PB98-963107
EPA 541-R98-038
September 1998
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Pacific Hide and Fur Recycling Company
Pocatello, ID
5/14/1998
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, Washington 98101
May 13, 1998
Reply To
AttnOf: ECL-113
MEMORANDUM
SUBJECT: Pacific Hide & Fur ESD Addendum
FROM: Neil E. Thompson
Project Manager, Unit 4
THROUGH: Ann Williamson, Unit Manager -j"
Site Cleanup Unit 4
TO:
Randall F. Smith, Director
Office of Environmental Cleanup
The attached "Addendum #1" to the Pacific Hide and Fur Co., Explanation
of Significant Differences (ESD), provides a legal description to the Restricted Area that
was identified in the ESD. A land survey of the Restricted Area was done in
cooperation with the Idaho Department of Environmental Quality to permanently locate
the area. The surveyed Restricted Area lies within the general area described in the
ESD. This addendum does not change any part of the ESD which was signed on April
20, 1998.
* Printed on Recycled Paper
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, Washington 98101
April 15, 1998
Reply To
Attn Of: ECL-113
MEMORANDUM
SUBJECT: ESD - Pacific Hide and Fur
FROM: James Oesterle
ORC Attorney
Neil Thompson ^XL/
Project Manager I
TO: Randy Smith
Office Director
Attached are two documents for your signature; the
Explanation of Significant Difference (ESD), and the First
Supplement to Administrative Order for Remedial Action. Both of
these documents reflect the decision by the PRPs to clean up the
Pacific Hide and Fur Superfund site to a more protective level
than was required by the Record of Decision (ROD). The ROD
called for clean up to industrial use criteria, but the PRPs
chose to remove additional contamination so that the site can be
classified as residential use under CERCLA. This change is more
protective of human health.and the environment.
" Printed on Recycled Paper
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EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD)
for the
PACIFIC HIDE & FUR RECYCLING CO. SUPERFUND SITE
POCATELLO, IDAHO
From the September 27, 1995,
Final Operable Unit Record of Decision
1.0 INTRODUCTION
1,1 Site Name and Location
Pacific Hide & Fur Recycling Company (Site)
Pocatello, Idaho
1.2 Lead and Support Agencies
The U.S. Environmental Protection Agency (EPA) is the Lead Agency on this
site. The Idaho Department of Health and Welfare, Division of Environmental
Quality (DEQ) is the Support Agency for the site.
1.3 Explanation of Significant Differences
This document addresses a significant change to the Selected Remedy for the
site-wide surface and subsurface soil excavation and off-site disposal of lead-
contaminated soil described in the Final Operable Unit Record of Decision
(ROD), dated September 25, 1995. The document provides an Explanation of
Significant Differences (ESD) as required under Section 117(c) of CERCLA, and
the National Contingency Plan (NCP), 40 C.F.R. Section 300.435(c)(2)(1).
1.4 Circumstances Leading to the Changes to the ROD
The ROD required the remediation of all lead (Pb) contaminated soils above an
industrial land use scenario cleanup level of 1,000 mg/kg. During
implementation of the selected remedy in 1996, the Potentially Responsible
Parties (PRPs) performing the remedial actions proposed removing
contaminated soils to levels at or below the more stringent residential
Pacific Hide and Fur
ESD April 16. 1998 1
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contamination criteria (400 mg/kg Pb). Confirmation sampling conducted by the
PRPs following completion of the initial remedial action indicated that a minimal
amount of lead contaminated soil remained above the residential land use level
criteria. Given the low levels of remaining contamination, the PRPs preceded in
1997 to develop and implement additional cleanup actions to remove all
remaining soil with lead contamination above the 400 mg/kg level. The
additional work reduced the risks to human health and the environment.
1.5 Administrative Record
This Explanation of Significant Differences will become part of the Administrative
Record File for the Site. The record is available in the EPA Region 10 Records
Center located at 1200 6th Avenue, Seattle, Washington, and at the information
repository located at the Pocatello Public Library in Pocatello, Idaho.
1J3 Site Background
The Pacific Hide & Fur Recycling Company (Pacific) Superfund Site comprises
an area of approximately 16.9 acres in the northwest region of Pocatello, Idaho,
bounded on the north by State Highway 30, and on the south by the Union
Pacific Railroad (UPRR) right-of-way. The Site is an aggregate of three
contiguous properties, owned respectively by UPRR, Pacific, and the McCarty
family (McCarty), Figure 1. The UPRR property comprises about 4.0 acres
along the southern boundary of the Site; the Pacific property comprises
approximately 4.6 acres in the northwestern region of the Site; and the McCarty
property comprises approximately 8.3 acres in the eastern section of the Site
and includes a former gravel pit approximately 20 feet deep and covering
approximately 3 acres.
The historical and current use of the site is metal recycling. The operators buy
metal scrap and sort, cut, and ship out for reprocessing. The recycling of lead-
acid batteries and electrical transformers are believed to be the primary sources
of the chemicals of concern (lead and PCS) that caused the soil contamination
problems. The site is still operating as Pacific Steel and Recycling, Inc.
Polychlorinated biphenyls (PCBs) were detected in the Site soils in 1983 and
EPA conducted an Emergency Response Action (ERA). During the 1983 ERA,
EPA removed 593 capacitors, approximately 30 cubic yards of contaminated
soils and 20 drums of miscellaneous hazardous wastes for off-site disposal. The
Site was listed on the National Priorities List (NPL) on September 21, 1984.
Various remedial activities, focusing on the PCB contamination in the Site soils,
were conducted between 1983 and 1990, including issuance of a Record of
Decision (ROD) in 1988 identifying solidification/stabilization as the preferred
Pacific Hide and Fur
ESD April 16, 1998
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remedy for RGB-contaminated soils. In August 1990, additional sampling
conducted by EPA identified lead (Pb) contamination. In April 1992, an
amended ROD was issued dividing the Site into two Operable Units (OUs). The
focus of the first OU was soils contaminated with PCBs and soils contaminated
with commingled PCBs and lead. Over 15,000 tons of contaminated soil and
scrap were disposed of during the remedial action for the first OU in 1992.
In 1993, a Remedial Investigation/Feasibility Study (RI/FS) for the Final OU
(lead-contaminated soils) was conducted by EPA's designated contractor,
Ecology and Environment, Inc. (E&E), using x-ray fluorescence (XRF) equipment
and confirmatory laboratory analysis. The RI/FS also incorporated data
collected during the 1990 and 1991 field investigations, as well as information
obtained during confirmation sampling for the first OU remedial action. Based
on the findings of the RI/FS, an amended ROD was issued for the Final OU in
September 1995. On July 12, 1996, EPA issued an Administrative Order to the
PRPs to clean up additional lead-contaminated soils that remained after the
initial remedial actions were completed to remove the PCB and lead
contamination. The field work to complete this Final OU was completed on
November 13, 1997.
ZO DESCRIPTION OF THE FINAL OU REMEDY IN THE ROD
The Record of Decision (ROD) for the Final Operable Unit for the lead-
contaminated soil and scrap metal dated September 27, 1995, is the second of two
operable units for this Site. The first operable unit involved remediation of soil and
scrap material contaminated with polychlorinated biphenyls (PCBs) and commingled
PCBs and lead. Groundwater monitoring was continued only to confirm that chemicals
from the site were not contaminating local groundwater. The Final Operable Unit
includes the proper removal of the groundwater wells and ending the groundwater
monitoring.
This final operable unit addresses remediation of the remaining soil and scrap
material contaminated with lead. The remedial action was selected to address threats
associated with lead-contaminated soil and scrap material above lead health-based
levels under a future industrial land use scenario. The specific components of the ROD
which are being addressed by this ESD include:
1. Excavation, processing, transport, and disposal of all lead-contaminated
soil above 1000 mg/kg.
2. Implementation of institutional controls including permanent fencing to
restrict public access to the Site, and property restrictions limiting future
Pacific Hide and Fur
ESD April 16. 1998 3
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property usage to industrial operations [emphasis added] only on all
properties that comprise the Site (the form of restrictions will be
determined following issuance of this ROD).
The selected final operable unit remedial action was considered protective of
human health and the environment, eliminating the risks above the 1000 mg/kg lead
cleanup level posed through each pathway by removal, treatment to the extent
practicable, and proper [sic] disposal of lead-contaminated soil. The selected remedial
action was chosen to effectively and permanently remove on-Site lead-contaminated
soils above levels protective of on-Site workers under a future industrial land use
scenario. The selected remedy did, however, anticipate that lead and PCBs would
remain above residential health-based levels, thereby prohibiting unrestricted future
land use. Reviews were to have been conducted no less often than every five (5) years
following initiation of the remedial action to ensure adequate protection of human
health and the environment.
3.0 CHANGES IN THE SELECTED REMEDY REQUIREMENTS IN THE ROD
3.1 Change in the Final Operable Unit ROD
The selected remedy at the Site is changed to remove Site-wide surface and
subsurface soil, with proper off-Site disposal of lead-contaminated soil above
400 mg/kg, which leaves only lead-contaminated soils which have a level
protective of future residential land use. The revised remedial action effectively
and permanently removes on-Site lead-contaminated soils above levels
protective of future residential health-based levels thereby allowing unrestricted
(residential) future land use under CERLA criteria.
The institutional controls component of the ROD is deleted. A Deed notation will
be placed on the property by the PRP to address State concerns regarding
potential subsurface contamination. The Deed.notation will contain a recorded
notice to alert the environmental agencies of any pending excavation in an area
of the Site known as the Restricted Area. The Restricted Area is identified as:
that portion of the site extending from the southeastern most property
corner of the Site (known originally as McCarty's Property); northwesterly
.along the property line for 275 feet; southwesterly 90° from the property
line for 350 feet; southeasterly parallel to the above referenced property
line for 275 feet; northeasterly along the property line back to the original
southeastern property corner. The Restricted Area approximates a
rectangular shaped parcel (275 x 350 feet) in the southeastern most
corner of the Site.
Pacific Hide and Fur
ESD April 16, 1998 4
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Because no known hazardous materials remain on-Site above health-based
levels, no Five-Year reviews of the Site are needed to ensure adequate
protection of human health and the environment.
32 Basis for the Change
The EPA is making this change in the remedy requirements as stated in the
Final Operable Unit ROD because the Site was cleaned up to significantly lower
concentrations of lead in the soil than was required in the ROD. During the
course of implementing the selected remedy, the PRPs elected to remove lead-
contaminated soil to less than 400 mg/kg to meet the residential and unrestricted
land use criteria. All of the identified lead-contaminated soil on the Site above
400 mg/kg was removed by the PRPs. Additional sampling was done to confirm
that all PCB-contaminated soil was removed to meet the residential use criteria
concentration of less than 1.0 mg/kg. This is a significant change because it
allows for unrestricted future use of the land.
The institutional controls component in the ROD has been deleted because it is
no longer necessary to prohibit future residential land uses at the Site. There is,
however, one limited area of concern identified by the State of Idaho in which
future subsurface excavation may disclose some contamination. The area of
concern has been identified as the Restricted Area and is described above.
While surface sampling in the Restricted Area confirmed that the 400 mg/kg
cleanup level had been met, the subsurface soils were not excavated. There is
presently no information to suggest that there is contamination in the
subsurface. A prohibition on future excavation in the Restricted Area, without
EPA and State approval, will be imposed on the present landowner and all future
landowners.
±0 STATUTORY DETERMINATIONS
The EPA and DEQ believe that the remedial actions, which cleaned up the Site
to lower concentrations of contamination than the ROD required, still remain protective
of human health and the environment even when the Site has no land use restrictions
under CERCLA The changes in the remedy as described in this ESD comply with
federal and state requirements that were identified in the ROD as applicable or relevant
and appropriate to this remedial action at the time the original ROD was signed, and
remains cost effective.
Pacific Hide and Fur
ESD April 16, 1998
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5J) SUPPORT AGENCY COMMENTS
This ESD is consistent with EPA guidance and has been reviewed by the Idaho
Department of Environmental Quality (DEQ). DEQ supports this action and the
implementation of the changes to the Record of Decision.
6J)- PUBLIC PARTICIPATION ACTIVITIES
A public comment period is part of the final Consent Decree process which
completes the cleanup of the Site. A Consent Decree is expected to be signed by the
settling PRPs and the U.S. Government to complete the cleanup process. If there are
any comments on the Consent Decree that would necessitate changes in the ROD, this
ESD, or other aspects of the remedial actions, EPA would address those comments.
The public will be notified of the comment period for the Consent Decree as part
of the Consent Decree process.
LO DECLARATION
This ESD change to the Final Operable Unit ROD continues to be protective of
human health and the environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the remedial action, and is cost
effective. This action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a
principal element.
r// 2*
Randall F. Smith, Director Date
Office of Environmental Cleanup
pr
/ Date
Pacific Hide and Fur
ESD April 16. 1998
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5JQ SUPPORT AGENCY COMMENTS
This BSD is consistent with EPA guidance and has been reviewed by the Idaho
Department of Environmental Quality (DEQ). DEQ supports this action and the
implementation of the changes to the Record of Decision.
6,0 PUBLIC PARTICIPATION ACTIVITIES
A public comment period is part of the final Consent Decree process which
completes the cleanup of the Site. A Consent Decree is expected to be signed by the
settling PRPs and the U.S. Government to complete the cleanup process. If there are
any comments on the Consent Decree that would necessitate changes in the ROD, this
ESD, or other aspects of the remedial actions, EPA would address those comments.
A public notice of the comment period for both the ESD and Consent Decree will
be announced publicly as part of the Consent Decree process.
DECLARATION
This ESD change to the Final Operable Unit ROD continues to be protective of
human health and the environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the remedial action, and is cost
effective. This action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a
principal element.
Randall F. Smith, Director
Office of Environmental Cleanup
Date
NAME
DATE
INITIALS
Thompson
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
IN THE MATTER OF: )
McCarty ' s/Pacif ic Hide and Fur )
Superfund Site )
) FIRST SUPPLEMENT TO
) ADMINISTRATIVE ORDER
Pacific Hide and Fur Depot, Inc., ) FOR REMEDIAL ACTION
a Montana Corporation, dba Pacific )
Steel Hide Recycling Company; )
Mccarty's, Inc., an Idaho ) U.S. EPA DOCKET NO.
Corporation; Lucent Technologies, a ) 10-96-0031 (CERCLA)
Delaware Corporation; ANR Freight )
.System, Inc., a Delaware )
Corporation; FMC, a Delaware )
Corporation,- Monsanto Company, a )
Delaware Corporation; Pacific Fruit)
Express Company, a Utah )
Corporation; J.R. Simplot Company, )
an Idaho Corporation; Terteling )
Company, Inc. , an Idaho )
Corporation; and Union Pacific )
Railroad Company, a Utah )
Corporation, )
Respondents. )
\
Proceeding Under Sections 106 (a) )
of the )
Comprehensive Environmental )
Response, Compensation, and )
Liability Act of 1980, as amended, )
42 U.S.C. § 9606 (a) . )
)
I . INTRODUCTION AND JURISDICTION
•
1. This First Supplement to Administrative Order for
Remedial Action (Supplement) modifies the Administrative Order on
Remedial Action (Order) initially issued on July 12, 1996 to
Hide and Fur Depot, Inc., a Montana Corporation, dba Pacific
Recycling Company; McCarty's, Inc., an Idaho Corporation;
FIRST SUPPLEMENT TO
ADMINISTRATIVE ORDER FOR REMEDIAL ACTION
Pacific
Steel &
Lucent
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Technologies, a Delaware Corporation; ANR Freight System, Inc., a
Delaware Corporation; PMC, a Delaware Corporation; Monsanto Company,
a Delaware Corporation; Pacific Fruit Express Company, a Utah
Corporation; J.R. Simplot Company, an Idaho Corporation: Terteling
Company, Inc., .an. Idaho Corporation; and Union Pacific Railroad
Company, a Utah Corporation, directing that each of the listed parties
implement the remedial design by performing the remedial action for
the remedy described in the Final Operable Unit Record of Decision
(ROD), dated September 27, 1995.
2. Subsequent to issuance of the Order, Pacific Hide & Fur
Depot, Inc., McCarty's, Inc., and Union Pacific Ra-ilroad Company
(Respondents) notified EPA of their collective intent to comply with
the terms of the Order. Respondents proceeded to implement the
remedial action for the remedy described in the ROD.
3. The ROD required the remediation of all lead (Pb)
contaminated soils above an industrial land use scenario, cleanup level
of 1,000 mg/kg. During implementation of the remedial action required
by the Order, Respondents proposed removing additional contaminated
soils to levels at or below the more stringent residential land use
scenario cleanup level of 400 mg/kg. The additional remedial work ;
proposed and subsequently undertaken by Respondents would reduce the
risks to human health and the environment.
4. The additional remedial work proposed by Respondents
represents a significant change to the selected remedy as described
in the ROD. EPA has issued an "Explanation of Significant Differences
(ESD) memorializing the additional remedial work proposed and
FIRST SUPPLEMENT TO
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undertaken by Respondents. The ESD, as required by Section 117 (c) of
the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (CERCLA) , 42 U.S.C. § 9617(c), and the
National Contingency Plan (NCP), 40 C.F.R. § 300.435(c) (2) (1) ,
documents that Respondents removed lead-contaminated soil to levels
at or below the more stringent residential land use scenario cleanup
level of 400 mg/kg.
5. .This Supplement to the Order is .issued under the
authority vested in the President of the United States by Sections
104, 122 (a), and 122 (d) (3) of CERCLA, 42 U.S.C. §§ 9.604, 9622 (a) , and
9622 (d) (3) . This authority was delegated to the Administrator of EPA
on January 23, 1987, by Executive Order 12580 (52 Fed. Reg. 2926,
January 29, 1987), and was further delegated to EPA Regional
Administrators on September 13, 1987, by' EPA Delegation No. 14-14-C.
Under Regional Order Number RIO 1290.3, this authority was further
delegated to the Environmental Cleanup Office Director for EPA, Region
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II. SUPPLEMENTATION OF PRIOR ORDER
6. The intent of this Supplement is to modify the scope
of paragraph 25 of the July 12, 1996 Order to read as follows:
Based on the foregoing, Respondents are hereby ordered to
comply with all provisions of this Order, including, but
not limited to, implementing all actions and performing in
accordance with the requirements of the (a) ROD, as
modified' by the ESD; (b) SOW; (c) attachments to this
Order; (d) documents incorporated by reference into this
FIRST SUPPLEMENT TO
.ADMINISTRATIVE ORDER FOR REMEDIAL ACTION
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All remaining terms and conditions of the July 12, 1996 Order remain
in effect.
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signed by the EPA.
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BY
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Order; (e) the Remedial Design documents; and (f) schedules
and deadlines in this Order, attached to this Order, or
incorporated by reference into this Order.
III. EFFECTIVE DATE AND SUBSEQUENT MODIFICATION
7. This Supplement shall be effective on the date it is
RANDALL F. SMITH, Director
Office of Environmental Cleanup
U.S. Environmental Protection Agency
FIRST SUPPLEMENT TO
ADMINISTRATIVE ORDER FOR REMEDIAL ACTION
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Order; (e) the Remedial Design documents; and (f) schedules
and deadlines in this Order, attached to this Order, or
incorporated by reference into this Order.
All remaining terms and conditions of the July 12, 1996 Order remain
in effect.
Ill. EFFECTIVE DATE AND SUBSEQUENT MODIFICATION
7. This Supplement shall be effective on the date it is
signed by the EPA.
BY:
DATE
RANDALL F. SMITH, Director
Office of Environmental Cleanup
U.S. Environmental Protection Agency
NAME
DATE
INITIAL
Thompson
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FIRST SUPPLEMENT TO
ADMINISTRATIVE ORDER FOR REMEDIAL ACTION
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ADDENDUM #1
to
EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD)
for the
PACIFIC HIDE & FUR RECYCLING CO. SUPERFUND SITE
POCATELLO, IDAHO
From the September 27, 1995,
Final Operable Unit Record of Decision
PURPOSE
The purpose of this Addendum #1 (Addendum) to the Explanation of Significant
Differences (ESD) for the Pacific Hide and Fur Recycling Co., Superfund site is to
further describe the location of the Restricted Area within the site boundary.
BACKGROUND
The ESD was signed by EPA on April 20, 1998, and contains the description of a
Restricted Area. The Restricted Area was defined in general terms in the ESD and has
been subsequently surveyed. A legal description of the Restricted Area, identified as
Parcel "C," is being added to the ESD to provide a precise boundary for the Restricted
Area. A copy of the Survey Plat is also attached to this Addendum.
Pacific Hide and Fur
ESD Add #! 5/12/98
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LEGAL DESCRIPTION OF RESTRICTED AREA
Restricted Area, also known as, Parcel "C"
A parcel of land located in the SW 1/4 of the SE 1/4 of Section 16, T 6 S,
R 34 E, B.M., Bannock County, Idaho, more particularly described as follows:
Commencing at the South 1/4 corner of said Section 16, said corner being
marked by an 8-inch diameter iron fence post as described in Corner
Perpetuation and Filing Record, Instrument #782026;
thence N 0°08'07"E, along the meridional centerline of Section 16, 1202.68 feet
to a point on the Southerly line of Quit Claim deed instrument #93009586;
thence S 56°30'28" E, along said Southerly line, 762.21 feet to a found 1/2-inch
diameter rebar with a red plastic cap stamped " Jacobsen LS 4430";
thence N 37°50'14" W, 143.61 feet to a set 1/2-inch diameter rebar with a red
plastic cap stamped "PLS 8075", said rebar marking the true point of beginning;
thence the following eight courses, the end point of each course being .marked
by a set 1/2-inch diameter rebar with a red plastic cap stamped "PLS 8075";
N61°38'00"W, 151.63 feet;
thence N 30°14'39" E, 49.66 feet;
thence N 86°45'12" E, 46.84 feet;
thence N 53°35'14M E, 36.62 feet;
thence N 14°32'40" E, 90.26 feet;
thence N 27°43'16" W, 46.56 feet;
thence N 35°33'00" E, 24.14 feet;
thence S 62°19'00" E, 154.93 feet;
thence S 29°06'56" W, 246.76 feet to the true point of beginning.
Said parcel containing 0.71 acres, more or less.
ADDENDUM EFFECTIVE DATE
This Addendum shall be effective on the date it is signed by EPA.
Randall F. Smith, Director Date
Office of Environmental Cleanup
U.S. Environmental Protection Agency
Pacific Hide and Fur
ESDAdd*! 5/12/98
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RECORD OF SURVEY PLAT
OF LAND LOCATED IN THE SW1/4 SE1/4
SECTION 16. T6S. R34E. B.M.
ViaNITY MAP
Icctt I* - 1000'
NOTES
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