PB98-963105
EPA 541-R98-036
September 1998
EPA Superfund
Record of Decision Amendment:
McCormick and Baxter Creosoting
Company (Portland Plant)
Portland, OR
3/17/1998
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U.S. Environmental Protection Agency Oregon Department of Environmental Quality
Region 10 811 Southwest Sixth Avenue
1200 Sixth Avenue Portland. Oregon
Seattle. Washington •
Amended Record of Decision
McCormick and Baxter Creosoting Company
Portland Plant
Portland, Oregon
March 1998
primed on recycled paper
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AMENDED RECORD OF DECISION
McCORMICK AND BAXTER CREOSOTING COMPANY
PORTLAND PLANT
THE DECLARATION
SITE NAME AND LOCATION
McCormick and Baxter Creosoting Company, Portland Plant
Portland, Oregon
STATEMENT OF BASIS AND PURPOSE
This decision document presents an amendment to the selected remedial actions for the
McCormick and Baxter Creosoting Company, Portland Plant site (McCormick & Baxter or
Site) located in Portland, Oregon. This Record of Decision Amendment (ROD Amendment)
has been developed in accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, 42 USC §9601 et seq. (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. This decision is based on the Administrative Record for the Site.
The documents added to the Administrative Record since the issuance of the original ROD in
March 1996 are listed in Appendix B.
The State of Oregon concurs with the ROD Amendment.
ASSESSMENT OF THE SITE
The McCormick & Baxter site is located on the Willamette River in Portland, Oregon, and
covers approximately 58 acres of terrestrial and aquatic land. The McCormick & Baxter
Creosoting Company operated a wood-treating facility on a portion of the site from 1944 until
1991. Site contamination is primarily attributed to releases of hazardous substances from these
wood-treating activities and on-site disposal of wastes.
Actual or threatened releases of hazardous substances from the Site, if not addressed by
implementing the response actions selected in this ROD Amendment, may present an imminent
and substantial threat to human health, welfare, and/or the environment.
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DESCRIPTION OF THE AMENDMENT TO THE REMEDY
This ROD Amendment changes a component of the selected remedial action for contaminated
soil. The original selected remedy documented in the March 1996 Record of Decision (ROD)
is a series of remedial actions that address the principal threats at the Site, by removing the
most highly contaminated soil, extracting nonaqueous phase liquid (NAPL) from and treating
contaminated groundwater, and capping the most highly contaminated sediment. These are
considered to be the final actions needed to control the release of contaminants and reduce the
risks to human health, welfare, and the environment from the Site.
The original soil remedy in the 1996 ROD called for excavation and on-site biological
treatment of contaminated soils, with an estimated 1,000 cubic yards of highly contaminated
soil and other wastes requiring off-site treatment and disposal. This 1,000 cubic yards was to
include soil with significant dioxin concentrations (i.e., several orders of magnitude above
protective levels). After the ROD was signed, DEQ initiated the detailed design of the
selected soil remedy, including additional soil sampling. Based on the data gathered during the
sampling, DEQ determined that dioxin contamination of soils was more widespread than
previously reported. The volume of soil with significant levels of dioxin is now estimated to
be approximately 20,000 cubic yards, versus 1,000 cubic yards estimated in the 1996 ROD. In
addition, the dioxin contamination is predominantly located in the same areas where elevated
concentrations of pentachlorophenol (PCP) and polycyclic aromatic hydrocarbons (PAHs) are
found in soils.
While the biological treatment included in the original remedy is effective in reducing
concentrations of PCP and PAHs in soil, it has not been demonstrated to be effective at
significantly reducing dioxin concentrations in soil. Because significant levels of dioxin are
present in soil areas originally identified for excavation and on-site biological treatment (i.e.,
areas where contamination exceeds the action levels for PCP and PAHs), it now appears
unlikely that this intended treatment will achieve the level of risk reduction contemplated in the
1996 ROD. Accordingly, DEQ and EPA have selected an alternative remedy for contaminated
soil at the McCormick & Baxter site.
The major components of the selected (amended) remedy for contaminated soil include:
• Completion of demolition and off-site disposal or recycling (except for concrete
rubble) of above-ground structures and debris, and of underground structures that
interfere with soil excavation;
• Excavation, to a maximum depth of approximately 4 feet, of contaminated soil that
exceeds the action levels for arsenic, PAHs and PCP established in the 1996 ROD;
• Use of engineering controls during excavation and transportation, such as dust
suppression with water sprays, truck washing prior leaving site; lining and covering
trucks and/or rail cars during loading and transport; and planning truck routes and
schedules to minimize potential adverse impacts on the surrounding community;
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• Off-site treatment of excavated soil that exceeds the toxicity characteristic leaching
procedure (TCLP) hazardous waste criteria for arsenic, chromium, and/or PCP,
established under the Resource Conservation and Recovery Act (RCRA);
• Off-site disposal of excavated soil at a RCRA-permitted hazardous waste disposal
facility, following any required treatment, as described above;
• Excavation of any soil beyond the property boundary with site-related contaminant
concentrations above the cleanup goals, and placement of that so;l onto the site
property to be capped;
• Backfilling of existing, in-ground concrete sumps, vaults, etc. with concrete rubble
from above-ground demolition activities, and backfilling of soil excavations with
clean soil imported to the site;
• Placement of a two-foot thick, clean soil cap over the entire site, a: described in the
1996 ROD, followed by long-term monitoring and maintenance; and
• Establishment of institutional controls, as described in the 1996 ROD, including but
not limited to, deed notices containing information on the levels and location of
contamination on the property, and deed restrictions, such as environmental ease-
ments or restrictive covenants limiting future uses of the site to industrial/commercial
or open-space recreational activities. The deed restrictions will prohibit future land
uses not consistent with the level of protectiveness achieved by the cleanup. Deed
restrictions may also include requirements for routine maintenance and repair of the
cap, restrictions on soil excavation activities without the necessary health and safety,
and engineering controls, and the proper disposal of any contaminated soil excavated
during installation or maintenance of underground utilities by future owners or
lessees, as applicable. Deed restrictions will be set forth in a DEQ-approved form,
running with the land and enforceable by DEQ against present and future owners of
the property.
All other elements of the selected remedy set forth in the 1996 ROD are unchanged in this
ROD Amendment.
DECLARATION
Although this ROD Amendment changes a component of the remedy selected in the 1996
ROD, the amended remedy continues to be protective of human health and the environment,
attains federal and state requirements that are legally applicable or relevant and appropriate for
this remedial action, and is cost effective. Because this remedy will result in hazardous
substances remaining on site above health-based levels, a review will be conducted within five
years after commencement of remedial action, to ensure that the remedy continues to provide
adequate protection of human health and the environment.
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The amended remedy includes many similar components to the original remedy selected in the
1996 ROD. Specifically, demolition and off-site disposal or recycling of structures and debris;
excavation of soil contaminated above action levels to a maximum depth of approximately 4
feet below ground surface; placement of a soil cap over the entire site; and institutional
controls, such as deed restrictions. Instead of on-site treatment, the amended soil remedy calls
for off-site disposal of soil in a permitted landfill, preceded by treatment, if the excavated soil
exceeds the TCLP hazardous waste criteria for PCP, arsenic and/or chromium.
The remedy for contaminated soil, as amended, continues to utilize treatment, although to a
lesser degree than the soil remedy contained in the 1996 ROD. Soil that exceeds the TCLP
Hazardous Waste criterion for PCP will be incinerated at a permitted off-site facility prior to
disposal. Soil (and ash resulting from incineration of site soil) that exceeds the TCLP
Hazardous Waste criteria for arsenic or chromium will be stabilized prior to disposal in a
permitted off-site landfill. During development of this ROD Amendment, on-site treatment of
wastes (i.e., stabilization) was evaluated to address the statutory preference for treatment to
permanently and significantly reduce the volume, toxicity, or mobility of principal threat
wastes. However, on-site stabilization of soil would result in a significant increase in the
volume of wastes to be managed on-site. Furthermore, the long-term reliability of
stabilization for organic contaminants (e.g., dioxin) is uncertain. Therefore, off-site treatment
(when necessary) and disposal was selected.
Date
epartment of Environmental Quality
Chuck Clarke
Regional Administrator
United Str.cs Environmental Protection Agency
Region 10
Date
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AMENDED RECORD OF DECISION
FOR
FINAL REMEDIAL ACTION
McCORMICK AND BAXTER CREOSOTING COMPANY
PORTLAND PLANT
PORTLAND, OREGON
DECISION SUMMARY
MARCH 1998
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AMENDED RECORD OF DECISION
McCORMICK AND BAXTER CREOSOTING COMPANY
PORTLAND PLANT
PORTLAND, OREGON
DECISION SUMMARY
Table Of Contents
Section Page
Introduction 1
Reasons for Issuing the ROD Amendment 6
Site History and Enforcement Activities 8
Scope and Role of Amended Soils Remedy 8
Summary of Site Characteristics 9
Summary of Site Risks 9
Description of the New Soil Remedial Action Alternatives 10
Evaluation of Soil Remedial Action Alternatives 20
The Selected Soil Remedy 25
Statutory Determinations 26
Documentation of Significant Changes '. 29
Illustrations
Figure ., Page
I Site Location Map 3
2 Site Map , .' 4
3 Primary Risk Drivers at Remedial Action Areas 14
Tables
Table Page
1 Remedial Action Area Dioxin data and Risk Summary 11
2 Total Excess Lifetime Cancer Risks On-site Worker Exposure Scenario 13
3 Evaluation Criteria for Alternatives 24
iii
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Appendix
Table Of Contents (Continued)
Appendices
A Responsiveness Summary A-1
B Administrative Record B-l
IV
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AMENDED RECORD OF DECISION
McCORMICK AND BAXTER CREOSOTING COMPANY
PORTLAND PLANT
DECISION SUMMARY
INTRODUCTION
Site Name and Location
The McCormick and Baxter Creosoting Company, Portland Plant site (McCormick & Baxter
or Site) is located at 6900 North Edgewater Street on the east bank of the Willamette River in
Portland, Oregon (Figure 1). The site covers approximately 43 acres of land and 15 acres of
sediment in the Willamette River (Figure 2). The site is downstream of Swan Island and
upstream of the St. John's Bridge.
Lead and Support Agencies
The Oregon Department of Environmental Quality (DEQ) is the lead agency for this Superfund
site, with cooperation and support of the United States Environmental Protection Agency
(EPA).
Statutory Citation for a Record of Decision Amendment
Section 117(c) of CERCLA, 42 USC §9617(c) provides for addressing and documenting
changes to the selected remedy after issuance of a Record of Decision (ROD). This ROD
Amendment documents the changes to the remedy set forth in the ROD. Additionally, since
fundamental changes are being made to the remedy, public participation and documentation
procedures specified in the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Section 300.435(c)(2)(ii) have been followed.
Date of Original Record of Decision
The original ROD is dated March 1996. It was signed on March 29, 1996 by EPA, and on
April 4, 1995 by DEQ.
Administrative Record
This ROD Amendment will become part of the Administrative Record file for this site, in
accordance with the NCP, Section 300.823(a)(2). The Administrative Record is available for
review at the St. John's Community Library, located at 7510 North Charleston Street,
Portland, Oregon, and at DEQ's Headquarters located at 811 Southwest Sixth Avenue (7th
Floor), Portland, Oregon. A third information repository, which contains most of the
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documents in the Administrative Record, is at the North Portland Neighborhood Office,
located at 2401 N. Lombard St., Portland, Oregon.
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H
>^^u>
McCormlck & Baxter
Site
Figure 1 SITE LOCATION MAP
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SCAU IN rcrr
200 400
800
Figure 2 SITE MAP
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Highlights of Community Participation
Community relations efforts prior to March 1996 are discussed in Section 3 of the original
ROD. The following community relations activities are relevant to this amended ROD. A
Responsiveness Summary is included as Appendix A.
April 1996 DEQ conducted a public meeting at the St. John's Community Center, on
April 23, 1996, to discuss cleanup for McCormick and Baxter, to respond to
comments received concerning the October 30, 1995 Proposed Plan, and to
discuss the March 1996 ROD.
May 1996 DEQ conducted a second public meeting to respond to comments concerning
the 1995 Proposed Plan and to discuss the 1996 ROD. This meeting was
held at the University of Portland on May 29. 1996.
July 1996 uEQ issued a fact sheet describing the Cooperative Agreement between
DEQ and EPA, ongoing groundwater remediation activities, preparation of
RD and RA planning documents, as well as discussing issues relating to site
security.
October 1996
January 1997
DEQ issued a fact sheet describing the Remedial Design Work Plan and
associated Sampling and Quality Assurance Plan, the Phase I Demolition
and Debris Removal Plan, and ongoing site activities.
DEQ issued a fact sheet notifying the public that Phase I demolition was
delayed due to the characterization of some materials as hazardous wastes
for disposal purposes. The fact sheet also described the December 1996 soil
sampling event and the plan to install a second water treatment system at the
Site.
March 1997 DEQ issued a fact sheet announcing that Phase I demolition would begin on
March 17, 1997, and describing the truck route, hours of operation, dust
control measures and other details.
May 1997 DEQ issued a fact sheet presenting the status of Phase I demolition, and
explaining the need for additional soil sampling to better define the extent of
dioxin contamination and to try to derive a proposed action level for han-
dling dioxin-contaminated soil. The fact sheet also described ongoing
groundwater remedial actions and announced mat a report pertaining to bio-
logical treatment of PAHs and PCP in soil was available for review.
August 1997 DEQ issued a fact sheet indicating that the current plan for cleaning up the
contaminated soil at McCormick & Baxter should be changed, due to the
widespread presence of dioxin at the Site. The fact sheet explained that di-
oxin cannot be effectively treated by biological treatment, the soil cleanup
technology selected in the ROD.
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October 1997 The Proposed Plan for the ROD Amendment was released to the public on
October 1, 1997. Notices were sent to each person on the mailing list for
the site, and were published in the Oregon Secretary of States' Bulletin, and
in The Oregonian, on October 1, 1997. The plan described the site
conditions necessitating a change to the selected soil remedy and identified
the preferred alternative proposed by DEQ and EPA for final cleanup of
contaminated soil at the site under Oregon's Environmental Cleanup Rules
and EPA's Superfund Law. The public comment period was officially open
from October 1 through October 31, 1997. A public meeting was held on
October 9, 1997 to present the plan and to allow for public comment and
testimony. EPA and DEQ responded to questions at the meeting, but no
public testimony was .received. Written comments from one individual were
submitted on October 31, 1997 and received on November 5, 1997 (see
Appendix A).
November 1997 On November 11, 1997, DEQ and EPA staff spoke at a meeting of the
Friends of Cathedral Park Neighborhood Association, to discuss the ROD
Amendment and to answers citizen's questions concerning the Site.
REASONS FOR ISSUING THE ROD AMENDMENT
Circumstances Prompting a ROD Amendment
The need for this ROD Amendment arose during soil sampling associated with design of the
original soil remedy. The soil sampling documented the widespread presence of dioxins in
soil. DEQ and EPA have determined that the remedy selected in the ROD is no longer
appropriate for soil cleanup, based on the extent of dioxin contamination found in the soils.
Soil Remedy Selected in the 1996 ROD
The major components of the selected remedy for contaminated soil contained in the original
ROD are described below:
• Excavation and on-site biological treatment and/or stabilization of approximately
30,000 cubic yards of soil contaminated above health-based action levels established
for PCP, PAHs (the primary constituents of creosote), and arsenic;
• Consolidation and capping of treated soil;
• Capping of all areas of the Site having soil contamination above established protective
levels (i.e., cleanup goals), but below the specified action levels for soil excavation
and treatment (essentially the entire site); and
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• Excavation and off-site treatment and disposal of approximately 1,000 cubic yards of
highly contaminated soil and other wastes that were not expected to be effectively tre-
ated on-site using bioremediation or stabilization. This 1,000 cubic yards of highly
contaminated soil was to include soil with significant dioxin concentrations (i.e.,
several orders of magnitude above protective levels); and
• Institutional controls, and long-term monitoring and maintenance, to ensure the
continuing integrity of the cap.
Subsequent Events and New Information
After the ROD was signed, DEQ began conducting remedial design activities. To prepare the
final remedial design for soil, field investigations, including additional soil sampling, were
conducted to refine the extent and volume of soil requiring treatment, identify soil
characteristics to confirm the efficacy of biological treatment, determine the magnitude of
dioxin contamination, and to confirm that there is no off-site contamination. These
investigations are described in the November 1997 Revised Draft Remedial Design Data
Summary Report, and are summarized below.
210 surface soil samples and 260 subsurface soil samples were collected, in December 1996,
and analyzed for arsenic, PAHs and PCP. Based on sampling results presented in the 1992
Remedial Investigation (RI) Report and in the 1995 Revised Feasibility Study (FS) Report, the
sampling locations included 14 contaminant source areas (e.g., the central processing area,
tank farm area, former waste disposal area, etc.), and other non-source areas, such as areas
that may require capping, the site perimeter and off-property locations along North Edgewater
St. and the east gate area. In addition, 20 of the surface soil samples were also analyzed for
dioxin. Two of those samples were collected from each of the major contaminant source areas
and one sample was collected from each of the other source areas.
The results of the December 1996 soil sampling indicated that contaminant concentrations
exceeded the cleanup goals in the 1996 ROD, virtually across the entire site, and that dioxin
contamination was much more widespread than previously believed (dioxin was detected in
each of the 20 samples collected). In addition, significant levels of dioxin (i.e., concentrations
several orders of magnitude above the cleanup goal) were found only in, or directly adjacent
to, areas that were slated for soil excavation and treatment (remedial action areas), because
contaminant concentrations for arsenic, PAHs and/or PCP in those areas exceed the action
levels in the 1996 ROD (see Figure 3). Accordingly, further sampling was conducted to better
characterize the nature and extent of dioxin contamination. Archived soil samples from the
December 1996 investigation were combined into 26 composite samples, in May 1997,
representing the 20 proposed remedial action areas, and areas along the site perimeter, North
Edgewater St. and the east gate area.
Based on the data gathered during these field investigations, DEQ determined that the volume
of soil to be excavated (i.e., soil exceeding the ROD's action levels) was lower than expected
(approximately 20,000 cubic yards versus the 30,000 estimated in the ROD). However,
dioxin contamination was found to be more widespread than originally believed, and dioxin
contamination was found to be co-located with the other contaminants of concern (PCP, PAHs
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and arsenic). On-site biological treatment was the method identified in the ROD to remediate
organic contaminants (PCP and PAHs). However, biological treatment is not an effective
treatment technology for dioxin. The ROD included a provision for off-site disposal of
approximately 1,000 cubic yards of soil that was not expected to be effectively treated on site,
but the post-ROD investigations indicated that the volume of such soil would be approximately
20,000 cubic yards, as described above.
Summary of DEQ and EPA Rationale for Changing the Selected Remedy
Based on the data collected during remedial design field investigations, DEQ and EPA began
to consider changing the soil remedy to specifically address the dioxin contamination in site
soil. DEQ conducted a risk evaluation (completed September 1997) to determine whether the
concentrations of dioxin found in site soil pose unacceptable risks. The risk evaluation
concluded that dioxin poses more risk than other contaminants, in 13 of the 20 areas
designated for soil excavation (remedial action areas) - see Tables 1 and 2, and Figure 3. The
risk evaluation is discussed further in the Summary of Risks section of this ROD Amendment.
Furthermore, DEQ and EPA determined that on-site biological treatment would not effectively
reduce the toxicity, mobility, or volume of dioxin. Although the original selected remedy
provides for off-site treatment and disposal of a limited volume of soil, the actual volume of
dioxin-contaminated soil that would be disposed off-site would be so much greater than
anticipated that it essentially would be inconsistent with the intent of the original ROD. In
order to remediate the dioxin-contaminated soil in a timely manner, and achieve protectiveness
of human health, DEQ and EPA considered alternative treatment and disposal methods.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The McCormick & Baxter site was proposed for addition to the National Priorities List (NPL)
on June 18, 1993. The Site was added to the NPL on June 1, 1994. In March 1996, after a
detailed study of the nature and extent of contamination at the Site and a detailed analysis of
cleanup alternatives, a remedy for the Site was selected and described in the ROD. A
complete description of the prior site history and enforcement activities is included in Section 2
of the ROD. Subsequent to the ROD, DEQ has continued to operate interim groundwater
remedial actions at the Site and has conducted demolition activities prescribed by the ROD.
SCOPE AND ROLE OF AMENDED SOILS REMEDY
This amended remedy is intended to be the final remedial action for contaminated soil at the
Site. The selected remedial actions for contaminated sediment and groundwater remain
unchanged from the original ROD. The purposes of those remedial actions are to prevent
current or future exposure to contaminated sediment, and to minimize NAPL discharges to the
Willamette River and NAPL migration to the deep aquifer, respectively.
Approximately 20,000 cubic yards of soil within four feet of the surface are contaminated with
dioxin, and with PCP, PAHs, and/or arsenic at concentrations exceeding excavation action
levels set in the ROD. The excavated soils will be taken to an off-site Resource Conservation
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and Recovery Act (RCRA)-permitted hazardous waste disposal facility, where any required
treatment of soils failing the RCRA toxicity characteristic leaching procedure (TCLP) for
Hazardous Waste determination will be conducted.
In addition, as provided in the 1996 ROD, the ROD Amendment requires that virtually the
entire site will be capped with two-feet of clean soil, to prevent current or future exposure to
the residual soil contamination. Capping of the Site will be followed by long-term monitoring
and maintenance, with institutional controls as necessary, to ensure that the Site remains
protective of human health and the environment.
SUMMARY OF SITE CHARACTERISTICS
Site characteristics are described in detail in the Summary of Site Characteristics section
(Section 5) of the original ROD. Information pertinent to changes in the remedial action for
soil at the Site is presented below.
As noted above, the data gathered during the remedial design field investigations, in December
1996 and May 1997, indicated that dioxin contamination was more widespread than previously
reported. The estimated volume of soil with significant levels of dioxin is now estimated to be
approximately 20,000 cubic yards versus the 1,000-cubic-yard estimate presented in the 1996
ROD. As defined in the ROD, "significant levels" of dioxin means concentrations several
orders of magnitude above the protective cleanup goal of 40 parts per trillion (ppt). In
addition, based on the available data, the significant levels of dioxin contamination are found
in the same soil areas where elevated concentrations of PCP, PAHs, and arsenic are found
(i.e., the areas where concentrations for those constituents exceed the excavation action levels
specified in the 1996 ROD).
With respect to off-property soil samples, none exceeded the action levels for excavation and
treatment of soil set forth in the ROD. One out of five surface soil samples collected along
North Edgewater Street, outside of the site fence, exceeded the (lower) cleanup goal for PAHs
and the composite sample from this area exceeded the cleanup goal for dioxin. Furthermore,
several samples collected inside the fence along the site perimeter exceeded the cleanup goals,
but not the excavation action levels, for PAHs and/or arsenic, and the cleanup goal for dioxin.
SUMMARY OF SITE RISKS
After completing the remedial design investigation, DEQ conducted a supplemental risk
evaluation (the original risk assessment for the Site was completed in 1992) to determine the
results of the soil removal action that was conducted in 1994, and to evaluate the significance
of the newly collected dioxin data. During the 1994 removal action, 377 tons of the most
highly contaminated soil were excavated and disposed off site. As a result of that removal, the
maximum dioxin concentration at the Site was found to be lower in the December 1996
sampling than previously reported (380 parts per billion before the removal action, versus 75
pans per billion after the removal action). Although risks calculated during the supplemental
risk evaluation are not significantly different than those reported in the 1992 risk assessment,
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the new data indicated that dioxin contributes more significantly than other contaminants to site
risks, because dioxin contamination is more widespread than previously reported.
A summary of the dioxin data collected from each of the planned remedial action areas is
presented in Table 1, along with the total excess lifetime cancer risks (from all site-related
compounds) calculated for each of these areas. Table 2 presents the excess lifetime cancer risk
from each contaminant of concern, as well as the total excess lifetime cancer risk, for each of
these areas. These risks represent the potential probability that a future site worker could
develop cancer, if no remedial action occurred at the Site, and if exposed to contaminants in
soil through incidental ingestion, dermal contact, and inhalation of wind-blown particulates,
over a lifetime of working at the Site. Figure 3 depicts the approximate remedial action areas
and shows the contaminant that is the primary risk driver at each area. DEQ and EPA
determined that biological treatment of soil at these areas would not adequately reduce risks
associated with 13 of these 20 areas, because dioxin is not believed to be amenable to
biological treatment.
This ROD Amendment does not change the risk-based action levels and cleanup goals
identified in the 1996 ROD, nor does it add an action level for dioxin, because dioxin is co-
located with other contaminants of concern. Therefore, soil excavation based on the original
action levels, followed by capping areas exceeding the original cleanup goals, will achieve the
level of protection envisioned in the 1996 ROD. Protectiveness is based on continued
industrial land use or open space recreational use of the Site.
DESCRIPTION OF THE NEW SOIL REMEDIAL ACTION ALTERNATIVES
The three alternatives considered by DEQ and EPA to replace the remedy for contaminated
soil described in the 1996 ROD are discussed below. Pursuant to Section 121(d) of CERCLA,
remedial actions shall, 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.
All of the soil cleanup alternatives under consideration would be designed to meet applicable
or relevant and appropriate requirements (ARARs). Since the alternatives considered during
development of this ROD Amendment incorporate similar components and technologies to the
alternatives included in the 1996 ROD, the ARARs have not changed significantly. The
ARARs specific to the soil remedy are discussed below:
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Table 1
REMEDIAL ACTION AREA DIOXIN DATA AND RISK SUMMARY
Site Area
Log Storage
Area
Pole Dryer
Area
East Yard
Area
Stacker
Shed Area
Southern
Corner Area
Former
Waste
Disposal
Area
Central
processin"
Area
Southeast
Waste
Disposal
Trench
Remedial
Action
Area
RA1
RA2
RA3
RA4
RA5
RA6
RA7
RA8
RA9
RA11
RA10
RA12
RA13-A
RA13-B
RA13-C
RA14
RA15
RA16
Sample
Locations
(Sample Type)1
LSA4, LSA5
(Composite)
LSAT7. LSA19
(Composite)
LSA14 (Grab)
PDA25. PDA27,
PDA28, PDA29
(Composite)
PDA28 (Grab)
EYA35, EYA38
(Composite)
EYA44 (Composite-
multiple depths)
EYA35 (Grab)
SSA119. SSA77.
SSA83 (Composite)
SSA79 (Composite-
multiple depths)
SSA91, SSA95
(Composite)
SSA92 (Composite-
multiple depths)
SSA85 (Grab)
SCA56 (Composite-
multiple depths)
SCA57 (Grab)
FWD205
(Composite-multiple
depths)
FWD205 (Grab)
FWD214
(Composite-multiple
depths)
FWD211. FWD212
(Composite)
FWD214 (Grab)
CPA226 (Composite-
multiple depths)
CPA232, CPA233
(Composite)
CPA238, CPA239,
CPA241 (Composite]^
CPA243. CPA244
(Composite)
SEW290 (Grab)
SEW293 (Grab)
SEW294
Sample
Depth
(feet bps)
0-1
0-1
0.5
0-1
0.5
0- 1
0- 1
05
0- 1
0- 1
0-1
0-1
0.5
0- 1
0.5
0-4
05
0- 10
0- 10
05
0- 10
0 -4
0-4
0- 10
05
05
0-4
Dioxin TEQ
Concentration
(ppt)
6,140
29.930
4,076
74,903
50.606
1.280
2,53o
1,280
3,276
2,386
5,016
25,450
129
625
933
3.780
2.305
47,320
16.125
480
346
56,650
5,750
51,980
5.534
6.665
756
Primary
Remedial
Action Area
Risk Driver
Dioxin
Dioxin
Dioxin
Arsenic
Dioxin
Dioxin
Dioxin
Dioxin
Dioxin
Arsenic
Dioxin
Dioxin
Arsenic
Dioxin
PCP
Dioxin
Dioxin
Arsenic
Total Excess
Lifetime Cancer
Risk:
On-site Worker2
7X10J
3 X 10°
7X 10^
8X10-
4X 10-
5X 10"
4X 10-
5X 10"
2 X 10 3
2 X 10"
7 X 10"
9X10J
4 X 10"
5 X 10 J
2 X 10 •'
6X 10"
8X 10"
2X 10"
-------
Table 1
REMEDIAL ACTION AREA DIOXIN DATA AND RISK SUMMARY
Sit* Area
Tank Farm
Area
Creosote
Tank
Area
Remedial
Action
Area
RA17
RA18
Sample
Locations
(Sample Type)1
(Composite-multiple
depths)
TFA251. TFA253
(Composite)
TFA251 (Grab)
TFA256 (Grab)
CTA262
(Composite-multiple
depths)
CTA262 (Grab)
CTA268 (Grab)
Sample
Depth
(feet bgs)
4- 10
0.5
0.5
4-10
0.5
0.5
Dioxln TEQ
Concentration
(ppt)
3.650
3.222
1.917
40
0.27
261
Primary
Remedial
Action Area
Riik Driver
PAHs
PAHs
Total Excevs
Lifetime Cancer
Risk:
On-site Worker2
1 X 10°
2X10"
1 Dioxin data are presented for areas where concentrations of at least one contaminant exceed site-
specific action levels.
2 Total excess cancer risk includes risks from all compounds
Abbreviations:
TEQ 2,3.7,8-Tetrachlorodibenzo-p-dioxin toxicity equivalents.
Bgs Below ground surface.
Ppt parts per trillion (nanograms/kilogram).
Notes:
The soil cleanup goal for dioxin TEQ concentration, as established in the 1996 ROD, is 40 ppt.
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Table 2
TOTAL EXCESS LIFETIME CANCER RISKS
ON-SITE WORKER EXPOSURE SCENARIO
Remedial
Action
Areas
RA1
RA2
RA3
RA4
RA5
RA6
RA7
RA8
RA9
RA10
RA11
RA12
RA13 A
RA13B
RA13C
RA14
RA15
RA16
RA17
RA18
Dioxin
5X10"
2X10"
6X10"J
1 X10"
2X10"
3X10"
2X10"
4X10"
2X10^
3X10"
5X10S
4X10^
3X10°
5X10J
4X10J
5 X 10"
6X10"
6X103
3X10"
3X10*
Arsenic
2X 10"
2X10"
5X10"
6X10"
1 X10"
3X 10"
1 X 10"
1 X 10"
1X10"
1X10"
2X10"
1 X 10 J
3X 10"
3X 10"
5X103
ex 10*
1X10"
9X103
3X 10*
6X 10'
Pentachlorophenol
1 X 10*
2X 10°
5X103
4X10*
1 X10*
4X10*
2X 10°
1 X10*
6X10*
1 X10"
3X10"
2X10J
2X10*
2X10"
2X10*
2X10°
2 X 103
8 X 10 '
2X103
NO
Carcinogenic
Polycyclic
Aromatic
Hydrocarbons
9X10*
1 X103
8X100
4X 10'5
5X10*
5X 10*
4X 10s
8X 10*
8X 10 D
2X10"
3X 10*
2X 10 J
2X 10'
2X10"
3X10"
1 X10"
1 X10"
2X 10*
7X10"
2X10"
TOTAL
7X10"
3X10J
7X10°
8X10"
4X10"
5X10"
4X10"
5X10"
. 2 X 10 J
7X10"
2X10"
9 X 10 J
4X10"
5X10J
2X10'
6X10"
8X10"
2X10"
1 X 10'J
2X10"
Key:
ND = Not detected
Notes:
The most significant risk driver at each area is shaded.
13
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0 100 200 300 400
!5SS
FEET
PAHs or PCP
Figure 3 PRIMARY RISK DRIVERS AT REMEDIAL ACTION AREAS
-------
Chemical-Specific ARARs. Chemical-specific requirements are usually health-based or risk-
based numerical values or methodologies that establish the acceptable amount or concentration
of a chemical in the ambient environment. No Chemical-specific ARARs apply to the
proposed soil cleanup alternatives.
Location Specific ARARs. Location-specific requirements are restrictions based on the
conduct of the activities in specific locations. These may restrict or preclude certain remedial
actions or may apply only to certain portions of a site.
• Executive Order 11988, Floodplain Management, and Executive Order 11990,
Protection of Wetlands, May 24, 1977 incorporated in 40 CFR Part 6, Appendix A;
Federal Clean Water Act, Section 404, 42 USC §1344. These requirements regulate
actions that occur in wetlands and flood plains and may be applicable to actions that
may adversely affect wetlands and flood plains.
Action-Specific ARARs. Action-specific requirements are restrictions on certain activities at
a site.
• Solid Waste Disposal Act, also known as the Resource Conservation and Recovery Act,
Subchapter III, (42 USC § § 6921-6939; 40 CFR Parts 261-264 and 268); and, Oregon
Hazardous Waste Management Act (ORS 466.005 et seq.). State management of
hazardous waste is authorized in the Oregon Hazardous Waste Management Act (ORS
466.005 et seq.). The law is implemented by regulations that are codified at OAR 340-
100-001 et seq. Oregon hazardous waste management regulations adopt by reference
most of the substantive provisions of Subtitle C of RCRA. Subtitle C is the primary
federal law for the management of hazardous waste. The principal federal regulations
that implement Subtitle C are codified in 40 CFR Parts 260-271. If federal and Oregon
hazardous waste laws conflict, the more stringent law will be followed. The specifics
of how RCRA applies to or is relevant and appropriate for cleanup activities at this site
are discussed in greater detail in the following section.
• CFR Part 261: Identification and Listing of Hazardous Waste. Part 261 contains
RCRA definitions and criteria for identifying hazardous waste. All listed or character-
istic wastes transported off-site for treatment and/or disposal will comply with these
regulations.
• CFR Part 262: Standards Applicable to Generators of Hazardous Waste. The
regulations in Part 262 establish standards for generators of hazardous waste regarding
manifesting, pre-transportation requirements, record keeping and reporting, and exports
of hazardous waste. All hazardous wastes generated at the Site, such as excavated soil,
will be managed in accordance with these regulations.
• CFR Part 263: Standards Applicable to Transporters of Hazardous Waste. Part 263
establishes standards for transporters of hazardous waste including manifesting, record
keeping, and hazardous waste discharge response requirements. In the regulations set
forth in Parts 262 and 263, EPA has expressly adopted certain regulations of the
Department of Transportation (DOT) governing the transportation of hazardous
15
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materials. Refer to the description of the requirements for transportation of hazardous
materials (49 CFR 171-177) in the next section. All hazardous wastes transported from
the Site will be managed in accordance with these regulations.
• CFR Part 264: Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities. This ROD Amendment eliminates the on-site
treatment portion of the soil remedy. Also, excavation, consolidation, stockpiling, and
sorting of soil and debris, and replacement of concrete rubble, will be conducted within
the area of contamination (AOC) at the Site. Therefore, these regulations are no longer
applicable. Also, there is no longer a need to designate a portion of the Site a
Corrective Action Management Unit (CAMU), as was done in the 1996 ROD. This
ROD Amendment removes that designation. Landfill closure requirements are relevant
and appropriate for the Site and will be met through a hybrid landfill closure. The
requirement for an impermeable cap is not met, since protection of groundwater is not
one of the Remedial Action Objectives for the Site.
• Procedures for Planning and Implementing Off-Site Response Actions (40 CFR
300.440). This regulation is applicable to, and will be complied with, for all wastes
that are transported off-site for treatment and/or disposal.
• Endangered Species Act (16 USC 1531 et seq.). Peregrine Falcon have been observed
near the Site; however, no nests or use of the Site by this protected bird have been
observed. If Peregrine Falcon are observed at the Site during implementation of the
remedy, precautionary steps will be taken to protect their habitat, in accordance with
this regulation.
• Oregon Hazardous Substance Remedial Action Act and Rules (ORS 465.200 et seq.)
The selected remedy meets the substantive requirements of these applicable regulations.
Policy, Guidance, and Regulations To-Be-Considered. Additional policies, guidance, and
other laws and regulations to be considered for source control and remedial actions include,
but are not necessarily limited to, the following.
• Transportation of Hazardous Materials (49 CFR 171-177; OAR 860-66-001 et seq.)
Transporters must comply with U.S. Department of Transportation labeling, contain-
ment, and spill reporting regulations found in 49 CFR, Subchapter C. Transportation
of hazardous waste by rail or highway must comply with regulations of the Public
Ut;lity Commissioner (OAR 860-66-001 et seq.), which adopt by reference U.S.
Department of Transportation regulations in Title 49 CFR. These regulations are
applicable for hazardous or dangerous waste disposed off-site. The selected remedy
will comply with these federal and related state regulations.
• EPA Area of Contamination Policy (Federal Register Volume 55, No. 46. March 8,
1990, pages 8759-8760). Excavation, consolidation, stockpiling, and sorting of soil
and debris, and replacement of concrete rubble, will be conducted within the AOC at
the Site.
16
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• Willamette Greenway Plan. DEQ has received Land Use Compatibility Statements
demonstrating that the selected remedy is consistent with these requirements.
• The Lower Willamette River Management Plan (LWRMP). Requirements of the
LWRMP are waived for environmental cleanup plans selected by DEQ and developed
in consultation with the Division of State Lands.
The most significant ARARs affecting the development and selection of cleanup alternatives
for the soil remedy for the McCormick & Baxter site are the regulations implementing RCRA
and the Oregon Hazardous Waste Management Act.
The regulations in 40 CFR Part 261 and parallel Oregon regulations (ORS 466.005 et seq;
OAR340-100-001 et seq) contain definitions and criteria for identifying RCRA hazardous
waste. Listed waste codes associated with the residuals from the wood-preserving processes
used at the McCormick & Baxter site are F032, F034, and F035. Although McCormick &
Baxter ceased operations prior to the effective dates of the F032, F034, and F035 listings in
Oregon (October 16, 1992, for F034 and F035, and June 6, 1991, with a conditional stay until
February 6, 1992, for F032), media contaminated with waste that meets the definition of a
listed hazardous waste takes on that waste designation when it is actively managed (i.e.,
treated, stored, or disposed under RCRA) outside the area of contamination (AOC). Because
the entire McCormick & Baxter site is contaminated to varying degrees, DEQ and EPA have
designated the entire site an AOC. Transfer of soil to a newly constructed, engineered unit
(for example, a stabilization unit under Alternative 2 below) is considered to be outside of the
AOC.
In addition, the contaminated medium may require management as a characteristic hazardous
waste, based on the toxicity characteristic for PCP (waste code D037), arsenic (waste code
D004) and/or chromium (waste code D007).
For those RCRA hazardous wastes that are disposed off-site or managed on-site outside the
AOC, and are RCRA listed or characteristic wastes, substantive RCRA 40 CFR 264 and 268
standards are applicable. This will primarily affect alternatives involving treatment of the
wastes. The regulations in 40 CFR 268 set standards that must be met before a hazardous
waste can be land disposed. Currently there is a two-year National Capacity Treatment
Variance (expiring May 12, 1999) from the Land Disposal Restrictions (LDRs) for the soil
designated as F032, F034 and F035 wastes. Therefore, these F-listed wastes will not require
treatment prior to land disposal on or before May 12, 1999, unless the wastes are also
characteristic wastes. These wastes would be considered characteristic (i.e., carry the D004,
D007, or D037 waste codes discussed above), if the leachate concentration exceed the criteria
specified 40 CFR Section 261.24. Therefore, under Alternatives 2 and 3 below, excavated
soil for which the leachate concentrations exceeds the criteria for PCP, arsenic, and/or
chromium would be treated prior to land disposal, by stabilization, incineration, or potentially
some other method, depending on the waste constituents and characteristics, and the
regulations in place at the time of disposal. Because no RCRA waste would be generated (i.e.,
excavated) under Alternative 1 below, no RCRA requirements are applicable or relevant for
that alternative.
17
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Where the substantive RCRA hazardous waste requirements are not applicable, they may still
be relevant and appropriate. At the McCormick & Baxter site, RCRA closure requirements
have been determined to be relevant and appropriate for contaminated soil within the AOC that
poses an unacceptable threat to human health and the environment.
EPA rules allow contaminated soil and other wastes to be excavated and consolidated and/or
replaced within an AOC, and processed within an AOC (but not in a separate unit such as a
tank), without the activity constituting a new placement of the soil that would cause the soil to
become regulated as a hazardous waste (46 FR 8758). Therefore, the RCRA closure
regulations of 40 CFR Part 264 are not applicable to the excavation, consolidation,
stockpiling, and sorting of the soil and debris, nor to the use of concrete rubble for backfill at
the Site. The requirements of 40 CFR Part 264 may be applicable to any alternative that
involves ex-situ treatment and replacement of hazardous waste soil (e.g., Alternative 2), unless
a CAMU is established.
Each alternative also includes institutional controls, as described in the 1996 ROD, which will
be used to prevent exposures to residual contamination remaining at the Site following
remedial action. Institutional controls will apply to current and all future landowners. Some
institutional controls, such as perimeter fencing and warning signs are already in place and
would be maintained until completion of the remedial measures. Other institutional controls,
such as deed restrictions, would include specific DEQ and EPA notification requirements, as
well as property restrictions, limiting the future use and development of the property to uses
consistent with the remedial action objectives specified in the ROD (i.e., health protectiveness
in an industrial land use or open space recreational scenario). Specific deed restrictions also
would inform future owners of the nature and extent of residual contamination on the property
and mandate precautions to be taken prior to disturbance of the cap or excavation. The deed
restrictions may include the granting of an environmental protection easement, that would
provide DEQ with continued future access to the site. Deed restrictions, along with other
components of the remedy, will be evaluated no less than every five years, to ensure that the
remedy continues to provide an adequate level of protection of human health and the
environment. A more comprehensive discussion of the institutional controls to be used may be
found in Sections 8.1.2 and 10.3.5 of the 1996 ROD.
The summary of alternatives presented below includes a cost estimate and estimated time
frame for completion of each remedial alternative. Cost estimates for each alternative are
given in present-value (1997) dollars and include design, construction, and long-term operation
and maintenance (O&M) costs. In accordance with EPA guidance, O&M costs were estimated
for a 30-year period; however, O&M activities at this site may extend beyond 30 years. The
cost estimates are believed to be accurate within -1-50 to -30 percent. Estimated time frames
include construction, operation and maintenance of the remedial alternatives. However, some
institutional controls will remain indefinitely.
In accordance with EPA's and DEQ's regulations, a uno action" alternative must be
considered. The No Action Alternative serves as a baseline against which other alternatives
are evaluated. In the case of this ROD Amendment, the soil remedy selected in the 1996 ROD
serves as the No Action Alternative. As discussed above, DEQ and EPA have determined that
18
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this alternative is not protective. Therefore, it is not evaluated further. The following sections
discuss the three new alternatives considered by DEQ and EPA.
Alternative 1: Capping in Place
Alternative 1 includes building demolition and debris removal (which has been partially
completed), site clearing, grading, and placement of a 2-foot thick cap of clean soil across the
entire McCormick & Baxter property. Concrete rubble from on-site, above-ground demolition
activities would be used to fill existing in-ground concrete sumps and vaults, prior to capping.
Any soil outside the site fence that was contaminated as a result of the wood-treating
operations, and which exceeds the established cleanup goal concentrations, would be excavated
and moved onto the site property to be capped. The cap design would include a gravel layer, a
soil layer, and a topsoil/vegetation cover, consistent with the 1996 ROD.
- Estimated Capital Cost: $3.55 million
- Estimated Annual O&M Costs: $0.56 million
- Estimated Total Present Value Cost: $4.11 million
- Estimated Implementation Time Frame: 3 to 6 months construction, 30 years O&M.
Alternative 2: On-Site Stabilization, Consolidation, and Capping
Alternative 2 includes all of the elements of Alternative 1, plus the excavation of soil with
contamination exceeding the actions levels established in the 1996 ROD. Excavated soil would
be stabilized on site with a mixture of Portland cement, fly ash, and activated carbon, to
reduce contaminant mobility. This alternative would retain the RCRA corrective action
management unit (CAMU) designated in the 1996 ROD, to allow for on-site treatment of
hazardous wastes. The CAMU could be necessary to address RCRA land disposal restrictions
or minimum technology requirements that are applicable to treatment and/or placement of
hazardous wastes. Stabilized soil would be placed in consolidation cells on site, prior to
capping the Site. Clean soil would be imported to the site to backfill the soil excavations.
Following this backfilling, the site will be capped, as in Alternative 1. This alternative also
includes off-site treatment and disposal of approximately 2,000 cubic yards of the most highly
contaminated soil and other wastes that are not expected to be effectively stabilized on site.
Because this 2,000 cubic yards of soil would be managed outside of the CAMU (i.e., off site
at a RCRA-permitted disposal facility), land disposal restrictions and minimum technology
requirements would be applicable. All wastes that are excavated and treated and/or disposed
either on- or off-site will be managed in accordance with the applicable RCRA standards.
- Estimated Capital Cost: $9.08 million
- Estimated Annual O&M Costs: $0.56 million
Estimated Total Present Value Cost: $9.64 million
- Estimated Implementation Time Frame: 1 year construction, 30 years O&M.
19
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Alternative 3: Excavation, Off-site Disposal, and Capping
Alternative 3 includes all of the elements of Alternative 1 and soil excavation as described in
Alternative 2. However, unlike Alternative 2, excavated soil would be disposed off site. Off-
site treatment of soil prior to disposal would also be required, when leachate from that soil
exceeds the established RCRA hazardous waste criteria for arsenic, chromium, or PCP using
the toxicity characteristic leaching procedure (TCLP) . Soil exceeding the TCLP criteria for
arsenic or chromium would be stabilized, and soil exceeding the TCLP criterion for PCP
would be incinerated, prior to disposal, under the current regulations. The treatment, if
needed, would be conducted at an off-site RCRA-permitted treatment, storage and disposal
facility, in accordance with the regulations in effect at that time. Excavations would be
backfilled with clean soil, as in Alternative 2, and the site would be capped, as in Alternatives
1 and 2.
- Estimated Capital Cost: $10.23 million
- Estimated Annual O&M Costs: $0.56 million
- Estimated Total Present Value Cost: $10.79 million
Estimated Implementation Time Frame: 6 months to 1 year construction, 30 years
O&M.
EVALUATION OF SOIL REMEDIAL ACTION ALTERNATIVES
EPA and DEQ criteria, defined in Table 3, are used to compare the alternatives, to determine
their relative performance and to identify their respective advantages and disadvantages.
Overall Protection of Human Health and the Environment
All of the alternatives satisfy this criterion. All of the alternatives reduce risks by eliminating
direct contact with contaminated soil by capping the Site. Continued protectiveness, however,
is dependent on maintenance of the site cap. Some incremental reduction in risk is realized for
Alternative 2 by stabilizing excavated soil and by removing approximately 2,000 cubic yards
of highly contaminated soil. Under Alternative 3, an incremental reduction in long-term risk
is realized through removal of approximately 20,000 cubic yards of highly contaminated soil
for treatment (when applicable) and disposal at an off-site RCRA-permitted facility. Protective
cleanup goals for all alternatives are based on assumed continued industrial use of the
property. However, consistent with the 1996 ROD, these cleanup goals would also be
protective for open space recreational use.
20
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Compliance with ARARs
All of the cleanup alternatives under consideration would be designed to meet applicable, or
relevant and appropriate, criteria or standards. All wastes that are excavated and treated either
on- or off-site will be managed in accordance with the appropriate RCRA standards. The
alternative involving on-site treatment and placement (in a treatment cell) of hazardous wastes
(Alternative 2) would retain the designation of a RCRA CAMU, as provided in the 1996
ROD. The CAMU would allow for on-site treatment and for site-specific cleanup standards,
rather than those dictated by the RCRA land disposal restrictions.
Long-Term Effectiveness
Alternative 3 best satisfies this criterion, since it includes removal of the largest quantity of
highly contaminated soil from the Site, and poses the least risk should the cap fail. All of the
alternatives rely, to some degree, on capping the Site, to attain long-term effectiveness, and all
would satisfy this criterion, as long as the soil cap is not disturbed. The long-term
effectiveness and permanence of the cap can be assured through restrictions on cap disturbance
or penetration and by required inspection and maintenance of the cap. Compared to
Alternative 1, Alternative 2 (stabilization) should increase the long-term effectiveness and
permanence, and removes about 2,000 cubic yards of highly contaminated soil. However,
treatability tests would be required to determine risks associated with solidified soil and the
long-term reliability of such treatment, particularly for organic contaminants.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternative 1 does not provide any reduction of toxicity, mobility, or volume of contaminated
soil through treatment. However, the mobility of soil contaminants through soil erosion and
contact with surface water would be reduced, due to the cap. Alternative 2 involves a
reduction in mobility of contaminants for the more highly contaminated soil through
stabilization; however, stabilization results in a significantly increased volume of material to be
managed. Additional reduction in mobility is realized, due to the cap, as discussed in
Alternative 1. Alternative 3 may involve some treatment prior to disposal at a permitted off-
site facility. Under current regulations, soil exceeding the TCLP hazardous waste criteria for
arsenic and chromium would be stabilized prior to disposal, resulting in reduced mobility and
increased volume. Soil exceeding the TCLP Hazardous Waste criterion for PCP would be
incinerated prior to disposal, resulting in reduced toxicity through destruction of the
contaminants. Alternative 3 would achieve the greatest reduction in the volume of
contaminated soil remaining on site, but not through treatment.
21
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Short-Term Effectiveness
Each of the alternatives would create some risk to site workers during construction of the cap.
Also, site clearing and grading and placing the cap would result in dust production, and noise
which could impact neighboring properties and significant increases in truck traffic. However,
air monitoring and dust suppression measures, such as watering, would be used to minimize
transport of dust to nearby residential areas. There would also be a significant increase in
truck traffic, if the clean soil for the cap was delivered by trucks. However, use of barges is
more likely. Alternatives 2 and 3 create some additional risk to site workers and neighbors,
during the excavation of the contaminated soil, as a result of increased dust production, noise,
and truck traffic. It should be noted that the good planning and implementation during recent
demolition activities at the Site resulted in no complaints to DEQ about increased truck traffic,
but rail transportation is also being considered. Alternative 2 has the greatest short-term risk
to site workers and neighbors, due to the increased potential dust generation during soil
handling for the solidification process. In addition, Alternative 2 would have the longest time
frame tur implementation - an estimated 1 year, versus an estimated six months to one year for
Alternative 3 and an estimated 3 to 6 months for Alternative 1.
Irnplementability
Alternative 1 would be the easiest alternative to implement, since it only involves capping.
Alternative 3 is also easily implemented. In addition to capping, it includes excavation and
transportation to a permitted off-site disposal facility; any treatment required would be
conducted at the disposal facility. Alternative 2 would require establishment of an on-site
treatment facility and construction of an earthen berm to contain treated soil. Treatability
testing would be required to determine the optimum mix of stabilizing agents and the reliability
of stabilization under Alternative 2, particularly for organic contaminants. Materials,
equipment, and labor are readily available for all of the alternatives.
Costs
The total estimated present value cost, for the original soil remedy in the 1996 ROD, was
$10.66 million. The total estimated present value costs for the three proposed Alternatives-
are:
Alternative 1: $4.11 million
Alternative 2: $9.64 million
Alternative 3: $10.78 million
Because all three alternatives utilize materials, equipment, and labor that are readily available,
these cost estimates are considered to have an acceptable degree of certainty and to be
proportionate to the risk reduction achieved.
22
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Supporting Agency Acceptance
Although EPA is responsible for issuance of this ROD Amendment, DEQ is the lead agency
for implementing the remedial actions at the site. All of the alternatives are acceptable to
DEQ.
23
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TABLE 3 - EVALUATION CRITERIA FOR ALTERNATIVES
EPA Criteria
Overall protection of human health and the environment • How well does the alternative protect human
health and the environment, both during and after construction?
Compliance with federal and state environmental standards - Does the alternative meet all applicable or
relevant and appropriate requirements (ARARs)?
Long-term effectiveness and performance - How well does the alternative protect human health and the
environment after completion of cleanup? What, if any, risks remain at the Site?
Short-term effectiveness - Are there potential adverse effects to either human health or the environment
during construction or implementation of the alternative? How fast does the alternative reach the cleanup
goals?
Reduction of toxicity, mobility, or volume through treatment - Does the alternative effectively treat the
contamination to significantly reduce the toxicity, mobility, and volume of the hazardous substance?
Implementability - Is the alternative both technically and administratively feasible? Has the technology
been used successfully on other similar sites?
Cost - What are the estimated costs of the alternative?
State (or supporting agency) acceptance - What are the DEQ's comments or concerns about the
alternatives considered and the preferred alternative?
Community acceptance - What are the community's comments or concerns about the preferred alterna-
tive? Does the community generally support or oppose the preferred alternative?
DEQ Criteria
Protectiveness - Is the alternative protective of present and future public health, safety, and welfare, and
the environment? See EPA criterion "overall protection of human health and the environment".
Effectiveness - What is the magnitude of risk from untreated waste remaining absent of any risk reduction
achieved through onsite management of exposure pathways? What is the adequacy of engineering and
institutional controls? Time until remedial action objectives would be achieved? See EPA criterion 'long-
term effectiveness and performance".
Long-term reliability - What is the reliability of treatment technologies in meeting treatment objectives?
What is the reliability of engineering and institutional controls necessary to manage the risk from treatment
residuals and untreated hazardous substances left on site?
Implementability - see EPA criterion "implementability".
Implementation risk - See EPA criterion "short-term effectiveness'.
Reasonableness of cost - See EPA criterion "costs". In addition, what is the degree to which the costs of
the remedial action are proportionate to the benefits to human health and the environment created through
risk reduction or risk management? What is the degree of sensitivity and uncertainty of the costs?
Treatment of hot spots - To what extent does the remedial action alternative treat hot spots of
contamination?
24
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Community Acceptance
Only one written comment was received during the 30-day public review and comment period.
The commentor raised a number of questions, but supported DEQ's and EPA's preferred
alternative, Alternative 3. Informal, verbal comments received at two public meetings were
also generally supportive of Alternative 3 (see Appendix A).
Long-Term Reliability
Alternative 3 offers the greatest degree of long-term reliability, because, to the greatest extent
feasible, the most highly .contaminated soil would be excavated and treated and/or disposed off
site at a RCRA-permitted disposal facility. For Alternative 2 (on-site stabilization), wastes
would remain on site, but in a less mobile state. Treatability tests would be required to
determine the long-term reliability of stabilization. For all three alternatives, the long-term
reliability of the cap can be assured through restrictions on cap disturbance or penetration, and
by required inspection and maintenance of the cap.
Treatment of Hot Spots
Alternatives 2 and 3 satisfy this criterion, because hot spots of contamination are excavated to
the extent feasible and are treated either on or off site. Alternative 1 does not satisfy this
criterion.
THE SELECTED SOIL REMEDY
Based on the new site data and the difficulty of treating dioxin-contaminated soil on site, DEQ
and EPA have determined that excavation and off-site treatment and disposal is the most
appropriate and protective remedy for contaminated soil. This remedy is preferred because it
best satisfies the nine criteria. In particular, this remedy provides the greatest overall
protection of human health and the environment, because approximately 20,000 cubic yards of
the most highly contaminated soil will be removed from the site. It also provides the highest
degree of long-term effectiveness and achieves the greatest reduction in toxicity, mobility or
volume. The selected remedy includes:
• Completion of demolition and off-site disposal or recycling (except for concrete
rubble) of above-ground structures and debris, and of underground structures that
interfere with soil excavation;
• Excavation, to a maximum depth of approximately 4 feet, of contaminated soil that
exceeds the action levels for arsenic, PAHs, and PCP, established in the 1996 ROD.
25
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• Use of engineering controls during excavation and transportation, such as dust
suppression with water sprays, truck washing prior to leaving the site; lining and
covering trucks and/or rail cars during loading and transport; and planning truck
routes and schedules to minimize potential adverse impacts on the surrounding
community;
• Off-site treatment of excavated soil that exceeds the toxicity characteristic leaching
procedure (TCLP) hazardous waste criteria for arsenic, chromium, and/or PCP,
established under the Resource Conservation and Recovery Act (RCRA);
• Off-site disposal of excavated soil at a RCRA-permitted hazardous waste disposal
facility, following any required treatment, as described above;
• Excavation of any soil beyond the property boundary with site-related contaminant
concentrations above the cleanup goals, and placement of that soil onto the Site
property to be capped;
• Backfilling of in-ground concrete sumps, vaults, etc. with concrete rubble from on-
site demolition activities, and bacfilling of soil excavations with clean soil imported
to the Site;
• Placement of a two-foot thick, clean soil cap over the entire Site, as described in the
1996 ROD, followed by long-term monitoring and maintenance; and
• Establishment of institutional controls, as described in the 1996 ROD, including but
not limited to, deed notices containing information on the levels and location of
contamination on the property, and deed restrictions, such as environmental ease-
ments or restrictive covenants limiting future uses of the Site to industrial/commercial
or open-space recreational activities. The deed restrictions will prohibit future land
uses not consistent with the level of protectiveness achieved by the cleanup. Deed
restrictions may also include requirements for routine maintenance and repair of the
cap, restrictions on soil excavation activities, without the necessary health and safety,
and engineering controls, and the proper disposal of any contaminated soil excavated
during installation or maintenance of underground utilities by future owners or
lessees, as applicable. Deed restrictions will be set forth in a DEQ-approved form,
running with the land and enforceable by DEQ against present and future owners of
the property.
STATUTORY DETERMINATIONS
The amended remedy satisfies the provisions of Section 121 of CERCLA, 42 USC §9621 and
the Oregon Revised Statutes (ORS) 465.315. DEQ and EPA believe that the amended remedy
is protective of human health and the environment. Section 121 of CERCLA establishes
several other statutory requirements and preferences. These preferences specify that, when
complete, final remedial actions must comply with ARARs and must be cost-effective and
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utilize permanent solutions and alternative treatment technologies or resource recovery
technologies, to the maximum extent practicable. In addition, the statute establishes a
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. The following sections discuss how the selected remedy meets these requirements.
Protection of Human Health and the Environment. The selected remedy is protective of
human health and the environment. The future land use at the Site will be restricted to
industrial or open space recreational uses, and the selected remedy is protective for these uses
at all points of exposure to each contaminated medium.
Soil contamination at the Site includes a mixture of both organic and inorganic contaminants.
Through on- or off-site treatment, off-site disposal, and containment, the selected remedy will
eliminate the risks posed by direct contact and incidental ingestion and reduce concentrations
in soil to levels acceptable under state and federal guidelines.
Compliance With Applicable or Relevant and Appropriate Requirements. Pursuant to
Section 121(d) of CERCLA, remedial actions shall, 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.
The selected soil remedy, as amended, satisfies this requirement by complying with all
ARARs. The action-specific and location-specific ARARs (there are no chemical-specific
ARARs) for this remedy are listed below:
• Executive Order 11988, Floodplain Management, and Executive Order 11990,
Protection of Wetlands, May 24, 1977 incorporated in 40 CFR Part 6, Appendix A;
Federal Clean Water Act, Section 404, 42 USC §1344. These requirements regulate
actions that occur in wetlands and flood plains and may be applicable to actions that
may adversely affect wetlands and flood plains.
• Solid Waste Disposal Act, also known as the Resource Conservation and Recovery Act,
Subchapter III, (42 USC § § 6921-6939; 40 CFR Parts 261-264, and 268); Oregon
Hazardous Waste Management Act (ORS 466.005 et seq.). State management of
hazardous waste is authorized in the Oregon Hazardous Waste Management Act (ORS
466.005 et seq.). The law is implemented by regulations that are codified at OAR 340-
100-uOl et seq. Oregon hazardous waste management regulations adopt by reference
most of the substantive provisions of Subtitle C of RCRA. Subtitle C is the primary
federal law for the management of hazardous waste. The principal federal regulations
that implement Subtitle C are codified in 40 CFR Parts 260-271. If federal and Oregon
hazardous waste laws conflict, the more stringent law will be followed. These
regulations address requirements for defining, characterizing and listing hazardous
wastes; for generators, pertaining to manifesting, transporting, and record keeping; for
transporters, pertaining to shipment of hazardous waste off-site; and land disposal
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restrictions. These regulations are applicable to the excavation, characterization,
transportation, treatment, and disposal of contaminated soil from the site.
• Procedures for Planning and Implementing Off-Site Response Actions (40 CFR
300.440). This regulation is applicable to, and will be complied with, for all wastes
that are transported off-site for treatment and/or disposal.
• Endangered Species Act (16 USC 1531 et seq.). Peregrine Falcon have been observed
near the Site; however, no nests or use of the Site by this protected bird have been
observed. If Peregrine Falcon are observed at the Site during implementation of the
remedy, precautionary steps will be taken to protect their habitat, in accordance with
this regulation.
• Oregon Hazardous Substance Remedial Action Act and Rules (ORS 465.200 et seq.)
The selected remedy meets the substantive requirements of these applicable regulations.
• Transportation of Hazardous Materials (49 CFR 171-177; OAR 860-66-001 et seq.)
Transporters must comply with U.S. Department of Transportation labeling, contain-
ment, and spill reporting regulations found in 49 CFR, Subchapter C. Transportation
of hazardous waste by rail or highway must comply with regulations of the Public
Utility Commissioner (OAR 860-66-001 et seq.), which adopt by reference U.S.
Department of Transportation regulations in Title 49 CFR. These regulations are
applicable for hazardous or dangerous waste disposed off-site. The selected remedy
will comply with these federal and related state regulations.
• EPA Area of Contamination Policy (Federal Register Volume 55, No. 46, March 8,
1990, pages 8759-8760). Excavation, consolidation, stockpiling, and sorting of soil
and debris, and replacement of concrete rubble, will be conducted within the AOC at
the Site.
• Willamette Green way Plan. DEQ has received Land Use Compatibility Statements
demonstrating the selected remedy is consistent with these requirements.
• The Lower Willamette River Management Plan (LWRMP). Requirements of the
LWRMP are waived for environmental cleanup plans selected by DEQ and developed
in consultation with the Division of State Lands.
Cost Effectiveness. The selected remedy is cost-effective, because it has been determined to
provide overall effectiveness proportional to its costs and duration for remediation of the
contaminated soil.
Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practical. DEQ and EPA determined that
the selected remedy, represents the maximum extent to which permanent solutions and
treatment technologies can be used cost-effectively at the McCormick & Baxter site. Of those
alternatives that are protective of human health and the environment and comply with ARARs,
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DEQ and EPA have determined that the selected remedy provides the best balance of trade-
offs, in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or
volume achieved through treatment; short-term effectiveness; implementability; cost; the
statutory preference for treatment as a principle element; and considering state and community
acceptance.
Preference for Treatment as a Principal Element. The remedy for contaminated soil, as
amended, continues to utilize treatment, although to a lesser degree than the soil remedy
contained in the 1996 ROD. Under current regulations, soil that exceeds the TCLP hazardous
waste criterion for PCP will be incinerated at a permitted off-site facility prior to disposal.
Soil (and ash resulting from incineration of site soil) that exceeds the TCLP criteria for arsenic
or chromium will be stabilized prior to disposal in a permitted off-site landfill (actual treatment
requirements will be dependent upon the regulations in place at the time of disposal). During
development of this ROD Amendment, on-site treatment of wastes (i.e., stabilization) was
evaluated to address the statutory preference for treatment to permanently and significantly
reduce the volume, toxicity, or mobility of principal threat wastes. However, on-site
stabilization of soil would result in a significant increase in the volume of wastes to be
managed on-site. Furthermore, the long-term reliability of stabilization for organic
contaminants (e.g., dioxin) is uncertain. Therefore, off-site treatment (when necessary) and
disposal was selected as part of the amended remedy.
DOCUMENTATION OF SIGNIFICANT CHANGES
There have been no significant changes from the Proposed Plan. The selected Remedial Action
for contaminated soils is the same as that described to the public in the Proposed Plan dated
October 1, 1997.
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APPENDIX A
RESPONSIVENESS SUMMARY
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AMENDED RECORD OF DECISION
McCORMICK AND BAXTER CREOSOTING COMPANY
PORTLAND PLANT
RESPONSIVENESS SUMMARY
This responsiveness summary summarizes and responds to substantive comments received
during the public comment period regarding the Oregon Department of Environmental
Quality's (DEQ's) and the United States Environmental Protection Agency's (EPA's) proposed
revised cleanup plan for the McCormick & Baxter Creosoting Company Site in Portland,
Oregon. Section 117(c) of CERCLA, 42 USC §96l7(c) provides for addressing and
documenting changes to the selected remedy after issuance of a Record of Decision (ROD).
Additionally, since fundamental changes are being made to the remedy, public participation
and documentation procedures specified in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 CFR Section 300.435(c)(2)(ii) have been followed.
DEQ and EPA published notice of the proposed ROD Amendment in the Oregon Secretary of
State's Bulletin and in The Oregonian newspaper on October 1, 1997. In addition, notices
were mailed to 130 individuals on DEQ's mailing list for the site. A public comment was
provided from October 1, through October 31, 1997. A public meeting was held near the site
on October 9, 1997. Nineteen people attended. DEQ and EPA staff also attended a meeting
of the Friends of Cathedral Park Neighborhood Association, on November 11, 1997, to
discuss the proposed ROD Amendment.
During the public comment period, written comments were received from one individual, Mr.
Peter Teneau. In addition, informal verbal comments were received during the public meeting
on October 9, and at the neighborhood association meeting on November 11. A summary of
the comments received, and DEQ's and EPA's responses, are presented below.
COMMENTS FROM MR. PETER TENEAU, DATED OCTOBER 31, 1997.
The majority of Mr. Teneau's comments referenced previous recommendations included in the
January 16, 1996 Review Report on McCormick & Baxter Creosoting Site - Proposed Cleanup
Plan and Feasibility Study, prepared by SJO Consulting Engineers, Inc. (SJO Report). DEQ
and EPA have previously responded to those recommendations in the Responsiveness
Summary (Appendix A) of the 1996 Record of Decision (ROD). DEQ and EPA have
responded to these comments of Mr. Teneau by referencing the appropriate sections in the
1996 Responsiveness Summary, as follows:
1. COMMENT: Mr. Teneau emphasized Recommendation 5 from the SJO Report
without comment. Recommendation 5 recommended off-site ambient air quality monitoring in
residential areas nearest the site, during remedial action activities.
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RESPONSE: DEQ and EPA have previously responded to this SJO Recommendation.
See Comment 5 in the Responsiveness Summary (Appendix A), in the 1996 ROD.
2. COMMENT: Mr. Teneau referenced Recommendations 12, 13, and 14 from the SJO
Report. These recommendations concern the potential future use of the site and residual risks.
In addition, Mr. Teneau stated that the method of capping will have a direct bearing on future
use of the site and should be planned in a more considered way than simply laying two feet of
soil cap over the entire site. Also, that it would be better to know what the future use of the
property will be before undertaking a more site-specific plan, if this would not incur undue
delay in the cleanup. In addition, Mr. Teneau noted that an impermeable cap placed over the
St. Johns Landfill did not allow for the planting of trees: He expressed concern that similar
restrictions at the McCormick & Baxter site would make the land unattractive, and notes that
many people would like to see the property become a park. In closing, he asked if excavations
deeper than four feet would be allowed, to provide for tree planting.
RESPONSE: DEQ and EPA have previously responded to these SJO
Recommendations. See Comments 12, 13 and 14 in the Responsiveness Summary (Appendix
A), in the 1996 ROD. In addition, Section 10.1.5 of the ROD states in part that cap
installation "may be delayed up to 2 years to coordinate future site development infrastructure
into final cap design." Section 10.1.5 further states that "Additional soil to increase the
thickness of the cap may be added or required of future landowners when zoning and future
property use become more firmly established. The appropriate cap thickness would take into
consideration building foundations; root depth for grasses, bushes, and trees; and surface
contours. The actual thickness of the cap and the soil/material type used may vary, depending
on developments in land ownership, land use zoning and use designations, and engineering
specifications." The ROD Amendment does not change this portion of the ROD. DEQ and
EPA will confer with the City of Portland, the Port of Portland, Metro and/or other
appropriate land use planning agencies in developing a final design for the site cap. As
presently envisioned, the cap would be permeable (unlike the cap at the St. Johns Landfill) and
would allow for the planting of trees. Excavations greater than 4 feet could be allowed, as
long as excavated soil was appropriately managed.
3. COMMENT: Mr. Teneau emphasized Recommendations 25 and 26 from the SJO
Report without further comment. These recommendations request that residual risks be
calculated after soil excavation and treatment, but before capping. Also, that the volume of
soil excavation required to achieve the cleanup goals, without the benefit of capping, should be
determined.
RESPONSE: DEQ and EPA have previously responded to these SJO
Recommendations. See Comments 25 and 26 in the Responsiveness Summary (Appendix A),
in the 1996 ROD. However, the response to Comment 25 envisioned on-site treatment of
excavated soil. DEQ and EPA stated that residual risk would be calculated following on-site
treatment. Since the ROD Amendment substitutes off-site disposal for on-site treatment,
residual risk will be based on the action levels for soil excavation. The action levels for
arsenic and carcinogenic PAHs (constituents of creosote) are equivalent to an excess lifetime
cancer risk of 1 x 10"* (1 in 10,000), and the action level for pentachlorophenol is equivalent
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to an excess lifetime cancer risk of 1 x 105 (I in 100,000), based on industrial land use.
These risk levels are within the range considered acceptable by EPA, for the anticipated land
use, but exceed the level considered acceptable by DEQ. Therefore, a cap is required, in
addition to the planned soil excavation, to comply with DEQ's rules. The residual risk for
dioxin cannot be calculated, due to insufficient data, but the soils having the highest
concentrations of dioxin will be excavated and removed from the site, and the soil cap and
institutional controls will greatly reduce any residual risk.
4. COMMENT: Mr. Teneau referenced Recommendation 29 from the SJO Report and
added that one remedial action alternative without capping would provide a useful perspective.
This recommendation requested that DEQ and EPA consider at least one remedial action
alternative that did not include capping.
RESPONSE: DEQ and EPA have previously responded to this SJO Recommendation.
See Comment 29 in the Responsiveness Summary (Appendix A), in the 1996 ROD.
5. COMMENT: Mr. Teneau emphasized Recommendation 30 from the SJO Report and
noted that this comment also relates to SJO Recommendations 12, 13 and 14, as described
above. Recommendation 30 requests that other cap designs be considered which provide better
isolation of contaminants (e.g., geotextile, asphalt or other barriers to intrusion).
RESPONSE: DEQ and EPA have previously responded to this SJO Recommendation.
See Comment 30 of the Responsiveness Summary (Appendix A), in the 1996 ROD. It should
also be noted that SJO Recommendation 30, which asks DEQ and EPA to consider an
impermeable cap, seems to conflict with Mr. Teneau's request, in Comment 2 above, for a cap
design that would facilitate the planting of trees.
6. COMMENT: Mr. Teneau referenced Recommendation 31, 32, 33, and 34 from the
SJO Report and asked additional questions concerning the groundwater and sediment remedies.
RESPONSE: DEQ and EPA have previously responded to these SJO
Recommendations. See Comments 31, 32, 33, and 34 in the Responsiveness Summary
(Appendix A), in the 1996 ROD. However, these comments, and Mr. Teneau's supplemental
comments and questions, pertain to the groundwater and sediment remedies which are beyond
the scope of this ROD Amendment (i.e., only the soil remedy is being amended). DEQ will
respond to Mr. Teneau concerning these issues, separately from this Responsiveness Summary.
In addition to the above comments, Mr. Teneau also commented on the October 1, 1997
Proposed Plan for the ROD Amendment, as follows:
7. COMMENT: Mr. Teneau stated that he much prefers Alternative 3, to Alternatives 1
and 2, but he expressed concern about the handling of excavated soil. He recommended that
all possible precautions be taken to insure that there is minimal escape of dust and/or liquid
from trucks onto roadways or into the environment.
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RESPONSE: DEQ and EPA acknowledge Mr. Teneau's support of Alternative 3,
which is DEQ's and EPA's recommended alternative. In addition, DEQ and EPA recognize
the need to control leaks, spills or other discharges of contaminated soil and/or water from
trucks. The remedial action construction specifications will include strict requirements and
precautionary measures related to truck loading and contaminated soil transportation in
accordance with U.S. Department of Transportation (DOT), EPA Resource Conservation and
Recovery Act (RCRA), and DEQ regulations. Requirements will include, at a minimum,
lining trucks prior to loading and covering loads with tarps during transport. These regulations
also require the immediate cleanup of any spill of hazardous wastes by transporters.
A truck washing rack has been constructed at the McCormick & Baxter site to clean the
exterior and tires of all trucks leaving the site. All trucks are inspected for the presence of
visible soil contamination by DEQ's contractor, prior to leaving the site. Dust control
measures, such as water sprays, will be used as necessary to control dust generation during soil
excavation and truck loading.
In addition, as stated beiow, DEQ and EPA will evaluate rail haul as an alternative to truck
transport of excavated soil from the site.
VERBAL COMMENTS RECEIVED AT PUBLIC MEETINGS
1. COMMENT: The October 1995 Proposed Plan indicated that excavation and off-site
disposal of soil would be too expensive. Now DEQ and EPA are saying that the cost of
excavation and off-site disposal is about the same as the cost of on-site biological treatment and
stabilization, as described in the 1996 ROD. How can this be?
RESPONSE: There are several reasons for this apparent inconsistency. First, the cost
presented in the ROD is for excavation and on-site treatment of approximately 30,000 cubic
yards of soil. The cost in the proposed ROD Amendment is for excavation and off-site
management of approximately 20,000 cubic yards of soil. Second, the costs for off-site
disposal of contaminated soil fluctuate with market conditions, and are currently 20 to 25
percent lower than they were when the Proposed Plan was issued in 1995. Third, DEQ and
EPA recommended on-site treatment in 1995, instead of off-site disposal, primarily because of
the statutory preference for treatment as a principal element of the remedy. Current
information, however, indicates that on-site treatment would not be effective.
2. COMMENT: A number of individuals expressed concern about potential increased
truck traffic through their neighbor, and about potential spills or leaks of waste from trucks.
RESPONSE: See response to comment number 7 above.
3. COMMENT: A number of individuals requested that rail haul be considered as an
alternative to truck transportation of excavated soil.
RESPONSE: DEQ and EPA will evaluate the possibility of using rail transportation,
as requested.
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APPENDIX B
ADMINISTRATIVE RECORD
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March 1998
McCORMICK & BAXTER CREOSOTING COMPANY
PORTLAND PLANT
PORTLAND, OREGON
ADMINISTRATIVE RECORD INDEX
1.0 SITE IDENTIFICATION
l.l Site inspection, McCormick & Baxter Creosoting Company. Prepared for the U.S.
Environmental Protection Agency, Region 10. Ecology and Environment, Seattle, WA.
December 9, 1983
1.2 Preliminary Site Investigation of McCormick & Baxter Creosoting Company Plant, dated
April 3, 1984, prepared by CH2M Hill. Submitted to Oregon Department of
Environmental Quality by McCormick & Baxter.
1.3 McCormick & Baxter Creosoting Company site water and soil investigation. Interim
Report. Submitted to Oregon Department of Environmental Quality, Portland, OR.
CH2M Hill, Portland, OR. January 1985.
1.4 CH2M Hill. February 1987. McCormick & Baxter Creosoting Co. Portland Plant:
environmental contamination site assessment and remedial action report. Volume 1.
Submitted to Oregon Department of Environmental Quality, Portland, OR. Prepared by
McCormick & Baxter Creosoting Company and CH2M Hill, Portland, OR.
1.5 CH2M Hill. December 1989. McCormick & Baxter Creosotinp Company 1988 and 1989
environmental monitoring summary report. Prepared for McCormick & Baxter Creosoting
Company, Portland, OR. CH2M Hill, Portland, OR.
1.6 McCormick & Baxter Creosoting Company 1990 environmental monitoring summary
report. Prepared for McCormick & Baxter Creosoting Company, Portland, OR. CH2M
Hill, Portland, OR. December 1990.
2.0 REMOVAL RESPONSE
2.1. PTI. March 1991. McCormick & Baxter Creosoting Company interim remedial action
work plari. Prepared for Oregon Department of Environmental Quality, Portland, OR.
PTI Environmental Services, Bellevue, WA.
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2.2. PTI. August 1991. McCormick & Baxter Creosoting Company interim remedial action
summary. Draft. Prepared for Oregon Department of Environmental Quality, Portland,
OR. PTI Environmental Services, Bellevue, WA.
2.3. PTI. September 1991. McCormick & Baxter Creosoting Company interim remedial action
creosote recovery work plan. Draft. Prepared for Oregon Department of Environmental
Quality, Portland, OR. PTI Environmental Services, Bellevue, WA.
2.4. McCormick & Baxter Creosoting Company DNAPL Extraction Design Report. October
1992. Prepared for Oregon Department of Environmental Quality, Portland. PTI
Environmental Services.
2.5. Creosote extraction system performance evaluation. McCormick & Baxter Creosoting
Company. Prepared for Oregon Department of Environmental Quality, Portland, OR. PTI
Environmental Services, Lake Oswego, OR. June 1993.
2.6. McCormick & Baxter Creosoting Company Extracted Groundwater Pilot Treatment System
Preliminary Engineering Analysis. March 1994. Prepared for Oregon Department of
Environmental Quality and PTI Environmental Services by Onsite Enterprises.
2.7. Site Activity Status Report, McCormick & Baxter Creosoting Company. Prepared for
Oregon Department of Environmental Quality, Portland, OR. PTI Environmental Services,
Lake Oswego, OR. June 1994.
2.8. NAPL Extraction System Operations and Maintenance Manual, McCormick & Baxter
Creosoting Company. Prepared for Oregon Department of Environmental Quality by PTI
Environmental Services, dated December 1994.
2.9. Tank Dismantling Summary Report, McCormick & Baxter Creosoting Company. Prepared
for Oregon Department of Environmental Quality, Portland, OR. PTI Environmental
Services, Lake Oswego, OR. January 1995.
2.10. Quarterly Creosote Extraction Summary, Fourth Quarter 1994. McCormick & Baxter
Creosoting Company. Prepared for Oregon Department of Environmental Quality by PTI
Environmental Services, dated February 1995.
2.11. EPA Action Memorandum dated March 2, 1995 authorizing Removal Action for the
McCormick & Baxter Creosoting Site.
2.12. Quarterly Creosote Extraction Summary, First Quarter 1995. McCormick & Baxter
Creosoting Company. Prepared for Oregon Department of Environmental Quality by PTI
Environmental Services, dated April 1995.
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2.13. Quarterly Creosote Extraction Summary, Second Quarter 1995. McCormick & Baxter
Creosoting Company. Prepared for Oregon Department of Environmental Quality by PTI
Environmental Services, dated July 1995.
2.14. Monthly Creosote Extraction Summary Reports dated June 1993 through August 1994,
Prepared for Oregon Department of Environmental Quality by PTI Environmental Services.
2.15. Pre-Remedial Design Work Plan, McCormick & Baxter Creosoting Company Portland
Plant. Prepared for Oregon Department of Environmental Quality by Ecology &
Environment, Inc., dated February 1996.
2.16. Memorandum from Mike Wiltsey, DEQ Northwest Region, to Jim Sheetz, DEQ Northwest
Region, dated February 21, 1995. Memorandum provides mixing zone modeling results
for interim NPDES discharge limits for treated groundwater discharge to Willamette River.
3.0 REMEDIAL INVESTIGATION (Rl)
3.1. McCormick & Baxter Creosoting Company Remedial Investigation and Feasibility Study
Sampling and Analysis Plan and Quality Assurance Project Plan. Prepared for Oregon
Department of Environmental Quality, Portland, OR. PTI Environmental Services,
Bellevue, WA. September 1990.
3.2. McCormick & Baxter Creosoting Company Remedial Investigation and Feasibility Study
Work Plan. Prepared for Oregon Department of Environmental Quality, Portland, OR.
PTI Environmental Services, Bellevue, WA. September 1990.
3.3. McCormick & Baxter Creosoting Company Phase II Remedial Investigation Work Plan.
Prepared for Oregon Department of Environmental Quality, Portland, OR. PTI
Environmental Services, Bellevue, WA. September 1991.
3.4. McCormick &. Baxter Creosoting Company Phase II Remedial Investigation Sampling and
Analysis Plan. Prepared for Oregon Department of Environmental Quality, Portland, OR.
PTI Environmental Services, Bellevue, WA. October 1991.
3.5. McCormick & Baxter Creosoting Company Remedial Investigation/Feasibility Study Pilot
Extraction Testing Results. Prepared for Oregon Department of Environmental Quality,
Portland, OR. PTI Environmental Services, Bellevue, WA.
3.6. McCormick & Baxter Creosoting Company Remedial Investigation Report. Prepared for
Oregon Department of Environmental Quality, Portland, OR. PTI Environmental Services,
Bellevue, WA. September 1992.
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March 1998
3.7. Supplemental Characterization and Initial Removal of Contaminated Soils, McCormick &
Baxter Creosoting Company Draft. Prepared for Oregon Department of Environmental
Quality. PTI Environmental Services, Lake Oswego, OR. October 1994.
4.0 FEASIBILITY STUDY (FS)
4.1. PTI. September 1992. McCormick & Baxter Feasibility Study Report. Prepared for
Oregon Department of Environmental Quality, Portland, OR. PTI Environmental Services,
Lake Oswego, OR.
4.2. McCormick & Baxter Creosoting Company Revised Feasibility Study. Prepared for
Oregon Department of Environmental Quality, Portland, OR. PTI Environmental Services,
Lake Oswego, OR. September 1995.
4.3. McCormick & Baxter Creosoting - Review of Treatability Study Data for Wood-Treating
Sites. Prepared for Oregon Department of Environmental Quality, Portland, OR. PTI
Environmental Services, Bellevue, WA. August 1992
4.4. Solid-Phase Bioremediation of Creosote- and PCP-contaminated soils: pilot test results.
Prepared for McCormick & Baxter Creosoting Company, Portland, OR. CH2M Hill,
Portland, OR. 1990.
4.5. Supplemental Technical Note: Laboratory Study PCP Degradation in an Oregon Soil.
Prepared by Grace Dearborn for U.S. Environmental Protection Agency dated May 1995.
4.6. Memorandum to the McCormick & Baxter Project file from Bruce Gilles, Project Manager
dated May 22, 1995. Provides written comments on the draft Revised FS Report dated
April 1995.
4.7. Memorandum to McCormick & Baxter Project File dated October 18, 1995 concerning
interpretations of applicable or relevant and appropriate RCRA regulations for the
McCormick & Baxter Site.
4.8. Memorandum to McCormick & Baxter Project File, dated March 14, 1996, by Bruce
Gilles, Project Manager, Oregon DEQ. Errata and Addenda for Revised Feasibility Study,
Appendix C - Alternate Concentration Limits Development.
4.9. Memorandum to McCormick & Baxter Project File, dated March 11, 1996, by Bruce
Gilles, Project Manager, Oregon DEQ - Rationale for Revision of Remedial Action Level
for Treatment for PAHs.
4.10. Memorandum from Bruce Gilles, DEQ Project Manager, to Jim Sheetz, DEQ Northwest
Region Water Quality dated March 8, 1996. Final NPDES Discharge Limits for Treated
Groundwater Discharge to Willamette River.
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4.11. Memorandum from Yu-Ting Liu, EPA Remedial Project Manager, to McCormick &
Baxter Project File concerning EPA's assessment of DEQ's March 11, 1996 memorandum
on PAH action level revisions.
5.0 RECORD OF DECISION (ROD)
5.1. McCormick & Baxter Cleanup Plan dated December 1992 prepared by Oregon Department
of Environmental Quality.
5.2. The Proposed Cleanup Plan for the McCormick and Baxter Creosoting Site prepared by the
Oregon Department of Environmental Quality and U.S. Environmental Protection Agency.
October 30, 1995.
5.3. Record of Decision, McCormick & Baxter Creosoting Company Portland Plant dated
March 1996.
5.4. Proposed Cleanup Plan for ROD Amendment, McCormick and Baxter Creosoting Site,
Portland, Oregon. Prepared by the Oregon Department of Environmental Quality and U.S.
Environmental Protection Agency. October 1, 1997.
6.0 STATE COORDINATION
6.1. Letter from Mary Wahl, Oregon DEQ to Carol Rushin, EPA Region X dated March 4,
1994 requesting State Lead for the McCormick & Baxter Site.
6.2. Letter from Carol Rushin, EPA Region X, to Mary Wahl, Oregon DEQ, dated May 11,
1994 prepared in response to DEQ request for State Lead for remedial design and remedial
action for the McCormick & Baxter Site.
6.3. Letter from Mary Wahl, Oregon DEQ, to Carol Rushin, EPA Region X, in response to
EPA's May 11, 1994 letter.
6.4. Memorandum from Allison Hiltner, EPA Remedial Project Manager, to Bruce Gilles, DEQ
Project Manager dated November 2, 1994 transmitting comments on the 1992 RI/FS and
necessary documentation to support a final remedy decision by EPA.
6.5. Superfund State Contract between U.S. Environmental Protection Agency and Oregon
Department of Environmental Quality dated March 30 1995. Contract provides funding
from EPA for removal action for continued creosote extraction activities being performed
by DEQ.
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6.6. Cooperative Agreement between Oregon Department of Environmental Quality and U.S.
Environmental Protection Agency for funding of interim remedial actions (IRA), March
1995.
6.7. Memorandum from Scott Huling, U.S. EPA Robert S. Kerr Environmental Research
Laboratory, to Allison Hiltner, EPA Remedial Project Manager, dated April 11, 1995.
Memorandum of comment on Technical Memorandum on Ground water Remediation, for
the McCormick & Baxter Creosoting Site.
6.8. Memorandum from Allison Hilter, EPA Remedial Project Manager, to Bruce Gilles, DEQ
Project Manager, dated May 8, 1995. Provides EPA comments on the draft Revised FS,
dated April 1995.
6.9. IRA Credit Application from Oregon DEQ to U.S. EPA for remedial action costs incurred
by DEQ prior to placement of the McCormick & Baxter Creosoting Company site on the
NPL, dated September 29, 1995.
6.10. Cooperative Agreement Amendment for IRA activities between Oregon DEQ and U.S.
EPA, dated February 29, 1996.
7.0 ENFORCEMENT
7.1. Stipulation and Final Order No. HWAVQ-NWR-97-64 between McCormick & Baxter
Creosoting Company and the Oregon Department of Environmental Quality, dated
November 24, 1987.
7.2. CERCLA Section 104(e) letter from Michael Gearheard, U.S. EPA Region 10 to Rhone
Poulenc Inc., dated January 11, 1996.
7.3. CERCLA Section I04(e) letter from Michael Gearheard, U.S. EPA Region 10 to
Burlington Northern Railway Company, dated January 11, 1996.
8.0 HEALTH ASSESSMENTS
8.1. Public Health Assessment, McCormick & Baxter Creosoting Company, Portland.
Multnomah County, Oregon. CERCLIS No. ORD009020603. U.S. Department of Health
and Human Services, Public Health Service, Agency for Toxic Substances and Disease
Registry. June 13, 1995.
8.2. Toxicological Profile for Pentachlorophenol. Agency for Toxic Substances and Disease
.Registry. Document No. ATSDR/TP-93/13.
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8.3. Toxicological Profile for Creosote, Draft Report. Agency for Toxic Substances and
Disease Registry. February 1995.
8.4. Toxicological Profile for 2,3,7,8-tetrachlorodibenzodioxin (TCDD), Agency for Toxic
Substances and Disease Registry. Document No. ATSDR/TP-88/23.
8.5. Toxicological Profile for Arsenic. Agency for Toxic Substances and Disease Registry.
Document No. ATSDR/TP-92/02.
8.6. Focused Human Health Risk Evaluation, McCormick & Baxter Site, Portland, Oregon.
Prepared by Ecology & Environment, Inc. for the Oregon Department of Environmental
Quality. August 27, 1997.
9.0 NATURAL RESOURCE TRUSTS ES
9.1. Letter from Bruce Gilles, Oregon DEQ to Russell Peterson, U.S. Fish and Wildlife Service
requesting endangered species consultation for the McCormick & Baxter Creosoting Site,
Portland. November 18, 1994.
9.2. Letter from Russell Peterson, U.S. Fish and Wildlife Service to Bruce Gilles, Oregon
DEQ, dated January 30, 1995 providing list of endangered or threatened species that may
occur within the area of the McCormick & Baxter Creosoting Site.
9.3. Notification of Natural Resource Trustees Letter from Deborah Yamamoto, EPA Remedial
Project Manager, to Mr. Chris Beaverson, NOAA Coastal Resource Coordinator, dated
October 30, 1995 requesting comment on DEQ and EPA Proposed Cleanup Plan for the
McCormick & Baxter Creosoting Co. Superfund Site.
9.4. Notification of Potential Natural Resource Damages Letter from Deborah Yamamoto, EPA
Remedial Project Manager, to Mr. Donald Samson, Chairman, Board of Trustees,
Confederated Tribes of the Umatilla Indian Reservation, dated October 30, 1995 requesting
comment on DEQ and EPA Proposed Cleanup Plan for the McCormick & Baxter
Creosoting Co. Superfund Site.
9.5. Notification of Potential Natural Resource Damages Letter from Deborah Yamamoto, EPA
Remedial Project Manager, to Mr. Donald Samson, Chairman, Board of Trustees,
Confederated Tribes of the Umatilla Indian Reservation, dated October 30, 1995 requesting
comment on DEQ and EPA Proposed Cleanup Plan for the McCormick & Baxter
Creosoting Co. Superfund Site.
9.6. Notification of Potential Natural Resource Damages Letter from Deborah Yamamoto, EPA
Remedial Project Manager, to Mr. Samuel N. Penney, Chairman, Nez Perce Tribe of
Idaho, dated October 30, 1995 requesting comment on DEQ and EPA Proposed Cleanup
Plan for the McCormick & Baxter Creosoting Co. Superfund Site.
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9.7. Notification of Potential Natural Resource Damages Letter from Deborah Yamamoto, EPA
Remedial Project Manager, to Bruce Brunoe, Chairman, Confederated Tribes of Warm
Springs, dated October 30, 1995 requesting comment on DEQ and EPA Proposed Cleanup
Plan for the McCormick & Baxter Creosoting Co. Superfund Site.
9.8. Notification of Potential Natural Resource Damages Letter from Deborah Yamamoto, EPA
Remedial Project Manager, to Jerry Meninick, Chairman, Yakima Tribal Council, dated
October 30, 1995 requesting comment on DEQ and EPA Proposed Cleanup Plan for the
McCormick & Baxter Creosoting Co. Superfund Site.
9.9. Notification of Natural Resource Trustees Letter from Deborah Yamamoto, EPA Remedial
Project Manager, to Mr. Charles Polityka, U.S. Department of Interior, dated October 30,
1995 requesting comment on DEQ and EPA Proposed Cleanup Plan for the McCormick &
Baxter Creosoting Co. Superfund Site.
9.10. Preliminary Natural Resources Survey for the McCormick & Baxter Creosoting Company
Superfund Site dated September 1995. Prepared by National Oceanic and Atmospheric
Administration for U.S. Environmental Protection Agency.
10.0 PUBLIC PARTICIPATION
10.1. DEQ Proposed plan for the McCormick and Baxter Creosoting Company Site. Oregon
Department of Environmental Quality, Portland, OR. December 1992.
10.2. News Release dated December 30, 1992 and February 4, 1993 issued by Oregon DEQ;
Public notices dated December 30, 1992 to Secretary of State's Bulletin and Oregonian.
Follow-up advertisements/articles published in local newspapers:
• St. Johns Review. Thursday, December 31, 1992.
• 'Daily Journal of Commerce. January 5, 1993.
• Oregon Insider. January 15, 1993.
10.3. DEQ Project Public Relations files containing Fact Sheets mailed to project mailing list
between November 1990 to July 1995, newspaper articles and information meetings
concerning the McCormick & Baxter Creosoting Site investigations and interim cleanup
activities conducted by DEQ.
10.4. Letter of Comment on Proposed Cleanup Plan from Julie Winslow to Paul Bumet, Oregon
DEQ, dated February 2, 1993.
10.5. Letter of Comment on Proposed Cleanup Plan from John E. Lilly, Oregon Division of State
Lands, to Paul Bumet, Oregon DEQ dated February 3, 1993.
10.6. Letter of Comment on Proposed Cleanup Plan from Dave King, Cathedral Park
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Neighborhood Association to Paul Bumet, Oregon DEQ, received February 16, 1993.
10.7. Memoranda to McCormick & Baxter project file from Paul Burnet, Oregon DEQ
summarizing the January 26, 1993 and February 2, 1993 public comment meeting on
proposed plan.
10.8. Letter of Comment on Proposed Cleanup Plan from Lee Poe, Chair of Portsmouth
Neighborhood Association and Odor Abatement Committee to Paul Burnet, Oregon DEQ,
dated March 5, 1993.
10.9. Memorandum of Comment on Proposed Cleanup Plan from Pam Arden, Kenton
Neighborhood Association, to Paul Bumet, Oregon DEQ, dated March 8, 1993.
10.10. Response to Comment on the Proposed Cleanup Plan letters from Paul Burnet to Pam
Arden, Julie Winslow, Dave King, and Lee Poe dated March 13, 1993.
10.11. Community Relations Plan for the McCormick & Baxter Creosoting Site prepared by the
Oregon Department of Environmental Quality, dated January 23, 1995.
10.12. Advertisements Announcing Availability of Proposed Cleanup Plan for Public Comment in
the Oregonian and St Johns Review Newspapers, November 6, 1995.
10.13. Letter from Dave Soloos, President of WAKE-UP, dated November 14, 1995, to Bruce
Gilles, DEQ Project Manager requesting a 60 day extension of the public comment period
for the proposed cleanup plan.
10.14. Letter from Bruce Gilles, Oregon DEQ, to Dave Soloos, President of WAKE-UP, dated
November 22, 1995 notifying WAKE-UP of DEQ and EPA's decision to grant a 35 day
extension of the public comment period to Friday, January 15, 1996.
10.15. Transcript and written comments from the public hearing held on November 28, 1995 at St
Johns Community Center.
10.16. Letter of comment on the 1995 Proposed Cleanup Plan from Richard Robinson, Agency for
Toxic Substances and Disease Registry, dated December 5, 1995.
10.17. Letter of comment on the 1995 Proposed Cleanup Plan from Mike Burton, Executive
Officer ."or METRO, dated December 8, 1995.
10.18. Letter of comment on the 1995 Proposed Cleanup Plan from Bowen Blair, Vice President
of The Trust for Public Land, dated December 29, 1995.
10.19. Letter of comment on the 1995 Proposed Cleanup Plan from Connie Lively, Project
Coordinator for Portland Development Commission, dated January 3, 1996.
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10.20. Review Report on McCormick &. Baxter Creosoting Site - Proposed Cleanup Plan and
Feasibility Study, Prepared for Willamette Associates for Kindness to the Environment in
University Part (WAKE-UP) by SJO Consulting Engineers, dated January 16, 1996.
10.21. Letter of comment on the 1995 Proposed Cleanup Plan from Stephen Miller, Architect for
Turtle Cove Community Trust, dated January 16, 1996.
10.22. Letter from James E. Benedict; Cable Huston Benedict & Haagensen, to Bruce Gilles,
DEQ, dated January 16, 1996.
10.23. Letter from Bill Barnes to Bruce Gilles, dated December 8, 1995.
10.24. Letter of comment on the 1995 Proposed Cleanup Plan from Russell D. Peterson, State
Supervisor, U.S. Department of Interior Fish & Wildlife Service dated January 19, 1996.
11.0 LAWS AND REGULATIONS
11.1. The Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended by the Superfund Amendments and Reauthorization Act of 1986.
11.2. The National Contingency Plan, 40 CFR Part 300.
11.3. Oregon Hazardous Substance Remedial Action Rules OAR Chapter 340, Division 122.
11.4. Oregon Hazardous Waste Management Act/RCRA. (ORS 466.005 et seq. and
implementing regulations codified in OAR 340-100-001 et seq.
11.5. Corrective Action Management Units and Temporary Units; Final Rule. Federal Register,
Volume 58, No. 29, Tuesday, February 16, 1993.
11.6. Federal Register, Volume 59, No. 103, Tuesday, May 31, 1994 Listing McCormick &
Baxter Creosoting Site on the National Priorities List.
11.7. Federal Register, Volume 58, No. 182, Wednesday, September 22, 1993. Amendments to
NCP; Procedures for Planning and Implementing Off-Site Response Actions.
12.0 TECHNICAL SOURCES AND GUIDANCE DOCUMENTS
12.1. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA,
Interim Final, OERR, EPA/540/G-89/004, OSWER Directive 9355.3-01, October 1988.
12.2. Risk Assessment Guidance for Superfund, Volume I, Human Health and Evaluation
Manual (Pan A), EPA/540/1-89/002, December 1989.
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12.3. Human Health Evaluation Manual, Part B: Development of Risk Based Preliminary
Remediation Goals, OSWER Directive No. 9285.7-01B, December 1991.
12.4. Risk Assessment Guidance for Superfund, Volume n, Environmental Evaluation Manual,
EPA/540/1-89/001, March 1989.
12.5. Final Guidance on Administrative Records for Selecting CERCLA Response Actions,
OSWER Directive No. 9833.3A-1.
12.6. CERCLA Compliance With Other Laws Manual, Part 1, EPA/540/G-89/006, August
1988.
12.7. CERCLA Compliance With Other Laws Manual, Pan 2, Clean Air Act and Other
Environmental Statutes and State Requirements, EPA/540/G-89/009, August 1989.
12.8. Guidance on Remedial Actions for Contaminated Ground Water, OSWER Directive
9283.1-2FS, April 1989.
12.9. On-Site Treatment of Creosote and Pentachlorophenol Sludges and Contaminated Soil,
EPA/600/2-91/019, May 1991.
12.10. Contaminants and Remedial Options at Wood Preserving Sites, EPA/600/R-92/182.
Prepared by Foster Wheeler Enviresponse, Inc., Edison, NJ. Prepared for U.S.
Environmental Protection Agency, Office of Research and Development, Risk Reduction
Engineering Laboratory, Washington, DC., October 1992.
12.11. Presumptive Remedies for Soils, Sediments, and Sludges at Wood Treating Sites. U.S.
Environmental Protection Agency. Draft Publication, November 1994.
12.12. Technology Selection Guide for Wood Treater Sites. Memorandum from Office of
Emergency and Remedial Response, U.S. Environmental Protection Agency, Washington,
DC., EPA/540/-F-93-020, May 1993.
12.13. Guidance for Evaluating the Technical Impracticability of Ground Water Restoration. U.S.
Environmental Protection Agency. Directive 9234.2-25, September 1993,
12.14. DNAPL Site Evaluation. Prepared by Robert M. Cohen and James W. Mercer of Geotrans,
Inc. for the U.S. Environmental Protection Agency. EPA/600/R-93/022. February 1993.
12.15. Land Use in the CERCLA Remedy Selection Process. U.S. Environmental Protection
Agency. OSWER Directive No. 9355.7-04. May 1995.
12.16. Risk Assessment Guidance for Superfund: Volume I - Human Health Evaluation Manual,
Pan C, Risk Evaluation of Remedial Alternatives. OSWER Directive 9285.7-01C.
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12.17. DNAPL Site Characterization, EPA/540/f-94/049. OSWER Publication 9355.4-16FS.
September 1994.
13.0 REMEDIAL DESIGN
13.1. Remedial Design Work Plan, McCormick & Baxter Creosoting Company, Portland Plant,
Portland, Oregon. Prepared by Ecology & Environment, Inc. for the Oregon Department
of Environmental Quality. October 1996.
13.2. Wood Debris Sampling Plan, McCormick & Baxter Creosoting Company, Portland Plant,
Portland, Oregon. Prepared by Ecology & Environment, Inc. for the Oregon Department
of Environmental Quality. October 1996.
13.3. Sampling and Quality Assurance Plan, Site Management Plan, Data Management Plan,
McCormick & Baxter Creosoting Company, Portland Plant, Portland, Oregon. Prepared
by Ecology & Environment, Inc. for the Oregon Department of Environmental Quality.
November 1996.
13.4. Literature and Vendor Reports on the Biodegradation of Polyaromatic Hydrocarbons and
Pentachlorophenol, Wood Debris Sampling Plan, McCormick & Baxter Creosoting
Company, Portland Plant, Portland, Oregon. Prepared by Ecology & Environment, Inc.
for the Oregon Department of Environmental Quality. April 1997.
13.5. Supplemental Soil Sampling Plan, McCormick & Baxter Creosoting Company, Portland
Plant, Portland, Oregon. Prepared by Ecology & Environment, Inc. for the Oregon
Department of Environmental Quality. August 1997.
13.6. Revised Draft Remedial Design Data Summary Report, McCormick & Baxter Creosoting
Company, Portland Plant, Portland, Oregon. Prepared by Ecology & Environment, Inc.
for the Oregon Department of Environmental Quality. November 1997.
14.0 REMEDIAL ACTION
14.1. Remedial Action Work Plan, McCormick & Baxter Creosoting Company, Portland Plant,
Portland, Oregon. Prepared by Ecology & Environment, Inc. for the Oregon Department
of Environmental Quality. March 1997.
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Notes:
Documents in the Administrative Record are available for public review at the designated locations:
St Johns Community Library, 7510 N. Charleston, Portland
Oregon Department of Environmental Quality, 811 S.W. 6th Avenue, Portland
(10th floor)
Most documents contained in the administrative record are also available for review at:
North Portland Neighborhood Office, 2410 N. Lombard, Portland.
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