PB97-963121
EPA/541/R-97/060
November 1997
EPA Superfund
Record of Decision Amendment:
Gould, Inc.,
Soils Operable Unit,
Portland, OR
6/3/1997
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AMENDED RECORD OF DECISION
DECISION SUMMARY, AND
RESPONSIVENESS SUMMARY
FOR
GOULD SUPERFUND SITE
SOILS OPERABLE UNIT
PORTLAND, OREGON
JUNES, 1997
UNTIED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
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GOULD SUPERFUND SITE
SOILS OPERABLE UNIT
AMENDED RECORD OF DECISION
TABLE OF CONTENTS
DECLARATION 1
DECISION SUMMARY
Introduction 4
Site History 5
Scope and Role of Operable Unit Remedial Action 8
Summary of Site Characteristics 9
Comparison with the Nine CERCLA Evaluation Criteria 15
Descripiton of the Selected Remedy 20
Statutory Determinations 28
List of Figures
Figure 1 Site Location Map
Figure 2 Lead Impacted Areas and Locations
of Stockpiles and Blocks
Figure 3 East Doane Lake Wetland Areas
Figure 4 Conceptual Liner and Cap Detail
Figure 5 Soils Operable Unit Remedial Action Area
Figure 6 Conceptual On-Site Containment Facility
Tables
Table '1 Comparison of Site Quantities
Appendices
Appendix A: Responsiveness Summary
Appendix B: Letter of State Concurrence
Appendix C: Administrative Record Index
Appendix D: Summary of Design Requirements
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Declaration for the
Gould Superfund Site
Soils Operable Unit
Amended Record of Decision
Site.
Gould Superfund Site, Soils Operable Unit
Portland, Multnomah County, Oregon
Statement of Basis and Purpose
This decision document presents the selected amended remedial
action for the Soils Operable Unit at the Gould Superfund Site
(Site). This Record of Decision (ROD) Amendment has been
developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfunti Amendments and Reauthorization Act of
1986 (SARA), 42 U.S.C. Section 9601 et seq.. and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. The decision to amend
the ROD is based on the administrative record for the Gould Site,
which was updated April 25, 1997 to include additional-
information generated since the issuance of the ROD in 1988. The
documents added to the administrative record since March 1988 are
listed in Appendix C.
The State of Oregon concurs with the ROD Amendment.
Assessment of the Site
Actual or threatened releases of hazardous substances at the
Gould Site, if not addressed by implementing the selected remedy
documented in the ROD, as amended in this ROD Amendment, may
present an imminent and substantial threat to human health,
welfare, or the environment.
Description of the Amendment to the Remedy
This decision documents changes to several components of the
selected remedial action for the Gould Site Soils Operable Unit.
The ROD for this operable unit, signed on March 31, 1988,
required treatment of contaminated battery casings to remove and
recycle lead, and treatment of soil, sediment and matte to reduce
the mobility of lead. This ROD Amendment allows treated and
untreated contaminated material to be consolidated and contained
in an on-site containment facility (OCF) on the Gould property.
The major components of the selected remedy include:
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* Perform design studies to evaluate Site constraints and
design parameters for, at least, consolidation and
settlement, lateral and vertical support of the OCF,
dewatering sediments, and the hydrogeologic impact of
filling East Doane Lake remnant and the open excavation in
the Lake Area (previously referred to as the Phase III Area)
portion of the Rhone-Poulenc property;
* Construction of an OCF, which has a leachate collection
system and allows for implementation of future Rhone-Poulenc
cleanup actions, on the Gould property;
* Excavation and dewatering of East Doane Lake sediments
contaminated above specified cleanup levels;
* Excavation of the remaining battery casings on the Gould
property;
* Treatment (stabilization or fixation) of the lead fines
stockpile (S-15), the screened Gould excavation stockpile
(S-22); and other lead contaminated material identified as
principal threat waste;
* Consolidating contaminated material, including sediments,
treated and untreated stockpiled materials, casings, soil
and debris in the lined and capped OCF;
* Filling the East Doane Lake remnant and the open excavation
in the Lake Area of the Rhone-Poulenc property;
* Institutional controls, such as.deed restrictions or
environmental protection easements, which provide access to
EPA for the purpose of evaluating the effectiveness of the
remedial action, and which limit future use of properties
within the Site to (1) industrial operations or other uses
compatible with the protective level of cleanup achieved
after implementation of the selected remedial action, (2)
uses which do not damage the OCF cap and liner system or
cause releases of buried materials;
* Performing groundwater monitoring to ensure the
effectiveness of the cleanup and that contaminants were not
mobilized during its implementation; and
* Long-term operation and maintenance requirements and reviews
conducted no less often than every five (5) years to ensure
the remedy continues to provide adequate protection of human
health and the environment.
The selected remedy will also allow off-site disposal of
contaminated materials from the Gould site at regulated Subtitle
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D or Subtitle C disposal facilities. Off-site disposal may be
necessary because of the uncertainty associated with final site
quantities and design constraints. The selected remedy defers a
cleanup decision on subsurface waste materials located on the
Rhone-Poulenc and ESCO properties.
Declaration
Although this ROD Amendment changes several components of the
remedy selected in the ROD, the remedy as amended continues to be
protective of human health and the environment. The remedy as
amended complies with, Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action and is cost effective. The remedy as amended continues to
utilize permanent solutions to the extent practicable for this
site. Significant quantities of hazardous substances have
already been treated at this Site through partial implementation
of the ROD. Treatment of the highly contaminated materials and
treatment of materials classified as hazardous waste prior to
their off-site disposal will be required; thus this remedy
satisfies the statutory preference for treatment as a principal
element.
Because this remedy will result in hazardous substances remaining
on-site above health based levels, a review will be conducted
within five (5) years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection
of human health and the environment.
Chuck Clarke
Regional Administrator, Region 10
U.S. Environmental Protection Agency
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Decision Summary
for the Gould Site Soils Operable Unit
Amended Record of Decision
INTRODUCTION
Site Name, Location and Description
The Gould Superfund Site (Site) is located in northwest Portland,
Oregon near N.W. 61st Avenue in the Doane Lake industrial area
between N.W. St. Helens Road and N.W. Front Avenue. It includes
property owned by Gould Electronics (approximately 9.2 acres) and
portions of property owned by Rhone-Poulenc AG Company (Rhone-
Poulenc or RPAC) , Sennitzer Investment Corporation, ESCO
Corporation, and Burlington Northern Railroad Company.
The Site is also adjacent to property owned by RPAC which was
formerly used for the manufacture, formulation, and distribution
of pesticide products. RPAC is conducting a Remedial
Investigation and Feasibility Study of contamination associated
with their property under a Consent Order with the Oregon
Department of Environmental Quality (DEQ).
Lead and Support Agencies
The U.S. Environmental Protection Agency (EPA) is the lead agency
with the Oregon DEQ the support agency for the Gould Superfund
Site.
Statutory Citation for a Record of Decision (ROD) Amendment
Section 117(c) of CERCLA, 42 U.S.C. S9617(c), provides for
addressing and documenting changes to the selected remedy after
issuance of a ROD. This ROD Amendment documents the changes to
the remedy set forth in the ROD. Since fundamental changes ,are
being made to the remedy selected in the ROD, - public " >- - -
participation and documentation procedures specified in the NCP,
Section 300.435(c)(2)(ii) have been followed.
Date of ROD Signature
The ROD for the Gould Site Soils Operable Unit was signed March
31, 1988.
Need for the ROD Amendment
The remedial action selected in the ROD has been partially
completed. The need for this ROD Amendment arose during remedial
action as a result of technical concerns. EPA has since
determined that the remedy selected in the ROD is no longer
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appropriate for completing the cleanup based on operating
experience and conditions at the Site.
Administrative Record
This ROD Amendment will become part of the administrative record
for the Gould Site, as required by Section 300.823 (a) (2) of the
NCP, and will be available for public review at the information
repositories listed below:
US EPA
Hazardous Waste Records Center, 7th Floor
1200 Sixth Avenue
Seattle, Washington 98101
Multnomah County Library
Central Library
801 SW Tenth Ave
Portland, Oregon 97204
SITE HISTORY
The Gould Site was listed on the National Priorities List
(Superfund) in 1983 because of documented lead contamination. A
secondary lead smelting facility was constructed on the current
Gould property and began operations in 1949 under the ownership
of Morris P. Kirk and Sons. Facility operations consisted of
lead-acid battery recycling, lead smelting and refining, zinc
alloying and casting, cable sweating, and lead oxide production.
Discarded battery casings and other waste materials from the
operations were disposed on the Gould property and adjacent
properties. NL Industries purchased the property in 1971 and
sold it to Gould in 1979. The facility was closed in 1981 and by
the summer of 1982 most of the structures, facilities, and
equipment had been removed.
The location of the Gould property and adjacent properties is
shown on the attached Figure 1. A detailed description of the
Site, including pre-1988 history, past waste disposal activities,
Site characteristics, and enforcement history, is included in the
1988 ROD and administrative record.
Remedy Selected in the ROD
EPA signed a ROD in March, 1988 for the Soils Operable Unit of
the Gould site. The selected remedy included:
* Excavation of all of the battery casing fragments and matte
from the Gould property and adjacent properties where
casings have been identified;
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* 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 the battery casing components;
* 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-site
disposal of non-hazardous, non-recyclable components;
* Excavation, fixation/stabilization and on-site disposal of
the remaining soil, sediment, and matte;
* Soil capping and revegetation;
* Isolation of surface water runoff to East Doane Lake by site
regrading; and
* A monitoring program to determine changes in groundwater
contamination over time and to ensure that remediation does
not adversely impact air quality.
The selected alternative also included additional study of
surface and groundwater in the area to help determine whether
action needs to be taken to deal with the contamination beneath
the Site.
Post ROD Site History
On February 29, 1988, EPA sent Special Notice letters to Gould
and NL to negotiate remedial design/remedial action. On June 15,
1989, a Consent Decree to implement was entered into whereby NL
agreed to perform predesign studies which evaluated the remedy
selected in the ROD. The predesign studies, which included bench
scale, pilot scale, and field demonstration testing, were
completed in 1990. The studies evaluated several aspects of the
cleanup remedy, including the ability of a proposed process to
separate, clean and recycle the battery casing components.
Following the review of the Predesign Report (January, 1991) EPA
determined that the results met the criteria in the Record of
Decision and the Consent Decree.
NL Industries agreed to complete the detailed design plans and
specifications under a Consent Order with EPA. EPA approved the
remedial design on September 30, 1991.
Special Notice Letters were sent on July 23, 1991, to 21
companies requesting that they provide good faith offers to
undertake the cleanup of the site. EPA entered into a De Minimis
settlement with six of the companies who were smaller
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contributors to pollution at the Site. The U.S. District Court
for the District! of Oregon approved entry of the De Minimis
settlement in February, 1993. Negotiations between the other
companies and EPA did not result in a settlement.
EPA issued a Unilateral Administrative Order to seven Gould Site
potentially responsible parties (Gould Site PRPs) on January 22,
1992, which required them to implement the selected remedial
action at the Gould Superfund Site. The seven companies named
include past and present owners, past operators of the facility,
and major contributors of waste sent to the site. The Gould Site
PRPs have performed the directed remedial action.
Remedial Action under the ROD.
Excavation and treatment of contaminated surface soils, surface
piles of battery casings, buried battery casings, matte (smelter
waste), and other debris began in the summer of 1993. Excavated
battery casings were processed through a battery treatment plant
designed to separate materials (lead fines, metallic lead, clean
plastic, and clean ebonite) for recycling. Contaminated soil and
matte were stabilized and stored for backfill on the Site. Site
operations included perimeter air monitoring and monthly
groundwater monitoring at select wells on the Gould property.
In May, 1994, EPA, pursuant to the Unilateral Order, directed the
Gould Site PRPs to evaluate alternative remedial actions and
conduct test studies in order to improve efficiency and
reliability at the Site. After this, work on the battery
recycling process was limited to cleaning plastic for recycling
while stabilization of other waste materials continued.
The Gould Site PRPs prepared a focused feasibility study (FFS) in
response to the revised Unilateral Order. The FFS evaluated the
treatment process and other potential treatment alternatives,
including off-site disposal of waste materials. Following the
submittal of the FFS, EPA determined that additional information
and evaluation of organic contamination was necessary.
Most of the cleanup activity at the Gould site has been suspended
pending an EPA determination on changes to the remedy previously
selected in the ROD. Prior to suspension, an estimated 24,OOO
tons of contaminated battery casings were treated. Approximately
244 tons of plastic and 88 tons of coarse lead were recycled for
reuse off-site. An estimated 20,000 blocks (1 cubic yard (cy)
each) of stabilized material from contaminated soil, matte and
debris)were produced. Several hundred tons of debris have been
shipped off-site for disposal. The FFS estimated that 68,000 cy
of untreated contaminated materials remain on-site. Of this
amount, approximately 15,000 cy of contaminated material that has
already been excavated is stockpiled on-site. Figure 2 shows the
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lead impacted a_reas and locations of the stockpiles and
stabilized blocks.
SCOPE AND ROLE OP OPERABLE UNIT REMEDIAL ACTION
The ROD issued in 1988 was for the Soils Operable Unit of the
Gould Site. The Soils Operable Unit addresses lead contaminated
battery casings, soil, sediment, debris, and other smelter waste
at the Site. Lead contamination was the. principal threat
addressed in the ROD and is the primary contaminant of concern
addressed in this ROD Amendment. A comprehensive discussion of
the selected remedial action is included in the March 31, 1988
ROD.
The ROD stated that insufficient hydrogeologic information was
available to make a decision on the groundwater unit. In order
to gather additional information on groundwater contamination,
EPA sent CERCLA 104(e), 92 USC §9604, information request letters
to property owners in the Doane Lake area. After the ROD for the
Soils Operable Unit was issued several industries in the area
formed the Doane Lake Industrial Group (DLIG) and agreed to
undertake an hydrogeologic investigation under a Consent Order
with DEQ in 1990. A final report, Hydrogeologic Investigation of
the Doane Lake Area, was submitted to DEQ in 1991. DEQ
subsequently decided to focus on individual sites in the area
rather than continue to pursue area wide studies with the
industry group. The DLIG.report data indicated that Rhone-
Poulenc is a potential source of organic contamination in
groundwater. DEQ is currently providing oversight of a remedial
investigation and feasibility study, under an Order on Consent,
at the RPAC site, adjacent to the Gould Site.
Additional groundwater and surface water investigations have been
conducted as part of the remedial action and post-ROD
investigation of the Site. Recent data from sampling of ground-
water monitoring wells located on- and off-Site have not shown
significant lead contamination. However, EPA does not anticipate
making a determination on whether groundwater cleanup will be
required until construction activities implemented in accordance
with this ROD Amendment have been completed and groundwater
quality has been monitored and evaluated. Groundwater monitoring
will be conducted to determine the effectiveness of the lead-
contaminated soil cleanup and to ensure that no contaminants were
mobilized during implementation of the selected remedy.
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SPMMARY OP SITE CHARAOTERTSTTf-g
A detailed description of the nature and extent of Site
contamination is included in the administrative record for the
ROD. Since the ROD was issued, significant additional
information has been obtained regarding Site contamination.
Canonic Site Investigations
Canonie Environmental (Canonie) , contractor for the Gould Site
PRPs, performed a limited investigation of groundwater and soils
in 1993 to estimate the risk to site workers from exposure to
organic compounds and to identify potential production issues.
Classes of compounds detected that could present a health risk to
workers upon exposure included volatile organics, chlorinated
herbicides, dioxins and furans, and phenols. Individual
constituent concentrations in soil/fill and sediments were
generally less than 1 mg/kg (less than 0.175 ug/kg for 2,3,7,8-
TCDD). Based on a comparison of detected concentrations with
personnel exposure standards, the risk of exposure to workers was
estimated to be low. Canonie used a combination of engineering
controls, safe work practices, and personal protective equipment
to minimize worker exposure during remediation.
Canonie also determined that the organics in the excavated
material would not affect the ability of the battery waste
treatment plant to produce materials for recycle or the ability
of the stabilization plant to generate stable materials for on-
site disposal.
Canonie conducted additional site investigations in 1994 to
develop a better estimate of the quantities of the various waste
materials present at the site and delineate the extent of buried
casings and matte. There were discrepancies between quantities
of materials estimated in the ROD with those encountered during
cleanup. The investigation determined that quantities of battery
casings on the Gould property were significantly overestimated
(54,100 cy ROD estimate vs 9,700 cy revised estimate). A summary
of the ROD estimates and revised estimates is shown in Table l.
Table 1 also shows the estimated quantities that would be placed
in the OCF and quantities that would be left in place under the
ROD Amendment. Based on the revised estimates about 90 percent
of the casings on the Gould property have already been excavated
and treated.
Sampling and Analysis for Organic Constituents
Organic chemicals of concern have been encountered during a
number of investigations of the Gould Site and surrounding areas.
The source of the organic contamination at the Gould site is
believed to be the former Rhone-Poulenc facility that was located
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adjacent to the Gould Site. Because of the presence of organic
contamination i-n the Gould Site Soils Operable Unit, additional
site investigation has been conducted by the Gould Site PRPs and
Rhone-Poulenc.
The information regarding organic contamination in surface and
groundwater developed in earlier investigations (including the
1993 Canonic investigation) was reviewed and summarized in the
Review of Organics Data Collected at the Gould Superfund Site
(ENVIRON 1994) . Groundwater samples collected at the Site from
wells and temporary well points on Rhone-Poulenc property have
had the following types of organic compounds reported: phenols,
herbicides, dioxins, and furans. Organic compounds detected in
surface water samples from the open excavation on the Lake Area
portion of the Rhone-Poulenc property include 1,2-
dichlorobenzene; 2,4-D; 2,4,5-T; 2,4,5-TP (Silvex); xylenes;
dioxins and furans.
The highest concentrations of organics are associated with NAPLs,
which have been found at depth below the RPAC former
manufacturing plant property and the adjoining southwest corner
of the Gould property. There have also been indications that
NAPL may be present in the Lake Area (formerly referred to as the
RPAC Phase III area).
Additional information regarding organic chemicals in East Doane
Lake sediments, stockpiled material, and stabilized blocks was
collected and presented in the Amended Remedy Document (ENVIRON
1996). In general, the highest concentrations of organics in the
East Doane Lake sediments are in the shallow zone (upper 2 ft) .
The shallow sediments also contain lead levels that exceed the
RCRA hazardous waste characteristic of EP toxicity, the cleanup
level set in the ROD. The levels of organics reported do not
appear to have had a significant adverse impact on lead
stabilization.
Surface water from the East Doane Lake remnant was sampled in
July 1995 by the Gould Site PRP Group. Chemicals detected in the
water sample included metals (cadmium, chromium, lead, and zinc);
petroleum hydrocarbons; herbicides (2,4-D, 2,4,5-T, and 2,4,5-
TP); and furans.
Rhone-Poulenc Investigation
Rhone-Poulenc is conducting a Remedial Investigation/Feasibility
Study (RI/FS) of soils and groundwater contamination. The RPAC
RI/FS is investigating contamination of a large area which
includes properties within the Gould Site. The RPAC RI/FS is
being conducted under a Consent Order with DEQ pursuant to State
authority. A substantial portion of the area to be remediated
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for lead under the 1988 ROD is located in the Lake Area portion
of the Rhone-Pou-lenc property.
Sediment Sampling and Investigation
Sediment samples in the East Doane Lake remnant were collected in
1994 at 16 locations. The samples were analyzed for total and
leachable lead to estimate the volume of sediment to be
remediated for lead. Additional samples were collected in 1995
at the same locations and were analyzed for organic constituents,
including organochlorine insecticides, PCBs, and dioxins and
furans. The frequency of detections and concentrations of
organic compounds generally decreased with depth.
RPAC is conducting an evaluation of organic contamination in East
Doane Lake sediments. Because the 1.5 to 2.0 feet of sediment
fails RCRA EP Toxicity criteria for lead, the RPAC evaluation
assumes those sediments will be removed and placed in the OCF as
part of the remedial action under the Gould Site Amended ROD.
The RPAC evaluation is being conducted as an Interim Remedial
Measure under the RPAC RI/FS Consent Order. Results from this
evaluation should be available prior to completing the final
design of the remedy in this ROD Amendment. The RPAC evaluation
will assess the impacts of organic contamination in the sediments
on downgradient current and reasonably likely beneficial use of
groundwater. If remedial action for the sediments below the
anticipated 1.5 to 2.0 foot excavation depth under the Gould Site
Amended ROD is deemed warranted by DEQ, the work will be
conducted as a time-critical action under State authority. EPA
and DEQ intend that additional excavation would occur during the
Gould Site excavation to avoid unnecessary delay in the
implementation of the amended remedy at the Gould Site. EPA and
DEQ will consider allowing disposal of additional sediments in
the OCF.
Amended Remedy Document
The Gould Site PRPs submitted a proposed alternative cleanup plan
to EPA in October 1995. The proposed alternative which the PRPs
submitted for EPA consideration was included in the Amended
.Remedy Document (ARD) .
The proposed remedy called for consolidating the stockpiled
contaminated soil, debris, and stabilized blocks within the area
of contamination, and placing them in an OCF that includes a
leachate collection system. The Gould Site PRPs proposed that
the OCF be located on Gould property. The proposal also required
that the East Doane Lake remnant be dredged and filled with clean
fill, and that the excavated sediments be dewatered before
placement in the OCF.
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The proposal included a conceptual design of the OCF. EPA and
DEQ identified several issues related to the proposal, including
those listed below.
l) The design needs to provide for adequate control of water
during the filling of the East Doane Lake remnant, and monitoring
and control of potential impacts from displacement of
contaminants in East Doane Lake water and sediments.
2) The OCF must be designed to accommodate implementation of
future RPAC groundwater cleanup actions. This may reduce the area
on the Gould property available for the OCF.
3) The OCF must be designed to provide control of stormwater
runoff and leachate.
Wetlands Investigation and Evaluation
An evaluation of the potential impacts associated with the
proposed dredging and filling of the East Doane Lake remnant was
performed by the Gould Site PRPs. The report, entitled the
Wetlands Investigation of East Doane Lake (Woodward Clyde, April
1996), classified East Doane Lake as non-wetland "open water"
which has a well-defined bank and ordinary high water mark. A
total of only 0.04 acre (1670 square feet) was considered
wetlands. Wetland areas identified in the 1996 study are shown
in Figure 3.
The East Doane Lake remnant is approximately 3.1 acres in size
and located on the Gould and Schnitzer properties. It is the ,
remnant of a larger water body that has been gradually filled as
a result of industrial development and waste disposal activities,
which includes the disposal of smelter and battery waste
generated by the former operations on the Gould property.
EPA has reviewed the proposed action for compliance with the
requirements of the Clean Water Act Section 404(b)(1) Guidelines.
The Guidelines provide flexibility to adjust the stringency of
the review for projects that would have only minor impacts.
Minor impacts are associated with activities that generally would
have little potential to degrade the aquatic environment and
include projects that are located in aquatic resources of limited
natural function and projects that are small in size and have
little direct impact.
The East Doane Lake remnant is already impacted by existing
chemical contamination, and is considered an aquatic resource of
very limited natural function. Significant adverse impacts to
the aquatic environment are already occurring at the site. East
Doane Lake has been used for industrial waste discharge from the
lead smelting facility formerly located on the Gould property, an
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acetylene gas production facility formerly located on the
Schnitzer site, "and the herbicide production facility formerly
located on the Rhone-Poulenc site. Remediation of the
contaminated portions of the Gould Site Soils Operable Unit are
expected to reduce or eliminate exposure to contaminated
sediments and possible uptake of contaminants from the sediments
into' the aquatic environment.
The dredging of East Doane Lake was a component of the original
remedy and is anticipated to have minor adverse impacts because
of the limited and degraded nature of the aquatic ecosystem and
organisms. Filling of East Doane Lake remnant with clean
imported fill will eliminate the East Doane Lake aquatic
ecosystem. Existing biological communities in the East Doane
Lake remnant are considered to be degraded due to physical and
chemical intrusions.
EPA has concluded that the 1988 ROD remedy is not a practicable
alternative for completing the cleanup of the Gould site. Other
alternatives evaluated in the 1994 PFS included: on-site
stabilization with a combination of on-site and off-site
disposal, on-site stabilization with on-site disposal of all
stabilized material, on-site stabilization with off-site
disposal, and off-site stabilization with off-site disposal.
The on-site disposal options included filling portions of the
East Doane Lake remnant and/or constructing a disposal facility
that would preclude reasonable future use of the property. Off-
site disposal may be a viable option that could require
additional treatment of significant quantities of the waste for
organic constituents in addition to treatment for lead to meet
RCRA land disposal restrictions. The alternatives were not
considered to have significantly less impact on the aquatic
ecosystem or the environment as compared to the proposed remedy
to offset the increased costs and loss of reasonable future use
of the property. Off-site disposal of some site materials would
be allowed as a component of the proposed amended remedy.
EPA has further determined there is a greater net environmental
benefit to be gained from protecting and/or enhancing a nearby
off-site area with more suitable habitat potential than by
selecting a remedial- action that would protect an unsuitable
habitat.
A mitigation/restoration plan will be required to compensate for
the loss of the wetlands and open water habitat as part of the
remedial action.
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Proposed Plan
EPA issued a proposed plan for public comment chat described
EPA's preferred alternative for completing the cleanup of the
Soils Operable Unit on April 1, 1996. The proposed alternative
in the plan was based on the PRP proposal described in the ARD.
The thirty day comment period on the plan was extended an
additional thirty days at the request of one commentor.
Reasons for Issuing ROD Amendment
l) The battery casings treatment process is not an efficient or
cost effective method of completing the site cleanup.
For several months the battery plant separated and treated
contaminated casings excavated from the Site. However, this
process was limited by operating problems. It was difficult to
process the highly variable waste feed and produce consistent
results in spite of making numerous modifications to improve the
process. Battery casing fragments from the RPAC and ESCO
properties are mixed with wood chips and other porous material
that could not be cleaned effectively or separated from the
ebonite and plastic. As a result, both the plastic and ebonite
output from the plant often failed the EP Toxicity and TCLP tests
for lead and had to be reprocessed. A detailed description of
the operation of the battery plant is included in the FFS.
Estimated costs to complete the project using the battery
processing plant increased substantially since the start of
cleanup. The cost of the cleanup was estimated at the end of
remedial design to be approximately $20 million. Revised
estimates based on operating experience and updated information
on waste quantities and characteristics were $40 to $56 million.
2) Only limited quantities of processed materials were
recyclable, and most of the remaining waste is not recyclable
The battery plant produced coarse metallic lead (88 tons) and
plastic (255 tons) products for recycle. The ebonite and lead
fines products have not been recycled. Most of the remaining
battery casings on the Site are located on the RPAC property, and
significant quantities of coarse lead have not been recovered
from this area. Most of the remaining untreated casing fragments
on the Site are composed of ebonite. There is essentially no
demand for the ebonite product and the ebonite treated to date is
stockpiled on the Site. The lead fines product was much lower in
concentration than was anticipated, and was not recyclable. The
lead fines are also stockpiled on the Site.
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3) Volume and nature of waste materials were different from Rl
estimates.
The results of additional investigation show that, the amount of
battery casings on the Gould property was overestimated in the
ROD, and that most of the remaining subsurface material on the
Gould property is matte, slag and debris (see Table 1) . Post-ROD
investigation and monitoring also indicate that stabilization to
reduce the mobility of this material will be of questionable
benefit because there is little evidence that lead associated
with the subsurface matte material is mobile or has had a
significant impact on area groundwater. There is also evidence
that lead contaminated material is also contaminated with
organics (presumably from the former RPAC facility).
4) Cleanup activities need to be coordinated with the RPAC
RI/FS.
Approximately 10,215 cubic yards of casings have been excavated
and treated from the Lake Area of the RPAC property portion of
the Gould Site. The remaining casings, an estimated 17,500 cubic
yards, are beneath several feet of other fill material and
generally below the water table. Further subsurface excavation
in these areas may adversely affect the migration of RPAC organic
contaminants. RPAC is currently investigating this area under the
Consent Order with the DEQ. DEQ and EPA agree that the remaining
battery casings in the Lake Area should not be excavated until
completion of the RPAC RI/FS. EPA will coordinate future cleanup
determinations and remedial actions located on this portion of
the Site with DEQ.
COMPARISON WITH THE NINE CERCIA EVALUATION CRITERIA
The proposed amended remedy includes excavation of the remaining
battery casings on the Gould and Schnitzer properties portions,
dredging and de-watering lead-contaminated sediments from East
Doane Lake; containment of sediments, stockpiled materials
(including previously treated materials) , shallow soils, and
debris in a lined and capped OCF located on the Gould property.
The proposed OCF would cover most of the Gould property,
approximately 8.5 acres, including the area now within East Doane
Lake.
The NCP establishes nine criteria for evaluating remedial action
alternatives. A discussion of the original remedy and amended
remedy relative to the nine criteria is required by CERCLA. This
section discusses the proposed changes to the existing remedy.
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Overall protection of human health and the environment.
This criterion addresses whether a remedial alternative protects
human health and the environment. Protection is determined by
assessing whether the risks associated with each exposure pathway
(i.e., ingestion of soil, ingestion of groundwater) are
eliminated, reduced, or controlled through treatment and
engineering or institutional controls.
The potential critical pathways for lead identified in the
endangerment assessment portion of the ROD were airborne exposure
from on-site fugitive dust emissions, incidental oral ingestion
of contaminated battery casings, matte and soil, and dermal
contact and incidental ingestion of lead from surface water in
the East Doane Lake remnant. The remedy in the ROD relied on
treatment and recycling to reduce exposures. Contaminated
material treated by stabilization would be backfilled on the
Site.
The ROD Amendment still addresses lead as the primary contaminant
of concern and provides additional protection for organic
chemicals that are commingled with waste materials to be placed
in the OCF. Routes of potential exposure to the materials placed
in the OCF are eliminated by the liner and cap. The OCF will
have a leachate collection system which will further protect
groundwater quality.
Subsurface battery casings located on the RPAC and ESCO
properties will not be excavated pursuant to this Amended ROD.
The subsurface casings are located beneath several feet of other
fill material and generally below the water table. The primary
exposure pathway associated with the subsurface battery casing
materials on this portion of the Site is groundwater, and there
are concerns that continued excavation (especially in the
southern portion of the Lake Area) could adversely affect the
migration of organic contamination that is currently being
characterized as part of the RPAC RI/FS.
Air monitoring conducted at the Site during past excavation has
not detected levels of airborne contamination that constitute an
unacceptable risk to human health and the environment.
Compliance with ARARs. The selected remedial action must comply
with identified substantive applicable requirements under federal
and state laws. The selected remedial action must also comply
with laws and regulations that are not directly applicable but do
pertain to situations sufficiently similar to those encountered
at the Site, so that use of the requirements is well suited to
the Site cleanup. These are known as relevant and appropriate
requirements. Evaluation of remedial alternatives with chemical-
location-, and action-specific ARARs is necessary for determining
compliance.
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Both the ROD alternative and ROD Amendment alternative comply
with ARARs. The ROD Amendment alternative will comply with
federal and state ARARs by providing specific design and
operating conditions that are developed to comply with specific
requirements of these ARARs.
Long-term effectiveness and permanence. This criterion
evaluates the ability of a remedial alternative to maintain
reliable protection of human health and the environment once
remediation goals have been achieved. The magnitude of the
residual risk is considered as well as the adequacy and
reliability of controls.
The ROD relied on treatment of lead contaminated materials to
address health and environmental hazards. It was anticipated
that removal and successful separation of the battery casing
fragments would substantially reduce sources of pollution at the
Site, and contamination in all media would decrease. Residual
risk remaining after remediation would have been primarily posed
by unremediated surface soils, groundwater and surface water.
The ROD also assumed that backfilling the treated material on the
Site without additional containment would be an effective long-
term solution.
Under the ROD Amendment, the OCF will be designed, constructed,
and monitored to ensure long-term effectiveness and permanence.
Direct contact will be eliminated because the wastes will have
been contained and/or capped, and the risk of leaching to ground
water will be greatly reduced by the liner and leachate
collection system. The liner and cap system will provide greater
protection from organic contamination that is commingled with the
lead contaminated waste than the remedy in the ROD. Further,
containment of the contaminated wastes in the OCF reduces the
potential for exposure to lead contamination from treated
materials that could be affected by weathering or other factors
if backfilled directly on the Site.
Long-term effectiveness under the ROD and the ROD Amendment is
also dependent on assuming future land use is limited to approved
industrial or other appropriate activities.
Reduction of toxicity, mobility or volume through treatment.
This criterion addresses the statutory preference for selecting
remedial actions that use treatment technologies that permanently
reduce the toxicity, mobility or volume of the hazardous
substances.
The treatment required in the original ROD remedy included waste
separation and recycling of lead, plastic, and ebonite, and
stabilization to reduce the mobility of lead. Stabilization
reduces mobility but does not reduce the toxicity or volume of
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waste material. Significant quantities of lead contaminated
material have Been treated as part of the remedial action that
was partially implemented at the site. Approximately 20,000
cubic yards of waste have been stabilized to inhibit the
migration of lead. A substantial portion of the principal threat
lead waste has already been treated.
The ROD Amendment uses a combination of treatment and containment
to reduce the mobility of lead. Lead remaining in the various
waste materials does not appear to be highly mobile in
groundwater. The aboveground, lined and capped OCF minimizes the
low level threat of lead associated with potential leaching to
groundwater. In addition, the threat of potential direct contact
is limited by the containment and capping. Principal threat
waste material will be treated prior to placement in the OCF to
limit the potential release of the highly contaminated material
in the unlikely event of a release from OCF.
Short-term effectiveness. This criterion refers to the period of
time needed to achieve protection, and any adverse impacts on
human health and the environment, specifically site workers and
community residents, that may be posed during the construction
and implementation period until cleanup goals are achieved.
Short term impacts for the amended remedy are similar to those
identified in the remedy under the ROD. The potential short term
community risk is inhalation of airborne dust during movement of
the impacted materials. Site ambient air monitoring conducted
during excavation and treatment activities indicates airborne
contaminant concentrations of concern can be controlled to
prevent levels that pose unacceptable risk. Typical personal
protective measures will be taken to protect workers from
airborne and dermal contact with contaminants.
Short term impacts associated with the dredging of East, Doane
Lake remnant, including increased concentrations of dissolved and
suspended contaminants, were identified in the original remedy.
The filling of the East Doane Lake remnant must occur at a rate
that allows for gradual dissipation of displaced water. In
addition, the use of temporary plastic covers for waste placed in
the OCF will minimize potential exposures prior to final capping.
Implementability. This criterion refers to the technical and
administrative feasibility of a remedial alternative, including
the availability of goods and services needed to implement the
selected remedy.
The treatment and recycle remedy selected in the ROD was
partially implemented at the Gould site. Implementation of the
remedy was difficult and cost estimates for completing the remedy
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increased substantially. Although some phases of the cleanup
were successful," continued operation of the treatment process was
not a practical alternative for completion of the Gould site
remedial action.
The excavation and construction of the OCF can be implemented
using established engineering and construction techniques. A
detailed design phase will be required, however, to ensure that
construction and operation of the OCF will be adequately
protective. The design will include special considerations for
dredging and filling of the East Doane Lake remnant and handling
of site materials. The services and materials to be utilized are
readily available (e.g., import of fill materials, construction
of liners, and placement of an asphalt cap) .
Cost. Evaluation of project costs requires an estimation of the
net present value of capital costs and O&M costs. The costs
presented below (and in the 1996 ARD) are estimates. Actual
costs could vary based on the final design and detailed cost
itemization.
The total cost associated with the original remedy as estimated
in the ROD was approximately $20.5 million, including capital
cost of about $3.5 million and O&M cost of about $17 million
(present worth) . The estimated construction cost to date was
estimated in the ARD at approximately $16.5 to $20.7 million,
depending on adjustments for plant equipment amortization and
contractor retentions. The cost associated with completing the
remedy, with some modifications to optimize some process
operations, was estimated at approximately $40.8 million.
The total estimated cost associated with the ROD Amendment remedy
was estimated in the ARD at $10.5 million, including capital cost
of about $10.1 million and O&M cost of about $400,000 (present
worth) . Additional costs associated with treatment and East
Doane Lake mitigation could increase the capital cost an
estimated $1.5 to $2 million.
State acceptance. DEQ has been actively involved with the
development and review of the ARD, the Proposed Plan, and this
ROD Amendment. The State of Oregon concurred with the 1988
selected remedy and concurs with this ROD Amendment. A letter of
concurrence is included as Appendix B.
Community acceptance. The Proposed Plan was released to the
public on March 31, 1996. EPA provided a thirty day public
comment period to accept comments on the proposed amendment. A
notice of availability of the Proposed Plan and the
administrative record was published in the Oregonian on March 28,
1996. The comment period began on April 1, 1996 and was extended
an additional thirty days at the request of one comtnentor. EPA
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received one letter with several comments during the extended
public comment period for this ROD Amendment. The Responsiveness
Summary provides EPA responses to the specific comments.
DESCRIPTION OF THE SELECTED REMEDY
Based upon a consideration of the requirements of CERCLA, the
comparative analysis of alternatives, and consideration of public
comments, both EPA and DEQ have determined that the proposed
amended remedy is the most appropriate remedy for completing the
cleanup of the Gould Site Soils Operable Unit.
The major components of the selected remedy include:
* Perform design studies to evaluate site constraints and
design parameters, including the following: consolidation
and settlement, lateral and Vertical support, dewatering
sediments, stormwater runoff and control, leachate
collection, treatment and disposal, and hydrogeologic impact
of filling East Doane Lake remnant and the open excavation
(also known as the Lake Area or Phase III Area) portion of
the Rhone-Poulenc property;
* Construction of an OCF on the Gould property, which has a
leachate collection system and allows for implementation of
future Rhone-Poulenc .cleanup actions;
* Treatment (stabilization or fixation) of the lead fines
stockpile (S-15) and the screened Gould excavation stockpile
(S-22), and other lead contaminated material identified as
principal threat waste;
* Excavation and dewatering of EDLR sediments contaminated
above specified cleanup levels;
* Excavation of the remaining battery casings on the Gould
property;
* Consolidating contaminated material, including sediments,
treated and untreated stockpiled materials, casings, soil
and debris in the lined and capped OCF;
* Filling the East Doane Lake remnant and the open excavation
on the Lake Area portion of the Rhone-Poulenc property with
clean fill material;
* Mitigation/restoration to compensate for the loss of East
Doane Lake wetland and open water habitat. A proposal
identifying work to be performed, including at least one
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off-site mitigation proposal, shall be submitted with the
final design report;
* Institutional controls, such as deed restrictions or
environmental protection easements, which provide access to
EPA for the purpose of evaluating the effectiveness of the
remedial action, and which limit future use of properties
within the Site to (1) industrial operations or other uses
compatible with the protective level of cleanup achieved
after implementation of the selected remedial action, (2)
uses which do not damage the OCF cap and liner system or
cause releases of buried materials;
* Performing groundwater monitoring to ensure the
effectiveness of the cleanup and that contaminants were not
mobilized during its implementation; and
* Long-term operation and maintenance, including but not
limited to, cap maintenance, leachate collection and
treatment, stormwater runoff control, and reviews conducted
no less often than every five (5) years to ensure the remedy
continues to provide adequate protection of human health and
the environment.
Design requirements described elsewhere in this document are also
considered part of the selected remedy. A summary of design
requirements referenced in this document is attached in Appendix
D.
The selected remedy will also allow off-site disposal of
contaminated materials from the Gould site at regulated Subtitle
D or Subtitle C disposal facilities. Off-site disposal may be
necessary because of the uncertainty associated with final site
quantities and design constraints. The selected remedy defers a
cleanup decision on subsurface waste materials located on the
Rhone-Poulenc and ESCO properties.
Comparison of ROD with the ROD Amendment
The following lists each of the elements from the existing ROD,
followed by a brief description of the actions that have been
completed or partially completed to date, and a comparison with
the corresponding element in the ROD Amendment.
* ROD - Excavation of all of the battery casing fragments and
matte from the Gould property and adjacent properties where
casings have been identified;
Status - Partially completed. An estimated 24,500 tons of
battery casings have been excavated and treated as part of
the remedial action under the ROD. This represents about
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56% of the estimated total. Approximately 18,500 tons of
battery ca~sings remain; 900 tons on the Gould property and
17,500 tons on the Rhone-Poulenc and ESCO properties.
ROD Amendment - Excavation of remaining battery casing
fragments (900 tons) from the Gould property. Excavation of
remaining matte from the Gould property located above the
water table only. The decision on whether to excavate the
17,500 tons of casing fragments on the Rhone-Poulenc/ESCO
properties will be deferred until completion of the Rhone-
Poulenc RI/FS. As previously described, the casings on the
Rhone-Poulenc/ESCO properties are located beneath several
feet of fill.
ROD - 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;
Status - Completed
EQD - Separation of the battery casing components;
status - Partially completed (see quantity estimates above).
ROD Amendment - consolidate remaining battery casings from
the Gould property in the OCF.
ROD - 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-site disposal of non-hazardous, non-recyclable
components;
Status - Recycling of components that can be recycled has
been completed. The following components were recovered
from the battery treatment process: 1) coarse lead, 2) fine
lead, 3) plastic battery casing fragments, and 4) ebonite
battery casing fragments. The coarse lead (88 tons) and
plastic battery casing fragments (244 tons) were recycled.
There was no market for the treated ebonite battery casing
fragments. An estimated 7,500 tons is stockpiled on-site.
The fine lead product was lower in concentration than
anticipated for recycling (8 to 12% actual vs 40% design) .
An estimated 2,600 tons of lead fines is stockpiled on-site.
ROD Amendment - Further recycling is not an objective of
the ROD Amendment.
ROD - Excavation, fixation/stabilization and on-site
disposal of the remaining soil, sediment, and matte;
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Status - An estimated 20,000 blocks (approximately one cubic
yard each) -of stabilized soil, matte and debris have been
produced and stockpiled on-site. An estimated 22,400 cy of
matte, slag and debris remains on the Gould site and 18,300
cy of contaminated overburden, fill and subsoils remain on
the Rhone-Poulenc/ESCO properties.
ROD Amendment; - Stabilized blocks and other contaminated
material, including sediments, soil and matte located above
the water table on the Gould property, will be consolidated
in the OCF. Waste material greater than 40,000 mg/kg lead
will be treated by stabilization or fixation prior to
placement in the OCF. Surface soil contaminated above the
1000 mg/kg lead cleanup level on the Rhone - Poulenc and ESCO
properties will be consolidated in the OCF. The other
contaminated material located on the Lake Area portion of
the Rhone-Poulenc property and the ESCO property will be
addressed as described below.
* ROD - Soil capping and revegetation;
Statug - excavated areas have not been capped
ROD Amendment: - The OCF will be located on the Gould
property and will have a multi-media cap covered by asphalt.
EPA has determined, in consultation with DEQ, that a final
decision on the need for a soil cap or other remediation of
lead contamination in the Lake Area portion of the Rhone-
Poulenc property and the ESCO property should be deferred
until after the following actions have been completed: 1)
removal of treated and untreated Gould Site waste material
currently stockpiled on the Rhone-Poulenc property, 2)
surface soil removal and confirmation sampling, and 3)
completion of a risk assessment for organic contamination in
soil in the Lake Area.
* ROD - Isolation of surface water runoff to East Doane Lake
by site regrading;
Status - Not completed
ROD Amendment; - After completing the removal of lead
contaminated sediments, the East Doane Lake remnant will be
filled with clean fill. Surface water runoff from the OCF
will be collected for discharge via storm drains.
* ROD - A monitoring program to determine changes in
groundwater contamination over time and to ensure that
remediation does not adversely impact air quality.
Status - Ongoing
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ROD Amendment - Air and groundwater monitoring will be
conducted "as part of the remedy.
Description of Changes to the Remedy
Several elements of the amended remedy are fundamental changes
from the remedy described in the ROD. The major changes to the
remedy are described below:
1) The contaminated materials that are stockpiled on-site and
additional contaminated material to be excavated will not be
treated in the battery treatment/recycle plant. The
treatment/recycle plant has been decontaminated and disassembled.
Instead, these contaminated materials will be consolidated, after
treatment by stabilization or fixation of principle threat
material (contaminated material above 40,000 mg/kg lead), in an
OCF which will be constructed on the Gould property. The OCF
will provide additional protection from organic contamination
that is commingled with lead waste by eliminating pathways of
exposure. The OCF will be designed to meet minimum technology
requirements for RCRA Subtitle C landfills, including liners,
leachate collection, and a cap. The RCRA Subtitle C cap will
reduce direct contact/ingestion threat, air emissions and
infiltration of water through the waste material. The liner will
provide additional protection against leaching and as a barrier
which further protects groundwater.
2) The lead fines stockpile (S-15) will not be recycled but will
be treated by stabilization or fixation to meet RCRA land
disposal restriction treatment standards and reduce the leaching
potential of this material. The lead fines will be placed in the
OCF after treatment. In addition, the screened excavation
stockpile (S-22), which is considered principal threat material
because of the high level of lead contamination (55,000 ppm
lead) , will be treated prior to placement in the OCF. Because
the liners and cap provided with the OCF are as protective as
treatment for non-principal threat lead waste, lower levels of
lead contaminated material will not be treated.
3) Excavation of matte (a smelter waste material that was
deposited on the Gould property) will be limited to material
above the water table. Excavation of subsurface matte and debris
below the water table will not be required under the ROD
Amendment. Groundwater monitoring will be conducted to ensure
that these remaining materials below the water table are not
impacting groundwater.
4) Excavation of subsurface soil and the remaining battery
casings on the Rhone-Poulenc and ESCO property portions of the
Site will not be included in the remedy at this time. EPA will
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reassess the need for further remedial action for subsurface
soils and other'waste materials after the stockpiled materials
currently located on the property have been moved to the OCF and
a risk assessment for the organic constituents has been completed
as part of the Rhone- Poulenc RI/FS. EPA may, later, determine
that disposal of subsurface materials or other waste materials
from the Rhone-Poulenc and ESCO properties in the OCF is
appropriate.
5) The East Doane Lake remnant will be filled to provide
additional surface area for construction of the OCF, and to
eliminate surface water pathways of exposure in this area.
The selected remedy includes excavation of the remaining battery
casings on the Gould and Schnitzer property portions of the Site,
dredging and de-watering of lead-contaminated sediments from the
East Doane Lake remnant (EDLR); containment of sediments,
stockpiled materials, including previously treated materials,
shallow soils, and debris in a lined and capped on-site
containment facility to be located on the Gould property. The
proposed OCF will cover approximately 8.5 acres, most of the
Gould property, including the area now within the EDLR.
Potential future industrial uses of the Gould property will be
considered in the design of the facility to the extent..
practicable.
When completed, the OCF is expected to contain approximately
60,000 cy of contaminated waste material, sediment, soil, and
debris. The OCF will have a total thickness of approximately
eight feet, including bottom liner, waste and impacted soil, cap
system, and asphalt surface. A cross section of the proposed
containment facility showing conceptual liner and cap details is
presented in Figure 4. Final design of the containment facility
will be subject to approval by EPA.
Ambient air monitoring around the site will continue during
construction to ensure that remedial actions are carried out in a
manner that is protective of public health. Monitoring of
groundwater at the site will be conducted as part the closure and
O & M requirements for the OCF and to ensure that the proposed
remedy remains protective of area groundwater. Long term 0 & M
will include cap maintenance, leachate collection and treatment,
stormwater runoff control, institutional controls and reviews
conducted no less often than every five (5) years to ensure the
remedy continues to provide adequate protection of human health
and the environment.
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Cleanup Goals
The remediation goals in the original ROD are being retained with
some exceptions. The goals for the various media are described
below:
* The surface soil cleanup level for lead is 1,000 ppm, the
cleanup level established in the ROD.
* The subsurface cleanup level for lead was the RCRA
characteristic waste EP toxicity criteria. For newly
generated waste, this test has been replaced by the TCLP
criteria since the ROD was signed. EPA will allow use of
the EP Toxicity criteria for materials that remain on-site
to avoid having to retest material already characterized
under the ROD. .
* Not all subsurface soils and contaminated material that
exceed EP Toxicity criteria will be removed under the ROD
Amendment. EPA has determined that the buried matte
material on the Gould property does not pose a significant
risk for contamination of groundwater based on supplemental
analysis, including additional leaching test information,
conducted on this material. EPA will reassess the need for
remedial action for subsurface soils and other waste
materials in the Lake Area portion of the Rhone-Poulenc
property after the stockpiled materials currently located on
the property have been moved to the OCF and a risk
assessment for the Rhone-Poulenc constituents has been
completed.
* Treatment and recycle of battery casings will no longer be
an objective of this remedial action.
Remedial Action Performance Standards
The Soils Operable Unit remedial action area is shown in
Figure 5. The Soils Operable Unit remedial action shall be
completed subject to the following standards of performance:
A. Within the Operable Unit remedial action areas, all
surface soil with lead concentrations of 1,000 ppm or
above shall be excavated and placed in the on-site
containment facility. There are no specific ARARs for
lead in industrial soil; however, a surface soil
cleanup level of 1,000 ppm was established in the ROD.
EPA set the lead cleanup level at 1,000 ppm for surface
soil based on current and future industrial land use.
The 1,000 ppm cleanup level is sufficiently protective
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for on-site workers, and has been used in the past for
similarly contaminated sites where the expected future
land use is industrial. This is consistent with the
present and anticipated future land use.
B. Contaminated waste shipped off-site must meet all
applicable regulations including RCRA requirements for
defining, characterizing and listing hazardous waste
(40 CFR 261), land disposal restrictions (40 CFR 268)
and EPA's Off-Site Disposal Rule (40 CFR 300.440). Any
off-site transportation of RCRA characteristic soil
must comply with RCRA hazardous waste manifesting and
transporter requirements (40 CFR 262 subpart B and 40
CFR 263), the Department of Transportation Hazardous
Materials Regulations which address shipment of any
hazardous material off-site, and Oregon Administrative
Rules (OAR Chapter 340, Division 101-105) .
C. On-site excavation of contaminated soils and sediments
will be by conventional protective methods. During
these activities, air monitoring will be conducted and
dust suppressive measures will be utilized to control
the release of dust and particulates. These measures
will comply with the applicable federal Clean Air Act
requirements (40 CFR Part 50) and Oregon Administrative
Rules.
D. Occupational Safety and Health Act (OSHA) requirements
(29 CFR Part 1910 and 1926) pertain to workers engaged
in response or other hazardous waste operations. Lead-
contaminated soil excavation is considered a hazardous
waste operation at this Site. Although this regulation
is not an ARAR, remedial workers must comply with these
OSHA requirements.
E. Dredging and filling of the East Doane Lake remnant is
subject to the requirements of Section 404 of the Clean
Water Act, and a mitigation/restoration plan will be
required.
F. The OCF will be constructed above the water table and
will be designed, constructed and operated to meet 40
CFR 264 Subpart N requirements for landfills,
including: 1) 264.301 design and operating requirements
for liners and leachate collection systems, 2) 264.303
monitoring and inspection requirements, 3) 264.310
closure and post-closure care requirements for covers
which minimize migration of liquids, function with
minimum maintenance, and provide long-term integrity.
40 CFR 264 Subpart G, Closure and Post-Closure
requirements are also relevant and appropriate
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requirements, specifically 1) 264.111 closure
performance standard, 2) 264.114
disposal/decontamination requirements for soils,
equipment, and structures, and 3) 264.117 post-closure
care and use of property.
G. Stormwater runoff and leachate collected from the OCF
will be managed in accordance with requirements of the
Clean Water Act and Oregon Administrative Rules.
H. Groundwater monitoring will be required to ensure that
the remedy is protective of Site groundwater and
complies with RCRA closure and post-closure
requirements.
Assessment of Further Remedial Action for the Lake Area
EPA has determined, in consultation with DEQ, that a final
decision on the need for a soil cap or other remedial action for
subsurface lead contamination in the Lake Area should be deferred
until after the following actions have been completed: 1) removal
of treated and untreated Gould site waste material currently
stockpiled on the Rhone-Poulenc property, 2) removal of surface
soil contaminated above 1,000 mg/kg lead, 3) confirmation
sampling, and 4) completion of a risk assessment by Rhone-Poulenc
for organic contamination in the Lake Area.
STATUTORY DETERMINATIONS
EPA's primary responsibility at CERCLA sites is to undertake
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C.
§9621, establishes several other statutory requirements and
preferences including: (1) a requirement that the remedial action
complies with applicable or relevant and appropriate
environmental standards established under federal and state laws
unless a statutory waiver is invoked; (2) a requirement that the
remedial action be cost-effective and utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and, (3) a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous substances over remedies that do not achieve such
results through treatment.
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The selected remedial action meets the statutory requirements of
CERCLA, and, to the extent practicable, the NCP. The evaluation
criteria are discussed below.
Protection of Human Health and the Environment:
The amended operable unit remedial action is protective of human
health and the environment. It reduces risks associated with
lead contamination by excavating contaminated material, treating
highly contaminated material, and placing contaminated material
in the lined and capped on-Site containment facility.
While this remedial action will address contaminated soils above
levels protective of on-Site workers under a future industrial
land use scenario, lead will remain above residential health-
based levels thereby prohibiting unrestricted future land use.
Reviews will be conducted no less often than every five (5) years
following initiation of the remedial action to ensure adequate
protection of human health and the environment.
Compliance with Applicable or Relevant and Appropriate
Requirementsi
Pursuant to Section 121(d) of CERCLA, 42 U.S.C. §9621(d), and
Section 300.435(b)(2) of the NCP, remedial actions shall, during
their implementation and upon their completion, reach a level or
standard of control for such hazardous substances, pollutants or
contaminants which at least attains legally applicable or
relevant and appropriate federal standards, requirements,
criteria, or limitations, or any promulgated standards,
requirements, criteria, or limitations under a state
environmental or facility siting law that is more stringent than
any federal standard (ARARs).
The selected remedial action satisfies the requirements of this
section of CERCLA by complying with all identified ARARs. No
ARAR waivers have been sought or invoked for any component of the
selected remedial action. The chemical- and action-specific and
location-specific ARARs for the amended remedy at this Site
include the following:
RESOURCE CONSERVATION AND RECOVERY ACT 40 U.S.C. § 6901 et seq.
RCRA regulations (40 CFR 261-263 and 268) , and Oregon
Administrative Rules (OAR) 340-100-108, address the requirements
for defining, characterizing and listing hazardous wastes; for
generators pertaining to manifesting, transporting, and
recordkeeping; for transporters pertaining to shipment of
hazardous wastes off-site; and, land disposal restrictions.
29
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These regulations are applicable to the characterization and off-
site disposal o~f contaminated waste from the Site.
RCRA Regulations 40 CFR Part 264 address Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities. The construction of the OCF and consolidation of
contaminated material in the OCF will occur within the area of
contamination. The OCF is not considered a new unit. The
following are relevant and appropriate to the construction of the
OCF:
* 40 CFR 264.18(a) and (b) standards for seismic
considerations and floodplain design, construction,
operation and maintenance to prevent washout.
* Subpart F: Release From Solid Waste Management Units,
40 CFR 264.91 - 264.100 Groundwater monitoring requirements
to establish a detection monitoring program (264.98), a
compliance monitoring program (264.99) and corrective action
monitoring program (264.100). All monitoring requirements
must meet general groundwater monitoring requirements
(264.97).
* Subpart G: Closure and Post-closure,
40 CFR 264.111, Closure performance standard
40 CFR 264.114, Disposal and decontamination of equipment
and structures
40 CFR 264.117, Post-closure monitoring
40 CFR 264.119, Post-closure notices
* Subpart L: Waste Piles
40 CFR 264.251 Design and operating requirements
* Subpart N: Landfills
40 CFR 264.301 Design and operating requirements to install
two liners, a top liner that prevents waste migration into
the liner, and a bottom liner that prevents waste migration
through the liner. Install leachate collection systems
above and between the liners. Construct run-on and run-off
control systems capable of handling the peak discharge of
the 25-year storm.
40 CFR 264.303 Monitoring and inspection requirements
40 CFR 264.310 Closure and post-closure care - Installation
of final cover to provide long-term minimization of
infiltration; 30 year or longer post closure care and
monitoring requirements.
CLEAN AIR ACT 42 U.S.C. §§ 7401 et seq.
30
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40 CFR Part 50 National ambient air quality standards for lead
and particulate matter are applicable to the control of fugitive
dust emissions during excavation and other field activities.
CLEAN WATER ACT 33 U.S.C. §§ 1251 et seq.
Clean Water Act regulates direct discharges to surface water
(Section 301, technology based effluent limitations; 303, 304
federal water quality criteria), indirect discharges to publicly
owned treatment works (Section 307, pretreatment), and discharges
of dredge-and-fill materials into surface waters (including
wetlands) (Section 404).
CWA Section 301 Requirements for Technology Based Effluent
Limitations are applicable for direct discharges. Discharge
limits for the Gould site will be set to meet the Willamette
River water quality criteria for toxic pollutants (OAR 340-41-
445)
CWA 303 and 304 Requirements for Federal Water Quality Criteria
are substantive requirements that are relevant and appropriate
for control of leachate from the OCF.
CWA 307 Regulations for Toxic and Pretreatment standards.
Discharges to POTWs may be subject to specific local limits,
which are established in City of Portland Code, Section 17.
These requirements are applicable if leachate is discharged to
the City sewer system.
CWA Section 402 Requires dischargers of pollutants from any point
source into surface waters of the U.S. to meet certain
requirements and obtain a NPDES permit. On-site discharges from
a CERCLA site must meet the substantive NPDES requirements only.
40 CFR 122.26 describes requirements related to storm water
discharges.
40 CFR Part 125, Subpart A, describes Criteria and Standards for
Imposing Technology-based Treatment Requirements Under Sections
309(B) and 402 of the Act.
40 CFR Part 125 - Subpart K, Criteria and Standards for Best
Management Practices Authorized Under Section 304(e) of the Act
are applicable to control of releases of hazardous pollutants
into surface waters during cleanup.
CWA Section 404 and ORS 196.800 to 196.990 contain requirements
that pertain to dredging and filling of hydric soils and/or
wetlands areas. Substantive requirements are applicable to the
dredging and filling of the East Doane Lake remnant.
HAZARDOUS MATERIALS TRANSPORTATION ACT 49 U.S.C. Ap. §§ 1801 et
seq.
31
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49 CFR Parts 171-177 U.S. Dept. of Transportation-Subchapter C -
Hazardous Materials Regulations are applicable to any off-site
disposal of hazardous waste.
OTHER CRITERIA, GUIDANCE, AND STANDARDS TO BE CONSIDERED (TBCs)
The following guidance was also considered:
EPA's Revised Interim Soil Lead Guidance for CERCLA Sites
and RCRA Corrective Action Facilities (Office of Solid Waste
and Emergency Response [OSWER] Directive No. 9355.4-12; EPA
1994) establishes a residential "screening level" of 400
ppm, above which further study is warranted. A cleanup
level of 1,000 ppm has been selected for this Site since
this level is considered protective of on-Site workers, and
the property comprising the Site is zoned industrial.
In addition, the Occupational Safety and Health Act (29 CFR Parts
19010 and 1926) must be adhered to as it addresses safety
requirements for workers engaged in response or other hazardous
waste operations.
Cost-Effectiveness:
The cost-effectiveness of each alternative was evaluated,
including those which were screened out prior to the
alternatives assessment in the Amended Remedy Document. The
selected final operable unit remedial action is cost-effective as
it affords overall effectiveness and protectiveness proportional
to costs. Other remedial alternatives considered were found to
be generally more costly without affording additional
protectiveness commensurate with their cost.
Utilization of Permanent Solutions and Alternative*
Technologies or Resource Recovery Technologies to the
Extent Practicable;
EPA and DEQ have determined that the selected remedial action
represents the best balance of tradeoffs among the alternatives
considered with respect to EPA's nine evaluation criteria. The
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner. It is protective of human health and the environment,
and complies with all applicable environmental regulations. This
remedial action also utilizes treatment where feasible and
practicable.
Preference? fnr Treatment As a Principal Element:
Significant quantities of hazardous substances have already been
treated at this Site through partial implementation of the ROD.
32
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Treatment of highly contaminated waste materials prior to on-site
disposal and treatment of materials classified as hazardous waste
prior to off-site disposal will be required; thus this remedy
satisfies the statutory preference for treatment as a principal
element. By treating the most highly contaminated soil and other
waste material prior to disposal in the OCF or at an off-Site
permitted landfill, the selected remedy satisfies the preference
for treating the principal threat posed by the Site.
Documentation of Significant Changes
The Proposed Plan was released for public comment in April 1996.
Comments received during the public comment period and EPA
responses are summarized in the attached responsiveness summary.
As noted in the responsiveness summary, EPA will address a number
of the technical considerations in the comments during the
remedial design phase.
The Proposed Plan indicated that EPA will coordinate future
cleanup determinations regarding battery casings and other
contaminated materials located on the Rhone-Poulenc and ESCO
property portions of the Site with DEQ. EPA has determined, in
consultation with DEQ, that a final decision on the need for a
soil cap or other remedial action to address subsurface lead
contamination, including additional removal of subsurface soil
and/or treatment, in the Lake Area should be deferred until after
the following actions have been completed: 1} removal of treated
and untreated Gould Site waste material currently stockpiled on
the Rhone-Poulenc property, 2) confirmation sampling for lead,.
and 3) completion of a risk assessment for this area that
includes organic constituents.
33
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HI !•• •«/. I •'• 'K.'.lil
\\ Kuat Dtmnu \
SCHNITZER
INVESTMENT
CORP.
fcu /a-m/iu/iM "."•
- .X"~x ^ ' i
AMERICAN STEEL
INDUSTRIES. INC,
RHONE-POULENC INC
RHONE-POULENC INC,
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SOL
SCHEMATIC SECTION B-B'
MMCICD UODWL
irocxrux stuumi
•a w.coKMcnc
cracr nUMioc
car* «a «*. COBUO*«WC.«««
i
-------
*vtHut
LIOl-
CORP'
. SCHNirZCR
INVESTMCNT CORPORATION
LOT 33
EAST OOANE LAKE
REMNANT
LIMITS or SUBSOIL
EXCAVATION 1/7/94
CSCO CORP. LOT 44
REMEDIAL ACTION
AREA
UCTRO
TRANSrtR '
LOT )
CONTAU1NATED
SURTACC SOILS
KCVISID LIUITS
Of BURItO
UHITS Of SUBSOIL
CXCAVATtOH 7/7/34
RHONt - POULCMC
LOT 4J
RPAC
PHASE HI
STUDY AREA
RHONE POULCNC. INC
LOT 31
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EXPLANATION
(~iT) Stockpile with dealgnalton
(771 Area ol tlibfllzed btocka
I__U wtlh deskralton
f'7"J Revised ttnlu ol
V-A banory <
INV(SIM[NT CORPORAIION
LOT JJ
RPAC PHASE III
STUDY ARCA
fiHONC -
AC COMPANY INC.
LOT
-------
,Winter Waterline
FRONT" A VE.
r
SCHNITZER
PROPERTY
5
Summer \
Waterline -' SE/GR
Stoblized Material
(Direct Pour Test Cell
Plant Communities
GOULD
PROPERTY
£SCO
DPERTY\
Wetland Areas
Sampling Point
50
SCALE
100
Wetland Upland
CT Cattail BB Blackberry
RC Reed Canorygross BB-BA Blackberry - Along Bonks
RC/BE Reed Conorygross/Bentgrass BB-Fl Blackberry - Upland Fill
RC/RU Reed Conorygross/Rush GR Grosses
RU Rush GR/BB Upland Grosses/Blackberry
SE/GR Sedge/Gross
SP Spiraea Other
WI/RC Willow/Reed Canorygrass Qw Open Wo(ef
EX Exposed Fill Material (Upland)
( IN FEET )
1 inch = 100 It.
200
=J
Project #
965007NA
WOODWARD-CLYDE
CONSULTANTS
EAST DOANE LAKE WETLANDS
INVESTIGATION
Gould Superfund Site PHP Group
Portland, Oregon
Map Showing Wetland Areas
Figure
3
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. ... •.•! .Ill I'l/lll -.Mil ,'A
6NVI
. e..i.,.i
RON
.1 • »••
GOULD SUPERFUND SITE CONCEPTUAL ON-SITE CONTAINMENT FACILITY
Figure
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Gould Superiund Site
Amended ROD
Table 1
Material
Gould site:
Surface Soils
Casings
Matte/debris
Subsoil
R-P/ESCO
Overburden
Casings
Bottom fill
Subsoils
East Doane
Lake
Sediments
Plastic
Totals:
1988
ROD
Quantity
-
54,100
6,000
9,580
970
26,700
6,470
5,500
109,320
Current
Quantity
Estimates
-
9,708
33,451
6,133
14,170
28,536
725
5,927
5,483
500
104,633
Estimated
Quantity
to be
Placed in
OCF*
-
9,708
9,181
3,000
3,991
10,215
25
3,370
5,483
44,390
Estimated
Quantity
to be
Left
in Place**
-
22,400
3,000
10,000
17,600
700
2,400
-
56,100
*Note 1: the ARD document estimates 60,000 cubic yards of contaminated material would be
placed in the OCF. The ARD estimates are higher than the total shown in this column because
the ARD estimates include additional volume associated with the stabilized blocks and an
estimated additional 5,000 cubic yards of contaminated surface material that will be scraped from
the surface of the Site.
**Note 2: total does not include approximately 4,143 cubic yards of material that has been either:
1) treated and recycled, 2) disposed off-site or 3) treated and placed on-site
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APPENDIX A
Responsiveness Summary
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RESPONSIVENESS SUMMARY
GOULD SITE SOILS OPERABLE UNIT
AMENDED RECORD OP DECISION
This responsiveness summary summarizes and responds to
substantive comments received during the public comment period
regarding United States Environmental Protection Agency's (EPA's)
proposed cleanup plan for the Gould Superfund Site located in
Portland, Oregon. The Proposed Plan was based on information in
the administrative record for the ROD Amendment. The
Administrative Record and the Proposed Plan are available for
review at the Multnomah County Central Library in downtown
Portland, Oregon and at EPA's offices in Seattle, Washington.
Copies of the Proposed Plan were mailed to local citizens and
other interest groups that were on a mailing list developed as
part of the Community Relations Plan for this Site.
One comment letter was received during the public comment
period. The comment letter and follow up responses from the
Gould Site PRP Group and the commenter are in the Administrative
Record for this Site.
Comments and Aapnrv
1) Zoning not addressed as an ARAR
Comment Commenter requested that Portland's Planning and Zoning
requirements for siting of solid waste facilities be considered
ARARs, and specifically identified 100 foot setback requirements
contained in the Sections 33.254.080 and 33.254.090 of the
Portland Planning .and Zoning, ordinance as ARARs for the
construction of the On-Site Containment Facility (OCF) . This
portion of the Portland Planning and Zoning Ordinance regulates
mining and waste-related uses.
Response in general, only federal and state laws or regulations
are ARARs and local zoning ordinances are not ARARs. However,
EPA, in this instance, agrees with the commenter that the
Portland Planning and Zoning ordinance (the "Ordinance") setback
requirements are relevant and appropriate. EPA's conclusion is
based on two factors: (1) the Ordinance was promulgated pursuant
to a State law, see Chapter 197 of the Oregon Revised Statutes;
and (2) the Ordinance is enforceable by the State of Oregon, ORS
197.090. Nonetheless, EPA has determined that, under the
Ordinance, the proposed setback requirement does not apply to the
proposed cleanup action. The use of the existing area of lead
contamination within the Site as a disposal area is a
"grandfathered" non-conforming use under the Ordinance.
Grandfathered non-conforming uses are not subject to the
Ordinance's set back requirements. EPA has also concluded that,
under the Ordinance, the disposal of hazardous substances in the
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On-Site Containment Facility will not change the non-conforming
use status.
Section 33.258.035 of the Ordinance defines a non-conforming
use as a use which was allowed when established and was
maintained over time. Section 33.258.050 of the Ordinance allows
such a non-conforming use to continue to operate and for a change
in the operation of the use. This Section of the Ordinance also
permits a use to be changed to another use within the same use
category as a matter of right.
EPA's cleanup includes the disposal of waste in the same
area where waste has been disposed of and landfilled since 1949,
therefore this cleanup activity satisfies the Ordinance's
criteria for a non-conforming use. The Amended Remedy addresses
wastes which were disposed of at the Site prior to the
implementation of the Ordinance. Waste disposal and landfill
activities began in approximately 1949. This is well before the
Ordinance was mandated by ORS 197 in 1973. The disposal area has
been continuously maintained as a disposal area since disposal
activities began. As such, disposal of wastes within the Site is
a grandfathered non-conforming use which the Ordinance permits.
The setback requirements need not be satisfied during
implementation of the Amended Remedy.
. A determination that the Ordinance is an ARAR, but that the
cleanup activity is a grandfathered non-conforming use, and thus,
not subject to the setback requirements, is consistent with the
NCP. The NCP makes clear that EPA may satisfy an ARAR by meeting
the conditions for an exception to such ARAR, see 55 F.R. at -8741
(March 8, 1990) .
Nevertheless, EPA intends to consider setbacks during the
design and implementation of the Amended Remedy. EPA will
consider providing setbacks from public streets and property
lines which are outside the existing disposal area. The existing
disposal area covers several properties, including the
commenter' s. It would be impracticable to use setbacks on
properties within the existing disposal area.
2} Landfill siting requirements
Comment: Commenter states that it agrees with the Oregon
Department of Environmental Quality that RCRA Subtitle C landfill
siting requirements should be included as ARARs for the ROD
Amendment. In particular, the commenter maintains that seismic
and flood related standards contained in 40 C.F.R. § 264.18
should be ARARs.
Responsp. The commenter is incorrect to suggest that the Oregon
Department of Environmental Quality identified RCRA Subtitle C
landfill siting requirements as ARARs. Nevertheless, EPA agrees
that 40 C.F.R. § 264.18, which includes seismic and flood related
standards, is relevant and appropriate to the remedial actions
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selected in the ROD Amendment. EPA will ensure that these
requirements are met during the remedial design of the Amended
Remedy.
3} Proposed plan not protective of adjoining landowners and
increases the risk of liability of adjoining landowners.
Comment The proposed remedy is not protective of adjoining
landowners and increases liability of adjoining landowners
because contamination will be covered, future removal will be
expensive and it forces the commenter to maintain property that
contains known contamination. The commenter further suggests
that the PRPs should purchase East Doane Lake area or require
Rhone Poulenc to indemnify the commenter with respect to
liability for RP. organics on the commenter's property.
Response This comment raised three concerns. First, whether the
Amended Remedy is protective of human health and the environment
on properties outside of the disposal area. Second, whether there
will be a need for further response actions if all sediment
contamination in the area where the OCF will be constructed is
not removed pursuant to the Amended Remedy. Third, whether the
PRP group or Rhone-Poulenc should compensate for the commenter
for RP organics on its property.
EPA believes that the Amended Remedy is protective of human
health and the environment. The Amended Remedy protects
adjoining "landowners from Site contamination. The commenter's
property includes areas that are within the area of contamination
being addressed by this remedial action. The commenter's
property is contaminated with hazardous substances associated
with the Gould Site operations and other sources, including
material disposed of by the commenter which contains hazardous
substances. The proposed action will include excavation of
contaminated sediments from the commenter's property and
containment in a lined and capped containment facility located on
the Gould property. The sediments that will be removed are
contaminated with lead above specified cleanup levels. Organic
contamination is commingled with the lead-contaminated sediments
and will be removed from the commenter's property and placed in
the OCF. Some sediments with low levels of organic contamination
may not be removed. However, if such sediments are not removed,
it will be after DEQ has determined that removal of such
contamination is not necessary to protect human health or the
environment. The Amended Remedy as implemented along with any
State directed removal actions will substantially reduce or
eliminate the potential for exposure to hazardous substances in
this area..
The proposed plan for the Amended Remedy indicated that
sediments removal will occur to a depth of between 1.5 to 2.0
feet (the depth may vary at individual locations) . Rhone Poulenc
is, pursuant to a consent agreement with DEQ, committed to
evaluate the residual organic contamination in sediments below
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two feet. The results of the evaluation will be used by DEQ to
determine if sediments not addressed by this remedy, ie, below 2
ft or in areas not contaminated with lead above the cleanup
levels, need to be removed or otherwise remediated to be
protective. The work is being conducted as a time critical
action under an existing consent order and is scheduled to be
completed in time to allow a determination during the preliminary
design phase of this remedy. If DEQ determines that additional
removal of sediments is required, this'work will be coordinated
with the sediment removal to be conducted as part of this ROD
Amendment and will occur prior to the construction of the OCF.
Lastly, EPA believes it inappropriate for EPA to direct
other parties to purchase East Doane lake from the commenter or
direct Rhone-Poulenc to indemnify the Commenter. CERCLA does not
provide EPA with the authority to order such relief. The relief
the commenter seeks is available to the commenter by agreement or
by civil suit. EPA notes that the commenter is essentially
seeking the requested relief in a civil action before the United
States District Court for the District of Oregon. EPA believes
this is the appropriate forum to receive such relief. EPA also
disagrees with the commenter's conclusion that the Amended Remedy
will increase the risk of liability of adjoining landowners.
Implementation of the Amended Remedy will not cause contamination
to spread to areas which are not already contaminated.
Accordingly, the Amended Remedy will not increase the risk of
liability to non-contaminated properties adjoining the Site.
4) Hydxogeologic Impact of the Remedy
Comment; The hydrogeologic impact of filling lake and building
OCF has not been considered. Commenter stated that there is a
serious risk that filling the lake will cause increased migration
of contaminants onto their property. Filling will likely cause
contaminated water and sediment to be extruded into adjoining
soils with the direct result that contamination on Schnitzer
property will increase
Comment. Filling lake will displace free liquid and sediments
and force them through the subsurface passages onto Schnitzer
property, and pressure from the OCF will force liquid currently
caught in pores of soil to migrate into groundwater, and could
have high levels of contamination
Comment. Subsurface movement will prevent the commenter from
mining fluff (shredder reside) oh its property, because
contaminants will flow into any mining excavation.
Comment. EPA urged to fully analyze the hydrogeologic impact of
the proposed remedy and allow meaning full comment prior to
amending the ROD.
Response EPA agrees that the hydrogeologic impact of filling the
East Doane lake remnant needs to be fully evaluated and indicated
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as such in the Proposed Plan. EPA will require the PRP Group to
conduct a detailed analysis as part of the preliminary design.
The results of the analysis will be available to the public,
including any adjacent property owners.
5) ROD improperly addresses organics
Comment EPA should clarify the nature of the portions of the
proposed ROD Amendment that addresses organics. Conclusions are
reached in the ARD about the handling and encapsulation of
organics that appear to be beyond the scope of the RI/FS process.
Where no characterization of the organics has occurred within the
formalized RI/FS process, it is inappropriate for the proposed
ROD Amendment to endorse remedies that involve the on-site
disposal of some organics contaminated sediment and leaving in
place of other contaminated sediments.
Response EPA has added language in ROD Amendment to clarify the
handling of organics contaminated sediments.
EPA is not limited to the RI/FS process in reviewing post-
ROD information. Agency guidance (OSWER Directive 9355.3-02)
notes that after a ROD is signed, new information may be
generated during the RD/RA process that could affect the remedy
selected in the ROD. The original ROD for the Gould Soils
Operable Unit was focused on remediation of lead contamination,
which was identified as the primary contaminant of concern.
Information regarding organics contamination has been generated
since the ROD was signed in 1988. In addition to the
characterization work conducted under the Rhone Poulenc RI/FS,
additional data has been collected as part of the evaluation "of
the Gould Site remedial action. Information from the additional
Gould Site studies was placed in the administrative record for .
the ROD Amendment.
Organic contaminants that are commingled with lead above
previously established cleanup levels will be addressed by this
ROD Amendment. EPA did not established cleanup levels for
organic contamination in the original ROD or as part of this ROD
Amendment. EPA has determined that the onsite containment
facility can be designed, constructed and operated to be
protective of human health and the environment for the lead and
organic contaminated materials that are being addressed by the
ROD Amendment. DEQ will determine the levels that will be
protective for organic contamination associated, with the Rhone
Poulenc facility, including areas on the Gould site not addressed
by the ROD Amendment. DEQ anticipates making a determination on
the remaining sediments prior to completion of remedial design.
6) Consolidation and settlement analysis
Comment The proposed plan fails to address consolidation and
differential settlement. Substantial differences in settlement
will occur between areas with indigenous cohesive soil and those
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areas that are compacted and-filled. Areas will settle at
different rates and put stress on liner, leak detection system,
contents of the OCF and the cover, liner, etc could fail and
leachate could be release to groundwater. Future use could also
add to settlement problems.
Response EPA and DEQ determined that a detailed design phase
would be necessary to ensure that agency concerns, including
those expressed in this comment, will be adequately addressed.
The agency agrees with the commenter that consolidation and
differential settlement analysis is needed, as noted in the
proposed plan ("the containment facility must be designed to
provide long term structural stability and effective containment
of the waste") . A detailed analysis will be conducted as part of
the preliminary design phase. The results of the consolidation
and settlement analysis, as well as other preliminary design
information, will be available to the public.
7) Lateral and vertical support
Comment; Areas surrounding the OCF that consist of fluff will
not offer sufficient lateral support to support the OCF. Require
a complete analysis of lateral and vertical support before an OCF
is determined to be a feasible remedy.
Response The agency agrees that a complete analysis of lateral
and vertical support is necessary. An analysis will be completed
as part of the predesign or design phase.
8} Leachate collection detection system
Comment There is a lack of detail on design of the leachate
collection and detection system.
Response The ARD included a conceptual view of a leachate
collection and detection system and description of the objectives
of the system. Detailed information on the leachate collection
and detection system will be developed as part of remedial
design.
9} Inadedequate analysis of neighborhood stonnwater runoff
Comment- The document ignores impact of filling East Doane lake
on stonnwater runoff (currently buffers large storms). The
alternative could overload stonnwater collection system. An
analysis should be made available for public comment.
Response The East Doane lake remnant may currently provide some
buffering of runoff during major storms. Years of filling and
waste disposal activity have significantly altered East Doane
lake remnant, however, and EPA believes that stonnwater runoff in
the area can be better managed through engineered control and
collection systems. Details of the stormwater collection and
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management system for the Gould site will be developed in the
design phase of the project. The system will be designed to
include adequate capacity to accommodate major storm events.
10) Impact of construction on neighbors
Comment: Runoff could lead to additional contamination of
neighboring property; and severe traffic problems likely during
construction.
Response Control of runoff was a requirement of the original
ROD and will be a design requirement for the OCF. There will
undoubtedly be short term impacts, like increased traffic, on
neighboring property during the construction. There is already a
considerable amount of traffic in the vicinity of the site
associated with nearby operating industries and the METRO waste
transfer station. EPA will attempt to minimize direct impacts on
adjoining landowners, although some short term impacts will be
unavoidable because of space limitations and the need address
contaminants on the commenter's property.
11} Handling of contaminated water
Comment Commenter expressed concern that the ROD doesn't
address handling and disposal of contaminated water from dredging
and dewatering sediment, and requested that EPA require the PRPs
to address the means of treating the water prior to disposal to
ensure no contamination of adjacent property.
Response EPA agrees with the commenter that handling and
disposal of contaminated water from .dredging and dewatering
sediment needs to be addressed as noted in the proposed plan.
EPA will require that the operation minimize short term impacts
from dredging and construction to the extent practicable.
Contaminated water from dewatering the sediments will be
collected and treated as part of the remedial action.
12) Details and documentation
Conunent The ARD lacks the specificity to comment on the
proposal, and more comprehensive documentation must be developed
and provided to the public to satisfy the public notice
requirements.
Resppnge The lack of specificity has been discussed in the
responses to several of the previous comments. EPA acknowledges
that the selected alternative as described in the ARD did not
include specific details that are typically addressed as part of
remedial design. Information developed during design will be
made available to the commenter. EPA does not plan to conduct an
additional public comment period during the design phase for this
project, however. Commenters may submit information to EPA after
the ROD Amendment is signed and EPA will review the information
to determine if it should be considered by the agency. If EPA
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determines that comments submitted by the commenter warrants
formal consideration, EPA will prepare a formal response to the
information received and document the response in the
administrative record.
If information generated during the remedial design phase
results in significant changes to the remedy as described in the
ROD Amendment, then the appropriate public notice requirements
will be followed.
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(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
DATE: 9/30/94 PAGES: 218
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Focused Feasibility Study for the Gould Superfund Site Volume III: Appendices C through F
(Redacted Copy. Confidential Business Information - Appendices C. D & F - Removed).
SUB-HEAD: 3. 5. 5. . Vol. 1 - Amended Remedy Document
3. 5. 5. . Vol. 1 - 1028943 DOC ID: 40649
DATE: 1/26/96 PAGES: 300
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Amended Remedy Document for the Gould Superfund Site.
SUB-HEAD: 3. 5. 6. . Vol. 1 - Proposed ROD Amendment
3. 5. 6. . Vol. 1 - 1028977 DOC ID: 40784
DATE: 3/29/96 PAGES: 12
AUTHOR(S): ADDRESSEE(S):
EPA Unknown
DESCRIPTION: Proposed ROD Amendment Gould Superfund Site.
SUB-HEAD: 3.5.6.1. Vol.1- Comments
3. 5. 6. 1. Vol. 1 - 1050819 DOC ID: 68066
DATE: 4/18/96 PAGES: 1
AUTHOR(S): ADDRESSEE(S):
Tom Zelenka/Schnitzer Investment Corp. Chip Humphrey/EPA
DESCRIPTION: Letter requesting an extension of the comment period for the Gould Superfund Site Proposed
ROD Amendment
3. 5. 6. 1. Vol. 1 - 1050820 DOC ID: 68067
DATE: 5/31/96 PAGES: 19
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Letter commenting on the Gould Superfund Site Proposed ROD Amendment.
3/5. 6. 1. Vol.1 - 1050821 DOC ID: 68068
DATE: 6/28/96 PAGES: 12 *
AUTHOR(S): ADDRESSEE(S):
Michael C. Veysey/Gould. Inc.
Ted Yackulic/EPA
DESCRIPTION: Letter responding to Schnitzer Investment Corporation's comments on the Gould site Proposed
ROD Amendment.
3. 5. 6. 1. Vol. 1 - 1050822 DOC ID: 68069
DATE: 7/23/96 PAGES: 7
AUTHOR(S): ADDRESSEE(S):
Tom Zelenka/Schnitzer Investment Corp. Chip Humphrey/EPA
Ted Yackulic/EPA
U.S. Environmental Protection Agency. Region 10 Page
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(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
DESCRIPTION: Letter responding to Gould's 6/28/96 letter and clarifying Schnitzels concerns about the
proposed ROD amendment
HEADING: 4. 0. . . DOANE LAKE GROUNDWATER/SURFACE WATER UNIT
SUB-HEAD: 4. 1. . . Vol.1 - Focused Remedial Investigation
SUB-HEAD: 4. 1. 5. . Vol.1- 1991 Hydrogeological Investigation
4. 1. 5. . Vol.1 - 1053282 DOC ID: 71124
DATE: 2/22/91 PAGES: 323
AUTHOR(S): ADDRESSEE(S):
Geraghty & Miller, Inc. The Industrial Group-Doane Lake Area
DESCRIPTION: Hydrogeological Investigation of the Doane Lake Area: Volume I.
HEADING: 5. 0. . . STATE COORDINATION
SUB-HEAD: 5. 3. . . Vol. 1 - Rhone-Poulenc RI/FS
SUB-HEAD: 5. 3. 1. . Vol.1 - Correspondence
5. 3. 1. . Vol.1 - 1053272 DOC ID: 71100
DATE: 11/30/95 PAGES: 15
AUTHOR(S): ADDRESSEE(S):
Mike Edwards/Woodward-Clyde Consultants Mavis Kent/ODEQ
Roger Gresh/Woodward-Clyde Consultants
DESCRIPTION: Letter transmitting IRM Evaluation for Organic Constituents at the Gould Property (attached).
5. 3. 1. . Vol.1 - 1053273 DOC ID: 71104
DATE: 6/12/96 PAGES: 10
AUTHOR(S): ADDRESSEE(S):
Mike Edwards/Woodward-Clyde Consultants
Roger Gresh/Woodward-Clyde Consultants
DESCRIPTION: Letter transmitting and commenting on a Statistical Analysis of the East Doane Lake Sediment Data
(attached).
SUB-HEAD: 5. 3. 2. . Vol. 1 - Work Plan
5. 3. 2. . Vol.1 - 1053274 DOC ID: 71105
DATE: 5/27/94 PAGES: 203
AUTHOR(S): . o ADDRESSEE(S):
Woodward-Clyde Consultants Rhone-Poulenc
DESCRIPTION: Final Work Plan to Complete Remedial Investigation/Feasibility Study (Including revisions through
11/23/94).
SUB-HEAD: 5. 3. 3. . Vol. 1 - Memoranda and Reports
5. 3. 3. . Vol.1 - 1053275 DOC ID: 71107
DATE: 6/20/95 PAGES: 38
AUTHOR(S): ADDRESSEE(S):
U.S. Environmental Protection Agency. Region 10 Page
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APPENDIX B
Letter of Concurrence from
The Oregon Department of Environmental Quality
-------
May 22, 1997
Oregon
DEPARTMENT OF
Mr. Chuck Clarke ENVIRONMENTAL
Regional Administrator •
QUALITY
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98102
Re: Gould Super-fund Site
State Concurrence on the Amended
Record of Decision
Dear Mr. Clarke:
The Oregon Department of Environmental Quality (DEQ) has reviewed EPA's proposed
Amended Record of Decision for the Soils Operable Unit of the Gould Superfimd Site in
Portland, Oregon. I am pleased to advise you that DEQ concurs with EPA's Amended Record
ofDecision.
I find that this decision is consistent with state statutory requirements and administrative rules
pertaining to the degree of cleanup required and remedy selection process. Specifically, this
decision is protective and balances effectiveness, implementability, implementation risk, long
term reliability, and cost-reasonableness in accordance with ORS 465.315 and OAR 340-122-.
040 and 090.
The DEQ looks forward to the implementation of the remedial action. Please let us know if we
can provide further assistance. The appropriate DEQ contact is Till Kieman at 530-229-6900.
igdon Marsh
Director
cc: Chip Humphrey, EPA/Oregon Operations Office
Jill Kiernan, DEQ
811 SW Sixth Avenue
Portland, OR 97204-1390
(503) 229-5696
TDD (503) 229-6993
DEQ-l &
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APPENDIX C
Administrative Record Index
-------
TABLE OF CONTENTS
GOULD INC. - ROD AMENDMENT AR (GOADD)
0. 0 TABLE OF CONTENTS/INDEX
1. 0 GOULD REMEDIAL ADMINISTRATIVE RECORD
3. 0 CASINGS/SOILS UNIT
3. 5 Revised Remedy Remedial Action
3. 5. 1 Correspondence
3. 5. 2 Sampling Plans/Work Plans
3. 5. 3 Site Investigation Reports (2 Volumes)
3. 5. 4 Focused Feasibility Study
3. 5. 5 Amended Remedy Document
3. 5. 6 Proposed ROD Amendment
3. 5. 6. 1 Comments
4. 0 DOANE LAKE GROUNDWATER/SURFACE WATER UNIT
4. 1 Focused Remedial Investigation
4. 1. 5 1991 Hydrogeological Investigation
5. 0 STATE COORDINATION
5. 3 Rhone-Poulenc RI/FS
5. 3. 1 Correspondence
5. 3. 2 Work Plan
5. 3. 3 Memoranda and Reports
8. 0 ENFORCEMENT
8. 1 Correspondence
8. 1. 1 Unilateral Administrative Order Correspondence
Page: 1
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TABLE OF CONTENTS
GOULD INC. - ROD AMENDMENT AR (GOADD)
8. 3 Administrative Orders
Page: 2
-------
(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
HEADING: 0. 0. . . TABLE OF CONTENTS/INDEX
HEADING: 1.0. . . GOULD REMEDIAL ADMINISTRATIVE RECORD
1.0... Vol. 1 - DOC ID: 40662
DATE: PAGES: 0
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Refer to the Gould Remedial Administrative Record located in the Superfund Region 10 Records
Center and the Multnomah County Library for the 1988 Record of Decision and supporting
documentation
HEADING: 3. 0. . . CASINGS/SOILS UNIT
SUB-HEAD: 3. 5. . . Vol. 1 - Revised Remedy Remedial Action
SUB-HEAD: 3. 5. 1. . Vol.1 - Correspondence
3. 5. 1. . Vol.1 - 1028958 DOC ID: 40709
DATE: 11/19/93 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
James F. Cronmiller/Gould Electronics Chip Humphrey/EPA
DESCRIPTION: Letter expressing concerns with the ongoing remedial efforts at the Gould Superfund Site.
3. 5. 1. . Vol.1 - 1028959 DOC ID: 40710
DATE: 1/14/94 PAGES: 5
AUTHOR(S): ADDRESSEE(S):
Steven Oster/Wilkie Farr & Gallagher Ted Yackulic/EPA
DESCRIPTION: Letter requesting the EPA to reconsider the remedial action at the Gould Superfund Site.
3. 5. 1. . Vol.1 - 1028960 DOC ID: 40711
DATE: 2/1/94 PAGES: 32
AUTHOR(S): ADDRESSEE(S):
Jay F. Young/NL Industries Chip Humphrey/EPA
DESCRIPTION: Letter providing requested information regarding costs to complete remedial action at the Gould
Site (correspondence and other materials reflecting Canonie Environmental cost projections
attached).
3. 5. 1. . Vol. 1 - 1028961 DOC ID: 40712
DATE: 3/21/94 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
Mavis Kent/ODEQ
DESCRIPTION: Letter identifying DEQ general concerns with disposal alternatives at the Rhone-Poulenc property.
3. 5. 1. . Vol. 1 - 1028962 DOC ID: 40713
DATE: 3/30/94 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
Chip Humphrey/EPA File
DESCRIPTION: Memorandum documenting the Gould meeting of March 23. 1994 and listing PRP arguments for
reconsideration of the battery waste recycle portion of the remedy.
3. 5. 1. . Vol. 1 - 1028963 DOC ID: 40714
U.S. Environmental Protection Agency, Region 10 Page
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(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
DATE: 7/7/94 PAGES: 19
AUTHOR(S): ADDRESSEE(S):
Jay F. Young/NL Industries t Chip Humphrey/EPA
DESCRIPTION: Letter requesting permission to suspend stabilization activities at the Gould site pending
completion of the Focused Feasibility Study (attached supporting documentation includes a 7/7/94
revised status review from Canonie Environmental).
3. 5. 1. . Vol. 1 - 1028964 DOC ID: 40715
DATE: 8/3/94 PAGES: 4
AUTHOR(S): ADDRESSEE(S):
Michael C. Veysey/Gould. Inc.
Ted Yackulic/EPA
DESCRIPTION: Letter expressing concern about continuing stabilization activities at the Gould site and requesting
that such activities be suspended pending selection of a final remedy.
3. 5. 1. . Vol.1 - 1028965 DOC ID. 40716
DATE: 11/7/94 PAGES: 13
AUTHOR(S): ADDRESSEE(S):
Chip Humphrey/EPA Jay F. Young/NL Industries
DESCRIPTION: Letter transmitting and summarizing EPA and support agency comments (attached) on the draft
Focused Feasibility Study for the Gould site.
3. 5. 1. . Vol. 1 - 1028966 DOC ID: 40717
DATE: 12/15/94 PAGES: 5
AUTHOR(S): ADDRESSEE(S):
Mark E. Hawley/ENVIRON Corporation . Chip Humphrey/EPA
DESCRIPTION: Letter responding on behalf of the Gould PRP Group to comments on the Focused Feasibility
Study submitted on September 30.1994.
,
3. 5. 1. . Vol. 1 - 1028967 DOC ID: 40718
DATE: 2/8/95 PAGES: 18
AUTHOR(S): ADDRESSEE(S):
Michael C. Veysey/Gould, Inc.
Ted Yackulic/EPA
DESCRIPTION: Letter responding to a 1/18/95 request that the Gould Site PRP Group formally advise EPA of rts
position on the need to further coordinate remedial action at the Gould Superfund Site with the
ongoing RI/FS and remedial action at the Rhone-Poulenc Site.
3. 5. 1. . Vol. 1 - 1028968 DOC ID: 40719
DATE: 2/10/95 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
David L. Blount/Copeland Landye Bennett & Wolf Chip Humphrey/EPA
Ted Yackulic/EPA
DESCRIPTION: Letter confirming that Canonie Environmental has terminated its contract with the Gould site PRP
Group.
3. 5. 1. . Vol. 1 - 1028969 DOC ID: 40720
DATE: 2/10/95 PAGES: 1
AUTHOR(S): ADDRESSEE(S):
Robert B. Hopkins/Copeland Landye Bennett & Wolf Canonie Environmental Services Corp.
U.S. Environmental Protection Agency. Region 10 Page
-------
(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
DESCRIPTION: Letter demanding that due to inappropriate and unilateral conduct and contract breaches, Canonie
immediately leave the Gould site.
3. 5. 1. . Vol.1 - 1028970 DOC ID: 40721
DATE: 2/16/95 PAGES: 4
AUTHOR(S): ADDRESSEE(S):
Jay F. Young/NL Industries Chip Humphrey/EPA
Ted Yackulic/EPA
DESCRIPTION: Letter transmitting a schedule (not attached) for sampling the stabilized blocks at the Gould site
and answering various EPA questions regarding the cost calculations in the Focused Feasibility
Study.
3. 5. 1. . Vol.1 - 1028971 DOC ID: 40722
DATE: 12/21/95 PAGES: 6
AUTHOR(S): ADDRESSEE(S):
Chip Humphrey/EPA Jay F. Young/NL Industries
DESCRIPTION: EPA and support agency's comments on the Amended Remedy Document for the Gould Superfund
Site Soils Operable Unit
3. 5. 1. . Vol. 1 - 1050816 DOC ID: 68063
DATE: 3/7/96 PAGES: 14
AUTHOR(S): ADDRESSEE(S):
Mark E Hawley/ENVIRON Corporation Chip Humphrey/EPA
DESCRIPTION: Letter on behalf of the Gould Superfund Site PRP Group supporting the remedy proposed in the
Amended Remedy Document submitted on 1/26/96.
3. 5. 1. . Vol. 1 - 1050817 DOC ID: 68064
DATE: 8/16/96 PAGES: 1
AUTHOR(S): ADDRESSEE(S):
Jill Kieman/Oregon Dept of Environmental Quality
DESCRIPTION: Letter preliminarily identifying Oregon's applicable or relevant and appropriate requirements
(ARARs) for the EPA proposed Record of Decision (ROD) Amendment
SUB-HEAD: 3. 5. 2. . Vol. 1 - Sampling Plans/Work Plans
3. 5. 2. . Vol. 1 - 1028938 DOC ID: 40643
DATE: 6/15/95 PAGES: 100
AUTHOR(S): ADDRESSEE(S):
ENVIRON Corporation Gould Superfund Site PRP Group
DESCRIPTION: Sampling and Analysis Plan for Stage I Investigation of Stockpiles. Stabilized Blocks, and
Sediments: Gould Superfund Site.
3. 5. 2. . Vol. 1 - 1028939 DOC ID: 40644
DATE: 12/4/95 PAGES: 16
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: 'Sampling and Analysis Plan for Stage II Investigation of Lead Fines and Matte: Gould Superfund
Site.
U.S. Environmental Protection Agency, Region 10 Page
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(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
SUB-HEAD: 3. 5. 3. . Vol.1 - Site Investigation Reports
3. 5. 3. . Vol. 1 - 1028942 DOC ID: 40645
DATE: 12/1/94 PAGES: 180
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Review of Organics Data Collected at the Gould Superfund Site.
3. 5. 3. . Vol. 1 - 1028940 DOC ID: 40646
DATE: 3/31/95 PAGES: 28
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Site Condition Report. Gould Superfund Site.
3. 5. 3. . Vol. 1 - 1028937 DOC ID: 40647
DATE: 10/31/95 PAGES: 250
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Ground Water Monitoring Field Activities. February 1995 - August 1995: Gould Superfund Site.
3. 5. 3. . Vol.1 - 1050818 DOC ID: 68065
DATE: 4/18/96 PAGES: 25
AUTHOR(S): ADDRESSEE(S):
Woodward-Clyde Consultants
DESCRIPTION: Wetlands Investigation of East Doane Lake: Final Report.
SUB-HEAD: 3. 5. 3. . Vol.2 - Volume2
3.5.3. . Vol.2- 1028941 DOC ID: 40648
DATE: 10/31/95 PAGES: 200
AUTHOR(S): ADDRESSEE(S):
ENVIRON Corporation
DESCRIPTION: Stage I Field Activities Report Gould Superfund Site.
SUB-HEAD: 3. 5. 4. . Vol.1 - Focused Feasibility Study
3. 5. 4. . Vol. 1 - 1028954 DOC ID: 40663
DATE: 9/30/94 PAGES: 89
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Focused Feasibility Study for the Gould Superfund Site Volume I: Main Report. Tables, and
Figures (Redacted Copy, Confidential Business Information Removed).
3. 5. 4. . Vol. 1 - 1028955 DOC ID: 40664
DATE: 9/30/94 PAGES: 218
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Focused Feasibility Study for the Gould Superfund Site Volume II: Appendices A and B (Redacted
Copy, Confidential Business Information - Appendix B - Removed).
3. 5. 4. . Vol. 1 - 1028956 DOC ID: 40665
U.S. Environmental Protection Agency. Region 10 Page
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(QOADD) GOULD INC. - ROD AMENDMENT AR INDEX
DESCRIPTION: Quarterly Progress Report 1st Quarter 1995 Surface Water and Sediment.
5. 3. 3. . Vol.1 - 1053276 DOC ID: 71108
DATE: 6/23/95 PAGES: 101
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Monthly Progress Report May 1995 Subsurface Soil and Reconnaissance Groundwater, Groundwater,
Biological Indicator Parameters. Surface Soil-Herbicide Area and Subsurface Soil-Insecticide Area.
5.3.3. . Vol.1- 1053277 DOC ID: 71109
DATE: 7/5/95 PAGES: 66
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Technical Memorandum #2 Preliminary Screening of Technologies (Draft).
5.3.3. . Vol.1- 1053278 DOC ID: 71110
DATE: 8/22/95 PAGES: 62
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Technical Memorandum #5 Environmental Evaluation Process (Draft).
5. 3. 3. . Vol.1 - 1053279 DOC ID: 71111
DATE: 9/29/95 PAGES: 125
AUTHOR(S): ADDRESSEE(S):
DESCRIPTION: Technical Memorandum #6 Human Health Evaluation Exposure Assessment and Identification for
the Chemicals of Concern.
5.3.3. . Vol.1- 1053280 DOC ID: 71112
DATE: 5/14/96 PAGES: 49
AUTHOR(S): ADDRESSEES):
DESCRIPTION: First Quarter 1996 Progress Report.
HEADING: 8. 0. . . ENFORCEMENT
SUB-HEAD: 8. 1. . . Vol.1 - Correspondence
SUB-HEAD: 8. 1. 1. . Vol.1 - Unilateral Administrative Order Correspondence
8. 1. 1. . Vol. 1 - 1028972 DOC ID: 40723
DATE: 5/24/94 PAGES: 3
AUTHOR(S): ADDRESSEE(S):
Carol A. Rushin/EPA Michael C. Veysey/Gould. Inc.
DESCRIPTION: Notice of Additional Response Actions Required Pursuant to Administrative Order, In the Matter
of the Gould Superfund Site. EPA Docket No. 1091-01-10-106 ("Gould UAO")
8. 1. 1. . Vol. 1 - 1028973 DOC ID: 40724
DATE: 8/1/94 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
Randall F. Smith/EPA James E. Benedict/Cable Huston Benedict &
Ferris
DESCRIPTION: Notice and Directive for Performance of Additional Response Actions Pursuant to Administrative
Order. In the Matter of Gould Superfund Site. EPA Docket No. 1091-01-10-106 (Gould UAO)
U.S. Environmental Protection Agency, Region 10 Page
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(GOADD) GOULD INC. - ROD AMENDMENT AR INDEX
8. 1. 1. . Vol.1 - 1028974 DOC ID. 40725
DATE: 8/17/94 PAGES: 2
AUTHOR(S): ADDRESSEE(S):
Ted Yackulic/EPA Michael C. Veysey/Gould, Inc.
DESCRIPTION: Letter expressing concern about Gould's August 3. 1994 letter and the possibility that the Gould
UAO Respondents may discontinue compliance with the Gould UAO
8. 1. 1. . Vol.1 - 1028975 DOC ID: 40726
DATE: 3/31/95 PAGES: 3
AUTHOR(S): ADDRESSEE(S):
Randall F. Smith/EPA
DESCRIPTION: Notice of Additional Response Actions Pursuant to Administrative Order. In the Matter of the
Gould Superfund Site. EPA Docket No. 1091-01-10-106 ("Gould UAO")
SUB-HEAD: 8. 3. . . Vol. 1 - Administrative Orders
8. 3. . . Vol. 1 - 1028944 DOC ID: 7389
DATE: 1/22/92 PAGES: 100
AUTHOR(S): ADDRESSEE(S):
Unknown
DESCRIPTION: Administrative Order. EPA Docket No 1091-01-10-106
U.S. Environmental Protection Agency. Region 10 Page 8
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APPENDIX D
Summary of Design Requirements
-------
APPENDIX D
Summary of Design Requirements
PAGE
12
13
19
20
21
24
PARA
3
5
2
3
1
5
TEXT
1) The design needs to provide for adequate control of water
during the filling of the East Doane lake remnant, and
monitoring and control of potential impacts from displacement
of contaminants in East Doane lake water and sediments.
2) The OCF must be designed to allow for implementation of
future groundwater cleanup actions to be performed by Rhone-
Poulenc as required by DEQ. This may reduce the area on the
Gould property available for the on-site containment facility.
3) The OCF must be designed to provide control of stormwater
runoff and leachate.
A mitigation/restoration plan will be required to compensate for
the loss of the wetlands and open water habitat as part of the
remedial action.
A detailed design phase will be required, however, to ensure that
construction and operation of the OCF will be adequately
protective. The design will include special considerations for
dredging and filling of the East Doane lake remnant and
handling of site materials.
Perform design studies to evaluate site constraints and design
parameters, including the following: consolidation and
settlement, lateral and vertical support, dewatering sediments,
stormwater runoff and control, leachate collection, treatment and
disposal, and hydrogeologic impact of filling East Doane lake
remnant and the open excavation (also known as the Lake Area
or Phase HI Area) portion of the Rhone-Poulenc property;
A proposal identifying work to be performed, including at least
one off-site mitigation proposal, shall be submitted with the final
design report;
The OCF will be designed to meet minimum technology
requirements for RCRA Subtitle C landfills, including liners,
leachate collection, and a cap.
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APPENDIX D (Continued)
Summary of Design Requirements
25
Potential future industrial uses of the Gould property will be
considered in the design of the facility to the extent practicable.
25
Final design of the containment facility will be subject to
approval by EPA.
27
Dredging and filling of the East Doane lake remnant is subject to
the requirements of Section 404 of the Clean Water Act, and a
mitigation/restoration plan will be required.
27
The OCF will be constructed above the water table and will be
designed, constructed and operated to meet 40 CFR 264 Subpart
N requirements for landfills, including: 1) 264.301 design and
operating requirements for liners and leachate collection
systems, 2) 264.303 monitoring and inspection requirements, 3)
264.310 closure and post-closure care requirements for covers
which minimize migration of liquids, function with minimum
maintenance, and provide long-term integrity.
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