United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R10-88/013
March 1988
Superfund
Record of Decision
Gould, OR
-------
ROD/R10-88/013
d Site, OR
st Remedial Action
16. ABSTRACT (continued)
and lead oxide. VOCs were discovered in ground water, but will be addressed in a future
operable unit.
The selected remedial action for the soils unit at the site include: excavation of
all battery casing fragments and matte from the Gould property and adjacent contaminated
areas; a phased design program to determine the amount of material that can be recycled,
and to minimize the amount of material that must be RCRA landfilled; separation of
battery casing fragments; recycling of all applicable components; offsite disposal of
nonrecyclable material failing the EP Toxicity test; onsite disposal of nonhazardous,
nonrecyclable components; excavation, fixation/stabilization, and onsite disposal of
remaining contaminated soil, sediments, and matte with soil capping and revegetation;
isolation of surface water runoff to East Doane Lake by site regrading; and a monitoring
program to determine changes in ground water contamination over time and to ensure that
remediation does not adversely impact air quality. Additional ground and surface water
studies will be performed to determine the need for remediation of the media. The
estimated capital cost of this remedy is $3,491,603, assuming a "worst case" scenario
where little of, the material is recyclable, with present worth O&M of $17,073,581.
-------
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R10-88/013
3. Recipient's Accession No.
""RECORD OF DECISION
Gould Site, OR
•tst Remedial Action
5. Rtpoi
8. Performing Organization Rept. No.
9. Performing Organization Nam* and Address
12. Sponsoring Organization Nama and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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
10. Abstract (Limit: 200 words)
The Gould site is located in a heavily industrial area of Portland, Oregon,
approximately 1.3 miles southeast of St. John's Bridge. The site is contained in a
60-acre study area consisting of the Gould property and outlying areas containing
battery casings and other residues from site operations. The area 'is sparsely populated
and lies on the left bank floodplain of. the Willamette River. Doane Lake, a small pond,
is located adjacent to the site. The Gould site is mostly paved with asphalt,
, onsite flora and fauna are limited. Between 1949 and 1981, various owners
the site as a secondary lead smelting facility specializing in lead-acid
battery recycling, lead-smelting and refining, zinc alloying and casting, cable
sweating, and lead oxide production. Operations ceased in August 1981; and by the
summer of 1982 most of the structures, facilities, and equipment were removed. Remedial
investigation and production records estimate that 86,900 tons of battery casings,
11,800 tons of matte, and 6,570,000 gallons of acid were disposed of at the site.
Approximately 2% of the total volume of battery casings is located in surface piles, the
remaining 98% is used as fill material, and is in direct contact with ground water. The
primary contaminants of concern affecting the soil and sediments are lead
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Gould Site, OR
First Remedial Action
Contaminated Media: sediments, soil
Key Contaminants: lead
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18.
tbility Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
91
22. Price
(See ANSI-Z39.18)
See Instructions on Reverie
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
-------
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
INTERIM REMEDIAL ACTION
SOILS UNIT
GOULD SITE
PORTLAND, OREGON
-------
RECORD OF DECISION
REHEDIAL ALTERNATIVE SELECTION
Site
Gould site - Portland, Oregon.
Purpose
This decision document presents the selected Interim remedial action
for the site, developed In accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorlzatlon Act of 1986 (SARA), and
consistent with (where not precluded by SARA) the Nat-onal Contingency
Plan (NCP, 40 CFR Part 300). The State of Oregon Department of
Environmental Quality concurs with the selected remedy.
Basis for Decision
The decision is based upon the administrative record for the site.
This record Includes, but Is not limited to, the following documents'. -
8 Final Remedial Investigation Report for the Gould site, Portland,
. Oregon (November 1987)
? Final Feasibility Study Report for the Gould Site, Final Report
(February 1988)
0 Decision Summary of Remedial Alternative Selection (attached)
0 Responsiveness Summary (attached as Appendix B)
8 A complete list of documents contained In the Administrative Record Is
Included as Appendix C
Description
This record of decision addresses the soils unit at the Gould site.
By doing so the remedy focuses on removing the principal source of lead
contamination to the environment. The remedy also Includes further study
to determine whether additional remedial measures are required for
groundwater and surface water at the site.
-------
This remedial action is designed to:
0 remove lead from the battery casings through recycling;
0 reduce the mobility of lead in the contaminated soil, sediment an8|
matte at the site through fixation;
continue monitoring of surface water and groundwater at the site
while additional study of contamination In these areas Is done; and
0 monitor ambient air around the site to ensure that remedial actions
are carried out in a manner that 1s protective of public health.
The extent to which lead and other components of the battery casings can
be recycled will depend on the results of design work under this remedy. The
results of the design studies will be used to determine the recyclablllty of
the battery casings and the protective measures to be employed during
remediation. A phased approach, described In the selected remedy, will be
employed in the design work.
It is EPA's Intent in selecting this remedy to treat all of the battery
cas1ngs at the site and at the same time minimize the amount of material that
rr.it be sent to a RCRA landfill. Should the results of the design phase show
that these goals are not compatible, an additional public comment period will
be established and this Record of Decision may be modified. At such time, EPA
would present for comment additional options for dealing with the treated
materials.
Treatment and removal of casings and treatment of soils will remove lead
and eliminate potential for exposure due to direct contact and Ingestlon.
Immobilization of lead in soils, sediment and matte will reduce migration o^
lead as a potential source of further contamination to groundwater and surface
water at the site.
Institutional controls will be Implemented, during and after
remediation. The purpose of these controls will be to assure that the
remedial action will protect public health and the environment during Its
execution, and to ensure a similar level of protection after the remedial
actions have been Implemented and prior to a final decision at this site.
-------
Declaration
Consistent with CERCLA, as amended by SARA, and the NCP, it is
determined that the selected remedy as described above is protective of
human health and the environment, attains Federal and State- requirements
which are applicable or relevant and appropriate, and is cost-effective.
This remedy satisfies the preference expressed in SARA for treatment that
reduces toxicity, mobility, and volume. Finally, it is determined that
this remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Date
—Regional Administrator
Environmental Protection Agenty
EPA - Region 10 \
-------
DECISION SUMMARY
REMEDIAL ALTERNATIVE SELECTION
INTERIM REMEDIAL ACTION
SOILS UNIT
GOULD SITE
PORTLAND, OREGON
-------
TABLE OF CONTENTS
Page
I SITE DESCRIPTION AND BACKGROUND ,
Site Location and Description
Site Features
II ENFORCEMENT SUMMARY «'
III COMMUNITY RELATIONS SUMMARY 9
IV NATURE AND EXTENT OF PROBLEM „
Contaminants Evaluated
Extent of Contamination
Treatability Studies
Potential Transport and Need for Additional Study
Endangerment Assessment . .
V ALTERNATIVES EVALUATION
Summary of Alternatives and Evaluation Criteria
Screening of Alternatives
Alternative 2C Evaluation
Alternative IOC Evaluation
Alternative 21 Evaluation
VI SELECTED REMEDIAL ALTERNATIVE
Description of the Selected Remedy
Design Studies
Monitoring
Institutional Controls
Additional Study
Performance Standards
Statutory Determinations
APPENDICES
A. APPLICABLE AND APPROPRIATE REQUIREMENTS
B. RESPONSIVENESS SUMMARY
C. INDEX TO ADMINISTRATIVE RECORD
D. STATE CONCURRENCE
26
-------
LIST OF TABLES
Pace,
Table 1 '
Table 2
Table 3
Table 4
Table 5
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Enforcement History
Battery Casing Quantities and Locations
Estimated Battery Component Quantities
Estimated Secondary Source Volumes
Cost Screening Summary
LIST OF FIGURES
General Vicinity Map
Study Area Location Map
Locations of Battery Casings and Mo:*:e
Lead Contamination In Surface Soils
Lead Contamination in Fill Aquifer
Lead Contamination in Upper Alluvial Aquifer
Lead Contamination in Lower Alluvial Aquifer
Summary of Exposure Calculations
Estimated Areas to be Remediated Under Selected
7
11
12
15
29
Paqe
2
3
13
14
\
17
18,
19
24
Remedy 43
Note: Sources for Figures are Remedial Investigation and Feasibility Study
Reports.
-------
I. SITE DESCRIPTION
Site Location and Description
The Gould site is located In the Doane Lake area of Portland between
N.H. St. Helens Road and N.W. Front Avenue, about 1.3 miles southeast of
St. John's Bridge. The Gould site Includes the property presently owned
by Gould, along with areas outside the property boundary where battery
casings and other residues from operations on the Gould site were placed.
Because of the potential for dispersion of contaminants In water, the site
also Includes the 1963 boundaries of Doane Lake. As shown on Figure 1
(General Vicinity Map), the Willamette River lies about 1,000 feet to the
northeast and flows northwest, parallel to Front Avenue. The area Is
heavily Industrialized. The Gould site Is only a portion of the 60-acre
study area, shown on Figure 2 (Study Area Location Map).
The study area is roughly bounded on the southwest by N.H. St. Helens
Road, on the northeast by N.W. Front Avenue, on the southeast by 61st
Street, and on the west and northwest by the Burlington Northern railroad
right-of-way. Industrial properties adjacent to the Gould site that lie
wholly or partly within the study area Include American Steel Industries,
Inc.; ESCO Corporation; Rhone-Poulenc Inc.; Northwest Equipment Rentals,
Inc. (leased from Rhone-Poulenc); Schnltzer Investment Corporation, and
Liquid Air Corporation (leased from Schnltzer).
Available aerial photographs taken since 1936, and topographic mapping
as early as 1884. indicate that the study area now occupied by"Gould
property and adjacent industries was formed by gradual and Intermittent
man made filling of a fairly large body of shallow water known as Doane
Lake.
On the current Gould site, a secondary lead smelting facility was
completed and went into operation In 1949 under the ownership of Morris P.
Kirk and Sons (Kirk & Sons), a subsidiary of NL Industries, Inc. Facility
operations consisted of lead-acid battery recycling, lead smelting and
refining, zinc alloying and casting, cable sweating (removal of lead
sheathing from copper cable), and (after 1965) lead oxide production. NL
Industries, Inc. purchased the property from the subsidiary In 1971. The
property was sold by NL Industries to Gould, Inc. In January 1979. In
October of the same year, Gould stopped receiving lead-acid batteries, but
continued to process a substantial existing stockpile of batteries. In
January 1980, lead refining operations were discontinued. Battery
breaking operations ceased on April 1, 1981. lead oxide production ceased
In May 1981. and the facility closed entirely In August 1981. By the
summer of 1982, most of the structures, facilities, and equipment had been
removed.
In 1981 EPA and DEQ began Investigating the site, and the site was
placed on the Superfund National Priorities list In 1983. In 1985 NL
Industries and Gould Inc. signed an Order on Consent with EPA under which
NL and Gould conducted a Remedial Investigation (RI) and Feasibility Study
(FS) at the site. The final RI report was submitted to EPA In November
1987 and the final FS report was submitted In February 1988.
-------
o.s
SCALE IN MILES
o
I
Figure 1
General Vicinity Me
-------
SCHNITZER
INVESTMENT CORP.
AMERICAN STEEL INDUSTRIES.
INC.
,\ RHONE-POULENC INC.
X
X.
NOTE: THE STUDY AHCA BOUNDARY AS SHOWN DOES NOT INCLUDE
THE WILLAMETTE RIVER SAMPLING AREA OR THE BACKGROUND
SURFACE SOU SAMPLING AREAS SOUTH OF ST. HELENS ROAD.
••• • •••
STUDY AREA BOUNDARY
1OO
400
fiom • lapoeopklc *u»«v •>•» «•••• Mmj IS. <•••.
Dr D.E. U»« S A»
f»t Dan*** ft Mo«f*
rtiT
SCALE I* ZOO*
Figure 2
Study Area Location
Map
-------
Site Features
In general, the Gould site is located in an area which Is less densely
populated than surrounding areas to the northeast and southeast. The :e
is located in census tract 43, a large tract which parallels the
Willamette River for approximately 7 miles. A few widely scattered
private residences and rental units are located In a narrow zone between
N.W. St. Helens Road and Forest Park, south and west of the study area.
The 1985 census data for all of Census Track 43 shows a total of 425
dwelling units, 380 of which are single family homes. The site Is located
about 13 miles from the city center of downtown Portland, with a
population of over 400,000.
The existing land use in the study area and vicinity Is primarily
Industrial, and generally follows the City of Portland zoning code
designations. No significant changes in the area's existing land use
patterns are presently planned.
Airflow is usually northwesterly in the Portland area In spring and
summer, and southeasterly in fall and winter. The winter season 1s marked
by relatively mild temperatures, cloudy skies and rain with southeasterly
surface winds predominating. Summer produces mild temperatures.
northwesterly winds and little precipitation. Wind direction at the Gould
site Is strongly Influenced by the topographic features of the hillside
southwest of the site. Resulting wind directions tend to be
northwest-southeast along the Willamette River. Precipitation In the
Portland area 1s mostly rain. Average rainfall Is 37.39 Inches. Monthly
averages vary from 0.46 Inches in July to 6.41 Inches In December.
The Gould site is located on the left bank floodplaln of the
Willamette River, approximately 7 miles upstream from the confluence of
.the Willamette River and the Columbia River. The floodplaln of the
Willamette River occupies the lowest portions of the Willamette Valley,
which is a broad downwarp between the Cascade and Coast Ranges of
northwest Oregon and southwest Washington. In addition to man-made fill,
the site is underlain by a few to several tens of feet of alluvial
deposits, which in turn overlie the lava flows of the Columbia River
Basalt. The site is situated on the northeast flank of the Portland Hills
anticline, where the anticline dips beneath the young sediments that fill
the Portland Basin. Groundwater flow Is generally In a northerly
direction.
The Gould site occupies a flat area between the Willamette River on
the east and the forested slopes of the Tualatin Mountains to the west.
The site Is mostly paved with asphalt and 1s basically devoid of natural
vegetation. The vegetation that exists Is mostly brush, small trees, and
blackberries along the property fencellne.
Occurrence of animals at the site Is low, since the habitat necessary
to support on-slte fauna Is limited. Common animal species that have been
seen on-s1te Include ground squirrels that are resident on the pond, and
bird species that feed In the brushy, weedy areas around the site
perimeter. Some cattails grow 1n East Ooane Lake.
-------
It is doubtful that any fish reside in either West or East Doane Lake
since natural water sources and discharges are limited. Also, high levels
of contamination have resulted in water quality levels that will not
support higher aquatic life forms. Some amphibians have been noted in and
around the lake. Numerous fish species reside in or migrate through the
lower reach of the Willamette River in the vicinity of the site.
-------
II.
On the current Gould site, a secondary lead smelting facility was
completed and went into operation 1n 1949 under the ownership of Morris P.>
Kirk and Sons (Kirk & Sons), a subsidiary of NL Industries, Inc. Facility!
operations consisted of lead-acid battery recycling, lead smelting and
refining, zinc alloying and casting, cable sweating (removal of lead
sheathing from copper cable), and (after 1965) lead oxide production.
Available records for the period between February 1960 and January
1970 indicate that Kirk & Sons received 14 complaints and/or violations
regarding emissions from the facility. A January 29, 1970 report by the
Columbia-Willamette Air Pollution Authority expressed concern over levels
of lead In the vicinity of Morris P. Kirk, and the potential threat to
health caused by continued plant operations.
NL Industries. Inc. purchased the property from the subsidiary In
1971. Three violations for excessive emissions were recorded In 1972.
Lead was detected in Doane Lake In 1973, and NL Industries was dted for
improper wastewater discharge into the lake. On July 30, 1973, NL
Industries curtailed all smelting operations, but the lead oxide still,
cable sweater, and refining kettles continued to ooerate. Available
records Indicate that the facility operated In corr.il lance with DEQ
guidelines during 1974 through 1976.
The property was sold by NL Industries to Gould, Inc. 1n January
1979. In October of the same year, Gould stopped receiving lead-add
batteries, but continued to process a substantial existing stockpile of
batteries. In January 1980, lead refining operations were discontinued.
Battery breaking operations ceased on April 1, 1981, lead oxide produc-
tion ceased in May 1981, and the facility closed entirely In August 1981.
By the summer of 1982, most of the structures, facilities, and equipment
had been removed.
In 1981 EPA and DEQ began Investigations of the site. The site was
placed on the Superfund National Priorities List In 1983. In 1985 an
order on consent was signed with NL and Gould which Involved the
performance of an RI/FS at the site.
More recently, Special Notice Letters have been sent to NL and Gould
under the authority of Section 122 of CERCLA. Information requests under
Section 104(e) have also been sent to Industries In the vicinity of the
site requesting Information on hazardous contaminants and contamination at
those facilities. The Information received from these companies will be
used In designing the additional groundwater and surface water studies
described In the selected remedy.
A historical sequence of enforcement related events Is presented 1n
Table 1.
-------
TABLE 1
ENFORCEMENT HISTORY
July 1966
Dec. 1966
1967
Dec. 1968
March 1969
Nov. 1969
Jan. 1970
March-June 1970
1971
March 16, 1972
March 1973
April 1973
July 1973
The Air Quality Control
-------
Oct. 1976 Violations for wastewater discharge by NL Industries
corrected.
Aug. 15, 1978 East Doane Lake sampled by DEQ; test results Indicated 0.1
and 0.3 ppm lead.
Jan. 1979 Gould Inc. purchased the facility from NL Industries.
Nov. 8, 1979 Preliminary modeling analysis by DEQ suggested Gould may be
violating the new ambient lead standard for the lead
trailer loading operation.
March 5, 1981 DEQ issued notice to Gould of discharge violations and
creating offensive conditions.
April 1981 DEQ obtained two yard-cleaning samples; EP leachate test
results indicated 280 and 4,200 ppm lead.
July 1981 DEQ sent notice to Gould of Intent to assess dv1l
penalties.
Aug. 1981 Gould facility ceased all operations.
Oct. 30, 1981 DEQ requested that Gould .undertake a comprehensive cleanup
program.
July 22, 1982 DEQ decided no cleanup of the Gould site was warranted b*i
the groundwater data received to date.
Sept. 24, 1982 DEQ requested that Gould submit a schedule for removing the
battery cases from the site and for sampling soil and pond
sediments on the site.
Oct. 26, 1982 Gould responded to DEQ request. Indicating that they would
level and cover the battery casings.
Dec. 1982 DEQ rejected Gould's plan for covering the battery casings.
Feb. 1983 Gould Inc. submitted a letter to EPA objecting to EPA's
Hazard Ranking System (HRS) score for the site (see
Appendix D). The score had been used by EPA to propose
Inclusion of the site on the NPL. In particular, the Gould
letter objected to the methods used to determine airborne
contaminant hazards at the site.
Aug. 1985 Gould Inc. and NL Industries signed Section 106, Adminis-
tration Order on Consent for the Remedial Investigation/
Feasibility Study (RI/FS) of the facility.
April 1986 Work. Plan for RI/FS by Dames & Moore was approved and site
Investigations began.
Nov. 1987 Final RI report submitted to EPA and OEQ.
Feb., 1988 Final FS report submitted to EPA and DEQ.
8
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III. COMMUNITY RELATIONS SUMMARY
In 1983, Oregon congressional representative Les AuCoin corresponded
with DEQ about the site, and DEO held a meeting with city, county, and
state agency officials to present information about environmental concerns
in the area and to solicit comments. Representative AuCoin specifically
requested that DEQ assure him that site cleanup would completely remove
potential contaminants.
A Community Relations plan was prepared for this site In 1985 based on
research and Interviews with interested community members and officials.
The Community Relations Plan identified several Issues of concern to the
affected community and local officials, Including:
1. Groundwater Pollution. People were concerned about ground- water
contamination in the area and how It might affect future growth
of the area.
EPA responsed to this concern by including extensive groundwater testing
in the RI.
2. Airborne Lead. Several agency officials "ndlcated that high
levels of lead emissions were a primary concern and that high
levels of airborne lead could adversely affect the health of
nearby workers. Exposure to lead at the approximately 10 houses
in the hills above the site was thought unlikely, but necessary
to investigate.
EPA has included air monitoring in the RI.
3. Effects on Workers' Health. Individuals were concerned about
exposure through incidental Ingestlon of ground water obtained
for Industrial use and exposure to airborne lead.
EPA has included exposure scenarios for workers in the risk assessment
for the site.
4. Cleanup Schedule. Staff from Representative AuCoin1s office and
a representative from the Oregon State Public Interest Research
Group expressed dissatisfaction that cleanup measures had not
been Implemented earlier.
EPA has attempted to evaluate the site and make a remedial decision in
an expeditious manner. By focusing on the soils unit, a decision will be
made now.
5. Future Development of the Doane Lake Area. The media and local
officials expressed concern about how the current pollution would
affect or restrict future uses of the land.
Future use restrictions are expected to be minimized by removing or
treating as much of the lead at the site as possible.
6. Disposal of Dredged Materials from the River. A representative
from the Port of Portland Indicated the Port's concern about
disposing of dredged materials from the Willamette River that
might be found to contain contaminants from the site.
-------
The RI included an evaluation of sediment around the outfall from East
Doane Lake.
7. Environmental Investigation of Doane Lake Area. A representative
from the Association of Oregon Industries and representatives of
elected officials indicated concern that OEQ's environmental
Investigation In the Doane Lake area could decrease future
Industrial development and jobs In the community.
No reports of decreased industrial development as a result of these
investigations has been received by EPA.
8. Disposal of Battery Casings. An aide to Representative AuColn's
office expressed dissatisfaction that battery casings had not
been removed from the site. Representatives from the Portland
Department of Public Works cautioned that any plan to dispose of
waste materials at St. John's'Landfl11 would be unpopular.
EPA intends to recycle as much of the battery casing components as is
. feasible.
Throughout the course of the RI/FS, additional updates were provided
to the public during the investigation and reporting phases. A proposed
plan and notice of public hearing was published In the Oregon Ian on
February 8, 1988. The public comment period for the site was from
February 8 through March 18. Two public meetings were held to discuss the
results of these studies and EPA's proposed plan: the first on February
18, 1988 and the second on March 10, 1988. At both meetings, there was
clear community support for thorough cleanup of the site and contaminated
groundwater. The results of these meetings will be discussed further In
the Responsiveness Summary (Appendix B).
IV. NATURE AND EXTENT OF PROBLEM
Contaminants Evaluated
During the scoping of the RI/FS, the emphasis at this site was on
metals contamination from the battery recycling operations. Of primary
Importance was the presence of lead In each of the media. Although
groundwater In this area also has organic chemical contamination, that
contamination was not evaluated In these studies. As part of .the selected
remedy, additional work 1s proposed for the groundwater which will take
Into account organic chemical contamination. The purpose of this
additional work will be to determine what, If any, remediation actions are
required for the surface water and groundwater at the site.
Contaminated media at the Gould site that were Investigated Include
battery casings, matte, surface soils, subsurface soils, lake sediments,
surface water, and groundwater.
10
-------
Extent of Contamination
Battery Casings and Matte. The lead smelter on the Gould property
operated between 1949 and 1973. During this period, a dally production of
approximately 35 to 40 tons of lead has been reported. An average of
1,500 batteries were processed dally. As a result of these production
records and the RI Investigation, a total of 86,900 tons of battery
casings and 6,570,000 gallons of acid were estimated to be disposed of at
the site.
In addition to acid and battery casings, a third waste product called
matte was produced by the smelting operation. Matte disposal Is estimated
at 11,800 tons. This material was reportedly used as fill only on the
Gould site, just to the northeast of the facility.
Much of the battery casing fragments produced during this period
(1949-1973) were disposed off site on the Rhone-Poulenc property. The
quantity of battery casing materials disposed was calculated using test
pits and a fill thickness contour map. Table 2 summarizes the locations
and estimated quantities of battery casings. Figure 3 shows the locations
of the battery casings and matte within the study area.
TABLE 2
BATTERY CASINGS QUANTITIES AND LOCATIONS
Gould Property (1949-1973) 41,300 cu yds 44,500 tons
(post-1973) 11.100 cu yds 12",000 tons
Surface Piles 1.700 cu yds 1,600 tons
Rhone-Poulenc Property 26.700 cu yds 28.200 tons
Totals 80,800 cu yds 86,900 tons
The batteries consist of hard rubber, ebonite, plastic casings,
metallic lead, and lead oxides. Lead concentrations (mostly lead oxide)
ranged from 7,600 mg/kg (0.76 percent) to 190,000 mg/kg (19 percent). All
of the battery casing samples had EP Toxlclty results for lead above the
regulatory limit (EP Toxlclty limit « 5.0 mg/1). These values ranged from
21 mg/1 to 220 mg/1. There was no apparent correlation between total lead
concentration and EP Toxlclty leachate lead concentration. The EP
Toxlclty results for arsenic, chromium, and cadmium were below detection
limits.
About 21 of the total volume of battery casings Is located In surface
piles on the Gould property, the remaining 981 Is part of the fill on the
Gould and Rhone-Poulenc properties. These subsurface casings are In
direct contact with groundwater underneath the site. The characteristics
of the surface piles of casings differ from the subsurface piles. The
surface piles contain a higher percentage of plastic and metallic lead
relative to subsurface casings on the Gould property'or from the
Rhone-Poulenc property, which contain a higher percentage of rock and
slag. The metallic lead, plastic, ebonite and lead oxide components of
these casings are potentially recyclable. The estimated fractions of the
various components In the surface and subsurface casings are shown 1n
Table 3.
11
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TABLE 3
ESTIMATED BATTERY COMPONENT QUANTITIES
Rhone-Poulenc &
Gould Subsurface
Ebonite
Plastic
Metallic Lead
Lead Oxide/Mud
Rock/Slag
Other
Moisture
Subtotal
In-Situ Density
Ibs/cu. ft.
68.00
46.56
297.46
238.37
105.56
74.28
62.30
79.80
In-SItu Volume
cu. yds.
69,008
4.070
117
2,703
1,938
1,264
0
79,100
Tons
63.349
2.558
469
8.700
2,762
1.268
6.113
85,218
Per Cent
(weight)'
74.3
3.0
0.6
10.2
3.2
1.5
7.2
Gould Surface
Ebonite
Plastic
Metallic Lead
Lead Oxide/Mud
Rock/Slag
Other
Moisture
Subtotal
Total
65.81
45.06
287.88
230.69
102.16
71.89
62.30
70.07
79.60
899
595
6
52
148
0
0
1.700
80,800
799
362
24
161
204
0
H
1.609
86,827
50.0
22.5
1.5
10.0
12.7
- 0
3.7
The matte materials consist of metallic sulflde chunks primarily
containing Iron and lead. Lead concentrations In the matte samples ranged
from 6.4 percent to 11 percent. All of the samples had EP Toxlclty
results for lead above the regulatory limit of 5.0 mg/1. Low
concentrations of arsenic and cadmium were detected 1n the EP Toxlclty
leachates. These concentrations were within the regulatory limits (5.0
mg/1 and 1.0 mg/1, respectively).
Surface Soils. Subsurface Soils, and Sediments
In addition to battery casings and matte, large quantities of soil at
the site are contaminated with lead and can serve as secondary sources for
lead transport. The quantities of surface soil, subsurface soil, and
sediment considered to be secondary sources were estimated by using total
lead and EP Toxlclty data.
Figure 4 shows the areas of surface soil that were Identified as
secondary source areas using the above total lead criteria. The quantity
of surface soil on the Gould property considered a secondary source Is
approximately 2.400 cu yds. The quantity on the Rhone-Poulenc property Is
approximately 970 cu yds. These quantities are based on a 3,000 ppm lead
level In soils. Criteria for surface soils In the selected remedy are
based on a lower lead level and as a result actual volumes determined In
design may be higher than these estimates.
12
-------
AMEMCAN STEEL MDUS1MES.
INC.
AUTO 000V nu. MTO
A9MOUMATI OLMT MMAM HAITI »*1 WTI
• MATT! Tt«f MT 1OCATMM*
Location of Battery
Casings & Matte
-------
PENNWALT CORP.
SCHNITZER
INVESTMENT CORP.
C"A \ '
;f*\ \ OOULOINC. +*$•'
^ .Una*8* ;*
MN STEEL INDUSTTUES.
INC.
D \
••-10
•x.
% RHONE-fOULENC INC.
V\
a
LIMMO
-i\
•UMAC! tAMPil LOCATION
COMCMTIIATMNI Of IIAO «»f M)
•M OuriWATI
MIT
86.
Figure 4
Lead Contamination
in Surface*
-------
The volumes of subsurface soils estimated to be secondary sources are
as follows:
1. One foot of soil below the entire area of the battery casing/
matte excavations. This would amount to 4,300 cu yds from the
area on Rhone-Poulenc property and 5,000 cu yds from the area on
the Gould property; and,
2. One foot of soil from the sides of the excavations. Assuming
average excavation depths of 20-feet on the Rhone-Poulenc pro-
perty and 25-feet on the Gould property, and an excavation
side-slope ratio of 2:1, this would amount to approximately 2,170
cu yds from the Rhone-Poulenc property and 2,180 cu yds from the
Gould property.
Sediment samples collected from East Doane Lake contained total lead
concentrations ranging from 160 mg/kg (parts per million) to 12,000
mg/kg. The estimated quantity of secondary source material In East Doane
Lake Is 5,500 cubic yards. West Doane Lake sediments are not considered
secondary sources.
Sediments collected In the Willamette River during August 1986 a.nd
February 1987 had generally low metals concentrations. Total lead con-
centrations ranged from 26 to 56 mg/kg. Other metals concentrations
Included total arsenic at 5.7 to 6.2 mg/kg, total chromium at 9 to 26
mg/kg, and total zinc at 72 to 82 mg/kg. Cadmium and hexavale«it chro--
m1um concentrations were near or below the detection limits. Like the
West Doane Lake sediments, Willamette River sediments are not considered
secondary sources. The total quantity of soil considered secondary source
material is summarized In Table 4. ' -
TABLE 4
ESTIMATED SECONDARY SOURCE VOLUMES
TYPE AND LOCATION QUANTITY (cu yds)
Surface Soil
Gould property
Rhone-Poulenc property
Surface Soil Total 3,370 3.370
Subsurface Soil
Gould property 5.000
Bottom Sides 2.180
Sub-total 7.180
Rhone-Poulejic property 4,300
Bottom Sides 2.170
Sub-total 6,470
Subsurface Soil Total 13.650 13.650
Sediment
East Doane Lake 5.500 5.500
Secondary Source Total 22,520
15
-------
Surface Hater. Surface water in the study area consists of two
remnants of Doane Lake. The two remnants are referred to as East Doane
Lake and West Doane Lake (see Figure 2).
Direct precipitation and precipitation runoff from surrounding
properties are the only sources of surface water to the lake remnants.
Groundwater recharge also contributes water to the remnants. Their
surface elevation rises and falls seasonally with rainfall and presumable
groundwater recharge. However, there Is no simple relationship apparent
between precipitation and lake level.
East Doane Lake discharges via a drain pipe to the north beneath N.W.
Front Street; the discharge enters the Willamette River approximately 200
feet east of the railroad bridge. There Is no known surface discharge
from the West Doane Lake remnant.
Surface water In East Doane Lake exceeds the lead drinking water
standard of 0.05 mg/1. Surface water concentrations were as high as 0.28
mg/1. Levels In West Doane Lake were below the standard.
Ground Water. The site hydrostratlgraphy Includes unconsol1 dated fill
and alluvial deposits overlying basalt flows. The fill consists largely
of sands and gravels, silts, and an abundance of slag, bricks, metal
parts, and battery casings. The alluvial deposits consist predominantly
of clays, silts and sands with the silt content generally Increasing with
depth. The basalt flow beneath the fill and alluvial deposits 1s thought
to be fractured and weathered. Ground water occurs In the fractured and
weathered portions of the basalts. "
The fill and alluvial deposits form an Interconnected, heterogen-
eous, and anisotropic aquifer.: The fill.and alluvial water-bearing zones
are believed to be generally unconflned; however, due to the layering,
heterogeneity, and anisotropy there may be locally confined conditions
within the aquifers.
Four water-bearing units are Identified beneath the site. These units
are the fill, the upper alluvial, the lower alluvial, and the basalt
water-bearing units. In the upper aquifers there Is a significant
component of downward flow, although flow at the basalt-alluvial Interface
appears to be from the basalt to the alluvial aquifer.
Groundwater Contaminant Delineation. Figures 5,6 and 7 show the
extent of lead contamination In the fill and alluvial aquifers. The
contours show where dissolved lead concentrations exceed the MCL of 0.05
mg/1 as well as the MCLG of 0.02 mg/1. The sulfate plume that has
resulted from disposal of battery add Is also shown.
The relationship between dissolved metals, sulfate concentrations and
pH 1s similar In both the fill and alluvial aquifers. Both show elevated
dissolved metals and sulfate levels In association with lower pH values.
In the-upper alluvium, the lead plume has migrated at least as far
north as well 100. shown in Figure 6. Increased dissolved metal
concentrations appear to be the result of the lower pH which Increases the
solubility of metals, thus carrying high levels of lead as the "plume"
migrates. Total lead migration from the site Is estimated to be from 0.3
to 0.6 Ib/yr.
16
-------
PEMHW ALT CORP
UOUD MR COHP.
SCHNIZTER
INVESTMENT CORP.
ELEVATED
SULFATE _
.AREA
AMERICAN STEEL MMJSTRCS.
INC.
RHONE-POULENC
PROPERTY LINE
RAH.ROAO SPUR
STRUCTURE
REMNANT LAKE. DASHED WHERE APPROXIMATE
WELL LOCATION AND NAME
BORING LOCATION AND NAME
TEST PIT .LOCATION AND NAME
STAFF GAUGE
APPROXIMATE SULFATE PLUME BOUNDARY
(AVERAGE OISSOLVEO SULFATE CONCENTRATION > SO PPM)
AVERAGE OISSOLVEO LEAD CONCENTRATION >0.02 PPM
X
AVERAGE OISSOLVEO LEAD
CONCENTRATION 20.03 PPM
100
•••too*
Flgun 5
Lead Contamination
in Fill Aquifer
-------
ELEVATED
SULFATE
AREA
SCHNIZTER
INVESTMENT CORP
X
STRUCTURE
REMNANT LAKE. DASHED WHERE APPROXIMATE
WELL LOCATION AND NAME
•ORMG LOCATION AND NAME
TEST PIT LOCATION AND NAME
STAFF GAUGE
APPftOXMATE SULFATE PLUME BOUMOARV
(AVERAGE DISSOLVED SULFAT* CONCENTRATION i 90 PPM)
AVERAGE DISSOLVED LEAD CONCENTRATION 20.02 PPM
AVERAGE DISSOLVED LEAD
CONCENTRATION jO.OS PPM
r-j
Figure 6
Lead Contamination in
Upper Allu\^BtAquifer
-------
V —
"±
^•<
^'
^
/'
riU-
f'l ' , "
NW FRONT AVI •
A
iK2*t — ::"" —
PCNNWALT CORP.
X
SCHNIZTER
INVESTMENT CORP.
UQUD AIR COUP.
ELEVATED
SULFATE
AREA fr-
AMERICAN STEEL MMISTOES
INC.
STRUCTURE
REMNANT LAKE. DASHED WHERE APPROXIMATE
WELL LOCATION AND NAME
•ORMO LOCATION AND NAME
TEST PIT LOCATION AND NAME
STAFF GAUGE
APPROXMATE SULFATE PLUME BOUNDARY
(AVERAGE DISSOLVED SULFATE CONCENTRATION > SO PPM)
AVERAGE DISSOLVED LEAD CONCENTRATION 20.02 PPM
0.
X
AVERAGE OISSOLVEO LEAD .
CONCENTRATION 20.08 PPM
100
IN MO*
Flgurt 7
Lead Contamination in
Lower Alluvial Aquifer
-------
Treatability Studies on Casings and Contaminated Soils
As part of the Feasibility Study, several engineering studies were
performed to determine whether the SARA preference for treatment could be
met. A bench-scale soil stabilization study was performed by Weston
Services, Inc. Weston used several different reagents to determine the
applicability of the soil stabilization technique to site soils and lake
sediments. The results showed that admixtures of.Portland cement, cement
kiln dust, and lime kiln dust with the soil and sediment at specific
Increments Improved the consistency and structural stability of the soils
and sediments, and also reduced the leachablllty of the contaminated
materials to levels generally below hazardous waste designation levels.
Three battery casing separation tests were performed on site
materials. One test was performed on equipment manufactured by MA
Industries, Inc. and the other two on equipment manufactured by
Poly-Cycle Industries, Inc. To conduct each test, representative material
was excavated from the site and shipped to locations where equipment
manufactured by the two companies Is in use. In the case of MA
Industries, the test was run on equipment operated by Ace Battery Company
of Indianapolis, Indiana. The tests of Poly-Cycle equipment were run at
the Poly-Cycle plant in Jacksonville, Texas. The studies show that much
of the battery casing material Is potentially recyclable, however,
additional design work will be required to modify the pilot facilities
used in the treatability studies to actual conditions at the site.
Reasonable physical separation of the plastic and ebonite components with
some equipment modifications appears to be possible, although sthe degree
of metallic lead contamination of ebonite may be h'igh even after
separation; additional design work will be required to modify the process
to treat the ebonite stream in order for It to pass the EP Toxlclty test.
During the evaluation of alternatives, similar tests were run
independently by researchers working on materials from the United Scrap
Lead Superfund site near Troy, Ohio. Researchers there performed
bench-scale tests using various solutions and mechanical cleaning steps to
determine the amenability of lead to be removed from the ebonite
material. The results of this test are generally favorable Indicating
that the ebonite stream can be cleaned. However, the researchers have
concluded that more work Is required before the bench-scale results could
be applied to any field-scale unit. This Is a typical requirement for any
bench scale testing.
Contaminant Transport and Need for Additional Study
Two types of lead sources exist at the Gould site. The major source
Includes debris remaining from earlier lead recovery operations, Including
battery casings and parts and the smelter matte. Secondary sources which
may be significant Include surface, sediment, and subsurface soils near
the Industrial sources. These materials may act as a source for lead In
ground water, surface water or air after the primary (Industrial) sources
have been removed or stabilized.
Groundwater Transport. The most Important chemical change encountered
In the groundwater system on (and near) the site Is pH change. At the
primary sources, the pH Is generally quite low (pH <5) because of the
sulfurlc add from the scrapped batteries. As pH Increases, the
solubility of lead In water decreases, accompanied by the precipitation of
lead oxides and hydroxides.
20
-------
The amount of lead that can be dissolved in ground water is a function
of temperature, pH, other dissolved species present, amount of available
lead and contact time. Assuming temperatures to be constant, all these
factors are significant with regard to lead solubility In ground water in
the study area. Based on these factors, an estimated migration rate of
0.3 to 0.6 Ib/yr was derived during the RI.
Airborne Transport. The potential for airborne contamination comes
from the surface piles of casings and contaminated surface soils at the
facility. During the RI, the highest dally ambient lead values observed
were 5.20 ug/m3. This is above the NAAQS of 1.5 ug/m3. The highest
monthly average airborne lead concentrations observed were 1.56 ug/m3
and 0.94 ug/m3. The highest quarterly average airborne lead
concentration was 0.56 ug/m3. These results indicate that dry weather
and disturbance of site mater dls may cause airborne transport of lead
containing materials.
Need for Additional Study The exact nature of lead migration has not
yet been well characterized. For that reason,' additional Investigations
of the groundwater and surface water unit at this site are recommended In
the selected remedy. The proposed additional work will Involve expanding
the area for groundwater and surface water monitoring and Including
organic chemical contamination in the evaluation of groundwater quality.
Endflpf^erment Assessment
Human Health Effects. An endangerment assessment was perf6rmed to
evaluate the potential for human health and environmental exposure risks
associated with the no-action alternative as well as the remedial action
alternatives. The primary contaminants Included In the assessment are
lead, along with arsenic cadmium, chromium and zinc. Arsenic Is treated
as a carcinoge/i for both inhalation and Ingestion routes, while cadmium Is
treated as a carcinogen for only the Inhalation route. As part of the
endangerment assessment, a screening analysis for these other contaminants
was performed based on the values found at the site and the relative
toxlclty of these compounds compared to lead. As a result of this
screening, risks from lead exposure were found to dominate risks from
exposure to the other chemicals. Lead was selected as the Indicator
compound for assessing risk and evaluating the various remedial
alternatives.
Three potential critical pathways were Identified, Including airborne
exposure from on-slte fugitive dust sources. Incidental oral Ingestion of
contaminants, and dermal contact as well as Incidental Ingestion of lead
from surface water In East Doane Lake. No exposure from drinking water
was Included. Groundwater contamination will be evaluated further In the
additional work proposed under the selected remedy.
Inorganic lead may be absorbed by Inhalation or by Ingestion.
Absorption by either route contributes In an additive fashion to the total
body burden. Among adults. Inhalation Is the more efficient of the two
mechanisms. The fraction of Inhaled lead absorbed from the respiratory
tract Is approximately 40 percent, while the fraction of Ingested lead
absorbed from the gastrointestinal tract Is approximately 10 percent.
These rates may be higher in children and are of particular relevance In
assessing exposures In this sensitive subpopulatlon.
21
-------
Lead is highly persistent in the environment and is bioaccumulatlve.
When lead is first absorbed, it enters the bloodstream and is dispersed
unevenly in the body among blood, soft tissue, and bone. Approximately
90 percent of the lead in blood is bound to the red blood cells. The
overall half-life of lead in blood has been calculated to be 36 + 5 days.
Lead Is excreted from the blood into the urine. Lead In soft tllsue has a
calculated mean half-life slightly less than that In the blood and Is
excreted by alimentary tract secretions, hair, sweat, and nails. Most
lead absorbed Into the human body Is deposited in the bone. Lead 1n the
bone is calculated to have a half-life of approximately 10,000 days (27
years).
The toxicology of lead has been extensively reviewed. Alterations In
the hematopoetic (blood forming) and central nervous systems are the
primary toxic effects caused by exposures to lead. Cognitive and
behavioral deficits are the focus of much current research on relatively
low levels of lead exposure.
The Centers for Disease Control (CDC) has determined that a blood lead
level in children of 25 ug/dl or above indicates excessive lead absorption
and constitutes grounds for medical Intervention. That determination Is
based on the occurrence of enzymatic abnormalities In the red blood cells
at blood lead levels above 25 ug/dl and by the finding of neurologic
dysfunction in children at blood lead levels between 35 and 50 ug/dl.
Further, the CDC defines childhood lead poisoning at a blood lead level of
25 ug/dl in association with an erythrocyte protoporphyrln (EP.) level- of
35 ug/dl or above (CDC 1985). In its draft toxlcologlcal profile for
lead, CDC has also cautioned that concentrations greater-than 500-1000 ppm
could lead to elevated blood lead levels In children Inhaling or
swallowing dirt. Recent findings of cognitive deficits associated with '
lower blood lead concentrations may result In a review of the adequacy of
the existing CDC threshold level. EPA has Issued a revised maximum
contaminant level goal (MCLG) of 20 ug/llter lead. The current MCL of 50
ug/liter is used to derive an acceptable Intake chronic (AIC) risk
criterion for Ingestlon of lead.
Based on discussions with EPA and following the noncardnogenlc risk
evaluation procedures of the Superfund Public Health Evaluation Manual .
Acceptable Intake: Chronic (AIC) values were used to assess the
significance for human health of potential Inhalation and Ingestlon
exposures to lead calculated for the Gould Inc. site. AIC criteria are
designed to represent an Intake for a contaminant that would be acceptable
on a long-term continuing basis without producing adverse health effects.
Separate AIC values for inhalation and Ingestlon exposures are derived by
EPA from the National Ambient Air Quality Standard (NAAQS) for lead (1.5
ug/m3 quarterly) and the drinking water standard for lead (0.05.mg/1),
respectively. Each AIC Is calculated as the environmental criterion
concentration times contact rate divided by adult body weight. Assuming
20 m3/day of air breathed, 2 liters/day of water Ingested, and an adult
body weight (bw) of 70 kg, the derived AIC values are 0.0004 mg/kg-bw/day
for Inhalation and 0.0014 mg/kg-bw/day for Ingestlon. For each calculated
exposure dose (In mg/kg-bw/day) In this endangerment assessment, risk Is
represented by a hazard Index (HI) number equal to the calculated dose
divided by the appropriate AIC value. Thus, a hazard Index greater than
1.00 represents a calculated dose greater than the AIC criterion value, ^
given the exposure model assumptions and the environmental concentrations!
used In the model.
22
-------
Figure 8 provides a visual summary of the results of the exposure
calculations for the No-Action Alternative. Inhalation and ingestion
exposures for each scenarios are scaled appropriately In comparison to AIC
values. As Figure 8 shows, the high dose cases for Ingestion of soils
Indicate extremely high Intakes of lead. These Intakes result from
calculations assuming contact with the lead oxide—almost pure lead—In
the battery casing waste piles. Even If more realistic assumptions than
continuous dally contact with the waste piles are made, the results of any
contact with and ingestion of contaminants from the battery casing piles
would be significant in comparison to either baseline exposures or
Ingestion AIC values. The high dose Ingestion calculations are not
considered to be a basis for evaluation of potential health Impacts from
the site (they are excessively conservative); however, they clearly
demonstrate the potential significance of any contact with the existing
source materials on site.
For on-slte workers (adults only), total lead Intake Increases to
about 2.5 times baseline intake, with Inhalation exposures Increasing by a
greater percentage than ingestion exposures but still accounting for less
than 10 percent of total exposures. Both Inhalation and Ingestion mean
dose exposures are lower than AICs. Off-site residential total lead
Intake Increases only marginally for adults or children (about 14
percent). Only inhalation exposures are Included In this scenario, with
the ambient air lead concentration assumed to be constant at 0.33 ug/m^,
or 22 percent of the NAAQS value of 1.5 ug/m3. In the on-slte
residential base case scenario, adult lead Intake Increases almost • .
fivefold and children's lead intakes by a factor of more than )l. Both
Inhalation and ingestion exposures are substantially Increased In all age
intervals; all hazard indices for children and adults are greater than
1.00, with a maximum of 11.2 for inhalation and 34.2 for Ingestion among
children's age intervals.
Environmental effects. It is doubtful that any fish reside In either
East.or West Doane Lake. During field sampling activities, numerous
aquatic insects and frogs were observed In the West Doane Lake. None were
observed during concurrent sampling In the East Doane Lake, although
mallards are reported to be resident there. Numerous fish species reside
In or migrate through the lower reach of the Willamette River 1n the
vicinity of the site. These Include migrant Chinook and Coho salmon, and
Steelhead and American shad. Resident species Include largemouth and
smallmouth bass, crapple, blueglll, walleye, northern squawflsh, catfish,
mountain whlteflsh, carp, sucker, peamouth, and chlselmouth (Oregon
Department of Fish & Wildlife 1972. 1986).
The Willamette River In the site reach flows through a highly
Industrialized area that receives a variety of point- and non-point source
pollutants. Dissolved lead values upstream of the area of the discharges
from the Gould site have exceeded the chronic aquatic life standard of 1.3
ug/1 In some 45 percent of the samples from the past decade (USGS 1975 -
1984 data). Total recoverable lead values have been still higher. Levels
of lead have trended downward with no values greater than 2 ug/1 In the
last three years of this period.
23
-------
10 ACTION ALTERATIVE
IKBEMEWAL AVEBAGE DAILT DOSE
Figure 8 81 EXPOSURE SCEJABIO
Summary of Exposure Calculations
-------
Estimates of the quantity of surface water overflow from the East
Doane remnant indicate a maximum value of 7,800,000. gallons per year.
Using a range of discharge-values, dilution calculations were made to
estimate the distance downstream of the outfall at which the concentration
in a plume within the Willamette River will reach background levels.
Using the above estimates, the plume where lead values measurably exceed
background could be several thousand feet long and up to 100 feet wide.
Few recent data are available on fish populations In the vicinity of
the Gould discharges; however it Is likely that these populations reflect
the stresses of the existing habitat. Of primary economic and
recreational concern are effects on anadromous (migratory) salmonlds.
Both Juveniles and adults migrate past the site on their way to and from
upstream spawning areas. Because of the shallowness of the beach adjacent
to the discharges, adults would not be expected to move through
concentrated areas of the plume and should suffer little Impact from their
limited exposures. Thus, it is likely that a significant percentage of
outmlgrating Juvenile salmonlds will pass through the plume. Expected
residency in the plume would be on the order of minutes If actively
migrating or hours if passively drifting down current. Exposures of this
duration may cause some minor stress to respiration and metabolism but
would not be expected to result In significant numbers of deaths unless a
fish were somehow trapped for an extended period In a region with very
high concentrations. The EPA criterion for short-term exposure (1 hour)
Is 0.034 mg/1.
25
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V. ALTERNATIVES EVALUATION
Summary of Alternatives and Evaluation Criteria
This section summarizes the detailed evaluation of the final candidate*
remedial action alternatives. First, alternatives are subject to a
screening for compliance with the protectiveness and ARAR criteria. An
additional screening of cost effectiveness Is then done to ensure the the
selected remedy is a cost effective one. Those that pass the screening
are then evaluated against all nine criteria and an alternative Is
selected that best addresses the combination of criteria. This
alternative is considered to represent treatment to the maximum extent
practicable.
The Final Candidate Alternatives, Identified briefly, are:
Alternative 1 - No-Action Alternative (presented to provide a baseline
for evaluating the other alternatives).
Alternative 2A - Removal and Disposal of Surface Piles of Battery
Casings; Lime Application to Contaminated Soils.
Alternative 28 - Removal and Disposal of Surface Piles of Battery
Casings; Capping of Contaminated Surface Soils; Regradlng of the Site
and Isolation of East Doane Lake.
Alternative 2C - Excavation and Separation of'Surface Pile's of Battery
Casings, and Subsequent Off-Site Management of Casings; Lime
Treatment; Capping of Contaminated Surface Soils; Treatment of Surface
Water; and Regrading and Revegetation of the Site.
Alternative 8A - Removal and Disposal of Surface Piles of Battery
Casings and Sediments of East Doane Lake; Capping of Contaminated
Surface Soils; Treatment of Surface Water; and Regradlng and
Revegetation of the-Site.
Alternative 86 - Excavation and Separation of Surface Piles of Battery
Casing Components, and Subsequent Off-Site Management of Casings;
Capping of Contaminated Surface Soils; Treatment of Surface Water; and
Regrading and Revegetation of the Site.
Alternative 10A - Excavation and Separation of all Battery Casings,
and Subsequent Recycle of Some Casing Components; On-Slte Incineration
of Non-recyclable Components; Fixation or Stabilization of Surface
Soils, Subsurface Soils, Sediments, and Matte; Treatment of Surface
Hater.
Alternative 10B - Excavation and Separation of all Battery Casings,
and Subsequent Recycle of Some Casing Components-; Incineration of
Non-recyclable Battery Casing Components; L1me Treatment and On-Slte
Placement of Sediments; Treatment of Surface Hater.
26
-------
Alternative IOC - Excavation and Separation of all Battery Casings,
and Subsequent Recycle of Some Casing Components; Off-Site Disposal of
Non-recyclable Components that Fail EP Toxicity;.Fixation or
Stabilization of Surface Soils, Subsurface Soils, Sediments, and
Matte; Additional Study of Groundwater and Surfacewater Quality.
Alternative 21 - Excavation of Battery Casing Components and Permanent
Disposal in an On-Site RCRA Landfill; Fixation or Stabilization of
Surface Soils, Subsurface Soils, Sediments, and Matte; Treatment of
Surface Water.
Alternative 25 - Permanent Disposal In an On-Site RCRA Landfill of all
Site Contaminated Materials, including Battery Casing Components.
Surface Soils, Subsurface Soils, Sediments, and Matte; Treatment of
Surface Water.
Evaluation Criteria
Nine factors will be considered in evaluating the Final Candidate
Alternatives:
0 Long-term effectiveness and permanence;
0 Reduction in toxicity*, mobility or volume;
Short-term effectiveness;
0 Implementabi1ity; •«
Cost;
Overall protection of human health and the environment;
0 Compliance with applicable or relevant and appropriate
requirements (ARARs) that are shown in Appendix A;
" State acceptance; and
0 Community acceptance.
27
-------
The process begins by applying the protectiveness and ARAR factors to
each of the candidate alternatives'. Alternatives that do not satisfy
these requirements will be s.creened out. Then a cost effectiveness *
screening is done to ensure that each of the alternatives would be a cost!
effective solution to the problems at the site. Finally, for the
remaining alternatives which have passed these screening steps, all of the
factors are weighed in determining the best overall solution to be applied
at this site.
Screening of Alternatives
Alternatives 1. 2A. 2B. 8A. and 86
These alternatives fail the protectiveness and ARAR screens for the
following reasons:
0 The alternatives rely heavily on Institutional controls and
monitoring for the protection of public health and the
envi ronment.
0 Uncontrolled wastes would be left In place on site.
e Extensive continued migration of site contaminants Into the
groundwater aquifers will occur.
0 The alternatives fail to meet ARARs. . N
Alternative 2C
Although Alternative 2C has many of the same disadvantages of the
above alternatives, it involves some treatment of the remaining
contaminated material at the site and Is therefore considered more
protective than the above alternatives. The alternative fails the EP Tox
ARAR, and a waiver in this instance would be required. Since alternative
2C Is the preferred alternative in the FS report submitted by HI and
Gould, It will be carried through the evaluation process.
Alternatives 10A & 10B
These two alternatives pass the protectiveness and ARARs screens.
However, the alternatives each Involve Incineration of the ebonite
casings. Due to expected opposition from the community and the State of
Oregon, these two remedies are also being screened out at this point.
Alternative IOC
This alternative passes the protectlveness/ARAR screening and will be
evaluated In more detail.
Alternatives 21 & 25
These alternatives pass the protectlveness/ARAR screening. They are In
fact quite similar alternatives, with the one difference being that 1n
Alternative 21 the soils and sediment are treated before being placed In
the RCRA landfill. Since alternative 21 appears to go further In
satisfying the preference In the law for treatment to the maximum extent
practicable, and since It Is later shown to be cost effective, only 21
will be evaluated in detail.
28
-------
Screening for Cost Effectiveness
The alternatives which pass the initial screening screen are 2C, IOC,
and 21. These are then evaluated to determine if any one falls to provide
for a solution that is cost effective. The evaluation for these Is shown
in Table 5.
TABLE 5
SUMMARY OF COST EFFECTIVENESS SCREENING
Alternatives Evaluated
Reduction In
Toxlclty, Mobility
or Volume
1C
$4,923,481
Moderate
Low
IOC
$20,565,184
High
High
11
$15.661.848
Moderate
Moderate
The costs for Alternative IOC are extremely difficult to estimate.
The above costs have been prepared by the Dames & Moore for NL and Gould
and are considered worst case costs assuming little of the material is
recyclable. In particular, costs for disposal of non-recyclable battery
components such as ebonite in a RCRA landfill are estimated at*over "
$2,500.000 per year for five years. These costs also do not allow for any
credit from the sale of recyclable components. Design costs for this
project are estimated at only $226,000. EPA views these detailed cost
estimates as providing a strong justification for Increasing the amount of
effort devoted to designing a process that minimizes the amount of
material that requires disposal In a RCRA landfill.
Based on the analysis above, all of the above alternatives are
considered to be cost effective ones. Each appears to provide an Increase
in effectiveness and reduction In toxlclty, mobility or volume Xboth
criteria evaluated together) that Is commensurate with the Increased
cost. The basis for the ratings In this table Is Included In the detailed
analysis that follows for these three alternatives.
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Alternative 2C Evaluation
Alternative 2C comprises removal of the surface piles of battery
casing fragments, followed by off-site component separation and recycle o&
some components, off-site disposal of others; lime treatment of the exposi
surface soils and battery casing material, followed by low-permeability
capping and revegetation; lime treatment of the East Doane Lake surface
water; site grading; and a long-term monitoring program.
Short-Term Effectiveness. Under this alternative, most of the fill
material would be left in place. During remediation, remedial action
worker safety issues similar to those for minor earthmovlng projects will
arise. Hazards associated with site contaminants will be controlled by
appropriate respiratory protection, proper safety attire and the
application of dust suppression techniques. Therefore, the short-term
risks for workers on-site would be negligible.
During remediation, lead concentrations In air emissions at the
fencellne of the property will be monitored to detect any exceedences of
the NAAQS for lead. Proper dust suppression techniques should minimize the
likelihood of this event.
The surface piles carry the greatest potential for environmental risk
because of their availability. Battery casing corrrnents contained In the
surface piles will be transported to an off-site recycler for separation of
components. After separation, some components will be recycled, while
others may have to be disposed of in a landfill. Risks associated wl.th
transport of hazardous wastes from the site to the recycler, and hazardous
waste transport from the recycler to a RCRA landfill, will be mitigated by
transporting the wastes in accordance with 40 CFR 263 and State of Oregon.
requirements for hazardous waste transportation. 4
Alternative 2C could be executed in approximately one year. Including
planning, review, contracting and implementation.
The disadvantages of this alternative In terms of short term
effectiveness are that significant quantities of hazardous materials remain
at the site and there is potential exposure to these substances 1f the
institutional controls proposed n this alternative are not effective.
Secondjy, the lime treatment proposed In this alternative has not been
fully evaluated during the FS and therefore Its effectiveness at this site
is not wel1 known.
Lonq-Term Effectiveness. Removal of the surface piles Is expected to
substantially reduce the potential for entrapment of dust from the site by
wind, and to reduce the potential for human contact with site
contaminants. Pumping and lime treatment of the site surface water may
reduce the concentrations of dissolved contaminants by raising the pH of
the water. Site grading will reduce the amount of runoff In East Doane
Lake, and eliminate the transport of surface water off site. The
application of lime to the surface areas where soil Is exposed or where
casings are exposed or burled may reduce the concentration of dissolved
contaminants In surface runoff by raising the local pH. However, the
effectiveness of this treatment technique at the Gould site has not been
fully evaluated.
30
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Subsequent capping will partially Isolate the remaining contaminants,
thereby reducing their avai-labl 1 Ity for off-site transport by surface
water, air and direct contaminant ingestlon with soils. However, the
location of the site in a 100 year floodplaln, the problems with
Implementing Institutional controls, particularly on the Rhone Poulenc and
ESCO properties, and the fact that only 2X by volume of the contaminated
casings will be removed make the long term effectiveness of this
alternative questionable.
Reduction in Toxicity. Mobility, or Volume. Alternative 2C reduces
the volume and toxicity of the site contaminants contained In surface
piles, which are about 2% of the total battery casings. The mobility of
contaminants In soil and subsurface casings may be reduced by Increasing
the pH of the soil system through lime treatment. Lime treatment may not
be effective In preventing mobilization from groundwater moving underneath
the site. Periodic reapplication of lime may be required to ensure the
effectiveness of the treatment. Subsurface contaminants are not reduced
In volume or toxicity.
Implementability. Equipment for separating the battery casing fill at
the site is available. However, the separation equipment tested during
the FS was designed to work on whole batteries, not on the mix of
materials found at the Gould site. In particular, plastic and ebonite
streams analyzed after processing through available separation equipment
contained sufficient residual lead to fall the EP Tox test. Further, lead
oxide is combined with much dirt in the separation process, which w11-1.
serve to reduce the recyclability of this fraction. Alternative 2C would
be accomplished using modified conventional machinery at an off-site
facility.
Alternative 2C involves the removal and treatment of the surface piles
of battery casings, surface soil treatment with lime, and surface water
treatment by pH adjustment and filtration. Recovered battery casing
components will be sent to other facilities for recycling or disposal.
Those facilities receiving battery casing components will be required to
meet RCRA Treatment, Storage or Disposal facility requirements for
processing of hazardous wastes, as required by the EPA Off-Site Policy.
Applicable DOT, EPA and State of Oregon regulations for the transport of
hazardous materials will also have to be followed.
Any facility Interested In accepting the lead compounds for the
purposes of recovering the lead would have to be permitted as a TSD
facility under RCRA. Recovered battery casing materials which cannot be
recycled and which fall EP Tox will be disposed of In a RCRA landfill.
Nonrecyclable materials which pass EP Tox may be disposed of In a sanitary
landfill.
Cost. The costs associated with this alternative are divided Into two
categories. The first Is capital cost which Includes direct costs such as
transportation, separation and disposal costs associated with the surface
casings; surface water treatment costs; lime addition to soil; site
grading; and Installation costs associated with monitoring. Also Included
31
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in capital cost are indirect costs such as permitting, engineering and
design, start-up, and contingency. The second category of cost is operating
and maintenance costs including site monitoring and reporting. Operating
costs are discounted to present worth for comparison of alternatives.
Capital -O&M 9 12X
Cost Present north
Alternative 2C $3,133,760 $1,789,722 $4,923,481
Compllance with ARARs. Contaminant-specific, location specific and
action specific ARARs that apply to the Gould site are contained In Appendix
A. All contaminant-specific, location-specific and action-specific ARARs
will be met by Alternative 2C, except for the EP Toxlclty requirement for
lead In soils and battery casing materials. This alternative also allows a
continual source of lead to impact the groundwater under the site, which
already exceeds the MCL of 0.05 mg/1 and Is considered a Class II aquifer.
Overall Protection of Human Health and the Environment. Surflclal
contamination on site is reduced under Alternative 2C by removal of the
surface battery casings piles and by paving/capping areas of highest
residual soil contamination, with lime applied before paving/capping to
further reduce the potential mobility of residual lead In subsurface soils.
These measures will provide controls for general Inhalation exposures and
direct contact ingestion exposures in these areas of the site, barring
physical disturbance of the pavement/cap. East Doane Lake surface waters
will also be treated under Alternative 2C. . > ' .
Assuming that the cap is not disturbed, on-slte residential exposures
by inhalation and Ingestion result in hazard Indices less than 1.00 for
age groups. On-site worker and off-site residential populations have
lower hazard indices for all exposure pathways evaluated. On-s1te and
off-site air lead concentrations are 1n compliance with the NAAQS ARAR
value. However, these values are based on the effectiveness of the cap and
the Institutional controls that would be required on the Gould,
Rhone-Poulenc, and the ESCO properties. There Is considerable uncertainty
as to whether Rhone-Poulenc or ESCO would allow these types of Institutional
measures on their property. Should the cap become disturbed, substantially
higher exposures for Ingestion might result.
Short-term, off-site worker inhalation exposures from fugitive dusts
generated during Alternative 2C remedial activities are determined to be
non-significant, with a hazard Index of 0.19. Maximum short-term
(quarterly) air lead concentrations off site are projected to be 1n
compliance with the NAAQS ARAR value.
Community Acceptance. Several letters were Included In the record of
public comment which clearly Indicate that this alternative Is not
acceptable to portions of the community. For example, the Northwest
District Association, which covers an area representing 12,000 residents,
stated that It cor.iders this alternative to be "totally unacceptable".
Other groups that have expressed opposition to Alternative 2C Include:
Hlllamette Heights Neighbors Concerned About Noise and Chemical Pollution,
Northwest Environmental Advocates, and OSPIRG. These responses are Included
In Appendix B.
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State Acceptance. The State of Oregon Department of Environmental
Quality (DEQ) has carefully reviewed this alternative and finds 'it
unacceptable.
33
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Alternative IOC Evaluation
Alternative IOC comprises excavation of all of the battery casing
fragments and matte from the Gould property and adjacent properties, follj
by on-slte separation of the battery casing fragments. Separation is foil
by recycling of those components (or portions of components) that can be
recycled; off-site disposal for non-recyclable components that fall the EP
Toxiclty test, and on-site disposal of non-hazardous components. It is EPA's*
Intent under this alternative to minimize the amount of material that would
require disposal in a RCRA landfill. Treatment studies performed during
design will be used to define what portions of the battery casings are
recyclable.
Additional processes under Alternative IOC Include excavation,
fixation/stabilization and on-site disposal of contaminated soil, sediment and
matte; soil capping of treated areas and revegetatlon; isolation of East Doane
Lake by site regrading; and a monitoring program to determine changes In
groundwater contamination over time. Under Alternative IOC, additional study
will be performed on surface and groundwater in this area. The proposed study
will help determine whether action needs to be taken to deal with the
contamination underneath the site, and how that action should be coordinated
with other cleanup efforts by nearby Industries that are currently going on.
The study will also address organic contamination as well as lead
contamination. The study would begin later this year.
Short-Term Effectiveness. Beneficial effects of removing and
successfully separating battery casings and fixing/stabilizing soils,- -
sediments and matte will be immediate on completion. The groundwater and
surface water monitoring program for Alternative TOC will be conducted as long
as site contaminants remain unremediated.
During remediation, worker safety Issues similar to those for moderate^
earthmoving projects will arise. For on-site workers, personnel protective
equipment, including respiratory protection, will mitigate the safety
concerns. However several activities will be conducted simultaneously In a
relatively small area, leading to some concern over worker safety due to the
intensive nature of site activity. As part of the remedial action, a
comprehensive health and safety plan will be developed before field work
begins.
During remediation, lead concentrations in air emissions at the fenceline
of the property will be monitored to detect any exceedences of the NAAQS for
lead. Proper dust suppression techniques should minimize the likelihood of
this events. Most of the material to be remediated Is currently saturated in
groundwater, which will also help prevent fugitive emissions.
The completion of remedial activities under Alternative IOC may take up
to 6 years after remedial design Is complete. Site conditions that may delay
execution of the alternative Include logistical difficulties associated with .
dredging of the lake sediments. Requirements related to stabilization of the
lake shoreline during deployment of dredging equipment may also serve to
extend the time required for dredging. The estimate Is based on a variety of
factors that Include the size of the facility and other Items that will be
evaluated during the design phase. It Is the agency's Intent to minimize the
time that Is required for remediation under this alternative.
-------
Long-Term Effectiveness. Removal and successful separation of the
battery casing fragments would substantially reduce sources of pollution at
the site. Without the battery casings, levels of pollution In all media will
decrease. Removal and disposal of contaminated sediments without treatment of
the site surface water will raise the concentration of dissolved and suspended
contaminants for a period of time.
Under this alternative, health and environmental hazards posed by the
site are Intensively addressed by treatment. Potential hazards posed by the
site fill are addressed by treatment of the battery casing fragments. The
treatment undertaken by this alternative addresses essentially all of the
contaminated material and related risks. Risks remaining after remediation is
completed are posed mainly by unremedlated surface soils, ground water and
surface water in the study area. The groundwater and surface water risks will
be addressed In the additional study that Is proposed under this alternative.
Should the cap become disturbed, additional Inhalation and Ingestlon risks
might result. However, because of the Intensive treatment employed 1n this
alternative, these risks are considered to be less than those presnented in
either Alternative 2C or 21.
The technology to be used in this alternative has been demonstrated In
other situations and appears to be feasible based on the studies that have
been done at this site, since the tests clearly showed that the materials can
be separated. Design modifications of the separation process will be
accomplished during the engineering studies that will occur as part of the
remedial design phase.
N
Reduction in Toxicity. Mobility, or Volume. In the Nature and Extent of
Problem section, the estimated quantities of metallic lead, plastic, lead
oxide, ebonite, and other material are calculated. An estimate of the
quantity of metallic lead is shown as 0.6 percent of all primary source
materials, plastic is estimated at 3.0 percent of primary source materials,
lead oxlde/dlrt/mud at 10.2 percent, and ebonite at 74.3 percent. Contacts
made during the conduct of the FS Indicate that the metallic lead would likely
be completely recyclable, the plastic would be recyclable at some locations.
depending on lead content, and lead oxide would likely be accepted by some
smelters. The largest component of source material, ebonite, may or may not
be recyclable depending on the extent to which It can be treated. Using these
assumptions, It Is estimated that approximately 25% of the lead In the casings
can be recycled.
The potential for long-term mobility of site contaminants 1s decreased
with Alternative IOC, by both removal of lead 1n the casings through recycling
and by treatment of contaminated soils and sediment to reduce the mobility of
lead.
Implementabllity. During the conduct of the FS, several efforts at
component separation and cleaning of the battery casing material were
attempted by the PRPs. A review of the efforts of others who attempted
separation and recycle was also conducted. These attempts can be generally
characterized as demonstrating that separation of battery casings Is feasible
at low feed rates.
Plastic and ebonite streams after processing may contain enough
Interstitial lead to fail the EP Tox test. All such materials that can not be
recycled would need to be landfllled In a RCRA facility.
Soil stabilization Is a proven technology and was shown to be effective
In a bench-scale test during the FS. Pilot testing of the technology under
actual site conditions will be required during remedial design to determine
the correct ratios of materials and to determine whether the technique can be
effective under actual site conditions.
35
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Sediment dredging may contribute to the difficulty of subsequent
treatment of East Doane Lake surface water, though some sedimentation of the-
suspended materials should occur prior to any future surface water
remediation. Excavation of the fill on the Gould and off-site properties ^t
also include a consideration of the power lines along the northwest edge
the Gould property, which may need to be relocated because of remediation'.
Alternative IOC involves the excavation and separation of all battery
casings, followed by recycle or RCRA disposal of specific battery casing
constituents. Those recycle facilities receiving the lead oxide and soil
component will have to meet RCRA TSD requirements for processing of hazardous -
wastes, as required by the EPA Off-Site Policy. Applicable DOT, EPA and State
of Oregon regulations for the transport of hazardous materials will also have
to be followed. No permit will be required for any of the wholly on-slte
portions of the alternative. During remediation, separation and treatment
facilities will be erected, operated and demolished, and excavation equipment
will be operated. These activities may require local construction permits.
Recovered battery casing materials which can not be recycled will be
disposed of In a landfill. Components which fall the EP Toxlclty test will
have to be placed in a landfill that meets the RCRA requirements of 40 CFR
Part 264. It is EPA's intent to minimize this portion of the separation plant
output stream.
Cost. The costs associated with this alternative are divided Into two
categories. The first is capital cost, which Includes direct costs such as
erection of process equipment, excavation, separation and disposal costs
associated with the surface and subsurface casings; sediment dVedglng costs,
soil stabilization costs; site grading; and Installation costs associated with
monitoring. Also included in capital cost are Indirect costs such as
permitting, engineering and design, start-up, and contingency. The secon^H
category of cost is operating and maintenance costs that occur throughout^?
multi-year remedial effort, such as excavation, separation, and disposal costs
beyond year one. Operating and maintenance costs are discounted to present
worth for comparison of alternatives.
Capital O&M 9 121 Total
Cost Present north Cost
$3,491,603 $17,073,581 $20,565,184
The costs for this alternative are extremely difficult to estimate. The
above costs have been prepared by the Dames & Moore for NL and Gould and are
considered worst case costs assuming little of the material Is recyclable. In
particular, costs for disposal of non-recyclable battery components such as
ebonite In a RCRA landfill are estimated at over $2,500,000 per year for five
years. These costs also do not allow for any credit from the sale of
recyclable components. Design costs for this project are estimated at only
$226,000. EPA views these detailed cost estimates as providing a strong
Justification for Increasing the amount of effort devoted to designing a
process that minimizes the amount of material that requires disposal In a RCRA
landfill.
36
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Compliance with ARARs. Contaminant-specific, location specific and
action specific ARARs that apply to the Gould site are contained in Appendix
A. All contaminant specific, location-specific and action specific ARARs will
be met by Alternative IOC. During remediation, lead concentrations In air
emissions at the fenceline of the property could exceed the NAAQS for lead.
If continued excedences occur, remedial operations will be shut down and
appropriate modifications to the operations will be made. Activities may also
be adjusted based on meteorological conditions. All materials handling will
be performed as a wet process where feasible. A site specific health and
safety plan will be developed to ensure the safety of remedial action
workers. Much of the material to be remediated Is currently saturated In
groundwater, which will also help prevent fugitive emissions.
Overall Protection of Human Health and the Environment. Surflclal
contamination on site is reduced under Alternative IOC by on-slte treatment of
all battery casings (piles and burled), with off- site disposal at a RCRA
landfill of materials failing EP Toxlclty tests and stablllzatlon/on-slte
disposal of remaining residual materials (soil, sediment, matte), and
pavement/capping of all disposal areas. These measures will provide
long-term, effective controls for general Inhalation exposures and direct
contact Ingestion exposures in these areas of the site. Stabilization of
residual wastes will provide an additional component of protection and further
prevent contaminant migration to groundwater.
Community Acceptance. In the public record there are several letters
Indicating support for this alternative. Groups that have expressed support
for Alternative IOC Include: Food Front Cooperative Grocery, Willamette
Heights Neighbors Concerned About Noise and Chemical Pollution? Northwest
Environmental Advocates, and OSPIRG. These responses are Included In Appendix
B. ; .
State Acceptance. DEQ fully endorses this alternative and supports EPA's
conclusion that Alternative IOC meets the statutory requirements for a remedy
contained In CERCLA and Oregon Senate Bill 122.
37
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Alternative 21 Evaluation
Under Alternative 21, all of the fill material on the Gould, and off-si-te
properties above 3000 ppm wi.ll be excavated for treatment (soil, sediments^" or
on-site disposal (battery casings). Contaminated soil, sediment, and matl
would be treated by fixation/stabilization, then backfilled into the sit«r
excavation. Excavated battery casing materials would be disposed of in an
on-site RCRA landfill. The alternative also includes pH adjustment and
filtration of the East Ooane Lake remnant, site grading, low-permeability
surface capping, and a long-term monitoring program.
Short-Term Effectiveness. Under this alternative, the recovered battery"
casing fill would be stored on an adjacent property while the landfill Is
constructed. During remediation, worker safety Issues similar to those for
moderate earthmoving projects will arise. For on-site workers, safety attire
will mitigate some safety concerns, however several activities will be
conducted simultaneously in a relatively small area, leading to some concern
over worker safety due to the intensive nature of site activity. As part of
the remedial action, a comprehensive health and .safety plan will be developed
before field work begins.
During remediation,- lead concentrations In air emissions at the fencellne
of the property will be monitored to detect any exceedences of the NAAQS for
lead. Proper dust suppression techniques should minimize the likelihood of
this events. Most of the material to be remediated is currently saturated In
groundwater, which will also help prevent fugitive emissions.
Remediation under Alternative 21 might be completed In about four years,
Including planning, review, contracting and construction.
Long-Term Effectiveness. The intent of this alternative Is to fullyl
mitigate potential health and environmental effects of site contaminants !
completely Isolating the contaminants from the environment. Enclosure of the
battery casing fill in a RCRA landfill will prevent the migration of
contaminants In water and air, and will limit their availability for direct
Ingestlon. Fixation/stabilization treatment of soil, sediment and matte will
also prevent contaminant migration and will decrease the mobility of these
materials. Site regradlng and blocking of the overflow from the East Doane
Lake remnant will reduce the accumulation'of runoff in the lake remnant, and
decrease the movement of contaminated surface water off site. With
appropriate institutional controls, the health and environmental hazards posed
by the site fill are mitigated.
The removal and on-s1te disposal of the battery casing fill will require
long term maintenance and monitoring. Frequent Inspection of the cap will be
required to ascertain that an Impermeable barrier Is maintained between the
contaminants and the environment. Site monitoring equipment will require
continued maintenance, as well. As a result, the effectiveness of leaving all
of the contaminated battery casings untreated on-site Is questionable, given
concerns about the long term maintenance requirement's of caps, the location of
the site In a floodplaln, and the effectiveness of Institutional controls at
this site.
38
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t. •
Soil stabilization is a proven technology and was shown to be effective
in a bench-scale test during the FS. Pilot testing of the technology under
actual site conditions will be required during remedial design to determine
the correct ratios of materials and to determine whether the technique can be
effective under actual site conditions.
Reduction In Toxlcitv. Mobility, or Volume. On-s1te disposal of
untreated battery casings cannot be considered a treatment that permanently or
significantly reduces the toxicity or volume of hazardous substances. The
mobility of contaminated soils Is reduced by treatment.
Implementabl11ty. Soil stabilization Is a proven technology and was
shown to be effective in a bench-scale test during the FS. Pilot testing of
the technology under actual site conditions will be required during remedial
design to determine the correct ratios of materials and to determine whether
the technique can be effective under actual site conditions.
Sediment dredging will contribute to the difficulty of subsequent
treatment of East Ooane Lake surface water. Excavation of the fill on the
Gould and off-site properties must also Include a consideration of the power
lines along the northwest edge of the Gould property, which may need to be
relocated because of remediation. Power supply to Industrial facilities may
be Interrupted as a result.
Alternative 21 would be accomplished using conventional machinery and
techniques. Surface capping Is a proven technology, and Is considered-
reliable. However, failure of a surface cap could require addltlona] .
remediation, consisting of replacement of the cap. "
During construction, monitoring systems will be Installed, site drainage
systems will be emplaced, and buildings will be demolished. Construction
permits will be required for any off-site portion (I.e., drainage) of these
activities.
During construction of the landfill, excavated wastes would have to be
placed on an adjacent property. Temporary storage of excavated material must
comply with 40 CFR 265.253 and 265.254. Off-site storage might also require
special arrangements with state and local agencies and authorities, and
special agreements with neighboring property holders.
The materials and equipment needed to Implement Alternative 21 Include a
dredge for the sediments, common excavation equipment, a plastic geomembrane
for the landfill, water treatment equipment, monitoring equipment, and a
source of lime and other reagents for fixation/stabilization. All of these
materials are readily available.
39
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Cost. The costs associated with this alternative are divided into two
categories. The first is capital cost, which includes direct costs such
as excavation and landfill construction costs; sediment dredging costs
surface water treatment costs; soil fixation/stabilization costs; site'
grading; and Installation costs asso- dated with monitoring. Also'
Included In capital cost are indirect costs such as permitting,
engineering and design, start-up, and contingency costs. The second
category of cost is operating and maintenance costs that occur throughout
the multi-year remedial effort, such as excavation, placement and
monitoring costs beyond year one. Operating and maintenance costs are
discounted to present worth for comparison of alternatives.
Capital O&M I? 12X Total
Cost Present North . Cost
Alternative 21 $9,678,453 $5,983,396 $15.661,848
Compliance with ARARs. Contaminant-specific, location specific and
action specific ARARs that apply to the Gould site are contained In
Appendix A. Several action specific ARARs are particular to Alternative
21. These are Indicated below:
0 Landfill: must comply with 40 CFR 264 standards for a hazardous
waste landfi 11.
e Capping: must comply with 40 CFR 264 Subpart G standards for a
cover over hazardous waste at closure. s
Closure with waste in place: must comply with 40 CFR 264 Subpart
G standards for closure performance and post-closure care and
monitoring.
0 Excavation: hazardous wastes excavated and replaced on-s1te must
be-replaced in a waste management unit that compiles wi.th RCRA
requirements.
All contaminant-specific, and location-specific ARARs can be met by
Alternative 21. During remediation, lead concentrations In air emissions
at the fencellne of the property could exceed the NAAQS for lead.
However, proper design of the materials handling process and proper dust
suppression techniques should minimize the likelihood of these events.
Much of the material to be remediated 1s currently saturated In
groundwater, which will also help prevent fugitive emissions.
Action- specific ARARs for Alternative 21 can be met, with details to
be worked out during remedial design.
Overall Protection of Human Health and the Environment. Surfldal
contamination on site Is reduced under Alternative 21 by on-slte treatment
of all contaminated soils, with stabl11zation/on-s1te disposal In a
constructed landfill of these materials and battery casing components.
These measures will provide long-term, effective controls for general
Inhalation exposures and direct contact Ingestlon exposures In these areas
of the site, barring physical disturbance of the RCRA landfill.
Stabilization of residual wastes will provide an additional component of
protection If the RCRA landfill Is disturbed.
40
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The long-term exposures and risks after completion of Alternative 21
remediation activities are determined to be acceptable. On-site
residential exposures by inhalation and ingestion result In hazard indices
less than 1.00 for all age groups. Should the landfill cap become
disturbed, however, these exposures could Increase.
Community Acceptance. During the public comment period, most of the
comments were addressed to either Alternative 2C or IOC rather than
Alternative 21. However, many of the comments expressed a .desire for a
"complete clean-up" of the site. To the extent that Alternative 21 falls
to remove lead from the battery casings, community concerns about this
alternative are assumed.
State Acceptance. DEQ's position regarding this Alternative Is that
the agency is opposed to any alternative that will Increase the number of
RCRA landfills In the State of Oregon. Since there Is another cost
effective alternative for this site, Alternative 21 Is deemed unacceptable.
41
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VI SELECTED REMEDIAL ALTERNATIVE.
Description of Selected Remedy
The selected remedy for the soil.s unit at the Gould site is based on
Alternative IOC. The selected remedy comprises:
8 Excavation of all of the battery casing fragments and matte from
the Gould property and adjacent properties where casings have
been Identified:
0 A phased design program to determine the amount of material that
can be recycled and to minimize the amount of material that must
be RCRA landfllled.
0 Separation of the battery casing fragments;
0 Recycling of those components (or portions of components) that
can be recycled, off-site disposal for non-recyclable components
that fail the EP Toxicity test, and on-slte disposal of
non-hazardous, non-recyclable components;
0 Excavation, fixation/stabilization and or'-slte disposal of the
remaining contaminated soil, sediment, and matte;
9 Soil capping and revegetatlon; N • .
0 Isolation of surface water runoff to East Doane Lake by site
regrading; and
8 A monitoring program to determine changes In groundwater
contamination over time and to ensure that remediation does not
adversely impact air quality.
Under Alternative IOC, additional study will be performed on surface
and groundwater in this area. The proposed study will help determine
whether action needs to be taken to deal with the contamination underneath
the site, and how that action should be coordinated with other cleanup
efforts by nearby Industries that are currently going on. The study will
also address organic contamination as well as lead contamination. The
study should begin later this year and will' be accomplished under'a strict
schedule.
42
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PENNWALT CORP.
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AMERICAN STEEL INDUSTRIE S.I
INC. 1
Flgutf 9
Estimated Areas to be
Remediated under Selected
Remedy
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Surface soils that have a total lead content above 1,000 ppm, and
subr-surface soils, matte, and the East Doane Lake sediments that fail EP
Toxicity standards; will be removed and treated with a fixation additive
to bind the lead in the soils matrix. The stabilized product from the
soils process will be backfilled, graded, and recompacted on site.
Topsol.l and a vegetative cover will be placed over the backfill to prevent
weathering of stabilized soil and subsequent remoblllzatlon of the metal
components. Battery casings which are recyclable will be excavated and
treated to separate the component materials such that they can be
recycled. Output streams from the separation facility that are not
recyclable, and that fail the test of EP Toxicity for lead are required
under RCRA regulations to be disposed of in a RCRA landfill.
EPA Intends to devote extensive design effort to developing a process
that will minimize the amount of material that will require disposal In a
RCRA landfill. If based on the results of the design phase. It appears
that the goals of treating all of the battery casings and minimizing the
amount of material requiring .RCRA disposal are not compatible, an
additional public comment period will be established, and the Record of
Decision may be amended. At such time. EPA would present to the public
other options for dealing with the treated materials.
Those output streams that cannot be recycled but pass the test of EP
Toxicity, will be disposed of on site, and covered with topsoll.
44
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The outfall of East Doane Lake will be blocked such that water that
fails the Oregon Water Quality Standard for lead will not be discharged to
the Willamette River. The processes and unit operations under the
selected remedy are described below. The areal extent of remediation
under the selected remedy is depicted in Figure 9.
Battery casings will be excavated and then delivered to a stockpile
located adjacent to the battery casing treatment plant. The contaminated
soils, sediments and matte will be removed and stockpiled adjacent to a
soils treatment facility. The estimated 1n-s1tu casing and contaminated
soil quantities are as shown In the following table.
Volume Mass
(cu yd) (tons)
Surface Soils 3,370 4,300
Sub-surface Soils 13,650 17,500
Sediments 5,500 7,520
Matte 6,000 12,000
Battery Casings 80,800 86,820
The contaminated soils wl11 be transferred to a stockpile formed
adjacent to the soils treatment facility. Soils *-;ich will not be treated
but were removed for ease of access and slope stability will be stockpiled
and later used as backfill. This volume Is estimated to be 17,800 cu. yd.
The treated soils will be back hauled to the excavation, then gradtd
and compacted in lifts suitable for the soil type. The site will be
graded to have swales and slopes to provide soil stability, drainage, and
prevent run-on from adjacent areas. Top soil will be Imported to provide
a four-inch soil cap with a vegetative cover to prevent weathering and
subsequent airborne migration.
In addition to the earthmoving required on the Gould site, the
northeast section of the American Steel Industries parking lot, which
drains to the lake, will require modification to reroute drainage from
that facility.
To prevent excess airborne migration during surface and subsurface
excavation of material, dust control by watering and other measures will
be practiced as required. In addition to watering, these activities could
Include reduced vehicle speeds; reduced drop heights; and special
enclosures and controls for conveyors. Additional design modifications
may also be required to ensure that fugitive emissions are kept to a
minimum. Site boundaries will be monitored to determine If air emissions
of lead exceed the NAAQS. If continued excedences occur, remedial
operations will be shut down and appropriate modifications to the
operations will be made. Activities may also be adjusted based on
meteorological conditions. A site specific health and safety plan will be
developed to ensure the safety of remedial action workers.
45
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The excavation of subsurface battery casings and subsequent treatment
will result in an extension of East Doane Lake in the Gould property, in
the Rhone-Poulenc property, and on the ESCO property. To prevent erosion,
the excavation will be graveled at the shoreline and coarse gravel will bj'
spread and graded above and below the waterline.
A treatment facility will be constructed at the site to treat con-
taminated surface soils, subsurface soils, sediment and matte. A typical
process for treating soils consists of a comminution system to reduce the
materials to a relatively uniform size, and then pugmllllng with an
additive to bind the metals in the soils matrix.
In the pugmilling section, the process commences at the feed hopper.
Stockpiling, retrieval, material handling, and circulating loads In the
crushing circuit provide a uniform blend of feed material to the pugml11.
In the pugml11 the feed is joined with binder additive and a predetermined
amount of water, then fed to the pugml11 as a water based slurry. In the
pugmlll the additive is driven into the soils. The additive comprise of a
cement-like fixative (cement, pozzolan, lime, clays); a reducing agent,
and various proprietary chemicals. The actual additive composition and
Its ratio will be determined by pilot testing during the design phase.
The pugmlll discharges the stabilized soil to a belt conveyer which
transports It to a stockpile from where 1t will be, retrieved by loader for
backfilling.
A treatment facility will also be constructed at the site to treat the
contaminated battery casings and produce potentially recyclabVe products
or a reduction in material to be subsequently disposed. The process
Includes a comminution system to reduce the materials to a size at which
they can be separated. This is followed by a series of hydroclasslflers ,
which separate the various products in water by the differential specific
gravities. Separation is performed as a function of material specific
gravity and detention time in each classifier. The quantities, specific
gravities, and loose bulk densities of each of the casing components are
estimated to be the following:
Specific Bulk Density Volume Mass
Component Gravity (Ibs/cu.ft.) (cu. vd.) (tons)
Ebonite 1.40 61.21 77,642 64,148
Plastics 0.94 41.90 5,162 2,920
Met. Lead 11.34 267.73 136 493
Oxide/Mud 5.65 214.54 3,059 8,860
Rock/Slag 2.20 95.01 2.313 2,966
Other 1.50 67.00 1,405 1,268
Moisture 1.00 62.30 0 6.175
Average/Total 2.15 71.68 89,717 86,827
46
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The actual volume of casings to be treated will be determined after
additional design work to further define the locations of battery casings
underneath the site and determine the characteristics of the subsurface
casings/soil matrix that can be recycled.
It Is also assumed that both the soils treatment and battery recycling
plants will operate concurrently.
The separated materials from the battery separation facility will be
ebonite, plastic, metallic lead, and a combined stream of lead oxide/mud.
Based on the results of pilot studies It Is assumed that all of the
metallic lead, half of the plastic, and 25 percent of the lead oxide/mud
will be potentially recyclable. Any of the ebonite, plastic, lead
oxide/mud streams that fail EP Toxlclty will be sent to an off-site RCRA
landfill. Materials that pass EP Toxlclty but which can not be recycled
may be left on site. These amounts will depend on the the results of the
separation step.
Rock/debris and other similar materials separated from the recycling
plant feed stream will be sent to the fixation plant and treated with the
soil for backfilling.
The end product of soil stabilization treatmer-: will be tested for the
appropriate physical and chemical characteristics. The design of the
testing procedures will be developed after the pilot testing and selection
of the particular stabilization technique. The testing program woul.d
determine treated and untreated soil properties such as porosfty,
permeability, wet and dry densities, particle size distribution, bulk
properties, and durability. Chemical leach testing of stabilized soil.
Including EP Toxlclty tests, will be done to predict Its chemical
stability.
Design Studies
A major feature of this selected remedy Is the design work that will
be required before the remedy can be Implemented. As discussed earlier,
EPA Intends to devote extensive design effort to developing a process that
will minimize the amount of material that will require disposal In a RCRA
landfill. The design work will consist of a phased series of studies to:
Define recyclabllIty criteria for the subsurface casings -that
will be used to determine the volumes of subsurface casings that
can be recycled.
* Determine the process requirements to separate the casing
components In a manner that minimizes fugitive emissions.
Depending on the results of Initial evaluations under this step,
large quantities of surface casing material may be transported to
an off-site facility for recycling and equipment modification
studies.
* Determine the modifications required to adapt existing separation
technology to conditions at the Gould site.
* Determine the process requirements for treating contaminated
soils, sediment and matte.
47
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
LAWS AND REGULATIONS TO BE CONSIDERED
A. FEDERAL LAWS AND .REGULATIONS THAT ARE ARARs FOR THE GOULD SITE
0 Resource Conservation and Recovery Act (RCRA) (42 USC 6901),
Subtitle C:
EP Toxlcity Standards for lead, cadmium, chromium, zinc.
Landfills: must comply with 40 CFR 264 standards for a hazardous
waste landfi11.
Capping: must comply with 40 CFR 264 Subpart G standards for a
cover over hazardous waste at closure.
Closure with waste in place; must comply with 40 CFR 264 Subpart
1 G standards for closure performance and post-closure care and
monltorlng.
Clean Air Act (CAA) (72 USC 7401):
\
National Ambient Air Quality Standards for.lead.
Ambient Air Quality Standard 1.5 ug/m3 lead
arithmetic average concentration of all samples
collected during any one calendar quarter period.
8 OSHA 29CFR 1910:
Regulations governing worker safety at hazardous waste- sites.
Other Action Specific ARARs
The following ARARS will be used for any wastewater discharges from
remedial actions at the Gould site.
Safe Drinking Hater Act (SHOW) (42 USC 300):
Drinking Water Standards (40 CFR 141), Including maximum
contaminant levels (MCLs).
* Clean Hater Act (CWA) (33 USC 1251):
National Pollutant Discharge Elimination System (40 CFR 122)
Water Quality Criteria (EPA440/5-86-001).
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B. OREGON STATE LAWS AND REGULATIONS' THAT ARE ARARs FOR THE GOULD SITE
Chemical Specific ARARs
Regulation Standard
OAR 437.100.010 No employee exposure to Inorganic arsenic at
concentrations greater than 10 ug/m3 of air
averaged over any 8 hour period.
OAR 340-31.055 Ambient Air Quality Standard ofl.5 ug/m3 lead.
Arithmetic average concentration of all samples
collected during any one calendar quarter period.
OAR 340.20.225 A1r/ Significant Emission Rate of 0.6 ton/year
lead
OAR 437.111.010 No employee exposure at lead concentrations
greater than 50
ug./m3 of air averaged over an 8-hour period.
OAR 340-45 Regulations Pertaining to NPDES and WPCF Permits
Suspended Partlculate Matter
OAR 340-31..015
Annual Geometric Mean 60 ug/m3
24 hour concentration 100 ug/m3
for more than 15 I of
samples In one calendar
month.
24 hour concentration 150 ug/m3
not more than once
per year.
Fine Partlculates/ PM10
Annual Arithmetic Average 50 ug/m3
24 hour average concentration, 150 ug/m3
not exceeded more than average
of one day per year.
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Action Specific ARARs
Hazardous Haste
OAR 340.100-002
(Federal Regulations Incorporated by Reference)
Capping
surface Impoundments - 40 CFR 264.228
waste piles - 40 CFR 264.258(b>
landfills - 40 CFR 264.310(a)
Closure with waste in place
stabilization - 40 CFR 264.228
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OAR 340-130 Notice of Environmental Hazards - pertains to
institutional controls at the site
Solid Haste
Regulation Standard .
OAR 340-61 Solid Waste Management - covers storage, disposal
and treatment of solid waste.
ORS 459-005 to 459-355 Solid Waste Control - same as above.
Air Quality
Depending on the type of action designed, the regulations described below
may contain specific requirements In addition to the chemical specific air
pollution regulations cited earlier.
Regulation Standard
OAR 340-20 Air Pollution Control - details contained In
regulations cited below.
OAR 340-20-001 Highest and Best Practicable Treatment and
Control Required
OAR 340-20-040 Methods
OAR 340-20-240 Requirements for Sources In Nonattalnment Areas
OAR 340-20-225 Significant Emission Rate
OAR 340-20-245 Requirements for Sources In Attainment or
Unclassified Areas (Prevention of Significant
Deterioration)
OAR 340-21 General Emission Standards for Partlculate Matter
OAR 340-31 Ambient Air Quality Standards
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Oregon Occupational Safety and Health Code
Regulation Standard
OAR 437-40 General Provisions
OAR 437-50 Personal Protective Equipment
. OAR 437-83 Construction
OAR 437-100 Inorganic Arsenic
OAR 437-111 Lead
OAR 437.114 Air Contaminants
OAR 437.129 Protective Equipment. Apparel, and Respirators
OAR 437.136 General Occupational Health Regulations
Transportation of Hazardous Materials
OAR 860.66.055 to 860.66.072
Oregon Land Use Goals:
OAR 660.15.000(6) . .
Goal 6. Air, Water and Land Resources Quality - Establishes that
discharges shall not exceed the carrying capacity of air water or
land and shall not violate applicable Federal or State
environmental quality statutes and regulations.
OAR 660.15.000(7)
Goal 7. Areas Subject to Natural Disasters and Hazards - Establishes that
floodplain areas should be evaluated as to the degree of hazard
present.
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C. FEDERAL LAWS AND REGULATIONS TO BE CONSIDERED
Safe Drinking Water Act (SWDW) (42 USC 300):
Drinking Water Standards (40 CFR 141), Including maximum
contaminant levels (MCLs).
0 Clean Water Act (CWA) (33 USC 1251):
National Pollutant Discharge Elimination System (40 CFR 122)
Water Quality Criteria (EPA440/5-86-001).
D. STATE OF OREGON LAWS AND REGULATIONS TO BE CONSIDERED
Chemical Specific Regulations
OAR 333.61.030 0.05 mg/1 Drinking Water Standard for chromium
0.05 mg/1 Drinking Water Standard for lead
5 mg/1 Drinking Water Standard for zinc
0.01 mg/1 Drinking Water Standard for cadmium
0.05 mg/1 Drinking Water Standard for arsenic
OAR 340-41-445 0.05 mg/1 Lead Standard for Protection of Human
Health from Water and Fish Ingestlon
0.01 mg/1 Chromium Standard for Protection of
Human Health from Water and Fish Ingestlon
0.05 mg/1 Arsenic Standard for protection .of
Human Health from Water and Fish 1nge«t1on
Water Quality Regulations
OAR 340-41-001 to State Wide Water Quality Management Plan -
340-41-029 regulates groundwater quality.
OAR 340-41-442 to 470 Willamette Basin - establishes beneficial uses to.
be protected and water quality criteria not to be
exceeded.
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APPENDIX B
RESPONSIVENESS SUHMARY
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RESPONSIVENESS SUHHARY
NL/GOULD, INC.
PORTLAND, OREGON
This community relations responsiveness summary Is divided Into the
following sections:
PAGE
Section A:
Overview.
Section B:
3
This section discusses the EPA selected alternative for
corrective action and public reaction to this alternative.
Background on Community Involvement and Concerns.
This provides a brief history of community Interest and
concerns raised during remedial planning and Investigation
activities at the NL/Gould, Inc., site
Section C: Summary of Comments Received During the Public Comment
Period and EPA's Responses to the.Comments.
Both written and oral comments are categorized.
responses to these comments, are also provided.
EPA's
Section D: Remaining Concerns.
This section describes remaining community concerns that EPA
should take Into consideration In conducting the remedial
design and remedial action at the NL/Gould, Inc.. site.
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OVERVIEW
At the time of the public comment period (2/18-3/18/88), EPA Identified a
preferred cleanup alternative for the NL/Gould site. EPA's preferred
alternative Involved removing the battery casings on and beneath the site and
treating them for proper disposal of lead, plastic, and other materials;
treating the lead contaminated soil and sediments with a chemical additive to
bind the lead to the soil and keep the contamination on site; and additional.
studies of groundwater pollution in the Ooane Lake area to decide If
additional cleanup is necessary. The preferred alternative 1s described
further In the detailed evaluation.
This Responsiveness Summary describes concerns which the community has
expressed regarding the problems at the site and the preferred cleanup
alternative. EPA's response to these comments are also provided.
After reviewing all the comments received during the public comment
period, EPA has determined that residents of the local communities, local
environmental groups, and the Oregon Department of Environmental Quality
strongly support EPA's proposed alternative. Indeed, some residents .and
groups would go farther. • ^
The potentially responsible parties, NL Industries and Gould, Inc., do
not support EPA's preferred alternat:ve. Instead, they recommend Alternative
2C, which is discussed in the detailed evaluation.
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3
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
From 1981 until 1985 when EPA assumed the enforcement lead for the site.
Oregon Department of Environmental Quality (DEQ) conducted community relations
activities as part of its regulatory efforts at the site.
In 1982, DEQ announced proposed listing of the NL/Gould site for the
National Priorities List. There was little public response to the proposed
listing. From December 1982 to September 1983, the site received moderate
media publicity. General public interest In the site appeared to be low
despite the Intermittent media coverage.
In 1983, Oregon Congressional Representative Les AuColn corresponded with
DEO about the site, and DEO held a meeting with city, county, and state agency
officials to present information about environmental concerns In the area and
to solicit comments. Representative AuColn specifically requested that DEQ
assure him that site cleanup would completely remove potential contaminants.
EPA prepared a Community Relations Plan for this site In 1985, based on
research and interviews with Interested community members and officials".. The
.issues of concern to the affected community and local officials Included:
1.- Groundwater Pollution. People were concerned about ground- water
contamination in the area and how It might affect future growth of
the area.
EPA responded to this concern by including extensive groundwater testing in
theRI.
2. Airborne Lead. Several agency officials Indicated that high levels
of lead emissions were a primary concern and that high levels of
airborne lead could adversely affect the health of nearby workers.
Exposure to lead at the approximately 10 houses In the hills above
the site was thought unlikely, but necessary to Investigate.
EPA has included air monitoring in the RI.
3. Effects on Workers' Health. Individuals were concerned about
exposure through Incidental Ingestlon of ground water obtained for
Industrial use and exposure to airborne lead.
EPA has included exposure scenarios for workers in the risk assessment for
the site.
4. Cleanup Schedule. Staff from Representative AuColn's office and a
representative from the Oregon State Public Interest Research Group
expressed dissatisfaction that cleanup measures had not been
implemented earlier.
EPA has attempted to evaluate the site and make a remedial decision in an
expeditious manner. By focusing on the soils unit, a decision will be made
now.
5. Future Development of the Doane Lake Area, the media and local
officials expressed concern about how the current pollution would
affect or restrict future uses of the land*
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Future use restrictions are expected to be minimized by removing or treating
as much of the lead at the site as possible.
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6. Disposal of Dredged Materials from the River. A representative from
the Port of Portland indicated the Port's concern about disposing of
dredged materials from the Willamette River that might be found to
contain contaminants from the site.
The RI included an evaluation of sediment around the outfall from East
Doane Lake.
7. Environmental Investigation of Doane Lake Area. A representative
from the Association of Oregon Industries and representatives of
elected officials indicated concern that DEQ's environmental
Investigation in the Doane Lake area could decrease future
Industrial development and Jobs In the community.
No reports of decreased industrial development as a result of these
investigations has been received by EPA.
8. Disposal of Battery Casings. An aide to Representative AuColn's
office expressed dissatisfaction that battery casings had not been
removed from the site. Representatives from the Portland Department
of Public Works cautioned that any plan to dispose of waste
materials at'St. John's'Landfill would be unpopular.
EPA intends to recycle as much of the battery casing components as is
feasible.
\ •
During the Investigation and reporting phases of the RI/FS, fact sheets
were produced and mailed out to the community and the press to keep them
Informed of progress at the site. EPA and DEQ also consulted by phone with
several prominent community members about Issues of concern shortly before
review and evaluation of the RI/FS produced by the contractor.
Two public meetings were held to discuss the results of these studies and
EPA's proposed plan: the first on February 18th and the second on March 10th.
The results of these meetings and comments received are discussed In the next
section.
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5
SECTION C
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
The comment period was held from February 16, 1988, to March 18, 1988,
and Included two public meetings. Comments and questions raised during the
NL/Gould public comment period on the draft FS and the proposed plan are
summarized briefly below. Comments are grouped and categorized by subject.
Detailed comment letters from the PRPs are summarized, along with the Agency's
response at the end of this section.
Approximately 50 people attended each of the two public meetings. Each
meeting consisted of about 45 minutes of presentations followed by question
and answer and public comment opportunities. The audience questioned EPA, the
potentially responsible parties, and their consultant. Dames and Moore, about
the site, the studies, the alternatives, and the Superfund process. At the
first meeting, citizens requested a second public meeting and additional
explanation by EPA of the preferred alternative as well as other
alternatives. This resulted In the second meeting. For that meeting, the
PRPs requested an opportunity to make a presentation. Dames and Moore were
given about 20 minutes at the second meeting to present their results, and
evaluation of the remedial alternatives. Transcripts of both meetings are
available in the Administrative Record.
After reviewing all the comments received during the public comment
period, EPA has determined that residents of the local communities, local
environmental groups, and the Oregon Department of Environmental Quality
strongly support EPA's proposed plan.
Preference for Remedial Alternative
A total of 21 comments were received supporting EPA's proposed
alternative and recommending the long range cleanup of the site. In addition
to their support, the following more detailed comments were made:
1. The Northwest District Association's Health and Environment Committee
prefer Alternative IOC. However, they recommended that the selected
remedy be expanded to clean up all pollutants In the qroundwater and
provide continuous qroundwater and air monitoring to ensure that
contaminants do not migrate Into the environment.
EPA Response: The intent of the selected remedy Is to Insure that all
health and environmental hazards posed by sediments.
soils, and casings at the site are addressed by
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treatment. Monitoring and control of air emissions will
be a priority during remedial design, and groundwater
issues will be resolved at the conclusion of the
groundwater studies planned for later this year (see
Section D).
2. The Oregon Department of Environment Quality recommends Alternative IOC.
DEO does not feel that Alternative 2C will be satisfactory to the state.
If 2C Is implemented, there is a high probability that the site would be
revisited under the state's new Superfund authority.
EPA Response: These and other concerns about Alternative 2C contributed
to EPA's choice of the selected remedy described In
Section VI of the ROD.
3. The Oregon State Public Interest Research Group (OSPRIG) preferred a
complete cleanup of the site. Of the alternatives described In the FS.
they preferred and recommended implementation of Alternative IOC. OSPRIG
raised questions about how thorough the site characterization was and
supported additional, more comprehensive, qroundwater studies. Concerns
were expressed with any solution leaving hazardous materials on site.
since the site is within the 100 year floodplaln of the Mlllame'tte
River. OSPRIG also expressed concern about site access and casual .
exposure to the hazards at the site, and that there are no signs warning
of the presence of hazardous waste at the site. OSPRIG also recommended
setting up a working task group made up of citizens, local officials, anlf
'academics.
EPA Response: The selected remedy will address the contaminated soils,
sediments, battery casings, and other solids. The current
information available on the surface and groundwater at
and around the site Is Insufficient to make a decision on
how to clean up those areas at this time. EPA will
propose additional remedial measures for ground and
surface water, If necessary, after further studies are
complete next year (see section 0).
The company has been asked to take measures to restrict
access and to warn of the presence of hazardous materials.
Working task groups consisting of citizens, local
officials, etc., have worked In some communities and may
be set up for the Gould site If there Is enough Interest.
4. Several other citizens expressed support for the preferred
alternative and added their opinion that the community would only
accept solutions that fully addressed toxicity and mobility of both
surface and subsurface contaminants.
EPA Response: The selected remedy Is Intended to reduce the
mobility, toxicity and volume of contaminants to the,
maximum extent practicable.
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5. The PRPs and their representative, recommended Alternative 2C.
EPA Response:
Alternative 2C would not meet the Superfund mandate to
reduce toxicity, mobility, and volume to the extent
practicable as well as the selected remedy. This
recommendation and other concerns are addressed In more
detail 1n letters from NL Industries and Gould. A summary
of the concerns raised in those letters as well as EPA's
detailed responses to those concerns are Included at the
end of this section.
Technical Concerns/Questions Regarding Remedial Alternatives
1. Resident expressed concern about reliance on Institutional controls for
the site.
•••••••^•••^•^MMV ^
EPA Response EPA does not believe that Institutional controls alone
will be protective If the contaminated material remains on
site untreated. However, Institutional controls may be
necessary in addition to the selected remedy to ensure
protection of public health.
2. Citizen asked what lead standard will EPA use at this site, the current
standard or a new standard if one is proposed/promulgated before remedial
action starts at the site.
EPA Response: The selected remedy 1s based on the current lead standard
(50 parts per billion). EPA will consider changing to any
new standards if they are more protective of human health
or the environment.
3. Citizen asked whether the selected remedy would result 1n creation of a
hazardous waste landfill by fixing the lead In the soil.
EPA Response:
The proposed plan would not Involve creating a RCRA
(hazardous waste) landfill. The contaminated materials
would be treated In such a way that they would no longer
have the properties that would make them a hazardous waste.
Citizen asked whether there would be any sodium hydroxide problems with
the preferred alternative.
EPA Response:
There should not be any sodium hydroxide problem. A
treatment facility on the site would be constructed to
treat the 20,000 yards of contaminated soils. Then the
clean material would be covered with some Imported top
soil and capped with new growth vegetation.
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5. Citizen asked whether the technology needed to recycle lead out of tha
casings 1s currently available.
EPA Response: Pilot tests have shown that recycling Is possible.
Additional design work will be done to apply the
technology to the Gould site.
6. Citizen asked how long monitoring would continue.
EPA Response: Under Superfund law, monitoring may continue for an
extended period of time. Under the new law, EPA Is
required to re-evaluate the site once every five years to
determine if additional clean up Is necessary.
7. Citizen asked whether Alternative IOC will involve draining the lake and
dredging all the sediments.
EPA Response: Alternative IOC will involve dreo:ing the sediments out of
the lake, not draining the lake.
8. Citizen asked whether draining the lake to reach contaminated bottom
sediments would be easier than dredging sediments and then treating them.
EPA Response: No, because the lake basically represents the surface of
the groundwater at the site. If the lake was drained, 1&
would re-fl11.
9. Citizen asked what current technology Is available to remove sediments In
the lake.
EPA Response: Options would Include a variety of dredging systems. This
Is one of the items that will be dealt with 1n the design
of the selected remedy.
10. Citizen asked about the history of filling Doane Lake and how much of It
has been filled with battery casings and when was the last time 1t was
routinely done.
EPA Response: Based on dated aerial photos taken throughout the years,
significant areas of the lake have been filled. The other
remaining fill Is just a variety of different types of
material. ML Industries says the last time casing were
used as fill was 1972.
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11
Citizen asked whether the aquifer has been examined for lead and whether
It has ever been examined In times of overflow to see how much lead Is
going Into the river.
EPA Response:
River Impacts have been estimated based on discharges from
the overflow storm drain for East Doane Lake.
12. Citizen asked about whether there was sufficient site characterization.
EPA Response:
EPA feels the site characterization was sufficient to make
a decision about soils, sediments, and battery casings.
There still Is contaminated groundwater at the sfte and we
do not feel that the situation there has been adequately
addressed. Additional groundwater studies are being
planned.
13. Citizen asked about the future use of the property.
EPA Response:
The future use of the property wi •* depend on the success
of the remedial action. It Is likely that some
institutional controls or restriction on use of the
property will be part of the final remedy; however, the
full extent of those controls will not be determined -until
later.
EPA Response:
Costs/Funding
1. C111zen requested information on costs and who would pay for the cleanup.
Since the.PRPs are conducting the RI/FS, EPA will first
negotiate with the PRPs to arrange to have them pay for
the cleanup as well as for any costs Incurred by EPA
during the cleanup.
If negotiations with the PRPs fall monies could come from
the federal trust fund set up for Superfund.
2.
Citizens asked several questions
for the alternatives.
about the basis of the price estimates
EPA Response:
Cost estimates are based on Superfund program guidance and
general cost estimation guides. The basis for these
specific cost estimates Is given In Appendix C of the FS
report.
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10
Public Participation
1. Citizens at the first public meeting expressed a concern that they had
not had enough time or information to fully comment on the Issues. As a
result, they requested a second public meeting and additional explanation
by EPA of the preferred alternative and Alternative 2C. .
EPA Response: The first public meeting was held at the Northwest Service
Center, Thursday, February 18, 1988, to explain the
results of the Investigations and to discuss the
recommended remedial alternatives. In response to
requests from the citizens, EPA provided additional
materials written In less-technical language explaining
the alternatives and scheduled a second meeting. A second
public meeting was held on March 10, 1988.
2. The PRPs requested an opportunity to speak at the second public meeting
and describe in their own words their reasons for preferring Alternative
2C (Additional concerns raised by the PRPs are summarized and responded
to at the end of this section).
EPA Response: At the second meeting, EPA allowed Dames & Moore .(the
consulting firm .which performed the RI/FS) to'make a brief
presentation describing the relative merits of various
alternatives. At both meetings, citizens were Invited ton
address questions directly to the PRPs and their
consultants as well as to the Agency. (At the first
meeting, the PRPs and consultants were given the same
opportunity as all others in attendance to make comments
on the record.)
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n
Health Issues
1.
Citizens expressed concern regarding long
to contaminants at the site.
term health effects of exposure
EPA Response: Lead and the other contaminants at the site are known to
cause developmental problems In children who are exposed,
as well as renal problems. Under the No Action
Alternative, the Endangerment Assessment prepared for NL
and Gould showed exposures above health based levels. The
selected remedy would reduce the risk of exposure to below
these levels.
2. Citizen asked whether women, particularly those of child-bearing age.
were more sensitive to renal problems and other potential adverse health
affects, and whether that was taken Into account In the studies.
EPA Response: Based on the Endangerment Assessment, children are seen as
the most sensitive group In terms of lead Impacts.
3. Concern regarding reproductlvely-aged persons working and living close to
the site and about renal toxidty. x - .
EPA Response:- In the Endangerment Assessment, altered testlcular
function and renal dysfunction were among the reported
effects of elevated blood lead levels.
4. Citizens and- neighboring businesses have raised concerns about the health
and safety of nearby workers during and after any remedial action.
EPA Response: EPA has expressed Its Intent to Implement the selected
remedy In a manner that Is fully protective of public
health, based on the National Ambient Air Quality Standard
for lead. Specific measures will be part of the remedial
design which will be presented for public comment before
Implementation.
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12
Comments/Concerns Raised by Neighboring Businesses
1. Since ESCO corporation boundary 1s Immediately adjacent to the NL/Gould. '
Inc. site. ESCO objects to any requirements which might be Imposed upon
ESCO or Its property in connection with proposed EPA cleanup
recommendations concerning the remedial work at the Superfund site.
EPA Response: Noted.
2. Pennwalt Corporation wished to make a correction to the FS report.
Pennwalt has never manufactured or even handled sodium arsenlte or any
other substances containing arsenic. The plant Is not a hazardous waste
generator and does not customarily ship wastes to Arlington. The report
also Infers that brine purification residue Is a hazardous b -product.
The residue consists of calcium carbonate and magnesium hydroxide and has
a pH of 10 to 11. This material Is not hazardous waste.
EPA Response: Noted.
3. Richard Bach, attorney representing the Northwest National Gas Company.
and James Benedict, attorney representing Rhone-Poulenc. vine, both
commented that it was their understanding that actions and records to
date regarding the NL/Gould site would not be part of the Administrative
Record for the planned groundwater study.
EPA Response-: An Administrative Record for the Record of Decision for
the groundwater/surface water unit at this site will be
developed. That Administrative Record will contain those
documents necessary to support appropriate remedial
actions.
4. The attorney for Rhone-Poulenc. Inc. raised concerns about access to the
Rhone-Poulenc property during RD/RA and about possible Institutional
controls which might affect company property, and stated while the Issues
were not resolved, the company Is willing to discuss those Issues.
EPA Response: EPA considers this additional reasons to question the
effectiveness of Institutional controls as a means of
protecting public health at this site.
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Comments from Potentially Responsible Parties
Concerns raised In the comment letter from NL Industries, dated March 15.
1988, are detailed and responded to below:
1) The site presents little
environment.
if any threat to public health or the
EPA Response:
The Endangerment Assessment prepared by the PRP's does In
fact show that under the No-Action Alternative AICs are
exceeded for some of the exposure scenarios.
2) The site would not qualify today for Inclusion on the NPL.
EPA Response: This statement Is untimely and moot. Since the site J_s on
the NPL, EPA is required by law to conduct a RI/FS study
and take appropriate remedial action consistent with
CERCLA. The ROD and Selected Remedy reflect the agency's
attempt to do that. Based on the Endangerment Assessment
prepared by Dames & Moore for NL and Gould, EPA has
determined that the No-Action Alternative pos.es
unacceptable health risks, and therefore remedial action
Is required at this site. > " -
3) As indicated In the FS. only Alternative 2C Is rated as "high" across-the
board.
EPA Response:
As indicated in the Detailed Evaluation of Alternatives
section of the Record of Decision, EPA's evaluation of the
Alternatives differs from NL's.
4) Alternative IOC will result in recycling 3 per cent of material.
EPA Response:
Using Information from the FS, Alternative IOC Is
estimated to recycle over 1,000 tons of lead, or about 251
of the total lead In the battery casings.
5) Implementation of Alternative IOC Involves substantial air emissions.
EPA Response: EPA has reviewed Attachment 2 of NL's letter. Several
assumptions and approaches used 1n the report lead to
conservative emission estimates and correspondingly high
estimated ambient lead concentrations. Namely:
* Some of the emission factors taken from AP-42 Include general
emission factors that are used to represent a variety of processes.
Including blasting. As a result, these factors are considered
conservative.
* A variety of controls are available that will provide dust
suppression In excess of that assumed by NL. These Include
biodegradable oil based dust suppressants, controls on vehicle
speeds, controls on drop heights, and coverings over specific
fugitive emission points. In particular, emissions from conveyors,
which are responsible for most of the estimated fugitive emissions
from remediation, are particularly well suited to fugitive dust
controls.
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14
* The modeling performed in the report was done without the use c*
on-site or local metorological data, despite the fact that data were
available for use in the model. Instead, worst case assumptions
were used to genrerate a one-hour average, which was later adjusted
to a quarterly average. This is an inappropriate use of the ISC
model and leads to overly conservative concentration estimates.
Other assumptions in the modeling which lead to conservative
estimates include: simulation of sources as area sources rather than
volume sources; and the close proximity of receptors to assumed area
source boundaries, which the user's manaul for the ISC model
indicates will generate higher estimated concentrations.
In conclusion, EPA's opinion is that NL's emission rates are
conservative and that the emissions from Alternative IOC can be controlled to
such an extent that the operations should comply with the lead NAAQS. It Is
EPA's Intent to comply with this standard 1n Implementing Alternative IOC.
7) Alternative IOC relies on unproven technology.
EPA Response: The battery recycling equipment *.;sed In the pilot studies
was conventional machinery. During the pilot studies that
equipment was able to recycle the material from the Gould
site. EPA recognized that there were some materials
handling problems associated with those tests and that
those problems will require additional design work before
a facility is constructed at the Gould site. However,
is EPA's opinion that the basic technology for
implementing IOC is proven.
8) EPA and DEQ have failed to follow basic administrative and environmental
law principles in selecting their preferred alternative.
EPA Response: EPA and DEQ, after reading the draft FS, expressed support
for an alternative that represented a variation of an
alterantlve presented In the draft FS. It was requested
that this alternative be further developed so that EPA and
DEQ could evalutate It In more detail. During subsequent
meetings In January, NL and Gould provided EPA- and DEQ
with sufficient additional Information that the agencies
were further able to evaluate this alternative and prepare
a proposed plan for the public. This Information was
provided to EPA prior to the delivery of the final FS
report.
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15
9) EPA and DEQ Ignored the recommendations of the report prepared by
Environmental Standards regarding risks from remedial actions.
EPA Response: EPA evaluated the report along with the FS. As the record
of decision shows, EPA's evalautlon of the Alternatives
differs from that contained In FS report. EPA's
evaluation differs from Environmental Standards on this
particular issue in that EPA has expressed Its Intent to
implement IOC In a manner that Is fully protective of
public health. During design estimates will be made of
fugitive emissions from the designed facilities and If 1t
appears that estimated fugitive emissions result In
exceedences of the NAAQS for lead, design modifications
may be required. In addition, during remediation. If
violations are noted, activities will be halted or
curtailed. By doing this EPA expects to minimize off site
deposition of lead such that the spread of contamination
from the site on to adjacent properties should not occur.
By "spread of contamination" EPA means a statistically
significant increase above backgrrjnd levels.
10) Alternative IOC is not cost effective and results In costs of $11.000 per
ton of recyclables.
" •" ^" . \
EPA Response: The $11,000 per ton figure appears to based on the total
cost for entire remedy; the cost for the recycling portion
alone appears to be far less than this. For example, the
detailed costs for this alternative Include estimated
costs of over $2,500,000 per year to dispose of the
material at a hazardous waste landfill. EPA has stated
that It Intends to minimize the amount of material that
requires RCRA disposal. Also, In the screening of
alternatives section of the Record of Decision, EPA states
that the higher costs of Alternative IOC are commensurate
with the higher long term effectiveness and greater
reduction In volume of lead In the waste stream achieved
by this remedy.
11) Institutional controls can be used effectively, those controls are as
much a part of IOC as they are of 2C. and they are widely accepted by EPA.
EPA Response: Although Institutional controls are mentioned In both IOC
and 2C, the controls differ In the extent to which they
are part of a complete remedial package. In IOC controls
will be used In areas where contamination has been treated
to the maximum extent practicable, while 1n 2C they are
not. In addition, EPA questions the effectiveness of
Institutional controls, particularly on portions of the
site that are not owned by Gould (see comment #4 on page
12).
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16
12) Has EPA/DEQ considered the impacts of utilizing some 80.000 yards of
landfill space.
EPA Response: EPA and DEO have considered the Impacts of disposing of
80,000 yards of material In a RCRA landfill and consider
them to be an undesirable requirement associated with
implementing the selected remedy. EPA Intends to devote
extensive design effort to developing a process that will
minimize the amount of material that will require disposal
in a RCRA landfill. If based on the results of the design
phase, it appears that the goals of treating all of the
battery casings and minimizing the amount of material
requiring RCRA disposal are not compatible, an additional
public comment period will be established, and the Record
of Decision may be modified. At such time, EPA would
present to the public other options which are equally or
more protective of public health that allow this material
to remain on site.
13) The discrepancies between EPA's decision at this site and EPA's decision
at the Newport Dump site were noted.
EPA Response: In each case It appears that EPA. evaluated the site- In
accordance with the requirements of CERCLA. Using the
same approach at different sites can result In different
decisions, depending on the specific alternatives
available for remediation, the specific health and
environmental threats, and the laws and regulation that
are considered ARARs.
14) EPA modified Alternative IOC in presenting It to the public.
EPA Response: EPA described additional work that was being done on
cleaning ebonite to point out that additional steps that
were possible aside from the washing steps Include In the
pilot studies. It Is EPA's Intent to design a treatment
plant that Is generally consistent with the processes
presented In the FS by NL and Gould.
15) Inconsistencies were noted In the Supplement to the Draft Feasibility
Study of Cleanup Alternatives for the NL/Gould Superfund Site.
EPA Response: The _.ie Inconsistency that has not been addressed earlier
In this response Involves differences between the
evaluation of the protectIveness of the cap under
Alternatives 2C and IOC. Although the cap under 2C Is
thicker, the overall protectlveness of a cap In this
situation Is not considered as high because of the higher
levels of contamination that will exist under the cap In
Alternative 2C.
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17
Concerns raised in the comment letter from Gould, Inc., dated March 18, 1988,
are detailed and responded to below:
1) Alternative IOC Is so dangerous to human health and welfare and to the
environment that It subjects EPA to massive third-party liability for personal
Injury and property damage.
EPA Response: As stated elsewhere In this Record of Decision, EPA
intends to implement IOC in a manner that Is protective of
public health and complies with ARARs, Including the NAAQS
lead standard. Given EPA's Intent regarding the
implementation of IOC, it Is not anticipated that the
agency will have to rely on any shield provided by the
Federal Tort Claims Act or liability limitations provided
for within CERCLA as amended.
2) EPA's proposal to select Alternative IOC is not supported by the record.
is Inconsistent with statutory and regulatory criteria, and will be overturned
by judicial review.
EPA Response: EPA believes that the selected remedy Is consistent with
statutory and regulatory criteria. The standard for
judicial review is the arbitrary and capricious standard.
EPA's selection must be upheld unless the objecting' party
can demonstrate on the Administrative Record that the
remedy is arbitrary and capricious and an abuse of
discretion or otherwise not In accordance with the' law.
The agency believes that its declslonmaklng process as
demonstrated by this Administrative Record is both
• deliberate and contemplative of all considerations.
3) Gould feels that for EPA to select Alternative IOC would be arbitrary.
capricious, unlawful, and an abuse of decretlon that will violate all
applicable criteria for remedy selection.
EPA Response: See response above.
4) . Gould feels it would be arbitrary, capricious, unlawful, and an abuse of
discretion to select an alternative not supported by the ROD
EPA Response: See response to #2.
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5) Gould feels EPA cannot properly take public acceptance into account wher
It has misrepresented the record to the public.
EPA Response: The public hearings were recorded and PRP's were given
sufficient opportunity to present their alternative. The
agency has presented both Its views and the views of the
PRPs to the public during the comment period, and has
complied with all requirements for public notice and
comment as established by CERCLA as amended.
6) Gould feels it was unlawful for EPA to add the Portland site to the
National Priorities List ("NPL")
EPA Response This statement is untimely and moot. Since the site |js on
the NPL, EPA is required by law to conduct a RI/FS study
and take appropriate remedial action consistent with
CERCLA. The ROD and Selected Remedy reflect the agency's
attempt to do that.
7) If Alternative IOC is selected and implemented. EPA and the PRPs will
potentially be subject to massive and costly litigation.
EPA Response: This concern as raised by Gould refers to eithe'r.
litigation brought by the PRP's against the agency or
third party liability actions brought by other parties.
As to third party liability actions, as stated elsewhere^
in this Record of Decision, EPA Intends to Implement IOC™
in manner that is protective of public health and compiles
• with ARARs, including the NAAQS lead standard. Given
EPA's Intent regarding the Implementation of IOC, It Is
not anticipated that the agency will have to rely on any
shield provided by the Federal Tort Claims Act or
liability limitations provided for within CERCLA as
amended. As to PRP generated litigation, EPA considers
the risk of such litigation to be endemic to the CERCLA
process, especially In such Instances where EPA's proposed
remedy differs from that of the PRP's. Such lltlgatlve
risk should not bear weight In arriving at an appropriate
remedy under CERCLA as amended.
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19
SECTION D
REMAINING CONCERNS
This section describes issues and concerns that EPA has not been able to
address to date or must continue to address during RD/RA.
• How contaminated is local qroundwater and what will be done about It?
EPA Response: EPA was unable to fully address this since additional
investigation is required to fully characterize local
groundwater and the impacts of surrounding Industries
and to evaluate feasible remedies. Additional
studies of a wider area are In the planning stages
and results are expected by Spring or Summer of 1989.
• Citizen asked what water quality standards the remedy would have to
achieve, and if we did not know, how could EPA select a cleanup
alternative.
EPA Response: EPA has decided to select a remedy for soils,
sediments, and casings, but to defer the groundwater
remedy until we have additional Information. Cleanup
and monitoring levels for ground and surface water
will be determined at that time.
• Hho wi11 pay for the remedy?
EPA Response: EPA was unable to address this since negotiations
with the PRPs remain unresolved.
Citizens rasied the following concerns and questions regarding details of
the design of the proposed plan/selected remedy which will have to be
responded to In the remedial design process:
• How will EPA take Into account BPA power lines across adjacent
properties which must provide uninterrupted electrical service?
• If lead is binding to the soil. Is there a saturation point and how
long will It be before the lead/soils reach the saturation point and
start leaching out and contaminating qroundwater?
• During cleanup, will the soils at the edge of the Gould property
would be disturbed?
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20
• Hhat precautions will be taken to control dust and airborne lea
emissions when materials are excavated and/or transported from th
site? (Some related issues were addressed In answer to the PRPs
concerns)
• Is there a risk that air emissions from the site could be
electrically conducted and cause a risk to/from the neighboring
power lines?
• Has EPA examined the existence or lack thereof of blomethylatlon of
lead and arsenic and does the selected remedy prevent any further
blomethylation.
EPA Response; EPA will address all the above issues during remedial design.
Citizens also requested the following:
• That EPA keep the public, including workers 1n the area. Informed In
a timely manner of the results of engineering studies, pilot tests,
and other aspects of remedial design of the selected remedy. EPA
will prepare and distribute fact sheets periodically and as
appropriate. . .
EPA Response: EPA will provide an opportunity for public comment,
including a meeting, to discuss the remedial design
before it is approved or completed by EPA. ,
• That EPA continue with the groundwater studies being planned and
report back to the community.
EPA Response: The studies willbe done and EPA will provide a
public comment period and meeting when results are
available.
• That EPA carefully monitor and control air emissions during
remediation to minimize airborne lead emissions.
EPA Response: EPA will specify and If necessary conduct airborne
emissions monitoring and control measures during
RD/RA.
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APPENDIX C
ADMINISTRATIVE RECORD
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MAR ?.S-1538
Department of Environmental Quality
811 SW SIXTH AVENUE. PORTLAND. OREGON 97204-1334 PHONE (503) 229-5696
March 28, 1988
Robie Russell
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
yj Re: Gould Proposed Plan Certification
Dear Mr. Rurfsell:
The Oregon Department of Environmental Quality (DEQ) has carefully reviewed
the EPA proposed plan for the soils unit as described in the draft final
record of decision (ROD). The Department concurs with EPA's selected ' -
remedy based on alternative IOC as satisfying the statutory requirements for
a remedy as required by the State of Oregon. It has been determined that
the proposed remedial action complies with the applicable or relevant and
appropriate requirements (ARARs) as identified to you in the Department's
letter of March 7, 1988.
The alternative based on IOC maximizes the use of recycling technologies in
providing a permanent solution to the contamination problem at the Gould
site. This concept is in keeping with the intent of Oregon's "superfund"
legislation.
Department staff are available to provide you additional information, if
necessary. The appropriate DEQ contact is William Renfroe, (503) 229-6900.
Sincerely,
Fred Hansen
Director
UTR:f
ZF3002
cc: Mike Downs, HSU
Kurt Burkholder, AG
Dick Nichols, WQ
Ron Householder, AQ
Tom Bispham, AQ
Chuck Findley, EPA
Dave Tetta, EPA
Mike Gearheard, EPA 000
William Renfroe, HSW
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APPENDIX 0
STATE LETTER OF CONCURRENCE
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APPENDIX 0
STATE LETTER OF
-------
NEIL OOLOSCHMIOT
MAR 29 1938
OFFICE OF
Department of Environmental Quality q£GIONAL ADMIN!
811 SW SIXTH AVENUE. PORTLAND, OREGON 97204-1334 PHONE (503) 229-5696
March 28, 1988
Robie Russell
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Si Re: Gould Proposed Plan Certification
Dear Mr. Russell:
The Oregon Department of Environmental Quality (DEQ) has carefully reviewed
the EPA proposed plan for the soils unit as described in the draft final
record of decision (ROD). The Department concurs with EPA's selected ' •
remedy based on alternative IOC as satisfying the statutory requirements for
a remedy as required by the State of Oregon. It has been determined that
the proposed remedial action complies with the applicable or relevant and
appropriate requirements (ARARs) as identified to you in the Department's
•letter of March 7, 1988.
The alternative based on IOC maximizes the use of recycling technologies in
providing a permanent solution to the contamination problem at the Gould
site. This concept is in keeping with the intent of Oregon's "superfund"
legislation.
Department staff are available to provide you additional information, if
necessary. The appropriate DEQ contact is William Renfroe, (503) 229-6900.
Sincerely,
Fred Hansen
Director
UTR:f
ZF3002
cc: Mike Downs, HSU
Kurt Burkholder, AC
Dick Nichols, WQ
Ron Householder, AQ
Tom Bispham, AQ
Chuck Findley, EPA
Dave Tetta, EPA
Mike Gearheard, EPA 000
William Renfroe, HSW
OEO-1
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