HAZARDOUS
   CONTROL
    DIVISION
      Remedial
     Planning/
          Field
   nvestigation
         Team
     (REM/FIT)
       ZONE II
 i
•f
CONTRACT NO.
     68-01-6692
CH2M-SSHILL
    Ecology&
  Environment
                      VOLUME I
                      FEASIBILITY
                      STUDY FOR
                      SUBSURFACE CLEANUP
                      WESTERN PROCESSING
                      KENT, WASHINGTON
                      EPA 37.0L16.2

                      March 6, 1985

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VOLUME I


FEASIBILITY
STUDY FOR
SUBSURFACE CLEANUP

WESTERN PROCESSING
KENT, WASHINGTON

EPA 37.0L16.2

March 6, 1985

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                           PREFACE
This volume of the Western Processing Subsurface Cleanup
Feasibility Study contains Chapters 1 through 7.  The
appendixes and an Executive Summary are bound in separate
volumes.
                               111

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                     ABBREVIATIONS LIST
ADI       Allowable Daily Intake



CAA       Clean Air Act



CERCLA    Comprehensive Environmental Response,



            Compensation, and Liability Act



CLP       Contract Laboratory Program



CSL       Close Support Laboratory



CWA       Clean Water Act



EP        Extraction Procedure



FS        Feasibility Study



GWPS      USEPA Groundwater Protection Strategy



HSWA      Hazardous and Solid Waste Amendments (to RCRA)



MCL       Maximum Contaminant Level



Metro     Municipality of Metropolitan Seattle



NCP       National Oil and Hazardous Substances



            Contingency Plan



NPDES     National Pollutant Discharge Elimination



            System



PAH's     Polynuclear Aromatic Hydrocarbons



PCB's     Polychlorinated biphenyls



PKB       Pacific Northwest Bell Telephone Company



PP&L      Puget Sound Power and Light



PRP's     Potentially Responsible Parties



PSAPCA    Puget Sound Air Pollution Control Agency



RCRA      Resource Conservation and Recovery Act

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RI        Remedial Investigation



RMCL      Recommended Maximum Contaminant Level



TIC's     Tentatively Identified Compounds



USEPA     United States Environmental Protection Agency



WDOE      Washington State Department of Ecology
                                VI

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CONTENTS
     Preface                                             iii

     Abbreviations List                                    v

     Introduction                                        1-1
     1.1  Purpose                                        1-1
     1.2  Site Background                                1-1
     1.3  Remedial Actions to Date                       1-6
     1.4  Potentially Responsible Parties'
            Activities                                   1-8
     1.5  Concurrent Work by Others                     1-11
     1.6  Objectives of the Remedial Action             1-11
     1.7  Report Organization                           1-14
     1.8  Feasibility Study Analysis Areas               1-15

     Alternative Cleanup Criteria                        2-1
     2.1  Introduction                                   2-1
     2.2  Methodologies for Determining Adequacy
            of Cleanup                                   2-1
     2.3  Criteria Evaluation                            2-7
     2.4  Approaches to Applying Standards               2-38
     2.5  Summary of Criteria Used in This  Report       2-49

     Nature and Extent of Contamination                  3-1
     3.1  Introduction                                   3-1
     3.2  History of Data Acquisition                    3-1
     3.3  Groundwater/Surface Water Flow System          3-1
     3.4  Sampling and Data Analysis                    3-25
     3.5  Soil Contamination                            3-35
     3.6  Groundwater Contamination                    3-113
     3.7  Mill Creek Contamination                     3-165
     3.8  Other Potential Contaminant Migration
            Pathways                                   3-196
     3.9  Summary of the Nature and Extent  of
            Contamination                              3-203

     Endangerment Assessment                             4-1
     4.1  Introduction                                   4-1
     4.2  Site Description                               4-1
     4.3  Contamination                                  4-2
     4.4  Toxicology and Exposure to Site Chemicals      4-2
     4.5  Soils                                          4-5
     4.6  Groundwater                                   4-13
     4.7  Surface Water—Mill Creek                     4-17
     4.8  Limitations of the Methodology                4-23
     4.9  Summary and Conclusions                       4-24
                          VII

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     Remedial Action Technologies
     5.1  Site Problems
     5.2  Technology Groups
     5.3  Assessment Criteria
     5.4  Discussion of Assessed Applicable
            Remedial Technologies

     Example Remedial Action Alternatives
     6.1  Introduction
     6.2  Component Analysis
     6.3  Description of Example Alternatives
     6.4  Evaluation of Example Alternatives
     6.5  Summary

     References
                                           5-11

                                            6-1
                                            6-1
                                            6-1
                                           6-18
                                           6-44
                                          6-151

                                            7-1
(The following appendixes are bound separately.)
Appendix A.


Appendix B.

Appendix C.


Appendix D.


Appendix E.


Appendix F.




Appendix G.
PRP Remedial Action Plan Development
Process (Prepared by PRP Group)

Summary of Applicable Regulations

Detected Indicator Compounds in Soils
and Groundwater

Environmental Migration and Fate of
Indicator Chemicals

Estimating Lifetime Average Water
and Soil Intake

Methods, Assumptions, and Criteria for
Contaminant Source Quantification,
Groundwater Quality Analysis, Battelle
Groundwater Flow/Transport Model

Methods, Assumptions, and Criteria for
Groundwater Treatment Process Selection/
Design
                          Vlll

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TABLES
                                                        Page
1-1  Materials Removed by USEPA From Western
     Processing                                          1-7

1-2  History of PRP Involvement with Western
     Processing Site Cleanup                             1-8

2-1  Summary of Numerical Criteria                       2-8

2-1A Key to Criteria Abbreviations                      2-22

2-1B References for Numerical Criteria                  2-23

2-2  Phytotoxic Guidelines From the British
     Department of the Environment                      2-28

2-3  Metal Concentrations in Background Soil
     Samples Collected in the Kent Valley               2-30

2-4  Links Between Environmental Media and Public
     Exposure                                           2-32

2-5  Soil Criteria From the British Department of
     the Environment                                    2-37

2-6  Washington State Standard/Background Cleanup
     Levels                                             2-47

2-7  Washington State Protection Cleanup Levels         2-48

2-8  Criteria From Table 2-1 Used in Other Chapters     2-66

3-1  Groundwater Level Elevation Data                   3-16

3-2  Summary of Data Sources, Test Methods, and
     Identifiers Used in the Data Management System     3-26

3-3  Selected Indicator Contaminants                    3-30

3-4  Tentatively Identified Compounds and Unknowns      3-34

3-5  Background Metal Concentrations for Soil and
     Groundwater in the Kent Valley, Washington         3-35

3-6  Number of Occurrences of Detected Priority
     Pollutants in Onsite Soils at Western Processing   3-36

3-7  Number of Occurrences of Detected Priority
     Pollutants in Off-Property Soils Near Western
     Processing                                         3-38
                           IX

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                                                        Page

3-8  Maximum Metals Concentrations in Soils             3-39

3-9  Metals in Soil and Dust Samples Taken from
     Rental Property North of Western Processing,
     June 1984                                          3-45

3-10 Maximum Concentrations for Indicator Organics
     in Onsite and Off-Property Soils                   3-65

3-11 Organics in SB-14                                  3-66

3-12 Maximum Volatile Indicator Organics in Area I
     Soils                                              3-73

3-13 Maximum Off-Property Volatile Indicator Organics
     in Soils                                           3-74

3-14 Methods for Volatile Analysis Used by the CLP
     and Radian Laboratories                            3-75

3-15 Comparison of Volatile Priority Pollutant Data
     in Soils Using Various Analytical Methods          3-76

3-16 Summary of Data for Samples having PAH Concen-
     tration Greater than 100,000 yg/kg                 3-90

3-17 Summary of PAH's in Soils at Concentrations
     Greater than 100,000 yg/kg                         3-91

3-18 PAH's Dected in Off-Property Boring WP-IB-03        3-91

3-19 Comparison of Data Generated by the EPA Region X
     Laboratory in Manchester and the EPA Contract
     Laboratory Program                                 3-92

3-20 Total Phthalates in Borings Having More Than
     10,000 yg/kg                                       3-99

3-21 Summary of PCB Occurrence in Onsite and Off-
     Property Soils                                    3-101

3-22 Onsite PCB Contamination                          3-102

3-23 Off-Property PCB Contamination                    3-104

3-24 Oxazolidone in Soils                              3-108

3-25 Oxazolidone and Arsenic in Soil Samples           3-109

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                                                        Paqe
3-26 Number of Occurrences of Detected Priority
     Pollutants in Groundwater Wells on Western
     Processing Site                                   3-114

3-27 Number of Occurrences of Detected Priority
     Pollutants in Groundwater Wells From Off-
     Property Wells                                    3-115

3-28 Maximum Indicator Metals in Shallow Groundwater   3-119

3-29 Summary of Maximum Indicator Metals in
     Groundwater                                       3-120

3-30 Indicator Metals in Off-Property Intermediate
     Depth Wells Having Concentrations Above
     Background                                        3-121

3-31 Indicator Metals in Off-Property Deep Wells in
     Concentrations Above Background                   3-122

3-32 Total Indicator Metals in Wells Sampled
     More Than Once                                    3-123

3-33 Number of Occurrences of Detected Volatile
     Priority Pollutants in Groundwater                3-127

3-34 Volatile Organics in Shallow Wells Having More
     Than 100,000 yg/L Total Volatiles                 3-131

3-35 Volatile Organics in Intermediate Depth
     Wells                                             3-133

3-36 Volatile Organics in Deep Wells                   3-134

3-37 Volatiles in Wells Sampled More Than Once         3-136

3-38 Number of Occurrences of Detected Acid
     Extractable Priority Pollutants in
     Groundwater                                       3-139

3-39 Acid Extractable Priority Pollutants in Wells
     Sampled More Than Once                            3-143

3-40 Number of Occurrences of Detected Base Neutral
     Priority Pollutants in Groundwater                3-145

3-41 Polycyclic Aromatic Hydrocarbons in Groundwater   3-149

3-42 Total PAH's in Wells Sampled Multiple Times       3-150

3-43 Total Phthalates in Groundwater                   3-152
                          XI

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                                                        Page

3-44 Total Phthalates in Wells Sampled Several
     Times                                             3-156

3-45 Oxazolidone in Groundwater                        3-157

3-46 Sources of Data on Contamination of Water and
     Sediment in Mill Creek                            3-166

3-47 Water Hardness, Concentration of Dissolved
     Metals, and Ambient Water Quality Criteria at
     WDOE Stations 09E090 (Upstream)  and 09E070
     (Downstream) at Western Processing                3-170

3-48 Concentrations of Total Copper (yg/L)  Measured
     by Metro and the USEPA at Stations Upstream,
     Downstream, and Far Downstream of Western
     Processing                                        3-171

3-49 Concentrations of Total Chromium (yg/L)
     Measured by Metro and the USEPA at Stations
     Upstream, Downstream, and Far Downstream of
     Western Processing                                3-172

3-50 Concentrations of Total Nickel (yg/L)  Measured
     by Metro and the USEPA at Stations Upstream,
     Downstream, and Far Downstream of Western
     Processing                                        3-173

3-51 Concentrations of Total Zinc (yg/L) Measured
     by Metro and the USEPA at Stations Upstream,
     Downstream, and Far Downstream of Western
     Processing                                        3-174

3-52 Concentrations of Total Lead (yg/L) Measured
     by Metro and the USEPA at Stations Upstream,
     Downstream, and Far Downstream of Western
     Processing                                        3-175

3-53 Concentrations of Total and Dissolved Metals in
     Water Samples From Well Points and Mill Creek
     (Surface Water) Collected by the USEPA on
     May 20-21, 1982                                   3-178

3-54 Concentrations of Dissolved Priority Pollutant
     Metals and Cyanide in Water From Wells Adjacent
     to Mill Creek                                     3-179

3-55 Concentrations of Organic Priority Pollutants
     Detected in Mill Creek and in Groundwater From
     Well Points Adjacent to the Creek by the USEPA
     in May 1982                                       3-181
                           Xll

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3-56 Organic Pollutants Detected During the January
     1984 Hydrologic Survey of Mill Creek in the
     Vicinity of Western Processing                    3-183

3-57 Sediment Sampling                                 3-184

3-58 Organic Compounds in Mill Creek Water and
     Sediments and in Water From Wells Adjacent
     to Mill Creek From All Available Data Sources     3-188

3-59 Mass Flows of Metals Past Three Locations Near
     Western Processing                                3-190

3-60 Mass Loadings of Dissolved Metals to Mill Creek
     in the Vicinity of Western Processing             3-191

3-61 Streamflow Records Used to Estimate Mill Creek
     Flows                                             3-191

3-62 Mill Creek Expected Mean Annual and Monthly
     Discharges                                        3-192

3-63 Mass Flows of Metals (as Total Metals)  Added
     to Mill Creek in the Vicinity of Western
     Processing                                        3-193

3-64 Average Concentrations of Metals in Sediment
     Upstream of and at Western Processing
     (Stations R30-14 and R26-17 A and B) and
     Bedload Transport of Metals                       3-195

3-65 Estimated Mill Creek Contaminant Concentrations
     Attributable to Groundwater Mass Loading          3-196

4-1  Known and Suspected Carcinogens on EPA Priority
     Pollutant List                                      4-4

4-2  Summary of Onsite Surface Soil Contaminantion and
     Cancer Potencies for Carcinogens, Worker Scenario   4-8

4-3  Summary of Onsite Soil Contamination to a Depth
     of 12 Feet and Cancer Potencies for Carcinogens,
     Worker Scenario                                     4-9

4-4  Summary of Onsite Surface Soil Contamination and
     Criteria for Noncarcinogens                        4-11

4-5  Summary of Onsite Soil Contamination to a Depth of
     12 Feet and Criteria for Noncarcinogens            4-12
                          Xlll

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                                                        Page
4-6  Summary of Onsite Groundwater Contamination and
     Cancer Potencies for Carcinogens,  Worker Scenario  4-15

4-7  Summary of Onsite Groundwater Contamination and
     Cancer Potencies for Carcinogens,  Lifetime
     Residential Scenario                               4-16

4-8  Summary of Onsite Groundwater Contamination and
     Criteria for Noncarcinogens                        4-18

4-9  Summary of Toxicity Values for Cadmium,  Copper,
     and Zinc to Four Salmonid Fish                     4-21

5-1  Impact of Technology Groups on Existing  and
     Potential Site Problems                             5-6

5-2  Technologies Potentially Applicable at Western
     Processing                                          5-7

5-3  Preliminary Assessment of Surface  Cap
     Technologies                                       5-12

5-4  Preliminary Assessment of Mill Creek Diversion
     Technologies                                       5-15

5-5  Preliminary Assessment of Containment Barrier
     Technologies                                       5-17
                                               "i
5-6  Preliminary Assessment of Groundwater Pumping
     Technologies                                       5-19

5-7  Preliminary Assessment of Sediment Removal
     Technologies                                       5-21

5-8  Preliminary Assessment of In Situ  Treatment
     Technologies                                       5-23

5-9  Preliminary Assessment of Groundwater Treatment
     Technologies                                       5-28

5-10 Preliminary Assessment of Groundwater Disposal
     Technologies                                       5-41

5-11 Preliminary Assessment of Soil Disposal
     Technologies                                       5-43

5-12 Technologies Available for Use in  Example
     Remedial Action Alternatives                       5-45

6-1  Site Average Metals Concentrations Remaining in
     Soil by Area at Selected Depths                     6-5
                          xiv

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                                                        Page

6-2  Site Average Organic Concentrations Remaining in
     Soil by Area at Selected Depths                     6-6

6-3  Predicted Concentrations of Selected Contaminants
     in Groundwater After Pumping For 30 Years          6-13

6-4  Potential Limitations for Discharge to Metro
     Sanitary Sewer System                              6-14

6-5  Potential Ambient Water Quality Criteria for
     NPDES Discharge                                    6-14

6-6  Technical Evaluation—Example Alternative 1        6-51

6-7  Technical Evaluation—Example Alternative 2        6-52

6-8  Technical Evaluation—Example Alternative 3        6-60

6-9  Technical Evaluation—Example Alternative 4
     (PRP Plan)                                          6-65

6-10 Technical Evaluation—Example Alternative 5        6-75

6-11 Technical Evaluation—Example Alternative 6        6-80

6-12 Technical Evaluation—Example Alternative 7        6-81

6-13 Environmental Evaluation, Example
     Alternative 1—No Action                           6-83

6-14 Environmental Evaluation, Example
     Alternative 2—Surface Cap With Groundwater
     Extraction and Treatment                           6-86

6-15 Environmental Evaluation, Example
     Alternative 3—Excavation With Onsite
     Disposal, Groundwater Extraction and
     Treatment, Surface Cap                             6-91

6-16 Environmental Evaluation, Example
     Alternative 4—PRP's Remedial Action Plan          6-94

6-17 Environmental Evaluation, Example
     Alternative 5—Excavation With Offsite
     Disposal                                           6-99

6-18 Environmental Evaluation, Example
     Alternative 6—Mill Creek No Action               6-102

6-19 Environmental Evaluation, Example
     Alternative 7—Sediment Removal                   6-104
                           xv

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                                                        Page

6-20 Summary of Major Beneficial and Adverse
     Environmental Impacts                             6-107

6-21 Laws, Regulations, and Standards Applicable
     to Western Processing                             6-112

6-22 Laws, Regulations, and Standards Applicable
     to Alternative 1, No Action                       6-121

6-23 Laws, Regulations, Standards Applicable to
     Alternative 2, Surface Cap/Groundwater Pump
     and Treat                                         6-122

6-24 Laws, Regulations, Standards Applicable to
     Alternative 3, Excavation With Onsite Disposal,
     Groundwater Pump and Treat, and Surface Cap       6-125

6-25 Laws, Regulations, Standards Applicable to
     Alternative 4, The PRP Alternative:  Excavation
     With Offsite Disposal, Diversion Wall,
     Groundwater Pump and Treat, and Surface Cap       6-129

6-26 Laws, Regulations, Standards Applicable
     to Alternative 5, 15-Foot-Deep Excavation         6-132

6-27 Laws, Regulations, and Standards Applicable
     to Alternative 6, Mill Creek/No Action            6-135

6-28 Laws, Regulations, and Standards Applicable
     to Alternative 7, Mill Creek Sediment Removal     6-137

6-29 Cost Estimate for Example Alternative 2           6-140

6-30 Cost Estimate for Example Alternative 3           6-142

6-31 Cost Estimate for Example Alternative 4           6-144

6-32 Cost Estimate for Example Alternative 5           6-146

6-33 Cost Estimate for Example Alternative 7           6-148

6-34 Summary of Public Health, Environmental,
     and Technical Evaluations                         6-153
                          xvi

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FIGURES

                                                        Page

1-1  Feasibility Study Process                           1-2

1-2  Location Map                                        1-3

1-3  Vicinity Map                                        1-4

1-4  Western Processing Site, December 31, 1984         1-13

1-5  Analysis Areas                                     1-16

3-1  Chronology of Investigation Activities              3-2

3-2  Regional Geology Map                                3-5

3-3  Regional Geologic Cross Section                     3-6

3-4  North/South Cross Section, Eastern Edge of Site    3-11

3-5  East/West Cross Section, Middle of Site            3-13

3-6  Schematic Geologic Section                         3-15

3-7  Computer Generated Groundwater Elevation Contours  3-19

3-8  Shallow Groundwater Elevation Contours             3-20

3-9  Schematic Representation of Local Groundwater
     Flow System                                        3-22

3-10 Well MB-03 Water Pressure Measurements             3-23

3-11 Soils Contamination Summary Map:  Metals
     Contamination at Surface                           3-40

3-12 Soils Contamination Summary Map:  Metals
     Contamination at 0-4 Feet Below Ground Surface     3-41

3-13 Soils Contamination Summary Map:  Metals
     Contamination at 5-9 Feet Below Ground Surface     3-42

3-14 Soils Contamination Summary Map:  Metals
     Contamination at 10-20 Feet Below Ground Surface   3-43

3-15 Soils Contamination Summary Map:  Metals
     Contamination at >20 Feet Below Ground Surface     3-44

3-16 Cross-Section Plan                                 3-47

3-17 Metallic Contaminants in Soils, Section A          3-49
                           xvn

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                                                        Page

3-18 Metallic Contaminants in Soils,  Section B          3-51

3-19 Metallic Contaminants in Soils,  Section C          3-53

3-20 Metallic Contaminants in Soils,  Section D          3-55

3-21 Metallic Contaminants in Soils,  Section E          3-57

3-22 Metallic Contaminants in Soil, Section F           3-59

3-23 Metallic Contaminants in Soil, Section G           3-61

3-24 Metallic Contaminants in Soil, Section H           3-63

3-25 Soils Contamination Summary Map:
       Volatile Organics at Surface                     3-67

3-26 Soils Contamination Summary Map:  Volatile
       Organics at 0-4 Feet Below Ground Surface        3-68

3-27 Soils Contamination Summary Map:  Volatile
       Organics at 5-9 Feet Below Ground Surface        3-69

3-28 Soils Contamination Summary Map:  Volatile
       Organics at 10-20 Feet Below Ground Surface      3-70

3-29 Soils Contamination Summary Map:  Volatile
       Organics at >20 Feet Below Ground Surface        3-71

3-30 Soils Contamination Summary Map:  Acid
     Extractables at Surface                            3-79

3-31 Soils Contamination Summary Map:  Acid
     Extractables at 0-4 Feet Below Ground Surface      3-80

3-32 Soils Contamination Summary Map:  Acid
     Extractables at 5-9 Feet Below Ground Surface      3-81

3-33 Soils Contamination Summary Map:  Acid
     Extractables at 10-20 Feet Below Ground Surface    3-82

3-34 Soils Contamination Summary Map:  Acid
     Extractables at >20 Feet Below Ground Surface      3-83

3-35 Soils Contamination Summary Map:  PAH's
     at Surface                                         3-85

3-36 Soils Contamination Summary Map:  PAH's
     at 0-4 Feet Below Ground Surface                   3-86

3-37 Soils Contamination Summary Map:  PAH's
     5-9 Feet Below Ground Surface                      3-87

                          xviii

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                                                        Page
3-38 Soils Contamination Summary Map:   PAH's
     at 10-20 Feet Below Ground Surface                 3-88

3-39 Soils Contamination Summary Map:   PAH's
     >20 Feet Below Ground Surface                      3-89

3-40 Soils Contamination Summary Map:   Phthalates
     at Surface                                         3-93

3-41 Soils Contamination Summary Map:   Phthalates
     at 0-4 Feet Below Ground Surface                    3-94

3-42 Soils Contamination Summary Map:   Phthalates
     at 5-9 Feet Below Ground Surface                    3-95

3-43 Soils Contamination Summary Map:   Phthalates
     at 10-20 Feet Below Ground Surface                 3-96

3-44 Soils Contamination Summary Map:   Phthalates
     at >20 Feet Below Ground Surface                    3-97

3-45 Total PCB Summary for All Depths                   3-100

3-46 Pesticides in Soils and Sediments                 3-103

3-47 Indicator Priority Pollutant Metals in
     Groundwater                                       3-117

3-48 Total Priority Pollutant Volatile Organics
     in Groundwater                                    3-129

3-49 Total Priority Pollutant Acid Extractables
     in Groundwater                                    3-141

3-50 Total Priority Pollutant PAH's in Groundwater     3-147

3-51 Total Priority Pollutant Phthalates in
     Groundwater Wells                                 3-153

3-52 Oxazolidone Concentrations in Groundwater
     Wells                                             3-159

3-53 Black River Drainage Basin                        3-167

3-54 Underground Utilities                             3-198

3-55 Historic Surface Water Drainage and Collection
     Areas                                             3-204

3-56 Summary of Nature and Extent, Indicator Metals
     in Soils 0-9 Feet Below Ground Surface             3-207
                          xix

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                                                        Page
3-57 Summary of Nature and Extent, Indicator
     Volatiles in Soils 0-9 Feet Below Ground
     Surface                                           3-208

3-58 Summary of Nature and Extent, Indicator Acid
     Extractables in Soils 0-9 Feet Below Ground
     Surface                                           3-209

3-59 Summary of Nature and Extent, Total PAH
     Compounds in Soils 0-9 Feet Below Ground
     Surface                                           3-210

3-60 Summary of Nature and Extent, Total Phthalates
     in Soils 0-9 Feet Below Ground Surface            3-211

4-1  Existing Land Use                                   4-3

6-1  Conceptual Site Plan for Example Alternative 2:
     Surface Cap/Groundwater Pumping and Treatment      6-21

6-2  Conceptual Cross-Section of Example
     Alternative 2:  Surface Cap/Groundwater Pumping
     and Treatment                                      6-23

6-3  Groundwater Treatment Process Flow Chart           6-25

6-4  Conceptual Site Plan for Example Alternative 3:
     Excavation With On-Property Landfill Disposal/
     Groundwater Pumping and Treatment/Surface Cap      6-27

6-5  Conceptual Cross-Section of Example
     Alternative 3:  Excavation With Onsite Landfill
     Disposal/Groundwater Pumping and Treatment/
     Surface Cap                                        6-29

6-6  Site Plan for Example Alternative 4                6-33

6-7  Site Cross-Section for Example Alternative 4       6-35

6-8  Conceptual Site Plan for Example Alternative 5:
     Contaminated Soil Disposal Offsite/Asphalt
     Surface Cap With Groundwater Treatment             6-39

6-9  Conceptual Cross-Section of Example
     Alternative 5:  Contaminated Soil Disposal
     Offsite/Asphalt Surface Cap With Groundwater
     Treatment                                          6-41

6-10 Plan View of Mill Creek Diversion Berms and
     Temporary Pipeline                                 6-45

6-11 Cross-Section of Diversion Structure               6-47

                          xx

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                          Chapter 1
                        INTRODUCTION
                        1.1  PURPOSE

This feasibility study was prepared to address the range of
potential remedial measures for the Western Processing Super-
fund site following the recently completed surface cleanup
actions.  The scope of this report includes (1) analysis of
the nature and extent of the contamination remaining at the
site, (2) evaluation of potential cleanup criteria,  (3) prep-
aration of an assessment of the public health and environmen-
tal endangerment, (4) development of applicable technologies
to address the site's problems, and (5) preparation of a set
of example alternative remedial actions.  For this site,
some tasks normally accomplished in the remedial investigation
(RI) report  (1 and 2 above) have been included in the feasi-
bility study  (FS).  The overall process for the development
of a feasibility study is specified by the National Oil and
Hazardous Substances Contingency Plan  (NCP).  Figure 1-1
shows this process as applied at Western Processing.  The
purpose of the FS is to provide relevant technical and re-
lated information leading to the selection by the U.S. Envi-
ronmental Protection Agency (USEPA) of "...the lowest cost
alternative that is technologically feasible and reliable
and that effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare, or
the environment" [40 CFR 300.68(j)].  The FS is not intended
to be a design document.  It provides a conceptual overview
of example remedial alternatives to address the problems at
the Western Processing site.

This report is prepared in partial fulfillment of Contract
No. 68-01-6692, Work Assignment No. 37.0L16.2, and the Re-
vised Work Plan dated January 15, 1985.

                    1.2  SITE BACKGROUND

This section was compiled from the previously issued Focused
Feasibility Study for Surface Cleanup  (USEPA, 1984) , the
Remedial Action Master Plan and Project Work Statement  (Black
and Veatch, January 1983) .  Discussions have been updated to
reflect activities that have taken place in the interim.

1.2.1  LOCATION

The Western Processing site is located in the Green River
Valley at 7215 South 196th Street in Kent, Washington.  Fig-
ures 1-2 and  1-3 show the general location and site vicinity.
The site is  located in an old farming region that has devel-
oped into a  light industrial/commercial area.  The Western
Processing property is bounded on the west by undeveloped
land and Mill Creek, which crosses into the northwest corner
                           1-1

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1
Establish
Remedial Goals
and Obiectives
Ch.1
Evaluate Potential _
Cleanup Criteria
Ch.2

Reiect Remedial a
Technologies

i ' '
i
Identify Problems
I & Operable Units)
and Contamination
Pathways ch 3

V
Identify Conceptual
Alternatives
Ch.5
i

Select Applicable
Remedial Technologies
Ch.5
i

Technical
Screening
Environmental, Public
Health & Institutional
Cost Screening
\

Identify Alternative
Remedial Actions Ch.6
<

' i
Human Health and
Environmental
Endangerment
Assessment ^ ^


i i '
Environmental & Institutional
Technical Analysis Cost Analysis Public Health Analysis
Analysis



'



Recommend
Remedial Action

I—	1
 Conceptual Design
                                       WESTERN
                                      PROCESSING
                                      FEASIBILITY
                                        STUDY
                                       ! BY EPA )
                                      TO FOLLOW
1-2
                                  FIGURE 1-1
                                  FEASIBILITY STUDY PROCESS

-------
                           «r


                           WASHINGTON
                                         ^"V-^
                                         ~ ^rSfciw»**j
      f; %, M
-------
      WES
      PROCESSING
      SITE
                           FIGURE 1-3
                           VICINITY MAP
1-4

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of the property.  South 196th Street is the northern bound-
ary, and the Interurban Trail and associated drainageway
form the eastern boundary.  To the south is property that is
currently being developed in accordance with the light in-
dustrial land use classification.

1.2.2  LOCAL HYDROLOGY

The site lies next to Mill Creek  (King County Drainage Ditch
No. 1).  According to the most recent flood insurance study
(FEMA, 1980), the majority of the site is outside the
100-year flood plain associated with Mill Creek.  The site
is shown as a standing water area for some local drainages
that have since been diverted to the drainageway between the
Interurban Trail and the railroad.  Currently, surface run-
off from the site is being collected and treated.

1.2.3  BRIEF SITE USE HISTORY

From 1952 to 1961 the site was leased to the U.S. Army for
use as an antiaircraft battery.  In 1961 the site was turned
back to the owner without removal of general support facili-
ties and sold to Western Processing Company, Inc.  From 1961
to early 1983 various chemical reclamation and industrial
waste processing and storage activities were conducted on
slightly over 11 of the 13 acres.  The balance of the hold-
ing (northwest of the creek) was used as a residence.

According to the Remedial Action Master Plan  (Black and
Veatch, 1983), information about the operations at the site
is limited because records are incomplete.  The principal
wastes received by Western Processing include:

     o    Electroplating solutions and sludges
     o    Pesticides/herbicides
     o    Spent acid and caustic solutions
     o    Waste oils and solvents
     o    Battery mud (chips)
     o    Flue dust from secondary smelters
     o    Aluminum slag
     o    Galvanization skimmings

Products that were produced from the wastes accepted at the
facility include:

     o    Zinc ingots
     o    Ferric compounds for moss control on lawns
     o    Flame retardants for wood products
     o    Fertilizer additives
     o    Wood preservative  (copper-chromium-arsenate)
     o    Sodium cyanide
     o    Fuel oil and recovered solvents
     o    Zinc sulfate  (liquid and pellets)
                           1-5

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     o    Zinc chloride
     o    Zinc nitrate
     o    Iron oxide pellets
     o    Iron sulfate
     o    Sodium aluminate
     o    Ammonium sulfate
     o    Aluminum sulfate
     o    Copper sulfate
     o    Copper hydroxide
     o    Sodium dichromate
     o    Lead chromate (pigment)

                1.3  REMEDIAL ACTIONS TO DATE

Since the site was closed in early 1983, there have been
three major remedial activities undertaken to mitigate the
hazards posed by the site.  The actions included an emergency
removal conducted by USEPA, a stormwater control project by
the Washington State Department of Ecology (WDOE),  and a
surface cleanup conducted by Chemical Waste Management, Inc.
and financed by the Western Processing Coordinating Committee,
a group of parties which generated or transported hazardous
wastes that were sent to the site.  The first two actions
are summarized below.  Section 1.4 addresses the Western
Processing Coordinating Committee actions to date at the
site.  In addition to the remedial actions at the site, a
number of data gathering actions have been undertaken.  These
latter activities are summarized in the remedial investiga-
tion data report released in mid-December 1984 and are shown
in Figure 3-1 (Chapter 3).  In addition to the investigative
and remedial activities at the site, the owner of the site
had access to the site after it was closed by USEPA, and
prior to the surface cleanup removed numerous materials
including zinc oxide, scrap metals, and assorted cans of
paint and stain.

1.3.1  EMERGENCY CLEANUP

After the results of the soil and groundwater investigations
were released and widespread contamination was confirmed,
USEPA issued an administrative order pursuant to the Compre-
hensive Environmental Response, Compensation, and Liability
Act  (CERCLA) instructing Western Processing to cease all
operations at the site and begin cleanup of contaminated
areas.  After it was determined that the owner would not
take action, an emergency cleanup action was undertaken using
CERCLA funds.  By July 1983 the USEPA team, which included
subcontractors and the U.S. Coast Guard, had removed from
the site the materials listed in Table 1-1.

Remaining drummed materials were relocated onsite according
to hazard potential.  The majority of drummed wastes was
analyzed as part of this cleanup effort to determine waste
                          1-6

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compatibility for bulking.  Some drums were not inventoried
or analyzed during the emergency response.  Each analyzed
drum was marked with an inventory code.  The types of tests
undertaken during emergency cleanup were noted in a separate
report (Tetra Tech, Inc., 1984).
                          Table 1-1
     MATERIALS REMOVED BY USEPA FROM WESTERN PROCESSING
                    (As of July 1, 1983)
         Material Description
Paint Sludges and Flammables
(Solidified)

Hazardous Liquids

Flammable Liquids (Bulk and Drums)

Combustible Liquids (Bulk)

Solvents (Recycled)

Corrosive Liquids (Bulk and Drums)

Noncorrosive Oxidizers (Drums)

Wastewater from Ponds and Tanks

Liquids and Other Materials
Contaminated with PCB's
       Quantity
1,944 cubic yards


461,610 gallons

50,470 gallons

85,000 gallons

24,700 gallons

51,280 gallons

660 gallons

249,500 gallons

127 drums
Source:  Roy F. Weston, Inc., 1984.
1.3.2  WASHINGTON STATE DEPARTMENT OF ECOLOGY STORMWATER
CONTROL

From September through December 1983, WDOE installed control
measures for stormwater.  The planned measures included
(1) relocation of the balance of the gypsum pond residuals
to the pile area  (created earlier by the emergency response
team),  (2) covering the pile with an impermeable, flexible
cover,  (3) regrading the portions of the site around the
pile and old pond area to promote drainage, (4) paving the
graded areas with an asphalt concrete mix, and (5) installing
berms at the perimeter of the paved area to prevent storm-
water run-on from contaminated areas.  A discussion of speci-
fic activities follows.
                           1-7

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Drums in the area graded by WDOE were relocated to two sepa-
rate areas in the southern portion of the site.  Two large
steel underground tanks were unearthed during these activi-
ties.  The contents of these tanks were shipped to a hazard-
ous waste disposal facility.  The empty tanks were crushed
and placed in the gypsum pile.  Samples were taken from the
gypsum material and onsite berms during this activity.  These
samples were analyzed for the presence of metallic and organic
contamination.

The old gypsum pond area was graded, bermed  (diked), and
paved in order to reduce the amount of stormwater infiltrat-
ing into the groundwater system.  A gravity drain line was
installed to discharge the stormwater runoff from the newly
paved clean area to Mill Creek.  A small berm was constructed
to contain stormwater that had always gathered at a low point
near a laboratory building inside the central road loop and
to prevent possible discharge of this potentially contami-
nated water to Mill Creek.

     1.4  POTENTIALLY RESPONSIBLE PARTIES' ACTIVITIES

In 1983, USEPA contacted approximately 300 entities that had
generated or transported waste materials to the Western Pro-
cessing site during its 22-year operating period.  USEPA
informed these parties that they were potentially responsible
under CERCLA for funding or conducting the cleanup of the
Western Processing site.  A brief history of activities under-
taken by the potentially responsible parties (PRP's) is pre-
sented in Table 1-2.
May 19, 1983
            Table 1-2
HISTORY OF PRP INVOLVEMENT WITH
WESTERN PROCESSING SITE CLEANUP

  USEPA informs PRP's of potential responsibil-
  ity for undertaking remedial measures at
  Western Processing and/or for costs incurred
  by the Agency; requests data on wastes de-
  livered to the site.

  USEPA-sponsored PRP meeting for purpose of
  encouraging negotiations leading to a cleanup
  of the site.  Ad Hoc Committee formed by PRP's
  to coordinate response to USEPA.

  First major PRP meeting; establishment of the
  Western Processing Coordinating Committee;
  initiation of activities designed to lead
  toward PRP-funded cleanup.
Jan. 11, 1984
May 8, 1984
                           1-8

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May 14, 1984


June 5, 1984



June 13, 1984



June 18, 1984



July 20, 1984



July 20, 1984
Aug. 1, 1984
Sept. 24 and
Oct. 3, 1984

Oct. 1, 1984
Oct. 16, 1984
Nov. 16, 1984
Chemical Waste Management, Inc., selected as
contractor for surface cleanup  (Phase I).

Negotiations on the Phase I Partial Consent
Decree begin between USEPA, Washington
State, and the PRP's.

Site access agreement between PRP's and the
Western Processing site owner, Garmt
Nieuwenhuis, reached.

Agreement in principle reached between gov-
ernment negotiators and PRP's on scope and
terms of Phase I surface cleanup.

Partial Consent Decree Judgment entered by
Judge McGovern of U.S. District Court (West-
ern District Washington).

Second Amended and Supplemental Complaint
filed, naming signatories to Phase I Consent
Decree as defendants and State of Washington
as plaintiff in the case of United States
vs. Western Processing et al.   (W.D.Wa.)
Civil No. C83-252M.

First shipment of waste leaves Western Pro-
cessing site.

Technical Plan for Phase II cleanup
submitted to USEPA/DOE for review.

Field study authorized to collect data and
to conduct field tests for use in final
design.

Presentation of PRP-sponsored subsurface
cleanup plan to federal and state
representatives.

Onsite precipitation treatment plant
operational  (water had been shipped offsite
for treatment prior to this date) .
On April 11, 1984, USEPA formally announced to the PRP's
that it intended to accomplish surface  (Phase I) cleanup of
the Western Processing site during the  summer of 1984.  WDOE
emphasized the need to complete the Phase I cleanup before
the winter rainy season began.  USEPA invited the PRP's to
submit a proposal for performing a PRP-funded surface  cleanup
and set a deadline of June 18, 1984, for reaching an agree-
ment on a PRP-funded cleanup.
                           1-9

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On May 14, 1984, the PRP's selected Chemical Waste Manage-
ment, Inc. (CWM) as the contractor to perform the Phase I
cleanup.  Shortly thereafter, the PRP's met with federal and
state negotiators to present a technical plan for the surface
cleanup of the Western Processing site.  The plan included
the complete removal of all wastes and structures from the
surface of the site, grading and construction of a lined
impoundment to provide stormwater collection, and treatment
of collected stormwater during the winter months.  All
removal activities were scheduled to be completed by Novem-
ber 30, 1984.  With minor modifications, the plan was subse-
quently approved by USEPA, the U.S. Department of Justice,
and the State of Washington.  In addition to negotiating a
Phase I cleanup plan with the federal and state governments,
the PRP's also negotiated a site access agreement with the
site owner.

On July 15, 1984, CWM began to mobilize for the Phase I
cleanup.  The first waste load left the site on August 1,
1984.

Cleanup proceeded according to schedule.  As of November 1,
1984, 2,437 truckloads of liquid, solid, and demolition
wastes had been shipped from the site.   During the surface
removal, stormwater was collected and transferred by truck
to a nearby private wastewater treatment facility, where it
was treated prior to discharge to the Municipality of
Metropolitan Seattle (Metro) sewer system.  An onsite
wastewater treatment facility has been constructed and is in
operation.  Discharge from this facility is to the Metro
sewer system.

During the Phase I cleanup activities,  chemical testing in-
dicated the presence of 2,3,7,8 TCDD (dioxin) in the liquids
of one tank on the site.  Disposal of this liquid by incin-
eration has been approved by USEPA.  Final disposal has been
delayed and is not yet complete.  The liquid has been
removed from the tank and placed in overpacked (doubly
contained) drums and stored in trailers on the site.  The
disposal of this liquid is the responsibility of the PRP's
under the Partial Consent Decree Judgment.  Therefore,
disposal of the dioxin-contaminated liquid is not included
in the alternatives presented in this study.

While the Phase I cleanup was underway, the PRP's developed
and reviewed a Phase II cleanup plan and submitted it to
federal and state representatives on September 24, 1984.
Backup documentation was submitted on October 3, 1984.  This
plan is incorporated into this feasibility study and is in-
cluded among the alternatives presented in Chapter 6.  Ap-
pendix A presents the process used to develop this plan.
                           1-10

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Following submittal of the technical plan, the PRPs' con-
sultants began a field program to collect additional data
and to perform field testing for use in the final design of
certain elements of the PRP-sponsored cleanup alternative.

In late January, as requested by USEPA, the PRP's submitted
for inclusion in this Feasibility Study those sections
dealing with the PRP plan for subsurface remedial actions at
the Western Processing site.

               1.5 CONCURRENT WORK BY OTHERS

The information presented in this report has been based on
data gathered by CH2M HILL and many different agencies and
on technical analyses by CH2M HILL and specific analyses
conducted independently by the USEPA and others.

The data gathering activities are summarized in Chapter 3.
Additional details are available in the Western Processing
Remedial Investigation Data Report  (CH2M HILL, December 1984).
Analytical activities performed by others for USEPA and used
in this report are:

     o    Hydrogeologic Assessment of Western Processing,
          Kent, Washington.  Prepared for GCA Technology
          Division by Hart-Crowser and Associates
          (October 1984) .

     o    Application of Groundwater Modeling Technology for
          Evaluation of Remedial Action Alternatives, Western
          Processing Site, Kent, Washington.  Prepared for
          USEPA by Battelle Project Management Division,
          Office of Hazardous Waste Management (Bond et al.,
          September 1984).

     o    Groundwater Modeling for Evaluation of Remedial
          Action Alternatives, Western Processing Site, Kent,
          Washington.  By Battelle  (ongoing).

This report also contains the cleanup plan developed by the
Western Processing PRP group  (example alternative 4).  This
plan and its supporting information in Appendix A have been
developed and documented entirely by the PRP group.

Many other activities that have been conducted and  remain
ongoing at the Western Processing site do not relate directly
to this feasibility study and are not discussed in  this
report.

          1.6  OBJECTIVES OF THE REMEDIAL ACTION

As stated in Section 1.1, the overall objective of  every
remedial action undertaken under CERCLA is to "...  mitigate
and minimize damage to and provide  adequate protection of


                            1-11

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public health, welfare, or the environment..." as stated in
40 CFR 300.68(j).  For the Western Processing site, the
overall objective has been divided into two major elements:
surface cleanup and subsurface cleanup.

As discussed in Section 1.4, the surface cleanup activities
by the PRP contractor have removed many potentially hazardous
materials to appropriate disposal points.  The removal phase
of these activities was completed in November 1984 except
for the dioxin contaminated liquid.  Potentially contaminated
surface runoff water has been treated since surface cleanup
operations began and will continue to be treated until sub-
surface cleanup activities obviate this need.  Figure 1-4
shows an aerial view of the site after completion of the
surface removal activities.

For the Western Processing subsurface cleanup addressed in
this feasibility study, specific considerations were devel-
oped for soils, groundwater, and Mill Creek as follows:

     SOILS

     o    Isolate soil contaminants to prevent migration to
          Mill Creek

     o    Eliminate potential for ingestion, inhalation, and
          dermal contact with contaminated soils

     o    Reduce or eliminate infiltration of precipitation
          through contaminated soil column and to groundwater

     GROUNDWATER

     o    Protect City of Kent's and others' current or fu-
          ture groundwater supplies in the productive deep
          aquifer

     o    Reduce or eliminate the discharge of contaminated
          groundwater from Western Processing to Mill Creek

     o    Improve the quality of the local shallow ground-
          water system

     SURFACE WATER

     o    Protect Mill Creek and other receiving waters and
          associated aquatic communities from sources of
          contamination at Western Processing

     o    Protect Mill Creek and other receiving waters and
          associated aquatic communities from degradation
          resulting from desorption of contaminants in the
          sediments
                          1-12

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FIGURE 1-4
WESTERN PROCESSING SITE
DECEMBER 31, 1984

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The above considerations fall within the scope of remedial
actions under CERCLA.  Additionally, it is the policy of the
USEPA under CERCLA to accomplish remedial actions that comply
with "applicable or relevant" environmental and public health
standards unless one of the following circumstances exists:

     o    The selected alternative is not the final remedy
          and will become part of a more comprehensive remedy.

     o    All of the alternatives which meet applicable or
          relevant standards fall into one or more of the
          following categories:

               Fund-balancing—the alternatives do not meet
               the fund-balancing provisions of CERCLA Sec-
               tion 104(c)(4).

               Technical impracticability—all alternatives
               capable of attaining applicable or relevant
               standards are technically impracticable based
               upon the specific characteristics of the site.

               Unacceptable environmental impacts'—all al-
               ternatives that attain or exceed standards
               would cause unacceptable damage to the
               environment.

     o    The remedy is to be carried out under CERCLA Sec-
          tion 106; the Hazardous Response Trust Fund is
          unavailable; there is a strong public interest in
          expedited cleanup; and litigation probably would
          not result in the desired remedy.

Chapter 2 presents the various criteria that could be applied
to meet the objectives stated for the Western Processing
site.

The PRP plan  (Example Alternative 4) was developed based on
different objectives and considerations.  As stated earlier,
the process for developing this remedial alternative is pre-
sented in Appendix A.

                  1.7  REPORT ORGANIZATION

This report is organized into chapters that present sequen-
tially the analysis of the problems and potential remedial
actions at Western Processing.  Chapter 2 discusses the var-
ious criteria that could be used for remedial actions at
Western Processing.  Chapter 3 presents the results of the
studies defining the nature and extent of contamination.
Chapter 4 describes the methodology and results of the public
health endangerment assessment.  Chapter 5 develops and
screens the technologies available to deal with the problems
                           1-14

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at the site.  Chapter 6 describes in detail six example al-
ternatives and the PRP plan for remedial actions at Western
Processing.  Chapter 7 lists the references cited in the
report.

           1.8  FEASIBILITY STUDY ANALYSIS AREAS

Data gathering and analytical activities have been conducted
in various locations around the Western Processing site.
For the purpose of discussing the nature and extent of con-
tamination and example remedial alternatives, the site and
contiguous analysis areas have been organized into areas
numbered I to X as shown on Figure 1-5.  The numbered areas
are based on approximate property boundaries and were delin-
eated by those areas where contamination was known or sus-
pected.  Area I is the portion of the Western Processing
property where processing and storage activities took place.
Area VII is also part of the Western Processing site, but no
processing activities are known to have taken place on that
parcel.  All the other areas are off the Western Processing
site and are referred to in this report as "off-property."
Mill Creek was analyzed as a separate, unnumbered area.
                           1-15

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1-16
                    FIGURE 1-5
                    ANALYSIS AREAS

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                          Chapter 2
                ALTERNATIVE CLEANUP CRITERIA
                      2.1  INTRODUCTION

The purpose of this chapter is to identify a set of assess-
ment criteria which include existing standards, guidance,
policies and other information that may be applicable when
evaluating potential remedial action cleanup alternatives at
the Western Processing site.  These criteria are useful for:
(1) serving as the basis around which to define the nature
and extent of contamination (see Chapter 3), (2) establishing
a baseline for the public health and environmental endanger-
ment assessment  (see Chapter 4), (3) developing and evaluat-
ing the appropriate Western Processing site remedial action(s)
(see Chapters 5 and 6), (4) defining the level of cleanup
that is desired or may be required  (see Chapters 5 and 6),
and (5) identifying the general types of actions that may be
appropriate.  Not all of the criteria available are relevant
to evaluating levels of contamination at or near the Western
Processing site.  Those that are considered to be relevant
are presented in this chapter.  Their compilation is based
on a review of the chemicals identified in samples collected
during investigation of soil, groundwater, and surface waters
at and around the site.

Depending on the particular environmental medium assessed
(i.e., soil, groundwater, or surface water), the most appli-
cable set of criteria was selected  for example evaluation.
Generally, the assessment criteria  fall into two categories:
environmental criteria and public health and welfare criteria.
In some instances, these criteria are actual standards that
have been previously promulgated or adopted by federal, state,
or local agencies.  In other instances, the criteria reference
guidelines, policies, advisories, or other information obtained
through review of the literature.   It should be noted that
criteria derived from different technical fields for a par-
ticular chemical are seldom, if ever, numerically equivalent.
Two criteria for the same compound may differ by several
orders of magnitude depending on the intended purpose of the
criteria.  For example, the ambient water quality criterion
for protection of public health for pentachlorophenol is
calculated to be 1.01 mg/L; but the acute toxicity for fresh-
water aquatic species is as low as  0.055 mg/L.

     2.2  METHODS FOR DETERMINING ADEQUACY OF CLEANUP

Two different methods can be used to apply the criteria to
assist USEPA and WDOE in determining what cleanup levels
(1) meet CERCLA  compliance goals,  (2) meet the goals of the
USEPA's Groundwater Protection Strategy,  (3) meet RCRA com-
pliance objectives, and  (4) meet the intent of WDOE's Final
                            2-1

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Cleanup Policy as well as other state and local regulations.
These methods measure whether or not the degree of cleanup
appropriate at the Western Processing site has been
accomplished.  They are:

     o    Performance-based.  The objective of this method
          is to reduce adverse effects or contaminant con-
          centrations to, or below, specified levels.  A
          typical example in remedial groundwater actions
          would be to specify that groundwater be withdrawn
          and treated until a certain contaminant concen-
          tration is not exceeded in any of the designated
          compliance monitoring wells.  Compliance for a
          performance-based remedial action can only be con-
          firmed by frequent monitoring and analysis of the
          media for the contaminant(s) of concern.

     o    Technology-based.  This method uses a technological
          approach to reduce environmental concentrations.
          Technology-based cleanup actions often do not have
          specified allowable residual or compliance concen-
          trations for the contaminant(s) of concern.  An
          example of a technology-based remedial groundwater
          action would be to specify that specific wells be
          pumped at a specified rate for a specified period.
          The major tasks would be designing the remedial
          program components (i.e., well location, depth,
          pumping rates and durations, and effluent treatment
          and discharge), projecting system performance, and
          determining overall technical feasibility.  Com-
          pliance monitoring of the technology-based remedial
          action consists of construction and operation over-
          sight.  Technology-based remedial actions are often
          designed very conservatively to account for uncer-
          tainties in the performance prediction.

The application of performance- and technology-based remedial
actions, although different in method, have similarities:

     o    Both require that specific cleanup goals and cri-
          teria be selected (e.g., allowable contaminant
          concentrations such as drinking water standards).

     o    Both remedial actions must consider technical fea-
          sibility in defining specific responses.

Major differences include:

     o    Performance-based remedial actions use criteria as
          direct measures of compliance.  Predictions of
          cleanup activities are only used as estimates with
          the actual cleanup activities being determined by
          measurements of the parameters of interest at
                            2-2

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          specified "points of compliance" (similar to those
          specified in RCRA, 40 CFR Part 264.95)  and compar-
          ison of these measurements to relevant criteria.

     o    Technology-based remedial actions use criteria
          only as the basis for design of the remedial
          action.

2.2.1  PERFORMANCE-BASED REMEDIAL ACTION

The most direct approach in determining whether or not the
specified cleanup level has been reached is to observe the
impacts on human health and the environment around the site.
This is a performance-based measurement of the attainment of
the objective.  This is not, however, an appropriate method
for measurement since failure of a remedial action would be
detected only by observing negative health or environmental
effects—the very outcome the remedial action is intended to
prevent.  For example, some health effects, such as cancer,
are known to have long latency periods, increasing the time
period between cause and effect.

Another performance-based approach for measuring the adequacy
of a site remedial action is the measurement of chemical
concentrations in the potential receptors.  These receptors
could be people who work or live near the site or organisms
such as bacterial species that might serve as early indi-
cators.  Although chemical concentrations in the receptors
would provide an earlier measure of the effectiveness of
site remediation compared to observing direct health effects,
it is also undesirable for the following reasons:

     (1)  It requires identification and continuous monitor-
          ing of all pathways.

     (2)  It does not take into account the lack of scien-
          tific knowledge about chemical concentrations in
          organisms and the associated consequences.

     (3)  It does not take into account the potential for
          exposure to the same chemical from sources other
          than the hazardous waste site.

     (4)  It measures what one is trying to prevent—exposure
          to site contamination.

A third performance-based approach is the measurement of
chemical concentrations in the environmental medium at the
point of direct contact with the human, animal, or plant
receptors.  For example, a drinking water production well
could be monitored for contaminants and action could be taken
if contamination were discovered.  Action levels could be
                            2-3

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derived as discussed in Section 2.3.  Although this approach
has the desirable feature of providing the means to prevent
human exposure, its negative aspect is that a large region
of the environment may become contaminated prior to detection
at the point of measurement.

The most commonly used performance-based approach is to
specify maximum allowable contaminant concentrations for the
environmental media at or near the source of the contami-
nants.  For example, it could be required that the ground-
water at the site be pumped until the concentration of the
contaminants has reached the specified allowable upper limit.
Options for these site-specific criteria (which are discussed
in detail later in this chapter) are listed below.

Background concentrations, or the concentrations of certain
compounds that would have been present in the area if the
hazardous substances had not been released.  This approach
is intuitively appealing for describing the distribution of
contaminated soil.  For inorganics  (metals), local background
concentrations are generally available.  For organics, back-
ground concentrations may be more difficult to assess because
of other chemical uses not related to the site (such as agri-
cultural use of pesticides).  Other organic chemicals have
become ubiquitous in the environment due to widespread use.
For these, it will also be difficult to determine "true"
background levels.

An important concern with using background levels as the
principal cleanup criterion is that background may be depen-
dent  totally on existing analytical detection limits for
each  contaminant.  For example, a particular contaminant
that  has a laboratory detection limit of one mg/kg may have
its respective background limit set equal to or below the
detection limit  (i.e., not detectable).  Through more so-
phisticated analytical procedures or the use of higher reso-
lution equipment, the detection limits could possibly be
reduced to one pg/kg for some contaminants.  In a case like
Western Processing, the level of specified cleanup would be
solely dependent on what procedure and what instrument were
used  to analyze the sample.

An additional concern with using cleanup to background is
that  for many contaminants, the background level may be below
that  necessary to protect the public health and environment.
Also, for some compounds the safe exposure level may be below
that  analytically detectable using the best existing tech-
nologies.  In this case, cleanup to background may not ade-
quately protect human health and the environment.

Site-specific concentrations that will prevent negative
human health or environmental impacts.  This approach is
often used because of its consistency with the objectives of
                            2-4

-------
site remedial actions.  A scientific approach to their estab-
lishment, however, requires an understanding of the fate and
transport of chemicals in the environment and the potential
interactions of the human, animal, and plant receptors with
the environment.  The major concerns with this approach
include some uncertainty in the overall extent of contam-
ination and the ability to predict chemical fate and trans-
port of site contaminants.  Implementation of this approach
requires that regulatory agencies carefully consider the
effects of uncertainty on the choice of the concentration
criteria.

Existing environmental standards or criteria.  This approach
uses federal, state, or local criteria developed independent
of knowledge of a specific waste site.  For example, national
drinking water standards could be applied to cleanup of an
aquifer used as a potable water source.  This approach does
not require the potentially complex analysis of the site-
specific criteria, and ignores site and regional use charac-
teristics.

If drinking water standards are used, the major question
that must be considered is "where is the point of compliance?"
Drinking water standards apply at the point of use.  Hence,
if the point of compliance was established on or near the
site and the nearest use of the aquifer is some distance
away, an additional factor for downgradient contaminant
dilution and dispersion could be applied.  A further lim-
itation in the drinking water standards is that, at present,
only a limited number of compounds and elements have estab-
lished concentration limits.

Particularly for groundwater and surface waters, an acceptable
regional or ambient concentration limit should be established.
Standards or criteria such as Ambient Water Quality Criteria
for Protection of Human Health (USEPA, July 1976) might be
more appropriate for this approach.

All three options for establishing remedial action concen-
tration limits result in some uncertainty in predicting the
remedial action costs and performance.  For example, the
duration of pumping required to obtain a specified ground-
water contaminant concentration is difficult to predict due
to the uncertainty in contaminant transport in and removal
from groundwater systems.  Further, the technology for
achieving the cleanup criteria may not be presently avail-
able, proven viable, or cost effective.

2.2.2  TECHNOLOGY-BASED REMEDIAL ACTION

In the technology-based approach, the remedial action is a
specified technology or group of technologies that have been
determined will achieve a specified level of cleanup.
                             2-5

-------
Examples of a technology-based cleanup include removal of
soil to a specified depth, or groundwater withdrawal and
treatment from a specified network of wells for a specified
period of time.  In implementing a technology-based cleanup/
each component of the remedial action is selected on the
basis of its predicted performance to satisfy the objectives
of the overall remedial activity, which may be defined by
the same performance criteria described in Section 2.2.1.

The advantages of technology-based remedial actions are the
knowledge that very specific actions are taken and the ac-
complishment of these actions is measurable (e.g., the depth
of excavation can be measured).  It is also possible to es-
timate the remedial action costs more accurately than for
the performance-based approaches.  The technology-based re-
medial action is selected based on the anticipated perform-
ance of the particular technology.  This approach can also
be used when health and environmental impacts cannot be di-
rectly measured or estimated.

The disadvantage of the technology-based approach is that
the technology  (e.g., excavation depth) may be selected with
incomplete knowledge of the technology's effectiveness with
respect to the specific site conditions.  Therefore, it is
possible that the technology-based remedial action may not
achieve completely the objective of protecting public health
and the environment.

2.2.3  SUMMARY OF METHODOLOGIES

The Feasibility Study process is intended to define and
evaluate alternatives that could be implemented to achieve
the desired level of cleanup using either performance- or
technology-based remedial methods.  The Feasibility Study
examines in some detail the performance of the remedial
alternatives under varying cleanup levels.

Whether a performance- or technology-based remedial action
is selected, final design is beyond the scope of the Feasi-
bility Study.  If the performance-based cleanup is chosen,
additional investigation will be required to appropriately
define ranges of specific technologies which are likely to
work, to define specific compliance criteria, to define the
points of compliance where the cleanup levels can be moni-
tored, and to define additional monitoring system require-
ments.  Similarly, if a technology-based cleanup is selected,
additional detail will be required to define target cleanup
criteria for technology selection, to modify cleanup tech-
nologies based on predictable results, to analyze (e.g., by
computer simulation) the effectiveness of the alternative,
and to define specific details for implementing the remedial
action.
                            2-6

-------
In this Feasibility Study, sample criteria are selected in
order to examine some example remedial actions that might
be employed at the Western Processing site (see Chapters 5
and 6) .

                  2.3  CRITERIA EVALUATION

Numerous federal, state and local exposure criteria have
been developed for the protection of the environment  (aquatic
and terrestrial life) and for the protection of public health
and welfare.  Criteria for a single compound or element are
often quite different with respect to allowable concentra-
tions or exposure depending on whether they are intended to
protect aquatic and terrestrial life or human health.  Listed
in Table 2-1 are the priority pollutants (as defined by the
Clean Water Act, PL 95-217) as well as other pollutants
identified in samples collected at the Western Processing
site.  Also tabulated (when available) are water, soil, and
air exposure criteria.  These criteria may be used to evalu-
ate various remedial action alternatives for cleanup or con-
tainment of priority pollutants at or adjacent to the Western
Processing site.  Presented in Tables 2-1A and 2-1B are ex-
planations of the abbreviations used in Table 2-1 and the
references from which criteria were obtained.

For numerical criteria to be used effectively in correcting
a problem, they must be appropriate to the nature of the
problem.  That is, they must apply to the likely routes by
which organisms or humans may be exposed to the pollutants.
As will be discussed in Chapter 3, the main source of expo-
sure to aquatic and terrestrial life is from contaminated
groundwater that migrates from the site into Mill Creek and
then flows downstream away from the site.  The most likely
routes of exposure for humans are through ingestion of soil,
inhalation of dust or fugitive emissions, and consumption of
contaminated groundwater.  At present, ingestion of soil and
inhalation of dust or fugitives would primarily occur during
construction remedial actions.  Consumption or exposure to
contaminated groundwater would not be likely.

2.3.1  ENVIRONMENTAL STANDARDS AND CRITERIA

Environmental standards apply primarily to aquatic and ter-
restrial life although they can also be interpreted in as-
sessing impacts to human health.  Both types of criteria
(environmental and human health) are relevant when evaluating
risks to humans at sites where contaminants occur in surface
water and sediment.  Human health criteria are appropriate
where soil and groundwater are contaminated.  The criteria
that are appropriate for evaluating risks to aquatic life
are ambient water quality criteria for protection of aquatic
life  (see Table 2-1).  In some cases where groundwater dis-
charges quickly to surface water, aquatic water quality
                            2-7

-------
                                                                                            Table  2-1
                                                                         SUMMARY  OF  NUMERICAL  CRITERIA
               Coapound
Hater Quality Criteria




Freshwater
Aquatic
Life
Health
Advisory (Bg/1)
Cancer Potency
(Bg/kg/day)
and Allowable
Dally Intake
(Bg/day)



HDSHS Standards
and HDSHS-EPA
Criteria Under
Consideration
                                                                                                                                                     Air Quality Criteria
                                                                                                                                                OSHA/HISHA
                                                                                                                                                                         Other
                                                                                                          Soil/
                                                                                                       Groundwater
                                                                                                        Background
                                                                                                          Levels
        1.  Inorganics
        (Metals and Cyanide
fO
 I
CO
        AntlBony
        Arsenic
                                                AT    9,000
                                                CT    1,600 Mg/Lll)
                                                N      440 ug/LU)
   146 Vg/l (MAO)
   45 mq/L (AOH1)
 CR3-14.6  (jg/L  (13)
  ADI .19  ag/d  (15)

   CR1 2.2 ng/L(l)
  CR2 17.5 ng/L(l)
  CR3 2.5  ng/L  (13)
                                                                                                                   STD .05 ag/L(6)
                           T-0.5 ug/m (8)
                           T-0.5 mq/m (8)
                           (organic CBod)
                             T-10 ug/a
                           (inorganic)(8)
        Beryl HUB
                                                AT     130 U9/L(1)

                                                CT     5.3 Wg/L(l)
   CR1 6.8 ng/LU)
   CR2 117 ng/L(l)
  CR3 3.9 ng/L  (13)
ADI 0.038 Bg/d   (15)
                               5 Ug/B3
                               /• -30 Bin)
   C-5
(25 Pg/B~-30 Bin)
  T-2 pg/B  (8)
        .01 pg/B
(avg. over 30 days) (16)
        CadBluB
                                                     H  (1)

                                             (1.05(ln(hardness)]-3.73)


                                                      A  (1)

                                             (1.05[ln(hardness)J-8.53)
     10 Ug/L  (1)
 ADI 0.17 Bg/d  (15)

  CM 1.2 ug/L  (13)
STD 0.01 Bg/L (6)
                         fu*e:
                             C-0.3 Bg/B

                             T-0.1 ag/B3
                         dust:
                             C-0.6 Bg/a
                           T-0.2 Bg/B  (8)
                                              S=2.9 ag/kg


                                              GU<6.8 pg/L
        Note:  A key to the criteria abbreviations Is given in Table 2-1A.
               References  (1) to (17) are listed  in Table 2-1B.
         Soll/Groundwater background levels:  S  indicates a soil background and GH a groundwater background.
        b
         Calculated as suggested by public contents  for comparison purposes only.  These cheBlcals are considered carcinogens by the oral route (per Reference 14).
        CThese values represent AHQC Errata.  Note that soae of these values have not yet been published.  Please contact  Prank GostOBSki at FTS 245-3042 with the Offlc* of Hater Regulations and
         Standards in Washington, D.C.. (per Reference  14).
         Freshwater aquatic life criteria froa Reference 7 are proposed criteria that have not been  tonally adopted by EPA.

-------
                                                                               Table  2-1   (cont.)
Lead
Mercury
Nickel
                                                                 Hater Quality Criteria





Coapound
ChroBltm
Trlvalent



Hexavalent


Copper


Cyanide




Freshwater
Aquatic
Life

M (1)

(1.08 [In (hardness)] +3. 48)

M 21 pg/L (1)
A 0.29 Mg/L (1)

A 5.6 Mg/L (1)
M (1)
(0.94 (In (hardness) ) -1.23)
A 3.5 M9/L (1)
M 52 Mg/L (1)
Health
Advisory (ng/1)
Cancer Potency
(mg/kg/day)
and Allowable
Dally Intake
Ing/day)

170 Bg/L (H&AO)
3,433 ng/L (AO)U)
ADI 125 mg/dC (15)
170 mg/L (DHO) (13)
50 Mg/L (1)
ADI 0.175 Bg/d (15)

1.0 ng/L-
organoleptlc (1)

200 pg/L (1)
DHS


HDSHS Standards Soil/
and HDSHS-EPA Groundwater
Criteria Under Air Quality Criteria Background
Consideration OSHA/HISHA Other Levels

T-0.5 Bg/B (8) S=40 Bg/kg
(sol. chroa., GH=24 Mg/L
chroBous salts
as Cr.)
STD 0.05 Bg/L (6) T-l Bg/B3 (8)
(aetal & insol.
salts)
STD 1 Bg/L (6) S=73 Bg/kg
GH=129 pg/L

CDC 200 pg/L(7) T-S Bg/B3 skin (8)

                                              A (1)
                                     (2.35[In(hardness)]-9.48)

                                              M (1)
                                     (1.22[ln(hardness)]-0.47)
A    0.2 Mg/L (1)
M    4.1 Ug/L (1)
                                              M (1)

                                      (0.76[In(hardness)]+4.02)
                                    e

                                              A (1)

                                     (0.76|In(hardness)]+1.06)
                                   ADI 7.6 mg/d  (15)

                                50 Ug/L DHS (1)
                               STD 0.05 mg/L (6)
T-0.05 «g/»   (8)
  1.5 ug/B
 (National
 Ambient  Air
   Quality
 Standard(4)
     and
   PSAPCA
Section 11.05)
   144 ng/L  (H&AO)
  146 ng/L  (AO) (1)
 ADI 0.020 ag/d (15)
 10 Mg/L  (DHO) (13)

  13.4 Ug/L  (H&AO)
   100 Mg/L (AO)

 ADI 1.5 Bg/dC (15)
15.4 Mg/L (DHO) (13)
                                                                             100 Ug/L  (AO) (1)
                                                                                                         STD 0.002 mg/L (6)
                                                                                                            T-l Bg/B  (8)
 C-l Bg/lUB  (8)
                                                                                                                                         S=76 Bg/kg
                                                                                                                                         GH=99
                                                                                                                                         S=43 Bg/kg
                                                                                                                                         GH=<40 pg/L

-------
                                                                                   Table   2-1   (cont.)
                                                                      Hater Quality Criteria





Compound
Selenium
as Selenlte

as Selenate
Silver




Freshwater
Aquatic
Life

A 35 pg/L (1)
M 260 pg/L (1)
AT 760 pg/L (1)
M
fl tt MnfH»r«4nAea\l-C C1I
Health
Advisory (mg/l}
Cancer Potency
(ng/kg/day)
and Allowable
Dally Intake
(•g/day)
lOpg/L DHS(l)
ADI 0.1 mg/t (IS)


ADI 0.1 rnq/0 (15)
50 pg/L DNS (1)


HDSHS Standards
and NDSHS-EPA
Criteria Under Air Duality Criteria
Consideration OSHA/HISKA Other
STD: 0.01 >g/L (6) T-0.2 *J/»3 (8)



STD: 0.05 Bg/L (6) T-0.01 mg/m* (8)



Soil/
Groundvater
Background
Levels






NJ
 I
Thailiu«



Zinc




II.  Base/Neutrals

Acenaphthene


Acenapthylene

Anthracene

Benzldlne



Benzo(a)anthracene

Benzolalpyrene

Benzo(b)fluoranthene

Benzo(ghl)perylene
                                            AT - 1400 pg/L (1)
                                            CT - 40 pg/L  (1)
                                             A    47 pg/L (1)
                                                  M  (1)

                                         (0.83[In(hardness)]+1.95)
                                           AT   1,700 pg/L (1)
                                           CT     520 pg/L (1)
                                          AT    2,500 pg/L (1)
    13 pg/L (H&AO)  (1)
     48 pg/L (A0>  (1)
   17.8 pg/L (DNO)  (13)

          5 «g/L-
     organoleptlc  (1)
20 gg/L-
organoleptlc  (1)
     CR1  0.12 ng/L (1)
     CR2  0.53 ng/L (1)
    CR3 0.15 ng/L (13)

          See PAH (1)

          P 11.5 (14)

          See PAH (1)

          See PAH (1)
STD: 5.0 mg/L (6)
CDC 20 pg/L (7)
                                                                                                               CDC  1.67 ng/L (7)
                          0.1 mg/m  (skin)
                            (soluble
                             pound)  (8)
                                                                       S-=109 vg/kg
                                                                       GH>227 pg/L

-------
                                                                                   Table  2-1   (cont.)
           Compound
     Benzo(k)fluoranthene

     Benzyl butyl phthalate
    See Phthalato
        Esters
                                                                      Hater Quality Criteria




Freshwater
Aquatic
Life
Health
Advisory lag/It
Cancer Potency
(•g/kg/day)
and Allowable
Dally Intake
(•g/day)



HDSHS Standards
and HDSHS-EPA
Criteria Dnder
Consideration
                                                                                       See PAH  (1)
                                                                                                                                                    Air Quality  Criteria
                                                                                                                                              OSHA/NISHA
                                                                                                                                                                       Other
                                                                                                                                                  Soil/
                                                                                                                                               Groundwater
                                                                                                                                               Background
                                                                                                                                                  Levels
     Bis  (2-chloro ethyl) ether
    See Chloroalkyl
        Ethers
  CR1 0.03  pg/L  (1)
  CR2 1.36  pg/L  (1)
 CR3 0.03 pg/L (13)
     P 1.14 (14)
                                                                                                                 CDC 0.42 pg/L  (7)
ho
 I
    Bis  (2-chlorolsopropyl) ether
    See Chloroalkyl
        Ethers
34.7 pg/L (N&AO)  (1)
 4.36 »g/L (AO)  II)
    ADI-0.07 (15)
                                                                                                                   CUC 11.5 pg/L
    Bls(2-ethyl hpxyll
      phthalate
    Bls(2-chloroethyl)
      ether
    Chloroalkyl Ethers

    Chlorinated benzenes

    Chlorobenzene
     See Phthalate
        Esters
AT    238,000 pg/L (1)
   (for Chloroalkyl
      ether)  (1)

AT    238,000 pg/L (1)

 AT      250  pg/L (1)

    See Chlorinated
     Benzenes (1)
  A    1,500  pg/L (7)
  H    3,500  pg/L (7)
   15 Kg/I (HSAO)
    50 ag/L (AO)
  ADI 42  ig/d  (15)

  CR1 0.03 Pg/L (1)
  CR2 1.36 Pg/L (1)
                                                                              See Individual compounds
       20 pg/L
  organoleptic (1)
   toxlclty data-
    488 pg/L (1)
  ADI 1.0 «g/d (15)
 CDC 10 »g/L (7)
CUC 0.42 pg/L (7)
 CUC 20 pg/L (7)
T-350 ag/m
(75 ppn)  (8)
    ChrysPne
       (1,2-flenzphenanthrene)

    Dlchlorobenzen^c
       (all isofcers)
 AT    1,120 pg/L (1)
 CT      763 Pg/L (1)
                                                                                      See PAH (1)
   400 pg/L (H&AO)
  2.6 mg/L (AO)  (1)
 470 pg/L (HK»  (13)
CDC 400 pg/1  (7)
  (all Isomers
    combined)

-------
                                                                       Table  2-1   (cont.)
                                                        Hater Quality Criteria
Compound
1,2-Dichlorobenzene




1,3-Dichlorobenzene




1,4-Dlchlorobenzene




Dlethyl phthalate



Dimethyl phthalate



2,4-Dlnltrotoluene



DI-N-Butylphthalate




Dl-N-Octylphthalate

Fluoranthene (PAH)
Freshwater
Aquatic
Life
See Dlchloro-
benezene (I)
A 44 pq/L (7)
« 99 pq/L (7)
See Dlchloro-
benezene (1, 13)
A 310 pq/L (7)
M 700 pq/L (7)
See Dlchloro-
benezene (1)
A 190 pq/L (7)
H 440 pq/L (7)
See Phthalate
Esters (1)
See Phthalate
Esters (1)
AT 330 pg/L (1)
CT 230 pq/L (1)
See Phthalate Esters (1)
Health
Advisory (•g/1)
Cancer Potency
(•q/kq/day) HDSHS Standards Soil/
and Allowable and HDSHS-EPA Groundwater
Dally Intake Criteria Under Air Quality Criteria Backqround
(•q/day) Consideration OSHA/NISHA Other Levels
See Dlchloro- CDC See Dlchloro- 0-Dlchlorobenzene: C-3OO mq/m (4)
benezene (1, 13) benezene (7) C-300 mq/m
(50 ppm) (8)
See Dichloro- CDC See Dlchloro-
benezene (1, 13) benezene (7)
See Dlchloro- CDC See Dlchloro- p-Dichcloro-
benezene (1, 13) benezene (7) benezene:
ADI 0.94 mq/d (15) T-450 mq/m
(75 ppa) (8)
350 >q/L (NUO) (1) CDC 350 «g/L (7)
1.8 q/L (AO) (1)
ADI 880 *q/d
313 inq/L (WAO) CUC 313 «q/l (7) T-5«g/«3 (8)
350 «g/L (DHO) (13)
ADI 700 (15)
Oil 0.11 pq/L (1) 1.5 «q/«3
CR2 9.1 yq/L (1) skin (8)
CR3 0.11 (iq/L (13)
34 mg/L (WSAO) (1) CDC 34 «g/L (7)
154 mq/l (AO) (1)
ADI 88 mg/A (15)
44 mg/L (DUO) (13)
                             See Phthalate Esters (1)

                               AT    3,980 pq/L (1)
                                A     250 pq/L (7)
                                M     560 pq/L (7)
                                                                            42 pq/L  (HCAO)
                                                                           54 pq/L (AO) (1)
                                                                          ADI 0.42 aq/d (15)
                                                                          188 pg/L (DHO)  (13)
CDC 200 pq/L  (7)

-------
                                                                                     Table  2-1   (cont.)
                                                                      Hater Quality Criteria





Compound
Fluorene (PAH)
Hexachloro benzene



Hexachloro cyclopentadlene






Freshwater
Aquatic
Life

See Chlorinated
benzenes


A? 7.0 liq/L (1)
CT 5.2 pg/L (1)
A 0.39 pg/L (7)
M 70 pg/L (7)
Health
Advisory (*g/D
Cancer Potency
(•g/kg/day) NDSHS Standards
and Allowable and NDSHS-EFA
Daily Intake Criteria Under Air Quality Criteria
lag/day) Consideration OSHA/HISHA Other
See PAH
CM 0.72 ng/L (1)
CR2 21.0 ng/L (13)
CR3 0.74 ng/L (1)
P 1.67 (14)
206 pg/L (1) CUC 1.0 pg/L (7)
1.0 pg/L (organoleptlc) (1)
ADI 0.42 (IS)



Soil/
Groundwater
Background
Levels









 I     Indeno
I—1    (l,2,3-C,D)pyrene
CO
      Tsophorone
     Naphthalene


     Nltrosanlnes

     Nitrobenzene
AT  117,000 pg/L (1)
 A    2,100 pg/L (7)
 H    4,700 pg/L (7)
AT    2,300 pg/L (1)
CT      620 pg/L (1)

AT     5,850 pg/L (1)

AT   27,000 pg/L (1)
                                                                                        See PAH  (1)
 5.2 >g/L (H&AO)  (1)
  520 mg/L (AO)  (1)
  ADI 11 mg/i  (15)
HA 0.35 (10-day)  (13)

      See PAH  (1)
                                                                                     19.8 Bg/L (1)
                                                                               30pg/L (organoleptic)  (1)
                                                                                      ADI 40 (15)
CDC 460 pg/L (7)
                                                                                                                 CUC 143 pg/L (7)
 T-140 mg/m
(25 ppa)  (8)
 T-55 mg/m
(10 pp«)  (17)
                                                           T-50 mg/m  (8)
                                                              T-5 mg/m
                                                          (1 ppm) skin  (8)
     N-nltrosodinethy-
       anlne
     N-nltrosodlphenyl-
       anlne
     PAH  (Polynuclear Aromatic
       Hydrocarbons)
  See Nltrosanlnes
         (1)
  See Nltrosanlnes
         (1)
   See Individual
      coopounds
  CR1 1.4 ng/L (1)
 CR2 16,000 ng/L (1)
  CR3 1.4 ng/L (13)

 CR1 4,900 ng/L (1)
 CR2 16,100 ng/L (1)
  CR3 7.0 pg/L (13)

    CR1 2.8 ng/L
    CR2 31.1 ng/L
  CR3 2.6 ng/L (13)
                                                                                                                  CUC 26 ng/L (7)
                                                                                                                     N.C.  (7)
                                                                                                                                           CDC 9.7 ng/L (7)

-------
                                                                                    Table  2-1   (cont.)
                                                                       Hater Quality Criteria





Compound
Phenantbrene
Phthalate esters




Freshwater
Aquatic
Life

AT 940 pg/L (1)
CT 3.0 pg/L (1)
Health
Advisory <«j/l)
Cancer Potency
(•g/kg/day)
and Allowable
Dally Intake
( eg/day)
See PAH (1)
See individual
compounds


NDSHS Standards
and HDSHS-EPA
Criteria Under Mr Quality Criteria
Consideration OSHA/HISHA Other





Soil/
Groundvater
Background
Levels"



      Pyrene

      2,3,7,8-TCDO (dloxln)
                                                                                      See PAH (1)
                                                                                      OU C CR3
                                                                                  0.000013 ng/L (13)
                                                                                  ADI 70 pg/djy  (15)
                                                                                  P 1.56 x 10  (14)
                                                                 CUC 4.55 x  lo"7 \jg/L (7)
NJ
 I
      III.   Acid Extractables
      2-Chlorophenol
      2,4-Dlchlorophenol
      2,4-Dlwthylpnenol
      2,4-Dinltrophenol
      (criteria for Dlnitrophenol)
      Nltrophenols

      2-Nltrophenol
AT    4,380 pg/L (1)
 A      60 pg/L (7)
 H     160 pg/L (7)
                                             AT
                                             CT
AT
 A
 H
      2,020 pg/L (1)
        365 pg/L (1)
2,120 pg/L (1)
 38 pg/L (7)
 86 pg/L (7)
See Nltrophenols  (1)

  A    79 pg/L (7)
  H    180 pg/L (7)

   AT-230 pg/L (1)

 See Nltrophenols  (l)
 A      2.7 ng/L  (7)
 M      6.2 ng/L  (7)
                                    0.1  pg/L-
                                organcleptlc  (1)
  3.09 »g/L (1)
    0.3 pg/L-
organoleptlc (1)
ADI 7.0 ng/d (15)

    400 pg/L-
organoleptic (1)
                               70 pg/L (H&AO)  (1)
                               14.3 >g/L  (AO)  (1)
                               70 pg/L (DHO)  (13)
                                  ADI  0.14  (15)
                                                              CUC 3.0 pg/L  (7)
                              CUC 68.6 pg/L (7)
      4-Nitrophenol
 See Nltrophenola  (1)
 A      240 pg/L (7)
 M      550 pg/L (7)

-------
                                                                                   Table  2-1   (cont.)
              Compound
KJ
 I
       Pentachlorophenol
       Phenol
       2,4,6-Trlchlorophenol
       IV.   Volatlles

       Acrylonltrlle
       (vinyl  cyanide)
       Benzene
Hater Quality Criteria







AT
CT


AT
CT
A
M
CT
A
H

AT
A
H
AT
A
M




Freshwater
Aquatic
Life
55 pg/L (1)
3.2 pg/L (1)


10,200 pg/L (1)
2,560 yg/L (1)
600 pg/L (7)
3,400 pg/L (7)
970 pg/L (1)
52 pg/L (7)
150 pg/L (7)

7,550 pg/L (1)
130 pg/L (7)
300 pg/L (7)
5,300 pg/L (1)
3,100 pg/L (7)
7,000 pg/L (7)
Health
Advisory («g/l)
Cancer Potency
(•g/kg/day)
and Allowable
Dally Intake
(•g/day)
1.01 mg/L (1)
30 pg/L-
organoleptlc (1)
ADI 2.1 ng/d (15)
3.5 ng/L (1)
0.3 mg/L
organoleptlc (1)
ADI 7.0 ng/d (15)
CR1 1.2 pg/L
CR2 3.6 pg/L (1)
CR3 1.8 pg/L (13)
P 1.99 x 10" (14)
CR1 0.058 pg/L (1)
CR2 0.65 pg/L (1)
CR3 0.063 pg/L (13)
0-RHCL (3)
CR1 0.66 pg/L
CR2 40 pg/L (1)



HDSHS Standards
and HDSHS-EPA
Criteria Under
Consideration
CUC 1,010 pg/L (7)



CUC 1.0 pg/L (7)



CUC 12 pg/L (7)



CUC 0.58 pg/L (7)


CDC 6.6 pg/L (7)


                                                                                  CR3 0.67 pg/L  (13)
                                                                                   HA 0.23 (10 day)
                                                                                  0.07 (chronic)  (13)
                                                                                                                                                  Air Quality Criteria
                           OSHA/HISHA

                            0.5 «g/«3
                            skin  (8)
                                                                                                                                              19 »g/»
                                                                                                                                              skin (8)
                                                                                                                                               (5 pp.)
                                                                                                                                                                     Other
                                                                         Soil/
                                                                      Groundwater
                                                                      Background
                                                                         Levels
                          T-2 ppa (10 pp»
                          for 15 Bin) (8)
                          C-25 pp« (8)
                         50 ppn-10 Bin (8)
                          T-10 ppm (8)
                          (32 mg/» ) (8)
       Broniod ichloromethane
                                              See Halomethane  (1)
                                                                                See Halonethane  (1, 13)
                                                                                 ADI 0.039 ng/dC  (15)
CUC 2 pg/L (7)

-------
                                                                                    Table  2-1   (cont.)
                                                                       Water Quality Criteria
            Compound
     BronoMthane
     Carbon Tetrachlorlde
                                                 Freshwater
                                                   Aquatic
                                                   Life
See HaloMthane (1)
 A   140 pg/L (7)
 H   320 pg/L (7)

 AT  35,200 pg/L (1)
  A  620 |lq/L (7)
  M  1,400 pg/L (7)
       Health
    Advisory (mg/1)
    Cancer Potency
     (•g/kg/day)
    and Allovable
    Dally Intake
      (•g/day)	

   See Ha lone thane (1)
    ADI 1.5 mg/a (15)
                                                                                    CK1 0.4 pg/L (1)
                                                                                    O)2 6.94 Ug/L (1)
                                                                                   CR3 0.42 Pi/I  (13)
                                                                                       P 0.13 (14)
                                                                                     HA 0.2 (1 day)
                                                                                   0.02 (10 day)  (13)
 HDSHS Standards
   and NDSHS-EFA
 Criteria Under
  Consideration

CDC 2 pg/L (7)
                                  CDC 4.0 pg/L (7)
                                                                                                        Air Quality Criteria
                                                                                                                                                OSHA/HISHA
                                                                  T-lOppi
                                                          (200 ppm for 5 Bin)  (8)
                                                                                                                                                                          Other
   Soil/
Groundvater
Background
   Levels"
KJ
 I
     ChlorodlbronoBethane

     Chloroethane

     Chloroform
      Chloromethane
     Dlchlorodlf luoroaethane
     1,1-Dlchloroetnane
     1,2-Dlchloroethane
                                              See HaloKthane  (1)
                                             AT   28,900 pg/L  (1)
                                             CT    1,240 Jlg/L  (1)
                                              A      500 (ig/L  (7)
                                              H    1,200 pg/L  (7)
                                              See HaloMthane  (1)
                                              See Halonethane  (1)
                                                  N.C.  (7)
                                             AT   118,000 Ug/L  (1)
                                             CT    20,000 pg/L  (1)
                                              A    3,900 pg/L  (7)
                                              H    8,800 pg/L  (7)
   See Haloaethane (1)
   0.1 mg/L - NCL (4)
  (for Trlhaloaethane,
    a combination of
     chlorofon plus
    4 trlhalogenated
                                                                                 P 7 x
                                                                                        •ethanes)
                                                                                       10"  (14)
                                                                               See Haloaethane (1,13)
                                                                               ADI 38 >g/dC (15)
                                                                                 See Haloaethane  (1,  13)
                                                                                      ADI 24° (15)
      0 - RMCL (3)
   CR1 0.94 pg/L (1)
    CP2 243 pg/L (1)
      CR3 0.94 (13)
P 6.9 x 10~  (14)
CDC 1.9 Ug/L (7)
CDC 2.0 pg/L (7)


CDC 3.0 ag/L (7)


     N.C. (7)


CDC 9.4 pg/L (7)
                                                                                                  C-240 mq/m
                                                                                                 (50 ppm}  (8)
                                                            T-4,950 mg/m
                                                            (1,000 ppa)  (8)
                                                                                                  T-400
                                                                                                 (100 ppa)  (8)

                                                                                                   C-100 ppa
                                                                                                 200 ppa for
                                                                                                   5 Bin (8)
                                                                                                 T-50 ppm (8)

-------
                                                                                     Table  2-1   (cont.)
            Coapound
     1,1-Dlchloroethenc
     (-ethylenc)
                                                Freshwater
                                                  Aquatic
                                                  Life
        530 (iq/L (7)
      1,200 pg/L (7)
                                                                       Hater Quality Criteria
                                     Health
                                  Advisory  lag/l)
                                  Cancer  Potency
                                   (•g/kg/day)
                                  and Allowable
                                  Dally Intake
                                    lag/day)	

                                     0-RHCL  (3)
                                 CR1  0.033 pg/L  (1)
                                  Cta 1.85 pg/L  (1)
                                 CR3  0.033 pg/L  (13)
                                   HA 1.0 (1 day)
                                   0.07  (chronic)
                                                                       HDSHS Standards
                                                                         and NDSHS-EPA
                                                                       Criteria Under
                                                                        Consideration
                                                                       Air Quality Criteria
                                                                                                                                                OSHA/HISHA
                                                                                                                                             CDC 1.3  pg/L (7)
                                                                                                                                                                         Other
                                                 Soil/
                                              Groundwater
                                              Background
                                                 Levels
     Dlchloroethylenes

     Ethylbenzene
NJ
 I
 AT  11,600 llg/L (1)

 AT  32,000 pg/L (1)
                              See Individual compounds

                                   1.4  ag/L (N&AO)
                                 3.28 mq/L  (AO)  (1)
                                  ADI 1.6 «g/d  (15)
                                   CUC  1.1 «g/L  (7)
T   435 ug/m
(100 pp») (8)
     Haloaethane
                                             AT  11,000 pg/L (1)
                                        CR1  0.19 pg/L  (1)
                                        CR2  15.7 (jg/L  (1)
                                       CR3 0.19 pg/L (13)
     Hexachlorobutadlene
                                              AT    90 pg/L (1)
                                              CT   9.3 pg/L (1)
                                        CR1  0.45 g/L  (1)
                                         CR2 50 pg/L  (1)
                                       CR3 0.447 (jg/L (13)
                                                                CUC 0.77 pg/L (7)
    Hexachloroethane
                                             AT    980 pg/L (1)
                                             CT     540 pg/L (1)
                                              A     62 pg/L (7)
                                              H    140 pg/L (7)
                                        CR1  1.9 pg/L  (1)
                                       CR2 8.74  pg/L (1)
                                       CR3 2.4_ pg/L  (13)
                                   P 1.42 x  icf   (14)
                                                                COC 5.9 pg/L (7)
                                                                10 »g/n  skin
                                                                 (1 Pf») (8)
    Methylene Chloride
       (dlchloronethane)
 See Halonethane (1)
 A    4,000 pg/L (7)
 H    9,000 pg/L (7)
                                                                                    ADI  13  ng/d  (15)
                                                                CUC 2.0 pg/L (7)
                                                                C-100 pp> (8)
     1,1,2,2-
      Tetrachloroethane
AT    9,320 pg/L (1)
CT    2,400 pg/L (1)
                                  CR1 0.17 pg/L  (1)
                                  CR2 10.7 pg/L  (1)
                                   CR3 0.17  (13)
                                 P 0.20  (14)
                                                                                                                  CUC 1.8 pg/L (7)
                                                                 T-35 mg/m
                                                                   (5 pp»)
                                                                  skin (8)
    Tetrachloroethene
       (tetrachloroethylene)
AT
CT
 A
 H
5,280 pg/1 (1)
  840 pg/L (1)
  310 pg/L (7)
  700 pg/L (7)
       CR1 0.8 pg/L
     CR2 8.85 pg/L (1)
    CR3 0.88 pg/L (13)
P 3.5  x lo"2 (14)
      HA 2.3 (1 day)
      0.175 (10 day)
    0.02 (chronic)  (13)
                                                                                                                  CUC 8.0 pg/L (7)
Peak above C
  300 ppa -
5 Bin In any
 3 hours (8)

-------
                                                                                    Table  2-1   (cont.)
                                                                        Hater Quality Criteria
            Compound
                                                 Freshwater
                                                   Aquatic
                                                   Life
     Toluene
                                             AT
                                              A
                                              N
                                            17,500 ug/L  (1)
                                              2.3 «g/L (7)
                                              5.2 mg/L (7)
                                            Health
                                         Advisory (Bg/1)
                                         Cancer Potency
                                           (•g/kg/day)
                                         and Allowable
                                         Dally Intake
                                            (•g/day)	

                                       14.3 mg/L (HSAO) (1)
                                         424 «q/L (AO) (1)
                                        15 «g/L (DM0) (13)
                                         ADI 30 «g/d  (15)
                                          HA 21.5 (1 day)
                                           2.2 (10 day)
                                        0.34 (cbronlc) (13)
                                  HDSHS Standards
                                   and HDSHS-EPA
                                  Criteria Under
                                  Consideration

                                CUC  14.3 «g/L  (7)
                                                                                                                                                 Air Quality Criteria
                              06HA/HISHA

                             C    300 PP"
                             (500 PDB for
                              10 Bin) (8)
                                                                                                                                                                          Other
                                                    Soil/
                                                 Grouodwater
                                                 Background
                                                 	Levels
NJ
 I
I-"
CO
      Trans-l,2-Dlchloroethylene
1,1,1-Trlchloroethane
See Dlchoroethylenes  (1)
   A     620 ug/l (7)
   H    1,400 pg/L (7)

  AT   18,000 pg/L (1)
   A    5,300 M9/L (7)
   M   12,000 lig/L (7)
                                                                                        N.C.  (1)
                                                                               0.2  «g/L RHCL  (3)
                                                                             18.4 «g/L (HSAO)  (1)
                                                                               1.03 g/L (AO)  (1)
                                                                               CR3  1.9 mg/L  (13)
                                                                               ADI  38  mg/a  (IS)
                                                                            HA 1.07 (chronic)  (13)
                               CDC 18,400 pg/L  (7)
                                                                                                                                                 790 mg/m   (8)
                           T    1,900 mg/m
                             (350 pp>)  (8)
      1,1,2-Trlchloroethane
                                             AT    18,000 U9/L (1)
                                                                               CR1 0.6 Ug/L (1)
                                                                               CH2 41.8 mg/L (7)
                                                                               CR3 0.6 pg/L (13)
                                                                          P 5.73 x 10"   (14)     (14)
                                                                                                                   CUC 2.7 pg/L (7)
                                                                                                    T    45 mg/m
                                                                                                      (10 Dpi)
                                                                                                      skin (8)
      Trlchloroethene
        (Trtchloroethylene)
                                       AT
                                        N
      Vinyl Chloride
        (Chlnroethene)
        45,000 Ug/L (1)
        1,500 yg/L (7)
                                             H.C.
                                             N.C.
             (1)
             (7)
    0    RHCL (3)
  CR1 2.7 U9/L (1)
  CR2 80.7 U/L (1)
     CR3 2.R U/L
 ADI 1.7 mg/f (15)
 P 1.9 x lo"  (14)
   HA 2.02 (1 day)
     0.2 (10 day)
0.075 (chronic)  (13)

  CR1 2.0 pg/L (1)
  CR2 525 Uq/L (1)
    CR3 2.0 UQ/L
CUC 27.0 yg/L (7)
CDC 517 Mg/L (7)
                             C    200 pp*
                          (300 pp> - 50 Bin)
                           T    100 pp»  (8)
T-l pp»-8 hours (8)
 (5 pp> - 15 Bin)
     10 pp» In
exhaust gases (16)

-------
            Compound
                                                 Freshwater
                                                  Aquatic
                                                  Life
                                                                                     Table  2-1   (cont.)
                                                                       Hater Quality Criteria
                                          Health
                                       Advisory («g/l)
                                       Cancer Potency
                                         (•g/kg/day)
                                       and Allowable
                                       Dally Intake
                                          tag/day)
                                HDSHS Standards
                                  and HDSHS-EPA
                                Criteria Under
                                 Consideration
                                   Air Quality Criteria
                                                                                                                                                OSHA/NISHA
                                                                                                                                                                         Other
                                                 Soil/
                                              Groundwater
                                              Background
                                                 Levels8
     V.  Pestlcldes/PCB's

     Aldrln
     Chlordane
NJ
 I
     DOT and metabolites
                                               H    3.0 gg/L  (1)
                                               A    1.9 ng/L  (7)
                                               H  1,200 ng/L  (7)
                                               A  0.0043 pg/L  (1)
                                               M  2.4 ug/L  (1)
                                               A  24 ng/L  (7)
                                               M 360 ng/L  (7)
                                               A  0.001 pg/L  (1)
                                               C    1.1 pg/L  (1)
                                      0)1 0.074 ng/L (1)
                                      CR2 0.079 ng/L (1)
                                       CR3 1.2 ng/L (13)
                                      P 11.4  (14)

                                       CR1 0.46 ng/L (1)
                                       CR2 0.48 ng/L (1)
                                      CR3 22.0 ng/L (13)
                                          r 1.61 (14)
                                   HA 0.0625  (1 and 10 day)
                                     0.0075 (chronic)  (13)

                                  See Individual compounds
                            CDC 4.4 x 10"2 ng/L (7)
                               CUC 1.2 ng/L (7)
                            T. 0.25 mg/m
                              skin (8)
                         T-0.5 mg/m -skin  (8)
     4,4'-DDD
 AT    0.6 |jg/L (1)
      N.C. (7)
                                                                                                                                                 M.C.  (7)
     4,4'-DDE

     4,4'-DDT



     Dleldrln
 AT    1,050 pg/L (1)

See DOT «, •etabolltes
 A    0.23 ng/L (7)
 M     410 ng/L (7)

 A    0.0019 pg/L (1)
 H       2.5 Ug/L (1)
 See Aldrln for (7)
CR1 0.024.ng/L (1)
 CR3 4.2 ng/L (13)
                                                                                   CR1 0.071 ng/L (1)
                                                                                   CR2 0.076 ng/L (1)
                                                                                    CR3 1.1 ng/L (13)
                                                                                   P 30.4 (14)
CUC 0.98 ng/L (7)
                            CDC 4.4 x ID*2 ng/L (7)
DDT: T-l mg/m
   skin (8)
                            T-0.25 mg/m
                              skin  (8)
     Endosulfan sulfate
     (Criteria Values for
     endosulfan)

     Endrln
      0.056 pg/L (1)
      0.22 lig/L (1)
                                             A   0.0023 pg/L  (1)
                                             M    0.18 Ug/L (1)
                                             A    0.002 pg/L  (7)
                                             M     0.1 pg/L (7)
74 pg/L (WSAO)  (1)
 159 pg/L (AO)  (1)
   ADI 0.28 (15)

 1 pg/L (H&AO)  (1)
10 pg/L (DM0)  (13)
   ADI 0.07 (15)
                                                                   STD 0.0002 »g/L  (131(6)          T-0.1 mg/m
                                                                       CUT  1 pg/L  (7)                skin (8)

-------
                                                                                Table   2-1   (cont.)
             Compound
to
 I
      Heptachlor
      Heptachlor epoxlde
      Toxaphene
      Llndane
      PCB's
Hater Quality Criteria







H
A
A
H
See

A
N
A
H
A
M
A
H
A
A
H




Freshwater
Aquatic
Life
0.52 Ug/L (1)
0.0038 vig/L (1)
1.5 ng/L (7)
450 ng/L (7)
Heptachlor (2)
K.C. (7)
0.013 Ug/L (1)
1.6 pg/L (1)
7 ng/L (7)
470 ng/L (7)
0.08 ug/L (1)
2.0 ug/L (1)
210 ng/L (7)
2,900 ng/L (7)
0.014 IJg/L (1)
1.5 ng/L (7)
6200 ng/L (7)
Health
Advisory (BO,/!)
Cancer Potency
(•g/kg/day)
and Allowable
Dally Intake
(•g/day)
CR1 0.28 ng/L (1)
CR2 0.29 ng/L (1)
CR3 11.2 ng/L (13)
F 3.37 (14)
See Heptachlor (2)

CR 1 0.71 ng/L (1)
CR 225.8 ng/L (13)
P 1.13 (14)

OU 18.6 ng/L (1)
CR2 62.5 ng/L (1)
CR3 26.4 ng/L (13)

CR1 0.079 »g/L (1)
CR2 0.079 ng/L (1)
P 4.34 (14)



HDSHS Standards
and HDSHS-EPA
Criteria Dnder
Consideration
CDC 0.23 ng/L (7)





SID 0.005 ig/L (13) d
COC 0.47 ng/L (7)


CDC 54 ng/L (7)
STD 0.004 «g/L (5,6)


CUC 0.26 ng/L (7)


                                                                                                                                                Air Quality Criteria
                                                                                         OSHA/HISHA

                                                                                        T-0.05 «g/»3
                                                                                          skin (8)
                                                                                                                                                                   Other
                                                                                                                                      Soil/
                                                                                                                                    Groundwater
                                                                                                                                    Background
                                                                                                                                      Levels3
                                                                                                                                          T-0.5 mg/m
                                                                                                                                           skin (8)
                                                                                                                                          T-0.5 mg/m
                                                                                                                                           skin (8)
                                                                                 HA 0.125  (1 day)
                                                                               0.0125 (10  day) (13)
      PCB 1016
      PCX 1242
      PCB 1248
      PCB 1254
      PCB 1260

      NPP, Non-Priority Pollutants

      Acetone


      Aluminum

      Barlui
See PCB's
                                   See PCB's
                                                                                                               STD 1  ag/L (6)
                                                                                      T    2,400 mq/m
                                                                                       (1,000 pp»>(8)
                                                                                                                                        T    0.5 mq/m
                                                                                                                                         (soluble)  (8)

-------
                                                                                Table   2-1   (cont.)
                                                                 Hater Quality Criteria
       Compound
 Benzole acid

 Benzyl alcohol

 Boron

 2-Butanone

 Carbondlsulflde


 Cobalt

 Dlbenzofuran

 2,6-Dlnltropbenol

 Fluorotrlchloromethane
   (dellsted 46TO266)

 2-Hexanone


 Iron

Manganese

 2-Methylnaphthalene

 4-Methyl-2-Pentanonp
   (Methyl Isobutyl ketone)
   (Hexone)

 2-Methylphenol

 4-Methylphenol

 Styrene
                                           Freshwater
                                             Aquatic
                                             Life
   Health
Advisory (mg/l)
Cancer Potency
 (mg/kg/day)
and Allowable
Dally Intake
  (•g/day)
HDSHS Standards
  and NDSHS-EPA
Criteria Dnder
 Consideration
                               CDC 32  mg/L  (7)
                              STD 0.3  og/L  (6)

                              STD 0.05 mg/L (6)
Air Quality Criteria
                                                                                                                                        OSHA/HISHA
                                                                                                                                                                 Other
   Soil/
Groundwater
Background
   Levels
                                                          T   590 «g/»
                                                          (200 ppa)  (8)
                                                         C    30  ppa  (8)
                                                       (100 pp» - 30  Bin)
                          T   5,600 mg/*
                          (1,000 pp>)  (8)

                          T    410 mg/m3
                           (100 ppn)  (8)
                                                         T    410 mg/»
                                                          (100 ppa)  (B)

-------
WDSHS-EPA
Criteria

AT

CT

W & AO


AO

ADI

T

M

DWO

C

e

Organoleptic


A

DWS

Skin

STD

cue

HA

P

N.C.

RMCL

CR1

CR2

CR3
         Table 2-lA
KEY TO CRITERIA ABBREVIATIONS

  Washington Department of Social and Health
  Services' interpretation of USEPA criteria

  Acute toxicity level

  Chronic toxicity level

  Ingestion of contaminated water and
  aquatic organisms

  Ingestion of aquatic organisms only

  Acceptable daily intake

  Time-weighted average

  Maximum concentration recommended criteria

  Drinking water only

  Ceiling level for air quality

  Natural logarithm constant 2.71828...

  Criteria based on organoleptic criteria
  only

  24-hour average recommended criteria

  Drinking water standards

  May be irritating or damaging to skin

  Indicates standard instead of criterion

  Criteria under consideration

  Health advisory

  Cancer potency

  No criteria

  Recommended maximum contaminant level

  10~  Cancer risk (W&AO)

  10~  Cancer risk (AO)

  10~6 Cancer risk (DWO)
                            2-22

-------
                         Table 2-1B
              REFERENCES FOR NUMERICAL CRITERIA
1.    U.S.  Environmental Protection Agency Part V,
     Water Quality Criteria Documents, Availability.
     Federal Register.  November 28, 1980.  (Revised-FR46:
     156.   August 13, 1981).

2.    U.S.  Environmental Protection Agency.  Ambient Water
     Quality Criteria (microfiche). EPA-440/5-80.
     Washington, D.C.  October 1980.

3.    U.S.  Environmental Protection Agency-  Part V,
     National Primary Drinking Water Regulations,  Volatile
     Synthetic Organic Chemicals, Proposed Rulemaking.
     Federal Register.  June 12, 1984.

4.    U.S.  Environmental Protection Agency, Office of
     Pesticides and Toxic Substances.  Intermedia Priority
     Pollutant Guidance Documents.  July 1982 (Revised
     October 1983).

5.    U.S.  Environmental Protection Agency, Office of Water
     Supply.  National Interim Primary Drinking Water
     Regulations.

6.    Washington State Department of Social & Health Ser-
     vices, Water Supply & Waste Section.  Rules and Regula-
     tions of the State Board of Health Regarding Public
     Water Systems. Revised August 1983.

7.    Washington State Department of Social and Health Ser-
     vices, Water Supply and Waste Section.  Organic Chemi-
     cals in Drinking Water.   A Reference Document For
     Agency Use.  June 1984.

8.    U.S.  Department of Labor, Occupational Safety and
     Health Administration.   General Industry, OSHA Safety
     and Health Standards.  Revised March 11, 1983.

9-    U.S.  Environmental Protection Agency.  Preliminary
     Draft, Remedial Investigation, Western Processing,
     Kent, Washington.  REM/FIT Zone II Contract
     No. 68-01-6692.  EPA WA 37-OL16.1.  July 27, 1984.

10.  Washington Department of Ecology:  Final Cleanup
     Policy, Technical.  Effective Date July 10, 1984.
                           2-23

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                         Table 2-1B
                         (continued)

11.   U.S.  Environmental Protection Agency.   Internal
     document from the Office of Solid Waste and Emergency
     Response.   August 27,  1984.

12.   Galvin,  David V.  and Richard K.  Moore.  Toxicants in
     Urban Runoff, Metro Toxicant Program Report #2.  Pre-
     pared by Municipality of Metropolitan Seattle for U.S.
     EPA.   Washington Operating Office, Lacey, Washington.
     December 1982.

13.   (USEPA and Office of Emergency and Remedial Response.
     Draft Guidance Document for Feasibility Studies Under
     CERCLA.   October 18, 1984.)

14.   USEPA Health Assessment Document for Epichlorohydrin,
     Final Report.  EPA-600/8-83-032F, Office of Research
     and Development,  Research Triangle Park, N.C. 27711,
     December 1984.

15.   (USEPA.   Summary of Published Acceptable Daily Intakes
     for EPA's Priority Pollutants.  Internal Review Draft.
     ECAO-CIN-437.  April 1984.)

16.   National Emissions Standards For Hazardous Air
     Pollutants, 40 CFR Part 61.

17.   Washington State Division of Industrial Safety and
     Health.   General Occupational Health Standards,
     Chapter 296-62 WAC.  June 1982.
                           2-24

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criteria may be applicable to groundwater.  In evaluating
criteria for use in this study, those relevant to the likely
routes of exposure were considered.  The criteria are dis-
cussed in greater detail by respective pathway in the follow-
ing sections.

2.3.1.1  Exposure Through Water

Ambient water quality criteria have been developed by USEPA
for the purpose of protecting aquatic life and human health.
Early development of those criteria is summarized in the
preface to the publication Quality Criteria for Water (USEPA,
July 1976).  This document also contains the criteria pub-
lished in response to a congressional mandate under the Clean
Water Act, Public Law 92-500-  In response to new and in-
creased knowledge about the hazards of certain elements and
compounds, Public Law 92-500 also required subsequent revi-
sions to the ambient water quality criteria.  Major revisions
were published by USEPA in the Federal Register during 1980
as well as in criteria documents for numerous chemicals and
elements.

The revised 1980 publications replaced some of the 1976 cri-
teria, added new criteria, and left some of the 1976 criteria
unchanged.  Subsequent revisions through 1984 have also
added, changed, or deleted criteria.  Further revisions have
been proposed in the Federal Register.  The ambient water
quality criteria shown in Table 2-1 represent the status as
of December 1984.  The federal water quality criteria are
guidelines only and do not have the force of law unless spe-
cifically adopted by the states.

The ambient water quality criteria have been developed from
information on direct toxicity  (acute and chronic) to aquatic
life and humans, and the toxicity or carcinogenicity to humans
and other organisms as a consequence of consuming contaminated
fish, shellfish, and water.  The intent of the criteria is
to protect aquatic or terrestrial life and/or human health,
or to prevent cancer.  If sufficient data are available for
formal development of a criterion based on toxicity, criteria
are stated as maximum contaminant levels  (MCL's) averaged
over 24 hours and as maximum allowable (instantaneous) con-
centrations.  When the available data are insufficient for
the development of criteria  (using the procedure specified
by USEPA), available toxicity information was used in lieu
of criteria in Table 2-1.  In general, criteria have been
developed for most of the 129 priority pollutants known to
be highly toxic to aquatic life.  As new information becomes
available, existing criteria are revised or new ones proposed.

For elements and compounds that are not known to be highly
toxic, but may pose a risk to human health or are considered
carcinogenic, values are given in terms of calculated risks
                            2-25

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of cancer or a no-observed-effect level  (NOEL) for noncar-
cinogens.  These criteria are listed in Table 2-1.  For the
chemicals considered to be carcinogens, the concentrations
shown are those estimated to lead to an increase of one in-
cident of cancer in a population of one million after life-
time exposure.  The 10   cancer risk levels are not used
here to imply acceptable risks.  Rather, they are given only
to provide a basis for discussion of the nature and extent
of contamination.

Chemicals that bioconcentrate (i.e., the concentration of
the chemical in an organism's tissue is greater than in the
environmental media) may have criteria  (i.e., concentration
limits) that are much lower than those needed for protection
of aquatic life.  Examples include some pesticides and metals
that are known or suspected carcinogens, and metals that are
more toxic to mammals than to aquatic life.  Elements and
chemicals that are more toxic to aquatic life than to humans
generally have criteria lower than needed to protect human
health.  An example would be the application of aquatic tox-
icity as the criterion for a metal such as zinc.  Zinc is
relatively harmless to humans but quite toxic to some aquatic
life.

When applying ambient water quality criteria to a Superfund
site, the likely routes of contaminant migration and likely
receptor populations should be considered.  It may be inap-
propriate to apply human health criteria to nonhuman receptor
populations or to media to which humans would not be exposed.
An example illustrating the possible misuse of criteria would
be the application of drinking water standards to Class III
groundwater sources (see Section 2.4.2).  Similarly, it may
not be appropriate to apply criteria for the protection of
aquatic life to a contaminated groundwater supply that would
not reach or discharge to surface water in quantities suffi-
cient to endanger aquatic life.  Ambient water quality cri-
teria, however, may be appropriate when evaluating remedial
actions at a site when surface water or groundwater is con-
taminated and may pose a threat to drinking water supplies
or aquatic life.

Other criteria that apply to surface water and groundwater
include maximum allowable concentrations for the protection
of crops and livestock and for the prevention of objection-
able tastes, odors, and color in drinking water.  Examples
of the substances considered by these criteria include man-
ganese, iron, and cobalt.  Substances covered by these cri-
teria generally do not pose a hazard to human health or to
aquatic life except at extremely high concentrations.  They
have not been considered in detail in the evaluation of con-
tamination at Western Processing.
                            2-26

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At Western Processing, contaminants appear to be entering
Mill Creek via migration of contaminated groundwater (see
Section 3.3.3.3).  These contaminants could threaten aquatic
life in Mill Creek.  In the absence of direct biological
evidence confirming adverse impacts to Mill Creek, the ambi-
ent water quality criteria could be used to assess potential
harm to aquatic biota through application as discharge cri-
teria to evaluate the feasibility of a discharge to Mill
Creek, and as a general frame of reference or goal for eval-
uating the effectiveness of alternatives.  Since domestic
water supplies have not been contaminated, the human health
components of the ambient water quality criteria, or appro-
priate values derived from them, should not be used to eval-
uate potential impacts.

Washington State law requires that the Washington Department
of Ecology (WDOE) determine deleterious concentrations of
toxic materials in consideration of the Quality Criteria for
Water published by USEPA in 1976, and all subsequent revi-
sions to the those criteria or other relevant information.
Washington State thus automatically adopts changes in the
ambient water quality criteria as they occur.

At present, WDOE establishes a mixing zone for permitted
point source discharges to surface waters of the state.
Toxic substance concentrations in the mixing zone may not
exceed the maximum allowable concentrations of any toxicant
covered by the federal ambient water quality criteria.  Con-
centrations of toxic substances may not exceed the criteria
values for 24-hour average concentrations at the edge of the
mixing zone.

Any surface water discharge of treated or untreated waste-
water (e.g., resulting from withdrawal of contaminated
groundwater) from Western Processing site remedial actions
would require compliance with National Pollutant Discharge
Elimination System (NPDES) permit requirements.  The dis-
charge would be subject to State of Washington effluent dis-
charge criteria as well as the mixing zone limitations.
These requirements would apply to any point source discharge
into Mill Creek or Green River.

2.3.1.2  Exposure Through Soil

In general, criteria for contamination levels in soil for
the protection of plants and animals have not been estab-
lished at the federal or state level although a state clean-
up policy exists.  Criteria or standards for hazardous waste
sites have historically been determined on a site-specific
basis.  Criteria have been determined by considering the
likelihood that the contaminants will enter the water or
will have plant uptake.  A partial exception is the Washing-
ton State Cleanup Policy  (Section 2.4.4) which references
                            2-27

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ambient water quality criteria and is intended to afford
protection to aquatic life.

The British Department of the Environment has developed
guidelines on acceptable concentrations of contaminants in
soil considering effects to plants (Smith, 1981).  Smith
states that the trigger values given in Table 2-2 for phyto-
toxicity  (toxicity to plants) criteria were considered to be
acceptable for plant growth, but exceeding them could only
be interpreted as suggesting the need to consider, not re-
quire, a remedial action.  That is, exceeding the specified
concentrations would be considered undesirable but not nec-
essarily unacceptable.  In developing the guidelines it was
assumed that the soil would be maintained at about pH 6.5
for arable soils and 6.0 for grassland.  Woodlands and per-
manent grasslands, except on chalk or limestone, commonly
have a pH less than 6.  Soils also have a natural tendency
to become more acidic through normal leaching and under other
environmental conditions, such as acid deposition (wet and
dry).
                          Table 2-2
      PHYTOTOXIC GUIDELINES FROM THE BRITISH DEPARTMENT
                     OF THE ENVIRONMENT
                       (mg/kg dry soil)

                                Zinc      Copper     Nickel

Trigger concentrations           130         50        20

Maximum normally tolerable:
  Gardens                        280        140        35
  Amenity grass and public
    open space                 280-562    140-280     35-70
Note:  Guidelines are for available metal concentrations.
       It is commonly assumed that the effects of zinc,
       copper, and nickel are additive.  Comparative toxi-
       cities may differ from those implied by the suggested
       limits.  The higher end of the range is applicable to
       calcareous soils.
Source:  Smith, 1981.
The uptake of most metals by plants tends to increase with
decreasing pH, but the uptake of molybdenum, selenium, and
hexavalent chromium tends to increase with increasing pH.
Some species, such as grasses, are more resistant to zinc,
copper, and nickel in the soil.  Some species of crops, such
as lettuce and radishes, tend to accumulate metals toxic to
humans.  Plants show differing responses to the presence of
other toxic chemicals in the soil.
                            2-28

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In addition to potential negative effects from direct uptake
of chemicals by plants, soil contaminants also have the po-
tential, through runoff, to pollute nearby surface water
sources, or, through leaching, to pollute groundwater aqui-
fers.  In these cases, contaminated soil serves more as a
source of contaminants than a specific exposure route for
biota.  Animals may also directly ingest contaminated soil
or plants containing unusually high concentrations of
chemicals.

Background soil concentrations for the Western Processing
site were developed for use in evaluating the nature and
extent of contamination.  Actual concentrations were deter-
mined for six "indicator" metals.  The term "indicator" is
defined in Chapter 3, Section 3.4.3.  A different approach
was used for organics as discussed below.  Background soil
concentrations for the seven metals are summarized on
Table 2-1.

The background metal concentrations used were approximately
the upper 95th percentile of regional soil or creek sediment
values.  This approach was used because Western Processing
is in an industrial area that was previously used for agri-
culture.  By the nature of its location, concentrations of
metals in soils might be somewhat above background values
than that found in pristine areas.  Additional justification
for selection of the upper 95th percentile for background
metal concentrations is that the probability of mis-identi-
fying high natural levels of metals as "contamination" is
lower than if average background values were used.

The background soil values shown in Table 2-1 were obtained
from two sources.  Concentrations of chromium, lead, nickel,
and zinc were determined using surface soil samples WP-BG-01
through WP-BG-07.  These data are summarized in Table 2-3.
The upper 95th percentile was determined assuming the data
conformed to a log-normal distribution.  The standard devi-
ation was multiplied by 1.96 and this value was then added
to the mean.  These samples were not analyzed for copper or
cadmium.  Background concentrations for those two metals
were derived from Lake Washington sediment data published by
the Municipality of Metropolitan Seattle (Table 74 in Galvin
and Moore, 1982) .  Lake sediments originate from regional
alluvial sediments.  The means and 95 percent confidence
limits for copper and cadmium given by Galvin and Moore were
within the range of other published and unpublished values
for the region and the earth's crust, cited in Table 56 of
that document.  The upper 95th percentile derived from Galvin
and Moore was based on a normal, rather than log-normal dis-
tribution.  This resulted in a slightly higher background
value than if a log-normal distribution was used.  The back-
ground value for arsenic was derived from stream sediment
values from Table 67 of Galvin and Moore.  The upper 95th
                            2-29

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percentile based on  a  log-normal distribution shown in
Table 2-1 is consistent  with values reported by Crecelius,
Bothner, and Carpenter (1975)  and by Carpenter, Peterson,
and Jahnke  (1978).   The  soils from samples WP-BG-01 through
WP-BG-07 were analyzed without drying, and percent moisture
was not measured.  To  convert the background values to a dry
weight basis, the measured moisture content of 25 samples
collected onsite was used to calculate a correction factor.
Based on a moisture  content of 13 percent, the correction
factor was I/.87 = 1.15.
                           Table 2-3
      METAL CONCENTRATIONS IN BACKGROUND SOIL SAMPLES
                COLLECTED IN THE KENT VALLEY
            WESTERN  PROCESSING, KENT, WASHINGTON

             Depth        Metal Concentration (yg/g) (Wet Weight)
 Sample       (feet)

WP-BG-01       0.5
WP-BG-02       0.5
WP-BG-03       0.5
WP-BG-04       0.5
WP-BG-05       0.5
WP-BG-06       0.5
WP-BG-07       0.5
Chromium
22.7
27.2
32.7
17.2
21.2
23.8
21.9
Lead
12.3
10.6
25.6
14.4
36.6
13.1
51.7
Nickel
13.0
21.8
33.1
14.8
16.8
25.4
19.0
Zinc
41.4
37.4
82.5
39.1
72.4
41.4
57.3
Source:  Remedial Investigation Data Report, Western Processing,
        Kent, Washington.  CH2M HILL, November 1984.


Background  soil concentrations for organic priority pollu-
tants were  determined assuming they are not naturally occur-
ring in the environment.   For this reason, it was assumed
that any detection  of an  organic priority pollutant indicated
potential contamination except where data were available to
suggest otherwise  (e.g.,  for certain pesticides and phthalates)
This information was  used to qualify the nature and extent
discussion  in  Chapter 3.

2.3.1.3  Exposure Through Air

Environmental  standards for  air quality include standards
for stationary emissions  sources such as smoke stacks, mobile
emission sources such as  vehicles, and for ambient air.  The
ambient air quality standards are achieved by enforcing the
emissions standards.   In  areas where ambient standards are
attained or exceeded  despite enforcement of emission stan-
dards  (i.e., in heavily industrialized areas), more restric-
tive emission  standards may  be developed for that area.
                            2-30

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Ambient air quality standards have been adopted by USEPA,
the Washington State Department of Ecology  (WDOE), and the
Puget Sound Air Pollution Control Agency  (PSAPCA) for sulfur
oxides, suspended particulates, carbon monoxide, ozone, ni-
trogen dioxide, and lead.  In the Puget Sound area (includ-
ing the City of Kent) PSAPCA is responsible for enforcing
the standards.  Lead and particulates are the only contami-
nant found at the site for which ambient air quality stan-
dards exist.

During cleanup work at the site it may be appropriate to
also apply the PSAPCA standard for visual air contaminants
in addition to existing ambient air quality criteria.  The
regulations require that no emission shall be greater than
20 percent density  (or No. 1 on the Ringelmann Chart pub-
lished by the U.S. Bureau of Mines).  PSAPCA regulations
also require that control measures be taken to reduce odor-
bearing gases or particulate matter.  No specific standards
are set for these emissions.

National emission standards for asbestos, beryllium, mercury,
and vinyl chloride were adopted to regulate facilities emit-
ting these pollutants (National Emissions Standards for Haz-
ardous Air Pollutants, 40 CFR 61).  These standards would
apply to emissions from air stripping or other stationary
emission sources if they are constructed at the site.

During remedial cleanup activities at the site additional
site-specific air quality criteria will probably be estab-
lished for those contaminants thought to pose potential haz-
ards in the area.  These criteria will be based on industrial
workplace exposure limits (as shown in Table 2.1).

2.3.2  HUMAN HEALTH AND WELFARE CRITERIA

As discussed previously, another approach used in evaluating
the nature and extent of contamination, and subsequent reme-
dial actions, is to evaluate the contamination on the basis
of risk to human health.  One of the major goals of virtually
all acts of environmental legislation is the protection of
human health and welfare.  Specific legislative acts may
indicate which group of people should be protected by any
one act.  For example, the Occupational Safety and Health
Act is designed to protect the health of workers, generally
presumed to be healthy adults who are fit enough to perform
industrial labor.  In contrast, legislation that considers
the protection of public health may require the protection
of particularly sensitive members of the population  (e.g.,
children, the elderly, pregnant women).  Often, therefore,
public health standards or criteria are more stringent than
occupational exposure standards for the same chemical.
                            2-31

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The development of public health protection criteria requires
an assessment of both exposure potential and toxicity of a
chemical.  Direct exposure episodes can occur from any or
all of the three basic environmental media  (air, water, and
soil).  Chemical intake can be through ingestion, inhalation,
or dermal absorption.  The links between the environmental
media and the exposure routes are summarized in Table 2-4.
                          Table 2-4
    LINKS BETWEEN ENVIRONMENTAL MEDIA AND PUBLIC EXPOSURE

                 Intermediate
Media              Mechanism                Intake Route
Air                  —                   Inhalation

Water          Aerosol formation          Inhalation
               Volatilization

               Drinking, cooking          Ingestion

               Bathing                    Dermal absorption

               Fish uptake                Ingestion

Soil           Dust entrainment           Inhalation
               Volatilization             Ingestion

               Surface contact            Dermal absorption

               Plant uptake               Ingestion
               Animal ingestion
Once an exposure episode has occurred (either acute or long-
term) , the body will attempt to metabolize or excrete the
chemicals.  Typical elimination pathways are through the
urinary or fecal tracts.  Chemicals that are rapidly elimi-
nated are typically excreted in the urine (largely as the
parent material).  Chemicals that are not rapidly eliminated
are generally absorbed in body tissues (e.g., lipids) and
not metabolized (i.e., bioconcentrated)  or are absorbed and
slowly metabolized.  Excretion in the latter instance is
usually in the feces as the parent compound or as a metabolite.

The total body burden is the chemical concentration in the
body.  The body burden results from the difference in the
rates of intake and elimination from the body.  Each of the
routes in Table 2-4 can contribute to the total body intake.
Chemicals that are eliminated more slowly than their intake
rate will bioconcentrate in the body.  Some chemicals have
particularly high bioconcentration factors (e.g., PCB's and


                           2-32

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many pesticides).  The duration of the exposure episode plays
an important role in determining to what extent an elevated
body burden is likely.  Generally, longer duration exposures
to chemicals known to bioconcentrate may result in higher
body burdens than a short duration exposure to the same
chemical at the same concentration.

Compounds toxic to humans may be divided into two classes:
threshold and nonthreshold chemicals.  The former include
all those chemicals that are believed to require a certain
minimal exposure before an adverse biologic effect occurs,
implying that there is a no-effect dose.  For chronic or
lifetime periods of exposure, the no-observed-effect level
(NOEL), after applying a safety factor, is commonly referred
to as  an acceptable daily intake  (ADI).  ADI's are defined
as exposure levels that are considered to be without risk to
humans when exposed daily over a lifetime.  ADI's for some
chemicals have been developed by toxicologists after a review
of the data for a chemical.  The ADI's developed by USEPA,
when available, are shown in Table 2-1 under Water Quality
Criteria.

Nonthreshold chemicals are those for which an incremental
exposure adds a finite increase in the risk of disease or
injury.  Carcinogens are one group of chemicals that are
believed to have no threshold exposure limit.  For carcino-
gens,  the measure of incremental probability of getting can-
cer from a given exposure is called the cancer potency.  The
estimate of excess lifetime cancer risk from exposure to a
carcinogen is related to the exposure by a risk model.
USEPA  is currently using the one-hit model  (USEPA, 1984):

      „ .,-  .          .  ,   ,   -(potency) x (exposure)    .    _  ,.
excess lifetime cancer risk = 1 - e                       (Eq. 2-1)

The concepts of an acceptable daily intake and cancer potency
can be used to establish site-specific criteria for target
exposures.  For example, assume that an ADI is available for
a noncarcinogen, or a cancer potency and a target cancer
risk are available for a carcinogen.  The target concentra-
tion in a particular environmental medium can then be calcu-
lated  from the rate of ingestion  (mass of water or food per
day),  inhalation  (mass of air per day), or dermal absorption
(mass  of material absorbed per day), as follows:

o    Noncarcinogen:

                                ADI
acceptable concentration = rate of intake          (Eq> 2~2)


o    Carcinogen:

target concentration =   ln 
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Cancer potencies and ADI's are shown in Table 2-1.

Although these two methods offer a means to calculate site-
specific exposure limits,  they are not without uncertainty.
Most ADI's and cancer potencies are determined from studies
on laboratory animals.  Based on the respective toxicological
properties or suspected carcinogenicity of the individual
chemical in the test organism, the laboratory data are ex-
trapolated to humans by use of appropriate safety factors.
For example, a safety factor of at least 100 is usually ap-
plied when extrapolating animal NOEL's to human ADI's.  When
the animal study information is less reliable, larger safety
factors are applied.  When employing ADI's or cancer poten-
cies to establish criteria, the relative uncertainty by which
they are derived must be recognized.  For some chemicals,
organoleptic criteria such as the threshold for controlling
undesirable taste and odor may be below the threshold for
toxicity.   The exposure criteria may be set on the basis of
these considerations as well as others.  It should be noted
that organoleptic data as a basis for establishing criteria
have limitations and have no demonstrated relationship to
adverse human health effects.

2.3.2.1  Exposure Through Water

Potable water can result in human exposure to chemicals
through the routes shown in Table 2-4.  Typically, the focus
of a public health exposure assessment has been on drinking
water.  Recently, however, the potential for significant
exposure to volatile organics through skin absorption (Brown
et al. , 1984) and volatilization of chemicals during indoor
water use  (Andelman, May 1984) have been described.

The Safe Drinking Water Act requires that USEPA publish pri-
mary drinking water regulations for public water systems.
USEPA must set a recommended maximum contaminant level
(RMCL), a non-enforceable health goal at which "no known or
anticipated adverse effects on the health of persons occur
and which allows an adequate margin of safety."  Regulations
specify maximum contaminant levels (MCL's) that are enforce-
able standards or that require a treatment technique if it
is not economically or technologically feasible to measure
the concentration of a contaminant in drinking water.  The
MCL must be set as close to the RMCL as is feasible, which
means "with the use of the best technology, treatment tech-
niques, and other means which the Administrator [of USEPA]
finds are generally available (taking costs into
consideration)."

The State of Washington Department of Social and Health Ser-
vices (WDSHS) has established drinking water standards as
part of their Rules and Regulations of the State Board of
Health Regarding Public Water Systems  (see Table 2-1).  The
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state standards are nearly identical to the Safe Drinking
Water Act Primary Drinking Water Standards.

The State of Washington may adopt criteria different from
the federal standards.  Proposed changes in the primary
drinking water standards  (and other federal water-quality
criteria) have been identified by the WDSHS (see Table 2-1).
Those values are mainly in addition to the primary drinking
water standards shown in Table 2-1.

ADI's and cancer potencies can be used to establish criteria.
For exposure assessments of drinking water contaminants, it
is usually assumed that an adult drinks two liters of water
per day.  If a threshold chemical has an established ADI,
then Equation 2-2 can be used to establish a criterion for
acceptable concentration in potable water.  If an estimate
of a carcinogen's cancer potency is available, then Equa-
tion 2-3 can be used to establish a criterion for an accept-
able concentration.

If human exposure to waterborne contaminants originating
from the Western Processing site was likely to occur, the
most probable pathways would be intake of contaminated sur-
face water or groundwater through ingestion and inhalation
of volatile organics.  The criteria available include the
Safe Drinking Water Act maximum contaminant levels (MCL's),
and ADI's or cancer potencies derived for water and other
exposure routes.

MCL's for drinking water are health- and technology-based.
For chemicals that have established RMCL's (i.e., they are
health-based), the MCL's are enforceable standards that are
set as close as possible to the RMCL with consideration
given to the best use of technology and treatment techniques.
For other chemicals in which the RMCL cannot be established,
the MCL may be specified as concentration achievable by use
of a specified treatment technique  (i.e., chemical treatment
or filtration).  For contaminants in this category, the pre-
sumption is that the treatment technique will achieve accept-
able levels, although it may not always be demonstrated.  On
this basis, MCL's for many Western Processing contaminants
were deemed not to be based totally on human health protec-
tion criteria.

The water quality assessment indicators for human health
that are used in the later chapters are ADI's and cancer
potencies.  Although not without uncertainties, these
indicators offer a fundamental approach in assessing risk
associated with chemical exposure.  For those chemicals
identified at Western Processing that are believed to be
noncarcinogenic, comparison to ADI's were made.  Cancer
potencies were used for known or suspected carcinogens.
                            2-35

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2.3.2.2  Exposure Through Soil

Contaminants in soil can lead to human exposure to chemicals
through the routes shown in Table 2-4.  With the exception
of the Extraction Procedure (EP) toxicity standards for the
eight metals and six pesticides listed in RCRA (40 CFR Part
261.24), few standards for soil contaminants have been de-
veloped by regulatory agencies.  Soil that is contaminated
by more than 50 mg/kg (dry weight) total PCB's must be in-
cinerated or disposed of in a USEPA approved chemical waste
landfill (40 CFR Part 761.60).

Exposure of receptors to contaminated soil can occur through
direct contact, through ingestion of soil, or by subsequent
migration of contaminants to other media, such as air or
water.  At Western Processing, the soils are a continuing
source of contamination to the local groundwater and Mill
Creek.  Possible future use of the site, without remedial
action, would expose humans to contaminated surface soils.

Smith  (1981) of the British Department of Environment (BDOE)
has proposed acceptable soil criteria based on the potential
for the ingestion of contaminated crops and soil (Table 2-5).
The guidelines are applicable to the future development of
contaminated sites, not to the evaluation of existing devel-
opment on contaminated soil.  The guidelines in Table 2-5
only identify acceptable concentrations; excess concentra-
tions require further evaluation to determine whether reme-
dial action is required.  The guidelines recommend that "No
individual  'spot' sample taken from the top 450 mm should
exceed the acceptable concentration and there should only be
an acceptably low probability  (say 1 in 100) that any signi-
ficant proportion of soil exceeds the limit."   (Smith, 1981)

Few quantitative measurements of soil ingestion by people
during work or outdoor recreation are available.   It has
been estimated that children may ingest at least 100 mg of
soil per day or as much as 5 g/day (USEPA, 1984) .  In their
assessment for 2,3,7,8-TCDD, Kimbrough et al.  (1984) esti-
mated an age-dependent rate varying from zero for infants to
10 g/day for 1.5- to 3.5-year-olds to 0.1 g/day for those
over 5 years of age.  Rates of exposure have also been esti-
mated for other routes  (USEPA, 1984).  As described in
Section 2.3.2.1, Equations 2-2 and 2-3 could be used with
these rates of soil exposure to calculate acceptable soil
concentrations.

Selection of human health criteria for endangerment assess-
ment due to exposure to contaminated soils at or near Western
Processing was based on acceptable daily intakes (ADI's) for
noncarcinogens and cancer potencies for carcinogens.  Other
criteria that were considered included the toxicity standards
of RCRA and the guidelines presented by Smith (1981).
                            2-36

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                            Table  2-5
SOIL CRITERIA FROM  THE BRITISH DEPARTMENT OF  THE ENVIRONMENT
                        (mg/kg dry soil)

                       Small      Large      Amenity     Public Open
                      Garden      Garden     Grass        Space	

Cadmium                   5           3          12            15
Lead                    550         550       1,500         2,000
Mercury                   1.5         1           4            20
Chromium
  Total                  600         600       1,000         1,000
  VI                    25          25          25            25
Molybdenum                555             5
Arsenic                  20          10          40            40
Selenium                  333             3
     p
Boron                    3333
Barium                   125         125         125         1,000
Antimony                 60          60          60           500
Fluorine                 800         800         800         1,000
 Arbitrarily defined as less than 75 square meters (m ) in area.

 Includes schools, play areas, and recreational areas around residential
 development where there may be regular contact by small children.  Areas
 where there may be more intensive use by small children  (e.g., nursery
 schools) should be treated as domestic gardens.

 Includes formal play field areas, parkland, and informal recreation areas.

 Soluble fraction in 0.1 M HC1 or solution corrected to pH 1.0 if alkaline
 substances present.
£
 Water soluble boron.
Source:  Smith, 1981.
The  RCRA standards  for extraction procedure  toxicity are
based  on drinking water standards for the  14 constituent
metals and pesticides multiplied by a factor of 100.  The
extraction procedure is intended to simulate leaching of
these  constituents  in a solid  waste landfill under mildly
acidic conditions.   When assessing human health implications,
RCRA toxicity standards may not provide a  complete basis  for
decisions.

Similarly, the guideline values presented  by Smith  (1981)
provide useful information on  identifying  levels of particu-
lar  metal contamination that may be of concern if exceeded.
Little or no documentation was presented in  the development
of the guideline values; therefore, they were considered  as
advisory only.
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As with selection of human health criteria for water, compar-
ison with ADI's and cancer potencies appears to provide the
most fundamental approach for assessing the risks to human
health associated with chemical exposure through ingestion,
inhalation, and dermal contact from the Western Processing
site.

2.3.2.3  Exposure Through Air

The Occupational Safety and Health Administration  (OSHA) has
adopted employee exposure limits to protect employee health
in the workplace (29 CFR Part 1910 Subpart Z).  Exposure
limits were adopted for approximately 400 air contaminants
and although the exposure limits are expressed in contaminant
per unit of air, they apply to all types of exposure  (inhal-
ation, skin contact, and absorption).

The exposure limits apply primarily to industries where the
regulated substances are manufactured, processed, repackaged,
or stored.  They are also applicable to any workplace where
the substances are otherwise released or handled.  They
would, therefore, apply to the work environment at Western
Processing during remedial action.

Table 2-1 shows the OSHA exposure limits for substances
found at the Western Processing site.  Operators are
required to use administrative or engineering controls to
reduce contaminant levels to the exposure limits.  If these
controls are insufficient, then protective equipment such as
clothing and respirators must be used to meet employee
exposure limits.

The OSHA exposure limits are the same as the Washington In-
dustrial Safety and Health Administration (WISHA) exposure
limits for most substances.  WISHA exposure limits are more
strict for isophorone, as shown in Table 2-1.

The OSHA/WISHA exposure limits represent conditions under
which it is believed that nearly all workers may be repeat-
edly exposed day after day without adverse effect.  As such,
the exposure limits represent contaminant levels that are
acceptable for prolonged exposure (e.g., 8 hours per day,
5 days per week).

            2.4  APPROACHES TO APPLYING STANDARDS

In the previous sections of this chapter, environmental and
human health criteria were discussed in terms of their pos-
sible use in determining methods and adequacies of remedial
cleanup at Western Processing.  Discussed in the following
sections are the administrative and regulatory requirements
and guidance that will provide the framework for implementing
remedial actions at the site.
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2.4.1  CERCLA COMPLIANCE GOALS AND REQUIREMENTS

As authorized by CERCLA, USEPA is mandated to respond to
releases or substantial threats of releases of hazardous
substances into the environment, and releases or substantial
threats of releases of pollutants or contaminants which may
present an imminent and substantial danger to public health
or welfare.  Section 104 (c) (3) of CERCLA requires that all
offsite storage, destruction, treatment, or disposal of haz-
ardous substances generated from remedial actions be taken
to a facility in compliance with Subtitle C of the Resource
Conservation and Recovery Act (i.e., a facility complying
with the requirements of RCRA).

In addition, USEPA has developed and is continuing to develop
administrative policies and guidance which further delineate
acceptable disposition of wastes generated from CERCLA reme-
dial actions.  For example, if hazardous substances are to
be disposed of at a RCRA-approved landfill as part of a
CERCLA-financed remedy, USEPA stipulates that the landfill
must be a double-lined landfill capable of complying with
the design and operating requirements of 40 CFR Part 264.301
and 40 CFR Part 264.302.  A landfill operating in compliance
under interim status with 40 CFR Part 265 Subpart N may not
satisfy this requirement.

CERCLA generally does not address the applicability of regu-
lations, guidance, and advisories developed under authority
of other federal environmental statutes to Hazardous Sub-
stance Response Trust Fund  (Superfund) financed actions or
CERCLA enforcement actions.  Despite the lack of specific
requirements, it is USEPA's policy to attain or exceed all
applicable or relevant environmental and public health stan-
dards or criteria when remedial actions are taken.  This
policy is applicable except in cases in which one or more of
the following circumstances exist:

     1.   The selected alternative is not the final remedy
          and will become part of a more comprehensive reme-
          dial action program.

     2.   All of the alternatives that meet applicable or
          relevant standards fall into one or more of the
          following categories:

          a.   Fund Balancing (for Fund-financed actions
               only); the alternatives do not meet the Fund
               balancing provisions of CERCLA
               Section 104 (c) (4).

          b.   Technical impracticability; based upon the
               specific characteristics of the site, the
               alternatives are technically impractical to
               achieve.


                            2-39

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          c.    Unacceptable environmental impacts; all al-
               ternatives that attain or exceed standards
               would cause unacceptable damage to the
               environment.

     3.    When the remedy is to be carried out pursuant to
          CERCLA Section 106, the Hazardous Substance Re-
          sponse Trust Fund financing is unavailable; strong
          public interest is in favor of expedited cleanup;
          and litigation probably would not result in the
          desired remedy.

2.4.2  USEPA GROUNDWATER PROTECTION STRATEGY

USEPA has developed guidelines establishing specific criteria
and definitions for classifying groundwater.  The following
general characterizations define the three categories of
groundwater under the USEPA Groundwater Protection Strategy
(USEPA,  August 1984) :

     CLASS I.  Special Groundwaters

     (1)  Irreplaceable source of drinking water.  These
          include groundwater located in areas where there
          is no practical alternative source of drinking
          water (islands, peninsulas, isolated aquifers over
          bedrock) or an insufficient alternative source for
          a substantial population.

     (2)  Ecologically vital.  The groundwater contributes
          to maintaining either the base flow or water level
          for a particularly sensitive ecological system
          that, if polluted, would destroy a unique habitat
          (e.g., those associated with wetlands that are
          habitats for unique species of flora and fauna or
          endangered species).

     CLASS II.  Current and Potential Sources of Drinking
     Water and Water Having Other Beneficial Uses

          All other groundwater currently used or potentially
          available for drinking water and other beneficial
          use is included in this category, whether or not
          it is particularly vulnerable to contamination.

     CLASS III.  Groundwater Not a Potential Source of
     Drinking Water and of Limited Beneficial Use

          Groundwaters that are saline or otherwise contam-
          inated beyond levels which would allow use for
          drinking or other beneficial purposes are in this
          class.  They include groundwaters with a total
          dissolved solids  (TDS) level over 10,000 mg/L, or
                           2-40

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          that are so contaminated by naturally occurring
          contaminants or by human activity (unrelated to a
          specific hazardous waste land disposal site)  that
          they cannot be practicably cleaned up using methods
          reasonably employed in public water system treat-
          ment.  In addition, Class III groundwater must not
          be connected to Class I or Class II groundwater or
          to surface water in a way that would allow contam-
          inants to migrate to these waters, potentially
          causing adverse effects on human health or the
          environment.

In general, goals for levels of cleanup under CERCLA remedial
actions have been established for each class of groundwater.
Those goals are:

     CLASS I:    Cleanup objectives will be to background or
                 drinking water standards or levels that
                 protect human health.

     CLASS II:   Cleanup of contamination will usually be to
                 background levels or drinking water stan-
                 dards, but less restrictive alternative
                 limits may be applied to potential sources
                 of drinking water or water used for agri-
                 cultural or industrial purposes.  Further,
                 USEPA recognizes that in some cases alter-
                 natives to groundwater cleanup and restora-
                 tion may be appropriate.

     CLASS III:  CERCLA will not focus its response activi-
                 ties on cleanup of groundwater in this
                 class.

USEPA has recognized in formulating its groundwater protec-
tion strategy that other factors may affect the achievement
of the stated goals.  Consideration of statutory factors
(such as cost-effectiveness and Fund balancing) may require
acceptance of less stringent cleanup levels.  In Class II
cases where the water is a potential rather than an existing
drinking water source, alternative cleanup criteria may be
considered adequate.  In Class II cases where technical fea-
sibility is an issue, providing an alternate drinking water
supply may be an acceptable alternative to restoring the
contaminated aquifer.

2.4.3  EFFECT OF RCRA ON CERCLA REMEDIAL ACTIONS

Although RCRA was not formulated with CERCLA-type remedial
actions in mind, many of the standards applicable to owners
and operators of hazardous waste treatment, storage, or dis-
posal facilities  (TSDF's) such as the Closure Performance
Standard  (40 CFR Part 264.111), the Groundwater Protection
                            2-41

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Standard (40 CFR Part 264.92), and specific facility-type
closure requirements (e.g., waste piles, surface impoundments,
and landfills)  will also help achieve the intent of a CERCLA
remedial action.  All standards seek to minimize or mitigate
release (or continued release) of hazardous substances to
the extent necessary to prevent threats to human health and
the environment.

Guidance and policy statements issued by USEPA generally
require that any hazardous substances generated from CERCLA
remedial actions that would be normally regulated by RCRA,
be managed in accordance with existing RCRA regulations as
well as with the Hazardous and Solid Waste Amendments (HSWA)
made to RCRA in November 1984.  These regulations would apply
to wastes removed from the site for offsite disposal, treat-
ment, or storage as well as any material left in place or
excavated and disposed at an onsite facility.  In addition,
as briefly discussed in Section 2.4.1 of this chapter, Sec-
tion 104 (c) (3)  of CERCLA requires that the offsite disposi-
tion of all "hazardous substances" as defined in Section
101(14) of CERCLA be done at a facility in substantial com-
pliance with Subtitle C (Hazardous Waste Management) of RCRA.

Hazardous substances as defined can include substances and
toxic pollutants designated in Sections 311(b)(2)(A) or 307(a)
of the Clean Water Act, substances designated in Section 102
of CERCLA, any hazardous air pollutants listed under Sec-
tion 112 of the Clean Air Act, any material that the Adminis-
trator  (of USEPA) has acted upon pursuant to Section 7 of
the Toxic Substances Control Act, and any hazardous waste
identified or listed pursuant to Section 3001 of RCRA.

2.4.3.1  Onsite Management of Hazardous Substances

As noted above, CERCLA remedial actions are intended to apply
criteria, standards, policies, and guidance from other environ-
mental statutes in the formulation of remedial action
alternatives.  Further guidance by USEPA requests that all
CERCLA feasibility studies consider at least one alternative
remedial action that would be fully compliant with the RCRA
regulations or standards.  USEPA"s policy for onsite remedial
action involving RCRA-type wastes is to pursue the standards
applicable to owners and operators of hazardous waste manage-
ment facilities  (Section 3004 of RCRA, 40 CFR, Part 264 for
construction of new facilities or 40 CFR, Part 265 for facil-
ities in existence on November 19, 1984, or under interim
status), although a RCRA permit would not be required for
onsite CERCLA activities.  According to RCRA, three different
approaches could be taken to manage or control hazardous
waste, including contaminated soils and groundwater, at a
CERCLA remedial action site:
                            2-42

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     (1)   Close the site as an existing storage unit pursuant
          to 40 CFR, Part 265—Interim Status Standards for
          Owners and Operators of Hazardous Waste Treatment,
          Storage, and Disposal Facilities.

     (2)   Close the site as an existing land disposal unit
          pursuant to the Interim Status Standards of 40 CFR,
          Part 265.

     (3)   Construct a new onsite land disposal facility pur-
          suant to 40 CFR Part 264, Subpart N—Landfills and
          the 1984 Amendments to RCRA.  Closure would also
          be required pursuant to 40 CFR Part 264, Subpart N.

The RCRA Closure Performance Standards applicable to all
regulated facilities (40 CFR Part 265.111 for existing facil-
ities and 40 CFR Part 264.111 for new facilities) state that
the owner or operator must close the facility in a manner
that:

     (1)   Minimizes the need for further maintenance, and

     (2)   Controls, minimizes, or eliminates, to the extent
          necessary to prevent threats to human health and
          the environment, post-closure escape of hazardous
          waste, hazardous waste constituents, leachate,
          contaminated rainfall, or waste decomposition
          products to the ground or surface waters or to the
          atmosphere.

These alternative closure approaches are briefly discussed
in the following sections.

CLOSURE AS A STORAGE UNIT

Although some minor differences exist for closure of specific
types of storage units, the general requirements applicable
to all are that at closure, all waste residues, contaminated
containment system components (if any), contaminated soils,
contaminated structures, and equipment contaminated with
waste or leachate be managed as hazardous waste either by
removal or decontamination.

This removal of contamination or decontamination generally
implies that the specific method should be used on the
waste, contaminated soils, and groundwater until background
levels or de minimus levels are achieved.  De minimus levels
are those levels of contamination that might be deemed
acceptable as a consequence of normal industrial/commercial
activities done at a well managed facility.

If storage facility closure is successfully completed in
accordance with 40 CFR Part 265:
                           2-43

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     (1)  No final cover cap will be required for a closure
          that achieves background levels

     (2)  A cover cap will be required until de minimus
          levels are determined or resolved

     (3)  No post-closure maintenance and care will be
          required               '

     (4)  No land use restrictions will be imposed on the
          property

CLOSURE AS AN EXISTING LAND DISPOSAL UNIT

The closure and post-closure care requirements for existing
land disposal facilities generally include:

     (1)  Installation of a final clay cover cap over the
          waste management area at the time of closure

     (2)  If not already in place, installation of a water
          monitoring system at closure in accordance with
          40 CFR Part 265, Subpart F

     (3)  Monitor and report groundwater quality during the
          post-closure period (30 years)

     (4)  Maintaining the function and integrity of the cover
          cap during the post-closure period

     (5)  Imposition of land use restrictions on future uses
          of the property

     (6)  Providing financial assurance for post-closure
          care of the facility

     (7)  Implementation of corrective groundwater actions
          if a leachate plume migrates from the waste man-
          agement area.

CONSTRUCTION AND CLOSURE OF A NEW LAND DISPOSAL FACILITY

For Western Processing it is assumed that any onsite land
disposal facility constructed would be a landfill.  A de-
tailed description of the design, operating, closure, and
post-closure care requirements for a new landfill facility
is provided in Appendix B of this report.  Given below is a
brief summary of existing requirements as well as additional
requirements that are imposed by the 1984 amendments to RCRA:

     (1)  The facility must meet the Minimum Technology
          Requirements of Section 3004(o)(1)(A)  of RCRA.
          These provisions include the installation of at
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          least two liners with leachate collection above
          and between the liners; and the installation of
          groundwater monitoring, unless otherwise waived
          under Sections 3004 (o)  (2)  or (3).

     (2)   The facility may be required to provide treatment
          of certain wastes.

     (3)   The facility may be subject to the site location
          standards of 40 CFR Part 264.18.

     (4)   The facility would be subject to corrective actions
          beyond the waste management area necessary to pro-
          tect human health and the environment [Sec-
          tion 3004(v) of RCRA].

     (5)   Financial assurance would be required during the
          operating life, closure, and post-closure periods.

     (6)   Closure and post-closure care would be required
          pursuant to 40 CFR Part 264.310.

     (7)   Land use restrictions would be imposed on future
          uses of the property.

     (8)   The facility would be subject to the Groundwater
          Protection Standards of 40 CFR Part 264, Subpart F.

2.4.4  STATE OF WASHINGTON CLEANUP POLICY

As discussed previously in this chapter, a number of criteria
are available to assess what contaminant levels are not con-
sidered harmful to human health or the environment.  Agencies
in several states are considering what standards or criteria
they should use to clean up sites where hazardous substances
have been spilled or released.  The standards, criteria, or
general policies when applied to spills or releases of haz-
ardous substances are referred to as "cleanup policies."
Discussed below is the State of Washington's cleanup policy.

The purpose of the WDOE Final Cleanup Policy  (July 10, 1984)
is to provide a framework to determine the cleanup level for
releases of materials that threaten public health or the
environment.  The cleanup levels derived from this policy
are goals to be used in feasibility assessments for evaluat-
ing the most appropriate remedial action at a site.  The
cleanup levels may be revised on the basis of the feasibility
assessment results.

The Cleanup Policy identifies three types of cleanup levels:
(1) initial cleanup levels,  (2) standard/background cleanup
levels, and  (3) protection cleanup levels.  The purpose of
the initial cleanup level is to eliminate all imminent
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threats to public health and the environment.  Further, it
is intended to eliminate situations where the difficulty of
subsequent cleanup activities will be increased unless a
timely response is initiated.

Standard/background cleanup levels are assigned to those
sites where total cleanup will not be initially implemented.
The purpose of the standard/background cleanup is to elimi-
nate any potential long-term threat to public health or the
environment.  The standard/background cleanup levels are
based on appropriate water quality and air quality standards.
If standards do not exist, background levels are specified.
The technical feasibility of achieving standard/background
cleanup levels is determined in a preliminary technical as-
sessment.  If, on the basis of this assessment, the standard/
background cleanup levels are judged not to be achievable or
appropriate, then protection cleanup levels are assigned to
the site.

Protection cleanup levels are based on: (I) multiples of
appropriate standards or background levels (for soil with a
threat to surface water or groundwater), (2)  dangerous waste
limits (for soil with a threat to air), or (3) site-specific
characteristics.  Predictive modeling may be used to define
protection levels if sufficient site-specific information is
available.

The Western Processing site cleanup would be expected to
fall under the category of standard/background cleanup lev-
els.  If these standards were judged not to be achievable,
the protection cleanup levels would be assigned to the site.
Shown in Table 2-6 are the standard/background cleanup
levels for soil, water, and air.

The following parameters are considered in preparing the
preliminary technical assessment:

     o    Presence of sole-source aquifers

     o    Barriers to contaminant migration and degree of
          natural protection

     o    Sorptive properties of the soil and/or aquifer

     o    Contaminant mobility

     o    Depth to groundwater

     o    Groundwater and surface water existing and poten-
          tial use, quality, and quantity

     o    Occurrence of volatile contaminants (air)
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          Susceptibility to wind erosion or re-entrainment
          (air)

          Availability of alternative water supplies
                          Table 2-6
     WASHINGTON STATE STANDARD/BACKGROUND CLEANUP LEVELS

A.   Soil

     1.   10 times appropriate drinking water or water qual-
          ity standard, or

     2.   If no standard exists, 10 times water quality
          background, or

     3.   If water quality background is not detectable,
          soil background.

B.   Groundwater and Surface Water

     1.   Appropriate drinking water or ambient water quality
          standard, or

     2.   If no standard exists, background.

C.   Air

     1.   OSHA/WISHA limits for air quality over the site
          prior to backfilling, or

     2.   Ambient air quality standards at the site bounda-
          ries prior to backfilling, or

     3.   If no standards exist, background
If this assessment indicates that the standard/background
level is achievable and appropriate, it is used to evaluate
the alternative remedial actions in the feasibility
assessment.

As noted previously, if it is concluded in the preliminary
technical assessment that the standard/background level is
not achievable or appropriate, protection cleanup levels
must be defined for the site.  Protection cleanup levels for
soil, groundwater and surface water are defined using one of
the methods shown in Table 2-7.
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                              Table 2-7
        WASHINGTON STATE  PROTECTION  CLEANUP  LEVELS


A.   Soil protection level where a threat to water  quality exists

     1.   100 times the appropriate water quality standard, or

     2.   100 times water quality background, or

     3.   10 times soil background, or

     4.   Defined based on site-specific contaminant and  soil character-
          istics, leaching tests, biologic test, etc.   If sufficient
          data are available predictive models may  be  used to define
          protection levels as follows:

          a.   Define the maximum acceptable level  of  contamination in
               the groundwater directly underlying  the contaminant
               source using:

               1)   The appropriate water quality standards or water
                    quality background, or

               2)   Biologic testing, or

               3)   The groundwater protection level (defined below)

          b.   Define the maximum acceptable concentration gradient with
               verified and calibrated  transport models using site-
               specific contaminant, hydrologic, and soil characteristics.
               The concentration gradient is used to determine the soil
               protection level, the maximum acceptable concentration of
               soil contamination at the source.

B.   Soil protection level where a threat to air quality  exists

     1.   Dangerous waste limit using equivalent concentration for LC
          (inhalation)  = .001 percent,  or

     2.   Dangerous waste limit for respiratory  carcinogens

C.   Groundwater and surface water protection levels

     Defined based on site-specific information  such as contaminant mi-
     gration characteristics, site geology and hydrology, leaching tests,
     biologic tests, etc.  If sufficient data are available, predictive
     models may be used to define protection levels as follows:

     1.   Identify existing and potential receptors; then

     2.   Define an acceptable concentration for the receptors using the
          appropriate water quality standards, background, or biologic
          tests; then

     3.   Define the maximum acceptable concentration  in  the groundwater
          or surface water using site-specific characteristics in veri-
          fied and calibrated contaminant transport models.
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        2.5  SUMMARY OF CRITERIA USED IN THIS REPORT

Table 2-8 is a summary of the criteria compiled in this
chapter that will be used in later chapters of this report.
Other intended uses of these criteria include:

     o    A frame of reference for discussing the nature and
          extent of contamination  (Chapter 3)

     o    A basis for evaluating risks associated with the
          site (Chapter 4)

     o    A basis for evaluating the technical feasibility
          of some remedial alternative components (Chapter 6)

In addition, the criteria will help to provide a conceptual
basis for the eventual selection of a preferred remedial
action alternative or combination of alternatives by USEPA
and WDOE.
                            2-49

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                                                         Table  2-8
                                  CRITERIA FROM  TABLE 2-1 USED  IN OTHER CHAPTERS
NJ
I
Ul
o
   Chapter/Medium

Chapter 3/Soils


Chapter 3/Groundwater



Chapter 3/Surface Water



Chapter 4/Soils



Chapter 4/Groundwater


Chapter 4/Surface Water
                                                 Criteria Used
                                     Soil background values
                                     Cancer risk  criteria, aquatic life
                                     criteria
                                     Cancer risk  criteria, aquatic life
                                     criteria
                                     Cancer potencies, allowable daily
                                     intakes
Cancer potencies,  allowable daily
intakes

Cancer potencies,  allowable daily
intakes, aquatic life criteria
                                    Ambient Water Quality
                                    Air quality criteria
        Chapter 7/A11 Alternatives   Ambient water quality criteria
Chapter 7/Groundwater
  Treatment
                                                       Purpose
Describing the distribution of
contaminated soil

Description of the distribution and
degree of contamination of
groundwater

Description of the distribution and
degree of contamination of surface
water

Determination of human health
endangerment through ingestion,
inhalation, and dermal contact

Determination of human health endan-
germent through ingestion

Determination of human health endan-
germent through ingestion Determina-
tion of endangerment to aquatic and
terrestrial life

Applied as discharge criteria to
evaluate feasibility of discharge to
Mill Creek

Technical evaluation of groundwater
treatment system

Used as a general frame of reference
and goal for evaluating the
effectiveness of the alternatives
         Aquatic life criteria were  used  to describe the distribution of contaminated groundwater because discharge
         of contaminated groundwater to Mill Creek, and resulting threats to aquatic life, is a major environmental
         impact associated with the  Western Processing site.

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                          Chapter 3
             NATURE AND EXTENT OF CONTAMINATION
                     3.1  INTRODUCTION

This chapter presents the conceptual model of the ground-
water and surface water flow system and summarizes contami-
nation data collected at Western Processing during past
investigations.  The nature, extent, and sources of contami-
nation will be delineated within the framework of the pres-
ently identified migration pathways.  Data limitations will
also be discussed where the available information is inade-
quate for definition of the nature, extent, or source of
contamination.

The soil and groundwater contamination are summarized in
Sections 3.5.3 and 3.6.3.  An overall summary of the nature
and extent of contamination is provided in Section 3.9.

              3.2  HISTORY OF DATA ACQUISITION

Hydrogeologic, surface water, soils, and contamination data
have been collected at Western Processing during numerous
investigations by several companies and governmental agen-
cies.  Figure 3-1 presents a chronology of these activities.
The sampling locations from these investigations are illus-
trated on Plates 1, 2, and 3 located in pockets at the back
of this report.  A brief summary of each investigation is
provided in the Remedial Investigation Data Report (CH2M
HILL, December 1984).  Documents 1, 2b, 3, and 8 in Fig-
ure 3-1 are included in the appendixes of the Remedial
Investigation Data Report.  Copies of all reports in Fig-
ure 3-1 are available to the public through the USEPA.

         3.3  GROUNDWATER/SURFACE WATER FLOW SYSTEM

3.3.1  REGIONAL GEOLOGY

Western Processing is located near the north-south axis of
the Duwamish  (Kent) Valley, a former erobayment of Puget
Sound.  The east and west margins of the valley are defined
by a dissected drift plain with elevations 350 to 600 feet
above the valley floor.  The valley is partially filled with
a sequence of recent alluvial and lacustrine deposits.  These
deposits are typically fine- to medium-grained sand, silt,
peaty silt, and clay.  The average depth to bedrock is es-
timated to exceed 500 feet  (Luzier, 1969) .

Five major geologic units comprise the hydrogeologic system
in the vicinity of Western Processing  (Hart-Crowser, 1984).
These units are shown in plan view and cross-section in Fig-
ures 3-2 and 3-3.  From youngest to oldest, the geologic
units include:


                            3-1

-------
            Document or Unpublished Data
       Soil, Groundwater, and Surface Water
          Contamination Data
       1.
       2a.
       2b.
OJ
 I
to
3.
       4.
       5.
         Municipality of Metropolitan
         Seattle (Metro).   Ramix II Data
         Base System.  Surface Water
         Quality Data Collected Along Mill
         Creek.   1977 to 1981.
Washington State Department of
Ecology.  Miscellaneous Water
Quality Data for Mill Creek and
Vicinity.  (unpublished)

Washington State Department of
Ecology.  Storett Data Base.
Monthly Ambient Water Quality
Sampling program, Mill Creek
Sampling Sites.  No. 09E090 and
No. 09E070.

U.S. Environmental Protection
Agency, Region X.  Report o_f
Western Processing Vicinity
Survey.  May 20-21, 1982.
Published June 1982.

U.S. Environmental Protection
Agency, Region X, Environmental
Sources Division.  Investigation
of Soil and Water Contamination at
Western Processing, King County,
Washington, Parts I and II.
                                                 Sampling
                                                 Location
                                        Mill Creek
                                                                                              Chronology
                                                 Mill Creek
                                                 Mill Creek
Mill Creek
                                                 On Property
                1983.
                                             May
                U.S. Environmental Protection
                Agency, Region X.  News Release on
                Groundwater Contamination Data.
                September 26, 1983.
                                                 On Property
1977 1981 1982 1983 1984 1985
Jai

\ 1 Ja


n 1 Ja


n 1 Ja
•MM
n 1 Ja
-*
"™""A
n 1 Ja
nl
       Legend
                Indicates data collected but unavailable for publication in this document.
                Indicates date of published report.
                Indicates period of investigation activity.
                Indicates period of sample analysis and report preparation.
                                                                                             FIGURE 3-1
                                                                                             CHRONOLOGY OF INVESTIGATION
                                                                                             ACTIVITIES AT WESTERN PROCESSING
                                                                                             HAZARDOUS WASTE SITE

-------
           Document or Unpublished Data
      6.
      7.
      8.
      9.
OJ
I
U)
      10.
      11.
      12.
 CH2M  HILL.   Interim  Offsite
 Remedial  Investigation  Report.
 Western Processing,  Kent,
 Washington.  Prepared for EPA
 WA  37-OL16.0.' October  1983.

 U.S.  Environmental Protection
 Agency, Region X.  Western
 Processing Alternatives Assessment
                          April
 U.S. Environmental Agency,
 Region X, Environmental Services
 Division, Field Operations and
 Technical Support Branch.  Water
 Quality Data  for Mill Creek Survey.
 January 1984.

 U.S. Environmental Protection
 Agency.  Memorandum from
 Spencer A. Peterson, Hazardous
 Materials Assessment Team, to Bob
 Courson, Region X, Environmental
 Services Division.  Preliminary
 Bioassay Results on Western
 Processing Samples Submitted to
 CERL.  No date.

Miller, W., S. Peterson, J.G.
Greene, and C.A. Callahan.  Draft
 Report.  Comparative Toxicology of
Hazardous Waste Site Bioassessment
Test Organisms.  USEPA, Corvallis
Environmental Research Laboratory,
Corvallis, Oregon.  September
 1984.

Schmidt, C.E., R. Vandervort.
Summary of the Nature and Extent
of Contamination Present on
Standard Equipment, Inc.  Property
in Kent, Washington.Radian Cor-
poration,  Sacramento, California.
October 1984.

Dames & Moore and Landau Associ-
ates.  Western Processing Remedial
Action Plan, Phase II:  Subsurface
Cleanup.  Volumes 1, 2, and 3.
September 24, 1984.
Sampling
Location

Off Property
                                                       Off Property
                                                       Mill Creek
                                                       On Property and
                                                       Off Property
                                                       On Property  and
                                                       Off Property
                                                       Off Property
                                                       NA
Chronology
1977 1981 1982 1983 1984 1985
Ja





nl Jai





i 1 Ja





n 1 Ja





n 1 Ja
"A
,




n 1 Ja
i
A
A
"""A
— A
il





                                                                                                        FIGURE 3-1 (CONTINUED)

-------
           Document or Unpublished Data
      Hydrogeological Data
      1.
OJ
 I
Ecology and Environment, Inc.
Memorandum from Steve Testa and
Katherine Lombardo to John Osborn,
EPA.  Installation of Four
Groundwater Monitoring Wells,
Western Processing Company, Kent,
Washington.  TDD RIO-8302-03.
(DW-31 through DW-34.)  June 8,
1983.

Bond, F.W., et al.  Application of
Groundwater Modeling Technology
for Evaluation of Remedial Action
Alternatives, Western Processing
Site, Kent, Washington.  Prepared
by Battelle Project Management
Division.  September 1984.

Hart Crowser and Associates, Inc.
Final Report Hydrogeologic
Assessment, Western Processing,
Kent, Washington.  Prepared  for
GCA Technology Division, Bedford,
Massachusetts.  EPA
No. 68-01-6769.  October 16, 1984.

Dames & Moore and Landau Associ-
ates.  Western Processing Remedial
Action Plan, Phase II;  Subsurface
Cleanup.  Volumes 1, 2, and  3~
September 24, 1984.
                                        Sampling
                                        Location
Off Property
                                                       NA
                                                       NA
                                                        NA
       Note:  NA = Not applicable.
Chronology
1977 1981 1982 1983 1984 19H5
Jar


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A
A
"'A
i 1


                                                                                                        FIGURE 3-1 (CONTINUED)

-------
                                                                     WESTERN
                                                                     PROCESSING*
          Recent White River and Older White River/Green River Alluvial Deposits
          Valley  deposits consisting predominantly of Interbedded Sand, Silt, Peat and Clay near
          the Western Processing Site. Includes coarse Sand and Gravel river channel deposits
          in other areas of the valley.

          Vashon Undifferentiated Glacial Deposits
          Surficial glacial sequence on the uplands consisting of Till and Outwash Deposits of
          Sand and Gravel with interbedded Silt and Clay, may include non-glacial deposits near base.

          Salmon Springs  Glacial Deposits
          Deeper glacial sequence in uplands consisting of Sand and Gravel with interbedded Silt,
          Clay, Till and some non-glacial sediments. Outcrops along flanks of the valley.

          Bedrock of Puget Group
          Consists of interbedded Sandstone, Shale and Coal occurring at depth in the uplands
          on the eastern side of the valley and outcropping near the city of Renlon.
From Hart Crowser, August 1984.
       Regional Ground Water
       Flow Direction Trends
                4000
Scale in Feet
8000
                                                                   3-5
            FIGURE 3-2
            REGIONAL GEOLOGY MAP
            WESTERN PROCESSING
            Kent, Washington

-------
                             WEST

                           600  r


                           400


                           200
                                                                                                                                                             EAST
                    0)
                    u.
                      o   -200

                      03

                      CO
 OJ
  I
 CTi
                         -400
                         -600
                         -800
                       -1000
                                                                                                   i
                                                          Qvu
                                                                                                                              Qvu
C3
\ " 'HI
\
\
\,
oo _!
rr
c
Qaw

)

3 •/
, fr~n77~i
wfa
^ Qou

2i
^

                                                                                                                                             /       Tp
                                                                                                                                         /
                                                                                                                        Tp
                                 Note:  The  stratum lines are based upon interpolation between wells
                                         and  may not represent actual  subsurface  conditions.	
                                                                                                                                                                    600
                                                                                                                                                                    400
                                                                                                                                                                    200
                                                                                                                                                                   -200
                                                                                                                                                                   -400
                                                                                                                                                                   -600
                                                                                                                                                                   -800
                                                                                                                                                                 -1-1000
                                                                                                                                 SECTION LOOKING NORTH
         Recent While River and Older White River/Green River Alluvial Deposits
         Valley deposits consisting predominantly of interbedded Sand. Sill, Peat and
         Clay near (he Western Processing Slle. Include coarse Sand and Gravel
         channel deposits In other areas ol the valley.

         Vashon Unditferentiated Glacial Deposits
         Surllclal glacial sequence In ihe uplands consisting ol Till and Ouiwash
         deposits ol Sand and Gravel with Interbedded Silt and Clay, may Include
         non-glacial deposit.

         Salmon Springs Glacial Deposits
         Deeper glacial sequence In the uplands consisting ot Sand and Gravel with
         Interbedded Silt, Clay.Till and some non-glacial sediments. Outcrops along
         flanks of the valley.

         Older Undifferentiated Glacial and Interglacial Deposits
         Deeper unconsolldated deposits In the uplands consisting ol Sand and Gravel
         wllh Interbedded SIM,Clay and Till.

         Bedrock of the Puget Group
         Consists ol interbedded Sandstone, Shale and Coal occurring at  depth In
         the uplands on Ihe eastern side ol Ihe valley and outcropping near
         the city ol Renton.

From Hart Crowser, August 1984.
T   Well Location
    Water Level


    Screen Section


    Aquifer Zone
                                                                                                                                           Horizontal Scale  in Feet
                                                                                                                                           Q               4000
                                                                                       8000
Qou
                                                     0                400
                                                     Vertical Scale in Feet
                                                     Vertical Exaggeration x10
                                                                                                                                                                              oUU
 Tp
                                                                                                                                                         FIGURE 3-3
                                                                                                                                                         REGIONAL GEOLOGIC
                                                                                                                                                         CROSS SECTION
                                                                                                                                                         WESTERN PROCESSING:
                                                                                                                                                         Kent, Washington

-------
1)    White River Alluvium (Qaw)  is a collective designation
     for the valley fill deposits that occur throughout the
     Kent Valley and beneath the Western Processing site.
     The alluvium consists predominantly of sand, silt, and
     clay with occasional layers of sandy gravel to depths
     of over 360 feet in the site vicinity.  Typically the
     upper 20 to 50 feet contain more discontinuous lenses
     of silt, clay, and peat, especially in the Western Pro-
     cessing area.

     White River alluvium is not considered to be a major
     groundwater source in the Kent area because of its rel-
     atively low permeability and poor water quality.  Many
     of the wells for which data are available indicate a
     sulfur odor, natural gas (methane), and/or high iron
     levels in the water (Luzier, 1969; Table 9).  The avail-
     able well capacity data indicate well yields are gen-
     erally less than 100 gallons per minute.  In addition,
     the electrical conductivity of water samples taken from
     offsite monitoring wells (Wells 35 to 44) shows a sig-
     nificant increase with depth from approximately
     250 vimhos/cm above 50 feet to over 1,000 ymhos below
     roughly 100 feet (CH2M HILL, April 1984; Table 3).

2)   Vashon Glacial Deposits (Qvu) comprise the surficial
     deposits of the upland areas and are estimated to be
     roughly 100 to 200 feet thick.  The deposits generally
     consist of recessional sand and gravel outwash near the
     surface overlying a significant thickness of dense till
     that in turn overlies advance outwash sand.  Many wells
     penetrate the sand and gravel layers within these de-
     posits in the west upland area, primarily for domestic
     water supply.  However, the deposits appear to be large-
     ly unsaturated in the east upland area.  The Vashon
     deposits lie well above sea level and the existing val-
     ley floor.

3)   Salmon Springs Drift (Qss)  occurs below the Vashon de-
     posits and flanks the valley wall on both the east and
     west sides.  The Salmon Springs contains significant
     zones of sand and gravel that form a major aquifer
     tapped by many deep wells in the upland areas.  The
     Salmon Springs occurs predominantly above sea level
     with the base approximately at or near the elevation of
     the valley floor.

4)   Older Undifferentiated Glacial and Interglacial  (Qou)
     deposits lie below the Salmon Springs and consist of
     thick sequences of low permeability silt and sand with
     layers of more permeable sand and gravel.  A deep sand
     and gravel layer occurs between roughly 100 and 200 feet
     below sea level  (Figure 3-3).  This zone is tapped by
     two King County Water District No. 75 wells (not shown)
     in the east upland area and is the principal aquifer


se9997a2                     3~7

-------
     tapped by the City of Kent.  This aquifer probably does
     not extend across the valley as evidenced by deep wells
     that penetrate into valley alluvium below this eleva-
     tion, and as supported by the erosional glacial history
     of the valley.

5)    Bedrock of the Puget Group (Tp) forms the base of the
     unconsolidated glacial and non-glacial deposits.  The
     bedrock crops out at the north end of the valley, and
     along the northeastern valley wall, and occurs at a
     depth of approximately 300 feet in the east upland area.
     The bedrock is estimated to lie at a depth greater than
     800 feet below the existing valley floor.  The bedrock
     does not yield significant quantities of good quality
     water to wells in the area.

3.3.2  REGIONAL GROUNDWATER FLOW

The regional groundwater flow system in the Kent valley is
characterized by recharge within the uplands and discharge
to the Green River.  The principal regional groundwater flow
directions are illustrated in Figure 3-2.

Recharge from precipitation is estimated to average between
approximately 7 to 9 inches per year in the area (Hart-
Crowser, 1984).  In the uplands, infiltration flows downward
under the influence of gravity to the saturated zone.  Once
in the saturated zone, groundwater flows through the more
permeable layers both downward and laterally towards ground-
water discharge points within the system, such as streams
and springs.  Downward vertical flow in the uplands is in-
dicated by water levels that show a decline in the static
head with depth.  This is illustrated in Figure 3-3 where
well water levels decline with depth.  Horizontal flow
towards the Kent Valley is indicated by water levels of
wells completed  (at similar elevations) in both the Salmon
Springs and the Older Undifferentiated deposits.

In the valley, the horizontal and vertical flow directions
are typical of a groundwater discharge area with upward ver-
tical hydraulic gradients.  The Green River is the primary
discharge outlet of the regional hydrogeologic system.  Other
surface water drainages such as Mill Creek influence local
shallow groundwater flow.  Groundwater flow in the valley is
generally to the northwest toward the Green River as shown
in Figure 3-2.  The regional horizontal flow gradient is
about 0.002.

3.3.3  SITE HYDROGEOLOGY

Western Processing has been the subject of numerous field
investigations.  Hydrogeologic data were collected during
soil boring drilling and installation, testing, and sampling
of groundwater monitoring wells.  The locations of these


                            3-8

-------
borings and wells are shown on Plates 2 and 3.  Data were
first collected by USEPA during the installation of 30 wells
(numbers 01-30), at Western Processing in September to Novem-
ber 1982 (USEPA, May 1983).  Additional data were collected
when the USEPA authorized  the installation of four cluster
wells (numbers 31 S and D  to 34 S and D) adjacent to Western
Processing in April to June 1983  (Ecology and Environment,
June 1983).  CH2M HILL collected hydrogeologic data during
the interim offsite remedial investigation  (CH2M HILL, Octo-
ber 1983 and April 1984),  which involved the installation
and sampling of 10 wells near Western Processing (numbers 35
to 44).  CH2M HILL obtained additional hydrogeologic data
during installation of three deep onsite wells (MB-01, 02,
and 03), one deep well south of the site (DB-01), 23 soil
borings adjacent to Western Processing  (SB-01 to -20, IB-01
to -03), and eight shallow piezometers  (PB-01 to -08) during
the summer 1984 remedial investigation  (CH2M HILL, Decem-
ber 1984).  Hart-Crowser included the results of these and
other reports in summarizing the hydrogeology of the Kent
valley and vicinity  (Hart-Crowser, October 16, 1984).

3.3.3.1  Site Geology

White River alluvium underlies the Western Processing site
as shown in Figures 3-2 and 3-3.  The alluvium consists of
a complex sequence of discontinuous interbedded silt, sand,
and clay lenses to approximately 40 feet below the ground
surface.  A fairly continuous fine to medium sand with in-
termittent silty zones exists below 40  feet.  Figures 3-4
and 3-5 are north-south and east-west cross-sections across
Western Processing that illustrate the complex nature of the
near  surface sediments.

Logs  from deeper wells in  the site vicinity  (Wells 31, 32,
and 34) indicate that the  sand unit extends to more than
150 feet.  A deep well  (DB1) completed 2,500 feet south of
Western Processing showed  that sand and silt extend to a
depth of approximately 150 feet.  Beyond this depth, dense
clay  and silt were found to extend to at least 365 feet be-
low the ground surface.

Figure 3-6 is a schematic  geologic column showing the three
major hydrogeologic units  that underlie the Western Process-
ing site.

3.3.3.2  Site Hydraulic Conductivity

Slug  tests and short-term  pumping tests were conducted at
nine wells to estimate the hydraulic conductivity of sedi-
ments underlying Western Processing  (Wells 31, 34, 36, 37,
38, 39, 40, 43, and 44).   Hart-Crowser  (October 16, 1984)
summarized the results of  these tests.  Hydraulic conduc-
tivities in the shallow  «40 feet) silt, sand, and clay range
                             3-9

-------
from less than one to 10 feet per day  (3 x 10~  to
3 x 10   cm/sec).   Tests on wells screened in the lower sand
unit yield hydraulic conductivities of from 10 to 100 feet
per day  (3 x 10   to 3 x 10   cm/sec).

3.3.3.3  Site Groundwater Movement

Groundwater movement near Western Processing is influenced
by four primary factors:

     o    Regional groundwater flow toward the Green River
          with an upward flow component

     o    Groundwater recharge and mounding onsite with a
          downward flow component

     o    Discharge to Mill Creek and the east drain
          (Note:   The east drain is between the jogging
          trail and the railroad to the east of the site.
          See Figure 1-4 for locations).

     o    Hydraulic conductivity (including horizontal to
          vertical ratios)

Local groundwater flow patterns within the upper 100 feet
 (shallow groundwater system) are complicated because of the
hydraulic effects of Mill Creek and the east drain and the
complex  stratigraphy (discontinous silt and clay lenses in
the upper 40 feet).

Groundwater elevation data have been obtained from monitor-
ing wells on and off the property since November 1982.  These
data are summarized in Table 3-1.  Seasonal water level vari-
ations are at least four feet as shown.  The highest levels
occur during spring and the lowest during early fall.  This
pattern  is consistent with precipitation and stream flow
data for the Kent valley.

Figures  3-7 and 3-8 are groundwater contour plots based on
data from shallow wells  (less than 20 to 30 feet).  The plots
show that Mill Creek and the east drain are local ground-
water discharge areas or sinks.  Shallow groundwater should
not flow beyond these sinks.  The groundwater depression
east of  the site shown in Figure 3-7 is the result of dis-
charge to the east drain.  The computer generated contours
are closed to the north because there are no water table
elevation data north of the site on the east side.

Groundwater influx to Mill Creek is probably on the order of
0.5 cubic foot per second  (cfs), based on summertime base
flows.  Flow from the site to the creek should be less than
50 percent of this value, probably on the order of 25 per-
cent based on flow net analysis using Figure 3-8.  This is
                            3-10

-------
   30
           SOUTH
                                                                                                                                                                                                  NORTH
                                                                                   -WESTERN PROCESSfNG-
   2(H
   10 -4

-------
 WEST


30-1
                                                                                                                                                                                     EAST
                                                                                                                        WESTERN PROCESSING
20-t
10 H
o
<
ui
_j
HI
-10 -i
-20 H
-30 H
-40 H
-50-J
           IB-3 (El. 23.93')
                     rpitmv:
                     ISM/ML
                                                                                                                                                                          84-2 (El.-25.0')
                                                                             P-l (EI.-25.0')
  APPROXIMATE GROUND SURFACE     17 (El. 22.0)


ML/CL
                                                            DW-34 (El. 20.78')

                                                                                                                                                                          Silt, Sand and Clay
                                                                                                                                                                          Combinations
                                 DI
                               "«"!,«              c
                           SP  = Well Sorted Sands, Few Fines
                           SM  =SiltySand
                           ML  = Sandy Silt, Silt
                           CL  =SiltyClay
                           Pt  =Peat
                           OH  = Organic Silts and Clays
                                                                                                                                                                     Clayey Silt

                                                                                                                                                                     Silty Clay
                                                                                                                                                                   \ffmK  Peat, Silt and Clay
                                                                                                                        SM/ML  = Primary Constituent/
                                                                                                                                  Secondary Constituent
                                                                                                                 P- I (El.~25.0'|  = Boring Number and Surface    lI'ffiKt'lr Combinations
                                                                                                                                  Elevation                      '
                                                                                                                                                                     Peat and Silty Peat
                                                                                                                            NOTE: Data For Boring Logs P-1 and 84-2
                                                                                                                                  Were Provided by Dames and Moore.
                                                                                                                                                                         3-13
                                                                                                                                                                                                   FIGURE 3-5
                                                                                                                                                                                                   EAST/WEST CROSS SECTION
                                                                                                                                                                                                   MIDDLE OF SITE
                                                                                                                                                                                                   WESTERN PROCESSING
                                                                                                                                                                                                   Kent, Washington

-------
                      DISCONTINUOUS LENSES OF SILT
                      CLAY,AND SAND.
                      Kh=1 T010FT./DAY?
  40 FT.
                       FINE-MEDIUM SAND WITH
                      ; DISCONTINUOUS SILT LENSES.
                      'Kh=10TO 100FT./DAY
150 FT.
                         DENSE CLAY AND SILT
                         «h=10-2 FT./DAY
                              (estimated)
                          3-15
FIGURE 3-6
SCHEMATIC GEOLOGIC SECTION
WESTERN PROCESSING
Kent, Washington

-------
                                                   Table 3-1
                                    GPOUNDWATER LEVEL ELEVATION  DATA
                                WESTERN PROCESSING,  KENT, WASHINGTON
                  Depth of
       Drilled    Screened
Static Water Level Elevation
 (feet above mean sea level)













OJ
1
I—1
en










Well
a
No.3
IS
ID
2
3
4
5
6
7
8
9
10
US
11D
12
13
14
15
16
17S
17D
18
19
20
21
Depth
(ft)
12
30
15
12
15
15
15
15
16
15
15
12
30
15
9
15
16
15
15
30
16
12
15
15
Interval
(ft)
Top Bottom
9
27
8.5
8.5
11.5
8.5
8.5
8.5
13
11.5
11.5
9
26
7.5
2.5
11.5
13
11.5
12
27
13
2.5
11.5
11.5
12
30
11.5
11.5
14.5
11.5
11.5
11.5
16
14.5
14.5
12
29
10.5
5.5
14.5
16
14.5
15
30
16
5.5
14.5
14.5
November
1982
13.55
12.86
14.37
18.35
12.37
15.17
14.19
14.59
13.39
11.35
12.09
14.83
12.94
14.10
11.91
—
15.29
13.73
16.39
12.72
15.86
14.35
15.88
12.80
May
1983
15.19
14.40
15.65
19.41
13.76
16.62
15.79
16.26
15.28
12.21
12.50
16.53
14.97
15.72
13.70
—
17.24
13.69
18.20
14.57
18.25
—
17.23
15.24
October
1983
12.59
12.47
13.14
18.38
11.95
14.46
13.37
13.75
—
—
13.25
14.06
12.57
Destroyed
—
14.55
Destroyed
Destroyed
15.86
12.77
15.84
—
14.13
12.80
March
1984
15.33
15.34
15.14
18.73
13.71
16.80
15.52
16.42
16.25
12.60
12.92
17.16
16.14
—
13.64
16.63
—
—
18.81
15.62
17.80
14.94
18.87
12.29
April
1984
15.02
15.51
14.98
18.36
13.34
15.92
15.27
15.96
16.87
11.80
16.92
17.25
16.14
—
13.27
16.55
—
—
19.73
15.45
17.80
14.64
18.45
16.31
May
1984
14.52
14.84
14.06
18.19
12.34
15.23
14.52
14.71
15.04
11.64
Dry
16.31
15.39
—
12.58
15.55
—
—
19.96
15.14
17.60
14.10
17.79
15.85
July
1984
13.75
13.78
13.48
17.94
11.77
14.54
13.90
14.31
14.25
10.88
Dry
15.41
13.97
—
11.69
14.55
—
—
18.40
13.91
16.65
12.69
16.62
13.68
December
1984
13.77
15.34
14.56
18.56
12.72
15.38
14.44
14.63
—
13.18
—
15.33
15.72
—
—
14.55
—
—
17.43
14.29
16.72
—
18.37
14.56
aWell locations are shown on Plate  2.

 Data sources are as follows:
    1.  For November 1982 and May 1983:  USEPA Region X,  Investigation of Soil and Water Contamination at
        Western Processing, King County, Washington,  September to November,  1982, Parts 1 and 2, May 1983.
    2.  For October 1983, March 1984, April 1984, May 1984, July 1984, December 1984:  USEPA Region X,
        Environmental Services Division, Field Operations and Technical Support Branch, Summary of Hydrogeologic
        Files on Static Water Levels in Wells at Western  Processing, Kent, Washington.

-------
                                                        Table 3-1
                                                       (continued)
                           Depth of
                 Drilled    Screened
Static Water Level Elevation
 (feet above mean sea level)
u>
Well
No.a
222S
22D
23
24
25S
25D
25C
26
7
28
29
30
31S
31D
32S
32D
33S
33D
34S
34D
35
36
37
38
39
40
41
42
43
44
Depth
(ft)
15
30
16
15
16
30
12
15.5
12
12
12
15
165
165
30
156.5
145.5
145.5
181.5
181.5
140
100
100
120
96
100
135
100
100
100
Interval (ft)
Top
12
23.5
12
11.5
13
23
9.5
12.5
8.5
8.5
8.5
8.5
45
130
18
96
28
55
52
124
55
74
75
35
20
20
75
50
15
15
Bottom
15
26.5
15
14.5
16
26
12
15.5
11.5
11.5
11.5
11.5
55
140
28
106
38
65
62
134
75
94
95
55
40
40
95
70
35
35
November
1982
13.90
13.77
14.05
13.34
13.81
13.85
—
14.48
14.51
—
—
—
—
—
—
—
—
—
—
—
	
	
—
__
	
	
__
_ _
_.
— —
May
1983
15.68
14.72
16.30
16.17
16.03
15.89
—
16.13
15.13
12.46
15.01
—
—
—
—
—
—
—
—
—
__
	
—
—
__
	
	
__
__
— —
October
1983
Destroyed
Destroyed
15.38
13.26
13.57
13.70
—
Destroyed
—
—
—
—
11.39
13.83
—
14.15
13.93
15.54
12.43
13.36
13.77
13.12
13.95
12.29
13.63
13.39
13.40
13.27
13.36
15.20
March
1984
^^_
—
18.32
17.74
Destroyed
Destroyed
—
—
16.25
—
14.35
—
17.90
—
15.32
—
16.25
—
16.05
Inaccessible
c
c
c
15.32
c
c
c
c
c
c
April
1984
__
—
18.32
17.41
—
—
—
—
16.50
11.64
14.43
—
16.07
17.24
15.49
17.49
15.99
18.67
16.13
18.07
17.55
17.39
17.64
15.41
17.68
18.02
17.31
17.59
17.74
19.47
May
1984
„
—
17.86
16.45
—
—
—
—
—
11.55
14.45
—
15.57
16.97
14.92
18.37
15.45
18.01
15.32
17.29
16.88
16.43
17.16
14.99
16.99
17.00
16.62
16.61
17.01
18.64
July
1984
__
—
16.61
15.24
—
—
—
—
—
10.88
13.43
—
14.01
13.66
13.88
15.89
15.70
16.80
14.25
16.08
15.57
14.01
15.89
13.89
15.64
15.53
15.31
15.24
14.37
16.14
December
1984
._
—
17.45
15.70
—
—
—
—
—
--
—
—
—
—
—
—
—
—
—
—
—
__
—
—
__
__
__
—
__
--
         "Water level indicator would not fit into well.

-------
                                                        Table  3-1
                                                        (continued)
I
!-•
CD
                            Depth of
                 Drilled    Screened
               Static Water Level Elevation
                 (feet above mean sea level)
Well
No.3
MDB-01
PB-01
PB-02
PB-03
PB-04
PB-05
PB-06
PB-07
PB-08
MB-01
B-02
MB-03










Depth
(ft)
365
—
—
—
—
—
—
—
—
100
60
100










Interval (ft) November May October
Top
140
14
14
14
14
13
12
12
14
75
35
6
14
21
28
36
41
54

66
75
90
Bottom 1982 1983 1903
150
16
16
16
16
18
14
14
16
95
55
12*
19*
26
33*
38*
51*
62*
d
73°
87*
100
March April May July
1984 1984 1984 1984
18.03
15.88
13.89
12.71
19.96
11.56
16.39
16.93
18.26
15.32
15.45
19.11
15.01
16.71
16.51
15.91
15.61
16.51

16.71
16.81
-- ' 16.41
December
1984
__
—
—
—
—
—
—
—
—
--
—
—
—
__
__
—
WH
__

— —
__
--
           MB-03 is  a West Bay multiple port well.
           sampling  port.
The depth range  represents the length of sand pack at each

-------
                WESTERN PROCESSING
                      SITE
             500
   Scale in Feet
From Battelle,1984.
NOTEfTHE AREAL EXTENT OF THE GROUNDWATER
    DEPRESSION EAST OF THE SITE IS AN ARTIFACT
    OF THE CONTOURING PROCESS.
                                     3-19
Groundwater Flow Direction

FIGURE 3-7
COMPUTER GENERATED
GROUNDWATER ELEVATION
CONTOURS
WESTERN PROCESSING
Kent, Washington

-------
 ,—".— . South 96th Street
        WESTERN PROCESSING
                SITE
                                                                                        16.4  Water Level Elevation in Feet

                                                                                        (13.6) Water Level Elevation in Feet
                                                                                            CCorrected for Upward Gradient)

                                                                                        •"» Water Level Elevation Contour
                                                                                            in Feet
                                                                                            Ground water Flow Direction
                                                                                       1. Spot elevations and elevation contours
                                                                                         based on water levels reported by E & E
                                                                                         from measurements taken 7/10-13/84.
                                                                                       2. Wells >20 feet deep corrected for an
                                                                                         average upward gradient of 0.02 (eel/loot.
                                                                                   0              250
                                                                                                  i
                                                                                   Scale in  Feet
                       500
From Hart Crowser, August 1984.
                                                          3-20
FIGURE 3-8
SHALLOW GROUNDWATER
ELEVATION CONTOURS
WESTERN PROCESSING
Kent, Washington

-------
because the 0.5 cfs includes inflow from the west side of
the creek and the measured reach extends up and downstream
of the site.  Mill Creek flow measurements taken by USEPA on
three occasions indicated that stream flow increased from
3.0 to 3.5 cfs in May 1982, 11.2 to 15.5 cfs in Novem-
ber 1982, and 11.3 to 17.3 cfs in December 1984 as the creek
flowed across an 0.8-mile reach that included Western Pro-
cessing.  Field personnel noted that the latter two esti-
mates include an unmeasured amount of surface inflow along
the reach.

East drain discharge has not been measured but estimated
flows are shown by Yake  (1985).  About 40 percent of the
site's shallow groundwater flows to the east drain based on
flow net analysis.  Using this ratio and noting that the
drain invert elevation is slightly higher than Mill Creek,
the flows in the drain should be about 0.1 cfs.

Ponded surface water, higher precipitation infiltration,
and/or variations in soil hydraulic conductivity at Western
Processing have caused a groundwater mound to form near the
center of the site in excess of the mound that would natu-
rally exist between two discharge areas such as Mill Creek
and the east drain.  Flow is radial from the mound to Mill
Creek on the west, to the east drain on the east, to the
south near the vicinity of Well 22S and 22D, and off the
property to the north.

Figures 3-7 and 3-8 show only the horizontal groundwater
flow component.  Vertical gradients (down and up) strongly
influence the local groundwater flow pattern at Western Pro-
cessing.  Figure 3-9 is a schematic cross-section that illus-
trates vertical gradients created by the local groundwater
flow.

Vertical gradients were calculated using water level data
from well nests (i.e., two or more piezometers or wells in-
stalled at the same location and completed at different
depths)  installed for the Western Processing site studies.
The nested wells are indicated in Table 3-1 as S (shallow)
and D (deep).  In general, for off-property wells greater
than 30 feet deep, as well depth increases, the well water
levels rise in elevation (indicating upward vertical flow).
The data indicate an average upward hydraulic gradient of
about 0.02.

Beneath the site, vertical downward flow gradients are pres-
ent that are related to the site groundwater mound.  The
downward gradients are strongest in the middle of the site
(approximately 0.10)  as indicated by water levels from
Wells 17S and 17D.  The downward component becomes less pro-
nounced near the site boundary as indicated by water level
data from Wells 1 and 25, and ultimately reverses to upward
flow as shown in MB-03 (see Figure 3-10) .  At depths below

                            3-21

-------
    WEST
                                                                                                         EAST
                                       GROUND SURFACE
          WEST VALLEY HIGHWAY
                                                                     WESTERN PROCESSING
OJ
I
to
NJ
                (Not to Scale)
FIGURE 3-9
SCHEMATIC REPRESENTATION
OF LOCAL GROUNDWATER
FLOW SYSTEM
WESTERN PROCESSING
Kent, Washington

-------
                 POTENTIOMETRIC LEVEL BELOW SURFACE (FT.)

                -10         -8          -6         -4         -2
LU
(J
<
LL
DC
=3
CO

O

LU
CO
I-
cc
O
o.
u.
O
I

t
LU
Q
   10-
   20-
    30-
40-
50-
60-
    70J
    80-
   90-
   100
                I
                I
                   I
                       I
Explanation
                                                       r
                                             Length of
                                             sand pack
                                                               Location of
                                                               measurement
                                                          •-1-   port
  Source:CH2MHILL,D«ceniber 1984.
                                         3-23
                                                             FIGURE 3-10
                                                             WELL MB-03 WATER PRESSURE
                                                             MEASUREMENTS
                                                             WESTERN PROCESSING
                                                             Kent, Washington

-------
about 70 feet the MB-03 data indicate horizontal flow pre-
dominates.  MB-03 is located at the north end of the site
where the influence of Mill Creek and the east drain are
strongest because of their close proximity to the site.  The
depth to horizontal flow could be deeper in the southern
area of the site where the effects of Mill Creek and the
east drain are less.

The depth to which Mill Creek affects local groundwater flow
is currently undefined.  Even though the creek penetrates
only a small portion of the shallow aquifer  (±8 feet), it
intercepts groundwater flow from much greater depths.  The
current conceptual model of the effective capture depth of
Mill Creek is about 50 to 60 feet (note: capture depth is
less than the depth to horizontal flow).  Site contaminants
that migrate to this depth could flow horizontally beneath
the creek to the west.  Water quality data from the seven
downgradient monitoring wells (35, 36,  38, 39, 40, 42, and
43) located west of Mill Creek are inconclusive in demon-
strating that the groundwater contamination west of Mill
Creek migrated from Western Processing  site.  A detailed
discussion of the groundwater quality results is presented
in Section 3.6 of this chapter.

3.3.4  HYDROGEOLOGIC DATA REQUIREMENTS

More hydrogeologic data from the Western Processing vicinity
are required to optimize individual components of the reme-
dial actions and to identify and quantify the source of
groundwater contamination west of Mill  Creek.

Required information includes:

     o    Large scale aquifer hydraulic conductivity (in-
          cluding vertical and horizontal hydraulic conduc-
          tivities) to determine the effects on Mill Creek
          and the east drain in response to groundwater
          pumping

     o    Variation of water quality and water level data
          with depth at several locations east and west of
          Mill Creek

     o    Physical and chemical properties of the soil and
          aquifer and of the contaminants that affect the
          migration rate such as soil porosity, particulate
          organic carbon, and sorption  isotherms for major
          contaminants
                            3-24

-------
               3.4  SAMPLING AND DATA ANALYSIS

3.4.1  SAMPLING AND ANALYSIS

The sample collection methods and field techniques used dur-
ing each of the previously identified studies have varied.
Sampling techniques are discussed in each referenced report.
Laboratory methodologies are summarized in Table 3-2.

For the most part, samples were processed through the USEPA
Contract Laboratory Program  (CLP).   It is assumed that all
samples in a given matrix (soil or water) analyzed by the
CLP were tested using identical procedures.  Data for sam-
ples analyzed using other than CLP standard procedures are
discussed separately, as appropriate.

3.4.2  SAMPLING NETWORK

The sampling network on and around the Western Processing
site is shown on Plates 1, 2, and 3  (included in pockets to
this report).  The locations of surface soil samples, sedi-
ment samples from Mill Creek, and water samples from Mill
Creek and other drainages around the site are shown on
Plate 1.  Groundwater monitoring wells are shown on Plate 2.
Subsurface soils sampling locations are shown on Plate 3.
References to the original sources of the data are provided
in the legends of each plate.

3.4.3  DATA REDUCTION TECHNIQUES

The data base used in this report to support the discussions
of the nature and extent of contamination is large.  Over
400 soil and water samples were collected during the May 1983
and the summer 1984 remedial investigations alone.  Approxi-
mately 100 priority pollutants were identified during these
studies, yielding a data base of over 40,000 discrete data
entries.  If non-priority pollutants, tentatively identified
compounds, and other samples are included in this inventory,
the total data base approaches 50,000 entries.  Because of
the size of this data base,  it was  necessary to reduce and
restructure these data into a manageable form.

Data from each of the referenced reports in Table 3-2 were
put onto a microcomputer data base  management system.  The
acronyms chosen for each of the data sources put into the
management system are included in Table 3-2 and identified
as "source".  These acronyms will be used throughout this
chapter to simplify the discussion.

To reduce the number of data entries, only detected priority
pollutants were put into the data base management system.
Samples for which priority pollutants were not detected were
excluded from the data base.  This  point is further discussed
in Data Qualifications, Section 3.4.4.


                             3-25

-------
                                                                      Table  3-2
                                 SUMMARY  OF  DATA  SOURCES,  TEST  METHODS,  AND  IDENTIFIERS
                                                 USED  IN  THE  DATA  MANAGEMENT  SYSTEM
                                                              WESTERN PROCESSING
                                                               KENT,  WASHINGTON
          Sample Category
                                      Data Source
                                                               Acronym to
                                                              Indicate Data
                                                                 Source
                                                          Testing Methods
                                                                                           R-Base Identifier
                                                                                           (i.e., ID Number)
       1.  Subsurface soils  a.
                                Investigation of  Soil and Water     3013
                                Contamination at  Western Proc-
                                essing, Kent, Washington.
                                USEPA.  Hay 1983.
                            b.   Interim Offsite Remedial         Not listed
                                Investigation Report.  CH2M
                                HILL.  October 1983.
                                            Organics:    CLP GCMS/Chromatographic
                                                        Methods3
                                            Inorganics:  CLP ICAP or  FAA/CVAA
                                            Field OVA Screen Headspace analysis for
                                            volatile organics in water.
EPA-boring number(01-26)-
  depth
Does Not Apply
                                The Western Processing
                                Alternatives Assessment Study,
                                1983 Data Report.  CH2M HILL.
                                April 1984.
                                    IRI      Organics:    CLP GCMS/Chromatographic
                                                        Methods3
                                            Inorganics:  CLP ICAP or FAA/CVAA
WPO-BC-boring number
(035-044)-depth
 I
KJ
CTi
Summary of the Nature and
Extent of Contamination
Present on Standard Equipment,
Inc.,  Property in Kent,
Washington.  Radian Corp.
November 1984.
                                                                 Radian     Organics:    1.   GCMS EPA 8240

                                                                                        2.   GC HECDd
                                                                                            Modified EPA 8010
                                                                            Inorganics:  ICPES Analysis Method
                                                                                        EPA 200.7e
WP-SB-boring number
  (07-18S20)-depth R
WP-IB-boring number
  (02 only)-depth R
        Organic priority pollutant analysis by the USEPA Contract  Laboratory Program  (CLP) using extraction methods with gas chromotography/mass
        spectroscopy  (GCMS).  Reference USEPA IFB Contract No.  68-01-16958 for specific analytical procedures.
       b
        Inorganic priority pollutant analysis by the USEPA Contract Laboratory Program (CLP)  using inductively  coupled argon plasma  spectroscopy (ICAP)
        or comparable flameless and cold vapor atomic absorption.  Reference USEPA  IFB Contract No. WA84J091 for specific analytical procedures.
        Organic priority pollutant analysis using USEPA method  8240  (volatiles),  8270A (acid extractables) and  8270B  (base/neutral compounds).
        Volatile hydrocarbon analysis using modified USEPA method  8010  (Halls electron capture detection), tetraglyme extraction followed by purge and
        trap.
        Inorganic analysis by inductively coupled plasma emission  spectroscopy (ICPES) using USEPA method 200.7 (the same or nearly  identical to ICAP
        analysis).

-------
                                                              Table  3-2  (cont.)
OJ
 I
ho
-J
         Sample Category
                                      Data Source
                                                                 Acronym to
                                                               Indicate Data
                                                                   Source
                                                                 Testing Methods
                                                   R-Base  Identifier
                                                   (i.e.,  ID Number)
      1.   Subsurface  soils   d.  Remedial Investigation Data
          (continued)
     2.  Surface Soils
    Report, Western Processing,
    Kent, Washington.  CH2M HILL.
    December 1984.
a.  Data provided to CH2M HILL by
    the USEPA laboratory in Man-
    chester, Washington November
    1984.  (Data can be found in
    appendix to Id)

a.  Same source as la.
                           b.  Same source as Ib.
                               Same source as Id.
                                                                     RI
Organics:    1.  CLP GCMS/Chromatographic
                 Methods3

             2.  GC BCD for PCB'sf

             3.  CSL GC FID Methods9
                 8010 Halogenated Volatiles
                 8040 Phenols
                 8060 Bis(2-ethylhexyl)
                   phthalate

Inorganics:  1.  CLP ICAP or FAA/CVAAb
             2.  CSL EPA 3010 (digestion)
                   and 7190 (chromium)
                   7520 (nickel) , 7950 (zinc),
                   7420 (lead),  and 7130
                   (cadmium)
WP-MB-boring number(01-03)-
  depth
WP-SB-boring number(01-20) •
  depth
WP-IB-boring number(01-03)-
  depth
                                                                     Man
                                                                    3013
                                                                     IRI
                                                                     RI
Organics:
Methods3'
                                                                                           CLP GCMS/Chromatographic
                                                                              Inorganics:   Not Tested
                                                   Organics:

                                                   Inorganics

                                                   Organics:

                                                   Inorganics

                                                   PCB's only using GC BCD
                                                                                           CLP  GCMS/Chromatographic
                                                                                           Methods3
                                                                                           CLP  ICAP  or  FAA/CVAA
                                                                                           CLP  GCMS/Chromatographic
                                                                                           Methods3
                                                                                           CLP  ICAP  or FAA/CVAA
WP-MB-boring number-depth M


WP-SB-boring number-depth M
WP-IB-boring number-depth M

EPA-Berm-1 thru 9

EPA-SS-02 thru 12

WPO-SS-001 thru 014



WP-SS-01 thru 04
      Field generated data for PCB's analyzed using a Shimadzu GC-mini-2 Electron Capture  Detection  (BCD)  system with a Shimadzu Chromatopac C-RIB Data
      Processor to obtain response factors for PCB standards and to compute sample concentrations.

     9Close Support Laboratory field generated data for methylene chloride, trichloroethene,  and  tetrachloroethene using USEPA method 8010, phenols
      (8040)  and bis(2-ethyhexyl) phthalate (8060)  with a Hewlett-Packard model  5880A dual column flame  ionizing detector.  These field generated data
      were not used in the data interpretation prepared for this feasibility study report.

      Close Support Laboratory field generated data for selected inorganics using a Perkin-Elmer  model 303 flame atomic absorption system.  These field
      generated data were used to determine background metal contents in Kent valley soils near the  site.

      Organic priority pollutant analyses at the EPA Region X laboratory in Manchester, Washington.  Samples had been stored since June 1984 at
      4°C.  Samples were reanalyzed at the Manchester laboratory after receipt of CLP data identified data gaps.  Because of extended storage time,
      data can be used only with qualification.
     869974E2

-------
                                                              Table  3-2  (cont.)
        Sample Category
Data Source
                          Acronym to
                         Indicate Data
                            Source
                                                                                      Testing Methods
                                                                                                                          R-Base Identifier
                                                                                                                           (ie.  ID Number)
3.  Groundwater       a.   Same  source as la.
                                                                   3013      Organics:    CLP GCMS/Chromatographic
                                                                                         methods             .
                                                                            Inorganics:  CLP ICAP or FAA/CVAA
                                                                                    EPA-well.number(01-30)-
                                                                                      S or D3
                           b.  Same source as Ib.
                                                                    IRI
                                                                            Same as above
                                                                                    WPO-GW-well number
                                                                                    (031-034)-D   (Note:  the
                                                                                    D description used for
                                                                                    well 031 to 034 indicates
                                                                                    the deep well of the
                                                                                    cluster was sampled.)
                              News Release No. 63-77.
                              USEPA Region X.
                              September 26, 1985
                                                                   EPAGW
                                                                            Same as above
                                                                                    EPA-well number (13,99,27-
                                                                                    30)-S or D3
 I
NJ
00
                           d.   Same source as Ic.
                           e.   Same  source as Id.
                            Radian     Organics:    EPA 601  (GC  Halocarbons)
                                       Inorganics:  ICPES analysis  using
                                                    USEPA method 200.7e

                              RI       Organics:    CLP GCMS/Chromatographics
                                                    Methods3
                                       Inorganics:  CLP ICAP or  FAA/CVAA
                                                                                                                     WPO-GW-well  number
                                                                                                                     (031-034)-S  or D3
                                                                                                                     EPA-27 or EPA-28-S/R
                                                                                                                         WP-GW-well number(01-03)
                                                                                                                         WPO-GW-well number
                                                                                                                            (34 and 35)-S or D
                                                                                                        j
     j
      S or D indicates "shallow" or "deep."
      Gas chromotography for volatile halogenated hydrocarbons using USEPA method 601/GC.
      B69974E3

-------
                                                                Table  3-2  (cont.)
Sample Category
4. Surface Water1
Data Source
a. Report of Western Processing
Vicinity Survey, May^20-21 ,
1982. USEPA. June 1982/
Acronym to
Indicate Data
Source
Vicinity Organics:
Inorganics:
Testing Methods
CLP GCMS/Chromatographic
Methods3'"
CLP ICAP or FAA/CVAA1"
R-Base Identifier
(i.e., ID Number)
EPA-SW-station number/V
EPA-WP-well point number/v
                                                                                           (Note:  station numbers are
                                                                                                                             01, 02, 03, 06,  07,  08,
                                                                                                                             10, 11 and well  point
                                                                                                                             numbers are 03,  06,  07
                                                                                                                             and 08.)
                           b.  USEPA Unpublished Water
                               Quality and Sediment Data
                               for Mill Creek.  January
                               1984.
                                                             EPAMill    Organics:    CLP GCMS/Chromatographic
                                                                                     Methods3
                                                                        Inorganics:  CLP ICAP or FAA/CVAA
                                                                                                EPA-SW-station number/MC  84
                                                                                                 (Note:   station numbers  are
                                                                                                    01,  06A,  Pipe,  and 08.)
U)
 I
NJ
5.  Sediments
c.  Unpublished Washington State
    Department of Ecology Water
    Quality Data, Mill Creek and
    Vicinity.

a.  Same source as 4a.
                                                                   DOEMill    Organics:
                                                                                     Information not readily
                                                                                       available
                                                                        Inorganics:  Information not readily
                                                                                       available
                                                            Vicinity    Organics:
                                                               CLP GCMS/Chromatographic
                                                               Methods3
                                                  Inorganics:  CLP ICAP or FAA/CVAA
DOE-SW-station number
  (09E070 or 09E090)-date
  (month/day/year)
EPA-SED-station number/v
 (Note:  station numbers
   are 01 thru 11.)
                           b.  Same source as Ib.
                                                                     IRI      Organics:    CLP GCMS/Chromatographic
                                                                                          Methods8
                                                                             Inorganics:  CLP ICAP or FAA/CVAA
                                                                                                                     WPO-SD-sample number
                                                                                                                         (001-030)
                           c.  Same source as 4b.
                                                                   EPAMill    Organics:
                                                                                     CLP GCMS/Chromatographic
                                                                                     Methods3
                                                                        Inorganics:  CLP ICAP or FAA/CVAA
                                                                                                EPA-SED-station number/MC84
                                                                                                 (Note:   station numbers are
                                                                                                   01,  06A,  and 08.)
                           d.  Same source as Ic.
                                                                   Radian     Organics:    GC HECD Halocarbons EPA 8010
                                                                             Inorganics:  EPA 200.7e
                                                                                                                      SE-station  number-SED/R
                                                                                                                      (Note:   station numbers are
                                                                                                                        019, 023, 026,  and 030.)
      Surface water data was partially input into the  data base  management system.  Sediment data was not input at all.  Surface water and sediment
      data were manipulated by hand in evaluating the  nature  and extent of contamination.
     in
      Organic and inorganic priority pollutant analysis at the USEPA  Region  X  laboratory in Manchester, Washington.

      Well points were K-V Associates model 12 driven  to a depth of 5 feet below the stream bed depth.  Data are considered as surface water since well
      point samples were intended to approximate  groundwater  flowing  into Mill Creek.

-------
Tentatively identified compounds (TIC's), unknowns, and non-
priority pollutants were not included in the data base even
though they were frequently detected.  The presence of the
TIC's are difficult to confirm or quantify because no refer-
ence standards are available.  Furthermore, there are few
toxicity data available regarding TIC and non-priority pol-
lutants and little information regarding their distribution
in the environment.  For these reasons, the non-priority
pollutants and the TIC's were omitted from the data base.

Sixteen indicator compounds and two compound classes were
selected from the soil and groundwater data to define the
nature and extent of contamination.  The occurrence of each
priority pollutant was first determined by performing a
"tally" of data entries by chemical name for both soil and
groundwater (see Sections 3.5 and 3.6).  Each contaminant
was evaluated according to its frequency of detection and a
list of potential "indicator" compounds was developed.  This
list included all of the more frequently detected contami-
nants in both soils and groundwater.  Each compound was then
evaluated in terms of its occurrence, detection limit, dis-
tribution, persistence, toxicity, and mobility-  The result-
ing indicator compounds are listed in Table 3-3.
                          Table 3-3
               SELECTED INDICATOR CONTAMINANTS
                     WESTERN PROCESSING
                      KENT, WASHINGTON

	Organics	   	Inorganics

Volatile Organics:                  Metals:
     1,1,1-Trichloroethane          Cadmium
     Trans-1,2-Dichloroethene       Chromium
     Tetrachloroethene              Copper
     Trichloroethene                Nickel
     Toluene                        Lead
     Chloroform                     Zinc
Acid Extractable Compounds:
     2,4-Dimethylphenol
     Phenol
Base/Neutral Compounds:
     Total PAH's
     Total Phthalates
Other Organics:
     PCB's
     Oxazolidone
aTotal priority pollutant polycyclic aromatic hydrocarbons
 (PAH's) .
                            3-30

-------
One tentatively identified compound was included on the list
of indicator contaminants.  This compound, 3-(2-hydroxypropyl) •
5-methyl-2-oxazolidone, or simply oxazolidone,  was included
because it was the primary constituent in approximately
700,000 gallons of bulk liquids shipped to Western Process-
ing.  Approximately 325,000 gallons remained at the site at
the beginning of the recent surface cleanup activities.  A
review of the TIC data found this compound to be widespread
around the site.  Since oxazolidone is highly water-soluble,
unique to the site, and toxicity data are available for it,
it was selected as an indicator contaminant.

3.4.4  DATA QUALIFICATIONS

There are several important limitations associated with the
use of the available contaminant data to evaluate the nature
and extent of contamination.  These include:

     o    Factors affecting data comparability

     o    Analysis at different laboratories

     o    High organic detection limits in certain soil sam-
          ples collected during the summer 1984 remedial
          investigation

     o    Exclusion of non-detects in the data base

     o    Exclusion of TIC's and effect on data interpretation

These are discussed below.

3.4.4.1  Factors Affecting Data Comparability

Contamination data have been collected at Western Processing
sequentially over the past three years.  Each of the major
data collection episodes was initiated after a review of
earlier data identified a need for further information.
This approach enabled the data collection efforts to be fo-
cused on defining the nature and extent of contamination.

Some reduction in the comparability of data is expected as a
consequence of sampling over time.  There are several rea-
sons for this, including:

     o    Naturally occurring changes in the chemical types,
          quantities, and distributions at the site

     o    Surface clean-up and control measures implemented
          since the initial sampling episodes
                            3-31

-------
Changes in the chemical types, quantities, and distributions
at the site have probably occurred since the earliest sam-
pling efforts as a result of factors such as photolysis,
chemical speciation, volatilization, sorption, and biologi-
cal accumulation or transformation.  These factors, while
capable of influencing comparability by themselves, have
acted in combination with several surface clean-up and con-
trol measures.  Disturbance of site surface soils, excava-
tion, aeration, compaction, and the removal of the existing
sources of contamination during the surface clean-up and
control measures have also reduced the comparability of data.

Despite these factors, the use of the existing data as if it
were a single uniform data base is justified.  Data collect-
ed on the site prior to surface clean-up and removal activi-
ties provides valuable information regarding the deposition
of contaminants and the types that may subsequently migrate.
These data can then be interpreted giving consideration to
possible changes in the chemical nature of the contaminants.
Compounds such as metals and PCB's, which are highly persis-
tent in the environment, can be compared over the time span
between sampling with little qualification.

3.4.4.2.  Analysis at Different Laboratories

Samples were analyzed at many different laboratories.  Even
when the same methodologies are used, variations in the com-
pound concentrations would be expected between laboratories.
These expected variances have been accommodated by subject-
ing the data to quality assurance evaluation.

3.4.4.3  High Organic Detection Limits in Certain Soil
Samples

The various contract laboratories encountered some problems
when analyzing for organic priority pollutants in soil sam-
ples collected during the 1984 remedial investigation (RI).
Because there were chemical interferences during the analy-
sis, the CLP reported high detection limits for base-neutral
and acid-extractable compounds.  Detection limits were nor-
mally about 500 yg/kg but ranged as high as 10,000 yg/kg and
in a few cases more than 30,000 yg/kg.  Selected duplicate
samples were subsequently submitted to the USEPA Region X
laboratory at Manchester, Washington, for analysis to deter-
mine if some priority pollutants might have gone undetected
at the higher detection of the CLP data.  Special sample
cleaning techniques to remove interfering nonpriority pollu-
tants were performed prior to analysis to get low detection
limits  (±10 yg/kg).  The results of the Manchester analyses
are discussed in Section 3.5.2.2.
                             3-32

-------
3.4.4.4  Exclusion of Non-Detects in the Data Base

Exclusion of the non-detects and their associated detection
limits restricts use of the data base in three principal
ways.  First, data manipulations such as tallies and compari-
sons can be performed only on detects.  Second, while the
data base can be used to identify where contaminants occur
at concentrations higher than the detection limits, it cannot
be used to identify where contaminants occur at low concen-
trations.  Third, the data base system cannot provide the
detection limits associated with these non-detects.  Detec-
tion limits must be obtained from the original data sources
presented in Table 3-2.

Exclusion of the detection limits from the data base did not
seriously compromise the usefulness of the system and greatly
eased the task of data input and verification.  Sufficient
contaminants were detected to adequately identify the extent
of contamination around Western Processing.  Contaminants
that might have been missed at detection limits lower than
that provided by the CLP were identified by analyzing dupli-
cate samples at the USEPA lab in Manchester.

3.4.4.5  Exclusion of TIC's and Effect on Data Interpretation

Tentatively identified compounds and unknowns were frequently
detected in soil and water samples.  Estimated concentrations
in soils ranged from less than 100 yg/kg to almost 2,000,000
yg/kg.  A sample list of TIC's and unknowns is provided on
Table 3-4.  Complete lists of TIC's and unknowns are pro-
vided in the 3013 report and the summer 1984 RI data report.

These TIC's and unknowns, except for oxazolidone, were not
included in the data base or used for interpretation.  The
difficulties with using these data are as follows:

     o    There are little or no toxicity data or criteria
          available for most of these compounds.

     o    It is difficult to positively identify "unknowns."

     o    Concentrations are only estimates because reference
          standards are not commonly available.

     o    The identification of the TIC's depends greatly on
          the judgment of a chemist to match the sample
          spectra with one of 20,000 to 30,000 compounds
          identified in USEPA/NIH spectral library.

At present, these obstacles are insurmountable and an evalua-
tion of the importance of TIC's and unknowns as contaminants
in the environment is not possible.  It is for these reasons
                            3-33

-------
                            Table 3-4
         TENTATIVELY IDENTIFIED COMPOUNDS AND UNKNOWNS
                       WESTERN  PROCESSING
                        KENT, WASHINGTON
 Sample
   ID
               Compound Name
 CAS
Number
Concentration0
    (yg/kg)
SB-01-04  1,2-Benzenedicarboxylic acid,
         Dipentylester
SB-01-04  5,Alpha,-Furost-20(22)-En-26-OL,
         Acetate,  (25R)
SB-01-04  1,2-Benzenedicarboxylic acid
         Dipentylester
SB-01-04  Butanedioicacid,  Chloro-Bis(1-
         Methylpropyl)Ester
SB-01-04  Dodecane, 1,1-Thiobis
SB-01-04  Hexadecanoic acid,(2-Pentadecyl-
         1,3-Dioxolan-4-yl)Met
                                      131-16-0

                                      24744-53-4

                                      131-18-0

                                      57983-51-4

                                      2469-45-6
                                      41563-11-5
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
SB-05-
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
•19B Unknown
            2,600 J

              390 J

              860 J

              270 J

              530 J
              300 J
        1,964,499 J
            1,756 J
            5,059 J
            4,918 J
            2,459 J
            6,949 J
              885 J
              516 J
          141,444 J
            2,634 J
 J Indicates concentration has been estimated.

Source:  CH2M HILL.  December 12, 1984.
that  Tie's and unknowns were  eliminated  from consideration
in the  discussion  of the nature and extent of contamination.

This  elimination does not appear to seriously compromise the
determination of the extent of contamination at Western Pro-
cessing;  TIC's and unknowns were only  identified  in samples
also  containing priority pollutants.   No samples  were identi-
fied  that contained TIC's and unknowns only.  Priority pollu-
tant  determinations, therefore, were adequate to  define the
extent  of contamination.

3.4.5  DETERMINATION OF BACKGROUND CONCENTRATIONS

Most  metals occur  naturally in the environment.   Contamina-
tion  is therefore  present only when metal concentrations
                               3-34

-------
exceed normal background levels.  Table 3-5 summarizes the
background metal concentrations representative of soils and
groundwater in the Kent valley.  A discussion of the devel-
opment of these background concentrations is provided in
Chapter 2, Section 2.3.1.3.  The organic indicator contami-
nants used in this study are believed not to occur naturally
in the environment except for benzo(a)anthracene.  For this
reason, any detectable quantity of the organic indicator
compounds is considered to represent contamination.  This
assumption is also discussed in Section 2.3.1.3.
                          Table 3-5
  BACKGROUND METAL CONCENTRATIONS FOR SOIL AND GROUNDWATER
               IN THE KENT VALLEY, WASHINGTON

                          Background Concentration
                          Soil          Groundwater
          Metal          (mg/kg)          (yg/1)
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
2.9
40
73
43
76
109
6.
24
129
<40
99
227
8





                   3.5  SOIL CONTAMINATION

Onsite and off-property soil contamination was evaluated
using data from the 3013, RI, and IRI data reports and data
from the USEPA Region X Laboratory at Manchester.  These
data were supplemented by additional samples collected on
the Standard Equipment property by Radian Corporation.  Con-
taminant concentrations are given in dry weight unless
otherwise noted.

Eighty-one priority pollutants were detected in soil samples
collected on the site and 56 in soil samples collected off
the site.  The number of occurrences of these contaminants
are shown in Tables 3-6 and 3-7.  Twenty-eight compounds
were found onsite that were not detected off-property and
four compounds were found off the property that were not
detected on the site.  The occurrences for metals are con-
siderably higher than for organics because metals are com-
monly found in soils and all detects were counted, including
concentrations less than the previously discussed metal
background levels.  The number of occurrences for organics
may be lower because of high laboratory detection limits and
because organic priority pollutants are not normally found
in soils.
                             3-35

-------
                         Table 3-6
   NUMBER OF OCCURRENCES OF DETECTED PRIORITY POLLUTANTS
           IN ONSITE SOILS AT WESTERN PROCESSING
                     KENT, WASHINGTON

                                               Number of
                Chemical Name                 Occurrences
   1.      1,1,1-Trichloroethane                    24
   2.      1,1,2,2-Tetrachloroethane                 4
   3.      l,l,2-Trichloroethanea                    2
   4.      1,1-Dichloroethane                        5
   5.      1,1-Dichloroethene                        1
   6.      1,2-Dichlorobenzene                       5
   7.      1,3-Dichlorobenzenea                      1
   8.      1,4-Dichlorobenzene                       2
   9.      2,4-Dichlorophenola                       6
  10.      2,4-Dimethylphenol                       16
  11.      2,4-Dinitrophenol                         2
  12.      2,4-Dinitrotoluenea                       1
  13.      2-Chlorophenola                           2
  14.      2-Nitrophenola                            1
  15.      4,4'-ODD                                  1
  16.      4,4'-DDT                                  2
  17.      4,6-Dinitro-2-methylphenol                2
  18.      4-Nitrophenol                             1
  19.      Acenaphthene                              6
  20.      Acenaphthylenea                           2
  21.      Aldrin                                    1
  22.      Anthracene                                4
  23.      Antimony                                 14
  24.      Arsenic                                 110
  25.      Benzene                                   9
  26.      Benzidinea                                1
  27.      Benzo(a)anthracene                        9
  28.      Benzo(a)pyrene                            3
  29-      Benzo(b)fluoranthene                      2
  30.      Benzo(ghi)perylene                        1
  31.      Benzo(k)fluoranthene                      1
  32.      Benzyl butyl phthalatea                   2
  33.      Beryllium                                49
  34.      Bis(2-ethylhexyl)phthalate               41
  35.      Bromodichloromethane3                     2
  36.      Bromoform                                 1
  37.      Bromomethanea                             1
  38.      Cadmium                                 145
  39.      Chlorobenzene                             3
  40.      Chloroform                                8
  41.      Chloromethane                             2
  42.      Chromium                                160
  43.      Chrysene                                 13
Compound was not detected in off-property soils.


                            3-36

-------
                          Table  3-6
                         (continued)

                                               Number  of
                 Chemical  Name                  Occurrences

                                                   160
                                                    74
                                                     3
                                                     9
                                                     2
                                                    30
                                                    25
                                                     8
                                                    52
                                                     1
                                                     3
                                                     1
                                                     4
                                                   150
                                                     3
                                                    50
                                                   122
                                                     2
                                                     3
                                                    33
                                                   150
                                                     2
                                                     6
                                                    10
                                                     8
                                                     6
                                                     8
                                                    33
                                                    41
                                                    27
                                                     5
                                                     3
                                                    42
                                                    63
                                                    12
                                                    78
                                                     2
                                                   164
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
Copper
Cyanide
Di-n-butyl phthalate
Di-n-octyl phthalate
Dieldrin
Ethylbenzene
Fluor an thene
Fluorenea
Fluorotrich lor ome thane
Hexachlorobutadiene
Hexachloroethane3
Indeno (1,2, 3-cd) pyrene
Isophorone
Lead
Lindane
Mercury
Methylene chloride
N-Nitrosodimethylaminea
N-Nitrosodiphenylamine
Naphthalene
Nickel
PCB-1016a
PCB-1242a
PCB-1248
PCB-1254
PCB-1260
Pentachlorophenola
Phenanthrene
Phenol
Pyrene
Selenium
Silver
Tetrachloroe thene
Toluene
Trans-1 , 2-dichloroethene
Trichloroe thene
Vinyl chloride
Zinc
aCompound was not detected in off-property  soils.
                            3-37

-------
                           Table  3-7
NUMBER OF OCCURRENCES  OF DETECTED PRIORITY  POLLUTANTS
     IN OFF-PROPERTY SOILS NEAR WESTERN PROCESSING
                      KENT,  WASHINGTON

                                               Number of
                  Chemical Name                Occurrences
     1.     1,1,1-Trichloroethane                    5
     2.     1,1,2,2-Tetrachloroethane                 7
     3.     1,1-Dichloroethane                       1
     4.     2,4,6-Trichlorophenol                    1
     5.     2,4-Dimethylphenol                       3
     6.     2,4-Dinitrophenol                        1
     7.     4,4'-ODD                                 1
     8.     4,4'-DDT                                 2
     9.     4,6-Dinitro-2-methylphenol                1
    10.     4-Nitrophenol                            2
    11.     Aldrin                                   2
    12.     Arsenic                                228
    13.     Benzene                                  4
    14.     Benzo(a)anthracene                       2
    15.     Benzo(a)pyrene                           1
    16.     Benzo(b)fluoranthene                     5
    17.     Benzo(k)fluoranthene                     2
    18.     Beryllium                               48
    19.     Bis(2-ethylhexyl)phthalate               16
    20.     Cadmium                                100
    21.     Chlorobenzene                            3
    22.     Chloroform                               6
    23.     Chloromethane                            2
    24.     Chromium                               239
    25.     Chrysene                                 3
    26.     Copper                                 164
    27.     Cyanide                                330
    28.     Di-n-butyl phthalate                     9
    29.     Di-n-octyl phthalate                     8
    30.     Dibenzo(a,h)anthracene                   1
    31.     Dieldrin                                 1
    32.     Ethylbenzene                             4
    33.     Fluoranthene                             5
    34.     Fluorotrichloromethane                  18
    35.     Heptachlor                               1
    36.     Heptachlor epoxide                       1
    37.     Indeno  (1,2,3-cd)pyrene                  3
    38.     Isophorone                               1
    39.     Lead                                   223
    40.     Lindane                                  1
    41.     Mercury                                 43
    42.     Methylene chloride                     175
    43.     Naphthalene                              2
    44.     Nickel                                 233
    45.     PCB-1248                                 5
    46.     PCB-1254                                10
    47.     PCB-1260                                 2
    48.     Phenanthrene                             5
    49.     Phenol                                   7
    50.     Pyrehe                                   5
    51.     Selenium                                 1
    52.     Tetrachloroethene                       12
    53.     Toluene                                 55
    54.     Trans-l,2-dichloroethene                17
    55.     Trichloroethene                         38
    56.     Zinc                                   240
  aCompound was not detected in onsite soils.


                              3-38

-------
3.5.1  METALS IN SOILS

3.5.1.1  General Trends of Metallic Contamination

This discussion is limited to the general patterns of heavy
metal contamination using a summation of total indicator
metals:  cadmium, chromium, copper, nickel, lead, and zinc.

Metal concentrations greater than background were detected
in soils on and off the property-  The highest metal concen-
trations were consistently found in onsite soils.  Lower
levels, but still above background, of the indicator metals
were found in scattered off-property soil samples.  A summary
of the maximum detected onsite and off-property indicator
metal concentrations is shown on Table 3-8.
                          Table 3-8
                MAXIMUM METALS CONCENTRATIONS
                          IN SOILS

                             Concentration (mg/kg)
Contaminant
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
Onsite
420
7,600
5,700
1,900
141,000
81,000
Off-Property
90
2,120
1,100
184
4,000
21,000
The distribution of metals in soils is summarized in Fig-
ures 3-11 through 3-15.  The shaded areas on each figure
represent a summation of the indicator metal concentrations
at each sampling point for the given depth range.  Background
concentrations are represented by the unshaded areas.  Back-
ground was assumed to be less than or equal to the sum of
the background concentrations provided in Table 3-6  (i.e.,
^ 350 mg/kg).

Samples were not collected in some areas of the site.  Loca-
tions where no samples have been collected were left un-
shaded.  It is important to note that these areas may be
contaminated to some extent, but the degree is unknown.

Indicator metals in excess of 10,000 rag/kg were found in
onsite soils (Area I) near the center of the site and along
the east berro which includes some of Area II.  The extent of
metal contamination consistently decreased with increasing
depth below ground surface.  Indicator metals in concen-
trations above background did not appear to extend much
deeper than 20 feet below the ground surface at any
location.
                            3-39

-------
                                 VACANT HOUSES
INDUSTRIAL PARK
                     OLD SANITARY
                     DISCHARGE LINE
    = 350-1.000/ug|kg
                I        !.
    = 1.000 — 10.000 |>g/kg
    = >10,000/ug/kg

  • SOIL BORING SAMPLES

  A SEDIMENT SAMPLES

  X SURFACE SOIL SAMPt€S;
  • BERM SAMPLES"
     100    200 Fe«
                                 3-40
                                              FIGURE 3-11
                                              SOILS CONTAMINATION SUMMARY MAP
                                              METALS CONTAMINATION AT SURFACE

-------
  = 350 —1.000 /ug/ikg
            *
  = 1.000 — 10.000|ig/kg
  = > 10.000/ug/kg-
  SOIL BORING SAMPLES
  SEDIMENT SAMPLES
X SURFACE
• BERM SAMPLES
                            3-41
                                        FIGURE 3-12
                                        SOILS CONTAMINATION SUMMARY MAP
                                        METALS CONTAMINATION AT 0-4 FEET
                                        BELOW GROUND SURFACE

-------
                                                INTERUHBAN TRAIL
                               VACANT HOUSES
INDUSTRIAL PARK
                    OLD SANITARV
                   DISCHARGE LINE
    = 350-1.000 /ugftg

    = 1,000 - 10.000 |g/kg

    - >10.000/ug/kgi

    SOIL BORING SAl|»H;6S««-«««
                              3-42
                                          FIGURE 3-13
                                          SOILS CONTAMINATION SUMMARY MAP
                                          METALS CONTAMINATION AT 5-9 FEET
                                          BELOW GROUND SURFACE

-------
                                                        RAILflOA
                                            INTERURBAN TRAIL
                OLD SANITARV
                DISCHARGE LINE
= 350—1.000 /ug /.kg

= 1,000- 10,000 /^g/ kg

- > lO.OOOjug/kg'

SOIL BORING
                            72ND AVE.
                                                        EAST
                                                        DRAINtj
                           3-43
                                      FIGURE 3-14
                                      SOILS CONTAMINATION SUMMARY MAP
                                      METALS CONTAMINATION AT 10-20 FEET
                                      BELOW GROUND SURFACE

-------
                                                 INTERURBAN TRAIL
                               VACANT HOUSES
INDUSTRIAL PARK
                    OLD SANITARY
                    DISCHARGE LINE
                                     WESTERN PROCESSING
    - 350—1.000 pg/kg

    =1,000-10,000 Jig/kg

    = >10,000/ug/kgi?

    SOIL BORING SAMPLES
     100   200 Feat
                               3-44
FIGURE 3-15
SOILS CONTAMINATION SUMMARY MAP
METALS CONTAMINATION > 20 FEET
BELOW GROUND SURFACE

-------
Off-property  metal contamination was  found in Areas II,  V,
VI, VII, VIII,  and IX.  Maximum off-property metals were
found in a  sediment sample taken from the south end of
Area II adjacent to Western Processing along the east fence-
line.  This sample contained 31,000 mg/kg zinc and 1,300 mg/kg
lead.

High concentrations of metals in Area VIII were found in a
sample taken  from a ditch along the north side of south
196th Street.   This sample had 21,000 mg/kg zinc and
4,000 mg/kg lead (see Figure 3-11).   Additional samples  col-
lected near this ditch by the Washington State Department of
Ecology and analyzed by CH2M HILL  during the summer 1984
remedial investigation at the Close Support Laboratory  (CSL)
identified  metals in the concentrations shown on Table 3-9.
Elevated levels of lead and zinc were detected.  Subsurface
soil samples  were not collected on this property.
                           Table  3-9
     METALS  IN SOIL AND DUST SAMPLES  TAKEN FROM RENTAL
       PROPERTY NORTH OF WESTERN  PROCESSING, JUNE 1984
        Sample
	Contaminant Concentration (mg/kg)	
Cadmium    Chromium   Nickel    Lead   Zinc
1.  Vacuum Bag, Bedroom    13.8
    Floor
2.  Vacuum Bag, Front
    Room Floor
  5.3
3.  Vacuum Bag, Kitchen   4.1
    Floor
4.  Surface, Driveway

5.  Surface Near
    Clothes Line

6.  Surface Near
    Swing Set
  3.9

  1.6


 10.2
38.6



84.7



98.9



48.1

32.3



22.4
52.4     570    1,940



17.9     426    1,290



19.2     560    1,820



33.5     216      818

13.4     383      408



11.0     103      165
 Copper was not analyzed.  Concentrations presented are wet weights.
 NT = not tested.
A comparison of these data with  lead  and zinc concentrations
found  in  street dirt from urban  areas indicates that while
the  lead  values are typical, the zinc values are not.
Lin-Fu (1973)  reported lead concentrations in street dirt of
                             3-45

-------
1,000 to 3,000 rag/kg and up to 12,000 rag/kg.  Galvin and
Moore (1982) reported lead in street dirt from urban areas
in Seattle at concentrations up to 1,300 mg/kg.  The lead
levels measured in Area VIII are within these ranges.
Galvin and Moore  (1982) measured zinc at concentrations in
street dust only up to 970 mg/kg.  While this value is
similar to the lower zinc concentrations found in Area VIII,
it is less than the maximum (21,000 mg/kg).

Elevated indicator metals (£1,000 mg/kg) were found in soil
samples from Area VI.  Contamination above background was
confined to the surface and upper four feet of soils.
Contamination above background levels was not apparent at
depths greater than four feet for any of the indicator
metals.

Off-property indicator metals were also found in Areas II,
V, and IX.  Metals in Area II were highest in surface soil
samples collected from the east berm.  Subsurface soils in
Area II contained elevated metals in a distinct region 5 to
15 feet below the ground surface.  Metals in this depth
range consistently exceeded 1,000 mg/kg in borings SB-01,
SB-02, and IB-01.  The source of this contamination is
unclear.  Boring logs did not identify any fill at this
depth, so this contamination is presumed to be the result of
migration from Western Processing.

Metal contamination in Area V was localized around borings
SB-09 and IB-02.  Metals exceeding 1,000 mg/kg were found in
surface and near surface soils in SB-09.  These appear to be
a result of migration from Western Processing, possibly along
an old sanitary drainfield discharge line near this boring.
Metals slightly above background were also found in IB-02 at
depths up to 20 feet.  These, too, are probably the result
of migration from Western Processing.

Indicator metals above background were identified in Area IX
at depths up to 20 feet.  Metals in this area were highest
on the south end in a low spot that has historically col-
lected drainage off Western Processing via a ditch located
immediately adjacent to the east side of the site.  Contami-
nant migration down this ditch with deposition in Area IX
and subsequent downward leaching is one possible cause of
these elevated metals.

The distribution of indicator metals by depth is shown in
Figures 3-16 through 3-24.  Figure 3-16 is a plan showing
the locations of the cross sections drawn in Figures 3-17
through 3-24.  These cross-sections support the conclusion
that the major metallic contamination at Western Processing
is restricted to the upper 20 feet of soils.
                            3-46

-------
3-47
            FIGURE 3-16
            CROSS SECTION PLAN

-------
Significant contamination with depth  (£10,000 rag/kg) exists
from east to west across the site.  Metals are roost pro-
nounced in the center of the site as shown in Sections C, D,
G, and H on the west edge of Area I in borings EPA-16, 20,
and 21.  A lens of contamination greater than 100,000 rog/kg
is apparent in Sections D and G in boring EPA-16 at a depth
of 6 feet.

A region of elevated metals  (Si,000 mg/kg) is notable in
Sections A, F, and G at a depth of 10 to 15 feet below the
ground surface in Area II east of the site.  A second region
of elevated metals in the same depth range but at higher
concentration  (£10,000 mg/kg) is apparent in Section B.

3.5.2  ORGANICS IN SOILS

Organic contamination has been identified in on- and off-
property soils.  The extent of this contamination varies
among the compounds, but the general pattern shows higher
organic contamination in onsite soils.  This point is demon-
strated in Table 3-10, which lists the maximum concentra-
tions for detects in on- and off-property soils.  Maximum
onsite indicator contaminants ranged in concentration from 2
to 3,000 times greater than off-property contamination.  The
number of samples and the percent of samples for which the
indicator compounds were detected were also greater for on-
site soils than off-property soils.  This suggests that or-
ganic contamination is predominantly onsite.

There is, however, off-property contamination as demonstrated
by Table 3-11, which lists all the organics detected in bor-
ing WP-SB-14 located in Area VI at some distance from the
Western Processing property line and west of Mill Creek.  A
total of 26 organic priority pollutants was detected in
samples from this boring.  Off-property organic contamina-
tion in soils  appears to be most evident in samples collected
close to the site and east of Mill Creek.  Some off-property
data  (e.g., Area VI) suggest additional sources may be con-
tributing to detected off-property contamination.  This will
be discussed in more detail in the following sections.

The distribution of onsite and off-property organic contami-
nation will be discussed by chemical type rather than by
specific area.  The organic chemical types to be discussed
include volatiles, semivolatiles, PCB's , pesticides, and
oxazolidone.   Semivolatiles were further divided into acid
extractables and base/neutrals.

3.5.2.1  Volatile Organics in Soils

The distribution of volatile organics in onsite and off-
property soils is shown on Figures 3-25 through 3-29.
Volatile organics were most widespread in onsite soils at
                            3-48

-------
    30—
    2O-
ID
fi
Q
I
iy
a!
     JO—
   -70 —
  -20 —
               NOTES: 1) Contaminant amounts shown on the above profiles are derived from
                         the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
                         centration levels. Therefore, the contaminant profiles provide the total
                         indicator metal concentrations.

                       2) Depth of the boring shows sampling depth. Actual drilling depth may be
                         different from the depth to which samples have been collected. Boring logs
                         are available in the 3013 Report (USEPAl, May 1983) and the Rl Data Report
                         (CH2M Hill, 12/84).
                                                                                                -99'-25
                                                                                                                      sao/
                                                                                                                            0-93
                                                                                                                                           LEGEND I
                                                                                                                                           OONCBNTKATION
NO
                                                                                                                                                           < IOOO

                                                                                                                                                           IOOO-IO.OOO

                                                                                                                                                           IO.OOO ~ lOO.OOO

                                                                                                                                                           > IOOfOOO
                                                                                                                                                       3-49
                                FIGURE 3-17
                                METALLIC CONTAMINANTS IN
                                SOILS SECTION A

-------
    30 -
    2O  -
    JO  -
5
1U
        _,
    o  -
L
                                            2.174-1
                                                  EFA23
•e>b
24O
  EPAI&
                               EPA 15
 s&Z
(2.04
                                                                                                                            	TO' -<2>3
                                            '<&!/• &Bto
                                                                                                                     -34-25
                                              NOTES: 1) Contaminant amounts shown on the above profiles are derived from
                                                       the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
                                                       centration levels. Therefore, the contaminant profiles provide the total
                                                       indicator metal concentrations.
                                                     2) Depth of the boring shows sampling depth. Actual drilling depth may be
                                                       different from the depth to which samples have been collected. Boring logs
                                                       are available in the 3013 Report (USEPAI, May 1983) and the Rl Data Report
                                                       (CH2M Hill, 12/84).
                                                                                                                                                     LEGEND I
                                                                                                                                                     NO MARK
                                                                                                                                                                    1000-10,000
                                                                                                                                                      VWSd   10,000 -100,000
                                                                                                                                                  3-51
                                                                                            FIGURE 3-18
                                                                                            METALLIC CONTAMINANTS IN
                                                                                            SOILS SECTION B

-------
    30-
    20-
\
HI
  -10— I
                                                                                      PROCESS/NG
                                                                 '5SOS
                                                                  59/5
 /-SS03
 /3O/70
^y
                                                                                                           /-SSO2
                                                                                                                                              EPA-/3
                                                    NOTES: 1) Contaminant amounts shown on the above profiles are derived from
                                                              the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
                                                              centration levels. Therefore, the contaminant profiles provide the total
                                                              indicator metal concentrations.
                                                           2) Depth of the boring shows sampling depth. Actual drilling depth may be
                                                              different from the depth to which samples have been collected. Boring logs
                                                              are available in the 3013 Report (USEPAI, May 1983) and the Rl Data Report
                                                              (CH2M Hill, 12/84).
                                                                                CONCENT/?AT/O/N

                                                                                NO MARK     <  IOOO

                                                                                                 I.OOO-IO.OOO

                                                                                                 lOjOOO - 100,000

                                                                                                 > lOO.OOO
                                                                                                                                                                  3-53
                                                                                                                                                                            FIGURE 3-19
                                                                                                                                                                            METALLIC CONTAMINANTS IN
                                                                                                                                                                            SOILS SECTION C

-------
                                                                WESTERN PROCESSING
    30-
    20-
IU
1U
*    oA
LU
id
   -7O-
  -20-
                                                                              SS05
                                                                              99247
                           56 20
                                                          <; 3'-48033
                                                                 \
                                                                 5683
                                          29'- 32
                                               NOTES: 1) Contaminant amounts shown on the above profiles are derived from
                                                        the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
                                                        centration levels. Therefore, the contaminant profiles provide the total
                                                        indicator metal concentrations.
                                                      2) Depth of the boring shows sampling depth. Actual drilling depth may be
                                                        different from the depth to which samples have been collected. Boring logs
                                                        are available in the 3013 Report (USEPAI, May 1983) and the Rl Data Report
                                                        (CH2M Hill, 12/84).
                                                                                                                              LEGEND
                                                                                                                              NO MARK    < IOOO
                                                                                                                               /////A  1,000-10,000
                                                                                                                              VWSI  10.000 -100,000
                                                                                                                                   3-55
                                                                                                                                                    FIGURE 3-20
                                                                                                                                                    METALLIC CONTAMINANTS IN
                                                                                                                                                    SOILS SECTION D

-------
    30-
UJ
UJ
s
UJ
al
     20-
     JO-
o-
                                                               . -4'-43
-24'-32

-29-44
    -/o-
-24'-
                                                                                                          se/7
                                                                              -
-------
                                                                                WESTERN  PROCESSING
      30-
tu
Ul
u
p
1
      20-
      70-
       O-
                                             2.9'-30
     -10 -
                                                                                   LEGEND :
                                                                                   CONCENTKAT/ON
                                                                                                                   NO MARK
    -20-]
NOTES:  1) Contaminant amounts shown on the above profiles are derived from
          the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
          centration levels. Therefore, the contaminant profiles provide the total
          indicator metal concentrations.
        2) Depth of the boring shows sampling depth. Actual drilling depth may be
          different from the depth to which samples have been collected. Boring logs
          are available in the 3013 Report (USEPAi, May 1983) and the Rl Data Report
          (CH2MHill, 12/84).
<  1OOO

1,000-10,000
                                                                                                                   VW>j   10,000 - 700,000
                                                                                                                                              3-59
                                                                                                                                FIGURE 3-22
                                                                                                                                METALLIC CONTAMINANTS IN
                                                                                                                                SOIL, SECTION F

-------
                                                                                       WESTERN PROCESSING-
    30-
    20-
W
1U
0
I
1U
a)
     10-
      o-
  -20-
                                                                    SS03
                                                                   30170
                                 SB-18
                                                                               LEGEND :
                                                                               CONCEHTKAT/ON
                                                                                                               NO MARK
NOTES:  1) Contaminant amounts shown on the above profiles are derived from
          the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
          centration levels. Therefore, the contaminant profiles provide the total
          indicator metal concentrations.
        2) Depth of the boring shows sampling depth. Actual drilling depth may be
          different from the depth to which samples have been collected. Boring logs
          are available in the 3013 Report (USEPA, May 1983) and the Rl Data Report
          (CH2M Hill, 12/84).
                                                                                               < IOOO

                                                                                              1,000-10,000

                                                                                              IQOOO - /OQOOO

                                                                                              > lOO.OOO
                                                                                                                                   3-61
                                                                                                                       FIGURE 3-23
                                                                                                                       METALLIC CONTAMINANTS IN
                                                                                                                       SOIL, SECTION G

-------
                                                                              WESTERN PROCESSING
  30-
                                           EPA2
  2.0-
UJ
IU
g

0
£
Ul
UJ
   /o-
    o-
 -10-
-2.0-
                                                              SSO8
                                                              59/5
                                                                                                      LEGEND:
                                                                                                      CONCENTRATION RANGE (mj/Kj )

                                                                                                      NO MARK     <  IOOO
                            NOTES: 1)  Contaminant amounts shown on the above profiles are derived from
                                      the summation of cadmium, chromium, copper, lead, nickel, and zinc con-
                                      centration levels. Therefore, the contaminant profiles provide the total
                                      indicator metal concentrations.
                                   2)  Depth of the boring shows sampling depth. Actual drilling depth may be
                                      different from the depth to which samples have been collected. Boring logs
                                      are available in the 3013 Report (USEPAi, May  1983) and the Rl Data Report
                                      (CH2M  Hill, 12/84).
                                                                                                       /////A   1,000-/o.ooo
                                                                                                     WV>I   10,000 -100,000
                                                                                                                     > 100,000
                                                                                                                               3-63
                                                                                                                                                    FIGURE 3-24
                                                                                                                                                    METALLIC CONTAMINANTS IN
                                                                                                                                                    SOIL, SECTION H

-------
                             Table  3-10
                      MAXIMUM CONCENTRATIONS
    FOR INDICATOR ORGANICS  IN ONSITE AND OFF-PROPERTY SOILS
                         WESTERN PROCESSING
                          KENT, WASHINGTON
       Contaminant
Volatiles
  1,1,1-Trichloroethane
  Trans-1,2-Dichloroethene
  Tetrachloroethene
  Trichloroethene
  Toluene
  Chloroform

Acid Compounds
  2,4-Dimethylphenol
  Phenol
         Maximum
  Concentration  (yg/kg)
  Onsite     Off-Property
   174,000
        34
    72,000
   580,000
   394,000
    18,000
    11,000
57
390
219
50,000
1,070
7.1
15
8
26
49
40
5
  6,660
             Percent of Samples
               for Which Con-
               taminant Was
           	Detected	
           Onsite  Off-Property
                         2
                         8
                         6
                        18
                        27
                         3
10
Base/NeutralCompounds
  Total PAH's
  Total Phthalates
53,239,000
   860,000
324,800
120,000
Other
  PCB's                        114,800     37,200       20         11
  Oxazolidone                  130,000     42,200       NAC        NA


 Percent was calculated by dividing the number of detects by the total
 number of samples analyzed.   For onsite soils, approximately 159 samples
 were analyzed for all priority pollutants.  For off-property samples,
 approximately 207 samples were analyzed for priority pollutant volatiles,
 190 for priority pollutant base/neutrals and acid-extractable compounds,
 and 159 for pesticides.  These totals were used above.  Total number of
 samples analyzed does not include samples submitted for repeat analysis
 which duplicate data for the  indicator compounds—such as Manchester or
 Radian data.

 Maximum PCB concentrations include all PCB's detected rather than specific
 arochlors.  PCB data are provided later in the text.
°NA = not applicable.  Oxazolidone was not normally analyzed for by the
 CLP.
                                 3-65

-------
                         Table 3-11
                      ORGANICS IN SB-14
            WESTERN PROCESSING, KENT, WASHINGTON

       _,   .                     Depth        Concentration
	Chemical Name	       (ft)            (yg/kg)

PCB-1248                           0             4 100
Dibenzo(A,H)Anthracene             4                38
Benzene                            0                 3.2
                                  29                 9.5
1,1,1-Trichloroethane              0                 1.6
                                   4                57.0
1,1-Dichloroethane                19                 2.3
1,1,2,2-Tetrachloroethane         14                 3.1
Chloroform                         0                 5.0
                                  19                 2.0
                                  29                 6.1
Trans-1,2-Dichloroethene           0               320
                                   4               390
                                  14                11.0
                                  19                 5.0
Ethylbenzene                       4                 2.8
Methylene Chloride                 0                86.0
                                   4               140
                                  14                42.0
                                  19                58.0
                                  24                19.2
                                  29                42.0
                                  34                27.0
Tetrachloroethene                  0                 1.4
                                   4                20.0
Toluene                            0                 3.6
                                   4                24.0
                                  14                 2.2
                                  19                 1.8
                                  29                 2.2
Trichloroethene                    0             2,500
                                   4            50,000
                                  14                26.0
                                  19                12.0
                                  24                 9.1
                                  34                12.3
                                  29                12.0
4,4'-DDT                          34                12.0
Phenol                             4               170
Fluoranthene                       4                19.0
Naphthalene                        4                15.0
Bis(2-Ethylhexl)Phthalate          4                36.0
Di-N-Butyl Phthalate               0             5,800
Di-N-Octyl Phthalate               0            12,000
Benzo(a)Anthracene                 4                22.0
Benzo(b)Fluoranthene               4                44.0
Chrysene                           \                22.0
Phenanthrene                       J                =£•"
Indeno(l,2,3-CD)Pyrene             4                38.0
Pyrene                             4                15'°
                            3-66

-------
                                                   INTERURBAN TRAIL
                                 VACANT HOUSES
           SOUTH 1»6TH ST
                                  $•[ ASPHALT PAD
                     OLD SANITARY
                     DISCHARGE LINE
      = 1 — 1,000yug/(
-------
                                                ini •<  m    r i
                                               INTERURBAN TRAIL
                             VACANT HOUSES
   = 1 — 1.000/jg/|ig
             •?.
   = 1.000 - 10.00f pg/kg

    >10.000pg/

• SOIL BORING SAMPLES
A SEDIMENT SAIwf'LES
X SURFACE SOIL SAMPLES
   BERM SAMPLES- •>««
                                        FIGURE 3-26
                                        SOILS CONTAMINATION SUMMARY MAP
                                        VOLATILE ORGANICS AT 0-4 FEET
                                        BELOW GROUND SURFACE
                            3-68

-------
               OLD SANITARY
               DISCHARGE LINE
= 1 — 1

=1.000-10.0009/kg

= > 10.000 pg/ kg:

SOIL BORING SAMPLES
                                   FIGURE 3-27
                                   SOILS CONTAMINATION SUMMARY MAP
                                   VOLATILE ORGANICS AT 5-9 FEET
                                   BELOW GROUND SURFACE
                        3-69

-------
= i — 1,
=1.000-10.000 AS/kg
= > 10.000 Ajg/kg
SOIL BORING SAMPLES
                          3-70
                                    SOK.S CONTAMINATION SUMMARY MAP
                                    VOLATILE ORGANICS AT 10-20 FEET
                                    BELOW GROUND SURFACE

-------
                                                 INTEHUABftN TRAIL
                               VACANT HOUSES
INDUSTRIAL PARK
                    OLD $AWf Af»Y
                    DISCHARGE LINE
    = 1 — 1,000/jg/kg

    =1,000-10,000 fig/kg

      > 10,000 ;ug/ kg<

    SOIL BORING SAKlPLES
WESTERN PROCESSING
     100    200Fe«t
                                3-71
      FIGURE 3-29
      SOILS CONTAMINATION SUMMARY MAP
      VOLATILE ORGANICS > 20 FEET
      BELOW GROUND SURFACE

-------
depths of less than  10  feet,  within this depth range vola-
tiles were most  frequently  found in soils from 5 to 9 feet
below the ground surface.   The depth to shallow groundwater
nas generally been measured at approximately six feet below
the ground surface  (see Table 3-1).  This means that
volatiles were most  often detected in  soils at about the
SBIflft f^PD't"!"! 3 « cH^ 1 1 r>T»T rrv/^iir*^*.T-»4-^*-
  	~ —- — — --*---•*— mv-x »_* >_ v,/ j- wt;ii *-iCL.CwL."U
same depth as shallow groundwater.
Table 3-12 summarizes  the maximum  detected concentrations
for each of the  indicator volatile organics  in  soils on the
site.  The highest detected  levels of  these  indicators were
found in borings EPA-15  and  EPA-17 at  a  depth of  about 6 to
9 feet.  Volatile contamination measured in  soils at EPA-17
is probably the  direct result  of the past solvent distil-
lation practices at  the  site.  EPA-17  was drilled near where
the solvent distillation apparatus was located  at Western
Processing. It is not  clear  from historic site  activities
why high volatiles should be identified  in EPA-15.

The maximum concentrations of  indicator  volatiles in off-
property soils are summarized  in Table 3-13.  The highest
concentrations were  found in borings drilled in Areas V
and VI for all of the  contaminants except chloroform.  Maxi-
mum detected concentrations  for 1,1,1-trichloroethane,
trans-1,2-dichloroethene, and  trichloroethene were all found
in Area VI in boring SB-14 at  4 feet.  Tetrachloroethene and
toluene were found at  their  maximum concentrations in Area V
in borings IB-02 at  14 feet  and SB-11  at 19  feet.   The maxi-
mum chloroform concentration was detected in Area X in bor-
ing IB-01 at 9 feet.

Trichloroethene  contamination  was  detected in two soil sam-
ples from IB-01  at 9 and 19  feet.  Chloroform was also
detected in this boring  at 9 feet. This trend  is signifi-
cant because this boring is  east of the  site and  near to
boring EPA-15 located  in Area  I where  high concentrations of
volatile organics have been  detected.  The data suggest that
contamination might  be migrating eastward off the site toward
IB-01.  Further  discussion of  this trend is  provided in Sec-
tions 3.6 and 3.9.

Other volatile organic data  were generated by the Radian
Corporation for  soil samples collected on the Standard
Equipment, Inc., property west of  the  site.  Samples
collected by CH2M HILL were  homogenized  and  split with
Radian for analysis  at Radian  Laboratories.  This section
discusses the data generated by Radian and compares it to
data generated by the  USEPA  Contract Laboratory Program for
the split samples.

The various methods  used by  the two laboratories  are pre-
sented in Table  3-14.  The CLP and Radian both  used Method
8240—organic priority pollutant analysis using gas
                            3-72

-------
                    Table 3-12
MAXIMUM VOLATILE INDICATOR ORGANICS IN AREA I
                WESTERN PROCESSING
                 KENT, WASHINGTON
SOILS

Compound
1,1, 1-Trichloroethane




Trans-1 , 2-Dichloroethene


Tetrachloroethene




Trichloroethene




Toluene




Chloroform





Sample ID
EPA-15-06
EPA-17-09
EPA-17-06
EPA-15-09
EPA-17-12
EPA-24-12
EPA-24-09
EPA-21-09
EPA-16-06
EPA-15-09
EPA-20-09
WP-MB-03-010M
EPA-20-06
EPA-15-06
EPA-17-06
EPA-17-09
EPA-15-09
EPA-17-12
EPA-17-06
EPA-17-09
EPA-15-06
EPA-17-03
EPA-17-12
EPA-17-09
EPA-15-06
EPA-17-12
EPA-17-21
EPA-14-12
Depth
(feet)
6
9
6
9
12
12
9
9
6
9
9
10
6
6
6
9
9
12
6
9
6
3
12
9
6
12
21
12
Concentration
(yg/kg)
174,000
16,000
15,000
15,000
333
34
28
24
72,000
14,000
1,300
550
530
580,000
558,000
350,000
180,000
25,300
394,000
280,000
48,000
39,000
19,900
18,000
5,000
505
65
42
                       3-73

-------
                              Table  3-13
  MAXIMUM OFF-PROPERTY VOLATILE INDICATOR ORGANICS IN  SOILS
                         WESTERN PROCESSING
                          KENT, WASHINGTON
        Compound
1,1,1-Trichloroethane
Trans-1,2-Dichloroethene
Te trachloroe thene
Trichloroethene
                   Depth
   Sample ID       (feet)

WP-SB-14-04           4
WP-SB-13-04           4
WP-IB-03-00           0
WP-SB-12-19          19
WP-SB-14-0            0

WP-SB-14-04           4
WP-SB-14-00           0
WP-SB-08-29          29
WP-SB-15-04           4
WPO-BC-035-060       60

WP-IB-02-14          14
WP-IB-02-09           9
WP-SB-14-04           4
WP-SB-04-29M         29
WP-SB-08-09M          9

WP-SB-14-04           4
WP-SB-14-00           0
WP-IB-01-09           9
WP-SB-08-09M          9
WP-IB-01-19M         19
        Concentration
           (pg/kg)

               57
               16M
               55
              390
              320
               59
               41
               40

              219
               30
               20
              7.8M
              6.9M

           50,000
            2,500
              862
              820
              610
Toluene
WP-SB-11-19A
WP-SB-11-19B
WP-SB-20-19
WP-SB-11-09
WP-SB-06-29
WP-SB-06-34
19
19
19
 9
29
34
1,070
  430
  289
  200
  196
  118
Chloroform
WP-IB-01-09
WP-SB-14-29
WP-SB-14-00
WP-SB-02-14
WP-SB-15-29
 9
29
 0
14
29
  7.1
  6.1
  5.0
  3.5M
  2.8M
 M indicates compound was  detected but not quantified.   Actual  concen-
 tration is between the  above  reported detection limit and five times
 this value.
                                 3-74

-------
                           Table 3-14
                 METHODS FOR VOLATILE ANALYSIS
            USED BY THE CLP  AND RADIAN LABORATORIES
                      WESTERN PROCESSING
                       KENT,  WASHINGTON
Laboratory

CLP
 Sample Preparation

Water dispersion,
purge and trap
Radian  1.  Water dispersion,
           purge and  trap

                    b
       2.  Tetraglyme
           extraction, purge
           and trap

       3.  Headspace
           (vapor phase)
 Gas  Chromatography
	Procedure	

Method 8240a
                   Method 8240
                   Modified 8010
                   Modified 8010
    Detector
Mass  Spectrometer



Mass  Spectrometer



HECDb'C
                    FID
                                          b,d
 Standard USEPA laboratory procedures for priority pollutant analysis.
 Reference USEPA IFB Contract Number 68-01-16958.

 Modified USEPA method 8010;  sample preparation and detector both
 different than specified under USEPA Contract Number IFB 68-01-16958.

"HECD = Halls electron capture detector.

 FID = flame ionization detector.
chromatography/mass spectroscopy (GC/MS) .   With this tech-
nique  the  sample is prepared for analysis  using a water
dispersion/purge and trap  method.  The prepared sample is
then injected into a gas chromatograph where the mixture  is
separated  into its components.   Finally, the individual com-
ponents  are eluted and  conducted into a mass spectrometer
for identification and  quantification.  In addition, Radian
analyzed for halogenated compounds using two variations of
USEPA  Method 8010.  The first was sample extraction with
tetraglyme followed by  purge and trap, injection into a gas
chromatograph, and quantification and identification using a
Halls  electron capture  detector  (HECD).  The second was a
headspace  analysis of VOA  vials followed by gas chromatog-
raphy  and  quantification and identification with a flame
ionization detector (FID).

The CLP  and the Radian  laboratory results  for two locations
are provided on Table 3-15.   The data do not show reasonable
                              3-75

-------
                                          Table  3-15
                        COMPARISON OF VOLATILE PRIORITY POLLUTANT DATA
                       IN SOILS USING VARIOUS ANALYTICAL METHODS (yg/kg)
                                                            Concentration (pg/kg)
    Sample
  WP-SB-14-4
  WP-SB-08-9
en

Compound
1 , 2-transdichloroethene
TCE
Toluene
1,1,2 , 2-tetrachloroethene
1,1, 1-trichlorethane
Benzene
1 , 2-transdichloroethene
Methylene dichloride
Toluene
TCE
Vinyl chloride

GC/MSa
77
3,100
12
ND
ND
36
143
2,825
37
1,460
82
Radian
GC/HECDb
106
68,500
ND
48
57
ND
3,670
20,800
ND
12,400
1,000

GC/FIDC
477
190,000
ND
57
143
__
—
—
—
—
—
CLP
GC/MSa
390
50,000
24
ND
57
ND
ND
ND
ND
ND
ND
   ND  =  not  detected
   —  =  analysis not  conducted
   aUSEPA methods  8240/8270
    Halls electron capture detector;  sample  extracted with  tetraglyme  followed  by  purge  and
    trap. Other parameters  as  for  USEPA method  8010.
    Flame ionization  detector;  headspace sampling.   Other parameters as  in EPA  method  8010.

-------
agreement between the different methods and laboratories.
In order to compare the data, it is useful to note the dif-
ferences in the detectors and the sample preparation methods
as they relate to the data.  The HECD is most sensitive to
certain types of molecules, such as the halogenated com-
pounds, whereas the mass spectrometer and the FID are ex-
pected to "see" all organic molecules upon proper separation.
Therefore, it is not unusual for the HECD to miss detecting
compounds such as benzene and toluene as seen on Table 3-15.

The MS and the FID are generally less sensitive to halogen-
ated compounds than the HECD.  This might account for the
higher concentrations of volatile organics identified by the
HECD method.  However, for all three methods, the compounds
are quantified by comparing to a known amount under equiva-
lent conditions (e.g., a "standard"); thus, ideally when
concentrations are above threshold amounts under controlled
conditions, the differences in the sensitivity of detectors
should not contribute greatly to the differences in quanti-
fication.  Also, due to the higher sensitivity of the HECD,
this detector may identify chlorinated compounds in concen-
trations below threshold levels of the MS and FID; but these
detections may be impurities.  The HECD is very sensitive to
trace concentrations of electron capturing compounds found
as impurities in the carrier gas, in leaks from the column
surface, or introduced by solvents used in decontaminating
of labware and in sample preparation.  Thus, without round
robin testing and/or special quality control procedures, it
cannot be concluded that the HECD is identifying a larger
number of compounds than the other detectors.

Differences in the measured contaminant concentrations are
expected due to the different sample extraction techniques,
but not as great as those observed in Table 3-15.  A report
by Batelle Columbus Laboratories (EPA Contract No. 68-03-3091,
March 1984) shows a two to one ratio for tetraglyroe extrac-
tion to water dispersion methods for 1,1,1-trichloroethane.
This ratio, as a general guide, does not account for the
observed differences.

At this point, not enough quality control data are available
to resolve the differences observed in the volatile concen-
trations.  Some of the quality control data still needed
include multiple samples, both in the way of field sampling
and sample preparation and round robin testing on controlled
parameters, as well as multiple runs for the electron
capture detector (in view of its sensitivity and linearity
over short concentration ranges).

3.5.2.2  Semivolatile Organics in Soils

Semivolatile contamination in soils is discussed in terms of
acid extractable and base/neutral compounds.  The extent of
                            3-77

-------
each is discussed in terras of the indicator compounds and
classes.  Acid extractables are represented by phenol and
2,4-dimethylphenol.  Base/neutrals are represented by total
polycyclic aromatic hydrocarbons  (PAH'S) and total phthalates

3.5.2.2.1.  Acid Extractable Compounds in Soils

Semivolatile organic contamination in the form of acid ex-
tractables is shown on Figures 3-30 to 3-34.  Acid extract-
able contamination was found mostly in subsurface soils in
Area I.  The distribution of acid extractable compounds
increased with depth to become most widespread between
10 and 20 feet beneath the site.  The wider distribution
with increasing depth below ground surface suggests some
downward migration from upper soil layers.  Soils at depths
greater than 20 feet contain few  acid extractable compounds
and probably delineate the vertical extent of soil
contamination.

Concentrations of acid extractables were highest  (i.e.,
>10,000 yg/kg) in subsurface soils between 10 and 20 feet
near the center of the site.  Acid extractables were also
detected at concentrations greater than 10,000 yg/kg at
depths less than 10 feet, but not as frequently -

Two locations on the south end of the site, EPA-21 and 22,
contained acid extractables exceeding 10,000 yg/kg in several
subsurface soil samples.  Soil samples from boring EPA-21
contained acid extractables above 10,000 yg/kg only at
depths between 10 and 20 feet.  Acid extractables were
consistently found in EPA-22 in all depth ranges from 0 to
20 feet.  Acid extractables might be present in the vicinity
of EPA-22 at depths greater than  20 feet but this possibility
could not be evaluated because no samples were collected
below 20 feet.

Acid extractable compounds were identified sporadically in
off-property soils.  Acid extractables identified in Areas V
and VI were too near the method detection limit (±500 yg/kg)
to quantify.  Some acid extractables were detected in
off-property surface soils north  and east of the site
(Areas IX and II, respectively) in concentrations greater
than 1,000 yg/kg.  Some deeper contamination was also
present in Area X subsurface soils between 10 to 20 feet at
boring IB-01.  These data suggest some off-property migra-
tion of acid extractables by surface and subsurface means to
the north and east of the site.

One off-property subsurface soil sample in Area V contained
more than 10,000 yg/kg acid extractables.   This sample was
collected from boring SB-08 at 9 feet.   A comparison of this
concentration with acid extractable data collected from the
depth range below this (10 to 20 feet)  suggests some
                             3-78

-------
                           X'-Sf I  ASPHALT PAD
                        _   Sfl I
                 OLD SANITARY
                 DISCHARGE LINE
= 0 — 1.000/ug/kg?

= 1,000— 10.000 nig/kg

- 10,000 — 100,0qb /ug/kg

 100.000 — 1.00(j;000 *jg/kg

    . 000,000 /uglkg    *

SOIL BORING SAMPLES
WESTERN PROCESSING
SEDIMENT

SURFACE SOIL SAMPLES

BERM SAMPLES I
                                           FIGURE 3-30
                                           SOILS CONTAMINATION SUMMARY MAP
                                           ACID EXTRACTABLES AT SURFACE
                             3-79

-------
                OLD SANITARY  i
                DISCHARGE LINE
= 0 — LOOOAJg/kgj

= 1,000 — 10.0000g/kg

= 10.000 — 100.CXSD /ug/kg

 100,000 — LOO^OOO /ug/kg
                 •
SOIL BORING SAMPLES
SEDIMENT SAMPitS""

SURFACE SOIL SAMPLES
BERM SAMPLES?
                            3-80
                                        FIGURE 3-31
                                        SOILS CONTAMINATION SUMMARY MAP
                                        ACID EXTRACTABLES AT 0-4 FEET
                                        BELOW GROUND SURFACE

-------
                                                  INTERUHBAN TRAIL
                                VACANT HOUSES
INDUSTRIAL PARK
                     OLD SANITARY
                    DISCHARGE LINE '
    = 0— L

    = 1.000—.10.000/g/kg

    = 10.000 - 100.000 wg/kg

    = 100,000 — 1.000.000 AJg/kg

    = > 1.000,000

    SOIL BORING SAMPLES
WESTERN PROCESSING
                                3-81
                                            FIGURE 3-32
                                            SOILS CONTAMINATION SUMMARY MAP
                                            ACID EXTRACTABLES AT 5-9 FEET
                                            BELOW GROUND SURFACE

-------
lillllillli = >1.000.000/ug/*g

    • SOIL BORING SAMPLES
                               3-82
                                           FIGURE 3-33
                                           SOILS CONTAMINATION SUMMARY MAP
                                           ACID EXTRACTABLES AT 10-20 FEET
                                           BELOW GROUND SURFACE

-------
                                                    INTERURBAN TRAIL
  INDUSTRIAL PARK
                       OLD SANITARY
                       DISCHARGE LINE
       = 0 — 1.000/ug/kg

       = 1.000-10,000 »g/kg

       - 10,000 — 100,000 /ug/kg

       = 100,000 — 1.0CKS.OOO jug/kg
Illllllllll  = > 1.000.000

    •  SOIL BORING SAMPLES
                                   3-83
                                               FIGURE 3-34
                                               SOILS CONTAMINATION SUMMARY MAP
                                               ACID EXTRACTABLES > 20 FEET
                                               BELOW GROUND SURFACE

-------
interrelation with onsite contamination.  Subsurface migra-
tion of acid compounds in the direction of Area V is strong-
ly suggested by these data.

3.5.2.2.2.  Base/Neutral Compounds in Soils

Base/neutral compounds, as  shown by total PAH's and total
phthalates, were roost frequently detected in onsite soils.
High concentrations of both PAH's and phthalates were identi-
fied in many onsite samples.  Offsite contamination by base/
neutrals was found primarily  in samples immediately adjacent
to the site to the north, east, and west as well as in
Area VI west of Mill Creek.

PAH contamination, as shown in Figures  3-35 through 3-39,
is most widespread in the surface and near surface soils
(0 to 4 feet).  The extent  of PAH contamination decreases
with depth beyond 4 feet.   PAH contamination is, however,
apparent to depths greater  than 20 feet in both onsite and
off-property soils.

Maximum PAH concentrations  were found in surface and near
surface soils on the south  end of the site.  Concentrations
of total PAH's were greater than 1,000,000 yg/kg in two sur-
face soil samples  (EPA-SS-08  and EPA-SS-11) located in this
area.  Individual PAH's and their measured concentrations
for each of these borings are provided  on Table 3-16.

Table 3-17 summarizes the concentration and distribution of
PAH's detected in concentrations greater than  100,000 yg/kg.
Of these 16 compounds, roost were found  in samples EPA-SS-08
and EPA-SS-11 and only two  were found in off-property loca-
tions (EPA-SD-05  (Area IX)  and EPA-SD-09  (Area II)).  No
PAH's greater than 100,000  yg/kg were identified in samples
collected below the surface.

PAH's in Area I soils were  restricted primarily to depths of
less than 20 feet.  The single exception was in the center
of the site at boring MB-01 where PAH's occurred at depths
greater than 20 feet in concentrations  less than 1,000 yg/kg
(specifically, 170 yg/kg at 60 feet below the ground
surface).

PAH's in off-property soils were highest  (i.e., >10,000 yg/kg)
in samples collected at or  near the surface in Areas II
and IX.  PAH's were, for the  most part, undetected in soils
at depths greater than 4 feet in these areas.

PAH's were detected at depths greater than 20 feet in off-
property soils at one location in Area V and one in Area VI.
Benzo(k)fluoranthene was identified in boring SB-08 (Area V)
at 29 feet at 996 yg/kg.  PAH's in Area VI were identified
                             3-84

-------
                                                    INTERURBAN TRAIL
                     OLD SANITAAV
                    DISCHARGE *.««
   = 0 — 1.000/ug/kg'.

   = 1,000 — 10,000 Aifg/kg

   - 10,000 — 100,0$ /ug/kg

   = 100,000 — LOOdsOOO /ug/kg

       .000.000 /ug/kg    *

   SOIL BORING SAMPLES

   SEDIMENT SAMPtES

X  SURFACE SOIL SAMPLES
                                3-85
                                              FIGURE 3-35
                                              SOILS CONTAMINATION SUMMARY MAP
                                              PAH'S AT SURFACE

-------
                                                INTERURBAN TRAIL
                               i  ASPHALT PAD
                 OLD SANITAftV
                 DISCHARGE UME
= 0- 1,000/ug/kg;
            ?
= 1,000— lO.OOOnifg/kg

= 10,000 — 100,000 /ug/kg

= 100,000 - 1.000^000 /ug/kg

= > 1.000.000

SOIL BORING SAMPLES
SEDIMENT SAMFfBS
SURFACE SOIL SAMPLES
BERM SAMPLES I
                                     FIGURE 3-36
                                     SOILS CONTAMINATION SUMMARY MAP
                                     PAH'S AT 0-4 FEET BELOW GROUND SURFACE
                             3-86

-------
                                                     INTERURBAN TRAIL
                                  VACANT HOUSES
           SOUTH 196TH ST
INDUSTRIAL PARK
                      OLD SANITARY
                     DISCHARGE LINE
    = 0— 1.000,ug/kg

    = 1.000 — 10,000 flg/kg

      10.000 —/100.000 /ug/kg

      100.000 — 1.009,000 /ug/kg

    = > 1.000.000 /ugi»*g*

    SOIL BORING SAMPLES
WESTERN PROCESSING
                                          FIGURE 3-37
                                          SOILS CONTAMINATION SUMMARY MAP
                                          PAH'S AT 5-9 FEET BELOW GROUND SURFACE
                                  3-87

-------
                 OLD SANITARY
                DISCHARGE LINE
= 0— 1,000*jg/kg

= 1.000-10.000 i|g/kg

= 10.000 — 100.0{)0

 100.000 — 1,00.000 /ug/kg

= > 1.000.000

SOIL BORING SAMPLES
WESTERN PROCESSING
 100    200 Feel
                                   FIGURE 3-38
                                   SOILS CONTAMINATION SUMMARY MAP
                                   PAH'S AT 10-20 FEET BELOW GROUND SURFACE
                            3-88

-------
                                                    INTERURBAN TRAIL
                                 VACANT HOUSES
INDUSTRIAL PARK
                      OLD SANITARY
                     DISCHARGE LINE
     = 0 — 1,000/ug/kgi

     = 1.000 -10.0000g/kg

     - 10.000 - 100,000 /ug/kg

     = 100.000 - 1.000.000 /ug/kg

     = > 1,000.000

     SOIL BORING SAPLES
WESTERN PROCESSING
                                           FIGURE 3-39
                                           SOILS CONTAMINATION
                                           PAH'S > 20 FEET BELOW GROUND SURFACE
                                 3-89

-------
                          Table 3-16
              SUMMARY OF DATA FOP SAMPLES HAVING
         PAH CONCENTRATIONS GREATER THAN 100,000 yg/kg
                      WESTERN PROCESSING
                       KENT, WASHINGTON
Sample  ID

EPA-SS-08
Depth
 (ft)

  0
      Compound
            Total PAH's
EPA-SS-11
Benzo(a)anthracene
Fluoranthene
Naphthalene
Benzo(k)fluoranthene
Chrysene
Acenaphthylene
Fluorene
Phenanthrene
Pyrene
         Benzo(a)anthracene
         Acenapthene
         Fluoranthene
         Naphthalene
         Chrysene
         Fluorene
         Phenanthrene
         Pyrene
Concentration
   (yg/kg)

    884,000
     15,000
  6,200,000
    130,000
  1,210,000
        400Ma
  8,600,000
 20,000,000
 16,000,000

 53,239,400

     76,000
        400M
    234,000
    627,000
     85,000
     62,000
    763,000
    283,000
            Total  PAH1s
                                   2,130,400
 M indicates  compound  was  detected  but not  quantified at the
 given detection  limit.
in boring  IB-03  as  summarized  on  Table  3-18.   PAH's were
found in this  location  at  depths  from 39  to  59 feet.  There
is no clear explanation why  PAH's were  detected at depths
greater than 20  feet  in these  locations except that low
levels of  PAH's  might not  have been  detected  in other
samples because  of  generally high detection  limits.

There is some  evidence  to  suggest that  PAH contamination at
low concentrations  might be  more  widespread  than indicated
by these data.   A limited  number  of  duplicate  samples were
submitted  for  analysis  at  the  USEPA  laboratory in Manchester,
Washington.  PAH's  were frequently detected  in these samples
at concentrations lower than measurable by the CLP labora-
tories.  These data are summarized on Table  3-19.  Had more
                             3-90

-------
                         Table 3-17
                SUMMARY OF PAH'S IN SOILS AT
          CONCENTRATIONS GREATER THAN 100,000 yg/kg
                     WESTERN PROCESSING
                      KENT, WASHINGTON


1.
2.
3.
4.
5.
6.
7-
8.
9.
10.
11.
12.
13.
14.
15.
16.

Compound
Phenanthrene
Pyrene
Fluorene
Naphthalene
Chrysene
Benzo (a) anthracene
Phenanthrene
Naphthalene
Pyrene
Fluoranthene
Benzo (b) f luoranthene
Phenanthrene
Benzo (k) f luoranthene
Benzo (a) anthracene
Fluoranthene
Naphthalene
Sample
Location
EPA-SS-08
EPA-SS-08
EPA-SS-08
EPA-SS-08
EPA-SS-08
EPA-SS-08
EPA-SS-11
EPA-SS-11
EPA-SS-11
EPA-SS-11
EPA-SS-08
EPA-SS-10
EPA-SS-08
EPA-SD-05
EPA-SD-09
EPA-SS-10
Depth
(ft)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Concentration
(pg/kg)
20,000,000
16,000,000
8,600,000
6,200,000
1,210,000
884,000
763,000
627,000
283,000
234,000
200,000
190,000
130,000
126,000
99,000
120,000
                         Table 3-18
                     PAH'S DETECTED IN
                OFF-PROPERTY BORING WP-IB-03
                     WESTERN PROCESSING
                      KENT, WASHINGTON

	Compound	      Depth      Concentration (yg/kg)

Fluoranthene                 59                   21
Phenanthrene                 39                   39

TOTAL                                             6 0
samples been analyzed at these lower detection limits, it is
possible that PAH's at low levels would be more widespread.

Total priority pollutant phthalates in soils are shown on
Figures 3-40 through 3-44.  Phthalates were most widespread
in onsite soils at depths less than 10 feet.  Phthalates
were found in fewer locations at depths up to and exceeding
20 feet in both onsite and off-property locations.
                             3-91

-------
                         Table 3-19
      COMPARISON OF DATA GENERATED BY THE EPA REGION X
              LABORATORY IN MANCHESTER AND THE
               EPA CONTRACT LABORATORY PROGRAM
                     WESTERN PROCESSING
                      KENT, WASHINGTON
                                Concentration  (yg/kg)
  Sample ID/Compound

WP-SB-09-00

Fluoranthene
Benzo(b)fluoranthene
Chrysene
Phenanthrene
Pyrene
Naphthalene

WP-SB-13-00

Fluoranthene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Chrysene
Phenanthrene
Pyrene

WP-SB-14-04

Fluoranthene
Benzo(a)anthracene
Benzo(b)fluoranthene
Chrysene
Phenanthrene
Pyrene
Napthalene
Indero(1,2,3-cd)pyrene
Dibenzo(a,h)anthracene
                        Manchester   CLP
                            Data      Data
                             81
                             90
                             76
                            130
                             74
                             39
                            210
                            100
                            210
                            130
                            120
                            120         —  v
                            280        460M
                             19
                             22
                             44
                             22
                             56
                             15
                             15
                             38
                             38
      CLP
Detection Limit
      447
      447
      447
      447
      447
      447
      460
      460
      920
      920
      460
      460
      460
      140
      190
       NDC
      240
       94
      140
       47
      420
       ND
 a —  indicates  compound not detected.
 DM indicates compound was detected but not  quantified at the
 given  detection limit.
'ND
     indicates no data available.
                              3-92

-------
                                                     INTERURBAN TRAIL
                                  VACANT HOUSES
INDUSTRIAL PARK
                      OLD SANITARY
                     DISCHARGE LINE
    = 0 — 1.000^ig/kg

    = LOGO — id.ooonig "1. 000.000
    SOIL BORING SAMPLES
    SEDIMENT SAMPfceS - >
    SURFACE SOIL SAMPLES
    BERM SAMPLES
                                              FIGURE 3-40
                                              SOILS CONTAMINATION SUMMARY MAP
                                              PHTHALATES AT SURFACE
                                 3-93

-------
                                                   INTERUHBAN TRAIL
                                 VACANT HOUSES
INDUSTRIAL PARK
                      OLD SANITARY
                     DISCHARGE LINE
     = 0— 1.000jjg/kg;
                5
     = 1,000 — lO.OOO^ig/kg
      10,000 — 100,0$) «g/kg
                i
      100,000 -I.OOdloOO /ug/kg

      > 1.000.000
     SOIL BORING SAMPLES
     SEDIMENT SAMPttS
     SURFACE SOIL SAMPLES
     BERM SAMPLES
                                             FIGURE 3-41
                                             SOILS CONTAMINATION SUMMARY MAP
                                             PHTHALATES AT 0 TO 4 FEET
                                             BELOW GROUND SURFACE
                                 3-94

-------
                                                   INTERURBAN TRAIL
                                 VACANT HOUSES
INDUSTRIAL PARK
                     OLD SANITARY  :
                    DISCHARGE LINE •
    = 0 —1.000 ,ug/k|

    = 1.000— 10.000 iijig/kg

    = 10,000 — 100.0^0 /ug/kg •

    = 100.000 — 1.000.000 yug/kg

    = > 1,000,000 /ug/tfg;>:

    SOIL BORING SAMPLES
                                 3-95
                                             FIGURE 3-42
                                             SOILS CONTAMINATION SUMMARY MAP
                                             PHTHALATES AT 5-9 FEET
                                             BELOW GROUND SURFACE

-------
                  INTERURBAN TRAIL
VACANT HOUSES
= 0— 1.000/jg/k^

= 1,000 —10,000 |g/kg
           I
= 10,000 - 100,000
           :;•.
 100.000 — 1.00|,000 /ug/kg

= > 1.000.000

SOIL BORING SAMPLES
       WESTERN PROCESSING
            SOILS CONTAMINATION SUMMARY MAP
            PHTHALATES AT 10 TO 20 FEET
            BELOW GROUND SURFACE
 3-96

-------
                                                   INTERURBAN TRAIL
                                 VACANT HOUSES
                                  ;|  ASPHALT PAD
INDUSTRIAL PARK
                     OLD SANITARY
                     DISCHARGE LINE
    = 0— 1,000/ug/kj

    =1,000-10,000/8g/kg

    - 10.000 — 100,OfO «g/kg

    = 100.000 — 1,008.000 ,ug/kg

       1.000.000 /ug/1tg

    SOIL BORING SAMPLES
WESTERN PROCESSING
                                 3-97
                                             FIGURE 3-44
                                             SOILS CONTAMINATION SUMMARY MAP
                                             PHTHALATES > 20 FEET
                                             BELOW GROUND SURFACE

-------
Concentrations of total phthalates were highest in surface
soil samples.  Phthalates exceeded 100,000 yg/kg in surface
soils collected on the south and central portions of Area I.
Concentrations greater than 100,000 yg/kg were also detected
in one sediment sample from the south end of Area II.  Phtha-
lates greater than 10,000 yg/kg were detected in Area VI
surface soils and in one sediment sample collected in Mill
Creek upstream of Western Processing  (not shown on contami-
nant summary maps).  All other surface soil samples con-
tained less than 1,000 yg/kg.

Phthalates detected in these surface or near-surface soils
were almost all in the form of bis(2-ethylhexyl)phthalate.
Data for surface soils having total phthalates greater than
10,000 yg/kg are summarized on Table 3-20.  Although other
phthalates are present, bis(2-ethylhexyl)phthalate
predominates.

Total phthalates were present at depths greater than 4 feet
in several locations both on the site and off-property-
Total phthalates greater than 100,000 yg/kg were measured in
soil samples from boring EPA-22 at depths between 5 and
9 feet.  Total phthalates in concentrations exceeding
10,000 yg/kg were found in soil samples from boring EPA-16
at 5 to 9 feet and from borings EPA-11, EPA-22, and MB-01 at
depths between 10 and 20 feet.  In each of these borings
bis(2-ethylhexyl)phthalate constituted between 75 and 100
percent of the total.  Phthalates, if present, could not be
detected in boring EPA-22 at depths greater than 20 feet
because no samples were collected.

Borings containing phthalates in soil samples collected at
20 feet or more were located in the central and northeastern
sections of Area I, on the south end of Area II, north of
the site in Area IX, and west of the site in Areas V and VI.

Phthalates in borings north of the site (SB-04)  and west of
the site (SB-07) were measured in higher concentrations at
depths greater than 20 feet than at any other depth.   The
reason for this is unclear.

3.5.2.3  Polychlorinated Biphenyls in Soils

Several different types of polychlorinated biphenyl (PCB)
mixtures (arochlors) were identified on the Western
Processing site and in off-property areas.  Table 3-21 sum-
marizes the number of occurrences (detections) of the dif-
ferent PCB's both on- and off-property.  Sediment samples
were not included in the table.  PCB's were detected in a
total of 25 samples onsite and 26 samples off-property.  The
predominant PCB onsite was arochlor 1248 and the predominant
PCB off-property was arochlor 1254.
                            3-98

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 Sample ID


Onsite


EPA-SS-11


EPA-SS-10


EPA-SS-04



EPA-SS-02


EPA-SS-12



Off-Property


EPA-SD-08



EPA-SD-09


WP-SB-14
                           Table 3-20
                  TOTAL PHTHALATES  IN BORINGS
                 HAVING MOFE THAN  10,000 yg/kg
                      WESTERN PROCESSING
                        KENT, WASHINGTON
                Compound
0

0

0


0

0
0

0
Bis(2-ethylhexyl)phthalate

Bis(2-ethylhexyl)phthalate

Bis(2-ethylhexyl)phthalate
Di-n-octyl phthalate

Bis(2-ethylhexyl)phthalate

Bis (2-ethylhexyl)phthalate
Di-n-butyl phthalate
Bis(2-ethylhexyl)phthalate
Di-n-octyl phthalate

Bis(2-ethylhexyl)phthalate

Di-n-butyl phthalate
Di-n-octyl phthalate
                            Concentration
                               (yg/kg)
860,000

500,000

410,000
 29,000

 74,000

 12,000
  2,600
 61,000
  2,200

120,000

  5,800
 12,000
The available data  from samples in  which PCB's were detected
are summarized in Table 3-22 and  3-23  for onsite  and off-
property  soils, respectively.  Figure  3-45 shows  the dis-
tribution of PCB contamination.   For this figure,  all the
different PCB mixtures  were summed  into a total value for
those  samples where more than one type of PCB was
identified.

The maximum  total PCB concentration found onsite was 114,000
yg/kg  in  boring MB-03 at 10 feet  below the ground  surface.
For off-property samples, the maximum  concentration of total
PCB was 37,200 yg/kg  in EPA-SED-04/V,  which was a  surface
sample collected from the south end of Area  IX.
                              3-99

-------
               OLD *AMfT*llV
              DISCHARGE tWrt
100 - rooo^/g/

1,000 — 10,000/Jj)/kg
                                               FIGURE 3-45
                                               TOTAL PCB SUMMARY FOR
                                               ALL DEPTHS
                          3-100

-------
                         Table 3-21
                  SUMMARY OF PCB OCCURRENCE
              IN ONSITE AND OFF-PROPERTY SOILS
                     WESTERN PROCESSING
                      KENT, WASHINGTON

                                      Number of
                                     Occurrences
            Onsite Soils
            PCB Arochlor:
              1016                        2
              1242                        6
              1248                       10
              1254                        8
              1260                       _6
            Total Detects                32

            Off-property Soils
            PCB Arochlor:
              1248                        5
              1254                       10
              1260                       _2_
            Total Detects                17
The maximum depth at which PCB's were found onsite was at
40 feet below the surface in MB-02.  This value is question-
able, however, because while 10 yg/kg was detected, a repli-
cate sample for this location did not show detectable levels
of PCB's.  Excluding this value, the maximum onsite depth at
which PCB's were detected was 15 feet below the surface.

All but one of the off-property samples in which PCB's were
detected were surface samples.  The one sample in which
PCB's were found at depth was in SB-04 at 34 feet.  A
detection at this depth is inconsistent with other PCB data
and may have been the result of contamination during
sampling or some other sampling or analytical error.

Four out of five surface soil samples collected in Area VI
contained quantified levels of PCB's.  These samples were
collected from visibly stained areas during the summer 1984
remedial investigation.  The presence of PCB's in the
stained areas suggests that spills might have occurred in
these locations.

3.5.2.4  Pesticide in Soils

Pesticides have been identified in soils and sediments both
on and near the Western Processing site.  These data are
summarized in Figure 3-46.
                            3-101

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                         Table  3-22
                  ONSITE PCB CONTAMINATION
                     WESTERN PROCESSING
                      KENT, WASHINGTON
Sample ID No.

EPA-05-03
EPA-05-03
EPA-05-12
EPA-06-06
EPA-06-09
EPA-07-06
EPA-09-03
EPA-10-03
EPA-14-03
EPA-15-03
EPA-15-06
EPA-15-06
EPA-15-09
EPA-21-06
EPA-21-06
EPA-23-06
EPA-23-09
EPA-25-09
EPA-Berm-6
EPA-Berm-8
EPA-Berm-9
EPA-SS-11
EPA-SS-12
WP-MB-02-00
WP-MB-02-40B
WP-MB-03-005
WP-MB-03-005
WP-MB-03-010
WP-MB-03-010
WP-MB-03-010
WP-MB-03-015
WP-MB-03-015
Depth
 (ft)

  3
  3
 12
  6
  9
  6
  3
  3
  3
  3
  6
  6
  9
  6
  6
  6
  9
  9
  0
  0
  0
  0
  0
  0
 40
  5
  5
 10
 10
 10
 15
 15
Arochlor
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
1016
1260
1248
1248
1248
1260
1248
1248
1254
±260
1016
1260
1248
1248
1242
1242
1242
1260
1242
1260
1248
1254
•1254
•1254
1254
•1248
•1254
•1248
•1254
•1242
•4242
•1254
Concentration
   (yg/kg)

      304
      108
      658
     2930
      586
       58
     1510
     1142
      407
      532
     3160
     1710
    19600
      935
      935
     1780
      810
      111
      137
     2030
     2045
     3300
     2912
      100
       10
     9690
     7210
      108
    48000
    66000
     2800
     2000
                             3-102

-------
                                                        ®EAST DRAIN STATION 2
                                                          SEDIMENT
                                                          4,4-DDT 6^9/kg
                                                          4,4-DDE 1 Vg/kg
                                                          4,4-DDD 27yug/kg
                                                          (OFF MAP)
® MILL CREEK STATION 1
  SEDIMENT
  3/,g/kg 4,4-DDE
  (OFF MAP)
                         SB-19-24
                         (DEPTH 24 ft)
                         DIELDRIN 64*g/kg
                         HEPTACHLOR62/,g/kg
                         4,4 DDT 55/.g/kg
                         ALDRIN45>ug/kg
                         LINDANE 44/,g/kg
                         ENDRIN 61/ug/kg
                           SB-14-34
                           (DEPTH 34ft)
                           4,4-DDT 12,ug/kg
                     OLD SANITARY
                     DISCHARGE LINE
MILL CREEK STATION 8
SEDIMENT
4,4-DDE 2xg/kg
(OFF MAP)
     Data for stations identified as
      are from the 1982 EPA
      Vicinity Survey (See Plate 1)
                                                                  EPA-06-03
                                                               / (DEPTH 3 ft)
                                                                  DIELDRIN 3,34<>g/kg
                                                                  ALDRIN 2,86Q*/g/kg
                                                                  EPA-17-03
                                                                  (DEPTH 3 ft)
                                                                  4,4-DDD 100/ug/kg
                                                                  LINDANE 11.8>.g/kg
                                                                  4,4-DDT 38,ug/kg
                                                                  EPA-SS-06
                                                                  LINDANE 30^g/kg
                                        EPA-SS-05
                                        (DEPTH-SURFACE)
                                        DIELDRIN 145/ug/kg
                                        LINDANE 34/ug/kg

                                               EAST DRAIN STATION 11
                                               SEDIMENT
                                               4,4-DDT 5*g/kg
                                               4,4-DDE 1 Vg/kg
                                               4,4-DDD 19«g/kg
                                               l
                                               EPA-25-09
                                               (DEPTH 9ft)
                                               4,4-DDT 129*g/kg
                                               SB-20-29
                                               (DEPTH 29ft)
                                               HEPTACHLOR EPOXIDE 742y"g/kg
                                               ALDRIN 38Vg/kg
                                               4,4-DDE 122>,g/kg
                                                    FIGURE 3-46
                                                    PESTICIDES IN SOILS
                                                    AND SEDIMENTS
                                                    WESTERN PROCESSING
                                                    Kent, Washington
                                3-103

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                          Table 3-23
                OFF-PROPERTY PCB CONTAMINATION
                      WESTERN PROCESSING
                       KENT, WASHINGTON
 Sample  ID No.

 WP-IB-02-00
 WP-SB-04-00
 WP-SB-04-00
 WP-SB-04-34
 WP-SB-07-00
 WP-SB-08-00
 WP-SB-09-00
 WP-SB-12-00
 WP-SB-13-00
 WP-SB-14-00
 WP-SB-17-00
 WP-SS-01
 WP-SS-02
 WP-SS-03
 WP-SS-04
 WP-SS-04
 EPA-SED-04/V
 EPA-SED-04/V
 EPA-SED-05/V
 EPA-SED-05/V
 EPA-SED-06/V
 EPA-SED-06/V
 EPA-SED-09/V
 EPA-SED-09/V
 EPA-SED-10/V
 EPA-SED-10/V
 Depth
 (feet)

   0
   0
   0
'  34
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
Arochlor
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
PCB-
•1254
•1260
•1248
•1248
1254
•1248
1254
1254
1254
1248
1260
1254
1254
1254
1254
1248
1254
1260
1254
1260
1254
1260
1254
1260
1254
1260
Concentration
   (yg/kg)

      100Ma
    9,600
    4,300
      121
      100M
      270
    1,900
      100M
      100M
    4,100-=—
       28»6
    4,300^
      500K
    1,000°
   14,800^
   10,000
   22,700
   14,500
    1,430
      570
      520
      170
    2,450
    1,060
      440
      730
 M indicates  detected  but  not  quantified  at  the  given detec-
 tion  limit.
 Concentration presented is  a  wet  weight.


The distribution  of  pesticides is  random.  No consistent
trend  is apparent other than that  the  pesticides onsite ap-
pear to be present in  slightly higher  concentrations than in
off-property  soils.

The source of these  pesticides is  unclear.   Nearly all pesti-
cides  identified  can be accounted  for  in  one of two ways.
First, pesticides  are  known  to have been  stored at Western
Processing and thus  may have leaked into  the soil.  However,
pesticides have also been  in common use in the Kent valley
                             3-104

-------
for agricultural purposes.  A brief review of aerial photo-
graphs covering Western Processing and its near vicinity
identified historic uses of these lands for row crops and
pasture.  Pesticides commonly used in the Kent valley and
also found in soils on- and off-property include lindane,
DDT, and aldrin.  DDD and DDE can be accounted for as being
co-metabolites of DDT.  Dieldrin could exist as a biodegrada-
tion product of aldrin.  Heptachlor was not commonly used in
the Kent valley but if present, can be microbially or bio-
chemically reduced to heptachlor epoxide.  Using this ra-
tionale, all the pesticides identified can be accounted for.

The actual source of these pesticides may be a combination
of disposal at Western Processing and agricultural use in
the Kent valley.  DDT and its co-metabolites were identified
in Mill Creek sediments both upstream and downstream from
Western Processing as well as in sediments from the east
drain.  The source of these may be agricultural.  Pesticides
identified in onsite soils, including DDT, DDD, lindane,
aldrin, and dieldrin, may be the result of the waste
handling activities at Western Processing.

Pesticides identified in three off-property borings, SB-14,
SB-19, and SB-20, are less easily accounted for.  Pesticides
in all locations were found at depths of 20 feet or more.
Deposition in these locations would have to be the result of
leaching from surface soils and/or subsurface transport by
groundwater.  The compounds present, including dieldrin,
DDT, DDE, and heptachlor, all have high retardation charac-
teristics and affinities for soil particles in water, making
a groundwater transport process unlikely.  Furthermore, no
traces of these contaminants were found through the soil
column above (or in some cases, below)  these sample
locations.

An evaluation of the persistence of the pesticides found in
SB-14, 19, and 20 is also inconclusive.  Both persistent and
nonpersistent compounds were found.  DDT and metabolites as
well as dieldrin are persistent in the environment.  Depend-
ing on soil pH, DDT has a half-life of up to 190 years.
Dieldrin has been shown to persist in soils from 5 to
25 years.  These pesticides could therefore be accounted for
by agricultural activities.  Lindane and heptachlor, on the
other hand, are readily degraded and their elimination should
be rapid.

For these reasons, it is not possible to identify the source
of pesticides in these borings.  However, given location,
depth, and the types of compounds present, it is suggested
that pesticides in SB-14, SB-19, and SE-20 may be the result
of past agricultural activities.
                            3-105

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3.5.2.5  Oxazolidone in Soils

Oxazolidones  (or, more properly, 2-oxazolidones) are hetero-
cyclic, five-membered ring compounds that contain a carbonyl
group.  Other names by which the compounds are known are
2-oxazolidone, oxazolid-2-one, oxazolidin-2-one, oxazoli-
done-2, and oxazolidinone-2.  The oxazolidones that are
present at the Western Processing site, primarily 3-(2-hy-
droxypropyl)-5-methyl-2-oxazolidone, were received from a
single source.  The oxazolidone compounds are formed
as byproducts of the sulfinol process  for removing CO- from
stack gas.  The reactions that lead to oxazolidone formation
were condensation reactions between C00 and di-isopropano-
lamine  (DIPA).                         2

Oxazolidones themselves are not considered to be hazardous.
However, the reclaimer bottoms from the process usually con-
tain between 5 and 200 ppm sodium arsenite, which is used as
a corrosion inhibitor.  This classifies the material as a
hazardous waste and was the reason why the oxazolidones were
shipped to Western Processing.  Between the period 1975 to
1983, roughly 700,000 gallons of oxazolidone were shipped to
Western Processing.  Approximately 325,000 gallons of oxa-
zolidone-containing liquids were found remaining in tanks on
the site during the summer 1984 Remedial Investigation.
These liquids have since been removed.

Because of its documented presence and frequent occurrence
on the site in high concentrations, oxazolidone [in the form
3-(2-hydroxypropropyl)-5-methyl-2-oxazolidone] is probably a
unique source in the Kent valley and can therefore be used
as an indicator of contamination and contaminant migration.
This compound is extremely soluble and is thought to be mo-
bile in the groundwater.

The main limitation in using oxazolidone as a tracer com-
pound to measure extent of contamination is the fact that it
is a tentatively identified compound.  Its identification
hinges on the particular GC/MS operator's ability to pick
the compound out of a complex array of chemicals for which
reference standards are not commonly available and to match
its mass spectra with an EPA/NIH library spectrum of the
compound.  This is particularly difficult in a soil matrix
because of chemical interference.  For this reason, and the
fact that many laboratories were involved in the analytical
work, it is possible that the compound was passed over in
many samples.

Distribution of Oxazolidone in Soils

Oxazolidone was identified in 50 soil  samples collected dur-
ing the summer 1984 field investigation and during previous
sampling efforts at the Western Processing site;  36 of these
                             3-106

-------
were onsite and 14 were in adjacent areas off the property.
These data are summarized in Table 3-24.

The maximum onsite oxazolidone concentration identified was
130,000 yg/kg in boring EPA-20.  The maximum concentration
offsite was 42,240 yg/kg found in boring IB-02 at 14 feet.

Most of the soil samples in which oxazolidones were iden-
tified were in the 10- to 20-foot depth range.  However,
concentrations greater than 10,000 yg/kg were found up to a
depth of 30 feet.  Thus, it appears that oxazolidones have
moved down through the soil column to at least 30 feet due
to leaching-

Oxazolidone contamination appears to be restricted to onsite
soils and other areas east of Mill Creek.  Oxazolidone was
not identified in any of the samples taken west of Mill
Creek.

Because oxazolidone was not typically analyzed for by the
CLP, it was thought that a possible correlation might be
made between the presence of oxazolidone and arsenic together
in samples.  A review of the inorganics data did not reveal
any such correlation.  Data for this review are provided in
Table 3-25.  Although the concentration of oxazolidone
fluctuates considerably, no such effect can be observed in
the corresponding arsenic concentrations.  Instead, the
detected arsenic levels correspond best with the mean
background concentration of 9.6 ng/kg  (see Chapter 2,
Section 2.3.1.3).  The presence of oxazolidone, therefore,
does not imply the presence of arsenic.

3.5.3  SUMMARY OF SOIL CONTAMINATION DATA

Organic and inorganic priority pollutant contamination of
soils exists at Western Processing in both onsite and off-
property locations. Contamination is greatest in Area I
locations at or near the surface and decreases with
increasing distance and depth from the site.  Off-property
contamination exists at concentrations less than those found
in onsite soils and is most evident in Areas II, V, VI,
and IX.

3.5.3.1  Metals in Soils

Inorganic contamination (i.e., concentrations greater than
background) predominates in Area I soils.  Total indicator
metals in Area I were highest on the south end of the site
where indicator metals exceeded 10,000 mg/kg to depths of 10
feet.  At depths greater than 10 feet, metals in soils on
the south end decreased to background levels.  Metals in the
north half of Area I were present in lower concentrations,
but still in excess of 1,000 mg/kg in soils to depths of
                            3-107

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                        Table 3-24
                  OXAZOLIDONE  IN SOILS
                   WESTERN PROCESSING
                    KENT,  WASHINGTON
Sample ID
                                              Concentration
Onsite Soils

EPA-SS-03
EPA-SS-04
EPA-11-03
EPA-17-03
EPA-20-03
EPA-22-03
EPA-23-03
EPA-02-06
EPA-08-06
EPA-09-06
EPA-10-06
EPA-20-06
EPA-02-09
EPA-05-09
EPA-09-09
EPA-20-09
EPA-22-09
MB-01-010
MB-03-010M
EPA-02-12
EPA-05-12
EPA-09-12
EPA-10-12
EPA-11-12
EPA-12-12
EPA-14-12
EPA-17-12
EPA-20-12
EPA-21-12
EPA-20-15
EPA-22-15
EPA-24-15
MB-02-15
EPA-17-24
EPA-17-27
EPA-17-30

Off-property Soils

SB-09-OOM
SB-02-09
SB-08-09
IB-02-14
SB-01-14M
SB-09-14
IB-01-19M
SB-09-19M
SB-11-19
SB-11-19M
SB-11-24
SB-04-29M
SB-08-29
SB-09-34M
 0
 0
 3
 3
 3
 3
 3
 6
 6
 6
 6
 6
 9
 9
 9
 9
 9
10
10
12
12
12
12
12
12
12
12
12
12
15
15
15
15
24
27
30
 0
 9
 9
14
14
14
19
19
19
19
24
29
29
34
    400  J
   1600  J
 14,000  J
    415  J
    200  J
 92,000  J
    700  J
    950  J
    230  J
    400  J
  6,000  J
 58,000  J
  3,600  J
  1,800  J
 60,000  J
 68,000  J
 39,000  J
    180  J
  5,000  J
  5,400  J
 12,000  J
 27,000  J
 16,000  J
 20,000  J
  1,400  J
    400  J
    300  J
130,000  J
  4,400  J
 34,000  J
    400  J
    580  J
  1,400  J
 49,000  J
 39,000  J
 21,000  J
     73  J
   2,700J
   2,700J
 42,243  J
  1,100  J
  8,387  J
    280  J
     29  J
  2,400  J
 13,000  J
  2,600  J
  3,900  J
  1,200  J
     37  J
aj indicates estimated concentration
                             3-108

-------
                         Table  3-25
           OXAZOLIDONE AND ARSENIC IN  SOIL SAMPLES
            WESTERN PROCESSING, KENT,  WASHINGTON

                                  Concentration (yg/kg)
           Sample Number          Oxazolidone      Arsenic

             MB-01-10                  180Ja         4.2
             MB-02-15                1,400J         3.1
             IB-02-14               42,243J         3.8
             SB-02-9                 2.700J         5.1
             SB-04-14                8,307J         4.0
            J indicates concentration is estimated.
20 feet.   (Note:  Groundwater  contamination by indicator
metals was greatest on the north  end  of the site and lower
on the south end.  This trend  is  opposite  that seen in soils.
Further discussion of this is  provided  in  Section 3.6.1 under
groundwater contamination.)

Indicator metals above background levels in off-property
soils were identified in Areas II,  V, VI,  VIII,  IX, and X.
These areas include land west,  east,  and north of Western
Processing.  Indicator metals  were  detected in concentrations
above background in only one surface  soil  sample collected
south of the site.  Total indicator metals were  found in
surface and near-surface samples  in Areas  V and  VI at concen-
trations greater than 1,000 mg/kg.  Subsurface indicator
metal contamination was identified  in Area V only (boring
IB-02) at a concentration of less than  1,000 mg/kg.

Total indicator metals in Area II east  of  the site were found
in concentrations exceeding 1,000 mg/kg to depths between 10
and 20 feet.  Soil contamination  by metals was generally
restricted to samples taken from  the  north half  of Area II
(although one sample with over 10,000 mg/kg total indicators
was also collected from the far south end).  Surface soil
contamination with indicator metals was most evident in sam-
ples collected from the east berm outside  the Western Pro-
cessing fenceline and on the bottom of  the drainage immedi-
ately east of the site.  Subsurface metals contamination in
Area II was found in an isolated  layer  of  metals exceeding
1,000 mg/kg at a depth of about 9 to  15 feet below the ground
surface.  This layer of metals continued eastward into Area X
as shown by concentrations exceeding  1,000 mg/kg at roughly
the same elevation in boring IB-01  (5 to 10 feet below the
ground surface).

North of the site, indicator metals above  background were
identified in soils from Areas VIII and IX.  Surface soil
samples from Area VIII contained  over 10,000 mg/kg total
                            3-109

-------
indicator metals.  The vertical extent of contamination in
Area VIII is unknown because no subsurface soil samples were
collected here.  Area IX contained indicator metals in ex-
cess of 1,000 mg/kg in samples collected to depths slightly
more than 10 feet.

3.5.3.2  Organics  in Soils

In general, organics were detected more frequently and de-
tected in higher concentration in onsite soils.  Off-property,
organic contamination appeared to be most evident in soils
close to the site  and east  of Mill Creek.  Some off-property
data  (e.g., Area VI) suggest additional sources may be con-
tributing to off-property contamination.

3.5.3.2.1  Volatile Organics in Soils

Indicator volatile organics were found in onsite soils to a
depth exceeding 20 feet.  Indicator volatile concentrations
were highest at borings EPA-15 and EPA-17 near the center of
the site.  The primary indicator volatiles found at these
locations were 1,1,1-trichloroethane, trichloroethene, tol-
uene, and chloroform.  Trans-1,2-dichloroethene was highest
in wells 21 and 24 on the southwest side of the site.
Tetrachloroethene  was highest in well 16 located on the west
edge of the site in the center.

Volatile organics  in Area I soils appear to be most wide-
spread and in highest concentrations at depths of 5 to 9 feet
below the ground surface.   These data suggest an accumulation
of volatiles beneath the site at a depth slightly shallower
than the groundwater table.  This conclusion agrees with
groundwater data from shallow wells  (at depths of 11 to 15
feet) where the maximum concentrations of volatile organics
were also detected.

Volatile organics  in off-property soils were highest in con-
centrations and most widely distributed in Areas V and VI.
Area VI also contained the  maximum off-property volatile
organics detected; 50,000 yg/kg trichloroethene in boring
SB-14.  Data for SB-14 indicate a spill might have occurred
in this area.

Elevated levels of trichloroethene were also detected in
soils from Area X  (IB-01),  which suggest some eastward mi-
gration of volatiles from the site.  Further discussion of
this last point is included in the groundwater summary for
volatile organics  (Section  3.6.3.2.1) and includes a discus-
sion of apparent groundwater flow to the east of the site.

3.5.3.2.2  Semivolatile Organics in Soils

Semivolatile organics were  widely distributed throughout
Area I with PAH's  and phthalates the most predominant

                             3-110

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semivolatiles.  Acid extractable compounds were also detected
in onsite and off-property soils, but in concentrations con-
siderably less than the PAH's or phthalates.  Acid extractable
compounds in soils, primarily phenol and 2,4-dimethylphenol,
were found mostly in onsite soils at depths between 10 and
20 feet.  Acid extractable compounds were rarely detected in
off-property locations and then, for the most part, only in
surface soils.

PAH's were the most concentrated organics detected in soils
at Western Processing.  The single highest PAH concentration
(and the single highest organic detection in Western Process-
ing soils) was phenanthrene at 20,000,000 yg/kg.  Total PAH's
were highest in surface soil samples EPA-SS-08 and EPA-SS-11
at 53 million and 2 million yg/kg, respectively.  Both sam-
pling points are located in the south central section of the
site.  PAH's in other locations were detected primarily at
depths less than 10 feet below ground surface.

Total PAH's in concentrations greater than 10,000 yg/kg were
found in surface soils in Areas II and IX.  PAH's were, for
the most part, undetected in soils at depths greater than
4 feet in these areas.

Total phthalates in onsite and off-property soils follow the
same general distribution patterns as the PAH's, with a few
exceptions.  Three factors concerning phthalates appear most
important.  First, total phthalates in excess of 10,000 yg/kg
were detected in a sediment sample from Mill Creek upstream
of Western Processing.  This suggests that there is at least
some other source of phthalate contamination in the area of
Western Processing besides Western Processing itself.  Second,
some phthalates were found in off-property subsurface soils
from boring SB-07 on Area V.  Phthalates in this boring were
found at depths from 5 to 9 feet and also at depths greater
than 20 feet below the ground surface.  This contamination
appears to be related to phthalates found in nearby onsite
subsurface soils and suggests subsurface migration from
Western Processing.  Finally, phthalates in concentrations
exceeding 1,000 yg/kg were detected in a single off-property
surface soil sample north of the site in Area VIII.  This
detection coincides with elevated metals found in the same
location in Area VIII and confirms the presence of contami-
nation at this location.

3.5.3.2.3  Polychlorinated Biphenyls in Soils

PCB's were widely distributed in onsite and off-property
soils.  Maximum PCB concentrations and the most frequent
occurrences were in Area I.  PCB contamination in Area I
soils were, however, spotty and occurred most frequently in
soil samples from three regions: the northeastern corner of
the site; the northwestern side where the asphalt pad has
recently been constructed; and in a few locations on the
south end of the site.
                             3-111

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PCB s were found in off-property surface soils from Areas II,
III, V, VI, and IX.  PCB's were detected in Area II at three
locations along the east  side of the site.  PCB's  in Area III
were found in one  sample  from a depression south of the site.
PCB's were detected in  five  samples from Area V; concentra-
tions were less than 270  yg/kg in  all  samples but  one which
contained 1,900 yg/kg.  Eight samples  from Area VI contained
PCB's in concentrations ranging from 20 to 10,000  yg/kg.
PCB's in Area IX were the highest  found off-property, having
37,200 yg/kg in one sample.  All but one off-property sample
showing PCB's were detected  in surface soils.  This subsur-
face detection was in boring SB-04 at  34 feet.  This detec-
tion is probably the result  of sampling or analytical error
because it is inconsistent with all other off-property data.

PCB's in Areas II, III, V, and IX  can  be accounted for by
surface water runoff from Western  Processing  (see  Sec-
tion 3.8).  In Area IX, this possibility is reinforced by
the detection of PCB's  in the east berm of Western Process-
ing  (Area II) from which  runoff could  enter a depressed area
along side Western Processing and  then flow northward into
Area IX.  This process  could easily transport PCB's (which
adhere to soil particles) northward from the site  and into
Area IX as suggested.   PCB's in Area II could have been
deposited during construction of the east berm which used
onsite surface soils.   PCB's in other  areas are more likely
the result of overland  flow  from the west side of  Western
Processing.

PCB's in Area VI cannot be accounted for by surface water
runoff from Western Processing.  This  is because Mill Creek,
located between the site  and Western Processing, collects
and diverts surface water from Western Processing  away from
Area VI.  This, plus the  fact that PCB's were detected in
surface soil samples collected from stained spots  in Area VI
indicates that the Area VI contamination may be due to
spills and not migration  from Western  Processing (see also
the discussion above on volatiles  in soils).

3.5.3.2.4  Pesticides in  Soils

Pesticides were detected  sporadically  in onsite and off-
property soils.  The highest concentrations of pesticides
were found in onsite locations and included aldrin, diel-
drin, DDT and derivatives, and lindane.  Pesticides in off-
property locations included  these  as well as heptachlor and
heptachlor epoxide.  The  wide scatter, both in concentration
and detected location,  indicates that  some of these pesti-
cides are the result of activities in  the Kent Valley other
than those at Western Processing.

3.5.3.2.5  Oxazolidone  in Soils

Oxazolidone was found in  many onsite and off-property sur-
face and subsurface locations.  However, because Oxazolidone

                             3-112

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is a tentatively identified compound and not regularly ana-
lyzed for by the CLP, it may have been missed in some samples
and its distribution cannot be fully evaluated.  The presence
of oxazolidone in soils generally supports conclusions re-
garding the extent of contamination as determined using the
indicator metals, volatiles, and semivolatile compounds.  Of
particular importance is the fact that the data to date show
no oxazolidone contamination west of Mill Creek.  Since this
compound is highly water soluble, failure to detect it (in
soils and groundwater)  across Mill Creek suggests that Mill
Creek does present a barrier to westward contaminant
migration from Western Processing.

               3.6  GROUNDWATER CONTAMINATION

Groundwater contamination was evaluated using data from the
3013, the 1983 News Release, the IRI, and the RI data sources
(see Table 3-3).  Fifty-seven priority pollutants were
identified in groundwater samples collected from wells on
Western Processing and 54 in off-property wells.  These
compounds, along with the number of times each occurred, are
presented in Tables 3-26 and 3-27.  Discussions have been
prepared for three groups of priority pollutants (metals,
volatile organics, semi-volatile organics) and oxazolidone.
Semi-volatiles were further subdivided into acid
extractables and base neutral compounds.

Summary figures for each contaminant class have been pre-
pared as an aid to interpreting the three dimensional dis-
tribution of contaminants.  Concentration and depth ranges
were used to simplify the data presentations.  The concen-
tration ranges were chosen to reflect order-of-magnitude
variations in contaminant concentrations and the presence of
contaminants at background levels.  It was assumed that
organic priority pollutants do not occur naturally in the
environment (See Section 3.4.5).  All organic priority pollu-
tants detected in groundwater were considered indicators of
contamination.

A total background concentration for the indicator metals
was calculated by summing the individual background concen-
trations provided in Table 3-5  (525 yg/L).  Wells having a
lesser total concentration were assumed at background and
therefore uncontaminated.

Three depth ranges were selected to illustrate the ground-
water contamination: shallow (zero to 15 feet), intermediate
(15 to 60 feet), and deep (61 to 155 feet).  These depth
ranges were chosen based on the average depths over which
the wells were screened.

The data presented in the groundwater contaminant summary
figures were compiled from the various sources listed on
                            3-113

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                         Table  3-26
NUMBER OF  OCCURRENCES OF DETECTED PRIORITY POLLUTANTS
    IN GROUNDWATER WELLS ON  WESTERN  PROCESSING SITE
                     KENT, WASHINGTON

                                                  Number of
             	Chemical Name	           Occurrences

 1.           1,1,1-Trichloroethane                   18
 2.           1,1,2-Trichloroethane                     5
 3.           1,1-Dichloroethane                      11
 4.           1,1-Dichloroethene                        9
 5.           1,2-Dichlorobenzene                       1
 6.           1,2-Dichloroethane                        6
 7.           2,4,6-Trichlorophenol                     4
 8.           2,4-Dichlorophenol                        4
 9.           2,4-Dimethylphenol                      13
 10.         2,6-Dinitrophenol                         2
 11.         2-Chlorophenol                            1
 12.         2-Nitrophenol                             3
 13.         4-Nitrophenol                             2
 14.         Antimony                                  2
 15.         Arsenic                                   9
 16.         Benzene                                   9
 17.         Benzo(A)anthracene                        1
 18.         Benzo(A)Pyrene                            1
 19.         Benzo (B)Fluoranthene                     1
 20.         Benzo(GHI)Perylene                        1
 21.         Benzo(K)Fluoranthene                      1
 22.         Benzyl Butyl  Phthalate                    2
 23.         Beryllium                                2
 24.         Bis(2-Chloroethyl)Ether                   2
 25.         Bis(2-Ethylhexyl)Phthalate                3
 26.         Cadmium                                 21
 27.         Chlorobenzene                             2
 28.         Chloroethane                              2
 29.         Chloroform                             15
 30.         Chloromethane                             1
 31.         Chromium                                21
 32.         Chrysene                                  1
 33.         Copper                                  25
 34.         Cyanide                                 16
 35.         Di-N-Octyl Phthalate                      3
 36.         Dibenzo(A,H)Anthracene                    1
 37.         Ethylbenzene                             7
 38.         Fluorotrichloromethane                    4
 39.          Indenod, 2,3-CD) Pyrene                    1
 40.          Isophorone                               2
 41.         Lead                                   12
 42.         Mercury                                 2*
 43.         Methylene Chloride                     22
 44.          N-Nitrosodiphenylamine                    !
 45.          Naphthalene                              ^
 46.          Nickel                                  2*
 47.          pentachlorophenol                         -J
 48.          Phenol                                  ^
 49.          Selenium                                 *
 50.          Silver                                   f
 51.          Tetrachloroethene                        ^
 52           Toluene
 53           Trans-l,2-Dichloroethene                 18
 54'          Trichloroethene                         2°
 55]          Vinyl Chloride                          ^


                              3-114

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                        Table 3-27
NUMBER OF  OCCURRENCES  OF DETECTED PRIORITY  POLLUTANTS
     IN GROUNDWATER WELLS FROM OFF-PROPERTY  WELLS
                    WESTERN PROCESSING
                     KENT,  WASHINGTON

                                                   Number of
                    Chemical Name                  Occurrences
 1.           1,1,1-Trichloroethane                     8
 2.           1,1,2-Trichloroethane                     1
 3.           1,1-Dichloroethane                        4
 4.           1,1-Dichloroethene                        5
 5.           1,2-Dichloroethane                        1
 6.           2,4-Dichlorophenol                        2
 7.           2,4-Dimethylphenol                        2
 8.           2,6-Dinitrophenol                         2
 9.           2-Chlorophenol                           1
 10.          2-Nitrophenol                             2
 11.          4-Nitrophenol                             1
 12.          Acenaphthene                             1
 13.          Acenaphthylene                           1
 14.          Aldrin                                   1
 15           Arsenic                                 14
 16.          Benzene                                  6
 17.          Benzo(A)Pyrene                           1
 18.          Benzyl Butyl Phthalate                    2
 19.          Beryllium                                1
 20.          Bis(2-Ethylhexyl)Phthalate                1
 21.          Cadmium                                 21
 22.          Carbon Tetrachloride                      2
 23.          Chloroethane                             2
 24.          Chloroform                              16
 25.          Chloromethane                             3
 26.          Chromium                                26
 27.          Copper                                  16
 28.          Cyanide                                  3
 29.          Dieldrin                                 1
 30.          Diethyl Phthalate                         3
 31.          Dimethyl Phthalate                        1
 32.          Ethylbenzene                            11
 33.          Fluoranthene                             1
 34.          Fluorene                                 1
 35.          Heptachlor                               2
 36.          Heptachlor Epoxide                        1
 37.          Hexachloroethane                         1
 38.          Isophorone                               3
 39.          Lead                                    26
 40.          Mercury                                  4
 41.          Methylene Chloride                       19
 42.          N-Nitrosodiphenylamine                    4
 43.          Naphthalene                              2
 44.          Nickel                                  17
 45.          Phenanthrene                             1
 46.          Phenol                                   7
 47.          Silver                                   3
 48.          Tetrachloroethene                        12
 49.          Toluene                                 17
 50.          Trans-1,2-Dichloroethene                  8
 51.          Trichloroethene                          9
 52.          Vinyl Chloride                           3
 53.          Zinc                                    36
                            3-115

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Table 3-2.  Each well has been sampled at least once, some
wells have been sampled more than once.  Consideration was
given to the various sampling dates and the data for the
groundwater summary maps were compiled in as consistent a
manner as possible.  Contaminant concentrations for all
shallow wells  (01 through 30) were developed from the 3013
report.  Intermediate depth well contaminant concentrations
were developed from the 3013 Report  (Wells ID, 11D, 17D,
22D, and 25D), the 1983 News Release  (i.e., source EPAGW,
Wells 31S, 32S, 33S, and 34S), the IRI report  (Wells 38, 39,
40, 43, 44), and the RI report  (Well MB-02).  Contaminant
concentrations for the deep wells were developed from the
1983 News Release  (wells 31D, 32D, 33D, and 34D), the IRI
report (Wells 35, 36, 37, 41, and 42), and the RI report
(Wells MB-01 and 03).

Wells that have been sampled more than once include num-
bers 13, 19, 27, 28, 29, 30, 31D, 32D, 33D, 34S, 34D, and
35.  A comparison of the data between multiple samplings is
provided in each of the sections following discussions of
the groundwater summary figures.

Contaminants in groundwater have also been discussed in re-
gards to the water quality criteria  for each indicator com-
pound and compound class discussed in Chapter 2.  This
comparison was completed to provide the reader with infor-
mation adequate to evaluate the relative importance of each
indicator contaminant.  A discussion of the application of
these criteria to human health is provided in Chapter 4.

3.6.1  METALS IN GROUNDWATER

Total dissolved indicator metals measured in the shallow
groundwater are shown on Figure 3-47.  Concentrations of
100,000 yg/L or more were found in the middle of Area I, at
the north end of Area X, and at the south end of Area IX.
Concentrations greater than 10,000 yg/L were identified in
shallow wells at the north end of Area I.  Shallow wells at
the south end of Area I were typically at background with
the principal exception of Well 26, which contained
34,000 yg/L.

Table 3-28 contains a summary of some of the highest concen-
trations of indicator metals detected in shallow wells during
the 3013 study.  The most frequently detected compound in
high concentrations was zinc.  The eight highest individual
metal levels detected were all zinc, ranging in concentra-
tions from a maximum of 510,000 yg/L to 350,000 yg/L.  The
metals in the next highest concentrations were nickel, chro-
mium, and cadmium.  These data are summarized on Table 3-29.

Of the metals in shallow wells with concentrations greater
than 10,000 yg/L, zinc was the most prevalent with
                             3-116

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OLD SANITARY
DISCHARGE LINE
                                                                                                                     Oft Map
Legend: All concentrations in /*g/L
      K indicates concentrations x 1,000.
      (ex. 23.7K = 23,700 M9/L)
              > 100,000 /ug/L
           Q 10000-100000 uq/L

           ® ^000-10,000 ^g/L
           © 525-1,000 ug/L
           O < Background

           27 V\fell Number
           101K Total Concentrations in
                                                                                                        OLD SANITARY
                                                                                                       DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
                                                                                                                                                  DEPTH:  60'-135'
                                                                                                                                                                                               FIGURE 3-47
                                                                                                                                                                                               INDICATOR PRIORITY POLLUTANT METALS
                                                                                                                                                                                               IN GROUNDWATER
                                                                                                                                                                                      3-117

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                       Table  3-28
  MAXIMUM INDICATOR METALS IN SHALLOW GROUNDWATER
        WESTERN PROCESSING,  KENT, WASHINGTON
  Compound

Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Well Number

     10
     14
     28
     IIS
     17S
     16

     14
     17S
     10
     28
     03
     IIS
     16S

     05
     17S
     10
     14
     US
     03
     15
     28

     03
     US
     17S
     14

     10
     US
     28
     14
     17S
     05
     27
     03
     16
     06

     28
     18
     10
     14
     17S
     29
     IIS
     19
     27
     16
     26
     20
     12
Depth       Concentration
(feet)           (ug/L)

 13               60,000
 13               12,000
 10               5,600
 10.5             4,800
 13.5             4,500
 13                 580

 13               65,000
 13.5             32,000
 13               17,000
 10               6,100
 10               2,200
 10.5             1,400
 13                 600

 10               13,000
 13.5             7,200
 13               6,300
 13               4,300
 10.5             4,200
 10               3,800
 14.5             3,400
 10                 590

 10               3,300
 10.5             1,600
 13.5             1,600
 13                 730

 13             280,000
 10.5             77,000
 10               77,000
 13               76,000
 13.5             26,000
 10               25,000
 10               6,400
 10               3,800
 13               2,500
 10               1,100

 10             510,000
 14.5           510,000
 13             400,000
 13             380,000
 13.5           360,000
 10             350,000
 10.5           350,000
  4             100,000
 10               94,000
 13               64,000
 14               34,000
 13               11,000
  9               8,400
                           3-119

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                         Table 3-29
                SUMMARY OF MAXIMUM INDICATOR
                    METALS IN GROUNDWATER
            WESTERN PROCESSING, KENT, WASHINGTON
Compound

Zinc
Zinc
Zinc
Zinc
Zinc
Zinc
Zinc
Zinc
Nickel
Zinc
Zinc
Zinc
Nickel
Nickel
Nickel
Nickel
Chromium
Zinc
Cadmium
Zinc
Chromium
Zinc
Nickel
Nickel
Chromium
Copper
Cadmium
Zinc
Zinc
Copper
Nickel
Copper
Chromium
Zinc
Cadmium
Well Number

    28
    18
    10
    14
    11D
    17S
    29
    US
    10
    17D
    19
    27
    18
    IIS
    14
    11D
    14
    16
    10
    26
    17S
    22D
    17S
    05
    10
    05
    14
    20
    12
    17S
    27
    10
    28
    03
    28
Depth

 10
 14.5
 13
 13
 27.5
 13.5
 10
 10.5
 13
 28.5
  4
 10
 10
 10.5
 13
 27.5
 13
 13
 13
 14
 13.5
 25
 13.5
 10
 13
 10
 13
 13
  9
 13.5
 10
 13
 10
 10
 10
Concentration
    (yg/L)

   510,000
   510,000
   400,000
   380,000
   375,000
   360,000
   350,000
   350,000
   280,000
   160,000
   100,000
    94,000
    77,000
    77,000
    76,000
    69,000
    65,000
    64,000
    60,000
    34,000
    32,000
    30,000
    26,000
    25,000
    17,000
    13,000
    12,000
    11,000
     8,400
     7,200
     6,400
     6,300
     6,100
     5,900
     5,600
                             3-120

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12 samples showing concentrations in excess of this level.
Nickel was the next most commonly detected metal in shallow
wells, having six hits with concentrations greater than
10,000 ct.g/L, followed by chromium with three, cadmium_:with
two, and copper with one.  Lead was not detected in
concentrations above 10,000 yg/L.

Maximum levels of indicator metals in shallow groundwater
appear to be localized around Wells 10, 11, 14, and 28.
Most indicator metals were detected in high concentrations
in these wells.  Wells 16, 19, 26, 27, and 29 are also nota-
ble for containing high concentrations of zinc.  Wells 3
and 5 contained elevated levels of copper, lead, and nickel.

Total indicator metals in intermediate depth wells were found
to exceed 100,000 yg/L at two locations in the central to
north-central region of Area I (Wells 11D and 17D).  Metals
in these two wells were predominantly zinc (375,000 and
160,000 yg/L, respectively) and nickel (69,000 and 3,200 yg/L,
respectively).  Well 22, located in the south-central por-
tion of Area I, contained more than 10,000 yg/L total indi-
cator metals.  The predominant element in Well 22 was zinc
(at 30,000 yg/L).  Most intermediate depth wells contained
background concentrations of total indicator metals.

One off-property intermediate depth well, Well 31S, had in-
dicator metals at concentrations slightly higher than back-
ground (see Table 3-30).  Background metal concentrations
for this well exceeded criteria for all indicators but cad-
mium.  All other off-property intermediate depth wells con-
tained less than 500 yg/L and can be considered.
                         Table 3-30
     INDICATOR METALS IN OFF-PROPERTY INTERMEDIATE DEPTH
        WELLS HAVING CONCENTRATIONS ABOVE BACKGROUND
                     WESTERN PROCESSING
                      KENT, WASHINGTON

              	Concentration  (yg/L)	
 Well   Depth
Number  (feet) Cadmium Chromium Copper Lead Nickel Zinc Total
 31S
50
59
171
198
58
241
727
Source:  1983 news release identified as source "EPAGW" on
         Table 3-2.

— indicates not detected.
                            3-121

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Deep well contamination ranged from a high of 1,315 yg/L in
onsite well MB-03  to less than 525 yg/L in most other wells.
Indicator metals  in off-property deep wells were above back-
ground in samples  collected from Wells 32D and 34D.  Data
for these wells are provided on Table 3-31.  A comparison of
these data with the background levels presented in Table 3-5
reveal that contamination is primarily due to elevated levels
of zinc.  Zinc was above background in each of these wells.
Well 34D contained the most compounds in concentrations over
background.   These compounds included zinc, nickel, and
chromium.  Cadmium was above background in Well 32D.  All
other deep off-property wells contained less than 525 yg/L
total indicator metals and can be considered as background.

Several wells were sampled more than once.  Total indicator
metals for these  wells are provided on Table 3-32.  Indicator
metals remained roughly the same in all wells.
                          Table 3-31
               INDICATOR METALS IN OFF-PROPERTY
         DEEP WELLS IN CONCENTRATIONS ABOVE BACKGROUND
                      WESTERN PROCESSING
                       KENT, WASHINGTON

 Well   Depth 	Concentration  (yg/L)	
Number   (feet)  Cadmium  Chromium Copper  Lead   Nickel  Zinc  Total

  32D    101     9.5       13     —     32     —    548    603
  34D    129     5.8       32    103     70     83    206    500
— indicates not detected.
Source:  1983 News Release  identified as source "EPAGW" in Table 3-2.


Concentrations of individual metals in groundwater are dis-
cussed  below in comparison with the USEPA criteria for the
protection of aquatic life and human health and welfare.
Only  metals from the list of critical compounds are included.
Maximum and 24-hour average allowable freshwater criteria as
well  as human health criteria were compared against the con-
centrations of dissolved metals in groundwater.  This was
done  because groundwater flow is a pathway of contamination
in Mill Creek and could therefore be a source of harm to
aquatic life.

Criteria for the protection of aquatic life from toxic metals
are sometimes variable depending on water hardness (See
Table 2-1).  In those instances, a hardness of 100 mg/L as
CaCO  has been assumed because this value is representative
of hardness values that have been measured in Mill Creek.
                              3-122

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                                            Table 3-32
                      TOTAL INDICATOR METALS IN WELLS SAMPLED MORE THAN ONCE
                               WESTERN PROCESSING, KENT, WASHINGTON
                                                 Concentration by Source (yg/L)
     Depth Range

    Shallow
    Intermediate

    Deep
|SJ
U)
Well Number

     13
     19
     27
     28
     29
     30

    34S

    31D
    32D
    33D
    34D
    35
     3013
(Aug-Sept  1982)

        441
    101,215
    100,700
    599,300
    351,050
        263
  EPAGW
(June  1983)

    2,604
   79,219
   64,316
  528,614
  426,552
      421
                         313

                         363
                         603
                         310
                         500
    IRI
(Sept  1983)
RI and Radian
(June 1984)
                                                                                    88,053
                                                                                   641,240
                                  483
                     111
                      79
                     120
                     147
                     142
                                                   2,995
     -- indicates no sample collected.
     Sampling period.

-------
Cadmium.  Cadmium was detected in concentrations exceeding
criteria in 33 monitoring wells.  Wherever cadmium was
detected, the measured concentrations exceeded the 24-hour
average and/or the maximum recommended freshwater aquatic
life criteria of 0.025 and 3.02 yg/L, respectively (see Fig-
ure C-17, Appendix C).  Both of these criteria may be revised
to 4.5 yg/L in the future, in which case fewer wells  (but
still a majority) will exceed the criteria.  Cadmium was
detected in concentrations above background in all onsite
wells except numbers  1, 4, 23, 24, and 25.  The highest
observed groundwater  concentration, 60,000 yg/L, was in a
13-foot-deep well  (No. 10) in the northeast portion of the
site adjacent to Mill Creek.

Most of the wells located in the central and northern half
of the site, as well  as one well off-property to the north
and one to the west,  have yielded concentrations of cadmium
greater than 85 yg/L.  This is the concentration in water at
which the allowable daily intake of 170 yg/day of cadmium
would be exceeded assuming an average consumption of two
liters per day.  The  drinking water standard of 10 yg/L was
also exceeded in most wells where cadmium was detected.

Chromium.  Chromium was detected in 35 monitoring wells in
concentrations above  background.  Data were unavailable to
distinguish between CrIII and CrVI.  Chromium concentrations
are compared against  criteria for both trivalent and hexa-
valent chromium.  As  shown in Figure C-18  (Appendix C) ,
chromium concentrations in all wells where it was detected
exceeded the 24-hour  average freshwater aquatic life cri-
teria for hexavalent  chromium of 0.29 yg/L (which may be
revised to 7.2 yg/L).  Many wells also exceeded the maximum
recommended freshwater aquatic life criteria for hexavalent
chromium of 21 yg/L  (which may be revised to 11 yg/L) .  Four
wells (numbers 10, 14, 17S, and 28) had concentrations in
excess of the maximum recommended freshwater aquatic cri-
teria for trivalent chromium of 4,692.  The highest ground-
water concentration of 65,000 yg/L was observed in a 15-
foot-deep well (number 14) in the north central portion of
the site.

The recommended allowable daily intake for human consumption
of trivalent chromium is 125,000 yg/day.  Assuming consump-
tion of two liters per day, the maximum concentration accept-
able is 62,500 yg/L, which was exceeded in only one well,
number 14, as discussed above.  The ADI for hexavalent chro-
mium is 175 yg/day (i.e., 87.5 yg/L).  It was exceeded in
many wells onsite and also in off-property Wells 13,  27,
and 28 in Area IX.

Copper.   Copper was detected in 30 monitoring wells in con-
centrations above background (see Figure C-19, Appendix C).
                             3-124

-------
Concentrations of copper exceeded the 24-hour average fresh-
water aquatic life criteria of 5.6 yg/L  (which may be revised
to 11 yg/L) in wells where it was detected.

The majority of the wells also had concentrations of copper
which exceeded the maximum recommended criteria of 22 yg/L
(which may be revised to 11 yg/L) for the protection of
aquatic life.  The highest observed concentration of copper
was 13,000 in a 10-foot-deep well in the north central sec-
tion of the site  (well number 05).

Nine wells, all of which were located onsite or immediately
adjacent to the site, contained copper in concentrations
which exceeded the human organoleptic value of 1,000 yg/L  (a
concentration that causes objectionable tastes in drinking
water).

Lead.  Concentrations of lead in many of the shallow and
deep onsite and near off-property wells exceeded criteria
for aquatic life and human health (see Figure C-20, Appen-
dix C).  The 24-hour average freshwater aquatic life cri-
teria of 3.8 yg/L (which may be revised to 2.5 yg/L) was
exceeded in all wells where lead was detected.  The maximum
recommended value for freshwater aquatic life of of 172 yg/L
(which may be revised to 64 yg/L) was equaled or exceeded in
15 wells.  The human health (drinking water) criteria of
50 yg/L was exceeded in all onsite wells where lead was
detected, and 11 wells off-property.  The highest concen-
tration of lead was found in Well 03 located on the north-
eastern edge of the site.

Nickel.  Nickel was found in concentrations above background
in 33 wells.  Nickel concentrations exceeded the maximum
24-hour average freshwater aquatic life criteria of 95 yg/L
in 31 wells  (see Figure C-21, Appendix C).  Twenty-five of
these wells were located onsite and six were located off-
property adjacent to the site.  Eleven wells, all located
onsite except one that was immediately adjacent on the west
side  (Well 28), exceeded the maximum recommended freshwater
aquatic life criteria of 1,844 yg/L.  The highest observed
level of nickel, 280,000 yg/L, was in a 13-foot-deep well in
the northwestern portion of the site (Well 10).

Ten onsite wells, all located on the northern half of the
site, had nickel concentrations which exceeded the allowable
daily intake concentration of 750 yg/L for humans calculated
from the ADI of 1,500 yg/day.  Off-property wells 27, 28,
and 29 also had concentrations in excess of 750 yg/L of
nickel.

Zinc.  Zinc was detected in concentrations above background
in 43 monitoring wells drilled around Western Processing.
                            3-125

-------
The majority of the onsite and nearby off-property ground-
water sampling wells had concentrations of zinc which, if
discharged to a surface water body, would exceed the 24-hour
average recommended freshwater aquatic life criteria of
47 yg/L  (see Figure C-22, Appendix C).  The maximum allow-
able freshwater aquatic criterion of  321 yg/L was exceeded
in most of the onsite wells and  some  of the near off-property
wells.  Highest concentrations generally occurred in the
central portions of the site.  Zinc was detected in all on-
site wells but number 24.  Monitoring well 35 was the only
off-property well with relatively high concentrations of
zinc  (2,260 yg/L).  The highest  concentration, 510 ,00_CL-ag/L,
was observed in two wells, one just outside the west central
boundary of the site  (Well 28) and one onsite near the south-
east central boundary of the site  (Well 18), respectively.

3.6.2  ORGANICS IN GROUNDWATER

Organic contamination of groundwater  was identified in onsite
and off-property monitoring wells.  Contamination was greatest
in onsite wells and decreased in extent and concentration
with increasing depth and distance from the site.  Contamina-
tion in off-property wells was most pronounced in wells adja-
cent to the site to the west and north.  Lower levels of
contamination were also apparent in one off-property well
located east of the site and another  off-property well
located west of Mill Creek.

The nature and extent of organic contamination in groundwater
has been discussed by chemical type to match the format of
the discussions previously presented  regarding soil contami-
nation.  The organic chemical types to be discussed include
volatiles, semivolatiles, and oxazolidone.  Semivolatiles
were further divided into acid extractables and base/neutral
compounds.  PCB's and pesticides in groundwater were not
discussed because no significant contamination by these chem-
ical types was detected.

3.6.2.1  Volatile Organics in Groundwater

Volatile organic priority pollutants were detected in onsite
and off-property wells.  The occurrence of these compounds
is summarized in Table 3-33.

The distribution of total volatile priority pollutants is
shown in Figure 3-48.  All volatile priority pollutants were
used to prepare Figure 3-48 because a review of the data
identified volatile priority pollutants other than the indi-
cators that were important to a  discussion of the extent of
volatile contamination in groundwater.

Several volatile compounds (chloroform, ethylbenzene, tetra-
chloroethene, toluene, and 2-butanone) were detected in
                            3-126

-------
                         Table 3-33
     NUMBER OF OCCURRENCES OF DETECTED VOLATILE PRIORITY
                  POLLUTANTS IN GROUNDWATER
            WESTERN PROCESSING, KENT, WASHINGTON

                                                 Number of
                  Chemical Name                  Occurences
Shallow Wells
             1,1,1-Trichloroethane                   22
             1,1,2-Trichloroethane                    6
             1,1-Dichloroethane                      13
             1,1-Dichloroethene                      12
             1,2-Dichloroethane                       7
             Benzene                                 13
             Chlorobenzene                            2
             Chloroethane                             4
             Chloroform                              19
             Chloromethane                            3
             Ethylbenzene                            10
             Fluorotrichloromethane                   4
             Methylene Chloride                      27
             Tetrachloroethene                       14
             Toluene                                 34
             Trans-1,2-Dichloroethane                17
             Trichloroethene                         28
             Vinyl Chloride                           8

Intermediate Wells

             1,1,1-Trichloroethane                    3
             1,1-Dichloroethane                       1
             1,1-Dichloroethene                       2
             Carbon Tetrachloride                     1
             Chloroform                               8
             Ethylbenzene                             5
             Methylene Chloride                       8
             Tetrachloroethene                        6
             Toluene                                  6
             Trans-1,2-Dichloroethane                 4
             Trichloroethene                          7
             Vinyl Chloride                           1

Deep Wells
             1,1,1-Trichloroethane                    1
             1,1-Dichloroethane                       1
             Benzene                                  2
             Chloroform                               4
             Chloromethane                            1
             Ethylbenzene                             3
             Methylene Chloride                       6
             Tetrachloroethene                        3
             Toluene                                  5
             Trans-1,2-Dichloroethane                 5
             Trichloroethene                          2
             Vinyl Chloride                           1

                            3-127

-------
trace concentrations in groundwater samples from Wells 35
to 44.  A review of data  from transport and transfer blanks
submitted with these samples indicated that the occurrence
of trace amounts of these contaminants was due to cross con-
tamination.  For this reason, unquantified trace detections
of these compounds were not included in the contaminant
totals.

Wells shown in Figure 3-48 were analyzed at detection limits
ranging from about 2.5 to approximately 100 yg/L.  In general,
wells with the greatest amount of volatile contamination
were analyzed at the higher detection limits.  Wells where
volatiles were not detected were generally analyzed at the
lower detection limits.  Wells having no volatile contamina-
tion may be considered uncontaminated or at levels less than
2.5 yg/L.

Total volatiles in shallow groundwater were highest in well
samples collected from the middle of Area I.  Total vola-
tiles in concentrations greater than 100,000 yg/L  (See
Table 3-34) were found in Wells 15  (1,346,000 yg/L); 21
(660,000 yg/L); 09  (250,000 yg/L);  11  (204,000 yg/L); 27
(183,000 yg/L); and 17S  (123,000 yg/L).  The maximum concen-
trations of total indicator volatiles  (all depths) were
found in Wells 15 and 21.

Shallow groundwater contained the greatest volatile contami-
nation.  In order of decreasing concentration, the following
volatiles were detected in their highest concentrations in
the following shallow wells:

     o    Methylene chloride—Wells 15 and 9
     o    Trichloroethene—Wells 15, 21, IIS, and 17S
     o    1,1,1-Trichloroethane—Wells 15 and IIS
     o    Trans-1,2-dichloroethene—Well 21

These wells may be considered potential source areas from
which volatile organics could migrate.

Well 15, located on the east edge of the site, contained the
highest total volatile organics found in any well at any
depth.  Methylene chloride, 1,1,1-trichloroethane, and tri-
chlorothene made up more than 90 percent of the total vola-
tile concentration.  Other contaminants in Well 15 having
individual concentrations greater than 10,000 yg/L included
1,l-dichloroethane, chloroform, and 1,2-dichloroethene.

Total volatile organics in intermediate depth wells are seen
in Figure 3-48 to be highest in onsite wells.  Well 11D con-
tained the most volatiles found in any intermediate well
with 271,000 yg/L.  Other onsite wells having high volatiles
include 22D (24,800 yg/L) and 17D (2,590 yg/L).
                            3-128

-------
        WESTERN PROCESSING
              22S
              578
              e
                        OLD SANITARY
                       DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
                                                                                                                                      DEPTH:  60'-135'
Legend: All concentrations in >Ug/L
 £ > 100,OOOjUg/L
 Q 10,000-100,000 >Ug/L
 ® 1,000-10,000>ug/L
 © 1-1,OOOAg/L
 O Not Detected
 27 Well Number
101K Total Concentrations in/ug/L
                                                                                                                                                                                              FIGURE 3-48
                                                                                                                                                                                              TOTAL PRIORITY POLLUTANT VOLATILES
                                                                                                                                                                                              IN GROUNDWATER
                                                                                                                                                                                   3-129

-------
                             Table  3-34
               VOLATILE  ORGANICS  IN SHALLOW WELLS
         HAVING  MORE  THAN 100,000  ug/L  TOTAL  VOLATILES
              WESTERN  PROCESSING, KENT,  WASHINGTON
    Well Number
Onsite Wells
15
Depth
(feet)
 14.5
    TOTAL
21
 13
    TOTAL
                      13
    TOTAL
US
 10.5
    TOTAL
17
 13.5
    TOTAL

Off-Property Wells

27                    10
    TOTAL
        Compound
Methylene Chloride
1,1,1,-Trichloroethane
Trichloroethene
1,1-Dichloroethane
Chloroform
1,2-Dichloroethane
Toluene
Trans-1,2-Dichloroethene
Trichloroethene
Methylene Chloride
Vinyl Chloride
          Methylene Chloride
          Trichloroethene
          1,1,1-Trichloroethane
          Trans-1,2-Dichloroethene
          Toluene
Trichloroethene
1,1,1-Trichloroethane
Methylene Chloride
Toluene
1,1-Dichloroethane
Trichloroethene
Methylene Chloride
Toluene
Chloroform
Benzene
1,1,1-Trichloroethane
Fluorotrichloromethane
Concentration
    (yg/L)
    720,000
    340,000
    210,000
     33,000
     27,000
     16,000
          Trichloroethene
          1,1,1-Trichloroethane
          Methylene Chloride
          Chloroform
          Toluene
 M indicates compound detected  but  not quantified.

                                 3-131
  1,346,005

    390,000
    170,000
    100,000
        360
    660,360

    220,000
     17,000
      5,500
      4,600
      2,400
    249,500

     80,000
     73,000
     46,000
      2,800
      2,100
    203,900

     42,000
     42,000
     22,000
     12,000
      2,200
      1,700
        920
    122,820
                               140,000
                                20,000
                                16,000
                                 6,700_
                              	5M£
                               182,705

-------
and ?5sP  suL!*i1S had me«««ble volatiles in Wells 32S
Well t^Q  *UgJestln9  SOI"e migration in these directions.
          S gained the maximum concentration of any off-
                                              with 3'570
                 in  intern>ediate depth wells are summarized
           -35 by descending concentration for onsite and
off-property wells.   Methylene chloride and trichloroethene
predominate.  Other volatiles frequently occurring in high
concentrations  include  1 ,1 ,1-trichloroethane, chloroform,
and toluene.

Contamination in intermediate Well  11D consisted of over
90 percent methylene chloride.  Trichloroethene, 1,1,1-
trichloroethane, trans-l-2-dichloroethene, and toluene were
also present in this well  in concentrations greater than
780 yg/L.  Onsite Well  22D contained trichloroethene at
17,000  yg/L as  well as  chloroform at 7,800 yg/L.  Well 17D
contained  roughly 80 percent methylene chloride and tri-
chloroethene as well as some toluene and chloroform.  Well ID
contained  less  than 100 yg/L of trichloroethene, trans-1,2-
dichloroethene, and 1 , 1 , 1-trichloroethane.

Contamination at approximately  10 yg/L trichloroethene was
detected in onsite  intermediate Well MB-02 at 45 feet.  MB-02
is the  deepest  onsite intermediate  well drilled, suggesting
some contaminant migration downward at this location.  Slight
downward vertical gradients measured in the summer of 1984
between MB-01 and MB-02 support this concept.  Additional
evidence is found in Wells 17D  and  deep well MB-01.  Vola-
tiles in Well 17D at 28.5  feet  and  MB-01 at 85 feet both
included trichloroethene.  These wells are close together
and suggest that this contamination migrated downward from
the shallow groundwater (see discussion on volatiles in
shallow groundwater) .

Off-property intermediate Wells 32S and 34S varied consid-
erably  in  total volatiles.  Well 32S contained a wide vari-
ety of  contaminants  as  shown in Table 3-35.  Contamination
in Well 32S consisted of over 80 percent trichlorethene and
methylene  chloride  as well as lower levels of 1 , 1 , 1-trichloro
ethane, carbon  tetrachloride, 1 , 1-dichloroethane, tetrachloro
ethane, 1 , 1-dichloroethene, trans-1 ,2-dichloroethene, and
chloroform.  Contaminants in Well 34S included trichloro-
ethene, vinyl chloride, and 1 , 1-dichloroethene.

Volatile organic  contamination in deep wells was identified
in two  onsite locations, MB-01 and MB-03, and three off-
property locations:   32D, 34D, and 35.   Table 3-36 contains a
summary of the  volatile contaminants detected in these wells.
Most volatiles  were  identified in concentrations too low to
quantify.  Trichloroethene was quantified in Well MB-03 at
                            3-132

-------
                             Table  3-35
         VOLATILE ORGANICS  IN INTERMEDIATE DEPTH WELLS
                         WESTERN PROCESSING
                          KENT,  WASHINGTON
    Well Number
Onsite Wells
11D
Depth
(feet)
 27.5
    TOTAL
22D
    TOTAL

17D



    TOTAL

MB-02

ID


    TOTAL

Off-Property Wells

32S
   25
 28.5
   45

 28.5
   23
    TOTAL
34S
   57
    TOTAL
        Compound
Methylene Chloride
Trichloroethene
1,1,1-Trichloroethane
Toluene
Trans-1,2-Dichloroethene
Trichloroethene
Chloroform
Methylene Chloride
Trichloroethene
Toluene
Chlorofrom
Trichloroethene

Trichloroethene
Trans-1,2-Dichloroethene
1,1,1-Trichloroethane
Concentration
   (yg/L)
   250,000
    14,000
     5,200
     1,100
       780
   271,080

    17,000
     7,800
    24,800

     1,200
       830
       430
       130
     2,590

        10

        46
        18MC
       6.8M
Trichloroethene
Methylene Chloride
1,1,1-Trichloroethane
Carbon Tetrachloride
1,1-Dichloroethane
Tetrachloroethene
1,1-Dichloroethene
Trans-1,2-Dichloroethene
Chloroform
Trichloroethene
Vinyl Chloride
1,1-Dichloroethene
                                          70.8
     2,000
     1,000
       300
        70
        70
        50
        50
        20M
        10M
     3,570

        70
        10M
        _5M
        85
 M indicates compound detected  but  not quantified.
Note: Data for Wells 11D,  22D,  17D,  and  ID are from the 3013 report.
      Data for wells 32S and 34S  are from the 1983 EPA news release
      (source EPAGW).  Data for MB-02 are from the 1984 PI report.
                                 3-133

-------
                             Table  3-36
                  VOLATILE ORGANICS  IN DEEP WELLS
                         WESTERN PROCESSING
                          KENT,  WASHINGTON3
    Well Number
Onsite Wells
MB-03
Depth
(feet)
                        85
MB-01

Off-Property Wells

32D


34D

35
  85



 101


 129

  65
                                       Compound
Trichloroethene
1,1,1-Trichloroethene
1,1-Dichloroethane
Trans-1,2-Dichloroethene
Chloroform

Trichloroethene
Chloromethane
Vinyl Chloride

Trans-1,2-Dichloroethene

Trans-1,2-Dichloroethene
                          Concentration
                              (yg/D
140 .
 21M13
 13M
 10M
 10M

 10M
 10M
 10M

  30

 260
 Data for Wells MB-03 and MB-01  are from the 1984 RI report.   Data
 from Wells 32D and 34D are from the 1983 EPA Newsletter (Source  EPAGW) .
 Data for Well 35 are from the IRI report.

DM indicates compound was detected but not quantified at the  given
 detection limit.
                                 3-134

-------
140 yg/L and trans-1,2-dichloroethene was quantified in
Well 34D at 30 yg/L and Well 35 at 260 yg/L.  These data
indicate that there may be contaminants migrating to depths
between 85 and 129 feet.

Several wells were sampled for volatiles more than once.
Data for these wells are provided in Table 3-37.  All wells
were located off-property.  Volatile concentrations de-
creased in consecutive samples for all wells but 34S, 34D,
and 35.  Volatiles in Wells 27 and 28 show the most marked
decrease between samplings.

Wells 34S, 34D, and 35 showed increased concentrations of
trans-1,2-dichloroethene between samplings.  The most marked
increase was in Well 34S where trans-1,2-dichloroethene con-
centrations increased from "not detected" to 3,080 yg/L.
Trans-1,2-dichloroethene was detected twice each in Wells 34D
and 35.  The repeated occurrence of trans-1,2-dichloroethene
in Well 35 confirms its presence west of Mill Creek.  Detec-
tion in Well 34D suggests that contaminants are migrating to
a depth of up to 129 feet.

Volatile organic priority pollutants from the list of indi-
cator compounds are discussed below in comparison to ambient
water quality criteria and appropriate values based on human
health criteria.  Organic pollutants occur in wells adjacent
to Mill Creek, are apparently carried to the creek by ground-
water, and thus pose a potential threat to aquatic life.

With regard to human health, concentrations of carcinogenic
organic pollutants are compared with a calculated concen-
tration based on a lifetime exposure, the cancer potency
(Table 2-1), and an assumed cancer risk level of one addi-
tional cancer in a population of one million people  (Chap-
ter 2).  This is not intended to imply that 10   is an
acceptable risk level, but to provide a basis for comparing
concentrations at different parts of the site and off the
property.  For non-carcinogens, concentrations were calcu-
lated from allowable daily intakes (Table 2-1) and assumed
daily consumption of two liters of water (Section 2.3.2) , or
stated in terms of the drinking water standard  (Table 2-1).

Chloroform.  Chloroform was found in groundwater sampling
wells throughout the northern three-quarters of the site at
depths of 10 to 28.5 feet and in concentrations of 29 to
27,000 yg/L.  (See Figure C-28, Appendix C).  The freshwater
aquatic life criterion for chronic exposure to chloroform
(1,240 yg/L) was exceeded in four wells (Nos. 14, 15, 17S,
and 22D)  in the central portion of the site with concentra-
tions ranging from 1,700 to 27,000 yg/L.  This criterion was
also exceeded in one off-property well  (No. 27).

All wells where chloroform concentrations were detected
(30 total)  from depths ranging from 4 to 129 feet exceed

                            3-135

-------
                                     Table  3-37
                 VOLATILES IN WELLS  SAMPLED MORE THAN ONCE
                                WESTERN  PROCESSING
                                 KENT, WASHINGTON
Ual I n*.wK*.u ^
Concentration (pg/L)
Depth Range Number (feet) COBDound ,S«,t-»™ ,««„
Shallow 13 4 None detected
19 4 Trichloroethene
Chloroform
1,1, 1-Trichloroe thane
27 10 Trichloroethene
1,1, 1-Trichloroethane
Hethylene Chloride
Chloroform
Toluene
Tetrachloroethene
Carbon Tetrachloride
1 , 1-Dichloroethene
Benzene
Trans-l,2-Dichloroethene
1 , 1-Dichloroethane
Ethybenzene
Chloroethane
26 10 Methylene Chloride
Trichloroethene
Toluene
1 , 1-Dichloroethane
1,1, 1-Trichloroethane
Tetrachloroethene
Ethylbenzene
Benzene
1 , 2-Dichloroe thane
1,1, 2-Trichloroethane
Chloroform
Chlorome thane
vinyl Chloride
1 , 1-Dichloroethene
Trans- 1 , 2-Dichloroethene
Chloroethane
29 10 Methylene Chloride
Trichloroethene
Chloroform
Benzene
Toluene
1,1, 1-Trichloroethane
30 9.5 None detected
Intermediate 34S 57 Trans-1, 2-Dichloroethene
Trichloroethene
Vinyl Chloride
1 , 1-Dichloroethene
Toluene
Deep 3 ID 135 None detected
32D 101 Chloromethane
vinvl Chloride
__
__
__
~
140,000
20,000
16,000
6,700 .
SM*
__
—
—
—
—
—
—
—
5,400
840
110
12M
100
50
19M
--
—
—
12M
14M
—
5.4M
—
5M
630
120
29
5M
5M
—
—








EPAGW IFI RI
(June 1983) (Sept. 1983) (June 1984)
__
2 OH
5M
5M
8,800
5,200
2,000
1,700
1,600
1,400
1,400
900
880
400
390
100
10H
2,500
700
180
110
100
90
70
40
20
20M
10M
10M
10M
7M
5M
—
538
170
22M
5M
5H
5M
—
3,080
70
10M
5M
5M
__
10M
10M
             33D     60   None detected

             34D     129  Trans-1,2-Dichloroethene
                         Toluene

             35      65   Trans-1,2-Dichloroethene
30
          86
         260
                    901
a	ind-lrates compound not detected.
 A blank space indicates a sample was not collected for the data source.
»« indicates compound was detected but not quantified at the given detection l»at.


                                           3-136

-------
0.5 yg/L, the concentration calculated (as described in Sec-
tion 2.3.2)  from an assigned risk level of 10~  and the can-
cer potency of chloroform.

1,1,1-Trichloroethane.   Concentrations of 1,1,1-trichloroe-
thane range from detection limits to 340,000 yg/L in one
well (15) near the northeast border of the site (see Fig-
ure C-23, Appendix C).   The freshwater acute toxicity crite-
rion for 1,1,1-trichloroethane is 18,000 yg/L.  This
concentration was exceeded in two wells onsite (Wells IIS
and 15) and one well off-property (Well 27).  1,1,1-Trichlo-
roethane was detected in Wells 11, 15, and 27 at concentra-
tions in excess of 19 mg/L, the concentration that would
cause the ADI to be reached with the consumption of two
liters per day of groundwater.

Trans-1,2-dichloroethene.  Concentrations of
trans-1,2-dichloroethene vary widely over the entire site.
The highest concentration observed was in a well near the
southwest corner of the site  (Well 21) with a concentration
of 390,000 yg/L at a depth of 13 feet  (see Figure C-24,
Appendix C).  The acute freshwater aquatic toxicity
criterion for total dichloroethenes is 11,600 yg/L.  This is
equaled or exceeded in Well 21 only.  There is no proposed
acceptable daily intake value with regard to human ingestion
of trans-1,2-dichloroethene.  This compound is
noncarcinogenic and therefore has no cancer potency.

Tetrachloroethene.  Tetrachloroethene was detected mainly in
wells in the northern half of the site at depths of 10 to
23 feet.  Concentrations in onsite wells ranged from a trace
to 1,800 yg/L  (see Figure C-25, Appendix C).  Tetrachloro-
ethene was also found in several off-property wells (mainly
Wells 27, 28, and 32S)  at concentrations ranging from a
trace to 1,400 yg/L.  The aquatic life criterion for chronic
exposure to tetrachloroethene  (840 yg/L)  was only exceeded
in only two wells  (20 and 27).  Both wells were located near
the west central edge of the site.  Well 20 is onsite and
Well 27 is off-property in Area V.

All wells where tetrachloroethene concentrations were quan-
tified exceeded 1.0 yg/L, the concentration calculated from
the cancer potency, an assumed risk level of 10  ,  and the
consumption of two liters of water daily.  Trace concentra-
tions were also detected in many wells but these cannot be
easily compared to criteria because the contaminant level
was not quantified.

Trichloroethene.  Concentrations of trichloroethene ranged
from the detection limits to 210,000 yg/L in Well 15 located
in the northeast central section of Area I at a depth of
14.5 feet (see Figure C-26, Appendix C).   Trichloroethene
was detected in 25 onsite wells and 5 off-property wells
                            3-137

-------
for *nn^   ^? Property  line.  The acute toxicity criterion
w^i«q J    •   v  f°r trichloroethene is 45,000 yg/L.  Four
»ni*       Xu the north^rn portion of the site (11 and 15)
and two on  the eastern  site boundary (21 and 22D) have
levels of trichloroethene ranging from 80,000 to 210,000 yg/L,
which exceed the  acute  aquatic  life criterion.  They range
in depth from 10  to 14.5  feet deep.

All wells where trichloroethene concentrations were quan-
tified exceeded 2.78 yg/L, the  concentration calculated from
an assigned risk  level  of 10~b, the cancer potency of tri-
chloroethene, and an assumed consumption of two liters of
water per day.

Toluene.  Concentrations  of detected toluene ranged from a
trace to 22,000 yg/L in Well 17 at a depth of 13.5 feet (see
Figure C-27, Appendix C). The  aquatic life criterion for
acute toxicity for toluene is 17,500 yg/L.  Well 17 is the
only well with toluene  concentrations exceeding this
criterion.

Toluene has a proposed  allowable daily intake of 30 ing/day.
Based on drinking water as the  sole source of toluene and a
consumption of two liters per day, an allowable concentra-
tion would  be 15,000 yg/L.  Well 17 is also the only well
containing  toluene in concentrations that exceed this
criteria.

3.6.2.2  Seinivolatile Organics  in Groundwater

3.6.2.2.1   Acid Extractables

Acid extractable priority pollutants have been detected in
onsite and  off-property wells.  The occurrence of these com-
pounds is provided in Table 3-38.  Acid extractables were
detected most frequently  in shallow groundwater.  The detec-
tion of acid extractable  compounds decreased markedly with
increasing  well depth,  although some were identified in all
depth ranges.

The distribution of total acid  extractables is shown in Fig-
ure 3-49.   All detected acid extractable compounds were used
to prepare  this figure  because  compounds other than the in-
dicators (phenol and 2,4-dimenthylphenol) were found to be
important to a discussion of the extent of contamination.

Wells shown in Figure 3-49 were analyzed at detection limits
ranging from 20 to 50,000 yg/L.  Wells having elevated con-
centrations of acid extractables were generally analyzed at
the higher  detection limits.  Wells where acid extractable
compounds were not identified were analyzed at the lower
detection limits and may  therefore be considered uncontam-
inated or at levels less  than 20 yg/L.
                            3-138

-------
                         Table 3-38
     NUMBER OF OCCURRENCES OF DETECTED ACID EXTRACTABLE
             PRIORITY POLLUTANTS IN GROUNDWATER
            WESTERN PROCESSING, KENT, WASHINGTON

    Chemical Name                      Number Of Occurrences
Shallow Wells

2,4,6-Trichlorophenol                             4
2,4-Dichlorophenol                                6
2,4-Dimethylphenol                               12
2-Chlorophenol                                    2
2-Nitrophenol                                     4
4-Nitrophenol                                     3
Pentachlorophenol                                 3
Phenol                                           16

Intermediate Wells

2,4-Dimethylphenol                                2
2-Nitrophenol                                     1
Phenol                                            3

Deep Wells

2,4-Dimethylphenol                                1
Phenol                                            4
                            3-139

-------
            S  u°0rnpOUnds in Callow groundwater were
         in the highest concentrations in wells located in
the central to north central sections of Area I.  Shallow
wells located in the extreme north and south ends of Area I
nad no detectable acid extractable compounds.  The single
highest concentration was found in off-property shallow
well 27.  Well 27, located west of the site on the north
half of Area V, contained 5,400,000 yg/L total acid extrac-
tables.  Approximately 75 percent of these consisted of
phenol; the remainder was 2-nitrophenol.

Off-property contamination with acid extractable compounds
in shallow wells was limited to Wells 27, 28, and 29.  Acid
extractable compounds identified in these wells consisted of
phenol, 2,4-dimethylphenol, and 2-chlorophenol.

Off-property acid extractable contamination was identified
in intermediate depth Well 39 with approximately 20 yg/L of
phenol.  This concentration is approximate because the phenol
level was near the method detection limit and was not quanti-
fied.  It is possible that some off-property migration of
acid extractable compounds could be occurring but the data
are inconclusive.

Acid extractable contamination in deep wells was identified
in groundwater samples collected onsite and to the south and
west (Wells 33D, 35, 42, and MB-03) .  Contamination in each
of these wells was limited to phenol at the method detection
limit and, therefore, not quantified.

Several wells were sampled for acid extractable priority
pollutants more than once.  These data are provided in
Table 3-39.  For the most part, acid extractable concentra-
tions decreased during subsequent samplings.  This trend is
apparent in Wells 27 and 28.  Total acid extractables in
Well 27 decreased from 5,400,000 yg/L in September through
November 1982 to 1,860 yg/L in June 1983.  Acid extractables
in Well 28 decreased from 4,420 yg/L to approximately
40 yg/L over the same time period.

Acid extractable compounds increased in subsequent samplings
in Wells 29 and 33D.  The difference between samplings is
small and the detected concentration in each of these wells
was at the method detection limit and could not be quantified.
Any trends toward increasing contamination suggested by these
data are inconclusive.

The concentrations of 2,4-dimethylphenol and phenol are
compared below with regard to the criteria for protection of
aquatic life and human welfare.
2,4-DimethyIphenol.  Concentrations of 2,4-dimethylphenol
some onsite and off-property wells ranged from detection
in
                            3-140

-------
                       OLD SANITARY
                       DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
                                                                                                                                                                      DEPTH: 60'-135'
Legend: All concentrations in/ 100,000//g/L
      K indicates concentrations x 1,000.   Q 10000 100QOOUQ/l
      	' = 23,700/zg/L.)          _ _,.    '
                                  © 1-1,000/tig/L

                                  O Not Detected
                                  27 Well Number

                                 101K Total Concentrations in^ug/L
                                                                                             FIGURE 3-49
                                                                                             TOTAL PRIORITY POLLUTANT ACID-
                                                                                             EXTRACTABLES IN GROUNDWATER
                                                                               3-141

-------
                                                       Table  3-39
                  ACID EXTRACTABLE  PRIORITY POLLUTANTS IN  WELLS  SAMPLED MORE THAN  ONCE
                                      WESTERN  PROCESSING,  KENT, WASHINGTON
Depth Range   Well Number   Depth (feet)
Shallow
OJ
 I
h-•
*>
LO
Intermediate

Deep
                       13
                       19
                       27
                       28
 29

 30

34S

31D
32D
33D
34D
 35
                                   4
                                   4
                                  10
 10


 10

9.5

 57

135
101
 60
129
 65
                                                                                     Concentration  (yg/L)
                                                   Compound
None Detected
None Detected
Phenol
2,4-Dimethylphenol
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
Phenol
2,4-Dichlorophenol
2-Chlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
None Detected

None Detected

None Detected
None Detected
Phenol
None Detected
Phenol
                                                                     3013
                                                                (Sept-Nov 1982)
                                                                      4,100,000

                                                                      1,300,000
                                                                      4,000
                                                                        220
                                                                        200M
                                                                         20M
                                                                  EPAGW
                                                               (June 1983)
                                                                  1,500
                                                                    190
                                                                     50
                                                                     70
                                                                     50M

                                                                     40M
                                                                                           50M
                                                                   IRI
                                                              (Sept 1983)
                                                                      RI
                                                                 (June 1984)
                                                                                                     20M

                                                                                                     20M
    Notes:  The symbol "--"  indicates  compound not detected.
           A blank space indicates  a  sample was not collected for the data source.
           M indicates compound was detected but not quanitfied.

-------
ure C-29° AAn«^^9/i»at dePths from 9 to 68 feet (see Fig-
for acute ex™     C) '  The f^shwater aquatic life criterion
is exceeded ?n     t0 2 '^"ethylphenol is 2,120 yg/L, which
10 feet   Fonr °"lonsite well (No. 7) with 4,600 yg/L at
ceeded 4nn   ^Taddltl0nal Wells with quantified levels ex-
taQ*«e >«* Pf ' ' a concentration that causes objectionable
Irillr-  f    rS'  There are no appropriate human health
criteria for 2,4-dimethylphenol.

Phenol.  Phenol was detected in shallow wells both onsite
ana olf-property in most sections of the monitoring area.
^nenoi was detected but not quantified in shallow Wells 3,
40 n«U    14 at detecti°n limits ranging from 20 to
4^,000 yg/L.  Phenol was detected and quantified in shallow
Wells 5, 7, 9, 10, 11,  12, 15, 17, 21, 23, 27, and 28 at
concentrations ranging from 120 to 4,100,000 yg/L.   Phenol
was detected in intermediate Wells 11 and 17 at concentra-
tions of 7,200 and 380  yg/L, respectively, and was detected
but not quantified in intermediate Well 39 at a detection
limit of 20 yg/L.  Phenol was detected but not quantified in
deep Wells 33D, 35, and 42 at a detection limit of 20 yg/L.

The acute toxicity criterion for the protection of fresh-
water aquatic life for phenol is 10,200 yg/L.  This cri-
terion is exceeded in shallow Wells 4 (19,000 yg/L detected
but not quantified), 5 (270,000 yg/L), 9 (100,000 yg/L, 10
(180,000 yg/L), 14 (42,000 yg/L detected but not quantified),
17 (91,000 yg/L), and 27  (4,100,000 yg/L).  All of these
wells are located in the northern half of the site except
for Well 27, which is located west of the site.

The criterion for the protection of human health for phenol
is 3,500 yg/L.  This criterion is exceeded in all the wells
discussed above and in shallow Wells 3 (10,000 yg/L detected
but not quantified), 15 (4,900 yg/L), 21 (10,000 yg/L), 23
(5,200 yg/L), and 28 (4,000 yg/L).  The concentration of
phenol exceeds human health criteria in all areas of the
site with the exception of the extreme southern portion.

3.6.2.2.2  Base/Neutral Compounds

Base/neutral compounds  were detected in onsite and off-pro-
perty wells.  The occurrence of these compounds is provided
in Table 3-40.  The widest variety of base/neutrals was
detected in shallow groundwater.   Fewer numbers of base/
neutrals were found in intermediate or deep well samples.

Polvcvclic aromatic hydrocarbons (PAH's)  were the base/
 ^it-ral most frequently detected in shallow groundwater.
Saw' c; were not often detected in groundwater samples from
j       ,7^-Mc;   The base/neutrals detected in the inter-
                              st often the  hthalate
        7^-Mc;   The  aseneu
        and deep wells were most often the phthalate
compounds.
                            3-144

-------
                         Table 3-40
              NUMBER OF OCCURRENCES OF DETECTED
       BASE/NEUTRAL PRIORITY POLLUTANTS IN GROUNDWATER
                     WESTERN PROCESSING
                      KENT, WASHINGTON

         Chemical Name                 Number of Occurrences
Shallow Wells

     1,2-dichlorobenzene                         1
     Benzo(a)anthracene                          1
     Benzo(a)pyrene                              1
     Benzo(b)fluoranthene                        1
     Benzo(ghi)perylene                          1
     Benzo(k)fluoranthene                        1
     Benzyl Butyl Phthalate                      1
     Bis(2-chloroethyl)ethane                    2
     Bis(2-ethylhexyl)phthalate                  3
     Chrysene                                    1
     Dibenzo(a,h)anthracene                      1
     Diethyl Phthalate                           2
     Dimethyl Phthalate                          1
     Indeno(1,2,3-cd)pyrene                      1
     Isophorone                                  2
     N-nitrosodiphenylamine                      1
     Naphthalene                                 3

Intermediate Wells

     Benzyl Butyl Phthalate                      2
     Di-n-octyl Phthalate                        1
     Isophorone                                  1
     N-nitrosodiphenylamine                      1
     Naphthalene                                 4

Deep Wells

     Benzyl Butyl Phthalate                      1
     Bis(l-ethylhexyl)phthalate                  1
     Di-n-octyl Phthalate                        2
     Diethyl Phthalate                           1
     N-nitrosodiphenylamine                      1
                            3-145

-------
cuLed below  i \°f seniivolatiles in groundwater is dis-
Wells shownV^6™3 °f total PAH's and total phthalates.
limits r*na-   ^hese figures were analyzed at detection
     unS  9«n?1  °™ i° to  20'000 ^/L depending on the
      v    ?   ^ Wlth high  levels °f contamination were
     v^-J?  YZed a* the higher ^tection limits and wells
     little contamination  at the lower detection limit.  In
general  wells where base/neutrals were not identified can
be considered uncontaminated or at levels less than 10 yg/L.
Exceptions to this rule are discussed in later parts of this
section.

The polycyclic aromatic hydrocarbons, as shown on Figure 3-50
were most widespread in shallow groundwater.  Fewer PAH's
were identified in intermediate depth wells and none in the
deep wells.   The types of  PAH's and the concentrations in
each well are listed on Table  3-41.  All detected PAH's were
found in concentrations too low to quantify.

Shallow wells containing PAH's were located mainly in the
central and north-central  regions  of Area  I  (onsite) .  The
largest number of PAH's was found  in Well  12S, which con-
tained nine.   Naphthalene  was  the most widely distributed
PAH and was found in every well where PAH's were detected.
Intermediate  depth wells containing PAH's were located
mostly in the center of Area  I.  One off-property well (num-
ber 3IS) also contained PAH's.  Naphthalene was the only PAH
detected in intermediate wells.

Some data inconsistency is  apparent between shallow and in-
termediate depth wells containing PAH's.  Most contaminants
found in deep cluster wells are also found in their associ-
ated shallow  cluster well.  However, low levels of PAH's
were identified in intermediate Wells 17D and 22D but not in
their shallow cluster Wells 17S and 22S.  High detection
limits in Well 17S (approximately 10,000 to 20,000 yg/L)  is
the most likely reason for  not detecting PAH's in this well.
There was no  detection limit problem for Well 22S and there-
fore PAH's detected in 22D  are probably the result of
migration from some other area of the site.

Several wells  besides 17S also had high PAH detection lim-
its.  These wells included  3, 4, 10, 14, 16, 20, 27, and 30.
PAH detection  limits for these wells were on the order of
10 000 to 20,000 yg/L.   Low levels of PAH's could not have
been identified at these high detection limits.

Data for wells that were sampled several times are sum-
marized on Table 3-42.   Two wells (numbers 27 and 30)  pre-
viously having detection limits of 10,000 to 20,000 yg/L and
no identified  PAH's were sampled again at detection limits
of 10 to 20 yg/L.   Well 30 was found to contain low levels
of Benzo(a)pyrene.   No PAH's were detected in Well 27.
                            3-146

-------
Legend: All concentrations initg/L
> 100,000/ug/L
                                                      \
      K indicates concentrations x 1.000   Q  10000-100,OOO^g/L
      (ex. 23.7K = 23,700/*g/L)
                                  ©  1,000-10.000 yug/L

                                  0  1-1.000>Ug/L

                                  O  Not Detected

                                  27  Well Number

                                  101K Total Concentrations inpg/L
                                                                                                                                        o
                                                                                                                                        38
                                                                                                                                       Off Map
                                                                                                                                   INTERURBAN TRAIL
                                                                                                       OLD SANITARY
                                                                                                      DISCHARGE LINE
                                                                                                                                         31S
                                                                                                                                          20
                                                                                                                                          0
                                                                                  WESTERN PROCESSING
                                                                                       22D
                                                                                        40
                                                                                        e
                                                                                       DEPTH: 16'-57'
                                                                                                                             25D
                                                                                                                             O
                                                                                  0    100   200
                                                                                                                   72ND AVE.
                                                                                                                    O
                                                                                                                    44
                                                                                                                                               EAST
                                                                                                                                               DRAINB
                                                                                                                                                    0
                                                                                                                                                   H32S
OLD SANITARY
DISCHARGE LINE
                                                                                                                                 DEPTH:  60'-135'
                                                                                                                                                                     FIGURE 3-50
                                                                                                                                                                     TOTAL PRIORITY POLLUTANT
                                                                                                                                                                     PAH'S IN GROUNDWATER
                                                                                                                                                            3-147

-------
                             Table  3-41
                POLYCYCLIC AROMATIC HYDROCARBONS
                           IN GROUNDWATER
                        WESTERN  PROCESSING
                         KENT, WASHINGTON
   Well  Number
Shallow Wells
    12S
        Compound
Benzo(g,h,i)pyrene
Benzo(a)anthracene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Benzo(k)fluoranthene
Benzo(a)pyrene
Benzo(b)fluoranthene
Naphthalene
Chrysene
          Total

Naphthalene

Naphthalene
                                                 Concentration  (yg/L)'
                                                          64M
                                                          60M
                                                          44M
                                                          42M
                                                          40M
                                                          40M
                                                          20M
                                                          20M
                                                          20M
    us

    15

Intermediate
  Wells

    11D

    17D

    22D

    31S

Deep Wells

    None detected

 M indicates  compound detected but not quantified.
                                                         370M
                                                          20M
                                                          20M
                     Naphthalene

                     Naphthalene

                     Naphthalene

                     Naphthalene
                                     23M

                                     36M

                                     40M

                                     20M
                                 3-149

-------
                                                    Table 3-42
                                   PAH'S  IN  WELLS  SAMPLED MULTIPLE  TIMES
                                               WESTERN  PROCESSING
                                                KENT,  WASHINGTON
                                                                         Concentration by Source (yg/L)
                                                                                                   a,b

Depth Range Well Number
Shallow 13
19



27
28
U)
<-n 29
o
30
Intermediate 3^5
°eep 3 ID
32D
33D
34D
35
Depth
(feet)
4
4



10
10

10
9.5
57
135
101
60
129
65
3013 EPAGW IRI RI
Compound (Sept. -Nov., 1982) (June, 1983) (Sept., 1983) (June, 1984)
None Detected
Acenapthene — 20M
Naphthalene — 20M
Fluorene — 10M
Phenanthrene — 10M
None Detected
Fluoranthene — 10M
Acenaphthylene — 650
None Detected
Benzo(a)pyrene — 20M
None Detected
None Detected
None Detected
None Detected
None Detected
None Detected
 — indicates compound not detected.  Blank indicates sample not collected from well in "source" investigation.
b
 Date given  is the sampling period and not the date the report was published.
c
 M indicates compound detected but not quantified.

-------
Two other wells sampled several times  (19 and 28) were also
found to contain PAH's at low levels when none were previ-
ously identified.  Well 19 contained acenaphthene and naph-
thalene at trace levels.  Well 28 contained acenaphthylene
at 650 yg/L.  Because high detection limits were not a prob-
lem in the first sampling, the PAH contamination in Wells 19
and 28 may be the result of contaminant migration occurring
during the time elapsed between samplings.

Total phthalates were found infrequently in groundwater as
shown on Figure 3-51.  Low levels of phthalates, with one
exception, were found in off-property shallow water.  Phthal-
ates were found most often at levels less than 20 yg/L.
Phthalates were identified in a few wells in all depth ranges
but no definite trend is apparent.  The types of phthalates
and the concentrations in each well are listed on
Table 3-43.  All but a few of the detected phthalates were
found in concentrations too low to quantify and therefore
contamination by phthalates is largely inconclusive.

Two phthalates  [bis(2-ethylhexyl)phthalate and di-n-butyl
phthalate] were frequently detected in trace concentrations
in groundwater  samples.  A review of data from transport and
transfer blanks submitted with these samples suggested that
the occurrence  of these contaminants in trace concentrations
was due to some sort of cross contamination.  Unquantified
trace detections of the compounds were not included in the
contaminant totals or in any of these previous tallies on
contaminants in groundwater.

Shallow wells containing phthalates were all located off-
property-  Concentrations were too low to quantify in all
wells except Well 30, which contained 544,000 yg/L of
bis(2-ethylhexyl)phthalate.

Phthalates were detected in one intermediate depth well in
Area I and one  off-property well in Area IX.  Concentrations
in each of these wells were too low to quantify.  Phthalates
were also identified in three deep wells, two onsite and one
off-property.

Phthalates were detected in two intermediate depth wells and
three deep wells.  In all cases but one the phthalates were
detected in concentrations too low to quantify and the data
are inconclusive regarding the presence of contamination.
Bis(2-ethylhexyl)phthalate in Well MB-01 was quantified at
76 yg/L.  Data  for Well MB-01 suggest some downward
migration of phthalates in this location.  However,
considering the low solubility of phthalates, the fact that
all other phthalates in deep wells were too low to quantify,
and because phthalates were frequently detected in field
blanks submitted for analysis, it is doubtful that this
concentration is accurate.
                            3-151

-------
                             Table 3-43
                  TOTAL  PHTHALATES  IN GROUNDWATER
                         WESTERN PROCESSING
                          KENT,  WASHINGTON
Well Number/Depth  Range

Shallow Wells

     19


     27


     28

     30

Intermediate Wells

     MB-02


     31S

Deep Wells

     MB-01


     MB-03


     35
         Compound
Diethyl Phthalate
Benzyl Butyl Phthalate

Diethyl Phthalate
Dimethyl Phthalate

Bis(2-ethylhexyl)phthalate

Bis(2-ethylhexyl)phthalate
Benzyl Butyl Phthalate
Di-n-octyl Phthalate

Benzyl Butyl Phthalate
Bis(2-ethylhexyl)phthalate
Di-n-octyl Phthalate

Benzyl Butyl Phthalate
Di-n-octyl Phthalate

Diethyl Phthalate
Concentration
         10M
         10M

         40M
         10M

         60M

       544,000
         10M
         10M

         10M
         76
         10M

         10M
         10M

         9M
 M indicates compound  detected but not quantified.
                                 3-152

-------
                        OLD SANITARY
                       DISCHARGE LINE
Legend All concentrations in>ug/L         • > 100,000/ug/L
      K indicates concentrations x 1,000   Q 10,000-100.000A«g/L
      (ex 23 7K = 23.700/ug/L)
 ® 1,000-10.000>ug/L
 0 1-1.000>ug/L
 O Not Detected
 27 Well Number
101K Total Concentrations in/zg/L
                                                                                                                                        O38


                                                                                                                                       Off Map
                                                                                                                                               RAILROAD
                                                                                                                                                  N
                                                                                                                                   INTERURBAN TRAIL
                                                                     OLD SANITARY
                                                                     DISCHARGE LINE
                                                                                                                                         31S
                                                                                                                                          10
                                                                                                                                          e
                                                                                      DEPTH:  16'-57'
                                                                                                                             25D
                                                                                                                             o
                                                                                       100   200
                                                                                                                   72NO AVE.
                                                                                                                    O
                                                                                                                    44
                                                                                                                                               EAST
                                                                                                                                               DRAIN
                                                                                                                                                    O
                                                                                                                                                    32S
OLD SANITARY
DISCHARGE LINE
                                                                                                                                    DEPTH: 60'-135'
                                                                                                                                                                                                       FIGURE 3-51
                                                                                                                                                                                                       TOTAL PRIORITY POLLUTANT
                                                                                                                                                                                                       PHTHALATES IN GROUNDWATER
                                                                                                                                                                                                       WELLS
                                                                                                                                                                                                   3-153

-------
Several wells were sampled several times.  Data for these
wells are provided on Table 3-44.  Phthalates were detected
more than once only in Well 30.  Concentrations of bis(2-
ethylhexyl)phthalate decreased in Well 30 from 544,000 yg/L
to 80 yg/L in the two samplings.  All other phthalates de-
tected in additional sampling at these wells were at concen-
trations too low to quantify.

The concentrations of total phthalates and total PAH's are
discussed below with regard to the criteria for protection
of aquatic life and human welfare.

Total PAH's.  There are published acute toxicity criteria
for the protection of freshwater aquatic life for three
PAH's:  acenaphthene, at 1,700 yg/L; fluoranthene at 3,980
yg/L; and naphthalene, at 2,300 yg/L.  None of theselevels
was exceeded in any of the monitoring wells.  The 10~
cancer risk level for total PAH's is 2.8 ng/L (ppt).  This
level was exceeded in all wells showing detectable concen-
trations of PAH's.

Phthalates.  There is an acute toxicity criterion for the
protection of freshwater aquatic life for phthalate esters
of 55 yg/L.  That criterion and the criterion for the
protection of human health for bis(2-ethylhexyl)phthalate
(15 yg/L) was exceeded only in shallow Well 30 off the
southeast corner of the site, which showed a concentration
of 544,000 yg/L.  No other wells exceeded human health
criteria for any phthalate.

3.6.2.3  Oxazolidone in Groundwater

Oxazolidone was identified and its concentration estimated
in several onsite and off-property groundwater samples.
Oxazolidine was detected in the field transfer blank at
100 yg/L.  This concentration was subtracted from all quan-
tified levels of oxazolidone to account for possible cross
contamination between samples.  The corrected data are pro-
vided on Table 3-45.

The distribution of oxazolidone in groundwater is shown on
Figure 3-52.  Oxazolidone was detected in the shallow wells
throughout the site, with the highest concentrations occur-
ring in the central and western portions of the site.  Maxi-
mum concentrations of oxazolidone were found in two wells,
20 and 27.  Well 27 is located off-property to the west in
Area V and had a concentration of 9,000 yg/L.  Well 20 is
located on the west side of the site near Well 27 and had a
concentration of 9,900 yg/L.  Other than Well 27, oxazoli-
done was not detected in any off-property well, at any
depth.

Oxazolidone was identified in the intermediate depth
Wells 11D and 17D, at concentrations of 1,600 and 630 yg/L,

                             3-155

-------
                                                  Table  3-44
                          TOTAL  PHTHALATES IN WELLS SAMPLED  SEVERAL TIMES
                                            WESTERN  PROCESSING
                                              KENT, WASHINGTON
                                                                           Concentration by Source (yg/L)

Depth Range Well Number
Shallow 13
19

27

28
29
U)
I
£ 30
Intermediate 34S
Deep 3 ID
32D
33D
34D
35
Depth
(feet)
4
4

10

10
10
9.5
57
135
101
60
129
65
3013 EPAGW IRI RI
Compound (Sept. -Nov., 1982) (June, 1983) (Sept., 1983) (June, 1984)
None Detected
Diethyl Phthalate — IOM
Benzyl Butyl Phthalate — 1QM
Diethyl Phthalate — 4QM
Dimethyl Phthalate — IOM
Bis (2-ethylhexyl) phthalate — 60
None Detected
Bis (2-ethylhexyl) phthalate 544,000 80
None Detected
None Detected
None Detected
None Detected
None Detected
None Detected
—  indicates compound not detected.  Blank indicates sample not collected from well during "source" investigation.

-------
Well Number

     5
     6
     7
     8
    11D
    12
    17S
    17D
    20
    24
    22D
    27
        Table 3-45
OXAZOLIDONE IN GROUNDWATER

        Average
        Depth of
      Well Screen

          10
          10
          10.5
          14.5
          27.5
           9
          13
          28.5
          13
          13.5
          25
          10
Concentration
   (yg/L)

   7,400Ja
     510J
     520J
     175J
   1,600J
     310J
     630J
     630J
   9,900J
     700J
     250J
   9,OOOJ
 J indicates concentrations are estimated.

Note:  Concentrations are corrected  for 100 yg/L identified
       in the  field transfer blank.
                             3-157

-------
respectively.   Both wells  are  located in the center of
                Contamination was identified in any of the
             we^ls-   Oxazolidone was detected, however, in a
 ™    •      n?lte Wel1' MB~03 at 60 feet-  Oxazolidone
contamination  in  this well was estimated to be 46 yg/L.
3.6.3
        SUMMARY  OF  GROUNDWATER CONTAMINATION DATA
Organic  and  inorganic  priority pollutants exist in onsite
and  off-property monitoring wells at Western Processing.
Contamination was  greatest in wells located onsite in
Area I.   Contamination decreased with increasing depth and
distance from the  site.  Contamination in off-property wells
was  most pronounced  in wells adjacent to the site to the
west and north.  Lower levels of contamination were also
apparent in  one off-property well located east of the site
and  in another off-property well located west of Mill Creek.

3.6.3.1   Metals in Groundwater

Metals in groundwater  were most pronounced in shallow wells
located  on the northern half of the site.  Total indicator
metals in these wells  often exceeded 100,000 yg/L.  Shallow
wells on the south end of the site, where metals in soils
are  highest, contain considerably lower concentrations of
indicator metals,  usually less than 10,000 yg/L.  These data
suggest  that metals  have been more highly solubilized on the
northern half of the site and are thus more apt to migrate
from the northern  region.

Total indicator metals in intermediate and deep wells were
highest  in onsite  locations and decreased off-property.
Indicator metals exceeded 100,000 yg/L in two onsite inter-
mediate  wells in the central  and north central sections of
the  site.  Indicator metals were above 10,000 yg/L in one
well located on the  southern  half of the  site.  All other
intermediate wells containing metals were off-property close
to the site  and in concentrations only slightly above
background.

Indicator metals in  deep wells were highest in one onsite
location at  the very northeastern corner of the site.  This
well contained slightly more  than 1,000 yg/L.  All other
deep wells containing  contamination were located off-property
close to the site  and  in concentrations only slightly above
background.

Several  wells were sampled more than once.  Total indicator
metals remained roughly the same in all samplings and dis-
played no other trends regarding  the extent of groundwater
contamination.
                             3-158

-------
OLD SANITARY
DISCHARGE LINE
                                                                                                     OLD SANITARY
                                                                                                     DISCHARGE LINE
OLD SANITARY
DISCHARGE LINE
                                                                                                                                            DEPTH:  60'-135'
Legend: All concentrations in //g/L
      K indicates concentrations x 1 .000
      (ex. 23.7K = 23,700#g/L )
          •  • 100.000#g/L
          Q 10000-100000 iia/L
               '   "   '
          ® 1. 000-10.000^ g/L

          27  Well Number
         101K Total Concentrations in/ig/L
                                                                                                                                                                                                  FIGURE 3-52
                                                                                                                                                                                                  OXAZOLIDONE CONCENTRATIONS
                                                                                                                                                                                                  IN GROUNDWATER WELLS
                                                                                                                                                              3-159

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3.6.3.2  Organics in Groundwater

3.6.3.2.1  Volatile Organics in Groundwater

Volatile organics in groundwater were highest in shallow
onsite wells in the central and the northern half of the
site.  Maximum volatiles  (> 100,000 yg/L) were found in
onsite Wells 15, 21, 9, US and 17.  Volatiles were greater
than 10,000 yg/L in two wells located on the west side of
Area I.

Volatile organics in groundwater were highest in the onsite
and near off-property wells.  The absolute highest total
volatile concentrations were detected in onsite Wells 15 and
21 at concentrations of 1,346,000 yg/L and 660,360 yg/L.
Methylene chloride, 1,1,1-trichloroethane, and trichloro-
ethene made up over 90 percent of the total concentration in
Well 15.  Trans-1,2-dichloroethene comprised almost 60 per-
cent of the total in Well 21.

Other onsite wells containing high concentrations of total
volatile organics  (i.e.,  >100,000 yg/L) included Wells 9,
IIS, 11D, and 17.  These wells are located in the central
and western portions of Area I.  Off-property Well 27 also
contained more than 100,000 yg/L total volatiles.

Shallow wells contained the overall highest levels of vola-
tile organics.  Shallow onsite and intermediate wells con-
tained the most volatile  contamination.  Off-property shal-
low, intermediate, and deep wells contained lower but still
significant concentrations of volatiles.  Most important is
the repeated occurrence of trans-1,2-dichloroethene in
Wells 34S, 34D, and 35 located west of the site.  Concen-
trations of trans-1,2,-dichloroethene increased in each of
these wells during all but one sampling  (at Well 34D in
July 1984).  East of Western Processing, volatiles were
detected in Well 32S.  Further discussion of the signifi-
cance of these off-property detections of volatiles in wells
west and east of the site is contained in Section 3.6.3.3
and 3.6.3.4.

Volatile organics were found in several wells in concentra-
tions much greater than those found elsewhere.  Methylene
chloride was highest in Wells 15 and 9  (in order of decreas-
ing concentration), trichloroethene in Wells 15, 21, IIS,
and 17S, 1,1,1-trichloroethane in Wells 15 and IIS, and
trans-1,2-dichloroethene  in Well 21.  These wells may be
considered potential source areas from which volatile or-
ganics could migrate.

3.6.3.2.2  Semivolatile Organics in Groundwater

Total acid extractables in concentrations exceeding
10,000 yg/L were detected in shallow groundwater only.  Many


                            3-161

-------
 of these shallow weiio „  ^  .
 in concentrating «    contained  acid extractable  compounds
 est concentration wf *** i"g  100'000 ^/L-  The  sin^le  hi9h~
 at 5 400 000 ?i?? Wa* detected  in Well 27  (west of the site)
 extracts were'rJnV0^ fre^e^ly detected acid
 extractahl* ™ I  Phenol and 2r4-dimethylphenol.   Acid
 cated on tL    ^lnation was highest in shallow wells lo-
 cated on the northern half of the site.
                  COItlP°unds were detected in three  intermediate
         u        three  deeP wells.  Only two onsite intermedi-
 av^  ? th  wells  contained high enough concentrations  of  acid
 a«S  iii? J"6. con)Pounds  to quantify  (Well 11D at  7,245  yg/L
 and  Well 17D at  730  yg/L) .  All other intermediate and deep
 wells  contained  only trace quantities of acid extractable
 compounds,  and because of this it  is difficult  to  conclude
   their presence  indicates contamination or not.   It is
 possible that some off-property migration of acid  extract-
 ablle  compounds  could  be occurring but the data are
 inconclusive.

 Acid extractable compounds in wells sampled more than once
 decreased  in  concentration in all  cases except  for three
 off-property  wells.  The increased concentration in these
 off-property  wells was small and the detected concentration
 was  too  low  to quantify.  Trends toward increasing contamina-
 tion in  off-property wells sampled more than once  are
 inconclusive.

 Base/neutral  compounds were detected infrequently  in  onsite
 and  off-property wells.  Concentrations of base/neutral  com-
 pounds were considerably lower than for metals,  volatiles,
 or acid  extractables.  High detection limits is probably the
 reason why base/neutrals were seldom detected.

 Base/neutrals in shallow wells included PAH's and  phthalates.
 These compounds were found primarily onsite in  concentrations
 less than 20  yg/L.  When detected, PAH's and phthalates  were
 most often seen in wells located on the northern half of the
 site.  Naphthalene, bis (2-ethylhexyl) phthalate,  and di-n-
 butylphthalate were the base/neutral compounds  most often
 detected.

 One  shallow well (No.  308) contained 544,000 yg/L  of  bis-
 (2-ethylhexyl) phthalate.  This well is located  approximately
 1/4 mile south of the  site.  Because this well  is  distant
 from the site and generally upgradient, it is doubtful that
 this contamination is  the result of migration from Western
 Processing.  The data  are more suggestive of sampling or
 analytical error.

No specific trends regarding base/neutrals in  groundwater
were identified during multiple sampling of wells.   While
 some iells showed slightly increased concentrations of PAH'S
                            3-162

-------
and phthalates in subsequent samplings, the levels were
generally too low to quantify and the data were inconclusive,

3.6.3.2.3  Oxazolidone in Groundwater

Oxazolidone was detected most frequently in onsite shallow
wells in the central and western portions of the site.  Max-
imum concentrations were seen in Wells 20 and 27 in concen-
trations up to 9,900 yg/L.  Both of these wells are located
near the western side of Area I and are close to each other.
Other than Well 27, no off-property well contained
Oxazolidone at any depth.

3.6.3.3  Groundwater Contamination West of Mill Creek

Groundwater contamination has been identified in monitoring
wells west of Mill Creek.  Volatile organics and metals
above background have been detected in the groundwater.
This section evaluates the extent and possible origin of
this contamination.

Mill Creek is the local shallow groundwater discharge area
west of the site.  The depth to which Mill Creek affects
groundwater flow is presently undefined.  Evidence suggests
that, although the creek penetrates only a small portion of
the shallow aquifer  (±8 feet), it intercepts groundwater
from much greater depths.  The conceptual model of the
effective capture depth of Mill Creek is about 50 to 60
feet.  Site contaminants that migrate to this depth could
flow horizontally beneath the creek to the west.

Groundwater quality data from seven downgradient monitoring
wells west of Mill Creek are inconclusive in demonstrating
that groundwater contamination from Western Processing has
migrated beneath the creek.  The following discussion is
based on and limited by only one sample set for Wells 36
through 44.  Well 35 was sampled twice and will be discussed
separately.

Downgradient Wells 39, 42, and 43, and upgradient Well 44
contained trace concentrations of chloroform, ethylbenzene,
tetrachloroethene, and toluene.  This contamination was dis-
counted because the same compounds were also found in the
field blanks.  Wells 39 and 42 also contained trace concen-
trations of phenol that could not be explained as blank
contamination.  Phenol concentrations were too low to con-
clude anything about the source of contamination.

Generally, the up- and downgradient wells contained low quan-
tified levels of chromium, zinc, cadmium, and lead (except
Wells 35 and 39).  Well 39 had zinc at 351 yg/L, or about
twice the background concentration.  Well 39 is located on
the north edge of Area VII, west of Mill Creek, adjacent to
South 196th Street.  The zinc in this well probably did not


                            3-163

-------
 such as  iSa; SreeK because other more roobile
 ent  wells mills 4  R mjuin "hich are  found  in onsite upgradi
 Mobile volatile*  ^  '  1° '  3nd 16) ' are  not Present-
 methvl^n« ~Ci   ^  Uch as  trans-l,2-dichloroethene  and
 also Jo?  chl°ride,  which  are  in Wells 4, 8, 9,  and 10,  are
      n°^.prefent «i  Well 39.   The source of zinc is probably
        ™lgrating fr°n> the  west towards the  creek and/or  from
     ™
Well 39  isYdrilled°n  SOUth  196th Street' next tO which

When first  sampled  in  1983, Well 35 had low levels  (near
oacKground)  of  chromium,  zinc, cadmium, and lead and  trace
levels of benzene,  chloroform, ethylbenzene, tetrachloro-
etnene,  toluene,  and phenol— the same as the other wells.
ocn115"            oethene' nowever» was quantified at
260  yg/L.   Well 35  was  resampled in 1984.  Trans-1,2-
dichloroethene  was  quantified at 901 yg/L and copper, lead,
nickel,  and zinc  were also  quantified at 434, 164, 111,
and  2,260 yg/L, respectively.

Even though upgradient  onsite wells had high quantified
levels of these contaminants, the source of the contaminants
in Well  35  is probably  local.  This is based on the pre-
dicted mobilities of the metal contaminants.  The estimated
retardation factors of  these metals are about 1,200.  43,000,
24,  and  87  for  copper,  lead, nickel, and zinc, respectively.
That is, they will move 1,200 times, etc., slower than the
water.   The  regional groundwater flow velocity is about
70 feet  per  year  for the  fine to medium sand unit underlying
the  upper 40 feet of silt,  clay, and fine sand  (based on K =
25 ft/day,  I =  0.002, and n = 0.25).  Therefore the metals
quantified  in Well  35 could probably not have migrated the
approximately 500 to 600  feet from the site in times  consis-
tent with site history-  The lack of other mobile volatiles
such as  methylene chloride  further suggests that the Well 35
contamination probably  did  not originate on the Western
Processing property.

3.6.3.4  Groundwater Contamination East of Western Processing

Volatile organic contamination has been identified in one
monitoring well east of Western Processing (Well 32S)  .
This section evaluates  the  extent and possible origin of
this contamination.

The  east drain is the local shallow groundwater discharge
east of  the site.   The  current conceptual model predicts
that groundwater on the eastern half of the site flows
towards  the east drain.  Some of this groundwater could  flow
oast the east drain.  Because the elevation of the  drain is
hiaher than Mill Creek, its effective capture  depth  would be
significantly less.  Groundwater would not  flow very  far
past the drain because the  regional gradient  is  to  the west.
                            3-164

-------
Groundwater_data from Well 32S show quantified levels of
seven volatile organics including trichloroethene, methylene
chloride, and 1,1,1-trichloroethane at 2,000, 2,000, and
300 yg/L, respectively.  These contaminants were also found
in high concentrations in upgradient onsite wells (5, 6, 7,
and especially 15) on the east side of the site.

The good correlation between up- and downgradient contami-
nants indicates that the Well 32S contaminants probably mi-
grated from Western Processing.  It is unlikely that the
contamination can migrate much farther east than Well 32S
because of the regional groundwater flows to the west-
northwest.

                3.7  MILL CREEK CONTAMINATION

Mill Creek, part of the Black River drainage subbasin, ex-
tends approximately 7.8 miles from its upstream headwaters
southeast of the city of Kent to its confluence with Spring-
brook Creek.  The total drainage area contributing runoff to
Mill Creek at its downstream limit is approximately
11.9 square miles.  Runoff from Mill Creek and Springbrook
Creek join upstream of South 180th Street to form the Black
River, which ultimately is discharged to the Green River at
Tukwila by pump station.  The Western Processing site is lo-
cated adjacent to Mill Creek, south of South 196th Street
between river miles 1.0 and 1.4.  Figure 3-53 illustrates
the Black River Drainage Subbasin, Mill Creek and Spring-
brook Creek subareas, and the Western Processing site
location along Mill Creek.

Contamination of Mill Creek has been documented by the Muni-
cipality of Metropolitan Seattle, by the Washington Depart-
ment of Ecology, and by the USEPA and Padian Corporation
(1984).  Sources of data on Mill Creek are shown in
Table 3-46.  The time period during which data were col-
lected is shown in Figure 3-1 of this report.  Sampling
locations for the various reports are shown on Plate 1.
Sampling locations are numbered as they were in the original
reference (See Table 3-46).

3.7.1  CONTAMINATION OF MILL CREEK WATER

3.7.1.1  Metals

The most direct evidence for contamination of Mill Creek by
metals is included in the Washington Department of Ecology
(WDOE) results from 1984 and USEPA results from May 1982 and
January 1984.  Metals were analyzed both as total metals and
dissolved metals.  Data from WDOE stations 09E090 (upstream
of Western Processing)  and 09E070 (downstream of Western
Processing)  show that concentrations of several dissolved
metals increased up to three orders of magnitude as Mill
                            3-165

-------
                                                     Table  3-46
               SOURCES  OF  DATA ON CONTAMINATION OF WATER  AND SEDIMENT  IN  MILL CREEK
                  [REFERENCES  1-7  FROM FIGURE  16, RI DATA  REPORT  (CH2M  HILL,  1984)]
u>
 i
CTl
CT>
            Document or Unpublished Data
1.    Municipality of Metropolitan Seattle
     (Metro).   Ramix II database system.   Sur-
     face water quality data collected along
     Mill Creek (unpublished)  1977 to 1981.

2.    Washington State Department of Ecology.
     Storett database.  Monthly ambient water
     quality sampling program. Mill Creek  sam-
     pling sites No. 09E090 and No. 09E070
      (unpublished).

3.   U.S. Environmental Protection Agency,
     Region X.  Report of Western Pro-
     cessing Vicinity Survey.  May 20-21,
     1982.  Published June 1982.

4.   CH2M HILL.  Interim Offsite Remedial
     Investigation Report.  Western Pro-
     cessing, Kent, Washington.  Prepared  for
     EPA WA 370L16.0.  October 1983.

 5.    U.S. Environmental Protection Agency,
      Region X.  Western Processing Alterna-
      tives Assessment Study, 1983 Data Report.
      April  1984.

 6.   U.S.  Environmental Agency, Region X,
      Environmental  Services Division, Field
      Operations and Technical Support Branch.
      Hydrologic data for Mill Creek survey.
      (unpublished)   January 1984.

 7.   CH2M HILL.  Remedial  Investigation Data
      Report.   Western Processing, Kent, Wash
      ington.   EPA WA 37 OL16.1.  December  1984,
                                                  Medium
                                                  Sampled
                                                     Water
                                                     Water
                                                     Water
                                                     Sediment
                                                     Sediment
                                                     Sediment
                                                     Water
Conventional
Water Quality
  Variable
                                                                    Yes
                                                                    Yes
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                                        Variables Analyzed
Priority
Pollutant
 Metals
                                                                                As total
                 As total
                 As total  dissolved
                 As total
                 As total  after EP
                   toxicity extraction
                                                                                As total
                                                                                As total
                                                                                As total
Priority
Pollutant
 Organics

   No
                                                                                                           Yes
                                                                                                           Yes
                                           Yes
                                                                                                          Yes
                                           Yes
                                                     Contains data  from  references 1, 2, 3
     8.   Radian Corporation (1984).   Unpublished
         draft report.
      Conventional water quality variables  are nutrients, temperature,  pH,  etc.

-------
\  '\
                                                                           \,-,< >, .  - ^   }   , 1
                                                                            T •  I  ! i ,  '  ,
                                     WESTERN
                                    PROCESSING
                                       SITE
                                                                           SPRINGBROOK CREEK
                                                                                SUBAREA
                                   MILL CREEK
                                    SUBAREA
    BLACK RIVER DRAINAGE SUBBASIN AREAS
     MILL CREEK ABOVE
     CONFLUENCE WITH
     SPRING BROOK CREEK 11.0 SO Ml
                            0           3350
                                      i
                              Scale in Feet
CT^
-J
    SPRINGBROOK CREEK
    ABOVE CONFLUENCE WITH
    MILL CREEK 7.2 SO Ml

    BLACK RIVER ABOVE
    CONFLUENCE WITH
    GREEN RIVER 26.5 SO Ml
      1-::
    0 OFF PROPERTY SAMPLING
   ,:~ LOCATIONS
                                                                                            FIGURE 3-53
                                                                                            BLACK RIVER DRAINAGE BASIN

-------
Creek passes Western Processing  (Table 3-47).  The concen-
trations of dissolved copper, lead, cadmium, and zinc ex-
ceeded the USEPA 24-hour criteria in most samples at the
station downstream of Western Processing.  Concentrations of
dissolved copper, cadmium, and zinc exceeded the USEPA max-
imum recommended concentration in one or more samples down-
stream of Western Processing  (Table 3-47).

The detection limits indicated for dissolved cadmium were in
excess of the 24-hour criterion, so it is possible that the
24-hour criterion for that metal was exceeded by water up-
stream of Western Processing.  Dissolved chromium could have
been present in either the trivalent or hexavalent state.
When detected on May 22, 1984, at the upstream station, and
on June 27, 1984, at the downstream station, the observed
concentrations were within the solubilities of both valence
states.  Table 3-47 shows criteria values for both valence
states.  The 24-hour criterion for hexavalent chromium is
lower than can be measured and thus could have been exceeded
both upstream and downstream of Western Processing.  Criteria
values for trivalent chromium were not exceeded anywhere.
The concentrations of dissolved zinc exceeded the 24-hour
criteria in all samples downstream of Western Processing,
and exceeded the maximum recommended concentration in all
but one sample downstream of Western Processing, but did not
exceed any criteria upstream of Western Processing.

Criteria values are stated in terms of total recoverable
metals.  Concentrations of dissolved metals are likely to
range from slightly less to much less than those of total
recoverable metals (as defined by USEPA, 1979).  The
extraction procedure for total recoverable metals uses a
weak acid to remove metals lightly bound to particulate
matter.  Concentrations of dissolved metals shown in
Table 3-47, which are slightly less than the criteria
values, could thus represent total available levels
exceeding the criteria.  Examples are some of the values for
copper, cadmium, nickel, and zinc.

The criteria used for chromium are for the hexavalent state
(+6) and trivalent state  (+3) (see Chapter 2).  Either form
could occur in Mill Creek water because the concentrations
observed are within the solubility range of both forms.
Because of its high affinity for reducing substances, hexa-
valent chromium would probably become bound to organic
substances shortly after entering Mill Creek.  Trivalent
chromium would probably occur with organic chelating sub-
stances or colloidal-sized particles.

There are more data on concentrations of total metals  (sus-
pended plus dissolved)  in Mill Creek than on concentrations
of dissolved metals.   Tables 3-48 through 3-52 show the con-
centrations of total copper, chromium, nickel, zinc, and
                            3-169

-------
                                                              Table  3-47
                  WATER  HARDNESS,  CONCENTRATION OF DISSOLVED  METALS AND  AMBIENT  WATER  QUALITY
        CRITERIA  AT  WDOE  STATIONS  09E090  (UPSTREAM)  AND  09E070   (DOWNSTREAM)  AT WESTERN  PROCESSING
               Hardness as
U>
 I

CaCO, (mg/L)

Date Sta. Not Sta. No. Sta.
(1984)
April 11
May 22
June 27
July 11
August 7



April 11
May 22
June 7
July 11
August 7

Dissolved
No. Criteria
09E090 09E070 09E090 24-hour
52 100
120 60
92 80
110 140
™ ™

Sta. No.
09E090

2.0
l.OU
l.OU
l.OU
l.OU
1.
2.
1.
1.
1.

OU 0.29(44)
0 0.29(44)
OU 0.29(44)
OU 0.29(44)
OU 0.29(44)
Dissolved Lead
Criteria


0.8
5.9
3.1
4.8
—
u •

77.5
215
156
193
—
Maximum
21(2,315)
21(5,713)
21(4,288)
21(5,201)
2K-)
(pg/L)
Sta. No.
09E070

1.0
l.OU
8.0
1.0
l.OU
Chromium
Sta. No.
09E070
l.OU
10. OU
5.0
l.OU
l.OU

(pg/L) Dissolved Copper (pg/L)
Criteria Sta. No. Criteria Sta. No.
24-hour
0.29(44)
0.29(44)
0.29(44)
0.29(44)
0.29(44)

Criteria


3.8
1.2
2.3
8.4
-
...

172
92
131
259
—
Maximum
21(4,692)
21(2,702)
21(3,687)
21(6,748)
2K-)

Sta. No.
09E090

0.20U
0.10U
0.10U
0.10U
0.20U
Dissolved Nickel (pg/L)


April 11
May 22
June 27
July 11
August 7
Sta. No.
09E090
1U
10
-
1U
1U
Criteria
24-hour
58
110
90
103
-
Maximum
1,122
2,119
1,731
1,983
-
Sta. No.
09E070
45
10
_
62
104
Criteria
24-hour
96
65
81
123
-
Maximum
1,844
1,251
1,557
2,382
-
Sta. No.
09E090
19
41
4
1U
1U
09E090 24-hour Maximum 09E070
2.0 5.6
1 . OU 5.6
1 . OU 5.6
2.0 5.6
1 . OU 5.6
Dj ssolved
Criteria
1A Knit*- U^viml n

0.0125 1.52
0.0301 3.66
0.228 2.77
0.0275 3.34
- —
Dissolved
Criteria
24-hour Maximum
47 187
47 364
47 300
47 425
47
12.0 12.0
26.3 l.OU
20.5 23.0
24.3 10.0
14.0
Cadmium (pg/L)
Sta. No.


6.40
0.90
-
18.90
14.50
Zinc (pg/L)
Sta. No.
09E070
470
113
877
936
710
Criteria
24-hour Maximum
5.6
5.6
5.6
5.6
5.6

22.2
13.7
18.0
30.4
~

Criteria


0.0249
0.0145
0.0197
0.0354
-



3.02
1.77
2.39
4.30
-

Criteria
24-hour
47
47
47
47
47
Maximum
321
210
267
425

      Chromium criteria for the hexavalent and trivalent forms are shown.  Criterion for trivalent chromium is placed within the parenthesis.

     Notes:  "-" indicates no value available.
           "U" indicates minimum level of detection (element not detected).
           All criteria are USEPA ambient water quality criteria for total available levels of the metal.

-------
                                                   Table 3-48
              CONCENTRATIONS  OF TOTAL COPPER (ug/L)  MEASURED BY METRO  AND THE USEPA
          AT STATIONS  UPSTREAM,  DOWNSTREAM, AND FAR DOWNSTREAM OF WESTERN PROCESSING
Station
Number
09E090

8


X317

E317
E317
E317
E317
E317
E317
6A
6A
3A
1
1
09E070


0317
0317
0317
0317
0317
0317
0317
0317
Year
Sampled
1984

1984


1981
1981
1979
1979
1979
1980
1981
1981
1982
1984
1982
1982
1984
1984


1979
1979
1979
1980
1981
1982
1983
1984
Reference
No.
2

7
Average:

1
1
1
1
1
1
1
1
3
7
3
3
7
2
Average:

1
1
1
1
1
1
1
1

Jan Feb


78
78.0 26.3



20 10


17 40



101


140

69.5 25

10 <10


13 21
<20 10
20 20
20 <10
10 10

Mar Apr May
13 t


26.3 13.0 t



<10 20 14


13 11 14


116

66
125

35 30
6.5 22 60.83

<10 <10 <10


14 <10 <4
10 10 <20
30 20 10
30 10 <10
10

Jun
20


20.0

10
< 10
12


9.7
30
40





50
21.7

10
<10

4 .4
10
10
<10


Jul Aug Sep
18 29


18.0 29.0 26.3



17 13 10
< 10

7.5 9.3 13







44 61
22.83 27.76 7.7

20 <10 30
10
30
<3 <6 3.2
<10 10 <10
10 10 <10
<20 10 <10


Oct Nov Dec Avg.
26.3
(upstream)

26.3 26.3 26.3 31.1
(downstream)


10 20 ]0
50
30
17.1 18 20








26.77 19 15 (far
downstream)



3.3 13 10
10 <10 <20
10 20
10 20 20

 Far downstream averages were not calculated because they  were not used to determine mass  flows.

Note:   Averages of  all  measured values are used for calculating mass flows upstream and downstream of Western Processing.

-------
                                                    Table  3-49
                CONCENTRATIONS  OF TOTAL CHROMIUM  (ug/L) MEASURED BY METRO AND THE  USEPA
             AT STATIONS  UPSTREAM,  DOWNSTREAM,  AND  FAR DOWNSTREAM  OF WESTERN PROCESSING
to
Station
Number
09E090


X317

E317
E317
E317
E317
E317
E317
6A
6A
3A
1
1
09E070


0317
0317
0317
0317
0317
0317
0317
0317
Year
Sampled
1984


1981
1981
1979
1979
1979
1980
1981
1981
1982
1984
1982
1982
1984
1984


1979
1979
1979
1980
1981
1982
1983
1984
Reference
No.
2

Average:
1
1
1
1
1
1
1
1
3
7
3
3
7
2
Average:

1
1
1
1
1
1
1
1

Jan


3.4


10


<35



19


20

12.3

20


<10
<20
<20
<20
<20

Feb Mar Apr
t

3.4 3.4 t


<10 30 70


17 <10 <20







9
8.5 15.0 26.3

10 <10 20


<10 <10 <20
20 <20 <40
<20 <20 <20
<20 <20 <20
<20 <20

May
4

4


43


46


24

33
36

13
32.5

<10


<24
<40
<20
<20


Jun Jul
13 t

13 t
20
<40
62 44


42.8 24.2
40
<40





24 t
27.0 22.7

21 <10


16.4 <18
<40 <20
<20 <20
<20 <20


Aug
t

t


28


<30







8
12.0

11


<30
<20
<20
<20


Sep Oct


3.4 3.4


25 18
25 110
45
43.7 37.6








31.2 52.7

10 19
<10 20
30
<21 <21
<20 <20
<20 <20
<20 <20


Nov Dec Avg.
3.4
(upstream)
3.4 3.4 (downstream)
25.2

44 22


<30 <40








22.0 11.0 (far
downstream)
18 <10


<30 <40
<20 <20
<20
<20 <40

      Far downstream averages were not calculated because they were not used to determine mass flows.

     Note:  Averages of all measured values are used for calculating mass  flows upstream and downstream of Western
           Processing.

-------
LO
                                                            Table  3-50
       CONCENTRATIONS  OF  TOTAL NICKEL  (pg/L)  MEASURED  BY METRO AND THE USEPA AT  STATIONS
                     UPSTREAM,  DOWNSTREAM,  AND  FAR  DOWNSTREAM OF  WESTERN  PROCESSING
Station
 Number

09E090
6A
8
1984
1982
1984
                          Reference
                             No.

                              2
                              3
                              7

                          Average:
Jan



 56

 56
                              Feb
                                      Mar
                                                             June
                                         10.7
                                                  10.7
                                                          <1
                                                                                 <1
                                                                             Aug
                                                                             <1
                                                                                        <1
                                                                                             Oct
                                                                                                     Nov
                                                                                                            Dec
                                                                                                                      Avg.
                                                                                                 10.7
                                                                                                        10.7
                                                                                                                10.7
                                                                                                                        10.7
  10.7
(upstream)
                                                                                                                               98.4
                                                                                                                               (downstream)











U)
1
I—1
X317

7A
E317
E317
E317
E317
E317
E317
6A
6A
1
1
09E070
1981
1981
1982
1979
1979
1979
1980
1981
1981
1982
1984
1982
1984
1984
1
1
3
1
1
1
1
1
1
3
7
3
7
2






<70



75

81

                                         40
                                                  40
                                                          60
                                                                495
                                                                 80
                                                                261
                                                                        <20
                                                                         40
                                                                         98.6
                                                                        140
                                                                        200
                                                                                95
                                                                                       113.3
                                                                                                 50
                                                                                                 50

                                                                                                175.1
                                                                                             40      50
                                                                                            <20
                                                                                             20
                                                                                            147.2   100
                                                                                                                        40
                                                                                                                        80
          Average:
                                   52
                                          40
                                                  40
                                                                261

                                                          99      12     117

                                                          79.5   221.8    99.3
                                                                     82     106

                                                                     88.5   109.6
                                                                                                 51.8
                                                                                                        51.8
                                                                                                                75
                                                                                                                       60
                                                                                                                              (far
                                                                                                                              downstream)'
0317
0317
0317
0317
0317
03]7
0317
0317
1979
1979
1979
1980
1981
1982
1983
1984
1
1
1
1
1
1
1
1


<20
30
20
30
30


<20
50
30
20
20


20
50
60
50
<20


30
70
40
40



20
40
30
20



21.3
20
40
<20



14.5
40
30
<20



21.4
40
20
20

<20
<20

<180
20
30
40

<20
<20
<20
21.4
50
40
20

<20

37
20

<20

<20

30
20
30
<20

 Far downstream averages were not calculated because they were  not used to determine mass flows.

Note:  Averages of  all measured values are  used for calculating mass flows upstream and downstream of Western Processing.

-------
                                                Table  3-51
       CONCENTRATIONS OF  TOTAL ZINC (yg/L)  MEASURED  BY METRO  AND  THE USEPA AT  STATIONS
                UPSTREAM,  DOWNSTREAM, AND FAR DOWNSTREAM OF WESTERN PROCESSING
Station
Number
09E090
8A
8


X317

7A
E317
E317
E317
E317
E317
E317
6A
Ul 6A
1 3A
S 1
,b 1
09E070


0317
0317
0317
0317
0317
0317
0317
0317
Year
Sampled
1984
1982
1984


1981
1981
1982
1979
1979
1979
1980
1981
1981
1982
1984
1982
1982
1984
1984


1979
1979
1979
1980
1981
1982
1983
1984
Reference
No.
2
3
7
Average :

1
1
3
1
1
1
1
1
1
3
7
3
3
7
2
Average :

1
1
1
1
1
1
1
1

Jan Feb


32
32 37




260 250


722 487



695


729

601.5 368.5

159 191


442 253
260 320
353 347
321 308
382 237

Mar Apr May
102 60
30

37 102 45



168
470 560 434


421 670 800


2,250

2,250
2,300

680 415
445.5 636.6 1,231

242 230 105


327 344 237
400 478 297
553 423 381
565 577 436
134

Jun Jul Aug Sep
20 3 11


20 3 11 37

42
10

541 591 340 377
377

822.5 1,010 1,110 1,538
3,670
1,790





935 1,262 1,425
1,115.8 954.3 958.3 764

97 32 57 33
33

140.7 85.7 87.9 125.1
250 237 204 107
384 225 138 198
413 230 226 2,850


Oct Nov Dec Avg.
36.9
(upstream)

37 37 37 828.4
(downstream)



94 78 44
481
474
1,560 910 750








652.3 494 397 (far
downstream)3
125 178 235
114
480
114.6 230 310
739 190 234
299 361
1,670 88 242

 Far downstream averages were not calculated because they were not used to determine mass flows.

Note: Averages of all measured values are used for calculating mass flows upstream and downstream of Western Processing.

-------
                                                Table 3-52
      CONCENTRATIONS OF TOTAL LEAD  (ug/L)  MEASURED BY  METRO AND THE USEPA AT STATIONS
                UPSTREAM, DOWNSTREAM,  AND  FAR  DOWNSTREAM OF  WESTERN  PROCESSING
Station
 Number

09E090
8A
8
  Year
Sampled

 1984
 1982
 1984










(jj
1
I—1
-J
U1









X317

7A
E317
E317
E317
E317
E317
E317
6A
6A
3A
1
1
09E070
0317
0317
0317
0317
0317
0317
0317
0317
1981
1981
1982
1979
1979
1979
1980
1981
1981
1982
1984
1982
1982
1984
1984
1979
1979
1979
1980
1981
1982
1983
1984
Jan   Feb   Mar    Apr
                                14   12.4   12.4    14
                                               15
Jun
                                14
                                14
Jul

 11



 11
                  Sep   Oct    Nov  Dec
             Avg.
                                           12.4
                                        (upstream)
                  12.4   12.4
12.4  12.4     18.0
          (downstream)
                   Reference
                     NO.

                       2
                       3
                       7

                   Average:


                       1
                       1
                       3
                       1

                       1
                       1
                       1
                       1
                       3
                       7
                       3
                       3
                       7
                       2

                   Average:


                       1
                       1
                       1
                       1
                       1
                       1
                       1
                       1


aFar downstream averages were not calculated because they were not used  to detrmine mass  flows.
Note:   Averages of all measured values are used for calculating mass flows upstream and downstream of Western Processing.


<20


<70



16


15

7.8

<20


<20
<40
<20
<20
<20


20


40








30

<20


70
<20
<20
<20
<20


<20


20








10

<20


30
<40
30
<20
30


60


<30







13
24.3

<20


<30
20
<20
<20


20
<20


<30


20

19
20

50
38.4

<20


<30
<40
<20
<20

<20
<20

<20


10.6
<20
20





70
14. 4

<20


<8
<20
<20
<20



<20


<24







8
2.7

<20


<24
<20
30
<20



<20


<12







12
4

<20


16.3
<20
<30
<20



20
<20

<28








6.7

<20
<20

<28
<20
<20
<20



80
20
60
<27








40

90
<20
<50
<27
<20
<20
20



40 60


24 20








32 40 (far
downstream)
<20 50


35 <20
<20 <20
<20
20 40


-------
lead compiled from all available sources.  The sampling
locations are arranged from upstream to downstream in the
tables.  The pattern of higher concentrations immediately
downstream of and adjacent to Western Processing is ap-
parent.  Concentrations of total metals should not be com-
pared with the ambient water quality criteria because the
sample extraction procedure for total metals results in an
overestimation of total available metals,by an unknown and
variable amount, depending in part on the relative amount of
metals present in mineral grains (suspended particles), as
discussed in Chapter 2.

Concentrations of total copper (Table 3-48) appear to in-
crease as Mill Creek passes Western Processing.  The data
from DOE show an increase of approximately 100 percent dur-
ing five months of 1984.  The data from USEPA are less clear
since a valid upstream concentration was measured only once.
(Other samples were rejected by USEPA quality assurance pro-
cedures.)  However, on that date in January 1984, the in-
crease in total copper was also about one hundred percent as
the creek passed Western Processing.  The Municipality of
Metropolitan Seattle (Metro) data include only two values
for total copper from station X317 (along the boundary of
Western Processing but not upstream from it) during June of
1981.  Concentrations of total copper increased three to
four times between stations X317 and E317  (Table 3-48; see
Plate 1 for station locations).  The Metro data from sta-
tion 0317 on the Black River  (below the confluence of Mill
Creek with Springbrook Creek and the tributary inflow of
Panther Creek and several other drainages)  do not show the
elevated concentrations of total copper observed at or below
Western Processing.

Data from WDOE show fairly large increases in the concentra-
tion of total chromium as Mill Creek passes Western Process-
ing during 1984  (Yake, 1985).  The 1982 analyses for total
chromium by USEPA from stations 8A (upstream) and 7A  (near
the upstream boundary)  were rejected during the USEPA qua-
lity assurance review of that study.  Increases in total
chromium thus cannot be shown with the USEPA data due to the
absence of upstream data.  The data from Metro do not demon-
strate the increase because of relatively high detection
limits and the absence of a station that is upstream from
the site (Table 3-49).

Total nickel increased ten to one hundred times in Mill Creek
as it passed Western Processing during April through August
1984, based on sampling by WDOE (Yake, 1985).  Samples col-
lected by USEPA in May of 1982 show a similar pattern, but
the increase in total nickel was less than two times in sam-
ples collected by USEPA in January 1984 (Table 3-50).  Con-
centrations of total nickel reported by Metro are relatively
consistent with the USEPA and WDOE data.  Ongoing studies by
WDOE will provide additional information on seasonal patterns,


                            3-176

-------
Concentrations of total zinc increased from ten to four-
hundred times as Mill Creek passed Western Processing (Ta-
ble 3-51 and Yake, 1985).  All of the sources of data are
consistent in showing large increases in total zinc.  Data
from Metro's distant downstream station  (0317) show concen-
trations of total zinc remaining four to one-hundred times
higher than the concentrations upstream of Western
Processing.

Other metals sampled in Mill Creek did not increase adjacent
to the Western Processing site.  These included arsenic,
cadmium, lead, mercury, selenium, and silver.   (Some of
these metals were not analyzed by all agencies.)  More data
are available for lead than for any other of the metals
listed above.  Concentrations of total lead are shown in
Table 3-52  (little, if any, dissolved lead was detected
during analysis).

Groundwater draining from the site is a possible source of
contamination.  Springs and seeps have been noted at and
near the site.  In May of 1982, the USEPA collected samples
of water from Mill Creek and from four well points adjacent
to Western Processing.  One well point (8B) and surface water
station  (8A) were upstream of Western Processing.   Three
well points and four surface water sampling locations were
adjacent to or downstream of Western Processing.  (Sampling
locations are shown on Plate 1.)

Concentrations of dissolved cadmium, nickel, and zinc were
higher in well point 7B, just downstream of a former drain-
age from Western Processing, than in the upstream well point,
8B  (Table 3-53) .  Concentrations of total metals were vari-
able but highest in the upstream well point.  Sediment in
the samples from the well points, a possible source of the
high concentrations of total metals, may indicate relatively
high concentrations of metals in the soil at USEPA Station 8,
but the concentrations of dissolved metals from the well
points adjacent to Western Processing support the hypothesis
that groundwater is flowing to Mill Creek.

Samples from groundwater monitoring wells near the creek
(Table 3-54) contained concentrations of dissolved arsenic,
cadmium, chromium, copper, lead, mercury, nickel,  zinc, and
cyanide that were considerably higher than those in Mill
Creek (Tables 3-47 and 3-53).  Ten- to one-thousand-fold
dilution of the concentrations of dissolved metals in water
from Wells 9, 10, 27, and 28 would result in the general
concentrations of dissolved metals observed in Mill Creek.
Groundwater flows to Mill Creek from Western Processing are
approximately 0.5 cfs  (Section 3.3.3).  Creek flows have
been shown by USEPA on two occasions to increase from 3 to
3.5 cfs and 11.2 to 15.5 cfs as the creek passes Western
Processing.  As an estimate of normally prevailing flows,
creek flows estimated by correlation with nearby stream

                             3-177

-------
                                                 Table  3-53
          CONCENTRATIONS OF  TOTAL AND DISSOLVED METALS IN WATER SAMPLES FROM WELL POINTS
              AND MILL CREEK  (SURFACE WATER)  COLLECTED BY THE USEPA  ON MAY  20-21,  1982
                                         (Concentrations in yg/L)

                                                             Sample





U)
1
-J
00




Metal
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Total 8A
Concentration Surface
(Dissolved Water
Cone.) T D
MCt (50) 8
__
(10) 0.3 0.3
(50)
~
(50) 24
(2) 0.2 --
14 7
__
__
30 20
8B 7A
Surface
Well Water
T D T D
1733 15 6
0.69 —
10 0.2 0.3 0.3
2500
2450
232 — 20 2
11 — 0.2
720 — 495 13
160
4.5
4560 10 168 150
7B 6A 6B 3A 3B
Surface Surface
Well Water Well Water Well
TDT DTDT DTD
147 29 23 ~ 515 ~ ~ ~ 483 11
7.2 —
8.7 7.1 53 38 1.2 ~ 45 29 1.4 --
200 ~ 24 26 490 ~ 33 22 350
166 ~ 116 — 850 ~ 68 ~ 493
20 11 ~ — 19
0.3 — 1.8 ~ 0.1 ~ 1.1 «
747 270 261 180 207 ~ — — 243
25 ~ ~ -- 20
1.2 -- -- -- 1.2 --
395 450 2260 1800 1265 ~ 2250 1820 840 10
1
Surface
Water
T
6
—
46
36
125
20
0.3
261
—
~
2300
D
4
~
34
29
~
4
~
207
~
—
1780
Note:  Stations 8A and 8B are located upstream of Western Processing; Station 1 is located downstream.
      T = Total.
      D = Dissolved.

-------
                             Table  3-54
        CONCENTRATIONS OF  DISSOLVED PRIORITY POLLUTANT
        METALS AND  CYANIDE IN WATER FROM  WELLS ADJACENT
                           TO MILL CREEK
                     (Concentrations  in yg/L)
 Metal          Date
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984

Aug-Sept 1982
June 1983
June 1984
                                            Well Number
9 10 27
25 21 25
50
<6
320 60,000 320
918
3,900
224
53
6,300
156
620
218
99
0.43
6,400 28,000 6,400
4,500
NM
45 ~ 45
<2
94,000 400,000 94,000
58,300
84,000
28
25
130
<6
5,600
53,700
28,000
6,100
39,900
300
590
7,720
2,500
6.5
294
440
—
77,000
129,000
NM
45
<2
510,000
298,000
610,000
Cyanide                         43

Note:"—"  indicates not detected.
       "NM"  indicates not measured.
                                830
43
920
                                3-179

-------
basins vary between 6 and 43 cfs  (Section 3.7.3.1).  If
groundwater flows to Mill Creek were as little as 0.1 cfs or
less, the concentrations of dissolved metals in Wells 9, 10,
27, and 28 would be sufficient to account for the concen-
trations observed in Mill Creek.  Samples of groundwater
near Mill Creek and surface sediments in areas which drain
to Western Processing thus provide indications of the
sources of the high concentrations of metals in Mill Creek.

Samples of surface water collected at various times from the
east drain, from pipes draining to Mill Creek, and from an
intermittent pond north of the site all had high concen-
trations of metals  (CH2M HILL, December 1984) .  Samples col-
lected from the same drainages upstream of Western Processing
did not have elevated concentrations of metals.  All known
surface drainage from the site is now collected and treated.
It is therefore unlikely that the high concentrations of
metals measured previously are now entering Mill Creek from
Western Processing through surface flow.

3.7.1.2  Organics

WDOE analyzed for a limited number of organic compounds in
water from Mill Creek during 1984 using GCMS Method 624 at
the USEPA laboratory in Manchester, Washington.  Benzene and
toluene were detected in trace  (unguantifiable) amounts up-
stream of Western Processing.  Trichloroethylene was found
at concentrations from 11 to 31 yg/L downstream in samples
collected during all months.  Chloroform was detected during
June and July 1984 at concentrations of 14 and 18 yg/L,
respectively.

Toluene, tetrachloroethylene, and 1,1,1-trichloroethane were
found at concentrations ranging from a trace to 8 yg/L.
Methylene chloride was observed at concentrations ranging
from undetected  «2 yg/L) to 41 yg/L.

USEPA analyzed for priority pollutants in water from Mill
Creek and well points near the creek on the side of Western
Processing during its vicinity survey of May 20 and 21, 1982.
Twenty-five organic compounds were detected  (Table 3-55).
Fourteen of those were found only in Mill Creek.  Five oc-
curred only in well points adjacent to the creek, and six
were found both in the creek and in well points.  Several
organic compounds found in the creek were not detected in
the well points.  Bis-(2-ethylhexyl)phthalate was present in
Mill Creek downstream of Western Processing in amounts in
excess of USEPA 24-hour criteria for ambient water (3 yg/L).
A water sample from a well point upstream of Western Pro-
cessing  (Station 8B, Plate 1) had 320 yg/L of bis-(2-ethyl-
hexyl)phthalate, the highest concentration reported in the
survey.  Therefore, Western Processing may not have been the
source of the bis-(2-ethylhexyl)phthalate that was detected
in the creek.


                            3-180

-------
                                                                                                  Table   3-55
       CONCENTRATIONS  OF   ORGANIC   PRIORITY  POLLUTANTS  DETECTED   IN   MILL  CREEK  AND   IN   GROUNDWATER  FROM
                                            WELL   POINTS  ADJACENT   TO   THE  CREEK   BY  THE   USEPA  IN   MAY   1982
U)
 I
00
Lab Nuiber
Date Sampled
Time Sampled
Estimated StreaBflov

  B/N Fraction
    Acenaphthene
    Isophorone
    Naphthalene
    Bis 12-ethylhexyl) phthalate
    Dl-n-butyl phthalate
    Dl-n-octyl phthalate

  Acid Fraction
    2,4 dlchlorophenol
    2,4 dimethyl phenol
    Phenol
    Tetrachloropbenol
    Pentachloroph«nol

TOTAL PHENOLS

      itiles
                         ,2 dlcbloroethone
                         fl,l trlchloroethane
                         ,1 dlchloroetbane
                         3ilaroforB
                         ,1 dlchloroethyleoe
                         ,2 trans dlchloroethylene
                        Ethylbenzene
                        Methylene Chloride
                        Tetracbloroethylene
                        Toluene
                        Trlchloroethylene
                      Pesticides
                        4,4' DDT
                        4,4' DDE

                      PhenolIcs

                      Others
                        Cyanide
                        pH  (units)
                        Conductivity I [Mhos)
8A 6B
(surface (well
water) point)
20027 20029
5/20/62 5/20/82
15:10 15:40
3 cfs
_
-
-
320
-
0.1.
_
-
-
0.004
0.007
-
_
-
-
-
-
IB
-
-
-
-
~
.
-
-
5 Sa
7.1 6.6
J2 219
7A
(surface
water)
20022
5/20/82
14:35
~""
.
-
-
-
0.07
6.8
.
-
-
-
-
-
In
33
]•
19
-
-
-
-
1.5
-
•
.
-
-
8
7.0
526
7B
(well
point)
20021
5/20/82
15:00
"•"
.
-
-
34
-
-
.
-
-
-
0.004
-
_
-
-
1.8
-
-
-
-
-
-
13
0.017
0.06
-
HO
4.6
969
6A 6B
(surface (veil
water) point)
20025 20056
5/20/82 5/20/82
12:45 12:30
3.37 cfs
0.57
0.2
0.06»
4.2 S
0.14
-
1.9
5.2 4.6
-
0.001
0.002
245
!•
8.7
1.7
45
]•
36
1>
98
2.6
!•
35
.
-
245
10 8
6.8 6.5
500 621
3A
(surface
water)
20056
5/21/92
12:25
—
f
-
-
-
-
"
1.8
4.6
120
0.002
-
202
1»
ll
10
51
1.3
45
In
57
3.3
1.
44
.
-
202
.5
6.8
600
3B
(well)
point)
20053
5/21/82
11:15
—
.
-
-
5.6
-
0.8
_
-
1.5
-
0.001
-
_
-
-
-
-
-
-
-
-
-
~
_
-
-
5
6.4
548
1
(surface
water)
20015
5/21/82
10:45
3.5 cfs
_
-
-
33
0.2
-
2.8
3.4
1.1
-
-
210
.
-
-
36
-
26
U
74
2.6
!•
43
.
-
210
15
6.7
610
                     Analyzed by gas chronotograph;  other organlcs analyzed by GS/MS unless noted.
                    Notes:  All data reported in M9/U  "~"  Indicates not detected.
                            Organic contaminants were detected In Mill Creek and shallow qroundwater adjacent to Mill Creek  (well points)  during  the May 20 to 21, 1982, vicinity at Western Processing.
                              Stations 8A and BB are upstreai of Western Processing.
                            "•" Indicates detected at BlniBUH detection Halt.

-------
The data from the 1982 vicinity survey may not fully repre-
sent the current conditions at Western Processing because
surface runoff control and treatment measures are now in
place and operating.  Sampling in January 1984 at three of
the locations sampled in May of 1982 revealed fewer organic
compounds: ten in January 1984 (Table 3-56)  versus twenty in
May 1982 (Table 3-55).  Of the compounds detected, only the
volatiles chloroform and trichloroethylene were detected
both adjacent to Western Processing (Station 6A)  and immedi-
ately downstream (Station 1).

The surface drainage control measures were implemented be-
tween the May 1982 and January 1984 samplings by USEPA.
Continued presence of the volatile compounds detected in the
samples collected by WDOE in the creek adjacent to and down-
stream of Western Processing suggests contamination via
groundwater.  In fact, if one assumes a constant input via
groundwater in comparing the January 1984 and May 1982
samples, the reduced concentrations of chloroform and tri-
chloroethylene in January 1984 can be explained by the
higher flows in Mill Creek in January 1984 than in May 1982.
The samples from well points in May 1982 (Table 3-55)  do not
strongly support the hypothesis that groundwater is a major
source of the volatile organics found in Mill Creek.  How-
ever, other groundwater data,  from Wells 9,  10, 27, and 28,
in 1982 through 1984 show substantial amounts of volatile
organic compounds in some samples and do support the con-
clusion that volatile organics are reaching Mill Creek via
groundwater.

3.7.2  CONTAMINATION OF MILL CREEK SEDIMENT

3.7.2.1  Metals in Sediments

Sediment samples taken from Mill Creek in August 1983 were
analyzed by the USEPA Contract Laboratory Program  (CH2M
HILL, 1983).  Samples collected in 1984 were reported by
Radian Corporation  (1984) .

Concentrations of some metals in Mill Creek sediments in-
creased at Western Processing and remained high downstream
of the site (Table 3-57).  Sediment concentrations of
cadmium, chromium, copper, nickel, and zinc all increased
ten- to one-hundred-fold at downstream locations relative to
concentrations upstream of Western Processing.  Other metals
such as lead, that were abundant onsite did not increase in
sediments of Mill Creek downstream of Western Processing.

The relatively high ratio of dissolved to total metals in
Mill Creek water (of the metals showing large increases in
concentration near Western Processing) and the absence of
apparent contamination by nearly insoluble metals such as
lead indicate that sediments in Mill Creek are becoming con-
taminated by adsorption of metals from solution rather than

                            3-182

-------
                         Table 3-56
                 ORGANIC POLLUTANTS DETECTED
   DURING THE JANUARY 1984 HYDROLOGIC SURVEY OF MILL CREEK
            IN THE VICINITY OF WESTERN PROCESSING
                   (Concentrations in yg/L)

	Compound	    Station 8   Station 6A   Station 1

Volatile Compounds

1,1,1-trichloroethane        2Ua          2U,          2.5
1,1-dichloroethane           2U           2M           2M
Chloroform                   2U           10           9
Tetrachloroethylene          2M           2M           2M
Trichloroethylene            2U           15           12

Base-Neutral Compounds

Isophorone                   3U           0.15         3U
Naphthalene                  0.06         0.13         0.03U
Pyrene                       0.1          0.08U        0.05U

Acid Compounds

2,4--dichlorophenol           0.1U         0.7          0. 1U
2,4-dimethylphenol           0.1U         0.7          0.1U
a
 U indicates compound was not detected at the given detection
 limit.
 M indicates compound was identified but not quantified at
 the given detection limit.

Note:  Stations sampled were the same as those shown in
       Table 2-27.
                            3-183

-------
                                                       Table  3-57
                                                   SEDIMENT  SAMPLING
u>
I
i->
00

Station
Mill Creek
10
11
12
13
22
R30
14
R26
15

23
R23
30
16
17A
17B
18
19
20
21
24
25
26
27
28
East Drain
4A
4B
3
6
7
East Ditch
2
5
8
Springbrook
Date
Sampled

Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983

Aug 1983


Aug 1983
Aug 1983

Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983

Aug 1983
Aug 1983
Aug 1983
Aug 1983
Aug 1983

Aug 1983
Aug 1983
Aug 1983
Creek
       29         Aug 1983
                               Reference
                                  No.a
5,6
5,6
5,6
5,6
5,6
 8
5,6
 8

5,6
5,6
 8
5,6
5,6
5,6
5.6
5,6
5,6
5,6
5,6
5,6
5,6
5,6
5,6
5,6
                                  5,6
                                  5,6
                                  5,6
                                  5,6
                                  5,6
                                  5,6
                                  5,6
                                  5,6
5,6
                                       Total Metals (mg/kg)
Chromium









1


1


















2
12
6
10
7
7
28
6
170
15
,560
300
64
,620
308
398
16
9
51
128
57
6
90
18
10
11
9
7
8
23
17
793
,620
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.5
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
Nickel
8
4
8
8
6
3
4
21
8
116
99
14
108
8
12
12
12
12
16
44
12
16
12
8
8
8
6
8
28
12
16
48
.0
.0
.0
.0
.0
.8
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
Zinc
91
51
79
47
27
85
48
470
155
1,130
930
146
1,120
168
215
46
91
248
280
898
94
430
102
52
167
118
878
1,470
3,630
31,100
1,670
3,710
Arsenic
.5
.5
.5
.0
.5
.0
.5
.0
.0
.0
.0
.0
.0
.0
.0
.5
.5
.0
.0
.0
.5
.0
.0
.5
.0
.0
.0
.0
.0
.0
.0
.0
7.
4.
5.
5.
3.
<60
3.
<60
5.
6.
<60
2.
5.
9.
8.
8.
6.
4.
6.
3.
3.
4.
4.
4.
7.
7.
5.
7.
7.
11.
12.
24.
0
5
5
5
0

5

5
0

5
5
0
5
0
5
0
0
5
0
0
0
5
5
0
0
5
0
0
0
0
Cadmium
0
0
0
0
0
<0
0
22
1
16
30
3
15
4
4
0
0
7
10
30
1
8
1
0
0
0
1
0
68
5
4
18
.55
.40
.45
.25
.10
.39
.40
.00
.50
.00
.00
.10
.00
.00
.00
.30
.70
.90
.00
.00
.30
.80
.00
.35
.80
.55
.40
.40
.00
.60
.60
.00
Lead Copper
38.00
11.00
42.00
21 .00
8.50
58 24
13.00
<8.5 64
26.00
25.00
22.00 730
7.50
31.00
100.00
100.00
3.75
18.00
21.00
24.00
21.00
1.25
29.00
14.00
10.00
25.00
18.00
27.00
5.50
11.00
1,300.00
439.00
240.00
              11.5
8.0
28.5
                       3.5
                                  1.60
                                                                      2.50
      Reference numbers  from Table 3-46.

-------
by transport of surface soils from the site.  Surface soils
have relatively higher concentrations of lead (Section 3.5.1).

Extraction procedure  (EP) toxicity tests (Federal Register,
Vol. 45, No. 98, May  19, 1980) performed by the USEPA (1982,
1984) revealed that sediment from Mill Creek at or below
Western Processing contained leachable metals, but at con-
centrations below permissible EP values.  Concentrations of
copper and zinc, for  which there are no published EP values,
increased up to ten times in samples at or downstream of
Western Processing.   Sediment collected upstream of Western
Processing also contained metals that were leached by the
extraction procedure.  Zinc was extracted in greater amounts
from upstream sediment than from some of the downstream
sediments in May 1982, but in much smaller amounts in Jan-
uary 1984.  Lead was  extracted in the greatest amount up-
stream of Western Processing in May 1982, but in similar
amounts at all locations in January 1984.

On the basis of available data, the contamination of sedi-
ment extends downstream past the active railroad line.  The
Metro data on total metals in water from a station below the
confluence with Springbrook Creek (see Figure 3-43 and Ta-
ble 3-51) indicate that high sediment concentrations of zinc
might extend quite far downstream.  Samples collected in
Springbrook Creek  (Table 3-57) had concentrations of metals
within the range of background values (Table 2-1).  However,
other sources of metals may exist between Western Processing
and Metro station 0317  (Plate 1).

Some sediment collected from the ditch immediately east of
Western Processing (east ditch) had relatively high concen-
trations of chromium, lead, nickel, and zinc  (Table 3-57).
It is very likely that the metals in the east ditch arrived
there by surface water and groundwater flow from Western
Processing.  Sediment from the drain between the jogging
path and the railroad (east drain) also had elevated concen-
trations of metals, but generally one to two orders of mag-
nitude lower than in  the east ditch (Table 3-57).  Yake
(1985) indicated that the east drain had contamination up-
stream of Western Processing.  However, the location of the
upstream sampling point shown by Yake near the southeast
corner of Western Processing does not preclude contamination
from the site.  Sediment samples collected further upstream
during the remedial investigations (sediment location 4 in
Plate 1) did not have elevated concentrations of metals.  It
appears most likely that the metals in the east drain arrived
there via groundwater.  Samples collected upstream of Western
Processing in the drainages leading to the east drain had
metals concentrations in the range of background values  (CH2M
HILL, December 1984).
                             3-185

-------
3.7.2.2  Organics in Sediments

Sediments from Mill Creek have been analyzed for organic
pollutants on four occasions.  The USEPA analyzed for all
organic priority pollutants in samples collected on May 20
and 21, 1982, August 1983, and January 1984.  Radian Corp.
(1984) reported the results of analyses for the volatile
organic priority pollutants from samples collected in June
1984.  Sampling locations are shown on Plate 1.

The results of analyses of sediments for organic pollutants
have been somewhat inconsistent.  In May of 1982, some chlo-
rinated phenols and the pesticide 4,4-DDE were found at low
concentrations upstream of the site.  Samples taken adjacent
to the site contained several polynuclear aromatic hydro-
carbons  (PAH's) with a total concentration of 111,435 ppb.
Several volatile organics were also found, with concentra-
tions highest for 1,1,1-trichloroethane, trans-1,2-dichloro-
ethene, and trichloroethene at 165, 160, and 150 ppb,
respectively.  PCB's were observed at a total concentration
of 690 ppb.  Numbers of compounds and their concentrations
were greatly reduced immediately downstream of the site.

In August 1983, bis-(2-ethylhexyl)phthalate was found up-
stream of Western Processing at 3,257 ppb (but noted as
detected but not quantifiable).  Acetone, toluene, and
methylene chloride were also observed in trace amounts up-
stream of Western Processing.  Adjacent to Western Process-
ing, bis-(2-ethylhexyl)phthalate was observed at 3,564 ppb
as were 12 volatile organics at concentrations ranging from
9 to 1,510 ppb.  Methylene chloride was the only organic
pollutant observed in sediment downstream of Western Pro-
cessing in August 1983.  As this compound is a common labo-
ratory contaminant, conclusions based on its presence would
be tenuous.  Acetone was used as a decontamination fluid and
could have entered the samples by accident.

In January 1984, bis-(2-ethylhexyl)phthalate was observed at
61,000 ppb upstream of Western Processing.  Several PAH's
were also found, with a total concentration of 161 ppb, and
the PCB arochlor 1254 at 36 ppb.  Only the ketone isophorone
was found adjacent to Western Processing, and the PAH phenan-
threne was found downstream; both were at very low concen-
trations.  The sampling in January 1984 was done at only
three locations, compared to five in May 1982 and six in
August 1983.

The analysis for volatile organics in samples collected in
June 1984 by Radian Corporation  (1984) resulted in the de-
tection of no pollutants upstream of or adjacent to Western
Processing, and only four compounds downstream.  Trichloro-
ethene and methylene chloride were observed at 314 and
215 ppb, respectively.  Tetrachloroethylene and 1,1,1-
trichloroethane were also found at 48 and 54 ppb,


                            3-186

-------
respectively.  Only three locations were sampled in June of
1984, and minimum limits of detection were not reported by
Radian Corp.

Contamination of Mill Creek sediments with organic compounds
attributable to Western Processing is not clearly indicated
from sediment pollutants alone.  Phthalates, some PAH's, and
DDT derivatives appear to be coming from sources upstream of
Western Processing.

During the May 1982 and August 1983 samplings, the concen-
trations of PAH's and other base/neutrals and several vola-
tile compounds increased in sediments adjacent to Western
Processing relative to upstream locations.  Areas of highest
concentrations are shown in Figures 3-35 and 3-39.  In
January and June 1984, evidence of contamination was noted
primarily upstream and downstream of Western Processing.
Sediment contaminated with organic pollutants may be moving
downstream from Western Processing, or may be distributed
very unevenly in Mill Creek near Western Processing, or
both, based on the data  (or metals) shown in Table 3-57.

Samples of groundwater from four wells near Mill Creek,
Wells 9, 10, 27, and 28  (CH2M HILL, December 1984), con-
tained three pesticides, one base/neutral (a ketone), sev-
eral acid-extractable compounds (phenols), and numerous
volatile compounds.  Notably absent were most of the base/
neutrals including the PAH's and bis-(2-ethylhexy)phthalate
(Table 3-58) .  Well No. 28 had the greatest number of com-
pounds, all at relatively low concentrations.  Wells 9, 10,
and 27 had phenolics at more than 100,000 ppb and volatiles
ranging from 21,300 to 249,500 ppb.

The distribution of maximum concentrations of organic pollu-
tants in creek water and sediments and in well water (Ta-
ble 3-58)  suggests that most of the base/neutral compounds,
including all of the PAH's, and the pesticides and PCB's
were derived from upstream of Western Processing or from
surface runoff prior to drainage control.  The acid extract-
ables and volatiles appear to be derived from groundwater
originating at Western Processing with minor contributions
from upstream.

3.7.3  CONTAMINANT MASS LOADINGS TO MILL CREEK

3.7.3.1  Metals

Metals loading to Mill Creek at Western Processing has been
calculated by the USEPA from data collected during their
vicinity surveys of May 1982 and January 1984.  Concentra-
tions of dissolved and total chromium,  copper, lead, nickel,
and zinc were multiplied by measured flows to determine
loadings.   The mass flow at an upstream station (8A) was
subtracted from the mass flow at a downstream station (1)  to
                            3-187

-------
                                          Table 3-58
              ORGANIC COMPOUNDS IN MILL CREEK WATER  AND SEDIMENTS
                 AND  IN  WATER FROM  WELLS ADJACENT  TO  MILL  CREEK
                           FROM  ALL AVAILABLE  DATA  SOURCES
                [Maximum concentrations  reported in pg/L  (water)
                                   or ug/kg  (sediment)]
Pesticides and PCB's

  Aldrln
  4,4 DDE
  4,4 DDT
  Dieldrin
  Heptachlor
  Arochlor 1254
  Arochlor 1260

Base/Neutral Extractables

(PAH Fraction)
  Acenaphthene
  Acenaphthylene
  Anthracene
  Benzo(a)anthracene
  Benzo(a)pyrene
  Benzo(X)flouranthene
  Fluoranthene
  Fluorene
  Naphthalene
  Fhenantbrane
  Pyrene

(Other Base/Neutrals)
  Bis(2-ethylhexyl)phthalate
  Dl-N-butyl phtbalate
  Di-N-octyl phthalate
  Isophorone
  Diethyl phthlate

Acid Extractables

  2-Chlorophenol
  2,4-Dichloropbenol
  2,4-Dimethylphenol
  2-Nitrophenol
  Pentachloropheno1
  Phenol
  Tetrachlorophenol
  4-Nltrophenol

Volatlles

  Carbon tetracbloride
  Benzene
  Chloroethane
  Chloroform
  1,1-Dichloroethane
  1,2-Dlchloroethane
  1,1-Dichloroethene
  Hexachloroethane
  Ethylbenzene
  Chloromethane
  Hethylenecbloride
  1,1,2,2-Tetrachloroethane
  Tetrachloroethene
  1,2-Trans-dichloroethene
  1,1,2-Trichloroethane
  Trichloroethene
  Trichloroflouromethane
  1,1,1-Trlchloroethane
  Toulene
    Upstream
   of Western
   Processing
Creek
Hater Sediments
          36
 0.1 M
          19

          56
          28
          25
61,000

 2,200
    33
          69
 1 M
          14.9 H
                At or
            Below Western
              Processing
           Creek
           Water
                                                                     In Well Water Near Mill Creek
Sediments   Well 9Well 10
                                Hell 27
                  33
                  0.14
                  6.8
                    520
                    170
                  2,300

                  8,800
                  6,000
                  1,500 Ma
                  4,000
                 29,000
                  1,800
                 29,000
                     14
 3,564
                                                             10 M
                                                             30 H
                                                             40 M
                   2.8
                   5.2
                  20
                   0.002
                            100,000
                  51
                  18
                   1 H
                   1.3

                   1 M

          28.4 M  98
            3.3
           36
           33
           44
            1 M
            8
            1 M
     2 H

    23 M
    25
    49.5
    40

    33.7 M

 1,710
     2 M
    48
   344
    12
 1,510

   165
   668
220,000


  4,600

 17,000

  5,500
  2,400
                                  Well 28

                                    3.3
                                                                       3.6
                                                                       3.29
                                   60


                                   540

180,000


18,000
5 M
910
5 M
2,300
190
1,300,000
1,500
70
1,400
880
6,700
390
20 H
20 M
100
16,000
1,400
140,000
5,200
1,600
200 H
220
4,000
50
40
5 M
12 H
110 M
7 M
70 M
14 M
5,400
90
20
840
100
180
   indicates compound was detected but not quantified at the given detection limit.
                                                3-188

-------
determine daily loading from the reach of Mill Creek passing
Western Processing  (Table 3-59).  Samples collected by WDOE
during 1984 were also reported with flow values allowing
calculations of mass flows.  WDOE data indicate additions of
dissolved metals to Mill Creek as it passes Western Process-
ing similar in magnitude to those reported by USEPA.

Table 3-60 shows the range of values calculated from each
data source.  Calculated loadings of dissolved zinc ranged
from 7.7 to 52 pounds per day.  Calculated loadings of dis-
solved copper and nickel ranged from 0.15 to 3 and 0.34 to
2.7 pounds per day, respectively.  Calculated loadings of
dissolved cadmium and chromium were 0.15 to 0.55 and 0.01 to
0.14 pounds per day, respectively.  The two sets of data are
in good agreement.  Yake (1985) calculated loadings based on
total metals from the WDOE data including WDOE flow measure-
ments.  As would be expected, the values reported by Yake
are higher than, but similar in magnitude to, those based on
dissolved metals shown in Table 3-60.  Similar calculations
by GCA Corporation  (unpublished draft report) are also in
agreement as to the general magnitude of metals loading.
GCA Corporation based their calculations on analyses of
total metals as discussed below.

A more extensive data base exists for total metals in Mill
Creek  (Tables 3-48  to 3-52).  However, measured flow data
are not available for most months.  In order to calculate
loadings to Mill Creek based on concentrations of total met-
als upstream and downstream, monthly mean and annual average
flows just downstream of Western Processing were calculated
based on nearby gaged basins.

Mean annual and monthly flows for Mill Creek at its conflu-
ence with Springbrook Creek were estimated for use in water
quality loading flux analyses.  Available flow data were
limited to instantaneous flow records.  Continuous flow
records necessary to establish average flows were not avail-
able for Mill Creek.  Therefore, flow estimates were devel-
oped from transfer  of long-term stream gage records from
adjacent drainage subbasins that have similar hydrologic
characteristics.  Table 3-61 describes the U.S. Geological
Survey streamflow gage records and basin characteristics
used in the analyses.  The calculated flows will slightly
overestimate the flows because some drainage area downstream
of Western Processing was included in the calculations.

In the absence of continuous streamflow records for Mill
Creek for correlation with those gage records, regional
regression relationships published by the U.S. Geological
Survey (Moss and Haushild, 1978) were used to transfer flows,
The regression equations relate expected peak recurrence
interval discharges for nonregulated streams with drainage
area and mean annual basin precipitation by a regression
                             3-189

-------
                                            Table  3-59
             MASS FLOWS OF METALS PAST THREE LOCATIONS  NEAR WESTERN PROCESSING
                                   Zinc
Lead
Coppery
Nickel
Chromium
Flow (cfs) /Station
January 1984 Survey
15. 51/
Station 1
13. 19/
Station 6A
11. 17/
Station 8A
May 1982 Survey
3'5/
i Station 1
i— >
o 3.37/
Station 6A
3.0/
Station 8A
Units
Ib/day
pg/L
Ib/day
pg/L
Ib/day
pg/L
Ib/day
pg/L
Ib/day
pg/L
Ib/day
pg/L
Diss.
54.3
649.0
45.3
637.0
2.3
38.0
33.6
1,780.0
32.7
1,800.0
0.3
20.0
Total
60.7
729.0
49.3
695.0
1.9
32.0
43.4
2,300.0
40.9
2,250.0
0.5
30.0
Diss.
0.3
3.0
0.1
2.0
0.1
2.0
0.08
4.0
0.2
11.0
—
Total
1.3
15.0
1.1
16.0
0.8
14.0
0.4
20.0
0.4
20.0
0.4
24.0
Diss.
3.8
46.0
3.1
44.0
0.8
14.0
—
—
—
Total
11.7
140.0
7.2
101.0
4.9
78.0
2.4
125.0
2.1
116.0
—
Diss.
5.9
71.0
4.8
67.0
3.2
53.0
.04
2.07
3.3
180.0
0.1
7.0
Total
6.8
81.0
5.3
75.0
3.4
56.0
4.9
261.0
4.7
261.0
0.2
14.0
Diss.
0.6
7.0
0.6
8.0
—
0.5
29.0
0.5
26.0
—
Total
1.7
20.0
1.3
19.0
—
0.7
36.0
0.4
24.0
—
Note:   Station 8A is upstream and Station 1 is downstream of Western  Processing.
       Station locations are shown in  Plate I.
Source:  USEPA, 1964.

-------
                          Table  3-60
       MASS  LOADINGS OF DISSOLVED METALS TO MILL CREEK
             IN THE VICINITY OF  WESTERN PROCESSING

                      Metal Loading as Pounds per Day
          Zinc
       Copper
 Cadmium
  Nickel
Lead   Chromium
USEPA   33.3-52       3          —       0-2.7   0-0.2

WDOE    7-7-41.5   0.15-1.06  0.15-0.55   0.34-3.97  0-0.19  0.01-0.14
Note:   Based on data reported by the USEPA (1984)  and WDOE (1984).
                           Table 3-61
    STREAMFLOW RECORDS USED  TO ESTIMATE MILL CREEK  FLOWS
 Station
 Number

12112600
12108500
    Station
  Description

Big Soos Creek
above hatchery
near Auburn

Newaukum
Creek near
Black Diamond
Drainage
  Area
(sg. mi.)

  66.7
  27.4
 Mean Annual
Precipitation
  (inches)

    50
    55
     Period
    of Record
    Considered

     1961-1981
     1944-1950
     1953-1981
constant  and coefficients.   Those values used  for  the Mill
Creek  analysis were for western Washington drainage basins
with a dominant winter peak.   Ratios of the regression equa-
tions  for each basin with  those for the Mill Creek basin
provided  an expected runoff discharge relationship between
each basin.  Those relationships were applied  to mean annual
and monthly flows compiled for those gaged basins  to develop
expected  mean flows for Mill Creek.  Table 3-62 summarizes
expected  mean flows for Mill Creek as derived  from the re-
ferenced  stream gage records.

The average of expected mean annual and monthly flows for
Mill Creek as derived from other basins was used in the
water  quality loading flux analyses.  Comparison of the com-
puted  mean flows with short-term records from  an additional
local  gage with similar drainage area and basin characteris-
tics confirmed the reasonableness of the resultant flows.
                              3-191

-------
In order to calculate mass flows of total metals upstream
and downstream of Western Processing, monthly average con-
centrations of metals are needed.  The data do not include
measurements of total metals upstream of Western Processing
for several months.  For those months, average concentra-
tions from all available data were used and have been in-
serted in Tables 3-48 to 3-52.  Metro station X317, located
downstream of some of the possible inputs from Western Pro-
cessing, was not included in the averages for upstream or
downstream because it is located where effects of Western
Processing are most fully observed in the creek.  Concen-
trations at that station appear to be intermediate between
those at other stations which are either upstream and clearly
unaffected by the site or are far enough downstream to be
clearly affected.
                         Table 3-62
   MILL CREEK EXPECTED MEAN ANNUAL AND MONTHLY DISCHARGES

                 Mean Flows Used To Derive Mill Creek Flows (cfs)
Period
Annual
Monthly :
January
February
March
April
May
June
July
August
September
October
November
December
From Big Soos Drain
20.7

44.8
41.8
33.4
23.9
15.5
11.4
7.3
5.7
5.8
6.5
16.5
36.6
From Newaukum Basin
20.5

40.7
35.4
29.8
23.2
16.2
13.2
8.9
7.0
7.3
8.9
21.2
35.1
Average
20.6

42.7
38.6
31.6
23.5
15.8
12.3
8.1
6.3
6.5
7.7
18.8
35.8
Mass flows were calculated by converting monthly and annual
average hydraulic flows  (Table 3-62) to liters per second,
and multiplying those values by the monthly average concen-
trations or estimated concentrations from Tables 3-48 to
3-52.  Resulting mass flows in mg/sec were converted to
pounds per day  (Table 3-63) for comparison with calculations
by USEPA and those based on the DOE data.  The values shown
in Table 3-63 are the net mass flows, i.e., mass flows down-
stream of Western Processing minus mass flows upstream of
Western Processing.  They thus estimate the loading of total
metals to Mill Creek in the vicinity of Western Processing.
Because flows may be slightly overestimated, the mass flows
of metals shown in Table 3-63 may also be slightly

                             3-192

-------
overestimated.   The mass flows of total metals (except for
copper) shown  in Table 3-63 are somewhat  higher than the
values for  dissolved metals (Table 3-60),  as  would be ex-
pected.  The negative mass flows of copper for some months
are not surprising because no effort was  made to account for
surface inflow at Western Processing or the effects that
analytical  precision may have had on the  calculated or es-
timated monthly averages.
                          Table 3-63
            MASS FLOWS OF METALS  (AS TOTAL  METALS)
             ADDED TO MILL CREEK  IN THE  VICINITY
                    OF WESTERN PROCESSING
Annual Average

Monthly:
  January
  February
  March
  April
  May
  June
  July
  August
  September
  October
  November
  December

  Average

Average treating
  negative values
  as zero
 Flow
(L/sec)

  584
                             Mass Flow of Metals Added at
                             Western Processing (Ib/day)
                          Zinc   Chromium   Copper  Nickel  Lead
88
1,209
1,093
895
665
447
348
229
178
184
218
532
1,014
131
69
70
68
101
73
41
32
25
26
46
70
         63
2.4
                2.0
                1.1
                2.0
                3.3
                2.4
                0.9
                1.0
                1.5
       1.6
0.5
         -0.2
                          0.6
9.8
        6.0
                        6.0
0.6
1.9
0.3
3.4
1.1
5.2
0.1
0.2
0
•0.7
0
•0.7
•2.2
-0.9
6.1
5.0
10.1
18.3
6.3
3.9
3.7
1.4
1.7
6.5
9.5
-1.4
3.7
-0.4
1.3
0.3
0
-0.4
0
-0.2
1.1
2.0
5.3
      0.9
                       1.1
If  the  negative values for copper  are treated as zero, the
magnitude of the mass flows of  total  metals (Table 3-63) are
in  good general agreement with  the estimated mass flows of
dissolved metals (Table 3-60).

The presence of contaminated  sediment in Mill Creek  (Tables
3-57  and 3-58)  indicates the  possibility of bedload movement
of  pollutants away from Western Processing.  Bedload trans-
port  of sediment was estimated  based  on methods presented by
Meyer-Peter and Mueller  (1948).  The  empirical formula de-
veloped by them relates bedload sediment discharge to
                              3-193

-------
critical bed shear stress for incipient transport as defined
by channel bed sediment characteristics and hydraulic rough-
ness and gradient factors.

For the Mill Creek drainage channel adjacent to Western Pro-
cessing, the following assumptions were made for estimation
of bedload sediment transport:

     o    Average hydraulic gradient slope equals
          0.0003 foot per foot

     o    Channel geometry:  bed width =15 feet
                             bed depth = 1 to 8 feet
                             side slopes = 1:1

     o    Channel bed sediment characteristics:

               Dgo = 1.0 mm, DIQ - 0.05 mm

     o    Hydraulic roughness of channel bed, n  = 0.035
                                               s

Bedload sediment transport estimates were developed for both
average annual flows and projected extreme flows associated
with a 10-year recurrence interval storm.  Based on the in-
dicated assumptions and on mean annual flow estimates for
Mill Creek as defined above, bedload transport is estimated
to average approximately two tons per day.  For the extreme
discharge event considered, bedload transport rates in ex-
cess of 30 tons per day are expected.  Bedload transport
rates would vary considerably with fluctuations in flows
since sediment transport capacity increases significantly at
higher flow volumes and velocities.

The indicated bedload transport estimates are order-of-
magnitude level with widely varying results possible.  The
results are also quite sensitive to assumed channel bed
sediment characteristics.  However, they do provide an indi-
cation of the expected level of bedload transport for eval-
uation of water quality loading flux analyses.

Bedload transport of metals was calculated (Table 3-64)
based on two tons per day of bedload transport and average
concentrations of sediment at stations R26 through 17A and
17B (Table 3-57).  Bedload transport may be about one-half
to l/150th of the suspended and dissolved load transport
estimated in Table 3-63.  Bedload transport appears to be
relatively small compared to total suspended and dissolved
transport of metals in Mill Creek.  Given the uncertainty of
the estimates of dissolved plus suspended transport, the
magnitude of bedload transport is likely to be less than the
magnitude of probable error in estimating dissolved and sus-
pended transport.
                            3-194

-------
Metals carried in solution by groundwater entering Mill  Creek
are likely to adsorb onto sediment at or near  the point  of
discharge if suitable adsorption  sites are  available.  The
available data on dissolved and total metals in Mill Creek
suggest that the immediately available adsorption sites  may
be saturated in the vicinity of Western Processing, leading
to an uneven distribution of contaminated sediment and high
concentrations of dissolved metals in the creek water.
                         Table  3-64
        AVERAGE CONCENTRATIONS  OF METALS  IN  SEDIMENT
            UPSTREAM OF AND AT  WESTERN PROCESSING
             (Stations R30-14 and R26-17 A and B)
               AND BEDLOAD TRANSPORT OF METALS
           Average Concentration
           	(mg/L)	
Bedload Transport
 (pounds per day)

Metal
Chromium
Nickel
Zinc
Cadmium
Lead
Copper

Upstream
12.60
6.20
61.00
0.49
26.00
21.00
Stations
R26-17
583
54
592
13
31
397

Upstream
0.010
0.005
0.050
0.000
0.021
0.020
Stations
R26-17
0.480
0.045
0.490
0.011
0.026
0.320
Net Gain
(Ib/day)
0.470
0.040
0.440
0.011
0.005
0.300
Mass loadings of metals attributable  solely  to  groundwater
influx were estimated by averaging  the July  through October
total mass loadings  from Table  3-63.  Cadmium and  copper
were estimated  separately based on  June  through September
loadings reported by Yake  (1985).   Creek flow during  these
months is primarily  sustained by groundwater base  flow;
therefore the dissolved groundwater component will predomi-
nate.  Seasonal variations  in groundwater influx (and thus
mass loading) also were assumed to  be small.  The  estimated
average groundwater  mass loadings in  pounds  per day are:
          Zinc =  31
          Chromium =  1.1
          Copper  = 0.50
  Nickel =2.7
  Lead =0.28
  Cadmium = 0.35
The average monthly concentrations  associated with  the  mass
loadings were calculated using  the  estimated creek  flows
from Table 3-63.  The  results are presented in  Table  3-65.
Concentrations at other flows can be  generated  using  the
ratios of new flow to  old  flow  times  the  old flow
concentrations.
                             3-195

-------
The estimated summer  copper and lead concentrations in Mill
Creek are lower than  average background groundwater
concentrations  (Table 3-5), probably because the chemical
precipitation and/or  sorption processes that tend to remove
dissolved constituents would be strong in the oxidizing  and
possibly higher pH environment of the creek.

3.7.3.2  Organics

Relatively high concentrations of volatile organics in wells
adjacent to Mill Creek and the detection of the same com-
pounds in creek water and  sediments at or downstream of
Western Processing  (Table  3-58)  indicate that organic pollu-
tants are  (or were previously)  transported via Mill Creek
sediment.  Data collected  during 1984 suggest that present
loadings are mainly volatile organics in small but unquanti-
fiable amounts.  As discussed earlier, volatile and acid
extractable organic pollutants may still be reaching the
creek in groundwater  flow.   The pesticides and base/
neutrals, which do not move readily through the soil,
probably entered the  creek with surface runoff, which is now
collected and treated prior to discharge to the Metro sewer.
                          Table 3-65
       ESTIMATED MILL  CREEK CONTAMINANT CONCENTRATIONS
          ATTRIBUTABLE TO GROUNDWATER MASS LOADING
                               Contaminant Concentrations


Month
January
February
March
April
May
June
July
August
September
October
November
December
Mill Creek
Discharge
(cfs)
43
39
32
23
16
12
8
6
6
8
19
36
                       Zn
                      (ug/L)

                      130
                      150
                      180
                      250
                      360
                      470
                      710
                      910
                      890
                      750
                      310
                      160
 Creek flows from Table 3-63.
 Cr     Cu     Ni     Pb
(yg/L)   (yg/L)   (yg/L)  (yg/L)
 4.8
 5.3
 6.5
 8.7
 13
 17
 25
 32
 31
 26
 11
 6
 2.2
 2.4
 2.9
 3.9
 5.9
 7.5
11
15
14
12
 4.9
 2.6
12
13
16
21
32
41
62
80
77
65
27
14
1.2
1.3
1.6
2.2
3.3
4.2
6.4
8.3
8.0
6.7
2.8
1.4
  Cd
(yg/L)

 1.5
 1.7
 2.1
 2.8
 4.1
 5.3
 8.0
10
10
 8.4
 3.5
 1.8
     3.8  OTHER POTENTIAL CONTAMINANT MIGRATION PATHWAYS

Several potential  contaminant migration pathways exist  at
the Western Processing  site in addition to soil,
                             3-196

-------
groundwater, and Mill Creek.  These are the surface water
drainage ways and underground utility corridors leading from
the site.  The surface water drainages are potential routes
for migrating contaminants and may also contain contaminants
that were deposited in the past.  Contaminants may migrate
down utility corridors depending on the nature of the trench
bedding material, the slope of the trench, and whether the
utilities are buried inside of conduits.  The purpose of
this section is to describe the location and type of the
utilities adjacent to the site  (Figure 3-54)  and the current
and historic surface water drainage from the site.

The City of Kent and the following companies were contacted
for information on their utilities in the area: Pacific
Northwest Bell Telephone Company, Northwest Natural Gas,
Olympic Pipe Line Company, and Puget Sound Power and Light.
The facilities that they identified are their major lines in
the area and may not include service connections, abandoned
lines, or illegal connections.  Also, the lines of other
companies who no longer operate in the area are not
identified.

The Western Processing property has been developed for a
number of different uses by different owners since the 1950's.
Because of this history, it would be difficult to inventory
all utilities on the property.  One of the most extensive
developments on the site was in the 1950's when the site was
used as an anti-aircraft battery.  Onsite utilities in place
at that time consisted of sewer, water, storm drainage, and
power.  Since the site was not demolished when it was deac-
tivated, many of these systems may remain at the site.  One
important utility extending off the property  is a 6-inch
sanitary drainfield discharge line shown in Figure 3-54.
This line was identified from old drawings of the site as it
existed in the 1950's.  This line still exists and its dis-
charge to Mill Creek has been located by the Washington State
Department of Ecology.  This line was plugged on the Western
Processing end during the recently completed site surface
cleanup.

3.8.1  UNDERGROUND UTILITIES

3.8.1.1  Power

Puget Sound Power and Light (PP&L) has two underground cables
located adjacent to the site.   They are located under South
196th Street north of the site and under 72nd Avenue South
adjacent to the south end of the site.  The cable on South
196th Street is a 12.5-kV power cable that runs underground
in an easterly direction from a pole located on the north
side of 196th Street about 50 feet west of the PP&L right-of-
way.  West of that pole, the lines are overhead.  Information
about the installation of the underground lines is not avail-
able, but typically the cable is placed in a PVC conduit in

                            3-197

-------
                    APPROXIMATE LOCATIONS OF
                    SIX WATER SERVICE LINES
                                                        14" OIL
                                                        PIPELINE
                                                       INTERURBAN
                                                       TRAIL
                                               12.5 KV
                                               POWER
                                               CABLE
            10" WATER
            LINE
                                            SOUTH 196TH ST
8" SEWER  r
LINE
         \ '    ^
TELEPHONE DUCT
   INDUSTRIAL PARK
         OLD
         SANITARY
         DRAIN FIELD
         DISCHARGE LINE
                                          WESTERN PROCESSING
                                       V/2" SEWER SERVICE
                          12" SEWER
                          LINE     \

                        10" WATER *
                        LINE
                      POWER CABLE
                      AND CONDUIT
                                                         FIGURE 3-54
                                                         UNDERGROUND UTILITIES
                                                         WESTERN PROCESSING
                                                         Kent, Washington
                                   3-198

-------
a trench with no special bedding material and the trench is
backfilled with native soil.  This underground line passes
under two sets of railroad tracks and such crossings are
normally made in steel conduit.

Underground power on 72nd Avenue South, south of the site,
consists of three 12.5-kV cables, street light wire, two
6-inch PVC conduits, and one 4-inch PVC conduit.  All of the
PVC conduits are empty and assumed capped because it is PP&L's
normal procedure to cap the conduits so that they do not
collect water.  All cables, wire, and conduit are located in
a single trench, approximately 10 feet behind the curb on
the east side of the street.  The system was installed in
late 1983 or early 1984 to serve the Corporate Properties
Investors development on 72nd Avenue South and other future
development in the area.

3.8.1.2  Sewer and Water

A 12-inch city sewerline extends toward the site in 72nd Ave-
nue South and ends at a manhole near the north end of the
street.  This line is located about one foot west of the
72nd Avenue centerline.  It flows by gravity to the south
away from the site.  A connection was made to this sewer
with a 1-1/2-inch line from the Western Processing site.  It
is not known whether this line is still in place.

An 8-inch city sewer line is located in South 196th Street
about 15 feet south of the centerline of the pavement.  This
line stops approximately 500 feet west of the Western Pro-
cessing site.

A 10-inch waterline is located in 72nd Avenue South approxi-
mately 25 feet west of the centerline.  This line is under
pressure and provides service to the Corporate Properties
Investors (CPI)  development west of 72nd Avenue South.

A 10-inch waterline is also located in South 196th Street
about 16 feet north of the centerline.  This line is under
pressure and provides service to the Western Processing site
and to other businesses and properties on South 196th Street.

All sewer and water lines are placed in trenches with pea
gravel or crushed rock as the bedding material.  The trenches
are typically backfilled with gravel.  The depth of burial
varies but is generally below the freeze level  (±4 feet in
Washington State) and above the water table (±10 feet at
Western Processing).  Sewer lines may, go deeper because
they are gravity flow and must slope downward between pump
stations.
                            3-199

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3.8.1.3  Telephone

Pacific Northwest Bell Telephone Company (PNB) has a duct
structure buried in South 196th Street adjacent to the West-
ern Processing site, approximately 13 feet south of the
centerline.  The structure extends east and west along South
196th Street at a depth of approximately 40 inches (to the
top of the structure).  Approximately 130 feet west of the
railroad tracks adjacent to the site is a telephone company
manhole structure that straddles the duct structure.   The
manhole cover is visible in the street.

The duct structure consists of twelve 4-inch PVC conduits
encased in concrete.  Eight of the conduits contain cables
and four are empty.  The cables include trunk cables, tie
cables, a Boeing Company circuit, and two fiber optics sys-
tems.  The fiber optics systems are expensive to repair if
damaged and one of the fiber optics systems is the largest
such system PNB has in the area.

The duct structure was constructed by excavating a trench
approximately 3 feet wide and 5 feet deep.   The conduits are
stacked directly in the trench  (with no gravel base)  in rows
of three, and the concrete is poured over them.  The resul-
tant duct structure is approximately 2 feet high and 15 inches
wide.  Because the cables may spread when the concrete is
poured, the structure should be assumed to be as large as
30 inches high and 24 inches wide when planning other under-
ground work in the area.

The manhole structure is precast concrete approximately
10-1/2 feet long, 5 feet wide, and 6-1/2 feet high.  It is
buried approximately 3 feet below the surface.

At this time, there are no plans to run cables in the four
empty conduits.  They are available to provide future ser-
vice as the area is developed.  They will be filled by run-
ning the cable between manholes.  Excavation will not be
necessary.

The PNB conduits are airtight and a PNB representative indi-
cated that one of the conduits in the duct structure is
experiencing air loss near the site.  At this time, it is
not affecting the operation of the cable and no water has
entered the conduit.

3.8.1.4  Oil

The Olympic Pipeline Company has a 14-inch-diameter pipe
located approximately 5 feet east of the fence along the
eastern boundary of the Western Processing site.  The pipe-
line was placed in a trench and backfilled with native soil.
The company does not keep records of the depth of the
pipeline.

                            3-200

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The pipe is solid steel with welded joints, coated with cold
tar enamel and wrapped with asbestos felt and fiberglass.
Corrosion control is provided by d.c. voltage.  The pipe
carries a variety of refined petroleum products such as
diesel oil, gasoline, kerosene, and plane fuel.  The pipe-
line is under approximately 1,440-psi pressure.

At this time, Olympic Pipeline Company does not plan to exca-
vate their line to check it or work on it.  About one to two
years ago, they checked the coating on the line.  Because it
was in good condition at that time, they assume corrosion
agents are not reaching the steel pipe and it is still in
good condition.

3.8.1.5  Natural Gas

Washington Natural Gas Company has a 4-inch wrapped steel
gas pipeline in South 196th Street adjacent to the Western
Processing site.  The pipe lies 14 feet north of the center-
line at a depth of approximately 3 feet.  Typically, the gas
company lines are excavated only to add service connections
or to repair them or replace them.  The gas company does not
anticipate excavating the line in South 196th for any of
these reasons.

3.8.2  POTENTIAL PATHWAYS

3.8.2.1  Utilities

The utilities described above may act as contaminant migra-
tion pathways.  Contaminated water could infiltrate existing
lines or enter broken conduit.  The slope of the utilities
could influence the direction and speed with which contami-
nants could be spread from the site, and the nature of the
trench bedding material could increase the permeability of
the utility corridor as compared to the surrounding soil.

One serious concern is that there is a potential for cross
contamination between contaminated groundwater and the 10-inch
potable drinking water supply existing on South 196th Street.
There are at least six service water connections to the
10-inch waterline within a distance of 400 feet east of the
main entrance to Western Processing  (see Figure 3-54).
These lines are still in place.  The water to all but
Western Processing is believed turned off.  The connections
serve the following addresses:

     o    South side of 196th Street:

          7113 South 196th (residence; water turned off in
          January 1983)

          Western Processing  (near main gate; water turned
          off July 1983, turned on May 1984)


                            3-201

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     o    North side of 196th Street:

          7130 South 196th (residence; water turned off
          August 1984)

          7124 South 196th (residence and business; water
          turned off July 1983)

          7122 south 196th (residence demolished; water
          turned off October 1972)

          7116 South 196th (residence demolished;, water
          turned off January 1979)

Other service connections also exist farther east along
South 196th Street.

The City of Kent began requesting the installation of back-
flow preventers on service connections in 1975.  The con-
nections near the site are believed to have been made prior
to 1975 and are not expected to be supplied with backflow
preventers.  Reverse flow could occur if the isolation valves
leak and if pressure were lost on the line due to unusually
heavy demand or a break.

Two other potential contaminant pathways are the utility
corridors in south 196th Street and in 72nd Avenue.  In 72nd
Avenue, the power cable conduits could act as transmission
routes, especially if they are broken or are not capped.
Where the conduit is sloped, water may also travel along the
outside of the conduit.  In general, however, the power cables
and the water line follow the topography, which is relatively
level near the site.  The sewer line in 72nd Avenue flows by
gravity to the south and may act as a transmission route for
water flowing along the outside of the lines.  The trench
bedding material for the sewer and water lines in 72nd is
pea gravel and the backfill material is gravel.  This mate-
rial will tend to act as a potential pathway for ground-
water, especially along the sewer line which is sloped to
the south.  The 1-1/2-inch sewer line leading from the site
to 72nd Avenue also represents a pathway for contaminants to
leave the site.  It is not known whether this line is still
in place.

Another potential contaminant pathway is along South 196th
Street.  The conduit for the underground power cable in 196th
Street near the northeast corner of the site could act as a
transmission route in a manner similar to the conduit in
72nd Avenue.  The conduit in 196th is generally level, fol-
lowing the natural topography.  However, it may slope down
to go under the railroad and therefore could transmit con-
taminants away from the site to the point east of the rail-
road where the conduit begins to slope upward.  The water
line corridor is not expected to be a significant pathway

                            3-202

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except  as  previously mentioned  regarding  cross  connections
because the  line  is under  pressure  and  therefore  is not
sloped.  it  is, however, in  a trench with a  crushed rock bed
and gravel backfill which  may tend  to collect water.  The
PNB conduits  in South  196th  are  set in  concrete in a gener-
ally  level trench.  These  conduits  are  not expected to act
as a  pathway.

The other  potential pathways are  the oil  pipeline extending
north-south  adjacent to the  site  and the  sanitary drain to
Mill  Creek.   The  oil pipeline is  level  and the  trench does
not contain  non-native materials.   It is  therefore not
expected to  act as a significant  pathway  for contaminant
transmission.  The presence  of  the  sanitary drain line to
Mill  Creek installed during  the  1950?s  when the site was a
military base has been verified.  Until recently, this line
was open and  could have been used for discharges.  Based on
a review of Army  Corps drawings,  this line was  installed
with  open  joints  to promote  exfiltration  of the treated sew-
age into the  soils prior to  discharge to  Mill Creek.  Contam-
inated  soils  found in the  area around this pipe may be the
result  of  discharges from  Western Processing through this
line.   Contaminants may also have been  transported to Mill
Creek through this line or by natural flushing of the
locally contaminated soils.  The Western  Processing end of
the pipe was uncovered during recent grading operations and
is now  plugged.

3.8.2.2  Surface Water

Surface water drainage patterns represent potential pathways
by which contaminants may  have been transported from the
site.   These also represent  areas where contaminated surface
water may  have collected and been absorbed by the soils.
Figure  3-55 shows historic surface water  drainage patterns.
The main areas where surface water  has  collected over the
years are  the low, wet areas onsite and north and south of
the site.  The channels for  drainage have changed over the
years, primarily because of  filling and the construction of
dikes.  The site owner filled the two drainage paths that
traversed  the southern portion of the site.  Recently, sur-
face runoff from the site  has drained to  a ditch along the
east side  of the site and  to Mill Creek on the west side of
the site.  The flows that  used to traverse the site are now
diverted down the east drain between the  railroad and the
jogging path.

   3.9  SUMMARY OF THE NATURE AND EXTENT  OF CONTAMINATION

Organic and inorganic contamination has been quantified in
soil, groundwater, and surface water at the Western Processing
site.  The nature and extent of contamination have been devel-
oped using priority pollutant metals,  volatile organics,  semi-
volatile organics, pesticides, PCB's,  and oxazolidone.  A

                             3-203

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NOTE: All information on this figure
      was obtained from aerial photos
      of the site taken in:  1960,1961,
      1964,1967,1968,1970,1974,
      1976,1977,1978,1981, and
      1983. The dates on this figure
      indicate the photos on which the
      features were noted. Those
      features not dated have been
      ongoing for several years.
INTERURBAN
TRAIL -
                                                               RAILROAD
Surface Drainage
Surface Water
Collection Areas
                                          FIGURE 3-55
                                          HISTORIC SURFACE WATER
                                          DRAINAGE AND COLLECTION AREAS
                                          WESTERN PROCESSING
                                          Kent, Washington
                         3-204

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summary of the most important issues is presented in the
following sections.

3.9.1  SOILS CONTAMINATION

     o    Onsite soils contained the most contaminants.
          These included metals, volatile organics, PAH's,
          phthalates, PCB's, and oxazolidone to a depth of
          generally 20 feet or less.  Most contamination was
          found in soils at 10 feet or less.  Figures 3-56
          through 3-60 show the extent of soil contamination
          at depths less than 10 feet for indicator metals,
          volatiles, acid extractables, total PAH compounds,
          and total phthalates.  Metals were distributed
          throughout the site but had their highest concen-
          trations on the southern half.  Volatiles were
          fairly uniform across the entire site.  Acid extrac-
          tables were highest in the central sections of the
          site.  Total PAH's and phthalates were measured in
          their highest concentrations in surface soils or
          near-surface soils in the central and southern
          portions of the site.

     o    Contaminants in offsite soils were highest in
          Areas II, V, VI, and IX.  In most cases, contami-
          nants detected in Areas II, V, and IX can be attri-
          buted to Western Processing as a source.  PCB's
          and high volatiles near the surface in Area VI
          suggest that this is an additional source of con-
          tamination not related to Western Processing.  The
          presence of Mill Creek between Area I and Area VI
          and the lack of potential migration pathways from
          Western Processing to Area VI further reinforce
          this conclusion.

3.9.2  GROUNDWATER FLOW AND CONTAMINATION

     o    The Kent Valley is a regional groundwater discharge
          area.  Groundwater flows in a north-northwesterly
          direction to the Green River.

     o    Groundwater flow patterns near Western Processing
          are complex because of stratigraphy and local shal-
          low groundwater discharge to Mill Creek and the
          east drain.  Mill Creek influences groundwater
          flow to a depth of 50 to 60 feet.

     o    Ponded surface water, higher precipitation infil-
          tration, and/or variations in soil hydraulic conduc-
          tivity have induced the formation of  a groundwater
          mound near the center of the site in  excess of
          what would normally occur between two groundwater
          discharges such as Mill Creek and the east drain.
                             3-205

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Local groundwater flow is primarily east and west
with some flow to the north and south.

Groundwater flow beneath the site has a strong
downward component to varying depths where flow
turns horizontal or upward.  This reversed primary
flow direction results from the influence of Mill
Creek and the regional groundwater flow pattern.
Data suggest that at depths of about 50 to 60 feet
beneath the site horizontal flow predominates.
Above this level, flow to Mill Creek predominates.

The extent of indicator metal contamination in
groundwater is shown on Figure 3-61.  Metals in
groundwater were most pronounced in shallow onsite
wells but were also detected in similar concentra-
tions in near off-property shallow wells to the
west (27 and 28) and several onsite intermediate
depth wells.  Total indicator metals often exceeded
100,000 yg/L in these wells.  Metals in ground-
water were highest in the northern half of the
site.  Zinc and nickel were detected in the high-
est concentrations.

The extent of organic priority pollutant contamina-
tion in groundwater is shown in Figure 3-62.  Or-
ganic contamination in groundwater consisted mostly
of volatiles and acid extractables.  These compound
classes were most concentrated in shallow wells
located in the north half of the site.  Concentra-
tions of total volatiles and acid extractables
often exceeded 100,000 yg/L in these wells.

Several shallow wells had volatile contaminants in
concentrations greatly exceeding those found else-
where.   Methylene chloride contamination was highest
in Wells 15 and 9.  Trichloroethene predominated
in Wells 15, 21, US, and 17S.  Wells 15 and US
contained the most 1,1,1-trichloroethane.  Trans-
1,2-dichloroethene was localized around Well 21.
These wells may represent potential migration
source areas of volatile organics.

Contaminants in wells west of Mill Creek cannot be
conclusively linked to migration from Western
Processing.

Volatiles in Well 32S east of the site indicate
contaminant migration at least to this location.
The Well 32S volatiles match those found in onsite
borings. This fact, coupled with shallow ground-
water flow, indicates that Western Processing is
the source of volatiles in Well 32S.
                   3-206

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            OLD SANITARY
            DISCHARGE LINE
= 1 — 1.000 mg/kg

= 1,000 - 10.000 mg/kg

- > 10.000 mg/kg
                                  FIGURE 3-56
                                  SUMMARY OF NATURE AND EXTENT
                    3-207        INDICATOR METALS IN SOILS
                                  0 TO 9 FEET BELOW GROUND SURFACE

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= 1 — 1.

= 1000 — 10.000/ug/kg
                     3-208
                            FIGURE 3-57
                            SUMMARY OF NATURE AND EXTENT
                            INDICATOR VOLATILES IN SOILS 0 TO 9 FEET
                            BELOW GROUND SURFACE

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            OLD SANITARY
           DISCHARGE LINE
1 — 1,000 pg/kg

1.000 — 10,000 pg/ kg

> lO.OOO^ig/kg
                      3-209
                               FIGURE 3-58
                               SUMMARY OF NATURE AND EXTENT
                               INDICATOR ACID EXTRACTABLES IN SOILS
                               0 TO 9 FEET BELOW GROUND SURFACE

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= 0 — 1,000/ug/kg

= 1.000-10.000 ug/kg

- 10,000 — 100.000 /ug/kg

 100.000 — 1.000.000 jug/kg

= > 1.000.000 /ug/kg
                                    FIGURE 3-59
                                    SUMMARY OF NATURE AND EXTENT
                       3-210      TOTAL PAH COMPOUNDS IN SOILS
                                    0 TO 9 FEET BELOW GROUND SURFACE

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                                                 INTEHURBAN TRAIL
                               VACANT HOUSES
INDUSTRIAL PARK
                     OLD SANITARY
                    DISCHARGE LINE
      = 0 — 1,000/jg/kg

      = 1.000— 10.000/ug/kg

       10.000 — 100.000 /ug/kg

      = 100,000 — 1.000,000 wg/kg
                                          FIGURE 3-60
                               .  .. .     SUMMARY OF NATURE AND EXTENT
                                - ^ 11     TOTAL PHTHALATES IN SOILS 0 TO 9 FEET
                                          BELOW GROUND SURFACE

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U)
 I
to
M
N)
                          SHALLOW WELLS
                            (0 to 25 feet)
                                                                                                                             Map
                     'l/lllllli = Background to 1,000 /ug/L
                          = > 1,000 yug/L

                        27 = Wall Number

                        O = Well where indicator metals
                           were not detected

                        • = Well where indicator metals
                           were detected
NOTE: Shaded area means that one or more
      indicator metals were measured at
      concentrations within the given range.
FIGURE 3-61
SUMMARY OF NATURE AND EXTENT
INDICATOR METALS IN GROUNDWATER

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U)
 I
NJ
M
U>
                        SHALLOW WELLS
                          (0 to 25 feet)
                                                                                                                            Map
                   'Ill/Ill/, = Quantified level
                          to 1,000 /ug/L
                   v\\\\> = >1,000,ug/L
                      27 = Well Number
                      O = Well where indicator organics
                          were not detected
                      % = Well where indicator organics
                          were detected
NOTE: Shaded area means that one or more
       organic priority pollutants were detected
       at concentrations within the given range.
FIGURE 3-62
SUMMARY OF NATURE AND EXTENT
ORGANIC PRIORITY POLLUTANTS
IN GROUNDWATER

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3.9.3  MILL CREEK
          For several priority pollutant metals, substantial
          dissolved and suspended concentration increases
          (i.e., 3 to 300 times upstream levels) have been
          measured in Mill Creek along the Western Processing
          stream reach.

          Priority pollutant metals appear to be present in
          Mill Creek sediments in leachable form.

          Contamination of Mill Creek water and sediment
          with organic priority pollutants appears to have
          diminished following surface remedial actions.

          Of the organic contaminants observed in  Mill Creek,
          the volatile compounds appear to be more likely
          from the Western Processing reach than upstream
          sources, while the base/neutral extractables appear
          to be more likely from upstream sources  than from
          Western Processing.

          Contaminated groundwater appears to be the primary
          route of transport of metals and volatile organics
          to Mill Creek.
                            3-214

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