEIN: Thank you. Sir.
13 MR. WALTER NETH: Why do you keep referring to
14 . drinking water standards, when nobody is going to put a
15 drinking water well there anyway, we couldn't get a permi
16 build a well to get wash water. So, you keep talking
17 drinking water standards, a lot of barn yards I wouldn't put
18 a well in, too, so it looks ridiculous I looked through
19 this for a week, and I'm not just out of my ballpark, but
20 I've been looking at those books for a week down at the
21 library, and we've got these shipped to the house just a fe<
22 days ago. But you could decipher that or you could figure
23 this thing out you could just easy walk away from the site.
24 There's nothing wrong with that, because it Indicates there
25 no problems anyplace. You could walk away from it if you
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49
1 don't get any money. If you get in the honey pot again, you
2 can get a lot of money to spend and retire on. It looks like
3 a-ridiculous whole thing to start with.
4 . MS. BERNSTEIN: Let me see if I can clarify.
5 You're asking why are people considering cleaning up water to
6 drinking water standards when it might not be used to that
7 reason? Can I turn that over to Mike Gallagher? Mike.
8 MR. GALLAGHER: It is a drinking water resource,
9 and it is contaminated. And we can't --
10 MR. WALTER NETH: But the city won't let you put a
11 well there, they won't let you put an industrial well there.
12 MR. GALLAGHER: I think the state has jurisdiction
13 over that
14 . MR. WALTER NETH: Whoever has jurisdiction, they
15 will not allow a well there, but you're still talking
16 drinking water standards.
17 MR. GALLAGHER: That's right, it exceeds drinking
18 water standards.
19 MR. WALTER NETH: You find a way to spend money and
20 you're going to stay with it until you die.
21 -MR. GALLAGHER: I don't necessarily agree with
22 that.
23 MR. WALTER NETH: That certainly sounds like what
24 you're trying to do.
25 MR. GALLAGHER: It's a drinking water resource that
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1 belongs to all the people in the State of Washington.
2 MR. WALTER NETH: The city won't allow you to do
3 that.
4 .MR. GALLAGHER: We have not heard any indication of
5 that.
6 MR. WALTER NETH: Did you read the reporta of the
7 water department put in the paper about what's going on down
8 there?
9 MR. GALLAGHER: I don't read the Vancouver
10 Columbian. I'd like to see the article.
11 MR. WALTER NETH: I've got one right here that the
12 Oregonian put out, that tells about how we're just loaded
13 with water in Vancouver, all through that drought. Water tc
14 burn. They put more wells in the same places which you thir
15 could get contaminated. You're working against each otha^^
16 But that doesn't make any difference.
17 MR. FREEMAN: Can I point out something that I
18 think you need to there are certain regulatory
19 ramifications of this. We operate in and this study will b,
20 conducted under provisions of the Superfund law as revised
21 what are called the SARA Amendments, the Superfund
22 Reauthorization Bill that was that came out about a year
23 and a half ago, two years ago now. We apply apply to site
24 cleanup standards when we're doing our feasibility study.
25 look at the realm of potential environmental regulations or
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1 standards that might apply to a given site. There's a
2 procedure that's established for that, and the law requires
3 as" to look at what are considered to be applicable, and
4 relevant standards for a given site. There is, in fact,
S within that, an exemption that can be granted from drinking
6 water standard. If you could show that upgradient of your
7 site, and in the general site area within that acqulfer the
8 contamination was of such a character, the chromium
9 contamination of that acquifer from other sources was such
10 that you contributing to it had essentially done nothing in
11 excess, you hadn't really ruined the resource, the resource
12 was already in a poor state before it came on to the property
13 with similar contaminants. That Is the only way that we can
14 take an exemption from drinking water standards as an
IS applicable standard to that ground water under the SARA
16 provisions.
17 MR. WALTER NETH: You found a loophole to spend
18 money.
19 MR. FREEMAN: No, sir, I follow the regulations.
20 MR. WALTER NETH: But there is a loophole that
21 you In my opinion, the only way this got Into Superfund is
22 that misquoting that there was contaminants In drinking
23 water, well water to start with, or It never would have
24 gotten into the Superfund, you never would have gotten in the
25 honey pot to start with. You put it into Washington in that
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1 manner, and misrepresent.
2 MS. PLESKES: Just one thing. Policy as to what
3 type of rules and regulations and how clean we have to cl<^
4 up sites is set by both Congressional and the state
5 legislature. Me as a governmental agency have to follow
6 those rules. We don't make then all. And we do need to
7 follow those rules on this site. Once it's into the
8 Superfund process, whether right or wrong in getting there.
9 we have to follow the rules to get it out again, and that
10 means going through the process.
11 MR. WALTER NETH: There's no way you know how to
12 turn it off?
13 MS. FLESKES: Not unless we can justify there's nc
14 problem there and we can find a way to get it off the list.
15 MR. WALTER NETH: No money will stop it?
16 MS. FLESKES: It will delay it until additional
17 money, but it doesn't cause the site to go away.
18 MR. GALLAGHER: In addition, if there is a
19 potential for a drinking water resource to become
20 contaminated, it can qualify for Superfund. It doesn't ha\
21 to actually be contaminated, but the potential exists. Am
22 at this site it's far beyond the potential, a drinking wat«
23 resource is contaminated, grossly contaminated.
24 MS. BERNSTEIN: Could I have your name, sir, for
25 the record?
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HR. WALTER NETH: Walter Neth.
MS. BERNSTEIN: I have your name down to make
comments later on. Is there anybody else that has questions
right now? I don't know your name, sir.
MR. JONES: My name?
MS. BERNSTEIN: Yes.
MR. JONES: Oewitt Jones.
MS. BERNSTEIN: Would you like to come up to the
microphone and finish asking your questions?
MR. JONES: I would like to know from this group
whether or not at this time on this night you have any
evidence that there is any hazard to life or to vegetation,
to the environment at your so-called layer A, as it exists at
its location in place?
MS. BERNSTEIN: Could I clarify that? Are you
asking Level A is the top half of the
MR. JONES: Level A is one of the levels
MS. BERNSTEIN: In the ground water acquifer.
MR, JONES: In the ground water acquifer, and they
have said it has a concentration of chrome or hexavalent in
excess of drinking water standards. What I want to know is
whether or not at this time and place that's a hazard to
anybody.
MS. BERNSTEIN: Okay. Bob, would you like to
answer that?
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1 MR. SMITH: I think we've said throughout the
2 presentations here that there are no existing drinking water
3 supplies contaminated at the current time, that the potent^BL
4 for someone to drill a well la the item of concern, but there
5 are no existing drinking water supplies that are currently
»
6 contaminated. We've said that several times.
7 MR. JONES: If I were to go down there, suppose.
8 and got a permit and dug a well 80 feet deep, do you have an^
9 evidence that there is any contamination from your studies
10 that would be at that level?
11 MR. FREEMAN: At 80 feet? I think given what we
12 know right now, you would probably have a hard time
13 convincing someone to allow you to drill a well at 80 feet
14 there.
15 MR. JONES: I agree that people aren't going td
16 drill wells down there for various reasons, and that is one
17 of the problems that we are confronted with here tonight, ar
18 that is to go in and spend money in a location and an area
19 where admittedly nobody's health is at risk. Now, I want tc
20 ask you in that connection, you have one instance, Just one
21 of anyone where a doctor has said they fell ill because of
22 any condition that exists at the Frontier site? Just give
23 to me.
24 MS. BERNSTEIN: Dave, do you want to answer that
25 question?
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MR. ROUNTRY: I don't know of any people that have
fallen ill, fortunately, from drinking water from this
contaminated ground water plume. Fortunately, there are no
drinking water wells accessing thla plume.
MR. JONES: Well, then, isn't it a true statement
that you have no evidence at this time that anybody has been
hazarded in connection with their health and well-being as
far aa that site is concerned?
MS. BERNSTEIN: Dave.
MR. FREEMAN: I think the operative question here
la has anyone up to thla time been hazarded by the
contamination of the ground water aupplies. And I would say
that at the time that the FMC wells were pparating there
were, although those were not drinking water supply wells,
there was production of contaminated ground water, in other
words contaminated ground water was being produced, brought
from underneath the ground up to the surface. And anytime
you bring a contaminated water supply to the surface you run
some risk that there could be a human exposure to it. And I
would submit to you that you have no evidence that that is
not the case, in other worda no system,, no system of ground
water, of water useage from a ground water supply is so
aacrosanct that it cannot develop a leak, that there cannot
be some exposure to either workers or local people of this
contaminated resource. And I think Dave stated it very well
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that we've been very fortunate that no ground water drinlcing
water wells have been affected by this contaminant plume. I
would submit to you, however, that if anyone did drill witd
that.contaminant plume, that there would be a severe health
risk.
MR. JONES: How would there be a severe health
risk, even assuming that condition, which isn't going to
happen?
MR. FREEMAN: Sir, we have, on the site, there are,
I think I showed you. that within the Level A acquifer zone.
there is contaminants in excess of a hundred parts per
million. The drinking water standard is a .05, you're an
intelligent man and can make the multiplication that can tel
you how far in excess of the drinking water standard that
is.
MR. JONES: It might be a thousand times greater.
But my point is it does not present any hazard to the
well-being or the health of anyone in this community. It
hasn't and it won't. If you leave it alone, it will take
care of itself. You've got a level at A and you've got a
level at B, now what's your level at B?
MR. FREEMAN: The level at B is in excess of .05
ppm over a broad area.
MR JONES: How much?
MR FREEMAN: It goes up to .32 ppm.
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MR. JONES: Have you determined where the water
from that acquifer ultimately flows?
-- MR. FREEMAN: It's definitely going in the
direction of the Columbia River.
MR. JONES: Have you, in connection with your
studies, examined and tested the water in the Columbia
River?
MR. FREEMAN: We are familiar with the water in the
Columbia River.
MR. JONES: No, no, I asked the question, have you
tested the water in the Columbia River
MR. FREEMAN: I think the intent of your question
is to ask whether we see any evidence of contamination of the
Columbia River associated with this site.
MR. JONES: Yes.
MR. FREEMAN: What I would say to you, sir, since
this appears that this contamination is going to, and may in
fact have reached the Columbia River, that in Itself is
evidence that there has been contamination either presently
or in the future that would affect the Columbia River. The
question perhaps should be better stated do I think that
particular level of contamination poses a risk to the
Columbia River. It is our belief that there would be enough
dilution as this stuff reaches the Columbia River that health
effects would probably not result from that, which is why we
L'-v^?«;s^rAi/.:/A-;xr^^^
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~~ -- - ^^^^BB^M^^B^B^i^W^^^^^^^gi^^^^^ ^f^f^m^^.
1 have not spent any of the public's money on extensive surface
2 water sampling.
3 MR. JONES: Your belief, then, is, and I hope yq
4 state it in the record clearly, whatever you send to
5 Washington, D.C., because I want it in the record, that this
6 group of people have not found any condition in which any
7 contamination has gone into the Columbia River that has
8 saturated that water to a point where it is below any or
9 above any standards that you might apply, including the
10 drinking water standard.
11 MR. FREEMAN: We would be forced to apply an even
12 more restrictive standard if we were, ourselves, discharging
13 to the Columbia River. Which we would, in fact, have to
14 cleanup to under the you saw that one of our remedial _
IS actions involved discharge to the Columbia River. We woflV
16 in fact, cleanup to a much more restrictive standard if we
17 did that.
18 MR. JONES: Well, is it true that what you're
19 concerned about is the amount of chromium, hexavalent that1
20 in a water supply, is that your concern?
21 MR. FREEMAN: Both with hexavalent and total
22 chromium.
23 MR. JONES: Assuming you put in hexavalent into
24 Columbia River, and because of the volume of water it was
25 diluted, so the water was well below the drinking water
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standards, where would you be in any violation there?
MR. FREEMAN: I don't think you'll see anywhere in
the document where we have said that we believe there's a
threat to the Columbia River. We have stated, and I just
stated to you previously that surface water is not an area of
concern, here. We're concerned about ground water supplies.
MR. JONES: If these waters that you term as ground
water flow into the Columbia River, and they're diluted
because of the heavy volume of water in that river, where is
any hazard?
MR. FREEMAN: The hazard results from our fear that
it is there is a potential that ground water resource6
could be developed in that area, and If there were, there Is
a risk inherent in that development.
MR. JONES: What evidence do you have that there's
anyone planning to make any development down there that in
any way affects the ground water that exists there today?
MR. FREEMAN: Sir, you know, I could follow that up
by asking you, you're obviously a very good attorney, whether
you would if I had a piece of property nearby and I wanted
to drill a ground water well into Level A and I just went out
and did it, whether you would say I had a right to do that.
MR. JONES: Well, no, because you have to get
permits to drill a well. Mr. Neth addressed that subject.
They wanted to drill a well just to use the water for washing
--3-i-v .«-' ;
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1 purposes, and the and they were denied that by the state
2 department. So
3 ~ MR. FREEMAN: I think maybe Mike could address
4 the regulations are.
5 MR. GALLAGHER: Regulations are, you need a permit
v
6 if you withdraw up to five thousand gallons a day; under that
7 you do not need a permit. But you have to
8 MR. JONES: Here you people sit proposing to spend
9 millions of dollars of public money, and that's what you're
10 proposing to do, when you don't have a situation existing
11 where anybody has been harmed or hurt or you have no evidence
12 now. You say about a potential. I could speculate about
13 anything in the world, but I'm interested in evidence and
14 hard facts.
15 MS. PLESKES: I have a question of you, do you
16 think it is proper public policy to foreclose a use for two
17 to three hundred years, where we at this point don't have ar
18 idea what the future demand may be? And that's what we're
19 talking about. That's the issue we're talking about.
20 MR. JONES: I know you
21 'MS. FLESKES: I'm asking
22 MR. JONES: You can estimate 90 years. 50 years,
23 doesn't mean a thing, because if it isn't broke don't fix
24 it. Now, that's a pretty solid rule. And what I hope as i
25 citizen I want one more question about the environment,
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1 because I'm curious about that. I've been watching that area
2 down there for years, as a citizen in this community.
3 ._ What tests have been made in connection with the
4 " blackberries, the grass, or any of the things that exist down
5 there that are part of the environment? The rabbits that run
6 around there, have you tested any of those to see if they
7 show effects of chrome? There are dozens of them down there,
8 you know. That's a part of nature. Now, have you, just
9 answer the question, have you made any tests in connection
10 with any of the environmental situation down there, including
11 the plants, the growth and so forth, and if so, I want
12 your I want to know what the score Is on it.
13 MR. FREEMAN: Well, to answer it very directly, no,
14 there have been no such tests. But if you'd read the
15 Endangerment Assessment, we don't believe, given the
:6 vegetation on the site, that there is a pathway of
17 significant concern in terms of, for instance, the
18 blackberries.
19 We still, you know, don't recommend that people run
20 out there and eat lots of them, but nonetheless it does not
21 appear to be a significant concern at this point. And I .
22 think that's stated n the document.
23 MR. JONES: Why don't you why do you put it in
24 your literature, then? Why do you put it in the background.
25 why do you have all these phrases in there that are that
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1 raise peoples question about oh, my goodness, four hundred
2 times it's in the ground, it isn't going any place. i
3 coUld sleep down there day after day if I was younger and
4 a tent, I'd never be bothered by it, you know that, you've
5 got the evidence. And you don't have any medical evidence
6 that is contradictory as far as this site is concerned, and
7 these problems are concerned.
8 So, in conclusion, I want to put in the record, so
9 it goes to Washington, D.C., that you people do not have the
10 evidence, only the potential speculation. And that should
11 not carry the day tc spend the amount of money that you're
12 proposing to spend. And as a citizen I object to it. Thank
13 you.
14 MS. BERNSTEIN: Thank you, sir. Sir, could I have
15 your name again, for the press?
16 MR. GALLAGHER: Dewitt Jones.
17 MS. BERNSTEIN: Mr. Dewitt Jones.
18 MS. PAT NETH: Getting back to the blackberries.
19 they did say, somebody over there, two or three times about
20 the blackberries being contaminated. Did they ever test
21 these blackberries? They say they're contaminated, they
22 wouldn't eat them. Why wouldn't they eat them?
23 MS. BERNSTEIN: Could I have your name, please?
24 MS. PAT NETH: Pat Neth. If you say you shouldn'
25 eat them, you must have tested them, or else why would you
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make that statement?
1
2 MR. FREEMAN: What we said Is that blackberry
3 boshes have been shown not to be a very effective bush for
4 sucking up heavy metals. In other words
5 MS. PAT NETH: I didn't hear that quote.
6 MR. FREEMAN: Have you read the document?
7 MS. PAT NETH: That isn't the way I understood you
8 to say.
9 MR. FREEMAN: What I said was the Endangerment
10 Assessment showed there was no risk in the blackberries,
11 we're not concerned with the blackberries.
12 MR. WALTER NETH: You lead everybody to believe
13 that you're going to die if you go near the place. That's
14 the impression you lead everybody. In the fine print you say
15 there's no problems, so why don't you go home and forget it?
16 The dust can be stopped by throwing a layer of blacktop
17 around the building, and it's all through, the project is
18 done, no more 230 some thousand dollars or nothing, plug then
19 with concrete and go some place where it's important.
20 MR. FREEMAN: One of the alternatives is the
21 surface only alternative, sir. And you might want to read
22 it.
23 MR. WALTER NETH: I've read about half of those.
24 MR. FREEMAN: It's an alternative that's very
25 similar to what you requested we take a look at. It's callei
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1 the SO alternative in your document.
2 MS. PAT NETH: Where do you go from here, after
3 thTs is done. 50 years from now?
4 MS. BERNSTEIN: Excuse me. at this point, because
5 we have a time limit on the room, I would like to take more
6 formal comments that excuse me for one second, and I'd
7 like to limit the time to four minutes each, and first of all
8 I'd like to start with people who have to fill out a card
9 with their name and to raise their hand and Jeanne will
10 collect your cards and I'll call your name. I also would
11 like you to come to the microphone if folks would come to
12 the front of the room. Also, I would like to let you know,
13 please summarize in the four minutes that you have, and then
14 anything else that you would like to submit will be we'll
IS be taking comments here tonight, written comments and at
16 Ecology until November 19th of this month. So, you have tin
17 to think about things tonight and get in your written
18 comments. But if you'd like to speak now, you folks have
19 four minutes each.
20 MR. WALTER NETH: Can I say a couple of words whi
21 they1re'getting these cards?
22 MS. BERNSTEIN: I'd like to wait and it would be
23 easier for our court reporter to get everything with your
24 name, all in one block. I want to say the address to send
25 the comments is in the fact sheet to Dave Rountry at
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1 Ecology. And you'll find the address in the fact sheet.
2 So, Walter, if you want to come up and speale
3 fl-rst?
4 MR. WALTER NETH: I would like to know who, where.
5 when makes any kind of decision on what happens of after you
6 hear the comments, here, where is it going to be, who is
7 going to make the decision and ia that open to anybody on the
8 outside or is that a closed meeting?
9 MS. BERNSTEIN: Could I refer that to Phil Wong of
10 the EPA?
11 MR. WONG: The process.from her* on out is that
12 once all the public comment is brought in, responses would be
13 put together, which essentially ia the agency for or EPA
14 responses to all the various comments, Ecology and EPA
15 together will write what is called a Record of Decision,
16 which will be the formal decision on how to proceed on this
17 site. EPA actually signs this Record of Decision, at this
18 point at that time the Record of Deci&ion goes out for
19 comment, pretty much it's final at that point, whatever
20 decision has been made. So, in other words your comments
21 should be in order for your comments to best be
22 accoraodated, they should be sent in during this comment
23 period.
24 MR. WALTER NETH: Who makes the decision, that's a
25 point I asked you.
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1 MR. WONG: EPA.
2 MR. WALTER NETH: Who's EPA?
3 MR. WONG: At this point, it will probably be Rq
4 Russel, the regional administrator.
5 MS. BERNSTEIN: EPA is the Environmental Protection
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6 Agency.
7 MR. WALTER NETH: He's going to listen to public
8 comments or only listen to what you guys are going to tell
9 him?
10 MR. WONG: The comments you submit during this
11 meeting and during the rest of the public comment period,
12 these will all be part of the Record of Decision.
13 MS. BERNSTEIN: I would like to, as community
14 relations person, explain a little bit about that process.
15 We take everything from this meeting that will be in wrifVPn
16 form, up until the 19th of this month. And it's written up
17 and summarized into what's called a responsiveness summary.
18 and then EPA uses that along with recommendations from
19 Department of Ecology to make their decision, and in their
20 Record of Decision they need to respond and show how they
21 have responded to the citizen's concerns. So, there's a ve
22 specific document in how the agencies, both federal and
23 state, have responded to the citizen's concern, and that is
24 the purpose. This meeting is a federal requirement, the
25 responsiveness summary is a federal requirement.
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1 MR. WALTER NETH: I know this is a federal
2 requirement. But I wondered if it had any effect. I think
3 sometimes these go just because they're a requirement, well,
4 we got that out of our hair, and now we go back and make the
5 decision, that we've got planned already.
6 MS. BERNSTEIN: I'm pretty sure the Record of
7 Decision and the responsiveness summary is available to the
8 public, once a decision has been made. And once again to
9 reiterate, a decision on the soil alternative will be made by
10 December 31st, and then they'll be one made on the water from
11 Spring of '88.
12 MR. WALTER NETH: Can anybody else sit In on those
13 meetings or is that a closed meeting?
14 MS. FLESKES: It basically becomes a government
IS decision once the comment period is closed. .
16 MR. JONES: I have one more comment and that is to
17 direct attention to the people who are working with the DOE
18 that there is pending in Clark County, Washington, a lawsuit
19 and that that lawsuit would permit us to come into court and
20 to have a hearing in a court of law, so that the decision
21 could be made because peoples property and their right to use
22 property cannot be taken away now, thank God, by a group of
23 people in a particular agency. So, I call that to their
24 attention, before they go forward with making any plans,
25 they're going to have to come into courts and face the judge
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1 and a Jury, perhaps, and have this matter decided by someone
2 locally who can evaluate what we've been talking about here
3 tonight.
i
4 MS. BERNSTEIN: Okay. Would you like to give your1
5 four minute comments now?
6 MR. JONES: Pardon? No. I've already given my
7 comments. I think my position is fairly well stated, I
8 hope.
9 MS. BERNSTEIN-. Would John Riser like to come
10 speak?
11 MR. RISER: Yeah, you bet. I'm half owner of
12 Richardson Metal Works, I'm right next door to the so-called
13 site. My main question is just whether or not in the budget
14 numbers of your different cleanup processes, whether or not
15 there's anything cut for reimbursement to the surrounding
16 businesses for disturbance to their normal business? I mear
17 obviously a lot of them entailed digging a big hole right
18 behind my shop which is my major staging area, let's put sot
19 wells back there and mess things up good. I'm just wonderi
20 where do I go for getting reimbursed? I'm an innocent part
21 and all of a sudden somebody is coming over my fence and
22 drilling a well.
23 MR. ROUNTRY: No, I'm afraid it's not so simple.
24 To answer your question, those potential costs in litigati
25 was not considered in the costs of these alternatives as
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1 you've seen them presented in our reports or in our
2 presentations tonight.
3 MR. RISER: What resource do I have, then?
4 .MR. ROUNTRY: Recognized that the potential is
5 there for litigation, franlcly it's the resolution of that, I
6 can't respond to at this time, I'm not in a position to
7 I'm not a legal person. If it's an issue that remains, it
8 will be addressed by our legal staff.
g MS. BERNSTEIN: Is that a question we could get
10 back to by consulting our attorneys?
11 MR. RISER: I'd love to have somebody call me and
12 let me know what I can do about this. If you dig a hole
13 behind my shop, you're going to cut off my major staging
14 area, my shipping and receiving and everything. It's going
15 to make things very difficult for me.
16 MR. ROUNTRY: I understand your concern.
17 MS. BERNSTEIN: So, we can consult our attorneys
18 and
19 MR. RISER: A letter?
20 MS. BERNSTEIN: And get back to you.
21 MR. RISER: Is there any time frame you're used to
22 getting back to somebody in this case, because I'm not going
23 to go too long.
24 MS. PAT NETH: Drag it out as long as they can.
25 MR. RISER: Oh, really. You're telling me not to
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hold my breath, then?
MS. PAT NETH: Yes, don't hold your breath.
MS. BERNSTEIN: I'll let Carol
MR. WALTER NETH: I want to make a statement, you"
guys put 15 guys out of work, and you've got about 15 right
here replacing the jobs, but I don't think those steady jobs
I don't think those people appreciated it very much, the
people that you put out of work. And the business that you
broke.
MS. BERNSTEIN: Would Herb Nissen like to give
comments, now?
MR. NISSEN: I just had a brief comment in going
through your brief history, essentially, if I understand yov
correctly, you have identified the alternative that you wan-
to pursue, which is solidification of the surface materj
down to a depth of approximately 20 feet, is that correct,
the removal and essentially you're going to fix the chrc
so it can't leach out of that area of soil: is that correct
MR. ROUNTRY: That's correct.
MR. FREEMAN: One thing we're not looking into i
vitrification, that's a separate.
MR. SMITH: Use the term stabilization.
MR. NISSEN: Lock the chrome up so it can't leac
out into the ground water.
MR. ROUNTRY: Specifically the alternative that
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we're proposing at this time for source control is identified
in the literature as the SS alternative.
"~ MR. NISSEN: SS.
MR. RQUNTRY: SS.
MR. NISSEN: I guess I have a question about and
as I understand the ground water situation is still up in the
air, is that correct, you have not made a recommendation, you
have not arrived at any conclusion at this point as to what
to do about the ground water?
MS. BERNSTEIN: That decision will be made this
coming spring.
MR. NISSEN: We're six months out on that
decision?
MS. BERNSTEIN: Right. But you can make your
comments on that tonight, this is the time to do that.
MR. NISSEN: One of the things I've noticed in
here, is that you've uncovered a nice little mixture of
chlorinated solvents in ground water today. I guess if I had
a choice as to whether I had a tenth of a part per million of
chrome in my drinking water or a tenth of a part per million
of solvents, I wouldn't have a real hard time making a
decision about which one I'd take. There isn't anything in
here about the levels you found or anything. How are you
going to address this question along with the chrome? If
we're talking about drinking water standards, I don't know
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1 what the drinking water standards are for chlorinated
2 solvents, but I know the EPA and OSHA and everybody else has
3 been death on chlorinated solvents for several years, they,
4 one of the nastiest things you can mix with your water. If
5 you intend to pursue cleanup of ground water, are we going to
6 pump this stuff out or do whatever, I'm just in supposition.
7 take the chrome out of it and then pump it back in the ground
8 with the chlorinated solvents in it or take that out, too, or
9 I would say possibly the most logical conclusion is say this
10 stuff is not safe to drink. And I for one would find it ver'
11 ill-advised to go in around any industrial area that's been
12 in place for any length of time and drill a well and drink
13 the water. I think you know that as well as I do.
14 MS. BERNSTEIN: Can I clarify, are you asking what
15 is going to be done about that, are you wanting to know w^pt
16 the levels are?
17 MR. NISSEN-. I'm not asking a specific question,
18 don't care how many parts per million of chlorinated solven
19 are there. We've talked about chrome tonight, and the grou
20 water issue is still up in the air. I think obviously you
21 know it's there, it hasn't been mentioned, it hasn't really
22 been addressed. I assume it's an area of concern that it't
23 there. And I assume that it's going to be taken into
24 consideration when some kind of a I hate to say return
25 investment -- but that's something we use in the private
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1 sector a lot
2 MR. FREEMAN: I think the question is well stated.
3 An<3 it was an inadvertent omission on my part not to mention
4 that .we had found some chlorinated solvents in the ground
5 water. We the information we have now. which is not
6 extensive, in terms of the chlorinated solvents in ground
1 water tend to indicate that they seem to be coming from some
8 source to the north, and not directly associated with the dry
9 well discharge, okay?
10 MR. NISSEN: I think there's a paint shop to the
11 north of Hard Chrome at one time.
12 MR. FREEMAN: The other sources could be a
13 potential explanation, but in answer to the question are we
14 going to address them in terms of the ground water cleanup,
IS the answer is yes. We are not cleaning up the ground water
16 to clean up the solvents, though, but any solvents that are
17 brought into the water stream during the cleanup for chromium
IS will be treated and we will not redischarge chlorinated
19 solvents to either the ground water or discharged line. And
20 costs have been included in the document for air stripping
21 and carbon absorption cleanups.
22 MR. NISSEN: Water solvents, also. 1 guess just in
23 summary, I think my earlier question or my first question
24 this evening, I think this story has been on and off the
25 front page of the Columbian for five years, roughly, since
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1 late or very early 1983, I think. I don't know how often
2 it's appeared. I've got received copies of the articles,
3 and it's always front page news. Frontier Hard Chrome was*
4 big issue around here. And I assume this meeting was well
5 publicized, as well. I would say the overwhelming evidence
6 at hand, is this is not an issue of public concern. Nobody
7 cares. Nobody cares enough to come here tonight to listen tc
8 what you have to say, other than the people that work next
9 door to it, work in the building or had something to do with
10 Frontier Hard Chrome, or possibly the news media, and
11 yourselves. We keep talking about the public concern, the
12 public isn't concerned. In an abstract way they are, yes,
13 but I don't think any of them plan to go down there and dril
14 a well and drink the water. And I think that should be take
IS into consideration when you take a look at the ground wd
16 study.
17 MS. BERNST2IN: Thank you for your comments. Doe
18 anybody else have would like to submit any comments?
19 MS. PAT NETH: Is there there is the maps that
20 have to do with it's a known fact where the acquifers gc
21 and where the ground water flows? There is a known fact, z
22 where the strata is and where the wells come from, and the
23 well they're drilling here might come from 20 miles away,
24 down under there, and there's a known fact where they go.
25 And this water that you're seeing here, it is not it is
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1 not in the acquifer that goes to any one of these wells, it's
2 a known fact that it Isn't going to those acquifers
3 they're underground rivers, and they know where these
4 underground rivers are, and this isn't part of one of those
S rivers that supply any of the wells.
6 MS. BERNSTEIN: la this a question or a statement?
7 MS. PAT NETH: That's a statement.
8 MR. ROUNTRY: I'd like to respond to that statement
9 by saying that these acquifers or underground water water
10 channels are interconnected, and in that respect it is the
11 same water that would service the Vancouver well fields.
12 MS. PAT NETH: You mean you think there's this
13 ground water will get you say right now that it goes to
14 the river, it doesn't go back north?
15 MR. FREEMAN: I think the clarification that's
16 necessary is it is the same acquifer system, but the
17 Vancouver well fields are what we call upgradient, in other
18 words that the water is flowing from those well fields
19 towards the Columbia River, which means that what we've
20 determined, and what we've reported is that we don't feel
21 that there's a risk to well fields 1 and 4, based on the
22 chromium contamination at Frontier Hard Chrome, because the
23 water underground water is flowing In another direction, away
24 from those two well fields. But the point of clarification
25 is that we are dealing with the same acquifer system, it's
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1 just that Frontier Hard Chrome is down gradient, down water
2 flow direction from down river, in your analogy.
3 MS. PAT NETH: What you're saying is eventually(
4 might just wash itself, if it's down river.
5 MR. FREEMAN: That's correct
6 MS. PAT NETH: Is that what you're saying?
7 MR. FREEMAN: Yes, and I believe Dave had a table
8 that he showed, which showed how long it would take for these
9 acquifers to clean themselves for we did nothing. It was th«
10 chart
11 MS. PAT NETH: Yeah, I seen that. 90 years.
12 MR. ROUNTRY: Would you like to look at it again?
13 MS. PAT NETH: I remember.
14 MR. FREEMAN: So, yes, in other words you've got
15 the right picture, here.
16 MS. PAT NETH: But there will never be condominiu
17 down there, there will never be houses down there. Someone
18 says they should never put housing down there or never put
19 condominiums, I don't know which one of you all said that.
20 MR. FREEMAN: Apparently, you know, there are sot
21 possibilities for development down towards the Columbia Ri
22 in the down gradient direction.
23 MS. PAT NETH: Around FMC.
24 MR. FREEMAN: Around FMC, correct. Remember the
25 plume extends to FMC. On the diagrams we showed Highway <
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and there was a well
MS. PAT NETH: 14.
-- MR. FREEMAN: Excuse me, 14. And further to the
southwest was a well we installed, but that's right amongst
the cluster of FMC wells. And the plume is in that area.
MS. PAT NETH: By the same token if they did build
there, they wouldn't put wells into service themselves, they
would put
MR. FREEMAN: One of things we've included in
they're, and one of the things that the agencies are trying
to discuss right now is their ability to apply what they've
explained to you is institutional controls to see if it is
possible to stop somebody from drilling a well down there.
That's a very important fact. That's one of the things
they're trying to address right now, can they, in fact, stop
people from developing that resource. Certain people would
argue, arguments similar to what we've heard about tonight
about property rights and water rights and that's one of the
problems, here, you know, does someone have the right to tell
you you can't drill a well down there if you want to. That's
what they're trying to look at. that's one of the reasons
there's no decision yet, because that's part of the problem.
MS. PAT NETH: Well, I bought a house out here in
Fern Prairie, and it didn't have a well on it. Somehow, the'
just had a bit well or whatever, and I wanted to get a well.
1 '"'"" ''"' ''"'*"".:;!.'.'. i!v-'''-'c7v'v?";'i-"vrc^w;v^"?>v'^^^
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1 It almost took an act of Congress to get a well, you know, to
2 put down for a well. So, I don't see nobody can drill a
3 well without a permit.
4 . MR. FREEMAN: Mllce, you want to address that?
5 MR. GALLAGHER: My understanding of the regulation
6 is that or the law, is that you can install a well and you
7 need a water right permit if you withdraw over five thousand
8 gallons per day.
9 MS. PAT NETH: I'll put one in, and beat the city
10 out of a two hundred dollar water bill.
11 MR. GALLAGHER: It might be a city regulation. Yo
12 might want to keep in mind, ma'am, that it might be a city
13 regulation
14 MS. PAT NETH: And that's in the city, that's in
15 the city.
16 MR. GALLAGHER: You may want to put in an
17 irrigation well, and that's not a supply well.
18 MS. BERNSTEIN: Does anybody else have any
19 questions or comments?
20 MR. WALTER NETH: What is the object in digging
21 stirring up the back of the barn yard, stirring it up, mak
22 it stink a little more, what is the object in digging it u
23 and moving some place else, which would be in somebody els
24 way. I can't figure it out if you take something up and \
25 it away and do something with it.
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MS. BERNSTEIN: We have some clarification.
MR. SMITH: There was two suggestions, one if we
dealt with the surface soil one and a half feet deep, we're
talking about a very small amount of material, that would be
hauled off site to an appropriately regulated land fill,
because it's too small of a volume to treat it or mix it.
MR. WALTER NETH: That's already a land fill, I put
it In there.
MR. SMITH: It's a fill zone. The other where we
excavated the surface Is subsurface soils, where we stablized
the soil by mixing it with a cement type material and put it
back into its existing place, so we don't remove it from the
site.
MS. PAT NETH: How many years is that cement stuff
going to be stablized?
MR. SMITH: An additional amount of testing I
can't say how long.
MS. PAT NETH: I've seen sidewalks disappear and
crack up.
MR. SMITH: That's true, and they're exposed to the
elements. There's sewers that have been in place a hundred,
two hundred years. It depends on the environment. We'd have
a large patch, and around the edges it might deteriorate a
little bit, but it's becoming a fairly proven technology.
MS. PAT NETH: If you mix cement with dirt, it
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1 doesn't stay very good.
2 MR. FREEMAN: This is not Portland Cement we're
3 talking about here, this is a soil additive that the
4 purpose of this particular material is to bind up the
5 chromium. And as long as it keeps that chromium bound up, w<
6 don't really care
7 MS. PAT NETH: How fluid is it, this stuff? If yoi
8 mixed it with water?
9 MR. SMITH: It dries into a fairly firm material.
10 MR. FREEMAN: Let me say, there are a number of
11 proprietary types of technologies that have been developed,
12 various people have their own particular mixtures that
13 they're marketing to do this particular treatment. And
14 really it's a good question, but it's very specific to the
15 type that would be selected a.t this site. In other worasq
16 there's not just one type, there's maybe four or five
17 different vendors that right now are offering an additive
18 that would be appropriate for this type of application. It
19 would very much depend on which one you picked, how fluid it
20 would be when you reintroduced it into the ground.
21 Ultimately it hardens. So, much like and I think that's
22 the analocy with a cement, you mix it in a with water anc
23 whatnot, and the additives, and then relntroduce it into tht
24 soil, and then it solidifies and at that point you've got
25 kind of a what we call a stablized soil mass.
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MS. PAT NETH: Let me ask you this, you said it's
not exactly like a cement, it's a little different you said.
If it a liquid to begin with or a powder?
MR. FREEMAN: A little bit of both. You've got
liquids you put it through what's called a pug mill and
you're mixing water and powder and soil, additive. And
then so, you get this mix and then much like you do on a
cement mixer you put that mix back into the excavation. And
then it solidifies.
MS. PAT NETH: Why couldn't a person make a mass of
that and would it sink down in the dirt
MR. FREEMAN: Like inject It into the dirt? .
Actually some of t..ase are, one way people have tried to do
this is to inject it into the uirt. Historically, injection
programs for soil stabilization, not this particular type of
soil stabilization, but any kind of soil stabilization, is
very difficult to drill a lot of wells, you know, well points
and Inject this stuff and get a real continuous application
and feel that you've really got the problem totally
resolved. It's one of those things that over the years
people have tried it, it hasn't been a very effective way to
do a soil stabilization.
MR. WALTER NETH: Wouldn't just blacktopping the
area solve your whole problem?
MR. FREEMAN: As I pointed out before, the SO
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alternative is very similar to that. You could, you know.
put some impermeable layer on the top or you can attempt to
make the contaminated soil impermeable by mixing it or youl
can take the contaminated soil some place else. But
essentially that's the whole point. You're either removing
that surface layer, or trying to make that an impermeable
layer, so you don't get water going down through it. So.
yes, asphalt has certain problems, but the concept you're
presenting is a valid concept.
MR. OTTO NETH: What happens if you don't do
anything at all? It will get better as years go on, I
imagine. Right now it's been there for 35 years. And I kee
reading in the book, documents back there, which are too muc
for me to handle about the blackberries, and it keeps saviiic
there's no harm if you eat the blackberries, but if young'
children had a playground down there, which is an industria
area, I don't think you'd get one, they can ingest the soil
and it would be harmful. I don't know of any kids which
would turn around and eat that darn stuff, anyway. But we'
using that as an example to do millions of dollars worth o:
project, which I don't see any problem, like I say, if you
cap it, and you can't get a well in, if there's somebody f
the city, you'll probably find out, if you can't put a wel
down, why are we going through all this expense?
MR. FREEMAN: I think what you're suggesting, ir
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sense what you're saying is you favor the SO alternative. i
mean there's a sense in which what you're saying it's not
exactly the same as what our SO alternative says, but it's
very .similar. And so in essence, you know, that's one of the
things that's important about thia meeting, you're giving us
some feedback that you think that's an appropriate way to
treat the site. I think I mean I think that's what I'm
hearing from you.
MR. OTTO NETH: I get upset a little bit. When
this started out it was going to be a couple hundred thousand
dollars, just only an investigation. Now I guess it's way
over a million. And there's no telling where it's going to
go before the project even starts. And why should the
project even start to start with? I haven't seen any sound
reason that I've.heard tonight that makes It legitimate to
put the dollars in that you people are suggesting.
MS. BERNSTEIN: Excuse me, sir.
MR. OTTO NETH: That's all.
MS. BERNSTEIN: That's why you're here giving us
comments, that's why we have an array of alternatives, and I
just wanted to state that we've heard a lot of skepticism
tonight about what our decisions as an agency will be, and
whether or not we're taking the public into consideration.
and I would like to reiterate, thia will all be written up in
a responsiveness summary, and it's the exact things that
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you're saying and everybody else is saying, that we need to
hear. Is the site going to be used, who's going to be using
it, what kind of public interest do we have, and I think it
been-really clearly statsd here tonight. So, I would like
excuse me, we need to finish up really soon. Ill take a few
more questions, I just want
MR. RISER: I have two minutes left on my four
minutes.
MR. OTTO NETH: We asked for a little extension to
see if we couldn't do something to keep this business going.
and the chairman of the board says no, that's it, you're cut
off as of right now. 35 years it's running. And we .got cut
off immediately. And loss our shirt. I mean the whole
business closed up. That's the power of what was against
us. We never had no alternative; we just had to close it
up,
MR. WALTER NETH: Needless to say you know we
resent it.
MR. OTTO NETH: For what reason, you people didn1
do anything for a couple of years there. It was Just
dormant. As critical as you're making it now, and you've c
to move on it. You were idle for so many years in there.
MS. BERNSTEIN: I would like Carol Pleskes to
respond to that as your section head.
MS. PLESKES: Thank you a lot for that, Lynn.
''"'"* '""-""-~>"^'">''^7?*:*i^^-s^.*:-^.^.t
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1 MS. BERNSTEIN: I think: that needs some
2 clarification.
3 -- MS. FLESKr. .>: I don't know all the history of this
4 site.anywhere near as well as you do. What I have been able
5 to find from some of the records, and I wasn't around
6 well, I started in the agency In '78, so I wasn't here all
1 the time you're talking about, but that we did try to work
8 with you over a period of time to get a treatment system in
9 place on the discharge. It was the difficulty in getting
10 that in place and finding chromium in the water at FMC wells
11 that caused us to order you to stop the discharge, and to
12 start looking to see what the problems have been caused. I
13 believe you must have appealed that to the board if you say
14 you went before some kind of board or, the Pollution Appeals
15 Hearing Commission.
16 MR. OTTO NETH: We didn't appeal it, he said you're
17 through, shut it down.
18 MS. FLESKES: The discharge of that material into
19 the ground water was not a practice that.the state could
20 accept under the state laws that we did have to enforce. One
21 of the things you're pointing out is that we tend to address
22 sites In starts and fits having to do with the fact that
23 we've got a lot of activity to carry on, not enough people tc
24 do it, priorities do change, and lots of things that I reallv
25 don't have any control over. It's Just a fact of life,
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you're not the only one we've addressed it to, do something.
and let you alone for a few years, and then say by the way
we're back.
MR. OTTO NETH: You're not concerned about a
private business. Now, if it costs now, we can't afford
to keep a business going and do what you asked us to do. You
have to fork up a hundred thousand, now, at home you can
budget your home, but you don't budget the government's
funds, you spend what the government gives you.
MS. FLESKES: Well, that's not true, exactly. We
have to request a budget.
MR. OTTO NETH: A couple hundred thousand dollars
is a lot of money for a business.
MS. FLESKES: For me, too.
MR. OTTO NETH: Not when it comes to spending
government money.
MS. FLESKES: You were asked in 1976 to develop t
plans. We didn't say we had enough until 1983, that was 7
years you could have been planning and implementing that
solution.
MS. BERNSTEIN: One more question in the back.
MR. NISSEN: I'd like to state
MS. FLESKES: I may not have all the facts right
MR. NISSEN: No, you don't. In that 7-year peri
we reduced our discharge over 80 percent. I think we alsc
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repeatedly stated to the Department of Ecology, we were
operating in an extremely competitive marketplace. We would
be~ more than happy to put this system in, but we knew it was
going to cost us money to put it in and cost us money to
operate it. We asked repeatedly that you address the other
shops that we were competing with equally, and if you if
you can come to us, I think our statement very clearly was,
if you can come to us and say we're enforcing this law
equally, all the way through, which is equal protection under
the law, then we will put a system in, no problem. But we
cannot afford it's a question of we can go out of business
putting a system in and Increasing our costs, because if we
raise our prices our customers go somewhere else. And I
think that was the one thing we stated categorically over anc
over again, I know I did at the Department of Ecology,
enforce the law equally, that's all I asked you to do. And 1
did not get that.
Now, one thing I think that as a matter of fact
out of the five or six Hard Chrome shops that are sti,ll
operating in the Portland/Vancouver area, I would say
probably 75 percent of them still don't have a waste
treatment system in place.
One thing I guess I have a question, when we
were listed In Superfund list there were 450, approximately,
companies on the original listing. And my understanding was
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1 those were listed in order of increasing severity, is that
2 correct, from 1 to 400 or something like that?
3 "~ MR. WONG: Generally that's true.
4 MR. NISSEN: There was a ranking. I think Love
5 Canal rated about 85 on that list. And we ranked 54th, if I
6 remember correctly. He were the 54th most hazardous disposal
7 site in the entire country. My question, I guess, if there
8 are 450 some sites on that list, that list came out almost
9 five years ago, has there been a single site cleaned up well
10 enough, I guess I could sum my question up, have they
11 issued permits for people to drill drinking wajer wells at
12 Love Canal. You keep talking about drinking water
13 standards. I want to know if there's a single site that's
14 received a clean enough bill of health that you can tell
15 somebody to drill a well and drink the water?
16 MR. WONG: I think actually cleanup activities hav
17 been completed, and the EPA has been signed off on 30
18 something sites.
19 MS. PAT NETH: That they can drill wells and drin
20 the water?
21 MR. WONG: The process takes a long time to get
22 through. And in some cases the remedial action may be shut
23 down in terms of the immediate, having to do some sort of
24 construction, in some of these cases there's not a long-tei
25 ground water cleanup project going on, in which the ground
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water may not be clean for some time. But it's in process.
MS. FLESKES: The final construction is complete.
- MR. NISSEN: I guess one question, if you've
cleaned up 30 sites, buttoned them up and said this is taken
ca~e of
MS. FLESKES: Even if it may be an operational
system like the 15 year pump and treat.
MR. NISSEN: Everything that can be done other than
monitoring is done, how much money was spent doing that?
MR. WONG: I couldn't tell you, I have no real idea
of what kind of money.
MR. BRINCEFIELD: The original funding for
Superfund was 1.5 billion dollars, and there's been an
additional 9 billion dollars In the new reauthorization,
which is, of course, the law we're operating under, it's the
law of the land that these 15 people that you're talking
about being here doing these meetings, that *hia gentleman
has spoken about, are attempting to enforce to the best of
their ability. And we do very much watch your I work for
the ground water protection agency, and we'll take that into
consideration. But it's very important to understand that we
ask the same questions that you do. And we have the same
concerns. We appreciate what you're saying here, and we need
to know where you're coming from, but that a lot of money has
been spent. The goal is to protect public health in the
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1 environment. We deal with potential situations, not juat
2 with actual demonstrated health effects the gentleman is
3 speaking about, but I hope that helps answer your questia
4 . MS. PAT NETH: How much is cleanup and how much fa
5 just overhead and salaries?
6 MR. BRINCEFIELD: I really don't know the answer t
7 that question.
8 MS. BERNSTEIN: I'll take one last question and
9 that's it, because we have to be out of here.
10 MR. GILMORE: I hear what you're saying. X kind of
11 agree with some of the things I'm hearing tonight. I think
12 this letter is a gross -- grossly misleading. Here it state
13 the blackberry vines are contaminated, the blackberries are
14 contaminated, the ground soil is contaminated, and there's
15 risk to soils, and all of that you guys contradicted
16 tonight. I want that stated.
17 MS. BERNSTEIN: I just want to say comments will 1
18 accepted in written form up until the 19th. I'd like to gi-
19 you Ecology's toll-free number is 1-800-458-0920, if you ha
20 more questions, feel free to call. You can ask my name
21 Lynn Bernstein or you can ask for Dave Rountry, and then we
22 can refer you to the right technical person or the
23 appropriate person to speak to. If you're not on the mail!
24 list and you'd like to be, please sign up out at the
25 registration taole, because when the decisions are made it
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1 will be distributed through the mailing list so you'll know.
2 MR. RISER: That list out in front is your mailing
3 M«t?
4 . MS. BERNSTEIN: I have a mailing list of about 40
5 people, but that's
6 MR. RISER: I'm obviously not on It, I learned
7 about this meeting word-of-mouth from somebody else. I was
8 kind of surprised I wasn't notified.
9 MS. LAWSON: You will be then. As long as your
10 writing is legible you'll be on it.
11 MS. BERNSTEIN: I Just want to remind you there
12 will be a decision on the soils source control by December
13 31st, and then again another one on the water this coming
14 spring.
15 MS. PAT NETH: How many people are employed on
16 this in this study, how many people are what's your
17 employment, how many people
18 MS. KAPLAN: How many staff people work on it?
19 MS. PAT NETH: How many people, like starting from
20 the top how many people are on your payroll?
21 .MS. FLESKES: How many people-are on our payroll?
22 MS. BERNSTEIN: We have a whole agency.
23 MS. FLESKES: The Frontier Hard Chrome team is
24 basically the people you see here, Dave Rountry, Mike
25 Gallagher and Megan White. But that's not the only site
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these people work on. They work on a number of other sites
than that.
"~ MS. PAT NETH: How many people are in here that
involved in the
MS. FLESKES; That are involved with the people in
some way?
MS. PAT NETH: That get payroll from it?
MS. BERNSTEIN: I'd like to get clear, that we work
on other projects, as well.
MS. KAPLAN: Probably just really the team.
MS. FLESKES: That are supported by the site
budget.
MS. PAT NETH: Five or ten-or 20?
MS. FLESKES: Basically I would say within Ecology
we basically have, you know, three people well, Lynn, o
four people that are partially supported by the Frontier Har
Chrome budget, and I stress partially supported, probably nc
more than 20 to 30 percent supported by that budget in the
long run.
MS. BERNSTEIN: Because we have other sites.
MR. GALLAGHER: 20 to 30 percent. That's one and
half equivalent people.
MS. PAT NETH: Other in Clark County?
MS. FLESKES: One other Superfund in Clark Count\
that we've been addressing.
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number?
MR. NISSEN: Would you repeat the toll-free
MS. BERNSTEIN: It's 1-800-458-0920. There will be
a machine, if somebody la not at the desk, but we will get
back to you within a day or two. I need to get your name and
phone number for the legal information.
MR. RISER: Are you pointing at me?
MS. BERNSTEIN: Yes.
MS. FLESKES: I think it's appropriate to draw the
meeting to a close. We will stay around for a few uinutes to
talk. Thank you for coming and providing us your comments.
(Hearing concluded.)
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CERTIFICATE
STATE OP WASHINGTON )
) 88.
County of Clark
I. Teresa Rider Poster, a Notary Public for
Washington, certify that the hearing re Frontier Hard Chrome
here occurred at the tine and place set forth in the caption
hereof; that at said time and place I reported in Stenotype
all testimony adduced and other oral proceedings had in the
foregoing matter; that thereafter my notes wern reduced to
typewriting under my direction; and the foregoing transcript
pages 2 to 94 both inclusive, contains a full, true and
correct record of all such testimony adduced and oral
proceedings had and of the whole thereof.
Witness my hand and notarial aval at Vancouver,
Washington, this 12th of November, 1987.
Teresa Rider Poster, RPR
Notary Public for Washington
My commission expires: 2-4-?
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