United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R10-89/018
September 1989
$EPA
Superfund
Record of Decision
Northwest Transformer, WA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R10-89/018
3. Redpienf'e Acceeelon No.
4. TO* «nd SublMe
SUPERFUND RECORD OF DECISION
Northwest Transformer, WA
First Remedial Action - Final
5. Report Dele
09/15/89
7. AuttiorO)
8. Performing Orgwiirtlon Rept No.
9. Performing OrgeJnlntlon Mune aid AdJran
ia ProJect/Teek/WorkUnHNo.
11. Contnc1(O or
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EPA/ROD/R10-89/018
Northwest Transformer, WA
First Remedial Action - Final
16. Abstract (continued)
the soil is PCB.
The selected Remedial action for this site includes excavation, consolidation, and
treatment of approximately 1,200 cubic yards of soil with a PCB concentration greater
than 10. mg/kg using in situ vitrification; placement of two feet of clean fill over the
entire site; abandonment of an onsite well; and ground water monitoring and sampling of
the wood in the onsite barn to determine if a second operable is necessary to address
PCB-contamination in these media. The estimated present worth cost for this remedial
action is $771,000 for soil treatment only with no O&M required.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE. WASHINGTON
RECORD OF DECISION,
DECISION SUMMARY,
AND RESPONSIVENESS SUMMARY
FOR
FINAL REMEDIAL ACTION
NORTHWEST TRANSFORMER (MISSION/POLE)
SUPERFUND SITE
SEPTEMBER 1989
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Declaration for the
Northwest Transformer (Mission/Pole)
Superfund Site
Record of Decision
Site
Northwest Transformer (Mission/Pole)
Hhatcom County, Washington
Statement of Basis and Purpose
This decision document presents the selected Remedial Action for the
Northwest Transformer site In Whatcom County, Washington, developed 1n
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorlzatlon Act of 1986 (SARA), and, to the extent practicable, the
National Contingency Plan. This decision Is based on the Administrative
Record for this site. The attached Index Identifies the Items which comprise
the Administrative Record upon which the selection of the Remedial Action 1s
based.
The state of Washington has verbally concurred on the selected remedy.
Description of Selected Remedy
This Record of Decision addresses on-site soil contamination as a first
operable unit. The selected remedy is In situ vitrification (ISV). The
remedy addresses the principal confirmed threat at the site by significantly
reducing the risk associated with exposure to the contaminated soil and by
reducing the potential for the soil to act as a source for groundwater
contamination. The aquifer will be monitored for contaminant migration and
may have to be addressed as a second operable unit.
In addition, there Is a wooden barn on site that will require some
sampling of the deeper wood matrix to determine whether or not the structure
will need to be treated as a separate operable unit.
The major components of the selected on-site treatment remedy include:
0 Excavation, consolidation, and treatment, via ISV, of approximately
1200 cubic yards of contaminated soil (soils with a PCS
concentration greater than 10 ppm (mg/kg)).
8 Abandonment of the on-site well (in accordance with Washington state
regulations).
8 Placement of approximately two feet of clean fill over the entire
site.
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Implementation of a comprehensive groundwater monitoring program to
determine whether contamination Is moving through the aquifer.
Sampling of the on-site wood structure to determine deeper matrix
contamination.
' The remedy will
significantly reduce
site.
destroy the PCS In the treated soils and therefore
the mobility, toxicity, and volume of contamination on
Continued groundwater monitoring will be performed to ensure the
integrity of the aquifer as a drinking water source. If groundwater analyses
indicate contamination at a concentration in excess of the accepted
U.S. Environmental Protection Agency (EPA) and state of Washington
health-based levels, further action will be initiated as a separate operable
unit.
Declaration
The selected remedy is protective of human health and the environment,
attains federal and state requirements that are applicable or relevant and
appropriate to the Remedial Action, and is cost effective. This remedy
satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the maximum
extent practicable. Because this remedy will result In hazardous substances
remaining on site (I.e., soils with a PCB concentration less than 10 ppm
(mg/kg)). a review will be conducted within five years after commencement of
remedial actlcri to ensure that the remedy continues to provide adequate
'Otectlqfi g£ rtguxf'y health ^n/d the environment.
Robie G. Russell i
Regional Administrator \
U.S. Environmental Protection
Date
Agency, Region 10
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NORTHWEST TRANSFORMER (MISSION/POLE)
SUPERFUND SITE
RECORD OF DECISION
Decision Summary
TABLE OF CONTENTS
Page
I. Site Description 5
II. Site History and Enforcement Activities 5
III. Community Relations History 10
IV. Scope and Role of Response Action 11
V. Site Characteristics 12
VI. Summary of Site Risks 15
VII. Documentation of Significant Changes 22
VIII. Description of Alternatives 24
IX. Summary of the Comparative Analysis of Alternatives 30
X. The Selected Remedy 39
XI. Statutory Determinations 41
XII. Responsiveness Summary 49
Administrative Record Index 58
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I. Sjte Description
Location
The Northwest Transformer Salvage Yard (Mission/Pole) site (hereafter
referred to as the Northwest Transformer or NUT site) is located
.approximately two miles south of Everson in Whatcom County, Washington
(Figure 1). The site, located immediately southwest of the intersection
of Mission and Pole Roads, occupies approximately 1.6 acres in the NE 1/4
of the NE 1/4 of Section 12, Township 39 N, Range 3 E, Willamette
Meridian. .
Topography
The NWT site is located in the Nooksack River basin. The basin lowlands
lie west of the foothills of the Cascade Mountain Range and east of the
Strait of Georgia and Bellingham Bay. The topography of the lowlands is
"the result of glaciation from the Fraser Glaciation, which left westward
trending streams and surface glacial features. The region Is dissected
by the Nooksack River and its tributaries. The course of the Nooksack
River Is dominated by the topography, which has a low gradient, and to a
lesser extent, by geologic structure. The river flows northward less
than one mile east of the site; however, the site does not lie In the
flood plain. The elevation at the site is approximately 120 feet above
mean sea level.
Adjacent Land Uses
The site is bordered by low density residential areas to the north and
east, and by agricultural fields to the south. A small gravel pit is
located approximately 500 feet to the west. Land use in the area is
comprised mainly of rural homesteads, dairies, and farms, with
approximately 200 persons living within a one-mile radius of the site.
Surface and Subsurface Features
. The soil In the area Is glacial outwash consisting of silt, sand and
gravel. Cobbles are commonly present at depths greater than three feet.
Well logs for wells within 2,000 feet of the site indicate that the water
table is encountered between 17 and 40 feet below ground surface. It was
approximately 30 feet below ground surface during the summer months at
the NMT site. At least 27 domestic wells surround the site within a
one-half mile radius. Many of these wells use the water table aquifer at
40 to 50 feet for a drinking water source. Saline water generally-occurs
at a depth of 100 feet or more beneath the lowland area. There is a
wooden structure (an old barn) on the northwest corner of the site (see
Figure 2).
II. Site History and Enforcement Activities
The NWT site was primarily used for the storage and salvage of
transformers prior to final disposition (disposal/sale as scrap) or
transportation to another facility for recycling. As many as several hundred
transformer casings were stored at the unsecured site. The casings were
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BRITISH COLUMBIA
WASHINGTON
WHA TCOM
COUNTY 2
Suptrfund Sit•
WASHINGTON
B«llingham
figure 1
Northwest Transformer
MUslon/Pol« Sit*
-------
LEGEND
3FCOTBORNG
SURFACE SAMPLES
DEEPBORNGS
5FOOTBOHNQS
MONfTORNQtMEUS
APPROXIMATE EXCAVATION AREAS
T.B.M.
r^titei^
»v >»•»•*<»«&«•******A* *»*«)^
I i '
^INCINERATOR
PIT AREA
B
Figure 2
Surface Soil Concentrations of RGBs (ppm)
Northwest Transformer Site
Everson, Washington
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placed directly on the ground, and there were no provisions for weather or
spill protection. Activities at the NWT site Included storage of
transformers; removal of dielectric fluids from the transformers (the primary
source of PCB and related compounds); burning of recovered oils in a space
heater to provide heat for the barn; dismantling of transformers in the barn;
burning of casings and associated parts in an air curtain open pit
Incinerator; and scrap metal reclamation. The open pit Incinerator was a
concrete structure sixteen feet long and eight feet wide with a manifold
designed to blow 8,000 cfm of air into the combustion zone. The incinerator
operated at temperatures of approximately 1,000 to 1,200° F. During operation
of the site, spillage and leakage of the PCB-laden oil onto the ground surface
appeared to have occurred frequently. In addition, It Is suspected that PCB
oil was dumped directly into a seepage pit (sometimes referred to as the
septic tank), in the southeast portion of the site (see Figure 2), where it
would seep out into the surrounding soil. This structure consisted of a pit
with wooden walls and a wooden cover with an access hole. The top was located
at the ground surface and the bottom was approximately six to eight feet below
the surface.
The NHT facility has been inspected several times since 1977. Soil
samples have been collected on a number of occasions. In 1977 EPA analyzed
two samples which revealed a total polychlorinated biphenyl (PCB)
concentration of 80 ppm (mg/kg) for Arochlors 1248 and 1254 In soil near the
Incinerator (see Figure 2) and 510 ppm (mg/kg) for Arochlor 1260 at a location
within the transformer storage area. In 1979 EPA analyzed two samples from
oil-stained areas of soil and found total PCB concentrations of 41 and 60 ppm
(mg/kg). In February 1981, EPA collected and analyzed a sample from the
Incinerator area which Indicated the presence of PCB at a concentration of 160
ppm (mg/kg). Samples were collected by the Washington Department of Ecology
(Ecology) during an August 1984 site inspection In which two soil samples from
an oil-stained area near the roadway indicated PCB levels at 6.3 and 0.72 ppm
(mg/kg).
In August of 1981. the company was cited and fined by EPA for violations
of recordkeeping, marking, storage, dating, and disposal requirements of the
Toxic Substances Control Act (TSCA) PCB Regulation 47 CFR Part 761.
Groundwater sampling results have been Inconsistent. In February 1981,
sampling of four wells showed low levels of PCB (0.05 to 0.11 ug/1) using a
detection limit of .015 ug/1, while In December of 1981, sampling of eleven
wells surrounding the site (Including the four wells sampled In February 1981)
showed no evidence of PCB contamination using a detection limit of .015 ug/1.
Between April 1983 and April 1984, groundwater samples were collected on
a periodic basis from domestic wells near the site by the Whatcom County
District Department of Public Health. PCB was detected in several samples at
concentrations slightly above the minimum detection limit of 0.50 ug/1.
In 1984, the site was added to the National Priorities List (NPL) under
CERCLA.
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A comprehensive soil sampling effort was completed in March 1985 by the -
EPA Region 10 Field Investigation Team (FIT). Sample analyses indicated PCB
soil contamination at the facility to be as high as 38,000 ppm (mg/kg), with
significant concentrations detected at various depths and locations around the
site.
. Five samples were also collected during the March FIT sampling effort and
analyzed for the presence of the full range of dioxin and furan isomers.
Three composite surface samples were collected from the perimeter of the
incinerator pit. Each composite consisted of soil from four discrete points
which were equally spaced around the pit and close to the edge. In addition,
an uncomposited sample was collected from the middle of the field south of the
site. A background sample was obtained from an area near Pole Road,
approximately one-half mile west of the site. Analytical results indicated
that dioxin and furans were present at concentrations well below 1 ppb (ug/1).
In March of 1985, EPA issued a CERCLA 106 Order to the owners of the
company requiring that they take immediate action to mitigate the threat to
public health and the environment.
In April and May of 1985, the EPA Technical Assistance Team (TAT)
Emergency Response Cleanup Services (ERCS) Implemented an Immediate Removal
Action (IRM). Activities Included the following:
0 Enclosure of the site with a chain-link fence.
9 Excavation and disposal of approximately 1,400 cubic yards of
contaminated soil and solid materials (barn soil/concrete, six-inch
surface scraps, 12 to 18 inch excavations. Incinerator pit
excavation and seep pit area excavation, 12 to 18 feet below the
ground surface.)
0 Draining, rinsing, and cleaning of thirty-five transformers.
0 Removal of approximately 6,000 gallons of PCB-contamlnated liquids
(less than 500 ppm (mg/1)).
0 Removal of approximately 660 gallons of PCB-contaminated liquids
(greater than 500 ppm (mg/1)).
0 Removal of four transformer casings and one drum found to be
contaminated by PCB (greater than 500 ppm (mg/1)).
8 Decontamination of concrete and selected wood surfaces of the barn.
0 Installation of five groundwater monitoring wells and sampling of
the associated soil and groundwater.
0 Two rounds of domestic well sampling: first round, twenty-one
residences, and second round, sixteen residences.
The NWT site was significantly altered by the IRM In 1985. The purpose
of the Remedial Investigation (RI) was to gather sufficient information and
data to characterize the degree and extent of contamination (if any) remaining
at the site.
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In June of 1987, the Remedial Investigation/Feasibility Study (RI/FS)
sampling effort took place. The scope of the RI included:
• Collecting and analyzing four ditch samples Immediately outside of
the security fence to determine if there was any off-site soil
contamination.
• Collecting and analyzing forty-eight randomly-located surface soil
samples to determine the degree and extent of contamination.
primarily In areas that were not disturbed by the IRM.
0 Collecting and analyzing surface and subsurface soil samples from
shallow (five-foot) borings at fifteen locations which were
determined to be "hot spots" prior to the IRM. The locations are
primarily south of the barn and are in an area that had six inches
to one foot of soil removed during the IRM.
•° Collecting and analyzing surface and subsurface soil samples from
deep (twenty- to forty-foot) borings at three locations near the
former septic tank area. This area was excavated during the IRM.
0 Collecting and analyzing surface and subsurface soil samples from
one shallow (three-foot) boring in the area of the former
Incinerator pit to determine the degree and extent of contamination
remaining. This area was overexcavated at least one foot during the
IRM.
0 Collecting and analyzing two surface soil samples and one wood
sample from the barn to verify the effectiveness of the
decontamination effort during the IRM.
0 Collecting and analyzing background soil samples from locations that
could not have been reasonably impacted from site operations.
• Collecting and analyzing groundwater samples from five on-slte
monitoring wells and four off-site residential wells to determine
the degree and extent of groundwater contamination.
III. Community Relations History
Community relations activities conducted for the NHT site to date include
the following:
In 1984 the site was added to the NPL under CERCLA.
In May 1985, EPA began an IRM at the site (see Section II). EPA
addressed community Information needs about the action at that time
through press releases.
8 In March 1986 community interviews were conducted in preparation for
the community relations plan.
0 The RI field Investigation began in June 1987. This was announced
In a May 1987 fact sheet sent to all citizens and local officials on
the EPA mai1 ing list.
10
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e In July 1988, a fact sheet updating progress at the site was sent to
all people on the EPA mailing list.
0 The proposed plan was mailed out on August 17, 1988.
. 8 On August 17, 1988, EPA placed a public notice in the local
newspapers announcing the following:
0 Brief description of the investigation results.
0 Public comment period running from August 17 to
September 21.
0 Location of the information repositories.
EPA contacts.
0 Potentially Responsible Parties
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The potential threat posed by contaminated groundwater associated with
the site is uncertain. Analyses of samples obtained from on-slte wells
Indicate low levels of contamination; however, analyses of samples obtained
off site are Inconclusive. A groundwater monitoring program that is designed
to 1) detect trace levels of PCS in the aquifer and 2) more clearly define
aquifer characteristics will be Implemented to allow for a better assessment
of the risk, If any. due to the use of groundwater as a drinking water
source. If groundwater analyses indicate groundwater contamination in excess
of the EPA and state of Washington health-based levels, groundwater will be
acted on as a separate operable unit.
In addition to soils and groundwater, there is a wooden structure (an old
barn) on site that was used for transformer repair and storage. The barn was
heated at times by burning PCB-contamlnated oil. Surflcial samples (I.e.,
wood shavings) were obtained during the RI and analyzed for PCB
contamination. The analyses indicated PCB concentrations below 1 ppm (mg/kg);
however, core samples will be required to determine the extent of at-depth
contamination. If core samples Indicate significant levels of PCB In the
wooden structure, the barn will be acted on as a separate operable unit.
V. Site Characteristics
Contaminant Characteristics
The contaminant of concern at the NWT site is PCB, primarily Arochlor
1260. It Is unlikely that free-flowing PCB-bearing fluids (I.e.,
transformer dielectrics) are still present at the site. PCB Is readily
adsorbed onto soil particles and does not easily leach from soil.
Adsorption of PCB by soil Is related to the organic content of a
particular soil type, and PCB recovered from soil Is found to concentrate
In the organic fraction of the soil media. The low water solubility and
low volatility of PCB also suggest that it is partitioned most heavily
Into the organic fraction of soil. The rate of PCB movement In saturated
soil has been found to be between one-tenth and one-hundredth the rate of
groundwater movement.
Affected Matrices Characteristics
For site management, stabilization, and cleanup purposes, the NWT site
can be divided Into specific affected matrices.
The following discussion summarizes the characteristics and volumes of
each matrix that are relevant to the Identification, screening, and
selection of remedial technologies and strategies.
Soil
The contaminant of concern in the soil is PCB. The
trl-tetrachlorobenzenes were not included in analyses because these
more volatile compounds were not expected to be persistent in
surface soils, especially considering the length of time between the
EPA IRM and the RI sampling effort. The distribution of PCB
contamination in the surface soil is shown in Figure 2 (p.7). PCB
12
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contamination has been shown to exist at levels exceeding the
April 1985 IRM cleanup level of 10 ppm (mg/kg) in two areas: 1) the
area south of the barn and 2) the former seepage pit area
(Figure 2). PCB concentrations between 1 and 10 ppm (mg/kg) exist
In surface soil throughout the site.
During the July 1987 RI, shallow subsurface samples were taken from
2.5 and 5.0 feet below ground surface at selected locations. The
principal contaminant of concern in these samples was PCB. The
trl-tetrachlorobenzenes were not detected in the samples. Results
indicated that PCB contamination generally decreased with depth and
that the PCB levels were at or below 1 ppm (mg/kg) below the depth
of five feet. The PCB analytical data show concentrations at or
above 10 ppm (mg/kg) in the area just south of the barn. Analytical
data indicate that below 2.5 feet some PCB concentrations are
between 1 ppm (mg/kg) and 5 ppm (mg/kg). PCB concentrations in the
subsurface soil in the seepage/septic tank area range between 1 to
10 ppm (mg/kg) at a depth of 19 feet.
The volumes of soil within the ranges of PCB contamination reported
In the FS are shown in Table 1.
The surface area of the site is approximately 70,000 square feet
(7,778 square yards) or approximately 1.6 acres.
Groundwater
There are two current primary PCB sources relative to groundwater
contamination beneath the NWT site and vicinity. First, historical
dumping of potentially high but undocumented concentrations of PCB
in the seepage pit may have resulted In significant PCB migration
into groundwater In the past. This high level contamination could
act as a future source of groundwater contamination by PCB. The
current low level PCB soil contamination can be considered a second
source. The soil PCB contamination could act as a constant low
level source of groundwater contamination until the site is
remediated.
Based on the results of this RI and previous investigations, PCB
contamination in groundwater has not been adequately characterized
to assess the lifetime incremental cancer risk through ingestion of
contaminated water, nor have the groundwater flow patterns been
fully determined.
On-Slte Structure (Barn)
During the IRM.-a significant amount of washing, rinsing, and
sandblasting of the surface of wooden structural members inside the
barn was conducted: however, there is uncertainty as to the
effectiveness of the decontamination of the deeper wood matrix of
the barn. Core samples of the wood must be analyzed for PCB before
all remediation alternatives, including the no action alternative,
can be evaluated for the barn.
13
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TABLE 1 NORTHWEST TRANSFORMER: ESTIMATED VOLUMES
ASSOCIATED WITH SURFACE SOIL CLEANUP LEVELS
RESIDUAL PCB
CONCENTRATION
(PPM)
40
32
24
16
10
8
5
1
EXCAVATION
DEPTH IN
10 PPM AREA
(ft.unm
0.0
0.5
1.0
1.5
1.9
2.0
2.2
2.5
VOLUME OF
SOIL FROM
10 PPM AREA
(cu.vd.Hli
0
313
625
938
1,172
1,250
1,367
1,563
VOLUME OF
SOIL FROM
AREA BETWEEN
10 AND 1 PPM
(cu.vd.un
0
0
0
0
0
171
468
964
TOTAL
VOLUME OF
SOIL
(cu.vd.)
0
313
625
938
1,172
1,421
1,836
2,526
(1) See Figure 2 for isoconcentration contours.
(2) Assume that concentration decreases from surface (avg
ft. depth (1 ppm) In a linear manner.
40 ppm) to 2.5
14
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Migration Pathways
The transport of the chlorinated contaminants In the environment is
controlled by their physical properties. Three potential pathways
of migration exist: groundwater, air, and surface water.
The potential for airborne migration of PCS from the site is
minimal. The contaminants, especially the more chlorinated isomers,
are not highly volatile. Also, the high equilibrium binding
constant for PCS in soil indicates that contaminants bind tightly to
the soils. Heavy vegetation on the site virtually eliminates any
migration of contaminants on particulates generated from wind
erosion. If surface vegetation is removed, the resulting wind
dispersion of existing contaminated surface soils is not expected to
result In off-site PCS contamination greater than one mg/kg based on
results of background soils and on-slte surface soils obtained In
July 1987.
Likewise, the potential for transport of PCS from the site via
surface water Is minimal. Due to the very high permeability of the
soils at the site and relatively flat topography, surface water
runoff from the site Is minimal.
It Is for these reasons that the major potential pathway of
contaminant migration Identified for this site Is the regional
groundwater system. PCS is readily absorbed from water by solid
particles and only slowly leaches from soils. PCB has poor mobility
through saturated soil. Downward movement of contaminants would be
effected very slowly by water infiltration from precipitation
coupled with sorptlon/desorptlon mechanisms based on contaminant
solubility. Rapid downward movement and horizontal migration would
only be suspected If large quantities of oil-soluble solvents were
allowed to percolate through the soil.
The highest potential for the downward migration appears to be 1n
the seepage pit area, where the excavated and caved area tends to
funnel precipitation. Review of previous investigations indicates
that unknown amounts of liquids were disposed of in this area of the
site by dumping Into the seepage pit. The construction of this pit
was such that liquids would seep out to the surrounding formations.
Sources of the liquids are not known but are suspected to Include
some portions of the liquids generated on site. Unless large
quantities of solvents were dumped into the excavated area,
migration of PCB would not be expected to be significant.
VI. Summary of Site Risks
Introduction
The surface, subsurface, and deep soils at the NWT site were analyzed for
all or a subset of the following contaminants: PCB, volatile organics,
semi-volatile organics, polychlorinated dlbenzo-p-dioxins and
dibenzofurans, and inorganics. Groundwater samples were analyzed for
PCB, volatile organics, and semi-volatile organics.
15
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The results showed PCB contamination in soils and in all five of the
groundwater wells on site. Because of the questionable quality of the
data from the off-site wells, it is not clear if they are contaminated
with PCB. Low levels of penta through octachlorinated dlbenzofurans
and/or dloxins were found in the soil samples from the burn pit that were
analyzed for these compounds. Of the other organics (volatile and
semi-volatile) analyzed for, acetone and methylene chloride were
Identified at or just below the detection limit in some of the samples
and blanks. Inorganics in soil samples were at or below background
levels except for copper and lead, which were slightly elevated in two
samples.
A risk assessment was performed for PCB in soil and groundwater and for
chlorinated dioxins and furans in the burn pit samples. Both acetone and
methylene chloride were present at very low levels in several of the
off-site groundwater samples and were likely found because of their use
as laboratory solvents. For the inorganics that were found at
concentrations above background (lead and copper), only lead Is of
concern to human health. The maximum soil lead level (53 ppm (mg/kg))
was well below the level of concern for lead in soil.
Toxicity of PCB and Polychlorinated Dlbenzofurans and Dibenzo-p-dioxins
The Arochlor oil used in transformers contains a mixture of PCB in
various proportions. The majority of the Arochlors found In the soil
samples at the NWT site was Arochlor 1260; the type of Arochlor present
in the water samples was not identified.
Each PCB compound may exhibit its own toxlcological characteristics. In
general, however, PCB has been shown to produce a variety of non-cancer
health effects in laboratory animals, including liver, thyroid, and
reproductive toxicity. Several studies have also shown that PCB causes
cancer in laboratory animals. The combination of the sufficient evidence
from these animal studies and inadequate, but suggestive, evidence from
human studies leads to a designation of PCB as a probable human
carcinogen. Group B2, under EPA guidelines. EPA has estimated an oral
cancer potency value of 7.7 per mg/kg/day for Arochlor 1260 based upon a
study by Norback and We Itman (For this and following references, see the
revised Risk Assessment, which is part of the Administrative Record for
the site.) In which chronic dietary administration of Arochlor 1260 was
shown to cause liver cancers In rats. A separate cancer potency value
for Inhalation of PCB has not been developed by EPA. For this risk
assessment, the inhalation potency of PCB was assumed to be the same as
the one calculated for the oral route.
Chlorinated dibenzo-p-dioxins and dlbenzofurans are structurally similar
compounds. They are not intentionally made for any commercial purpose,
but rather are by-products created during the manufacture of other
chemicals or as a result of incomplete combustion of materials containing
chlorinated compounds, such as PCB. There are seventy-five different
chlorinated dioxin isomers and over one hundred furan isomers. The toxic
effects of these isomers can differ markedly depending upon the location
and number of chlorine molecules. The most toxic isomer,
2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDO), has been shown to
cause many different types of toxic effects in animals, including
reproductive effects, thymic atrophy, and a "wasting syndrome" leading to
death.
16
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2,3,7,8-TCDD, as well as a mixture of two 2,3,7,8 hexachlorodibenzo-
p-dloxlns, have been shown to cause cancer in laboratory animals and are
among the most potent animal carcinogens evaluated by EPA to date.
Available experimental data suggest that some of the other chlorinated
dioxins and furans may exhibit similar toxic effects. The toxicity of
each chlorinated dioxin and furan is estimated relative to that of
2,3,7,8-TCDD by using a toxicity equivalence factor (TEF) approach
derived by EPA from comparisons with the in vitro tests. With the TEF
procedure 2,3,7,8 TCDD is always given a value of 1 and other chlorinated
dioxins and furans a value that is a fraction of this.
Baseline Risk Assessment for PCB - Maximum Cancer Risk for an Individual
Estimates of risk from exposure to PCB in soil and groundwater were made
assuming the following exposure scenarios:
0 Residential Scenario—The NWT site may sometime become a residential
area. Humans could be directly exposed to PCB in soils as a result
of ingestlon and inhalation of contaminated soils, absorption of PCB
from soils onto skin surfaces (dermal absorption), and Indirectly
through the ingestlon of vegetables that are grown In contaminated
soil. In addition, it was assumed that PCB-contamlnated water from
wells dug on the site would be used for drinking water.
• Grazing Scenario—Since the soils at and surrounding the site are
designated as prime farmland by the Soil Conservation Service, the
NWT site may sometime become farmland used for cattle grazing.
Residential Scenario
In this scenario, it was assumed that a person lives on the NWT site
for an entire lifetime (70 years) and that:
1. Children (ages 0-5 years) Ingest 0.05 to 0.5 grams of soil per
day as a result of hand-to-mouth activity.
2. Older children and adults Ingest from 0.05 to 0.25 grams of
soil per day.
3. Inhalation rate Is 20 m3/day for all age groups.
4. The concentration of dust In the air at the site is 50 ug/m^.
5. Skin contact with soil ranges from 0.1 g to 10 g per day for
children, and is 0.1 g per day for adults.
6. Soil exposure occurs six months per year.
7. The absorption of PCB from soil in the gastrointestinal (GI)
tract is 30%; through the lung, 507.; and through the skin, 17..
8. Children and adults ingest two liters of water per day;
absorption of PCB in the GI tract is 100X.
17
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9. PCS uptake values [ug/g of PCBs In plant tissue (dry weight)
per ug/g of PCBs in soil (dry weight)] for root crops, garden
fruits, and leafy vegetables were estimated to be 0.150, 0.007,
and 0.013, respectively. It was assumed that from 25X to 100%'
of the vegetables consumed by a person are grown on the NWT
site.
10. PCS concentrations in soil and water will remain the same over
the next seventy years (i.e., no degradation in soil occurs and
no changes in groundwater concentrations occur).
These exposure parameters were selected from the literature because
they appear to be the most reasonable and fairly conservative and
because they give a range of exposure values with which to calculate
risk. The final exposure parameters to be selected are the PCB soil
and groundwater values.
Direct Soil Contact: Ingestlon, Inhalation, and Dermal
Absorption
For soils, the PCB concentrations In surface soil samples were
used since human exposure to surface soil Is of greatest
concern in the residential scenario. Existing surface soil
values at the site range from below the detection limit of
25 ppb (ug/kg) to 92 ppm (mg/kg). Risk estimates were
performed using the weighted average surface soil concentration
(6.6 ppm (mg/kg)) for the site as well as the weighted average
soil concentration plus two standard deviations (36.9 ppm
(mg/kg)) to account for the fact that some "hot spots" of
contamination are present.
Using the average PCB soil concentration (6.6 ppm (mg/kg)) to
calculate risk from Ingestlon, Inhalation and dermal absorption
results in an estimated upper-bound lifetime cancer risk of
2 X 10-5 to 7 X 10-5 (2 chances In 100,000 to 7 chances in
100.000). Using the average soil value plus two standard
deviations (36.9 ppm (mg/kg)) results in an estimated
upper-bound lifetime cancer risk that is about five to six
times higher, or 1 X 10~4 to 4 X 10~4.
Groundwater
Three analyses of the five on-site monitoring wells have been
performed. Two of these (done In April 1985 and July 1987)
used detection limits of 1.0 ug/1 and showed no contamination.
The third analysis, done by EPA in May 1985, used a detection
limit of 0.02 ug/1. Contamination ranging from 0.03 ug/1 to
0.12 ug/1 was found in all five wells. The average value of
0.06 ug/1 and the maximum value of 0.12 ug/1 from the May 1985
analysis were used to estimate the upper-bound lifetime risk of
developing cancer from drinking on-site groundwater. This
resulted in risks of 1 X 10'5 and 3 X 10~5 for the average
and maximum values, respectively.
18
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Vegetables
To calculate exposure to PCB through ingestion of vegetables
grown on the NNT site, ft is necessary to have estimates of the
PCB concentrations expected In vegetables grown on the site and
estimates of the consumption rates of these vegetables.
Estimates of PCB Concentrations in Vegetables
To estimate the PCB concentrations In vegetables, both
published and unpublished literature of PCB uptake into
vegetables was reviewed. The literature available is very
limited and uptake factors Cug/g of PCB in plant tissue
(dry weight) per ug/g of PCB in soil (dry weight)] for a
given vegetable varied greatly depending on several
factors, including the type and amount of PCB isomer
present in the soil and the type of soil. When possible,
the uptake factors used in the Risk Assessment were those
estimated from experiments where Arochlor 1260,
Arochlor 1254, or highly chlorinated Isomers were present
In the soil at levels ranging from a few parts per million
PCB up to about 100 ppm (mg/kg) PCB. These experiments
were chosen since they most closely represent conditions
at the site [I.e., presence of highly chlorinated PCB In
soils at concentrations up to 92 ppm (mg/kg)].
The uptake factors used in this risk assessment and the
information upon which they are based are summarized
below. More details of these calculations are presented in
Appendix 1 of the revised Risk Assessment, which is
included in the Administrative Record for the site.
Root Crops
Data from Wallnofer, et al. and Iwata, et al. were
used to estimate an uptake factor for carrots of
0.30. An uptake factor for radishes of 0.007 was
also calculated from Wallnofer, et al. and uptake
factors of 0.002 and 0.008 for beets and turnips,
respectively, were calculated from Sawhney and Hankin.
It was assumed that 501 of the root crops consumed at
the site would have an uptake factor equal to that of
carrots (0.30) and 50% would have an uptake factor
equal to that of the average of the other three root
crops (0.006). This resulted in a weighted average
uptake factor for all root crops of 0.15. It was
assumed that all root crops are eaten unpeeled.
Garden Fruits
Garden fruits include such vegetables as beans, peas,
eggplant, and tomatoes. Only one reference was
found, that of Sawhney and Hankin, which contained
information on any garden fruits (bean pods). Use of
this data resulted in a calculated uptake factor for
garden fruits of 0.007.
19
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Leafy Vegetables
No data on PCB uptake Into lettuce, spinach, and
other commonly eaten leafy vegetables were found.
However, data are available for beet greens and
turnip greens; therefore, these data were used to
calculate an uptake factor for the leafy vegetable
group. Using the data of Sawhney and Hankln resulted
1n an uptake factor of 0.004 for beet leaves and
uptake factors of 0.002 and 0.007 for turnip leaves.
The data of Strek, et al. resulted in a calculated
uptake factor of 0.45 for beet tops.
The uptake factor used for leafy vegetables (0.013)
was estimated by calculating the geometric mean of
the four values (0.004, 0.002. 0.007. 0.45) for beet
greens and turnip greens.
Potatoes
Data provided by Lewis Naylor Indicated no detectable
uptake of Arochlor 1254 when potatoes were grown on
soils containing from 0.08 to 1.3 ppm (mg/kg)
Arochlor 1254. Therefore, an uptake factor of 0 was
assumed for potatoes.
Vegetable Consumption Rates
Consumption rates for leafy vegetables, garden fruits, and
root vegetables were calculated using data presented in
"Methodology for the Assessment of Health Risks Associated
with Multiple Pathway Exposure to Municipal Haste
Combustor Emissions" (October 1986. EPA, external
draft). In this document, consumption rates for various
food groups (In grams per day, dry weight) are presented
by sex and for certain age groupings. These consumption
rates are based on a reanalysls of data compiled In the
FDA Total Diet Study.
For this Risk Assessment, the consumption rates In the EPA
document were adjusted to provide consumption rates for
three age ranges covering 0-70 years of age:
1. A 0-11 month old child (based upon the consumption
rate for a 6-11 month-old given in the EPA document).
2. An 11 month - 5 year-old child (based upon the
consumption rate for a 2 year-old given in the
document).
3. Older children and adults, from 5-70 years of age
(based upon the average of all the consumption rates
(male and female) for a 14-65 year-old given in the
document).
20
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Estimation of Increased Cancer Risk from Consumption of
Vegetables
To estimate the risk from ingesting vegetables grown at
the NWT site, two different scenarios were used. In the
first, it was assumed that 100% of the vegetables consumed
by a person were grown on the site; in the second, it was
assumed that 25% of the person's vegetables were grown on
the site.
Using the average PCS soil concentration (6.6 ppm (mg/kg))
to calculate risk from vegetables results in an estimated
upper-bound lifetime cancer risk of 2 X 10-5 (assuming
25% of vegetables are grown on site) to 9 X 10~5
(assuming 1007. of the vegetables are grown on site).
Using the average soil value plus two standard deviations
(36.9 ppm (mg/kg)) results In an estimated upper-bound
lifetime cancer risk of 1 X 10~4 (1f 25% of vegetables
are grown on site) to 5 X 10~4 (1f 100% of vegetables
are grown on site).
Risk from all Exposure Routes for the Residential Scenario
The Increased chance of developing cancer from the three routes
of exposure to PCB in the residential exposure scenario can be
obtained by adding the risks from direct contact to soils, from
drinking water consumption, and from vegetable consumption (see
Table 7). Using the average soil PCB concentration on site
(6.6 ppm (mg/kg)) results in estimated risks ranging from
5 X 10~5 (using the less conservative Ingestlon and skin
absorption factors, assuming 25% of vegetables consumed are
grown on site, and using the average groundwater
concentrations) to 2 X 10~4 (using the more conservative
Ingestion and skin absorption factors, assuming 100% of
vegetables consumed are grown on site and using the highest
groundwater concentration).
Using the higher soil PCB concentration (36.9 ppm (mg/kg),
average plus two standard deviations) results in risks ranging
from 2 X 10~4 (using the less conservative values) to
9 X 10~4 (using the more conservative values).
Grazing Scenario
In this scenario, it is assumed that the NWT site is converted to
agricultural land that is used for beef and dairy cattle grazing.
PCB can be ingested by cattle because they consume soil during
foraging (about 0.72 kg of soil/day). Therefore, if soil is
contaminated, beef and milk can also become contaminated.
To estimate the risk from ingesting beef and dairy products from
cattle raised on the NWT site, two different scenarios were used.
In the first, it was assumed that 100% of the beef and milk products
consumed by a person are from cattle raised at the site; in the
second, it was assumed that 25% of their beef and milk products come
21
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from cattle raised at the site. It was also assumed that the
average soil value of 6.6 ppm (mg/kg) Is the most appropriate to use
for livestock grazing.
Uptake studies of PCS by cattle are not available; therefore, data
on polybrominated blphenyls (PBBs) were used. Fries and Jacobs
conducted studies In which cattle were kept 1n an area where soils
were contaminated with PBBs. Under these conditions, the beef
fat/soil ratio was 0.39 and the milk fat/soil ratio was 0.40. An
assumption was made that the same fat/soil ratios exist for PCS.
In Schaum, the following table is given:
Total Consumption Percentage Fat Consumption
Rate (g/person-day) Fat Rate (g/person-day)
Beef 124 15 19
Dairy Products 550 7.8 43
Using these data, the cancer risk for a person who obtains all his
beef and dai
to be 1 X 10
beef and dairy products from cattle grazing on the site is estimated
i~fc
The cancer risk for a person who obtains 251 of his beef and dairy
products from cattle grazing at the site is estimated to be
2.5 X 10-3.
Uncertainties in Risk Assessment Estimates
Many uncertainties exist and several conservative assumptions were used
in generating the risk estimates just discussed. For example, the
exposure scenarios presented are conservative ones and represent
reasonable worst cases; yet they could potentially occur If the site 1s
converted to residential or agricultural land. Several of the exposure
parameters used (e.g., soil Ingestlon and dermal contact rates, vegetable
uptake factors, uptake of PCB Into cattle) are estimates and may be
higher than actually would occur. Finally, the cancer potency value for
PCB Is based upon oral studies in animals at high concentrations and must
be extrapolated to humans.
Therefore, these cancer risk numbers should not be considered precise
numbers but rather conservative estimates that err on the side of
safety. The actual risks due to potential future exposure at the site
are unlikely to be higher than those presented here and could well be
much lower; however, because PCB Is a probable human carcinogen, it is
prudent to use conservative estimates of risk in deciding what remedial
action may be needed at the NUT site.
VII. Documentation of Significant Changes
The FS and the Proposed Plan recommended thermal destruction of PCB in
PCB-contamlnated soils with concentrations at or above 10 ppm (mg/kg).
22
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Table 2
Baseline Bisk Assessment for PCBs1
Residential Scenario
PCB Soil
LCYtlS
Estimated Upper-Bound
Lifetime Cancer Risks
Consumption
6.6 ppm2
36.9 ppm3
Direct Soil
Contact
2-7 X ID'5
1-4 X 10"4
Of
Homegrown
Vegetables
2-9
1-5
X 10*s
X 10**
Drinking
Water
1-3 X lO'5
1-3 X 1
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Thermal destruction technologies include incineration and vitrification, as •
well as the thermal-based processes such as catalytic combustion and infrared
destruction. Upon further review and cost analysis by EPA and further review
of documentation of demonstrations of the vitrification technology, the best
thermal destruction process for this site was determined to be vitrification.
This determination was made based on 1) relative ease and foreseen schedule of
mobrlization, 2> advantageous costs over other thermal processes as reflected
in the FS, 3) acceptability of the vitrified mass as an on-site residue over
other conventional materials classified as ash, 4) the foreseen local
acceptance of contained, "in-the-ground" thermal destruction of PCB
contaminants over conventional incinerator operations, and 5) the criteria set
forth for technology selection in the FS.
In addition, EPA has been provided with an updated cost for ISV for
smaller scale applications ($250-$330/ton versus $180/ton). One unknown
regarding ISV Is the availability and cost of the appropriate high-voltage
electrical service. EPA has been advised that In regions where electrical
service is Insufficient to accommodate the system, a mobile substation can be
provided. This additional power source represents a ten to twelve percent
increase in the project cost, yielding a minimum small-scale cost range of
approximately $275-$350/ton. The cost of this technology Is still within the
range of costs cited In the Proposed Plan under thermal destruction.
VIII. Description of Alternatives
For this operable unit, remedial action technologies have been
specifically evaluated and selected for application to the surface soil
contamination and associated exposure/migration routes. During the initial
stage of the FS process, a broad range of possible treatment/disposal
technologies were identified and evaluated. Several alternatives were found
to be acceptable In terms of the primary screening criteria used. These
alternatives included the following:
Off-site landfill
Off-site Incineration
0 On-s1te thermal destruction
0 On-site soil washing
0 On-site Immobilization
8 On-site thermal stripping
0 On-site dechlorination by potassium hydroxide and polyethylene
glycols (KPEG)
0 In situ vitrification
In situ immobilization
0 Capping
Cover
24
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Secondary screening of these technologies in terms of feasibility,
environmental and public health concerns, and costs reduced the number of
technologies to five. These five technologies were then assembled to develop
the alternatives described below.
The estimated volume of soil contaminated with PCS at a concentration
greater than or equal to 10 ppm (mg/kg) is approximately 1200 cubic yards.
This volume estimate is based on a 25 X 25 foot soil sampling grid utilized
for RI sampling and an assumption that the concentration of PCS decreases
linearly In the soil with depth.
All alternatives (except the no action alternative) will include
abandonment of the one on-site well In accordance with state law. In
addition, a groundwater monitoring program and sampling of the deeper wood
matrix of the barn timbers will be included as a part of the remedial action
for the site.
t
Alternative 1: Off-Site Management
This alternative Includes the excavation of PCB-contamlnated soil with a
concentration greater than or equal to 10 ppm, transport to a
TSCA-approved chemical waste landfill for disposal, and backfilling of
the excavated area, to grade. In addition, a two-foot soil cover would
be applied and hydroseeded for stabilization.
The Implementation of this alternative Is relatively straightforward with
the soils being transported in truckloads of approximately 10 cu yd per
load.
This alternative would meet all Applicable, Relevant, and Appropriate
Requirements (ARARs) including the "to be considered" requirements by
removing the soils with a PCS concentration greater than or equal to 10
ppm from the site. The risk due to exposure to the residual
contamination (soils with PCS concentrations less than 10 ppm (mg/kg)>
would be significantly reduced with the placement of the two-foot clean
soil cover.
Covers less than two feet In depth are not considered adequate for future
use of the site (I.e., crop growth or cattle grazing) and would be used
only with conditions/restrictions placed on future property use. The
two-foot depth limit 1s derived from recommended tilling depths for
common root crops.
Alternative 2: Vitrification
Vitrification Is a thermal destruction/stabilization process that
converts contaminated soil into a chemically inert, stable glass and
crystalline product. Four electrodes are placed in a square arrangement
and inserted into the ground to the desired treatment depth (see Figure
3). Because the soil is not electrically conductive, a mixture of flaked
graphite and glass frit is placed among the electrodes to act as a
starter path. An electrical potential is applied to the electrodes,
which establishes an electrical current in the start path. The resultant
power heats the starter path and surrounding soil to 3600° F, well above
the initial melting temperature or fusion temperature of soil (2000° and
25
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Support Trailer
x. Electrical System
Glycol Cooling System
Control Trailer
.-•\"*
S" Site to Be
"XT'- Vitrified
v:
Electrode'
Off-Gas Hood
Cover
HEPA Filter
Housing
Figure 3
In Situ Vitrification
26
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2500*). The graphite starter path is eventually consumed by oxidation,
and the current Is transferred to the molten soil, which is now
electrically conductive. As the vitrified zone grows, it Incorporates
nonvolatile elements and destroys organic components (PCB) by pyrolysis.
The pyrolyzed by-products migrate to the surface of the vitrified zone,
where they combust in the presence of oxygen. A hood placed over the
processing area provides collection of the combustion gases, which are
drawn off to the off-gas treatment system.
Because the depth of contamination in the soil at NWT is relatively
shallow, use of the vitrification process would require staging the
contaminated soil to a trench or stockpiling It above ground in order to
achieve a more appropriate process depth. A typical configuration for
treatment is a 20 to 25 foot square, 10 to 15 feet deep. The soil at the
site would have to be placed in such a configuration in order to make the
use of vitrification cost effective.
The soil characteristics at the NWT site are compatible with use of this
technology. The gravelly and sandy soil do not Interfere with the
process; however, moisture content of the soil could cause additional
costs.
Prior to the implementation of this technology, a site-specific
treatability test would be required to:
1. Obtain confirmation that ISV is technically applicable to the
PCB-contamlnated soils at the site.
2. Confirm that the treatment levels required (I.e. a residual
product that contains less than 1 ppm PCB) can be obtained.
3. Determine any technical factors that may cause the cost of
remedial operations to vary from the FS estimates.
This alternative would meet all ARARs (Including the "to be considered"
requirements) by destroying the PCB contamination in the treated soils,
such that the concentration of PCB In the residual remaining after
treatment is less than 1 ppm.
The risk due to exposure to the residual contamination (soils with PCB
concentration less than 10 ppm (mg/kg)) would be significantly reduced
with the placement of the two-foot clean soil cover.
The vitrified mass would be left on site once it was determined to
contain less than 1 ppm of PCB. It is estimated that the remaining
vitrified mass would occupy approximately one-sixth of an acre.
Alternative 3: Soil Hashing
Soil washing Involves the on-site excavation and extraction of organic
contaminants (PCB) by contacting soil particles with a solvent. The
solvent is then separated from the soil and the solute is concentrated by
distillation or other processes. The solvent may then be recycled to the
extraction process, and the washed soil is returned to the site. The
27
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only type of solvents that would be appropriate for use at the NWT site
are chemicals that are proven not to pose a public health or
environmental hazard due to the high level of the groundwater table. The
concentrated solutes and/or unrecycled contaminated solvent must be
handled as hazardous waste after treatment is completed. Typically, the
•PCB residues from pilot tests exceed 500 ppm (mg/1) and must, therefore,
be incinerated or further treated to destroy the PCB residues. These
final treatment technologies include hydrolysis, ultraflltration. reverse
osmosis, carbon adsorption, dechlorinatlon, and the light-activated
reduction (LARC) process.
The majority of the techniques for soil washing are in the pilot research
phase, yet preliminary field work Indicates that soil washing may be a
feasible alternative for the NWT site. The EPA high pressure soil
washing technique, using only water and surfactants as solvents, would
significantly reduce the volume of leachate that would require further
treatment. Another advantage is that this method does not Introduce
additional chemicals into the site soil.
Prior to Implementation of this technology, a site-specific treatability
test would be required to:
1. Determine whether soil washing is technically applicable to the
PCB-contaminated soils at the site.
2. Confirm that the treatment levels required can be obtained.
3. Determine any technical factors that may cause the cost of
remedial operations to vary from FS estimates.
4. Determine which leachate treatment technology would be most
applicable.
This alternative would meet all ARARs (Including the "to be considered"
requirements) by removing the PCB contamlnaton from the treated soils to
a concentration of less than 2 ppm.
The risk due to exposure to the residual contamination (soils with PCB
concentration less than 10 ppm (mg/kg)> would be significantly reduced
with the placement of the two-foot clean soil cover.
Alternative 4: Asphalt Cap
The surface sealing technique of using asphalt as a capping material is
an effective measure for reducing or limiting the exposure pathways of
direct contact, windblown dust, and surface water transport. Although
the contaminant remains in place, it is confined from wind and surface
water.
However, to be effective as a long-term remedial action measure, the
asphalt cap must be periodically maintained. The design must also take
Into account measures for controlling increased or redirected storm water
runoff.
28
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Use of an asphalt cap at the site is considered only as a stand-alone
alternative. The other alternatives (I.e., soil removal and/or
treatment/disposal) will be sufficient to eliminate requirements for a
subsequent cap. Therefore capping was not considered as a supplementary
technology In the development of the other remedial alternatives.
Control of future land use is viewed as a supplemental requirement where
capping is implemented in order to assure future integrity of the cap
structure.
Surface sealing with an asphalt cap will provide protection against
direct contact with contaminated materials and the migration of
subsurface contamination; however, this technology will not meet the
ARARs (TSCA 761.60-761.79) without redesignatlng this site as a TSCA
landfill, and, therefore, restricting land use in perpetuity.
This alternative would not meet the "to be considered" requirements
because it would not meet the cleanup goal (TSCA spill cleanup policy) of
removing soils contaminated with PCB at a concentration greater than or
equal to 10 ppm.
Alternative 5: Soil Cover
This alternative Includes the application of a soil cover without
previous excavation or treatment of contaminated materials.
For this site, covers. In contrast to caps, are not designed to
significantly decrease infiltration Into the underlying strata. A cover
at this site will decrease the potential for direct contact and/or
physical dispersal of surface soil only. Its performance would be
attributed to short-term (10-15 years) .Isolation of underlying
contaminated soil. For this reason, a cover at this site has been viewed
as a complementary technology, used as a final measure In addition to
other cleanup processes.
A soil cover of two-foot thickness provides some level of protection for
the environment In that direct contact and surface erosion/ transport are
controlled. However, application of a soil cover alone (without prior
cleanup) does not meet the cleanup goal of 10 ppm (mg/kg); nor does it
meet the designated ARARs for the site without redesignating the site as
a TSCA landfill.
Alternative 6: No Action
This alternative must be considered as a viable option when the existing
and future risks attributable to the site are within acceptable ranges.
The "no action" alternative infers that the status quo conditions at the
site will be allowed to persist and that remedial actions to protect
human health and the environment are unwarranted.
No action at the NWT site constitutes on-site (and uncontrolled) disposal
of PCB-contaminated wastes and does not meet the designated ARARs for the
site.
29
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IX. Summary of the Comparative Analysis of Alternatives
For the five finalists, the following nine criteria, as outlined in
section 121 of SARA and the RI/FS guidance, were explored during the final
analysis of remedial alternatives:
Short- and Long-term Effectiveness
Each remedial alternative considered during the FS process represents
some identifiable risk to community health and safety during the
implementation stages. However, for most processes, these risks can be
identified and mitigated through proper process control, monitoring, and
execution.
During removal of soil to an off-site facility (Alternative 1), some
potential exists for distribution of contaminated soil from trucks and
. other equipment passing through the adjacent community. This can be
mitigated by covering the soil loads and, If necessary, applying moisture
to dry, dusty loads. The short-term threat due to fugitive dusts
generated during excavation could be mitigated, if necessary, by applying
moisture.
On-slte vitrification (Alternative 2) may create air emissions, but
effective and reliable technologies have been developed for capturing
and/or destroying contaminants in this process. As there would be some
excavation required during the implementation of this remediation
technique, mitigation of fugitive dusts generated would be required.
Soil washing (Alternative 3) does not present any measurable risk to the
community. The only exception would be the release of extractants or PCS
while mixing the soil during the extraction process. The process also
generates a PCB concentrate that must be transported off site and
disposed of. Again, there would be some excavation required during the
implementation of this remediation technique, and mitigation of fugitive
dusts generated would be required.
Capping or application of a soil cover at the NWT site (Alternatives 4
and 5) do not pose any unique short-term risk to the adjacent community
beyond those Inherent In any construction activity. The only exception
would be accidental tracking of contaminated soils off site by heavy
equipment. However, this risk is common to all the alternatives
discussed above and can be reduced by proper project management and
equipment decontamination protocols prior to exiting the site.
The long-term effectiveness and risk reduction for the six alternatives
is estimated to be highest for those that actually treat and/or destroy
PCB contaminants in the soil (i.e., vitrification and soil washing).
While off-site disposal of soils in a landfill also reduces the on-site
concentrations of PCB, it potentially transfers the contaminant problem
to another land-based facility. Further, off-site transportation and
disposal of hazardous substances without treatment should be the least
favored alternative where practicable treatment technologies are
available CCERCLA §121(b)]. Caps must rely on land-use restrictions,
regular inspections, and scheduled maintenance to assure their long-term
performance. Installation of a cap or soil cover is not a permanent
30
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solution and would require regular maintenance.
Reduction of Toxlclty. Mobility, and Volume
Landfllling of soils off site does nothing to physically destroy or treat
PCB-contaminated soils from the site. In contrast, vitrification
effectively destroys the contaminants in the soil matrix and thereby
permanently reduces toxlcity, mobility, and volume. Soil washing removes
the contaminants from the soil matrix; however, this technology may
introduce new problems because residual washing agents may still be
present in the treated soil to be redeposited on the site, and the
concentrated PCS extracts require subsequent treatment or disposal.
Installation of a cap or soil cover does nothing to address the volume or
toxicity of the contaminant but has the potential of reducing contaminant
mobility.
Implementability
All of the finalist alternatives are technically feasible methods for
addressing the PCS contamination at the site. Alternative 1 (off-site
landfllling) is probably the most commonly practiced method of disposal
but does not result In actual detoxification or destruction of the PCS.
Also, landfllling of PCB-contaminated soils 1s more commonly practiced
for highly contaminated materials (above 50 ppm (mg/kg» when on-slte
options are not as feasible.
Alternative 2 (In situ vitrification) has been successfully used in
engineering-scale studies involving PCB-contaminated soil; however, it
has not yet been demonstrated commercially. A site-specific treatability
test would be required prior to implementation of this technology as a
remedial action.
Alternative 3 (soil washing) would also require site-specific
treatability testing of soil from the site to evaluate its
effectiveness. In addition, the concentrated process waste (leachate
contaminated with PCB) would still require off-site treatment/disposal.
During the course of the FS, a number of surface-sealing methods (capping
and soil covers) were evaluated. The use of an asphalt cap was finally
selected as the most cost-effective capping method for further
consideration as Alternative 4. The Installation of an asphalt cap is
straightforward; however, the long-term effectiveness can only be assured
through routine monitoring and maintenance of the paved surface. Because
the subsurface soils would not be treated or altered, the site would
require classification as a TSCA landfill.
Alternative 6, the "no action" alternative, is included in the FS to
assess the current site status. It serves as a reference point for
measuring the relative effectiveness of other alternatives and
determining if cleanup is necessary. If accepted, the no-action
alternative would leave the site as it is, with no constraints on
continued exposure to hazardous materials for those who enter the site
and with possible migration of contaminants into the shallow potable
water aquifer. It was determined that this alternative is unacceptable
because the environmental and public health risks would not be reduced.
31
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Cost
The cost estimates for each process for cleaning up or capping
RGB-contaminated soil to the 10 ppm (mg/kg) level are shown in Table 3.
The cost elements considered and included as applicable for each of the
. assessed technologies include the following:
Treatabllity testing (where applicable)
0 Mobilization/demobilization
0 Confirmatory testing
0 Excavation/soil staging
0 Processing (Including utilities, chemicals, labor, etc.)
0 Construction materials
Backf111
The no-action alternative has only those Implementation costs common to
all alternatives. I.e., the cost of the five-year review required by CERCLA,
but the cost of environmental degradation was not assessed.
Compliance with Other Laws and Regulations
As part of the FS process, each alternative was evaluated to determine
whether or not It met ARARs. The chemical-specific requirement for this
analysis Is TSCA, specifically, TSCA 40 CFR 761.60-761.79, Subpart D:
Storage and Disposal.
This regulation states that PCB at concentrations greater than or equal
to 50 ppm must be disposed of In an incinerator which complies with
§ 761.70. However, the regulation goes on to state that non-liquid
PCB-contaminated materials, such as soil, can be treated by an alternate
methodology as described In § 761.60(e) or disposed of In a chemical
waste landfill that compiles with § 761.75. In order .to meet the
requirement that an alternate methodology be equivalent to thermal
treatment, a destruction removal of 99.99991 should be achieved.
However, other factors may have to be considered In the determination of
equivalency. For example, the mathematically calculated PCB destruction
efficiency of a process may be less than 99.9999% due to the analytical
Limit of Quantification
-------
TABLE 3: SUKMARY OF ESTIMATED COMPARATIVE COSTS FOR EACH ALTERNATIVE
II
II
II
II
IP
IP
II
II
II
II
i
2A
19
3
4
5
6
II
II
ALTERNATIVE ||
OFF-SITE NCT/LANDFILL ||
THERMAL OBSTRUCT.: ISV ||
THERMAL DESTRUC: INCIN. | |
SOIL UASHING ||
ASPHALT CAP ||
SOIL COVER ||
NO ACTION ||
0.5
$101
8287
8448
8302
836
819
80
TOTAL COST
EXCAVATION
1
8177
8448
$641
$504
$36
$19
$0
($ X 1,000)
DEPTH (FT)
1.5
$254
8610
8833
8707
837
819
80
••*«««••••••
AT:
2
8330
8771
81,026
8909
837
819
80
2.5
8407
$933
$1,219
$1,111
837
819
80
3
8483
81,094
$1.412
$1,313
838
$19
80
II
II
II
II
II
II
II
II
II
II
(•ssuwt contMirutad «r«« of 16,875 squirt f««t)
33
-------
However, the state of Washington Dangerous Waste Regulations (WAC
173-303) require various analytical results depending on the sampling/
analytical procedures used. The most stringent requirement is 1 ppm PCS
for treated material; therefore that is the standard that must be met for
the treated soils at this site.
The NWT site is classified as a non-restricted acc.ess area (i.e.,
residential area). Even though it is surrounded by a chain-1ink'fence,
it is considered to be a non-restricted access area due to its close
proximity (less than .1 km) to a residential area. Based on this
non-restricted access classification and the PCS concentrations in the
soil, the TSCA spill cleanup policy (40 CFR 761.120, Subpart G) requires
a 10 ppm (mg/kg) cleanup level (provided that soil is excavated to a
minimum depth of 10 inches) In addition to at least ten Inches of clean
backfill (i.e., soil with less than 1 ppm PCB) for this site.
Alternatives 1, 2. and 3 (landfill Ing, vitrification, or washing of
PCB-contaminated soils) are all estimated to meet the requirements and
limitations of both the TSCA regulation and spill cleanup policy.
Capping and covering of the site without Initial cleanup to 10 ppm
(mg/kg) does not meet the Intent of the TSCA spill cleanup policy and
would have to meet the design requirements for on-slte disposal of wastes
as specified under TSCA.
Overall Protection
All of the finalist cleanup alternatives (except the no action
alternative) will afford an enhanced level of environmental protection in
the vicinity of the site. As Indicated in the discussion of public
health below, each alternative would protect the environment by removing,
destroying, or isolating PCB compounds In the soil. The candidate
measures will reduce the potential for these compounds to migrate off
site via windblown dust or storm water runoff.
Excavation of soils and hauling to an off-site landfill (Alternative 1)
will protect the environment In the vicinity of the site, but will
increase the risk to the environment along the haul routes to the distant
landfill and at the landfill.
Vitrification (Alternative 2) will result In the destruction of PCB in
the soils and therefore provides the most permanent solution to the PCB
contamination problem. Destruction of PCB In the vitrified mass would
permit future unrestricted land use at the site, and potentially the site
could be used as farmland or for residential purposes. Although there is
a small potential for airborne release from the ISV process, emissions
can be effectively controlled and are not viewed as a significant
environmental risk for this technology.
Soil washing (Alternative 3) requires direct mixing of the soil with an
extracting liquid. The concentrated waste extract must be transported
and disposed of off site. Similar to the landfill alternative, this
alternative would reduce the risk in the vicinity of the site, but has
the potential to increase the risk with respect to the ultimate
placement/disposal of the contaminated extract.
34
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The capping and cover processes represented by Alternatives 4 and 5 do
not address contaminants that remain in the soil and would require
designating the site as a TSCA landfill facility. Environmental and
public health protection is contingent upon long-term maintenance of the
capping system, and land use restrictions would need to be imposed in
perpetuity.
The no-action alternative represents no enhanced level of public health
or environmental protection over current site conditions.
Public health risks from the NNT site arise from the following:
1. Potential contact, ingestion, or inhalation of PCB-contaminated
soil.
2. Potential agricultural activities (growth of vegetables or
dairy and beef cattle grazing) associated with the soil that
might result In Ingestion of accumulated PCS.
3. Contamination of shallow groundwater resources.
In order to assess the effectiveness of each cleanup alternative, each Is
evaluated In terms of the "residual" risk at the site after the cleanup
is finished. This is done by examining the mitigating effect each
cleanup alternative would have on the pathways listed above and by
examining the impact of the degree of cleanup achieved (I.e., the
residual PCS concentrations).
The highest degree of risk mitigation (the lowest final risk levels) is
achieved through surface sealing (I.e., a barrier technology such as a
cap or cover), since all potential risks posed by contaminated surface
soils are eliminated. However, the long-term effectiveness of these
measures Is highly dependent on regular Inspection and maintenance, as
well as strict limits on future land use. All other processes that treat
or dispose of contaminated soils also achieve risk reduction, but since
some residual Is left In the soils, there is still a residual risk
level. This was the key reason for selecting the best treatment/disposal
technology and combining it with a final soil cover. The resulting
preferred alternative achieves both the soil cleanup objectives (removing
or treating soil contaminated with more than 10 ppm (mg/kg) PCB) and
reduction of the potential for direct contact with residual PCB levels
(below 10 ppm (mg/kg)) by covering with clean soil.
35
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Summary of Evaluation ai Final Alternatives
Criteria
Short-ten
Effectiveness
Alt 1:
Landfill
Coiiunity arc
*er«:er exposure
Alt 2:
Vitrification
Potential exists
to for community ano
Alt 3:
Sc:l Xasning
Potential exposure
:o ?C3 dust during
Alt 4:
Asphalt Cap
The :ap :ouid be
i-staiied in 4-6
Alt 5:
Soil Cover
A 2 ft. son cover
•ould Deduce
Alt 6:
No Action
Evolves
continuation :•
sccur
PCBs via airborne worker exposure
during excmtisn.
Excavation »ouio
take approx. 2
neeks. The
potential for
dust could
curing the
excavation and
hauling pnase.
Estimated
potential for PCB
exposure due to
airborne sust ;s
process off-gases
to escape from :.~e
air enissions ":cd
less than a icnth. exists.
excavation exists. *eeks. However,
In addition, the 'is* is cose-: ;y
potential -cr fugitive dust
mractints to be generated during
released into the the grading
rvironment during process.
the «:.-,.i-; pnase
?-ists. sod
•asning process
•;.3S 4-12 mo.
a direct contact
*ith the
contaminated soil.
. The import and
grading of the
cover may generate
fugitive dust.
Takes approx. 4-6
weeks.
the status quo
conditions at the
site.
.ong-term
Effectiveness
and Fsrmanance
Reduces the Effectively
mobility and destroys 5C?
volume of contamination n
contaminants in the soil tnrcugh
t.ie site soil. pyrolysis.
nunc.fr . > t does
not offer a
permanent solution
to the
contamination
problem, only
transfers it to
another location.
So;. *as;u ng Kith
•ater is reported
t3 "i a reliable
method for
'amoving ?CB
:ontafinants from
tre sail. Process
say not completely
'amove PCBs from
the soil. Thus, a
potential threat
to groundvater may
still exist.
"he surface rap is
not a pens- sat
alternative
because its'
effectiveness is
highly dependent
on regular
inspection and
maintenance.
Long-term Involves
reliability is continuation of
questionable due status quo.
to the potential
for erosion and
uncontrolled
infiltration of
surface «ater.
Deduction of Does not destroy Vitrification is a ::.'. •is^.ig
":x;c:ty, or treat PCB thermal :estruct::r -emc.es
*obil;ty, and contaminants. The ;':c*ss t.iat i;;r:-:iately "M and aces '.ot
volume naste is simply converts :» :-I: '5=::ues trsat, sestrc» ;r
:*ans?crted to :onta«inated soil •*:* :reitsa -eouce tne
another Lccatian. into a cnemicalir ie::«. 5s«-:vea ;:r.tamiratec soil.
inert, stasla ;lai= -=3::aJ5 «:ula
and c"ystall:"r ~?ec 'jrt'-er
product. featia-'". jisoosal
This is not a 5ee ilternat;/e 4 :.ivol/es the
permanent met"oa continuation :;
••9 status q-u.
3ee alternative •
36
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Suwary of Evaluation of Final Alternatives
Criteria
>3le»entabie
::st
Operation and
*a:--reiance
Alt 1:
Landfill
•
This is a reliable
and effective
approach to
cleaning up the
site. Process
utilizes coiion
construction
letnoos.
»330,000 "otal
cast indices
oh-site
excavation,
hauling and
disposal costs.
None
Alt 2:
Vitrification
Prccass lachinery
requires
iobihration.
"reatabiltty test
;s requires.
$771,000 Cost
includes
fobilizaticn ana
deiobil; ration,
sampling ana
treatability tsst,
soil ex:avati;n a.ifl
soil treattent.
None
Alt !: flit 4: Alt 5: i't i:
Soil taj-iing Asa-iait Cap Soil Cover NO Action
rrccess is in Technical See alternative * "echnica;
pilot testing »'easibility of 'easibiitty :
stage. npieienting this high, but it
T-»atabi;ity test alternative is not »eet the
15 'sau.refl. high. Process cleanup joais
.i'llires coiion agency "'S'ec'
construction • c; acequate s
lethods. control.
1909,000 Does i:t 137,000 119,000 . Mo capital
nclude tne expenditure,
necessary C ard *. cost of
c:sts. environiental
dsgraaation «
not assesses.
No :r,Toriati:r 11,600/per year 12,000/per year None
Currently
available.
4
3
ioes
2^
; VPC
• » C 3
ite
c
u
but
ias
•i
Iciciiance «ith Co»plies «ith TSCA S« Alternative
ASAS'S requireifftt 40 CFR
761.60-761.79,
Sjopart 0: Storage
and
See H.te-native 1 Coes not ieet "3Cfi See Alternative * See alter-ative
•9Quire«ents
unless Me 3:t; is
C;a55i';?a as a
'SCA landfill.
37
-------
Criteria
Alt 1:
Landfill
Smiary of Evaluation of Final Alternatives
Alt 2:
Vitrificatian
sit 3:
Soil Mashing
Alt 4:
Asphalt Cap
sou Cover
Alt s:
No Action
5"ATE
ACCE?*SNC:
*he Washington
State Sept. of
Ecology has
sustained an
on-going
invoiveient in the
zecision-iaiung
process for this
site. The State
agrees that the
statutory
requi*e§ents are
being addressed
and concurs mth
EPA's
"ecaiiendations.
See Alternative 1. tee Alternative 1. See Alternative 1. See Alternative 1. See alternative
IZMUNITY The Proposed Plan One letter Has See Alternative
ACCEPTANCE for NUT had a -eceived
seven »eek public questioning tne !SV
couent period. technology.
Concern uas
expressed through
a petition, signet!
ay approx. 100
people, that any
cleanup action at
t-9 site Nould
result in an
increase in their
utility rates.
See Alternative 1. See Alternative i. See Alternative '..
38
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X. The Selected Remedy
Approximately 1,200 cubic yards of soil shall be excavated within the
areas of PCB contamination of a concentration greater than or equal to 10 ppm
(mg/kg) (Figure 2). The actual excavation boundaries will be more closely
defined In the Remedial Design/Remedial Action phase. The excavated soils
wil-1 be treated through in situ vitrification such that the concentration of
PCB in the remaining residual is less than 1 ppm (mg/kg).
The excavated area will be backfilled; then the entire site will be
covered with a two-foot thick layer of native fill. The site will be
hydroseeded to stabilize the fill cover.
The on-site well will be abandoned in accordance with Washington state
law.
Post-Cleanup and Continued Site Monitoring
Part of the site remediation will include plans for sampling the deeper
wood matrix of the barn, post-cleanup confirmatory sampling, and ongoing
groundwater monitoring to document the effectiveness of the implemented
measures.
Barn
Because of the uncertainty relative to the effectiveness of
decontamination of the deeper wood matrix of the barn, additional
sampling and analysis of the wood is required. Core samples of the wood
in the barn will be obtained and PCB analyses will be performed on
subsamples taken from several different depths of the core. If core
samples Indicate significant levels of PCB In the wooden structure, the
barn will be acted upon as a separate operable unit.
Groundwater
Groundwater monitoring Is an important activity which will be included as
part of the remedial action. As discussed In the RI report. PCB has a
low potential to migrate from soil into groundwater. Investigations of
the rates of PCB desorption from soils suggest that the relationship
between soil PCB concentration and transfer to percolating water is
highly dependent on the solubility of the particular PCB cogener, water
flow rate, and the diffusion rate of PCB out of the soil matrix. The
aqueous solubilities of PCB are extremely low and are most likely the
primary factor limiting PCB concentrations In slow-moving groundwater in
contact with highly contaminated soils.
In the past, certain areas of the site, such as the seepage pit, had very
high PCB levels in the soil. At these "hot spot" areas there was assumed
to be a higher potential for migration of PCB into groundwater than at
other areas. Hot spots were excavated during the removal action in 1985
on the basis that this action would reduce the driving force for
contamination to enter groundwater.
39
-------
If the remainder of the areas of soil where PCB greater than 10 ppm
(mg/kg> are remediated, the potential for future groundwater
contamination will be greatly reduced. Lower levels of PCB which would
remain In son should not contribute significantly to groundwater
contamination. Nevertheless, there is uncertainty regarding the degree
and extent of low part per trillion contamination of groundwater which
could have resulted in the past from migration of PCB from the hot spot
areas. Therefore, a groundwater monitoring and aquifer characterization
program/plan will be prepared that Is designed to provide sufficient
Information upon which to base a decision regarding the need for
groundwater remediation.
Several factors are important in obtaining the necessary groundwater
information and should be considered In the design of the groundwater
monitoring program:
0 Characteristics of aquifer. The existing well log data for
monitoring wells and residential wells do not appear to provide
sufficient hydrogeologlc Information to characterize the aquifer.
The need for additional monitoring wells that fully penetrate the
aquifer and for the performance of pump tests to define the
site-specific aquifer characteristics must be evaluated in the
design of the groundwater monitoring program.
0 Direction of groundwater flow. The groundwater table has a low
gradient near the site. Very little Information exists relative to
the direction of groundwater flow. Based on the measurement of
static water levels at two different times, the flow appears to
deviate slightly to the east and west of due north. There is
uncertainty whether seasonal effects would cause a change in flow
direction which would in turn Impact contaminant movement.
Monitoring groundwater levels at scheduled Intervals and taking
samples from residences found to be downgradient of the site will be
a requirement of the groundwater monitoring program.
0 Sampling point for residential wells. Sampling residential wells at
a point before the water enters the houses In order to avoid
Interferences from trace compounds that may be associated with PVC
piping will be a requirement of the groundwater monitoring program.
PCB detection limit. PCB detection limits should be established at
or below five parts per trillion (5 ppt) to allow quantification of
the risk of drinking groundwater at the 10~6 cancer risk level.
To achieve reliable results at this low level, It Is essential that
careful adherence to sampling and analytical protocols and quality
control practices be followed.
40
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XI. Statutory Determinations
Protection of Human Health and the Environment
The selected remedial alternative best meets all statutory requirements
particularly those of CERCLA as amended by SARA. The use of the ISV
technology and the subsequent placement of two feet of clean fill over
the site best protects human health and the environment by eliminating
PCS contamination above the 10 ppm level from the site and creating a
barrier between any remaining low level contamination and the existing
ground surface. The two-foot depth for clean fill was derived from the
recommended tilling depths for common root crops and should therefore be
protective for both residential and agricultural future uses.
Any short-term risks due to implementation of this remedy can be
mitigated/controlled through proper process control, monitoring, and
process execution. Continued protection at the site is assured through
the barrier layer and the groundwater monitoring program. In addition,
since the remedial technology chosen for the site will destroy the PCS
contamination, there is the added dimension of overall environmental
protection.
Attainment of ARARs
The selected remedy will meet all applicable requirements as listed below.
TSCA PCB regulations in 40 CFR 761.60 - 761.79, which address
the requirements for storage and disposal of PCB-contamlnated
media.
OSHA regulations 1n 20 CFR Subpart 1910.120, which address
worker protection standards for employees involved in
operations at CERCLA sites.
0 Department of Transportation: Hazardous Materials Regulations
In 49 CFR, Subchapter C, which address shipment of any
hazardous material off site.
New Waste Generation--0ff-gas Treatment
0 Hashlnqton State Dangerous Haste Regulations (MAC 173-303)
The vitrification process generates off-gases from the
soil that are collected under a hood and are cooled,
scrubbed, filtered, and chemically treated before release
Into the atmosphere. There may be dangerous wastes
generated from the off-gas treatment process that will
require designation and treatment or disposal under the
dangerous waste regulations.
070 Designation of Dangerous Waste. This section
describes how to determine whether a waste is a dangerous
waste.
41
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110 Sampling and Testing Methods. This section describes
the testing methods which may be used in designating a
dangerous waste.
140 Land Disposal Restrictions. The purpose of this
section is to encourage the best management practices for
dangerous wastes according to the priorities of RCW
70.105.150 which are, in order of priority: reduction;
recycling; physical, chemical and biological treatment-
incineration; stabilization and solidification; and
landfill. This section Identifies dangerous wastes that
are restricted from land disposal, describes requirements
for restricted wastes, and defines the circumstances under
which a prohibited waste may continue to be land disposed.
141 Treatment, Storage, or Disposal of Dangerous Waste.
This section describes the requirements for offering a
dangerous waste to a TSD facility.
145 Spills and Discharges Into the Environment. This
section sets forth the requirements for any person
responsible for a spill or discharge Into the environment.
150 Division, Dilution, and Accumulation. This section
prohibits dividing or diluting wastes to evade the Intent
of this regulation.
170 Requirements for Generators of Dangerous Waste.
180 Manifest. Before transporting dangerous waste or
offering dangerous waste for transport off the site of
generation, the generator shall prepare a manifest and
shall follow all applicable procedures described In this
section.
190 Preparing Dangerous Waste for Transport. This
section details requirements for packaging, labeling,
marking, and placarding before transporting off site or
offering for off-site transport any dangerous waste.
200 Accumulating Dangerous Waste On Site. A generator
may accumulate dangerous waste on site for ninety days or
less after the date of generation without being subject to
storage facility requirements.
201 Special Accumulation Standards. This section
provides for an extended accumulation period based on the
quantity of dangerous waste generated per month.
202 Special Requirements for Generators of Between Two
Hundred Twenty and Two Thousand Two Hundred Pounds per
Month that Accumulate Dangerous Waste in Tanks.
210 Generator Recordkeeping.
42
-------
220 Generator Reporting.
230 Special Conditions.
Air Emissions
The vitrification process generates off-gases from the soil that are
collected under a hood and are cooled, scrubbed, filtered, and
chemically treated before release into the atmosphere. The air
emissions generated are addressed by the following directly
applicable requirements.
0 Washington State General Regulations for Air Pollution
Sources (WAC 173-400)
Section 040 General Standards for Maximum Emissions.
This section addresses control of fugitive dust and
emissions during excavation and other field activities.
9 Implementation of Regulations for Air Contaminant Sources
(MAC 173-403)
Section 050 New Source Review. Subsection (7) -
Portable Sources. This subsection describes air emission
requirements for new sources.
Well Construction and Abandonment
0 Minimum Standards for Construction and Maintenance of
Hells (HAC 173.160)
This regulation addresses how wells will be installed and
abandoned by licensed well contractors. Though reporting
and recording requirements are not considered substantive.
well contractors are required to submit well construction
and abandonment information.
Part One - General Requirements.
020 General (introduction) and Subsection (1). This
section provides minimum well construction standards and
details conditions that require well construction
standards in excess of the minimum.
065 Design and Construction.
075 Design and Construction - Sealing of Casing - General
085 Capping.
Part Two - Water Supply Wells.
415 Abandonment of Wells. This section applies to the
abandonment of the water supply wells at the site.
43
-------
Part Three - Resource Protection Wells.
500 Design and Construction - General.
510 Design and Construction - Surface Protective
Measures. Subsections (1), (2), (3), and (5).
520 Design and Construction - Casing.
530 Design and Construction - Cleaning.
540 Design and Construction - Well Screen, Filter Pack.,
and Development.
550 Design and Construction - Well Seals. Subsection
(1), (2), and (3) without the variance requirement.
560 Abandonment of Resource Protection Wells.
The selected remedy will meet all relevant and appropriate requirements
as specified below.
Soil Contamination
9 Washington State Dangerous Waste Regulations (WAC 173-303)
145 Spills and Discharge Into the Environment. This
section sets forth the requirements for any person
responsible for a spill or discharge Into the
environment. The vitrification process and associated
support activities create the potential for a spill or a
discharge as a result of materials handling or equipment
malfunction.
610 Closure and Postclosure. Subsection (2a) - Closure
Performance Standard. The owner or operator must close
the facility In a manner that minimizes the need for
further maintenance; controls, minimizes or eliminates to
the extent necessary to protect human health and the
environment, postclosure escape of dangerous waste,
dangerous constituents, leachate, contaminated run-off, or
dangerous waste decomposition products to the ground.
surface water, groundwater, or the atmosphere; and returns
the land to the appearance and use of surrounding land
areas to the degree possible given the nature of the
previous dangerous waste activity.
(Closure, for the purpose of Interpreting these relevant
and appropriate requirements is considered equivalent to
completion of the remedial action.)
44
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Subsection (7d) - Postclosure Care and Use of Property.
Postdosure use of property on or in which dangerous
wastes remain after partial or final closure must never be
allowed to disturb the Integrity of the final cover or any
other components of any containment system, or the
function of the facility's monitoring systems, unless the
department finds that the disturbance is necessary to the
proposed use of the property and will not increase the
potential hazard to human health or the environment, or is
necessary to reduce a threat to human health or the'
environment.
Subsection ClOb (1XAXB)] - Notice in Deed to Property.
Within sixty days of closure the owner or operator must
record, in accordance with state law, a notation on the
deed to the facility property, or on some other instrument
which is normally examined during title search, that will
in perpetuity notify any potential purchaser of the
property that the land has been used to manage dangerous
waste and that its use is restricted as specified in
subsection <7d).
645 Groundwater Protection. Subsection (8, a through g)
- General Groundwater Monitoring Requirements. The owner
or operator must comply with the requirements of this
subsection for development of a groundwater monitoring
program that Is specified In the ROD as part of the
remedial action.
655 Land Treatment. Unsaturated Zone Monitoring.
Subsection (6).
(The purpose of the monitoring specified in this section
is to determine what effect the vitrification process has
on the soil that surrounds the vitrified mass. It is
intended as a one time event, provided It is performed in
such a manner that reliable conclusions can be clearly
made. "Background" in this instance is defined as the
soil on site that Is just beyond the boundaries of the
soil to be vitrified. Sampling the soil In these areas
must be done prior to and following vitrification.)
(a) An owner or operator must establish an unsaturated
zone monitoring program. The owner or operator must
monitor the soil and soil-pore liquid to determine whether
dangerous constituents migrate out of the treatment zone
during vitrification and cooling.
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(b) The owner or operator must Install an unsaturated
zone monitoring system that Includes soil monitoring using
soil cores and soil-pore liquid monitoring, using devices
such as lysimeters. The unsaturated zone monitoring
system must consist of a sufficient number of sampling
points at appropriate locations and depths to yield
samples that represent the quality of background soil-pore
liquid and the chemical make-up of the soil that has not
been affected by potential leakage from the treatment
zone; and indicate the quality of soil-pore liquid and the
chemical make-up of the soil below the treatment zone.
(c) The owner or operator must establish a background
value for each dangerous constituent to be monitored.
(d) The owner or operator must conduct soil monitoring
and soil-pore liquid monitoring immediately below the
treatment zone.
(e) The owner or operator must use consistent sampling
and analysis procedures that are designed to ensure
sampling results that provide a reliable Indication of
soil-pore liquid quality and the chemical make-up of the
soil below the treatment zone.
State Hater Pollution Control Act (RCH 90.48)
Section 080 - Discharge of Polluting Matter in Waters
Prohibited. Groundwater impacts as a result of soil
vitrification are not anticipated. This section is Included to
address any unidentified threats to the groundwater.
The selected remedy will meet all "to be considered" criteria as
specified below.
TSCA PCB Regulations in 40 CFR 761.120, Subpart G, which
address the requirements for cleaning up a PCB spill.
Washington State Final Cleanup Policy - Technical (July 1984)
This policy provides a framework to determine cleanup levels
for releases of materials that threaten public health and/or
the environment. Ecology currently has a general requirement
that PCB-contaminated soils are to be cleaned up to a
concentration of 1 ppm. The FS considered cleanup of PCB in
the soil down to 1 ppm. Based on site-specific factors, the FS
recommended a cleanup level of 10 ppm and a requirement for 2
feet of clean soil cover. The proposed soil cleanup is
consistent with the final cleanup policy for the specific
characteristics of the NWT site.
(Regulations that are being developed under the Washington
State Model Toxics Control Act [Initiative 97] may impact
implementation of the cleanup policy for future site cleanups.)
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0 Draft Toxic Air Contaminant New Source Review Guidelines
(Ecology - August 1988).'
These guidelines are designed to assist regulatory agencies and
the regulated community in reviewing proposed new air pollution
sources for toxic air contaminant emissions.
U.S. EPA. Statement of Policy to Protect Environmentally
Significant Agricultural Lands (EPA - September 8. 1978)
The statement calls upon the agency to evaluate and mitigate
direct and indirect impacts on agricultural lands during the
preparation and review of environmental impact statements (or
functionally equivalent documents).
Cost Effectiveness
The selected remedy appears to be cost effective in light of the degree
of protectiveness provided by the destructive element of the chosen
technology when compared to the overall protectiveness of the
non-destructive technologies. The projected cost of the selected remedy
is higher than the projected costs of most of the non-destructive
technologies; however, the added benefit in the degree of overall
protectiveness appears to be cost effective.
Utilization of Permanent Solutions and Alternative Treatment Technologies
to the Maximum Extent Practicable
During the comparative evaluation of the various cleanup alternatives, it
became apparent that all of the final alternatives would meet the
applicable requirements as defined for this site. However, there were
two issues that significantly influenced the analysis and the consequent
choice of remedy when the "to be considered" requirements and the
following evaluation criterion were factored Into the analysis:
e Overall protection of human health and the environment.
* Long-term effectiveness and permanence.
Reduction of toxlclty, mobility, or volume.
The two Issues relate to current and future land use and the potential
for destruction of the contamination.
As stated earlier in this Record of Decision, the NWT site is located in
the middle of a rural area where the soils are designated as prime
farmland by the Soil Conservation Service. The land supports both
residential and agricultural uses for several miles in all directions.
This issue tended to make the alternatives that left the contamination on
site much less desirable because these alternatives would require that
the site be classified as a TSCA landfill. The agencies believe that
this classification would be highly incompatible with current and
possible future land use. Classification as a TSCA landfill would very
likely preclude the site from being used as farmland or for residential
purposes.
47
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When evaluating the alternatives for 1) their degree of protection of
human health and the environment, 2) their long-term effectiveness and
permanence, and 3) their ability to reduce the toxlcity, mobility, or
volume of the contamination, the alternatives that were capable of
destroying the contamination were viewed as much more desirable than the
nondestructive alternatives.
The final remedy was selected because it was considered to provide the
best combination of attributes in terms of all the evaluation criteria.
It Is highly protective, attains all ARARs including the "to be
considered" requirements, and is believed to be cost effective with
respect to the degree of overall protection provided.
Preference for Treatment as a Principal Element
The statutory preference for treatment that permanently and significantly
reduces the toxicity, mobility, or volume of hazardous substances as a
principal element is met by the use of a thermal destruction technology.
Contaminant destruction will be implemented to the maximum extent
practicable. The use of this technology provides for a permanent
reduction in the mobility, toxicity, and volume of the contaminant at the
site.
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XII. Responsiveness Summary
After Identifying a preferred alternative and informing the public of the
proposed plan, EPA opened a thirty-five day public comment period on
August 7, 1988. A copy of the Proposed Plan and an accompanying fact sheet
were mailed to all people on the mailing list for the site. The fact sheet
stated that a public meeting would be held if requested; however, no meeting
was requested.
The PRPs requested an extension of the public comment period, so a
fourteen-day extension was granted to allow them to submit comments. The
public comment period closed on October 5, 1988.
Background on Community Involvement
Several residents of the community had been concerned about the site
during the 1970s and had complained to the state and other officials
about possible contamination at the site. They noted that children in
the neighborhood had played at the site over the years. They also
commented that there had been frequent burning at the site. They were
assured that there was no significant problem on the basis of local. •
state and federal testing which did not show significant levels of
contamination.
Community interest was not high when the site was listed on the NPL in
1984 because of the earlier assurances that the site did not pose a
threat and a lack of awareness that more recent sampling had revealed
much higher levels of PCS contamination.
The community was therefore taken by surprise when EPA chose to undertake
an immediate removal of PCB-contaminated material from the site. The
appearance of workers in protective gear and heavy press coverage of the
"emergency" caused confusion and worry for residents. In subsequent
community interviews done by EPA in March 1986 (in preparation for the
RI/FS), local residents complained that EPA had failed to keep the
community informed and Involved, and that either EPA had overreacted or
that earlier problems had been concealed.
During those 1986 interviews, a number of residents and officials
expressed confusion and/or concern about EPA coming back to do the
RI/FS. Some were confused because they said they had been told after the
removal that "the site had been cleaned up." These and others did not
understand the Superfund process and/or requirements. Some felt that EPA
was overreacting to the severity of the problem by returning to do the
RI/FS. Some also expressed concerns about other NUT sites in the area
and the stigma and economic costs associated with Superfund sites.
In response, EPA explained the goals and results of the 1985 removal and
the goals of the RI/FS as part of an ongoing effort to provide timely
information to the community. During the RI/FS, EPA and its contractors
maintained contact with local officials and sent four fact sheets to the
public and the press.
A thirty-five day comment period (extended to forty-nine days) followed
publication of the Proposed Plan and availability of the RI, FS, and
Administrative Record at information repositories for the site.
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Summary of Comments and Agency Responses
The following Is a summary of the comments that were received during the
public comment period for the FS and the corresponding agency responses.
All submitted comments have been included in the Administrative Record
for the site.
The comments submitted by the Geosafe Corporation (the owners of the ISV
technology) focused on updating the information contained in the FS
regarding the ISV technology. The current information Includes the
following.
0 ISV technology has been continuously developed since 1980.
8 The number of ISV tests performed to date Is about sixty.
," The first ISV machine is presently committed to three projects.
0 It is not necessary to dry soil prior to ISV treatment; however, it
requires energy for the ISV process to remove water by vaporization.
0 Leaching of PCS from the residual monolith is impossible since
organics do not remain in the glass residual.
ISV 1s a pyrolysis process.
0 The unit cost estimate for ISV ranges from to $250 to $350 per ton.
0 Mobilization and setup time Is expected to be less than one week.
The current Information regarding the ISV technology was factored into
the evaluation of the remedial alternatives.
Comments were received from the PRP "steering committee" that "was formed
as a result of a consensus among a larger group of parties Identified by
EPA." Their detailed review comment document and detailed agency
responses have been Included In the Administrative Record. Their
summarized comments and EPA's summarized responses follow:
e Comment
1. The Risk Assessment prepared by EPA and included as Appendix A
to the FS employs excessively conservative assumptions. A risk
assessment that employs more reasonable but still very conservative
assumptions Indicates that the removal action already conducted by
EPA has brought risks associated with residual soil contamination to
acceptable levels and that additional action is not necessary.
EPA Response
1. EPA agrees that a few of the assumptions used in the Risk
Assessment were overly conservative and these have been modified
(see below). However, for the majority of the assumptions, EPA used
either an average value or a range of values. These resulted in
conservative yet reasonable worst case estimates of risk.
50
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The following assumptions/values were changed and the risk
assessment was revised accordingly:
• New vegetable uptake factors and consumption rates were
calculated. In addition, risks were calculated assuming that
25% of the vegetables consumed by a person are grown on the
site, as well as the original assumption of 100%.
For the grazing scenario, only average PC8 soil concentration
were used instead of the average and the average plus 2
standard deviation. Risk estimates were also made assuming
that a person obtains 25% of his beef and dairy products from
cattle grown on the site as well as 100%.
0 Risks associated with consumption of groundwater from off-site
wells were deleted due to the lack of reliable data.
0 For modeling purposes, the concentration of dust in the air was
assumed to be 50 ug/nn.
8 Risk estimates were performed using the weighted average
surface soil value and the weighted average plus two standard
deviation values calculated by Landau and Associates.
The Risk Assessment, as revised, is summarized In section VI of this
Record of Decision and is Included 1n its entirety as part of the
Administrative Record for the site. See Table 2 on page 23 for a
summary of the risk levels associated with the site. The risk
calculation for the grazing scenario (which assumes the site is used
for beef and dairy cattle grazing) resulted In an estimated
upper-bound lifetime cancer risk ranging from 2.5 X 10~3 to
1 X 10~2. Based on these results, EPA and Ecology believe that
further remedial action on the site 1s necessary.
Comment
2. Were further action nonetheless required, soil cover or
cement-soil stabilization/immobilization are the most appropriate
alternatives, and they meet the statutory criteria of 42 U.S.C. §
9621. "Thermal destruction" by on-site vitrification Is too costly
and technically uncertain to constitute a desirable alternative.
EPA Response
2. Following current EPA guidance and § 121 of SARA, the FS
evaluated remedial alternatives using the following criteria:
a. Compliance with applicable or relevant and appropriate
requirements (as defined by federal, state and local
regulations and/or policy)
b. Permanent and significant reduction of toxicity, mobility
or volume
c. Short-term effectiveness
d. Long-term effectiveness
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e. Implementabi1ity
f. Cost
g. Community acceptance
h. State acceptance
1. Overall protection of human health and the environment
EPA recognizes that the recommended alternative for this site is
more expensive than some of those proposed by the reviewers.
However, the FS (as summarized by the following) demonstrates that
this cost 1s offset by the benefits under the other criteria
required to satisfy the CERCLA process.
0 Short-term effectiveness: stabilization would require
additional testing that may delay Implementation.
0 Long-term effectiveness: ISV represents the lowest long-term
risk from residuals remaining after implementation.
9 Permanent and significant reduction of toxlclty, mobility, or
volume: ISV results in destruction of PCS in the soil matrix,
rather than Increase in the volume of contaminated solids, less
certain reductions In toxldty or mobility through fixation, or
relocation of contaminants to a landfill.
0 Implementabi1ity: ISV has undergone testing for
PCB-contaminated soils specifically. Fixation technologies
must be demonstrated to assure long-term stability.
0 Compliance with ARARs/TBCs: Residual PCB concentrations above
the allowable limits under TSCA are not left on site.
0 Overall protection of human health and the environment: Risk
of direct contact or exposure to contaminated soils and dust 1s
eliminated by the direct treatment and destruction of PCB to an
acceptable risk level. The potential for PCB leaching from the
treated material to other matrices (groundwater) Is also
eliminated.
Efforts to Identify the least costly, most effective, and innovative
measures for remediating PCB-contaminated sites are appreciated and
supported. However, these measures must 1) meet the intent of the
ARARs as presented in the FS, and 2) be applicable to the specific
contaminants and site conditions. Remedial actions that leave
residual PCB soil contamination above 50 ppm (mg/kg) do not meet the
ARAR-defined objective of contaminant destruction set forth under
TSCA 761.60: "Any non-liquid PCBs at concentrations of 50 ppm or
greater in the form of contaminated soil, rags, or other debris
shall be disposed of:
(i) In an incinerator which complies with Section 761.7; or,
(11) In a chemical waste landfill which complies with Section
761.75."
52
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nor under the technical requirements for construction of chemical -
waste landfills defined by TSCA 761.75. Unfortunately, little
scientific or CERCLA-based support is provided by the reviewers for
their proposed approach of mixing PCB-contaminated soil with
Portland Cement.
Testing costs for the cement/soil stabilization process
(approximately $120-150 thousand) would have to include additional
long-term leachability tests to demonstrate long-term viability of
this option. The suggested process Is not proven for PCS
specifically. In comparison, the vitrification testing would only
require a one-time demonstration of applicability to site-specific
soils as the process has been proven to destroy PCB, and this test
could be conducted in a relatively short period of time (i.e., 2 to
3 months).
A recent, in-depth review of stabilization technologies (Pollution
Engineering Magazine. August 1988) states that Portland Cement
stabilization technology is more appropriately applied to waste
materials containing inorganic (i.e., heavy metals) contamination.
It is widely known In the concrete industry that even very low
concentrations of organic compounds can hinder the molecular binding
and curing processes of aging concrete. While it is possible that
binding of PCB-contaminated soil in cement blocks reduces the
mobility or accessibility of the soil matrix, research indicates the
primary contaminant (PCB) may migrate through concrete to Teachable
and weathering areas near the surface. When compared to an
alternative such as ISV, which destroys the contaminant, the
long-term uncertainty makes fixation less desirable.
Section 121 of SARA states a preference for selecting remedial
actions that employ treatment technologies that permanently and
significantly reduce toxlcity, mobility, or volume of the hazardous
substances as their principal element. This preference Is satisfied
when treatment is used to reduce the principal threats at a site
through destruction of toxic contaminants, reduction of the total
mass of toxic contaminants, irreversible reduction in contaminant
mobility, or reduction of total volume of contaminated media. None
of the alternative remedial methods suggested In the review document
(no action, soil cover, off-site land disposal), with the exception
of the cement/soil stabilization process, meet any of the tests
under this criterion.
The FS recommended thermal destruction of PCB in PCB-contaminated
soils with concentrations at or above 10 ppm (mg/kg). Thermal
destruction technologies include incineration and vitrification, as
well as the thermal-based processes such as catalytic combustion and
infrared destruction. Upon further review and cost analysis by EPA
and further review of documentation on demonstrations of the
vitrification technology, the best thermal destruction process for
this site was determined to be vitrification. This determination
was made based on 1) relative ease and foreseen schedule of
mobilization, 2) advantageous costs over other thermal processes as
reflected in the FS, 3) acceptability of the vitrified mass as an
on-site residue over other conventional materials classified as ash,
53
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4) the foreseen local acceptance of contained, "1n-the-ground"
thermal destruction of PCB contaminants over conventional
Incinerator operations, and 5) the criteria set forth for technoloav
selection in the FS.
The statement that a soil cover is equivalent in protect!veness to
the technologies recommended In the FS Is based solely on the
reduction of the numerical value for short-term risk. It ignores
the significance of all other .criteria and requirements under the
ARARs as they were appropriately considered In the FS. The
technique is not a permanent solution and would require restrictions
on land use in perpetuity.
During the FS process, the appropriateness of deed and access
restrictions were considered. For this specific site, these
measures are considered Ineffective and inappropriate when viewed 1n
the context of the assumed long-term land uses and are therefore
less protective. In conducting the FS, It was assumed the completed
(cleaned up) site would support uses similar to those at surrounding
properties and would be acceptable for eventual development into
relatively unrestricted agricultural (grazing/farming) or
residential uses.
• Comment
3. A groundwater monitoring program Is desirable to verify that
on-slte and off-site groundwater have not been contaminated.
EPA Response
3. We are in agreement that a groundwater monitoring program Is
desirable and this was expressly stated in the FS and Proposed Plan.
Clallam County Public Utility District submitted a comment letter. It
is paraphrased by the following comments, which are followed by the
respective EPA responses.
* Comment
1. Based on a review of the RI, a six-inch soil scrape is all that
is necessary to remove soil with PCB contamination above the 10 ppm
(mg/kg) action level.
EPA Response
1. As stated In the FS, assumptions were made regarding the
distribution of PCB contamination with depth within the cleanup
area. Because of the porous nature of soil at the site and handling
practices of concentrated liquids (being applied directly to the
site), a linear decrease is a conservative assumption for the
relationship of PCB concentration with depth.
The theory has been advanced that high clay content in shallow soils
at the site retained free-flowing PCB materials in the upper six
inches.
54
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The variability of the silty clay layers is highlighted in Figure"
1.5 of the RI document (HDR 1988) and casts serious doubt on this
layer's overall uniformity and ability to contain PCB. The
discontinuous nature of these layers is well known and documented
for outwash materials (alluvial sediments) of the northwest region.
Some surface soils with the higher organic and clay content were
removed during the IRM. To assume that the estimated PCB retention
capabilities of these removed materials (a proposed decrease rate of
16 to 1) is equally applicable to the more porous underlying sand
and gravel layers is not consistent with the fact that PCB
concentrations at or above 1 ppm (mg/kg) were detected in the areas
in question at a depth up to 2.5 feet.
Comment
2. They questioned the use of in situ vitrification because of the
experimental nature of the technology and had particular concerns
regarding the a) formation of PCDO and PCDF at the outer edges of
the vitrification zone; b) uncontrolled gas venting during the
vitrification process; and c> contamination of surface water by PCDD
and PCDF on the edge of the vitrified zone.
EPA Response
2. The development of the ISV technology was initiated In 1980.
There have been approximately sixty tests performed to date using
this technology. ISV has been successfully used In
engineering-scale studies involving PCB-contamlnated soil.
a. PCDD and PCDF are PCB oxidation products and will be sampled
for during the site-specific treatabillty testing. According
to the tests done to date, it is believed that the PCDD/PCDF
content observed was generated above the melt, under the hood,
rather than in the ground.
b. The ISV off-gas treatment system Is designed to maintain a
slight negative pressure In the off-gas hood. It is not
necessary that the hood Itself be airtight; in fact,
significant amounts of excess air are allowed Into the hood to
oxidize any combustible pyrolysis products. In the event of a
loss of power to the system, an emergency backup power supply
is employed to maintain flow through the off-gas system.
c. See response to a.
Comment
3. They felt that the short-term effectiveness of Alternatives 1,
2, and 3 Is the same due to excavation and the potential for
fugitive dust generation.
EPA Response
3. The short-term effectiveness with respect to excavation and
fugitive dust generation is the same for Alternatives 1, 2, and 3 as
defined in the FS and Proposed Plan. This information was factored
into the remedial alternatives analysis.
55
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8 Comment
4. The operation and maintenance cost was underestimated for both
Incineration and vitrification technologies.
EPA Response
4. Operation and maintenance costs are considered to be the costs
of operating and maintaining the remedial action fix. As
incineration and vitrification are destructive technologies, they
are one-time actions and therefore do not require ongoing operation
and maintenance inputs. In contrast, the reliability of
non-destructive alternatives such as capping, soil cover, and cement
fixation is dependent upon the continued Integrity of that
particular remedial action fix. Those kinds of fixes must be
monitored and maintained/repaired in perpetuity, resulting in
ongoing operation and maintenance costs.
Responses to concerns regarding the viability of vitrification as a
full-scale technology are Included In comments on the FS provided by
Geosafe Corporation to EPA. The basic ISV technology has been
developed for large-scale operations. Tests of large-scale
equipment, available since late 1983, have removed scale-up concerns
and verified economic projections. For reference, the large-scale
equipment will process up to 5 tons/hr and will produce up to 800
tons of melt In a single setting. Large-scale ISV experience has
produced data sufficient for estimating labor, materials, and other
input critical to costs. Geosafe Corporation has provided an
updated cost for ISV for smaller scale applications <$250-330/ton),
and this cost is competitive with other thermal destruction
technologies.
A local geologist had several concerns, which are listed below with the
respective EPA responses.
0 Comment
1. He was concerned that dust generated by excavation of soils on
site and the potential for that dust to expose residents of Everson
or to enter the food chain through local dairy cattle consumption of
"dusted" vegetation would be a problem during remediation.
EPA Response
1. The potential for fugitive dust generation during remediation
does exist. Part of the remedial action design will Include
measures to mitigate the generation of those dusts.
Comment
2. The commenter thought EPA should have specified a preference
for either incineration or vitrification and asked whether EPA
sacrificed effectiveness for lower cost by selecting vitrification
rather than incineration.
EPA Response
2. EPA and Ecology have specified that vitrification is the
thermal destruction technology to be used at the NWT site. ISV is
less expensive than incineration, but both technologies provide for
the destruction of PCS in soil.
56
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A petition signed by approximately one hundred people and submitted to
EPA suggested that institutional controls were more appropriate than the
preferred plan due to the possibility that their electrical rates would
increase If the PRPs (mostly public utility districts) were made to pay
for the remediation on site.
A letter was sent to all petition slgnees (with approximately one-third
being returned to EPA stamped "addressee unknown") explaining what
criteria the agency must use in evaluating the various cleanup
alternatives and how, after completion of this evaluation, the agency
believes that the preferred alternative best meets the requirements as
represented in the evaluation criteria.
The Snohomish County Public Utility District wrote and recommended deed
restriction and follow-up groundwater monitoring rather than the
recommended alternative of thermal destruction, because in their view it
is more cost effective and appropriate for the circumstances of the site.
Deed restrictions, such as limiting access to the site or limiting use of
the site, were considered in evaluating what the appropriate cleanup
alternative for the site should be. EPA and Ecology believe that deed
restrictions alone are inappropriate for this site due to the surrounding
land uses and close proximity of residences. Follow-up groundwater
monitoring will take place. (See response to comment 2 from PRP steering
committee.)
Other Comments Received
Two local residents wrote and recommended Alternative 4 rather than
Alternative 2 because of a belief that Alternative 4 will be adequately
protective and that a better and safer method of dealing with PCS will
eventually be developed.
SARA requires EPA to look for a permanent solution that reduces the
toxlcity, mobility and volume of waste, and not to choose Interim
solutions that will have to be redone later.
57
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, Washington 98101
ADMINISTRATIVE RECORD INDEX
for
NORTHWEST TRANSFORMER - REMEDIAL
Everson, Washington
September 8, 1989
-------
NORTHWEST TRANSFORMER • REMEDIAL^
INOEX TO ADMINISTRATIVE RECORD
September 8, 1989
Ooc. • file
1. Background
00000001. Background
00000002. Background
Type/Description
00000003. Background
00000004. Background
00000005. Background
00000006. Background
00000007. Background
re referral for enforcement
evaluation. Northwest Transformer
Service, Everson. Washington
Investigations of uncontrolled
hazardous waste sites, FIT Project,
task reports to the EPA, Contract No.
68-01-6056, Northwest Transformer
Salvage Tard. BEIlinghM, Washington,
final report, TOO 10-8108-05
Background letter re Notice of
Noncompl lance with PCB regulations
under Tonic Substances Control Act
Cover letter with attached copy of
Findings re Release and Threat of
Release of Hazardous Substances and
Order for (Mediate Removal re
Northwest Transformer Company
Federal On Scene Coordinator's Report,
Hazardous Waste Site Cleanup. Northwest
Transformer Salvage Yard, Everson,
Washington, for 4 Apr! I -17 Nay 1985
Northwest Transformer Salvage Yard,
Field Investigation, Final Report, TOO
R10-8503-04
Cover lettera. Notice and Complaint re
Administrative Action against Northwest
Transformer Service for Alleged
Violation of PCB Regulations
Pate
3/23/81
4/82
t Pop Author/Organ i z a t i on
Alexandra B. Smith/EPA
50 Ecology t Environment,
Inc
1/21/83
3/29/85
7/85
8/85
9/30/86
Alexandra B. Smith/EPA
15 Charles E. Findley/EPA
53 Region 10 Technical
Assistance Team
70 Jeff Uhldden/Ecology t
Environment. Inc
19 Anita J. Frankel/EPA
Addressee/Organ!zaifon
Lloyd E. Reed/EPA
Ron Wallace/Northwest
Transformer Service
Ronald and Noah
Wallace/Northwest
Transformer Company
Region 10/EPA
J. E. Osborn/EPA
Noah Wallace and Merle
SidelI/Northwest
Transformer Service
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NOB!HUESt IHAMSfOBMER • REMtOfAj.
I MOCK TO ADMINISTRATIVE RECOUP
Septeafcer 8. 1989
Doc. *
2. Preliminary Assessment Report
Type/Description
00000008. Preliminary assessment report Potential hazardous Matte site--
prellalnery assessment
Pale
8/IS/84
0 Pa» Author/Organization
Addreisee/OraanliatIon
3. Site Investigation Reports
00000009. Site investigation report*
00000010. Site investigation report*
00000011. Site investigation reports
00000012. Site investigation reports
00000013. Site investigation reports
000000U. Site investigation reports
0000001S. Site investigation reports
Potential haiardoua waate site--site
inspection report
Potential haiardoua waate site--
tentatlve dlapoaltion
Potential hazardous waate log
Potential hazardous waste site—site
Inspection report. Part 7, owner
Infonaatlon
Potential hazardous waste site-site
Inspection report, Part 1, site
location and Inspection infonaation
Prel(Binary alte Inspection, report of
Northwest Transformer Salvage Vard,
Everaon, Washington, TOO R10-8408-12
Inspection Report re Northwest
Transforaer Salvage Yard
3/5/81
3/19/81
3/19/81
8/31/84
1
19
1
1
C.
C.
C.
--
U. Rice/EPA
U. Rice/EPA
Rice/EPA
9/25/84 1 Jeff Whidden/Ecology t
Environatnt, Inc
10/26/84 39 Jeff Uhldden/Ecology t J. E. Osborn/EPA
Environment. Inc
10/29/86 1 Sue SiSM/Uashington DOE
t. MPL Proposals and Connenti
90000016. NPL proposals and conaents
Excerpt fraa Fed. Regiater, V. 49,
MOO, pp. 40320-40352. EPA, 40CFR Part
300, Aawnd. to National Oil C Hazardous
Substances Contingency Plan; National
Priorities list-Proposed Rule
10/15/84
34
-------
NORTHWEST TRANSFORMER • REMEDIAL^
INOEX TO ADMINISTRATIVE RECORD
September 8. 1989
Poc. « file
00000017. NPL proposals and comments
00000116. NPL proposals and comments
Tvpe/Oescrlotion
Excerpt fro* Fed. Register. V. SI.
fill. pp. 21054-21098. EPA. 40CFR Part
300, AMnd. to National Oil t Hazardous
Substances Contingency Plan; National
Priorities List-Final Rule
Letter: Cements re comments on
"Solidification/lsMobiliiation as a
viable Remedial Action" by Landau
Associates, 1/4/89. (15-Page report of
consents included)
Date
6/10/86
1/9/89
I Pas Author/OraanIlation
45
Addressee/OmanilatIon
18 Frederic A Morris/Perkins Sally Nartyn/EPA
Coie
5. RI/F5 Work Plans
00000018. RI/FS Work Plans
00000023. RI/FS Work Plans
00000052. RI/FS Work Plans
00000073. RI/FS Work Plans
Work plan for RI/FS re Northuest
Transformer Salvage Yard. Everson,
Washington
1/87
Letter with attached Statement of Work 10/18/85
for Feasibility Studies re RI/FS for
Northwest Transformer
Feasibility Study Work p|.n for 10/23/87
Northwest Transformer Service Salvage
Yard
Cements on RI/FS work plan 11/19/86
349 Memingson, Durham I
Richardson. Inc
15 Nonas Lewis/EPA
39 NOR Engineering. Omaha.
NE
Department of the Army.
Kansas City District.
Corps of Engineers and
EPA, Region 10
Edward Ray/Army Corps of
Engineers--Kansas City
District
Corps of Engineers.
Kansas City District
Clynls A. Stuspf/UA Oept. Norma lewis. EPA
of Ecology
6. Correspondence and Metros
00000019. Correspondence and nemos
00000020. Correspondence and menus
Nemo re Northwest Transformer 3/11/87
Compliance with SARA
letter re description of possible 8/19/87
future set Ions by EPA at Northwest
Transformer facility
Ron Vernesonl/EPA
File
2 Philip C. Ml I lam/EPA Joe Doffing. Attorney at
law
-------
NORTHUEST TRANSFORNER • RENEOIAL
INDEX TO ADMINISTRATIVE RECORD.
September 8. 1989
Doc. * fill
00000021. CorretpondMKt and
00000041. Correspondence and memo*
Correspondence and nemos
00000042.
00000043. Correspondence and nemos
00000044. Correspondence and nemos
0000004S. Correspondence and nemos
00000055. Correspondence and nemos
00000056. Correspondence and nemos
00000057. Correspondence and nemos
00000074. Correspondence and nemos
00000117. Correspondence and nemos
Type/Description
Letter re comments on draft Scope of
Work for Feasibility Study at Northwest
Transformer Salvage Yard
Letter of notification re proposed
Superfund project to State
Letter of notification re potential
liability of responsible parties
Letter of notification re potential
liability of responsible parties
Letter of notification re potential
liability of responsible parties
List of naMS of potential responsible
parties
Letter regarding release of hazardous
substances at Northwest Transformer
Superfund alte with list of PUPS
Letter regarding release of haiardous
substances at Northwest Transformer
Superfund site without PHP list
Letter regarding release of haiardous
substances at Northwest Transformer
Superfund site with Mailing list
Request to be removed from PHP list for
the Northwest Transformer Superfund
site
Nemo: Re completion of review of
sasples from Northwest Transformer
Date
9/9/87
6/17/85
10/2/86
10/2/86
10/2/86
10/2/86
10/2/86
6/8/88
9/14/88
2/1S/B9
i Pas Author/Oraanilet \ on
2 Sally Nartyn/EPA
3 Kathryn N. Oavidson/EPA
2 Charles Findley/EPA
2 Charles Findley/EPA
2 Charles Findley/EPA
19
Charles Findley/EPA
Charles Findley/EPA
Charles Findley/EPA
H. Roy Oonehower/Public
Utility Dlst. No. 2 of
Grant City
Alice Tau/EPA
Addressee/Groan!leti on
Clark Cunlon/Army Corps
of Engineers--Kama*
City Oiatrlct
Ken Back/Washington
Planning and Community
Affairs Agency
Noah Us11ace/Northwest
Transformer
Nerle SidelI/Block Steel
Claude Potts
Trans-Mountain Pipeline
Corp, Vancouver. B.C.
John S. Uilllams/Uhatcom
guilders, •ellingham, UA
Nailing list
Robie Russell/EPA
Joyce Crosson/EPA
-------
Doc. »
000001 IB. Correspondence and nemo*
00000119. Correspondence and memo*
00000120. Correspondence and memos
00000121 Correspondence and memo*
NORTHWEST TRANSFORMER - REMEDIAL
INDEX TO ADMINISTRATIVE RfCQBp
September 8, 1989
Type/Description
Transmittal of final ATSOR Health
Aase*aa*nt
Transmittal of sup (attached) and
explanation of tenas for land
classification In wnatcon County
Mean: Re question of whether Northwest
Transforawr alt* lies in an area
containing significant agriculture
lands and if any related regulations
are ARARs
Letter: Cements re selection of
alternative for stabilisation of
Northwest Transformer site
Bill * Pa|
4/14/89 1
5/17/89 2
6/16/89 1
8/2S/89
Author/Organ!tati on
Stephen 0. Von
Allawn/Agency for Toxic
Subatances and Disease
Registry, Atlanta, CA
John K. Clllies/U. S.
Oept. of Agriculture
Christine Psyk/EPA
U. J. fInnegan/Puget
Power
Addressec/Oraaniiatlon
Phil MlllasVIM
Christine Psyk/EPA
Sally Martyn/EPA
Charles flndley/ EPA
7. SampI ing Plans
00000022. Sanfil ing Plans
8, lab Reports/Raw Data
00000036. Lab reports/raw data
00000037. Lab reports/raw/data
Engineering and design, che*ical
Data Package Case «3980, located at EPA
Region 10 Headquarters
Letter re analytical results with
attached: quail tat lave review of sample
nusbere 1SS6J-01 through 1556J-07, aid
MSS chroMtograM, chain of custody
form, quality control sunaary for
polychlorinated dfoxin/furan analysis.
Located at Northwest Transformer HU 924
files at EPA Regional Office
12/30/8S
Shipping
date:
3/29/8S
4/18/85
43 Ar«y Corps of Engineers
EAL
Paul Taylor. Michael J.
Nillle, Terl J.
Vergara/CalIfornia
Analytical Labs, Inc.
EPA Region 10 files
John Osborn/EPA
-------
NORTHWEST TRANSFORMER - REMEDIAL
INDEX TO ADMINISTRATIVE RECORD
September 8, 1969
Doc. * Mil
00000036. lab reports/raw data
00000039. lab reports/raw data
00000040. Lab reports/raw data
00000046. Lab reports/ran data
00000047. Lab reports/raw data
OOOOOM8. Lab reports/raw data
00000049. Lab reports/raw data
00000050. Lab reports/raw data
MMOOOS1. Lab reports/ray data
XM00061. Lab reports/raw data
MMM0062. Lab reports/raw data
10000063. Lab reports/raw data
Type/Description
at ion foras rt parameter hazards,
•aaple nuabers 85121650 through
85121654
at Ion fora* r« parameter hazards,
saeple nuabers 65181025 through
65181052
Suajaation fonas re parameter hazards,
sasple nusbers 85201047 through
85201049
turning site, saaple analysis results
for saaple nuabers 8435571 and 81435572
Everson, UA, aasple analysis results
for sasple nuabere 85121775 through
5121785
Saaple analysis results for saaple
nuabers 85121850 through 85181654
Saaple analysis rtsults for saaple
nuabers 85181025 through 85181052
Saaple analysis results for sanple
nusbers 85201047 through 85201049
Saaple analysis results for saaple
nuabers 86224615 through 66224617
»C6 analytical data ausaary package for
81 soil aaaplea
Soil saaple analysis data for Northwest
Transformer site for PC8s. 81 sasples
RevieM of analytical data on PCii In
groundwater. Northwest Transforswr site
Pate < Pas Author/Oraaoiiat ion Addrestee/Ornanlzation
1985 5 EPA Manchester Laboratory
1985 32 EPA Manchester Laboratory --
1985 3 EPA Manchester Laboratory
8/31/84
3/19/85
3/19/85
5/1/85
5/14/85
6/2/86
8/11/87
9/8/87
4/21/66
2
11
5
30
3
3
9
7
12
EPA Lab, Region 10
EPA Lab, Region 10
EPA Lab, Region 10
EPA Lab, Region 10
EPA Lab. Region 10
EPA Lab, Region 10
Victor »astrop/Ver»ar,
Inc. Springfield. VA
Paul P. tarber/COE,
Kansas City District
Michael J. Conzett/HOR
Corp* of Engineers,
Kansas City District
Sally Nartyn/EPA
Clark Cunlon. COE.
Kansas City District
-------
MQOIHUtSI TRANSFORMER • REMEDIAL
INDEX TO ADMINISTRATIVE RECORD
September 8. 1969
Doc. » File
00000075. Lab reports/raw data
00000076. Lab reports/raw data
00000077. Lab reports/raw data
00000078. Lab reports/raw data
00000079. Lab reports/raw data
00000080. Lab reports/raw data
00000081. Lab reports/raw data
00000082. Lab reports/raw data
00000083. Lab reports/rat* data
00000084. Lab reports/ran data
Tvpe/Descr lotion
»: Draft approval of work
accomplished during removal action
Covar (attar transmitting results of
laboratory analysis of Mail water
samples taken 7/16/87
Covar (attar transmit ting results of
laboratory analysis of well water
samples taken 7/16/87
Covar (attar transmitting results of
laboratory analysis of wall water
saaplaa taken 7/16/87
Covar latter transmitting results of
laboratory analysis of wall water
samples taken 7/16/87
Disposition Fora: Transmittal of Corps
of Engineers' review comments of tha
Remedial Investigation of Northwest
Transformer Salvage Tard
Comments on the need for
additional groundwater sampling for
PCB'S
Nemo: Answer to concerns about
Inconsistent analytical results
Nemo: Answers to questions rising from
Remedial Investigation
Letter: Transmittal of data reference
Mod's determination of PCi levels In
groundwater
Date » Pgs Author/Organ!istion
11/3/87 1 Rene
Fuentes/EnvlronmentaI
Services Division
11/16/87 7 Richard T. Sprague/HOR
Infrastructure, Inc
11/16/87 7 Richard T. Sprague/HOR
Infrastructure, Inc
11/16/87 7 Richard I. Sprague/HOR
Infrastructure, Inc
11/16/87 7 Richard T. Sprague/HOR
Infrastructure, Inc
5/3/86 5 John E. Noylan/Corps of
Engineers, Kansas City
District
5/5/68 1 Dana Davoli/ESD, EPA
6/7/66 2 Raleigh Farlow/QA
Management Office, EPA
4/25/88 2 Sally Nartyn/EPA
6/30/88 2 Nichael J. Comett/HOR
Engineering, Inc
Addrenee/Oreafli set I on
Joyce Croason/OA
Mr. ft Nrs. D. Turner,
Everson, UA 98247
Mr. ft Nrs. R. Harrlmen,
Everson, UA 98247
Mr. ft Mrs. E. •ergermon.
Everson, UA 98247
Mr. ft Mrs. R. Reynolds,
Everson, UA 96247
EPA
Sally Martyn/EPA
Sally Martyn/EPA
Pat Storm/N ft E
Assessment, EPA
Clark Cunion/U.S. Arny
Corps of Engineers
-------
NORTHWEST TRANSFORMER - REMEDIAL
INDEX TO ADMINISTRATIVE RECORD
September 0, 1989
Poc. » Flie
9. Interaacncv Agreement*
00000024. Interagency agreements
00000025. Interagency agreement*
00000026. Interagency agreements
00000027. Interagency agreement*
00000113. Interagency agreements
00000114. Interagency agreement•
00000115. Interagency agreement*
Tvpa/Daacriot ion
Inttragency agreement/amendment between
EPA and Army Corps of Engineer* re
•I/FS at Northwest Transformer
Intaragsncy agreement/amendment between
EPA and Ansy Corps of Engineer* re
•I/FS at NorthMMt Tranafonaar
Letter with attached contract, fee
proposal, and *cope of aervices re
agrismsnt between EPA and Army Corp* of
Engineer* for RI/FS at Northwest
Tran*former
Interagency agreement/smtndment between
EPA and Army Corp* of Engineer* re
RI/FS at Northwest Transformer
Interagency agreement/amendment between
EPA and Army Corp* of Engineer* re
•I/FS at Morthweit Tranaformer
Letter: •• Washington State Applicable
and Relevant and Appropriate
Requirementa (ARARs)
Letter: Re Washington Stats Apptfcable
and Relevant and Appropriate
Reauirement* (ARARs)
Pefe
9/24/85
3/12/66
3/23/87
5/26/87
2/13/89
8/2/89
9/5/89
i Pas Author/Groan)tattoo
Ernests R. Barnes/EPA
Charles Flndley/EPA
Addrctsee/Oroanllat i on
Martha N. Lows/Army
Corps of Engineers
Martha M. Lowe/Army
Corps of Engineers
49 Paul 0. •arber/Army Corps Ronald Verna*oni/EPA
of Engineer*--Kansas City
District
7 Charles E. Flndley/EPA
and Martha N. Lowe/Army
Corps of Engineers
IS Oddvar K. Aurdal/EPA and
Will Iam Nut I loan/Army
Corps of Engineera
8rad J. Euy/Waahlngton
Oapt. of Ecology
Charles E. Findley/EPA
Christine Psyk/EPA
lekrry
Hussmsn/Uaahlngton Dept.
of Ecology
10. Community Relations
00000028. Comaunity relations
00000029. Conmunity relations
Article entitled. -PCi'*: Everson
struggles wllth toxic uncertainty
Mailing list for those in attendance at
Everson town meeting 4/8/85
1/85
Diana Olets/Kllpsun
-------
NORTHWEST TRAMSfORMER • REMEDIAf,
I MOCK TO ADMINISTRATIVE RECORD
September 8. 1989
OOC. f flic
00000030. Community relations
00000031. Community relations
00000032. Community relations
00000033. Coomunity relations
00000053. Community relations
00000054. Comunity relations
00000085. Co*nunity relations
00000086. Community relations
00000087. Community Relations
00000088. Community Relations
Ivoe/Descr I Dt I on pug
Letter re stete intergovernmental 6/17/85
review proceaa for Northwest
Transformer
Handwritten notes re meetings with 4/1-2/86
members of community re cleanup work at
Northwest Transformer
Community Relations Plan for Northwest 6/86
Transformer, Mission Pole Road site
feet sheet re Northwest Transformer • 6/29/87
Superfund site
fact aheet re Northwest Transformer 7/28/88
Superfund site
fact sheet re Northwest Transformer 8/15/88
Superfund alte
Notice of investigations results and 8/17/88
public comment period for Northwest
Transformer Superfund site
Notice of Investigations results and 8/17/88
public comment period for Northwest
Transformer Superfund alte
Transmittal letter for information 8/17/88
repository
Correction to fact Sheet of 8/15/88 8/22/88
f Pos Author/Orqenilat i on
3 Kathryn N. Oavidson/EPA
9 N. L.
19 EPA
1 EPA
1 EPA, Region 10
1 EPA. Region 10
1 Bel Iingham Herald.
•ellingham, UA
Addreisce/OrflfnJiatlon
l*n Sack/Washington
Planning t Coamunity
Affairs Agency
General Public
Uestsida Record-Journal, General Public
ferndale, UA
Sally Nartyn/EPA
Sally Nartyn/EPA
Barbara Skinner/Everson
library, Evarson, UA
jl. References/Guidance
00000034. References/guidance
List of guidances for Administrative
Record
EPA
-------
NORTHWEST TRANSFORMER - REMEDIAL,
INDEX TO ADMINISTRATIVE RF.COBO
September 8, 1989
10
Tvne/Descr iptIon
Date
§ PQS Author/Oraanilat i on
Addressee/Groan!iatton
12. Naoa and Photos
00000035. Naps and photos
Aerial photographic analytic of
Northimt Transforawr
8/85
17 F. Mynar, I I/Lockheed
Engineering and
NanagaMnt Strvlce*
Company. Inc. prepared
for EPA
13. Qraft Remedial Investigation Reports
Draft remedial investigation Draft Remedial Investigation report,
reports Northwest Transformer
10/87
230 HDR Engineering. Omaha
Corps of Engineers--
Kansas City District.
EPA Region 10
U. Remedial Investigation/feasibility Study Consents
00000065. RI/FS study comments CoMents on draft RI/FS
00000066. Rl/fS study comments
00000067. Bl/fS study conroents
00000068. RI/FS study comnents
00000089. RI/FS study comments
00000090. RI/FS study comments
00000091. RI/FS study conments
CoMwnta on draft RI/FS
Consents on draft RI/FS
. 11/30/87 U
2/25/88 22
7/1/88 3
Response to cements on draft RI/FS 5/6/88
Letter: Coasunts on RI/FS for
Northwest Transformer
9/20/88
Letter requesting period of cossstnt on 9/9/88
RI/FS be extended 30 days
Handwritten letter stating preference 9/17/88
for alternative *1
46
4
Brad EMy/Uashington Dept.
of Ecology
Paul D. larber/Corps of
Engineers--Kansas City
District
Martin Uerner/UA Dept. of
Ecology
EPA Region 10, UA Dept.
of Ecology
Philip K. Jackson/Clsltan
County PUD «1
Frederick A.
Morris/Perkins Coie
Elaine t Jordan Silves,
Everson. UA
Sally Nartyn/EPA
Nike Coniett/KDR
Engineering. Qj*aha. ME
Brad Ewy/UA Oept. of
Ecology
Sally Nartyn/EPA
Robert Goodstein/EPA
Sally Nartyn/EPA
-------
NOHTHUtST TRANSFORMER • RENEQIAy
INOEK TO ADMINISTRATIVE RECORD
September 8. 1989
Doc, f File
00000092. RI/FS study comments
00000093. RI/FS study contents
00000094. RI/FS study conments
00000095. Rl/fS study conments
00000096. RI/FS study conments
00000097. Rt/FS study conments
00000090. RI/FS study conments
00000099. RI/FS study cowmen«•
00000100. RI/FS study comments
00000101. RI/FS study conments
00000102. RI/FS study comnents
Type/Description
Mtltlon/Coamcntary on proposed plan
and cleanup alternatives
Letter extending public comment period
for Northwest Transformer site another
2 week*
Lettert Response to petition
requesting no cleanup action to be
taken
Letter requesting destruction of former
letter, dated 9/21/88. and its
replacement with attached letter
leter: Comments on Northwest
Transformer draft Feasibility KStudy
Letter: Response to EPA's RI/FS et
Northwest Transformer
Cover letter and review cements on
RI/FS. Northweat Transformer alte
its
Nemo: Response to FS c
pertaining to risks
Letter: Comments on response to
comments (sepsrste from FS consent
period)
Letter: Comments on response to
comments (sepsrste from FS comment
period)
Nemo: Response to review comments of
the Northwest Transformer Steering
Conmittee
Pate
9/20/88
9/22/88
9/29/88
10/3/88
10/4/88
10/5/88
10/S/88
11/3/88
11/U/88
10/26/88
12/88
i Pas Author/Oraani tat ion
11 Uhatcom County area
residents
1 Usyne Crotheer/EPA
Sally Hsrtyn/EPA
Addrtssee/Oreanilet 1on
Sally Nartyn/EPA
Northwest Tranaformsr
Superfund site steering
committee
Concerned
citixens/Uhatcom County
3 Gary R. Gates, Deming. UA Sally Nartyn/EPA
98244
7 James E. Hansen/Geosafe
Corp
2 J. 0. Naner/Snohomish
County PUD *1
55 Puocst South Power t
Light Company t Landau
Associates
S Dana
Oavoll/Envlronomental
Health Assessment, EPA
IS Frederic A.
HorrIs/Perk ins Cole and
Landau Associates. Inc
4 James E. Hansen/Geosafe
Corp
47 NOR Engineering, Omaha,
NE
Sally Nartyn/EPA
Sally Nartyn/EPA
Sally Nartyn/EPA
file/EPA
Sally Nartyn/EPA
Sally Nartyn/EPA
Corps of Engineers--
Kansas City District and
EPA
-------
NORTHWEST TRANSFORMER • REMEDIAL
INOEK TO ADMINISTRATIVE RECORD
September 8, 1989
12
Doc. * F)H
Tvoe/DescriptIon
Date
t Pat Author/Ornaniiat ion
Addresset/Oraanliation
15. Final Remedial Investigation Report
00000070. Final remedial investigation Final Remedial Investigation Report,
report Northwest Transformer Superfund site
7/U
246 HOI Engineering, Omaha.
HE
Corp* of Englneera--
Kantai City Olttrlct t
EPA legion 10
16. Final Feasibility Study deport
00000069. Final feasibility study
report
00000103. Final feasibility study
report
00000104. Final feasibility study
report
Final Feasibility Study Report:
Northwest Transforswr (Mission/Pole)
Superfund alta
a/M
TransMlttat letter and Ml ling list for 8/26/58
feasibility study
Response to request for Feasibility
Study Information
9/26/88
160 HOR Engineering, Omaha,
NE
Sally Nartyn/EPA
Sally Nartyn/EPA
Corp* of Engineers--
Kansas City District i
EPA Region 10
Nailing list
Ken Norgan/Clallua
County PUD
17. Ritk Assessment
00000071. Risk assessment
00000105. Risk assessment
00000109. Risk assessment
00000110. Risk assessment
Risk Assessment, Northwest Transformer •-
Revised Risk Assessment, Northwest 12/29/88
Transformer
Revised Risk Assessment, Northwest --
Transformer
Nemo: Record of conference call re 11/03/88
comments on Risk Assessment
13
27
35
5
EPA Region 10
EPA Region 10
•-
Dana Davoli/Er
File/EPA
Health and Assessment.
EPA
IB. Proposed Cleanup Plan
00000072. Proposed cleanup plan
Proposed Cleanup Plan: Northwest
Transformer (Mission/Pole) Superfund
site
8/17/88
10
EPA Region 10
-------
BPJf^f
lili
NORTHWEST TRANSFORMER - REMEDIAI,
INDEK TO MMIfHHMTIVt BECTIg
Soptesfcer 8. 1989
lyDt/DeecrlDtlon
Date
* Pot Author/Organ! tat ion
Addressee/Oraanlutlon
19. Meetings
00000056. Meetings
OOOOOOS9. Meetings
00000060. Meetings
00000106. Meeting*
00000111. Meetings
00000112. Meeting*
SuMary of EPA/COE/Ecology/HM Meting
5/26/86 (u/notea and roster
>ting
of EPA/COE/Ecotogy/NDR
7/6-7/06 (w/roeter)
SuMary of EPA/COE/Ecology/HM Meeting
S/6/88 (M/aganda and roster)
Notice of InfonMtion sweting on
8/22/88 for P»Ps and Mi I ing list
Handwritten notes (M/roster) for
Morthiwst TransforMr Meting held
12/22/68
Handwritten notes (notes Include naecs
of attendees) for Northwest TransforMr
ting held 8/22/89
6/13/88
7/88
S/16/88
12/22/88
8/22/69
EPA Region 10
EPA Region 10
EPA Region 10
Charles Findley/EPA
Meeting participants
Meeting participants
Meeting participants
Mailing liat
2p. Health Assessments
00000107. Health asses*e*nte
00000106. Health aaaessMnts
Draft ATSOI Health AasessMnt for
Northwest TransforMr Salvage Yard NPl
aite
12/6/88
Final ATSOR Health Assessawtt for 4/U/89
Northwest Transfonaar Salvage Yard NPL
site
11 Agency for Toxic
Substances and Disease
Registry, Atlanta, GA
11 Agency for Toxic
Substances and Diaease
Registry. Atlanta. GA
Phil Millaat/EPA
Phil Nillaa/EPA
21. Record of Decision
00000123 Record of Decision
Record of Decision for Northwest
TransforMr aite
9/89
71
Robie G. Russell
-------
MQRTHKST TBAMSK»MER - EEMEOIM.
IMOEK TO AOMIMISTHATIVC MOMO
September 8. 1989
U
ill Ocsinn Docuncnu
1000122 >«MdUl Ottlgn OocuMnta
ttport: Application and Evaluation
Considerations for In Situ
Vitrification Tachnology
Data » Pas Author/Orasntntion
4/89 75 Ceosafe Corp
AddresiM/Oraanliatlon
------- |