UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 SIXTH AVENUE
SEATTLE, WASHINGTON
RECORD OF DECISION,
DECISION SUMMARY AND
RESPONSIVENESS SUMMARY
FOR
FINAL REMEDIAL ACTION
COMMENCEMENT BAY - NEARSHORE/TIDEFLATS
TACOMA TAR PITS SITE
TACOMA, WASHINGTON
DECEMBER 1987
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
FINAL REMEDIAL ACTION
COMMENCEMENT BAY - NEARSHORE/TIDEFLATS
TACOMA TAR PITS
TACOMA, WASHINGTON
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site •—
Commencement Bay - Nearshore/Tldeflats, Tacoma Historical Coal
Gasification site: Commonly known as Tacoma Tar Pits Site - Tacoma, Pierce
County, Washington
Purpose
This decision document presents the selected final remedial action for
the site, developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and consistent
with (where not precl.ded by SARA) the National Contingency Plan (NCP, 40 CFR
jt-
Part 300). The State of Washington has been consulted and has verbally
concurred with the selected remedy. Formal concurrence of the state is
expected shortly after this decision document .is signed.
Basis for Decision
The decision is based upon the administrative record for the site, as
obtained from the files of the U.S. Environmental Protection Agency (EPA) and
the Washington State Department of Ecology. This record includes, but is not
limited to, the following documents:
Remedial Investigation Report for the Tacoma Tar Pits, Tacoma, Washington
(September 1987)
Feasibility Study of the Tacoma Historical Coal Gasification Site, Final
Report (October 1987)
Risk Assessment of the Tacoma Historical Coal Gasification Site - Final
Report (July 1987)
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Decision Summary of Remedial Alternative Selection (attached)
0 Responsiveness Summary (attached as Appendix II)
0 A complete list of documents contai-ned In the Administrative Record is
Included as Appendix I
9 Staff summaries and documents
Description
This record of decision addresses source control of on-site contamination
through excavation of contaminated soils and stabilization of these
contaminated soils 1n a polymer/cement matrix. The stabilized matrix will be
capped to reduce surface-water infiltration. Management of migration is
addressed by diversion of surface-water runoff. On-site shallow groundwater
contains detectable concentrations of contaminants. However, because
contamination has not been detected off-site and as the remedial action is
expected to prevent further contamination, groundwater extraction and
treatment is not considered as appropriate at this time. Should monitoring
indicate contamination migration, further treatment may be necessary, to
address the shallow groundwater.
The remedial action is designed to:
0 Excavate and treat all contaminated soils considered to be Extremely
Hazardous Wastes (EHW) defined for this site as exceeding 1 percent tot a
polynuclear aromatic hydrocarbon;
* Excavate and treat (stabi1ize)^a11 surface soils (<3 feet) containing
contaminants that exceed a 10~5 lifetime cancer risk level;
0 Reduce surface water infiltration and potential human exposure to
stabilized soils by capping the stabilized matrix with asphalt;
Reduce surface water transport of contaminants by channeling and managing
surface waters; and
* Provide for continued groundwater monitoring to evaluate the
effectiveness of the remedial action and the need for groundwater
extraction and treatment;
Remove and treat oonded water to achieve cleanup goals.
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Treatment will be sufficient to reduce contaminant levels in the soils,
and surface waters to or below cleanup standards. Numeric values for these
cleanup standards and the criteria used in performance standard development
are presented in Table 1. Treatment should be permanent, and should
effectively reduce the toxicity and mobility of the contaminants. Performance
levels are not to be exceeded during the operational life of the remedial
action.
Although Table 1 contains cleanup standards for groundwater the remedial
action does not currently provide for groundwater extraction and treatment.
Source control measures are expected to reduce contaminant concentrations in
the local groundwater system. Ground water monitoring performed during
implementation and following the remedial action will aid in determining the
effectiveness of the remedial action. If cleanup levels are not achieved at
the site boundary in the aquifers within a reasonable period of time following
completion of the remedial action, an alternative remedial action will be
evaluated and implemented which may include groundwater extraction.
Continued monitoring of surface waters will also be performed to ensure
cleanup levels are met during and following implementation of the remedial
action. Treated water discharge shall at all times be of quality consistent
with U.S. and Washington State laws.
Institutional controls such as deed restrictions to prohibit excavation
or drilling will be developed, consistent with the final design, to ensure
that the remedial action will continue to protect human health and the
environment.
In compliance with SARA the effectiveness and performance of this final
remedial action will be ^eassessed at regular intervals, not to exceed 5 years.
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Table 1. Cleanup Goal Performance Standards
Maximum Allowable Contaminant Concentrations
Tacoma Tar Pits Site
Groundwater (sand
mtamlnant or
mtaminant Class
Lead
Benzene
KB,
mm,
Soils
(mg/kg)
166(2)
56(3)
1.0(3)
n(3)
Surface Water,
Boundary (ug/1)
32(4)
53(5)
Q2(4)
c ™<6>
Surface Water
On-Slte (ug/1)
172(7)
5,300(7)
2(7)
om<7>
and fill aquifers)
(ug/1)
50(8)
53(5)
02(4)
c ,.(6)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
Included are benzo(a)pyrene, bcnzo(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, dibenzo(a,h)anthracene, and Indenod,2,3-c,d)pyrene.
Acceptable dose.
10~6 Risk Level.
Chronic freshwater ambient water quality criterion. Performance based on detection limit.
Acute freshwater ambient water quality criterion x 1/100.
Estimated range of chronic freshwater ambient water quality criterion based on marine
criteria.
Estimated acute freshwater ambient water quality criterion.
•f
Drinking Water MCL.
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Declaration
Consistent with CERCLA, as amended by SARA, and the NCP, it is determined
that the selected remedy as described above is protective of human health and
the environment, attains Federal and State requirements which are applicable
or relevant and appropriate, and is cost-effective. This remedy satisfies the
preference expressed in SARA for treatment that reduces toxicity, mobility,
and volume. Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
Date Regionarl Administrator
Environmental Protection Agenty
EPA - Region 10
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DECISION SUMMARY
REMEDIAL ALTERNATIVE SELECTION
FINAL REMEDIAL ACTION
TACOMA TAR PITS
TACOMA, WASHINGTON
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TABLE OF CONTENTS
I INTRODUCTION 1
II SITE DESCRIPTION AND LOCATION 3
III SITE HISTORY 5
A. Site Operations/Disposal History 5
B. Regulatory History - Previous Investigations 6
C. The Remedial Investigation 7
D. The Risk Assessment 16
IV ENFORCEMENT 19
V COMMUNITY RELATIONS 20
VI ALTERNATIVES EVALUATION - FEASIBILITY STUDY 25
VII SELECTED REMEDIAL ALTERNATIVE (No. 13) 30
A. Description of the Selected Remedy 30
B. Statutory Determinations 34
APPENDIX
I. INDEX TO ADMINISTRATIVE RECORD
II. RESPONSIVENESS SUMMARY
III. APPLICABLE AND APPROPRIATE REQUIREMENTS
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LIST OF TABLES
Table 1 Pathway Specific MASC Values
Table 2 Cleanup Goal - Performance Standards
Table 3 Summary of Remedial Alternatives
Table 4 Detailed Evaluation Criteria
Table 5 Summary of Detailed Evaluation
LIST OF FIGURES
Plate 1 Site Location Map
Plate 2 Distribution of Coal Gasification Wastes
Plate 3 Subsurface Lithology and Tar Occurrence
Plate 4 Total PCB Distribution in Surface Soils and Tars
Plate 5 Lead Distribution in Surface Soils and Tars
Plate 6 Total PAH Concentrations in Fill Aquifer
Plate 7 Total PAH Concentrations in Sand Aquifer
Plate 8 Approximate Extent of Remediation
111
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I INTRODUCTION
The Tacoma Tar Pits site is part of the Commencement Bay -
Nearshore/TTcfeflats Superfund site located within the Tacoma Tideflats
industrial area near Commencement Bay. A coal gasification plant was in
operation on site from 1924 through 1956. A metal recycling facility has been
operating on the site from 1967 to the present. Preliminary investigations
were conducted at this site between 1981 and 1983 to determine if contaminants
were present on site at levels that were a potential threat to human health
and the environment.
As a result of the preliminary investigations and the detection of a
variety of contaminants in both soils and water, the U.S. Environmental
Protection Agency (EPA) identified the need for further investigations
performed according to guidelines established by the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as
amended in 1986 by the Superfund Amendment and Reauthorization Act (SARA).
The purpose of this Decision Summary is to summarize:
The nature and extent of contamination
The pathways of contaminant migration
Rates of contaminant transport
Risk, associated with potential on-site and off-site exposures
The method for establishing site cleanup standards
The method of remedial alternative development
The methodology for evaluation of remedial alternatives
The results of :he detailed evaluation of alternatives
The preferred ^emeaial alternative
The enforcement status of the site
The opinions ana -.: issuance of the preferred alternative by the
community.
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The Decision Summary Is designed to present technical Information needed
to support the Record of Decision.
Several companies have either previously owned land at the site or
currently own or operate on land at the site. Collectively these companies
are termed Potentially Responsible Parties (PRP). With guidance and oversight
by the EPA and Washington State Department of Ecology (Ecology), several PRPs
have undertaken and completed a Remedial Investigation (RI), a Risk Assessment
(RA), and a Feasibility Study (FS) for the Tacoma Tar Pits site. EPA and
Ecology have found these documents to be acceptable although EPA has prepared
an addendum for each document addressing Issues that the studies have
inadequately or Incompletely addressed.
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II SITE DESCRIPTION AND LOCATION
The Tacoma Tar Pits site covers an area of approximately 30 acres within
the Commencement Bay - Nearshore/Tideflats site, an area of approximately
9 square miles which includes Commencement Bay, seven urban waterways,
shoreline areas along the southeast side of Commencement Bay, and the Puyallup
River delta. The site lies between the river and the City and Wheeler-Osgood
Waterways. As shown in Figure 1, the site is bordered by Portland Avenue and
St. Paul Avenue on the north, by East River Road on the east, by East 15th
•Street on the west, and by Burlington Northern Railroad tracks to the south.
A variety, of industries are located on or adjacent to the site. The study
area currently contains a metal recycling facility (Joseph Simon and Sons), a
natural gas transfer station (Washington Natural Gas), a rail freight loading
yard (Union Pacific Railroad), a meat packing plant (Hygrade Food Products),
and a railroad switching yard (Burlington Northern Railroad).
The .site currently contains two ponds, a small tar pit, and various
surface-water drainage ditches. The metal recycling facility contains
stockpiles of scrap metal and shredded car interiors. The area is generally
flat with local variations in relief of 2 to 5 feet. The present topography
has resulted from modif::ations to the land surface by dredging, filling, and
grading activities. Ground elevations generally range from +8 to +12 feet
(Mean Sea Level), with highci elevations resulting from stockpiles of shreddet
car interiors and scrap metal.
The study area is located near several major surface water bodies
including the City and Wheeler-Osgood waterways, the Puyallup River, and
Commencement Bay. Although none of these water bodies are used for water
supply, the bay and river do support extensive fish and shellfish
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1180
Commencement
Site Location Mac
"acorna ~ar =".
"accrna.
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populations. Several portions of Commencement Bay have been Identified as
being severely contaminated, resulting in adverse biological effects.
In addition to concerns on the site's Impact on surface water quality,
contamination of the local groundwater resource is also of concern. Many
local industries use groundwater from on-site wells in spite of the fact that
potable water from the City of Tacoma is available. Most of these wells are
screened at depths of greater than 400 feet. No water supply wells were
identified in the uppermost aquifers investigated by the RI and no domestic
water supply wells are located in the immediate vicinity of the site.
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Ill SITE HISTORY
A. Site Operations/Disposal History
In 1924 a coal gasification plant was constructed on the site. The plant
was also sold In 1924 and continued to operate until 1926 when the property
was sold again to Washington Gas and Electric Company. Waste materials from
the coal gasification process were disposed of on site. These materials
Included coal tar liquors, coal ash, and coal tars. These substances by
definition contain a wide variety of organic compounds and heavy metals. Many
of these organic compounds are toxic and several are considered to be
carcinogenic. These compounds include aromatic hydrocarbons (i.e., benzene,
toluene), polynuclear aromatic hydrocarbons collectively known as PAH's (i.e.,
naphthalene, benzo(a)pyrene), as well as numerous other classes of
hydrocarbons and cyanide. Heavy metals which are relatively common in such
waste streams include arsenic, mercury, and lead.
In 1956, the plant's production of coal gas was terminated due to the
availability of natural gas. At this time, Washington Gas and Electric
Company merged with Seattle Gas Company to form Washington Natural Gas
Company, a distributor of natural gas. Although coal gas production ceased,
the plant remained intact until 1965. At that time, dismantling of the plant
began. Demolition was completed by 1966. Most metal structures were /amoved
from the site; however, all demolition debris and below grade structures were
left in place. Such structures included tanks and pipelines containing tars.
In 1967, a metal recycling company (Joseph Simon and Sons) began
operation at the site. A small portion of the property (0.3 acres) was
retained by Washington Natural Gas Company. Fill material consisting of scrap
5 of 36
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iron, car bodies, soil, and shredded car Interiors were used to fill the
western and southern portions of the site. This facility recycled a variety
of metals largely from automobiles and transformers. Automobiles were
disassembled and materials sorted and processed. The recycling of automobile
batteries Introduced both acid and the heavy metal lead to the soil. Prior to
scrapping, transformers were drained of their oil. During the time period in
question, these oils typically contained polychlorinated biphenyls (PCBs).
The Hygrade property originally was owned and operated by Carstens
Packing. Little has been changed since the original construction of the
Carstens Packing complex in the early 1900's. Hygrade purchased the plant and
property from Carstens Packing in 1979. In about 1965, the eastern half of
the Union Pacific Railroad property was filled, a freight house constructed,
and the surrounding area ^aved.
The area east of East River Street remained undeveloped until after
1970. The area has been filled and leveled for possible warehouse
construction..
B. Regulatory History - Previous Investigations
In 1981, EPA analyzed aerial photographs of the site as part of their
evaluation of the Commencement Bay tidal flats area and found evidence of a
pond that potentially contained waste materials. In 1981, the Washington
State Department of Ecology (Ecology) conducted an inspection of the Joseph
Simon and Sons property, noting runoff contained a considerable amount of oily
material. A tar sample *as collected from the tar pit and was found to
contain 4 percent PAHs ira 240 ug/1 phenol.
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In 1982, the EPA Field Investigation Team (FIT) conducted a perimeter
Inspection of the site, and the results were used together with historical
1nformat1ofTTo complete a EPA Potential Hazardous Waste Site Preliminary
Assessment. This assessment concluded a potential hazard to the environment
existed due to the presence of oils, grease, phenols, PAHs, heavy metals, and
unknown chemicals.
Following the FIT investigation, the EPA requested that the property
owners conduct a preliminary investigation to assess the severity of
contamination. This study consisted of a data review, a hydrogeologic
Investigation, and the collection and analysis of soils, surface waters,
groundwaters, and tars. The report from this study was issued in May 1983.
In addition to contaminants derived from the coal gasification process, lead
and PCBs were detected.
In September 1983, another site inspection was performed by EPA and
Ecology and in the same year, the EPA issued a final report entitled, "Tacoma
Tar Pit Scope of Work.," which contained investigative work elements necessary
to complete a RI. In 1984, the EPA prepared a Final Work Plan and in
September 1984, initiated RI activities. Shortly after the EPA investigation
was initiated, agreement was reached with several PRPs and a Consent Order was
signed allowing these D9Ps to conduct the RI/FS. The PRP investigations
commenced in November '984.
C. The Remedial Investigation
The purpose of the 31 was to determine the types of waste materials that
were present on site, -~e composition of these wastes, the extent to which
waste materials were r;t-:buted over the site, and the extent of migration of
toxic compounds from ---e v^ste materials. In addition to defining the nature
7 of 36
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and extent of contamination, the RI was designed to characterize site geology
and hydrology to evaluate mechanisms and rates by which toxic compounds may be
transported-£)=om the site to potential receptors. The RI also examined the
potential for airborne transport of site contaminants. The RI was performed
1n several phases with Intermediate reports reviewed by EPA and Ecology. The
final RI document was submitted to the EPA In September 1987. EPA and Ecology
have prepared an addendum to this report to identify and discuss issues that
were not fully addressed or investigated by the RI.
1. Site Contaminants
Based on the results of previous investigations, a variety of waste
materials were anticipated to be present on-s1te. These materials included:
Organic compounds derived from coal tar including PAHs, volatile
organics, aliphatic hydrocarbons, cyanide, sulfite, phenols, and
heterocyclic compounds of sulfur, oxygen, and nitrogen.
p
Ash from coal carbonization
Coal residue
Shredded car interiors containing metal, oil, grease, plastics, and
synthetics fibers
Animal fat or animal byproducts
Heavy metals
PCBs
Pesticides, herbicides, and rodentlcides.
To maximize the efficiency of the RI, the investigation was divided into
ten subtasks comprised of:
Project management
Research of available records
Site features investigation
Hazardous waste investigation
Hydrogeologic investigation
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Surface-water Investigation
A1r quality Investigation
Biota Investigation
Bench and pilot tests
Public health and environmental concerns
No bench or pilot studies have been performed to date, these being left
until the Remedial Design is commenced, and the final task was redirected to
evaluate contaminant transport pathways. With these exceptions, the RI was
executed in its entirety.
2. Soil
The RI Included the drilling of 32 soil borings, excavation of 13 backhoe
pits, and analysis of soil samples for a variety of toxic contaminants.
Organic compounds and other tar-related contaminants were found in soils at
locations known to contain coal gasification wastes. In most locations i-where
organic contaminants were detected, there existed physical evidence (i.e.,
staining, odor) of tar materials.
Coal Gasification Hastes
Coal tar and other coal gasification wastes are known to be present in
three site locations: the tar pit, the North and South Ponds, and in an area.
of tar boils. Coal tar most likely occurs in a thin layer within these
historic waste emplacements. Coal tar in the ponds is 1 to 3 feet thick and
is approximately 2 feet thick beneath the tar pit. The total estimated volume
of tar is 5000 yd3.
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Tar and soil contaminated with tar are widely distributed over the site
as a result of coal gasification plant operations. Figure 2 shows the
principal areas of waste discharge. These areas Include:
The plant property - possible spills and waste
Areas receiving overland flow
Areas where wastes and wastewaters were ponded
Areas receiving runoff from ponds.
Surface areas of tar contamination are confined to the three areas listed
above. The vertical extent of a relatively "pure" tar is estimated to be on
the order of several feet. However, during the soil investigation, evidence
of tar contamination-was observed at greater depths. The vertical migration
of tar appears to have been affected by gravitational pull as black oily
layers were observed _jst above silty layers. The deepest penetration of tar
was observed at a location adjacent to the ponds where a slight tar odor^was
detected at a depth of 50 feet. Figure 3 shoWs cross sections of the site
with the location of this soil boring (18). The location of the cross
sections can be found on Figure 1.
The presence of tar at depth is in part a function of the underlying
stratigraphy. In locations where less permeable confining zones (aquitards)
are present, evidence of tar at depth is not found. At the borehole 18
location, this upper aquitard appears to be very thin or absent. A lower
aquitard between the sand aquifer and the lower aquifer also appears absent at
this location.
10 of 36
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I I 'I III'
fy.
CO
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V.
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I r* | ttMii}*Mt.,«m«i MoriiiuilrtQ S|il««(« Iftlioifttoiy.
las vcqit* lUttil MAicn tl.tftO fmmm No. • 44
IAMO 8 iUnn •>•.( 15 (AMD BlOlOl
Figure 2 - Distribution of
Coal Gasification Wastes
-------
(•II MC»
••IT
OLD FILL
SAND
••14
o'
20
V 01 )
-VOUNO
-20
I I <,t Nil
II 1. I..V U - >(. •»! '...I, J
I 41 l«i >J.«t. L .1 <.il ..!.«
1 .i, J..J fj, *
Mo.litlall lu til oily ftnj ull>l..l
C0»l >•' bJ0' ">U «>J»l>«»t.l
IO (llOiig NAMl Cunl« «ll mg.t.l.J U>I>IX (II^/KU I
Mil
MOI(:
i.) •wt.i.utii «««, I-MIO 10.
Figure 3 - Subsurface
Llthology and Tar Occurence
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PCBs
PCBs are widely distributed In the fill material across the site, with
concentrations In surface soil ranging from the method detection limit to 204
mg/kg. PCBs appear to be confined to the fill material overlying the upper
aqultard. Figure 4 shows the areal extent of PCB contamination as defined by
the RI.
Metals
Metals concentrations are generally elevated In the fill material with
significantly lower concentrations at depths of 8 to 10 feet, coinciding with
the top of the upper aquitard. Highest concentrations are present in areas
where shredded car interiors are stockpiled. Lead was the most widely
distributed heavy metal, with concentrations highest in the northern portion
of the site (greater than 10,000 mg/kg). Tars generally contained less than
«=
200 mg/kg of lead, while most surface soils contained concentrations of 2000
to 8000 mg/kg. Figure 5 shows the extent of lead contamination in surface
soil.
3. Surface Hater
Surface runoff pa^cerns at the site are complicated by the variety of
surface materials (i.e., asphalt, car interiors, scrap metal) and the lack of
topographic relief. Surface waters in the eastern portion of the site flow
primarily to the BNRR ditch on the south side of the property, and then are
diverted northeast towards the Puyallup River. Surface water in the western
portion of the site flows westward toward the North and South ponds.
Monitoring of surface water flow was performed at 15 surface water
monitoring stations. Surface water quality was determined on several
occasions at five of these stations. Heavy metals, cyanide, and organic
contaminants were detected in surface waters on-site.
11 of 36
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i :\
LEGEND
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-------
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• I I •,. All H I t !
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Figure 5 - Lead Distribution In
Surface Soils and Tars
-------
Surface water quality 1s characterized by near-neutral pH (6.5 to 7.2)
with conductivities ranging from 270 to 525 umhos/cm. Trace concentrations of
barium, IrdTTTmanganese, and zinc were detected In most surface water
samples. Aluminum, arsenic, cadmium, chromium, copper, lead, mercury, and
nickel were Intermittently detected In low concentrations. Cyanide was
detected at one sampling station.
Analytical data indicates a variety of organic compounds are present In
surface waters. These compounds include aromatlcs compounds (benzene,
toluene, xylene), PAHs (naphthalene, pyrene, acenapthene), nltrophenols, and
PCBs.
4. Groundwater
The local groundwater system was investigated by construction of soil
borings, installation of 23 groundwater monitoring wells, the sampling of
*.
these 23 wells, and sampling of 6 wells Installed.during a prior
investigation. Information on subsurface conditions obtained by the soil
Investigation program was also used to define local geologic conditions. The
results of the groundwater investigation showed that three shallow
water-bearing strata (aquifers) exist at depths of less than 60 feet. In
order of increasing depth, these aquifers are referred to as the fill, sand,
and lower aquifers resoectively. In some locations these three "aquifers" are
separated by finer clay minerals. In these locations, flow between these
aquifers would be reduced. However, in some locations this "confining" layer
is absent and waters from one aquifer are in direct contact with waters from a
deeper aquifer (see Figure 3), allowing waters from these two aquifers to mix.
12 of 36
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The presence of groundwater monitoring devices 1n three subsurface zones
allowed estimations of directions of groundwater flow. Results Indicate that
In the shaTTowest zones (fill and sand aquifers) tides strongly affect the
direction of groundwater flow and, therefore, water movement. However, the
system 1s extremely complex, and therefore, only estimates of the quantity and
rates of water movement are possible. As there are only a limited number of
groundwater wells investigated in the deepest aquifer, the direction of
groundwater flow cannot be accurately estimated.
Fill Aquifer Hater Quality
Water quality in this aquifer is characterized by near-neutral pH (6.1 to
7.2) with conductivity ranging from 300 to 860 umhos/cm. These conductivities
suggest levels of total dissolved solids of about 500 mg/1. Trace
concentrations of aluminum, barium, iron, manganese, and zinc were detected in
f
most fill aquifer samples. Mercury, arsenic, and lead were detected in
groundwaters from some wells.
A variety of organic compounds were detected in groundwaters of the fill
aquifers. These include benzenes, phenols, and PAHs. For most wells, total
PAH and benzene concentrations range from 5 to 30 ug/1, although samples from
some wells indicate waters containing significantly higher concentrations.
Figure 6 shows the areal distr" .Jtion of total PAH compounds in the fill
aquifer for four round; of groundwater sampling.
Sand Aquifer Ha-?*- Quality
Groundwater in tn-? :and aquifer is characterized by pH values ranging
from 6.0 to 7.0, with ::nJuctivities (720 to 7250 umhos/cm) higher than the
overlying fill aquife^ :oncentrations of trace metals in this aquifer are
similar to those obsa•••-?: -n the fill aquifer. Cyanide was detected in the
one well, and organic -":.-as were detected in 9 of 14 wells sampled.
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lit v*g«i iUI*U Mitch lA.IBdl F(«m« No » 44
IAMO 6 JUIUI «iiJ li (AMO
Figure 7 - Total PAH
Concentration in Sand Aquifer
-------
Organic compounds detected Include benzenes, phenols, and PAHs, similar to the
fill aquifer-. Although very high PAH concentrations were detected 1n wells
within the-site boundary (up to 14,000 ug/1). concentrations decrease with
distance from the site. Figure 7 shows the distribution of PAH compounds in
the sand aquifer.
Lower Aquifer Hater Quality
Three groundwater monitoring wells are placed in the third aquifer at the
site. Although these zones may not be continuous and the direction of
groundwater flow in this zone is poorly defined, the wells are placed such
that there is a reasonable degree of certianty that "worst-case" downgradient
water quality 1s being measured. Water quality results suggest that water in
this zone does not contain significant concentrations of contaminants.
5. Migration Pathways
^
Coal gasification wastes were placed into or onto soils. Contaminants
resulting from other site operations were also introduced directly to the
soil: Therefore, exposure to contamination by humans or the environment will
occur via a migration pathway relating to the on-site soil contamination.
Contaminants in soil may be transported directly to a receptor by ingestion,
direct exposure, or inhalation of soil particles suspended in air.
Contaminants volatilized from soils may also be inhaled by on-site workers or
others. Soil contaminants may be solubilized and transported via surface
waters or groundwaters. Human receptors may be exposed to contaminants by
direct contact with waters or ingestion. Biota may be exposed to site
contaminants by vegetation uptake, ingestion of aquatic organisms, ingestion
of soil, ingestion of contaminated surface waters, or direct contact. The
pathways considered to oe :f oriority are transport from soil to air, surface
water, and groundwater
14 of 36
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6. Contaminant Migration
Air
ContajjrUjants of concern at the site could potentially be transported from
the site by wind. Therefore, the RI considered the potential for movement of
small particles by this mechanism. There are two methods to estimate wind
dispersion. The concentrations in the air can be measured directly or the
quantity of particulates can be estimated using established mathematical
methods. The RI team utilized the latter of these approaches. Results
suggest that PCBs and lead are the pollutants of greatest concern. Results
also Indicate that on-site w^'-kers would be the only humans at risk from
exposure to these contaminants. The site poses no risk to the surrounding
community by wind blown dispersion of contaminants.
Surface Hater
Surface-water flow rates and contaminant concentrations were used to
calculate fluxes of contaminants leaving the site via the surface-water
pathway. A single surface-water-moni-toring station was selected and fluxes
calculated for compounds that had been detected at that location. Fluxes are
available for selected metals, benzenes, and PAHs.
Ground Hater
The estimation of rates of transport for contaminants via the groundwater
system is limited by the current lack of understanding of local groundwater
hydrology. Due to the complicated nature of the system, values have a low
degree of confidence and should be used with caution. Fluxes for metals,
benzene, phenols, and PAHs were calculated for fill and sand aquifers.
Contaminant fluxes are generally low.
15 of 36
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D. The Risk Assessment
The purpose of the risk assessment was to determine the magnitude and
i
probability "Of- potential harm to humans and the environment and to determine
site performance standards (cleanup levels). The RA evaluations were based on
the results of the RI and methodology currently In use by the EPA. These
methods establish guidance for the estimation of levels to which hazardous
waste sites should be remediated.
The RA evaluations consisted of four study elements: exposure, toxlcity,
risk characterization, and selection of "How Clean is Clean" levels or site
performance standards. The methodology used in the RA under the above study
elements Includes the identification of exposed populations and exposure
pathways, the selection of indicator contaminants for carcinogens and
threshold-acting chemical constituents, computation of acceptable doses for
these target chemicals, and the quantification of risks.
The major contaminants at the site are coal tar pitch residuals, PCBs,
and trace metals. From data generated by the RI, three organic constituents
and one trace metal were selected as indicator chemicals representing the
overall level of site contamination. These indicator contaminants were
selected based on their toxicity, concentrations in site waters and soils, and
tendency to be transported from the site. The selected indicator compounds
are benzo(a)pyrene, PCBs, benzene, and lead. The RA evaluations were
performed for these indicator chemicals and the exposure pathways appropriate
to the target population. Soil ingestion, inhalation of airborne particulates
and vapors, and dermal contact were all considered pathways for exposure.
The target receptors (exposed population) considered for the RA were the
on-site workers. Since che site is within a heavily industrialized area,
wildlife or fish populations were not considered as target receptors except
16 of 36
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for the avlan population which occasionally uses the pond areas on the site.
The "How Clean 1s Clean" levels defined as maximum allowable
concentrations (MASC) for on-s1te soils were determined from simple models
which quantify the transport of contaminants from the source (on-site soils)
to the receptor (on-site workers). In addition to transport factors, the
models account for the contaminant Intake rate which will not Induce an
adverse affect to target receptors. This latter parameter, defined as the
Acceptable Dose (AD), was estimated from EPA-appro1 °d hazard assessment data
for carcinogens and threshold acting chemicals.
MASCs were calculated from these predictive models and the uncertainty
associated with these values was quantified using probabilistic sampling
techniques. The MASC values for the target contaminants were then reported as
the concentration of the contaminant in soil associated with a specific
probability of exceeding the acceptable level for that constituent.
For lead, the MASC was computed for two AD values corresponding to the
promulgated maximum contaminant level (MCL) and the recommended-maximum
contaminant level (RMCL). The ADs for lead were derived from drinking water
standards. For the carcinogens (benzene, benzopyrene, PCS), the MASCs were
reported for two risk levels, 10" and 10" , and for two exposure periods
(lifetime and short term). The lifetime exposure period assumes that a site
worker would be in contact with site soils for a 70-year period. The
short-term exposure period assumes continuous contact with deeper soils or
tars for a 1-month period during construction or excavation activities.
The MASC values computed for the individual and cumulative pathways are
summarized in tabular form in Table 1. Included in the table are the
comparable MASC values associated with a TO percent probability of exceeding
17 of 36
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Table 1. Pathway. Specific MASC Values
Chemical
1 .M.I
I I'd. I
UAH
PCB
Benzene
Exposure
Period
Daily
Daily
Lifetime
Short Term
Lifetime
Short Term
Short Term
Risk Level
0; AD from MCL
0; AD from RMCL
•4
10'6
JO'6
I0~6
10"6
10~6
10'6
10~6
10'6
Ingestion
MASC
(mg/kg }
91
' 226
16
0.2
1132
11.3
3.6
0.04
3,013
30.1
444,000
4,440
Dermal
MASC
(rag/kg)
98
242'
2.4
0.02
93
0.93
0.7
0.01
588
5.9
1,637,000
16,370
Inhalation
MASC
(mg/kg)
2,500
6,250
2,673
26.7
158,800
1,588
947
9.5
782,353
7,824
5,654
56.5
Cumulative.
MASC f
(mg/kg)
57
139
2.2
0.02
87
0.9
0.6
0.01
524
5.2
5,613
56
C253l.prn
-------
the acceptable dose for each target chemical and each pathway, and the
cumulative exposure rates. This risk level has been selected as a recommended
level of protection. As shown, dermal contact 1s the critical exposure route
for the organic contaminants. Inhalation Is not a significant pathway at the
maximum total suspended particulate matter concentrations predicted for the
site.
The RA presented these values with recommended cleanup goals. In a series of
meetings between the EPA and Ecology, it was agreed that remedial objectives
associated with both the 10 and 10~4 risk levels would be evaluated
during the FS. The mutually agreed upon cleanup standards are summarized in
Table 2.
18 of 36
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Table 2. Cleanup Goal Performance Standards
Maximum Allowable Contaminant Concentrations
Tacoma Tar Pits Site
Groundwater (sand
Contaminant or
Contaminant Class
Lead
Benzene
PCBs
PAHsU>
Soils
(mg/kg)
166(2)
56(3)
1.0(3)
1.0<3)
Surface Water,
Boundary (ug/1)
3.2(4>
53(5)
0.2(4>
5 - 30<6)
Surface Water
On-Site (ug/1)
172(7)
5,300(7>
2<7)
219(7>
and fill
(ug/1)
50(8)
53(5)
02(4)
5 - 30(
aquifers)
6)
(2)
(3)
(4)
(5)
(6)
(7)
Included are benzo(a)pyrene, ben2o(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, dibenzo(a,h)anthracene, and indenod ,2,3-c,d)pyrene.
Acceptable dose.
1C-6 Risk Level.
Chronic freshwater ambient water quality criterion. Performance based on detection limit,
Acute freshwater ambient water quality criterion x 1/100.
Estimated range of chronic freshwater ambient water quality criterion based on marine
criteria.
Estimated acute freshwater ambient water quality criterion.
Drinking Water MCL.
-------
IV ENFORCEMENT
A RI and. FS was conducted by Joseph Simon & Sons, Inc., Washington
Natural Gas Company, Hygrade Food Corporation, and Burlington Northern
Railroad Company pursuant to an "administrative order on consent" entered" into
and issued by EPA on November 1, 1984. EPA is now prepared to implement the
settlement procedures set forth in Section 122 of CERCLA, 42 U.S.C. §9622, and
offer these same parties the opportunity to perform the selected remedial
action pursuant to a consent decree. EPA Intends to commence a negotiation
period with the PRPs shortly after the signing of the ROD. The Department of
Interior and the State of Washington have been invited to participate in the
negotiations. If for any reason, agreement cannot be reached with these
parties, EPA will initiate alternative action to insure that the remedial
action proceeds. Finally, EPA is still considering the possibility of
Identifying additional parties who may be potentially responsible for
conditions at the site.
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V COMMUNITY RELATIONS
Community Interest for the Tacoma Tar Pits Superfund site has not been
actively demonstrated to either EPA or Ecology. It must be considered that
this site Is actually a small unit within the larger Superfund site,
Commencement Bay - Nearshore/Tideflats and that the Tacoma Tar Pits 1s located
within a heavy Industrialized area with no private residences nearby. In
fact, the community relations plan for the Tacoma Tar Pits 1s contained within
the plan for Commencement Bay and South Tacoma Channel Superfund sites. Under
a cooperative agreement with EPA 1n 1983, Ecology was delegated as the lead
agency 1n conducting Investigations for the Nearshore/Tideflats, Ruston/Vashon
Island, and Tacoma Municipal landfill sites. EPA retained Its role as the
lead agency for the Tacoma Tar Pits, ASARCO Tacoma Smelter, South Tacoma
F
Swamp, and Well 12A sites. The Tacoma-Plerce County Health Department,
(Health Department) through another Interagency Agreement with Ecology,
conducts community relations support activities for the Nearshore/Tldeflats
and Ruston/Vashon Island sites.
The Commencement Bay and South Tacoma Channel Superfund sites are located
within the City of Tacoma, on the south central portion of Puget Sound, Pierce
County, Washington. Tacoma is one of the oldest ci.ties in the Pacific
Northwest, dating back to 1841. The population of Tacoma, the second largest
city 1n Washington nest to Seattle, is 158,501 (U.S. Department of Commerce,
1980), and 485,667 people live in Pierce County.
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Manufacturing, wholesale and retail trade, and services are the primary
Industries In the Tacoma area (Washington State Employment Security, 1985),
with a 1arge~"p"ortion of the labor force employed In the manufacturing sector.
Surrounding areas are characterized with densely populated forests which
supply the lumber necessary to local Industry. Manufactured goods are
primarily wood and paper products, and chemicals. The Port of Tacoma is the
state's largest export port, and auto import port. It is the fourth largest
auto Importer on the West Coast. During the years 1980 to 1986 the county's
population has grown 9.3 percent, and non-agricultural employment increased by
15.2 percent (Washington State Employment Security. 1987). Clearly, Tacoma1s
economy has been growing steadily in recent years.
Both present and historical industrial activities have released hazardous
*
chemicals and other production by-products into Commencement Bay, the South
Tacoma area aquifers, and the surrounding environment. These products include
metals (arsenic, lead, zinc, copper., cadmium, hydrocarbons (PAHs), chlorinated
butadienes, and pesticides. Hazardous substances have been found in sediments
in the waterways, cadmium and arsenic have been documented is soils near the
Ruston area, PAHs and PCBs have contaminated groundwater aquifers in the South
Tacoma area, and fish and shellfish in Commencement Bay have been found with
elevated levels of organics and other clorinated compounds in their tissues.
Chemical contamination of Commencement Bay and the South Tacoma Channel
area prompted the site's nomination to the National Priorities List (NPL) in
October, 1981. In April, 1983 the EPA announced an agreement with Ecology to
conduct a RI/FS for the Commencement Bay Superfund site. The RI, which was
completed in 1985, characterized the nature and extent of contamination in the
21 of 36
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Nearshore/Tideflats area. The FS, which evaluates and alternatives of cleanup
action for this area of the Tacoma Superfund Sites Is now underway. RIs for
the Tacoma Municipal landfill, South Tacoma Swamp, Tacoma Tar Pits, and South
Tacoma Channel, and FSs for the South Tacoma and Tacoma Tar Pits have been
completed. An on-site RI for the ASARCO Tacoma Smelter began In September,
1987. These Investigations are being conducted by private consulting firms.
Community Involvement
Tacoma area residents became acutely Involved in Commencement Bay and
South Tacoma Channel environmental issues prior to their nomination to the NPL
1n October 1981. Over one hundred people attended an April 1981 public
meeting at which several federal, state, and local governmental agencies met
«-
to explain the area's contamination and hazardous waste'problems, and describe
what would be done about the situation. Concern about these problems was
moderate, with groups such as the.Audubon Society and Washington Environmental
Council the most active. Most people's comments at that time centered around
the perception that not enough was being done to correct the problems, at
that time, Commencement Bay and the South Tacoma Channel were given
considerable press and media attention.
In the years following Commencement Bay and South Tacoma Channel's
nomination to the NPL, the level of citizen concern appears to be less than it
was in 1981. EPA, Ecology, and other agencies have conducted several
investigations, samp]ing-anaiysis surveys, and cleanup activities at many of
22 of 36
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the Individual areas within the Commencement Bay and South Tacoma Superfund
sites. These Investigations have served as demonstrations that Tacoma's
hazardous waste problems are not being ignored, and have provided a better
understanding of the nature of the problem and its risk to human health and
the environment.
The Health Department by Interagency Agreement with Ecology has been the
lead agency for Implementing a Superfund Community Relations Plan was
completed for the Commencement Bay site. In response to input at a public
meeting held in 1983, the Health Department developed a Citizen Advisory
Committee (CAC) to help implement the Community Relations Program during
investigations and remedial action at these Superfund sites.
Community Relations activities conducted by the Health Department frave
Included: Coordinating and holding public meetings for informational purposes
and at various sta-ges of the specific site investigations, and cleanup,
briefing local governmental officials on the status of area Superfund
investigations, hazardous waste presentations to grade school children,
presentations to environmental groups and interested parties upon request, and
tours of Commencement Bay. Additional activities have included the production
and distribution of pamphlets and fliers (including translation for Asian
communities) to Tacoma and Pierce County communities, and preparing project
updates, fact sheets, and press releases.
23 of 36
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Specific Activities: Tacoma Tar Pits
On thnsr separate occasions over the past two years EPA has met with the
CAC to update the group as to the progress with the Investigations and to
Indicate EPA's future plans. The CAC as well as a larger group of Interested
citizens and special interest groups have been recipients of news letters and
project updates. The most recent mailing was issued the first week in
November 1987. Approximately 200 copies of the Proposed Plan and Project
update (Fact Sheet) for Tacoma Tar Pits were sent out using the Commencement
Bay mailing 11st. On November 18, 1987, EPA held a public meeting at the
Pierce County Health Department to accept comments on the preferred
alternative for remedial cleanup at the Tacoma Tar Pits site. Despite wide
coverage by newspaper, radio, and a local television station, only two private
^_
citizens came forward to comment on the proposed plan. These comments are
addressed In the Responsiveness Summary. Copies of the Administrative Record
have been maintained at the Tacoma Public Library. Although no comments other
than those from the Potentially Responsible Parties (PRP) were sent by the
close of the public comment period, EPA shall continue to make the effort to
keep the public informed and provide an opportunity for participation. This
aspect of the community relations effort addresses the overriding concern
expressed by citizens that information must be both accurate and timely as
opposed to the information they formerly received solely through the media.
The other major concern expressed is that they do not see the agencies taking
corrective action on so called priority sites. The high level of community
relations activities and proceeding forward with the ROD leading to remedial
action are the best measures to deal with these concerns.
24 of 36
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VI ALTERNATIVES EVALUATION - FEASIBILITY STUDY
The purpose of the FS was to develop and evaluate possible alternatives
to perform site cleanup. Available technologies were screened for
applicability and assembled into alternatives ranging from no action to
permanent treatment of all contaminants. A total of 19 preliminary
alternatives were developed, nine of which included options for groundwater
extraction and treatment. Technologies considered in these alternatives
included dust control, capping, stabilization, excavation with off-site
landfilUng, electric pyrolysis, incineration, and in situ vitrification for
the soils. Groundwater extraction with wells or subsurface drain pipes was
included, as was pumping of pond water. Water treatment options included
activated carbon adsorption and filtration or stabilization. Ten of the
F> _
preliminary alternatives, including no action, were retained after initial
screening for health protection and cost.
Site conditions were evaluated and clean-up levels established based on
_4
lifetime cancer risk levels of one per ten thousand (10 ) and one per 1
million (10 ). Alternatives containing soil excavation were evaluated for
both of these risk levels.
Table 3 contains a brief description of the 10 candidate alternatives.
These alternatives were subjected to detailed analysis. According to
regulatory guidelines, the detailed analysis of each alternative included:
Refinement of the alternative with emphasis given to defining established
methods of handling or treating wastes.
Evaluation in terms of engineering implementation, reliability,
anticipated performance and safety.
An assessment of the extent to which the alternative is expected to
effectively prevent or reduce the threat to public health and welfare and
the environment.
25 of 36
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An analysis of any adverse environmental Impacts and methods for reducing
or eliminating these Impacts.
Detailed cost estimation, Including costs associated with long-term
operation and maintenance associated with the alternative.
The degree to which each alternative conforms to federal and state
requirements and regulations.
Concerns of the community.
Table 3. Summary of Remediation Alternatives
Alternative
1 No soil or water remediation is performed. Continued groundwater
monitoring. Every five years, the site is reinvestigated to
determine the disposition of contamination. No other actions are
conducted.
4 Source control of contaminated pond water. On-s1te land use
restrictions are. imposed to prevent future exposures to soil.
Potential exposures to contaminated groundwater are controlled by
water use restrictions.
5 Source control by treating contaminated surface water, management of
migration of soil contamination by capping with a soil base and an
asphalt surface, monitoring of groundwater, land-use restrictions
and water-use restrictions on the site.
6 Treatment of pond water. Use of an impermeable cap to manage
contaminant migration, and institutional controls including land-use
and water-use restrictions.
9 Stabilization of surface soils exceeding one per 10,000 cancer risk
to create an impermeable surface, treatment of the pond water by Its
use in the stabilization process, control of surface water
infiltration by constructing drainage ditches, land and water use
restrictions, and site monitoring.
9b Groundwater extraction and treatment used in conjunction with
alternative 9.
13 Similar to Alternative 9, except that surface soils with
contamination exceeding the one per one million cancer risk levels
for PCBs, PAHs, and benzene are stabilized.
13b Groundwater extraction and treatment used in conjunction with
alternative 13.
15 Permanent treatment of the contaminated surface soils by
Incineration and stabilization. Pond water is treated by its
incorporation into the stabilization process. Clean backfill
material is placed on the unpaved areas. Incineration residues are
stabilized with the lead-contaminated wastes. The stabilized
material is spaced to form an impermeable cap. Groundwater
monitoring ana 'and and water use restrictions.
15b Groundwater e«:racrion and treatment used in conjunction with
alternative '5.
26 of 36
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16 Surface-water treatment; excavation of surface and subsurface soils
contaminated above the one per 10,000 risk level for PAHs;
dewaterlng of soils as necessary for excavation and treatment of the
water, backfilling and compaction; grading of the site and
construction of a drainage ditch to prevent surface-water ponding;
repavlng of areas necessary for metal recycling operations; land and
water use restrictions.
16b Groundwater extraction and treatment used in conjunction with
alternative 16.
18 Surface water in ponds is treated with water obtained from
dewatering of soils. All contaminated soils above the one per 1
million risk level are removed and landfilled off-site. Clean soil
is backfilled into the excavation pit. The soil Is then compacted
and graded so that surface water flows to a drainage ditch and does
not pond. Ground water is monitored and temporary water use
restrictions are imposed.
18b Groundwater extraction and treatment used in conjunction with
alternative 18.
19 Organic contaminants in soils above the one per ImllHon risk level
are destroyed by incineration. Soils containing lead and other
heavy metals are stabilized; contaminated surface water is used in
the soil stabilization process. The slurry is spread over the site
and allowed to solidify into an impermeable surface. Ground water
is extracted and treated until analyses indicate that the *
groundwater meets the cleanup levels.
The ten candidate remedial alternatives were rated according to the
concerns listed above as grouped into the following five criteria:
Technical feasibility
Institutional requirements
Public health impacts
Environmental impacts, and
Cost analysis
Table 4 contains factors -vhich contribute to each of these five criteria.
27 of 36
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Table 4. Detailed Evaluation Criteria
TECHNICAL FEASIBILITY
Performance
Effectiveness
Useful life
Reliability
Operation and maintenance requirements
Possible failure modes
Implementability
Construetability
Time
Safety
Worker
Neighborhood
INSTITUTIONAL REQUIREMENTS
Conformance to Applicable or Relevant and Appropriate Requirements (ARARs)
Community Concerns
ENVIRONMENTAL IMPACTS
Beneficial effects
Final environmental conditions
Improvements in biological community
Improvements in resources
Adverse effects
Construction and operation
Mitigative measures
PUBLIC HEALTH IMPACTS
Minimization of chemical releases
Exposures during remedial action
Exposures after remecnai action
COST
Capital cost
Operation and maintenance costs
Present worth
28 of 36
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Each of the candidate alternatives was rated for the above factors
according to a high/moderate/low scheme. -A high rating Indicated that the
a1ternat1v«-meets or exceeds objectives for cleanup. A moderate rating
Indicates the alternative only partially addresses the clean-up objectives,
while a low rating indicates that clean-up objectives are not met for this
criteria. The ratings for each factor in general categories are then
combined. These ratings for the 10 candidate alternatives are presented in
Tables. As Alternatives 9, 13, 15, 16, and 18 contained options for
groundwater treatment, these alternatives have two sets of ratings. The
alternatives Including groundwater treatment are numbered with the Symbol b
<1.e. 9b).
From this evaluation a preferred remedial alternative was selected. The
selection considered the degree to which site performance standards would be
.**"
attained, the degree of clean up performed as required by regulations, and the
degree to which routes of contaminant exposure are eliminated or controlled.
29 of 36
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I able S. Summary of Detailed Evaluation
Technical
Feasibility
No. Rating .
1 H i gh
'. H 1 9h
High
t High
v High
Vb High
15 High
lib High
1t> High
ISb High
16 High
16b High
10 High
Iflb High
Institutional
Considers ions
Rating
LUM
low
I OH
Moderate
H i ah
High
H i gh
High
High
High
Idyll
H i yl)
High
High
Environmental
Impacts Rating
Moderate
Moderate
Moderate
Moderate
Moderate
High
Moderate
High
Moderate
High
High
High
High
High
Public Health
Impacts Rating
Lou
Moderate •
High
High
High
High
High
High
High
High
High
High
High
High
Cost Analysis
(Present Worth,
Million Dollars)
0.8
1.0
1.7
3.8
3.3
4.2
3.4
4.3
8.1
9.0
93.1
93.8
133.1
133.6
19
High
High
High
High
242.9
Note: Nun tierod cleanup alternatives with the Symbol b indicate ground-water extraction and treatment has been included.
-------
VII SELECTED REMEDIAL ALTERNATIVE (No. 13)
The preferred remedial alternative (No. 13) 1s a combination of source
control measures, measures to control contaminant release, and also measures
to reduce human exposure to contaminants. This alternative consists of the
excavation of the most severely contaminated soils, stabilization of these
soils using a technique which immobilizes contaminants, capping of the
stabilized material, treatment of surface water, continued groundwater
monitoring, regulatory controls on water usage for both surface and
groundwater, and restrictions on site access.
A. Description of the Selected Remedy
1. Soil Excavation
Surface soils exceeding the 10 lifetime cancer risk level, and all
soils regardless of depth which are classified as Extremely Hazardous Wastes
?=
(EHW) under state law are to be excavated. Soils classified as EHW are
defined as those soils exceeding 10,000 mg/kg (1 percent) PAH. Soils beneath
the tar pit and ponds are known to contain PAH in excess of 1-percent. These
soils will be excavated to a depth required to show PAH concentrations less
than 1 percent. When the Remedial Action is Undertaken, this state standard
may be reevaluated for technical feasibility as allowed under §121 (d)(4)(B) of
SARA.
Soils and sediments from other areas will be excavated to a depth not to
exceed 3 feet in all locations where soils exceed concentrations defined to
have a 10"6 lifetime cancer risk. This 10" risk level translates to 1
mg/kg for PCB, 1 mg/kg for PAHs, and 56 mg/kg for benzene (Table 2). Surface
soil contaminated with lead above the 166 mg/kg level is also excavated and
stabilized. The approximate area designated for excavation is shown in
Figure 8.
30 of 36
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N
I
APPHOXIMATE
SCALE(FEET)
0 100 200 400
Q
A
EXCAVATION, 0 - 3 FEET
IMPERMEAOLE CAP
DRAINAGE DITCHES
Fill AQUIFEF) MONITORING WELL
S Ar ID AUUII Ct \ MOf4ITOniNG WELL
Figure 8 - Approximate Extent
ol F^^mcsrlizitior-w
-------
The total estimated volume of material to be excavated 1s 45,000 cubic
yards. Backhoes, bulldozers, and front end loaders will be used to excavate
soils. DusT control measures such as wetting of soils will be used during
excavation to prevent wind dispersion. Sediments from the ponds are excavated
later 1n the remedial a:tion as waters must first be removed from the ponds.
Operations at the metal recycling facility will be temporarily relocated when
the area which 1s currently paved Is remediated.
2. Soil Stabilization
To reduce the ability of contaminants to migrate from the soils prior to
replacement on site, the excavated soils will be chemically treated or
stabilized. Laboratory experiments will be performed to ensure that the
stabilization process effectively immobilizes contaminants. Following this
activity, a larger scale "pilot study" will stabilize a larger volume of
contaminated material from the site. This pilot study will determine the
effectiveness of the stabilization process.
As excavation proceeds, the contaminated material- is moved to a hopper
which screens out material larger than 6 inches in diameter and feeds the
material to a grinder or crusher. The grinder pulverizes the material to
produce particles smaller than 5 to 10mm in diameter. The material is then
fed to a mixing vessel where silicate polymers, cement, and water from the
site ponds is added. The waste will need to be thoroughly mixed prior to this
step.
The proportions of polymer and cement to be added will be determined by
laboratory scale studies. The final composition of the stabilized material
may vary depending on the composition of soil encountered during excavation.
It is estimated that 200 :o 400 pounds of cement and polymer will be added per
ton of contaminated 30;'. along .vith 10 to 25 gallons of water.
31 of 36
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3. Replacement of Stabilized Soil
The chemical stabilization process should significantly reduce the
toxlclty and"Teachability of site soils. Therefore, this material will be
placed back Into the locations from which 1t was excavated. The stabilized
soil will be dense and relatively Impermeable to rainfall or surface water.
To further reduce the flow of surface water through this stabilized material,
an asphalt cap will be placed over the stabilized soil. An asphalt sealer
will be used as part of this capping procedure.
Prior to placement of the stabilized mixture, the site surface will be
graded to form a 3 percent slope toward the BN railroad tracks to the south.
A furrow will be dug along the edge of these tracks and along the western side
of the existing ponds to provide a drainage ditch. Clean fill material may be
needed in the areas of the ponds to bring the surface up to grade. The^
mixture will then be spread over the area Indicated In Figure 8. This process
win proceed from the tar pit area toward the ponds. The material will be
laid as a continuous layer and will be allowed to cure for up to 1 month.
The reagent composition is formulated to provide a high-strength surface
capable of supporting trucks and other vehicles. In order to protect the
stabilized surface from heavy equipment wear, a 2-inch layer of asphalt will
be placed over it. The surface will be periodically inspected and, if
necessary, repaired.
Land use restrictions will be imposed to prevent or require stringent
control of future excavation on the site, to prevent future use of surface
water and shallow groundwater, and to prevent site access by personnel other
than site workers.
32 of 36
-------
4. Groundwater Extraction and Treatment
At this time, 1t Is not expected that groundwater extraction and
treatment wTtl1 be necessary. An expanded groundwater monitoring network
utilizing to the extent practicable those wells shown In Figure 8 will be
designed, and regular groundwater monitoring will be performed. To accomplish
this, It Is likely that additional wells will need to be installed. If
concentrations are determined to be statistically representative of levels
exceeding site performance standards, the need for groundwater extraction and
treatment will be evaluated in a subsequent study.
At the current time, the groundwater system has been insufficiently
characterized to completely design groundwater extraction and treatment
systems for the fill, sand, and lower aquifers. Exact locations and depths of
extraction wells cannot be specified nor can anticipated rates of groundwater
f _
extraction be estimated. Therefore, if groundwater extraction is deemed
necessary, additional characterization of the hydrogeologlc conditions of the
site will be necessary as part of the system design.
5. Performance of the Selected Alternative
The proposed cleanup option was selected due to the fact that it provides
a treatment alternative which reduces the mobility and toxicity of the
contamination, will be protective of human health and the environment, attains
ARARs, and is a cost-effective method of site cleanup. The benefits of this
alternative are discussed below. First and foremost, human exposures to
contaminated soils are prevented, thereby addressing the most significant
health concern. Pond water is treated, and surface water infiltration is
prevented by the impermeable cap. Thus, potential exposures via water sources
are controlled. Permanent treatment can be provided through the
33 of 36
-------
Immobilization of contaminants. The cost of this alternative, estimated to be
about $3.4 million, Is significantly less than other alternatives which offer
a comparable^Tevel of protection.
As required by Section 121 of CERCLA for Remedial Actions where wastes
remain on-site, the performance of the remedial action will be reinvestigated
every 5 years to ensure that the remedial action has been effective, that
Increasing levels of contaminants are not being released to the environment,
and that human health and the environment are protected. If as a result of
this frequent reassessment, the remedial action Is shown to have decreased
performance, the nature and extent of additional actions will be considered.
B. Statutory Determinations
The selected remedial alternative meets all statutory requirements,
particularly those of CERCLA as amended by SARA. The highest priority is the
*?
protection of human health and the environment. The use of stabilization
permanently treats/fixes contaminants. Therefore, the landfill closure and
post-closure care requirements are satisfied with respect to control of soil
contamination releases. In addition, tar sludge beneath the site with PAH
concentrations in excess of 1 percent are ramoved and treated. PCS materials
exceeding 50 ppm are permanently immobilized, consistent with the Toxic
Substances Control Act (TSCA) regulations. Permanent treatment, as preferred
under SARA, is used.
ARARs pertaining to surface water are satisfied because contaminants in
existing surface water are removed to nondetectable levels. Future off-site
discharges of surface water should meet discharge limits because the
surface-water runoff does not flow into contaminated materials.
34 of 36
-------
The release of additional contaminants to the groundwater 1s reduced by
the placement of an Impermeable cap, and the control of surface-water runoff.
Additionally, the permanent Immobilization of wastes satisfies groundwater
protection regulations. Therefore, presently uncontaminated groundwater will
be clearly protected, consistent with groundwater protection and
nondegradatlon regulations. Existing contaminated groundwater within the site
remains untreated; however, land use restrictions will ensure that the
groundwater Is not extracted or used. Action levels of contaminants in
groundwater have not been consistently exceeded at off-site locations.
Groundwater monitoring is conducted at the site boundaries 1n accordance with
Resource Conservation and Recovery Act (RCRA) closure requirements to ensure
that contaminated groundwater does not migrate beyond the site boundaries.
Impacts to the community are minimized through the use of this -,-
alternative. Some operations at the metal recycling facility may be suspended
during the Implementation of this alternative; however, following remediation,
activities may resume and should not be restricted.
The cap which is produced from the stabilized soil and asphalt will be
able to support driving and operation of light equipment. Large structures
may be placed if support piling is included. Land use restrictions will
ensure that placement of any such support is done in such a way that 1) any
contaminated soil brought to the surface during placement is handled in
accordance with RCRA and state hazardous waste regulations, and 2) the
Integrity of the cap in maintained.
The selected remedy will also meet all substantive laws and regulations
of other ARARs. These ire listed and their application is briefly described
in the FS.
35 of 36
-------
The law and regulations of concern Include:
Resource Conservation and Recovery Act (RCRA, 42 USC 6901); RCRA
regulations (40 CFR 261 to 280); Washington State Dangerous Waste
RegulaTtons (WAC 173-303); Minimum Functional Standards for Solid Waste
Handling (WAC 173-304).
The selected remedy prevents further spread of groundwater contamination
and constitutes a Corrective Action Program as specified in 40 CFR 264,
and WAC 173-303-645(11).
Safe Drinking Water Act (SDWA, 42 USC 300); Primary Drinking Water
Standards (40 CFR 141).
Clean Water Act (CWA, 33 USC 1251); National Pollution Discharge
Elimination System (NPDES, 40 CFR 122); NPDES Permit Program (WAC
173-220).
The final selected remedy meets the requirements of cost-effectiveness as
this alternative provides for permanent treatment, and contaminant release
minimization for a cost significantly less than other alternatives exhibiting
a similar level of protection. The estimated present worth of the selected
remedy is $3.4 million, while alternatives 15, 16, 18, and 19, provide similar
levels of protection for costs of $8.1, $93.1, $133.1, and $242.9 million,
respectively. Additional cost of these is the result of the use of more
costly technologies such as incineration (15, 19) or the excavation of larger
volumes of soils coupled
-------
APPENDIX I
INDEX TO ADMINISTRATIVE RECORD
-------
ADMINISTRATIVE KtCUKU OF 1AR PITS SITE
Doc*
file
Type/Description
Date
Pages
Author/Organization
Addressee/Organization
00000001. I'm SuperCund Information
Research material re: Tacoma Tar Pit
and Washington Natural Gas froa 192<»
to 1967
Wl/82
Kwasl Boateng, Ecology and
Environment, Inc. (E&E)
John Osborn, EPA
0000000V. Pru. Sup.ii fund 11\ format Ion
Miscellaneous data re: Tacoma Gas Plant 1965
Including Washington Natural Gas Retire-
ment Requisition
I'crwll to Abrupt ialc Ciiblic Ground 9/;/y/(>7
Waters of Ida State ol Washington
10
Unknown
Unknown
llygrade Food Products Corp. State of Washington, Dept.
Water Resources
i,i,i,i..,.,i. •. 111 .,)•<:i innJ liilui iii;u loi> Washington Gas and Electric Company
-------
Doc«
File
Type/Description
Date
* Pages
Au thor/Organl za t Ion
Addressee/Organization
00000012. Preliminary Sice Investigation
00000013. Preliminary Site Investigation
00000014. Preliminary Site Investigation
00000015. Preliminary Site Investigation
duOuoOlb. I i . 1 liiilh.n y Site Investigation
(juuuuol/. l'i tl lu.liu.iy bite Investigation
00000018. Preliminary Site Investigation
00000019. 1'iellinlnary Site Investigation
00000020. Preliminary Site Investigation
00000021. Preliminary Site Investigation
Letter re Union Pacific Involvement in 8/31/82
initial site investigation
Letter re Involvement of Washington 10/1/82
Natural Gas in preliminary site Investi-
gation
Letter re preliminary site investigation 10/25/82
with attached comments of EPA on proposal
by Kennedy/Jenks Engineers
Letter re Tacoma Tar Pits investigation 11/9/82
consent order
Letter re participation of llygrade Food 11/11/82
Products in site Investigation of
Tacoma Tar I'lts
Letter re participation of llygrade 11/12/82
Food Products in site investigation
of Tacoma Tar Pits, and response to
Administrative Order
Letter re participation of Joseph Simon 7/30/82
£, Sons in site investigation of
Tar Pits
Memo re assistance for Tacoma Tar Pita 1/24/83
site investigation in sample analysis
Letter with attached map and diagram re 2/4/83
proposed locations of wells and sampling
sites at Tacoroa Tar Pits
Draft report entitled "Soil and Ground 5/83
Water .Contamination Assessment of
Commencement Bay Tar Pits"
00000022. Preliminary Site Investigation Letter re Washington DOE's comments
on draft report on soil and groundwater
contamination by Kennedy/Jenks
Engineers
7/18/83
Jeff Asay, Union Pacific Robert Poss, EPA
Railroad Co.
Timothy Hogan, Washington Robert Poss, EPA
Natural Gas
Robert Poss, EPA
Roy Kussmann of McGavick,
Graves, Beale & McNcrthney
Douglas Eh Ike, Douglas B.
EhIke & Assocs.
Douglas Ehlke, Douglas B.
Eh Ike & Assocs.
Robert Poss, EPA
Judy Schwarz, EPA
Mikf Cook, Burlington
Northern
Cheryl Koshuta, EPA
Timothy Hogan,
Washington Natural Gas
Cheryl Koshuta, EPA
Philip Simon, Joseph
Simon & Sons
Bill Schmidt, EPA
James Dragun, Kennedy/Jenks Judy Schwarz, EPA
Engineers, Inc.
Kennedy/Jenks Engineers on
behalf of Burlington Northern
Railroad, Hygrndc Food Products,
Joseph Simon & Sons
Jim Oberlandcr, WDOE
Judy Schwarz, EPA
-------
Doc*
File
Type/DescriptIon
Date
Author/Organization
Addressee/Organization
00000023. Preliminary Site Investigation
0000002*.. Preliminary Site Investigation
00000025. Technical Directive
Document
00000026. Work plan/.isslgnmenLs/
amendment, a
(j(ju(j()(j21, Uurk |) lai,/assignments/
amendments
00000028. Work plan/assignments/
amendments
00000029. Work plan/assignments/
amendments
00000030. Work plan/assignments/
amendmenta
00000031. Work plan/assignments/
amendments
00000032. Work plan/assignments/
amendment a
Letter re modification of proposal . 9/30/82 2
for soil and groundwater contamination •
assessment of Commencement Day Tar Pits
Letter re Washington DOE'a comments on 9/7/83 1
Groundwater Contamination Assessment
Report of 8/83
Memo re property ownership for area 3/7/84 6
surrounding lacoma lar Pits with
attached landowner Hat
Report entitled "Final Work Plan, 5/18/84 140
Remedial Investigation/Feasibility
Study, lacoma Tar Pits"
Letter re scope of work for assessment 5/24/8<« 16
of soil and groundwater contamination
at Commencement Bay Tar Pits, with
attachments re: protective equipment,
monitoring and sampling locations, on-
site contamination assessment
Work plan re Remedial Investigation/ 6/25/84 12
Feasibility study of soil and groundwater
contamination
Letter re Washington DOE's comments on 9/14/84 9
a final workplan for RI/FS with
attached copy of WDOE's draft cleanup
policy
Report entitled "Draft Workplan, 10/30/84 20
Remedial Investigation/Feasibility
Study
Letter re proposed modification of 11/9/64 A
workplan for RI/FS, Xacom Xar Pits,
with attached maps of proposed well
locations
Memo re meeting on proposed modifications 1/9/85 7
to RI/FS workplan with attached
handwritten notes re: same meeting
Roger Adams, Kennedy/Jenks
Engineers
Washington DOE
Hussein Aldis, Ecology
and Environment, Inc.
Michael Cook,
Burlington Northern PR
Judy Schwarz, EPA
JohnfOsborn, EPA
Eric G. Lappala, John G. EPA
Catts, Harding Lawson Assocs.
Koger Adams, Kennedy/Jenks Charles Rliunenfeld,
Engineers Bogie & Gates
Kennedy/Jenks Engineers EPA
Megan White, WDOE
Applied Geotechnology
Wayne Grotheer, EPA
EPA
Mark Adams, Applied Ceotech- Wayne Grotheer, EPA
nology
Wayne Grotheer, EPA
Meeting attendees
-------
Uoc*
Kile
Type/Description
Date
* Pages
Author/Organization
Addressee/Organizati < "
00000033.
00000034.
00000035.
00000036.
Work plan/assignments/
amendments
Wi.rk plan/assignments/
ainundim nl s
Work plan/assignments/
amendments
Work plan/assignments/
amendments;
OouuUOjy. Wuik plan/assignments/
00000040. Remedial Investigation Reports,
Foldei 1, drafts and comments
00000041. Remedial Investigation Reports,
Folder 1, drafts and comments
00000042. Remedial Investigation Reports,
Folder 1, drafts and comments
Letter/proposal re proposed scope
01 work to address data gaps in
Remedial Investigation/Feasibility
Study for Tacoma Tar Pits
Letter re EPA's comments on proposed
scope of work and schedule for Remedial
Investigation/Feasibility Study
Letter and attached report entitled
"Supplement Work Plan and Quality
Assurance Plan for Remedial
Investigation
Letter re final workplan for well
installation and sampling program
Work assignment 95-0611.1
Work plan approval for well
Installation and sampling by CH2M1IU1
Report entitled "Technical Work Plan
Remedial Investigation/Feasibility
Study, Tacoma Tar Pits"
Letter with attached schedule re
revised project schedule for Tacoma
Historical Coal Gasification site
Tacoma Tar Pits RI - draft information
package
Letter re review of Applied Geotechnology's
package
Vol. I, Preliminary Draft RI, Tacoma
Tar Pits
00000043. Remedial Investigation Reports, Vol. 2, Preliminary Draft RI appendices,
Folder 1, draft and comments Tacoma Tar Pits
8/14/85 6
8/85 2
10/4/85 21
9/5/86 3
9/5/H< 1
9/2/86 9
3/10/87 i
5/28/85 56
6/21/85 3
6/28/85 149
6/28/85
Mark Adams, Applied Geo-
technology
Wayne Crotheer, EPA
Wayne Crotheer, EPA
Mark Adams, Applied
Geotechnology
Mark Adams, Applied Geotech- Wayne Grotheer, EPA
nology
Joan Stoupa, CH2MIU11
Wayne Grotheer, EPA
Wayne Crotheer, EPA
Wayne Sellnan, EPA
Harding Lawson Associates CH2MHill
Spyros Pavluu, Envirosphere Wayne Grotheer, EPA
Company
Applied Geotechnology
Unknown
John Catts, Harding Lawson Wayne Grotheer, EPA
Associates
Applied Geotechnology on
behalf of Washington Natural
Gas, Joseph Simon, Hygrade
Food Products, Burlington
Northern Railroad
Applied Geotechnology on
behalf of Washington Natural
Gas, Joseph Simon & Sons,
Hygrade Food Products,
Burlington Northern Railroad
-------
IJOC*
Fik
Type/Description
Date
Pages
Author/Organization
Addressee/Organization
OOOOnu',;,. Remedial Investigation Reports,
KG hie i 1, di;ift.s and comments
00000045. Remedial Investigation Reports,
Folder J, drafts and comments
00000046. Remedial investigation Reports,
Folder I, drafts and comments
00000047. Keinedl.il Investigation Reports,
Folder 1, drafts and comments
0000004U. Remedial InvuslIgation Reports,
KulJii 1, iliafts JIM) comments
OOOUUU'.'J. l< i-ihcdl.it Investigation Reports,
I'uldei 1, drafts and comments
00000030. Remedial Investigation Reports,
Foldui' 1, diafta and comments
00000051. Remedial Investigation Reports,
Folder 2, dial is and comments
00000052. Remedial investigation Reports,
Folder 2, drafts and comments
00000053. Remedial Investigation Reports,
Folder 2, drafts and comments
Letter re Washington DOE's comments
on preliminary RI submitted by Applied
Geotechnology
Letter re comments on preliminary RI
submitted by Applied Geotechnology
and FS progress report submitted by
Howard, Needles, et al.
Letter re EPA comments on preliminary
RI submitted by Applied Geotechnology
Memo/attachments re comments on draft
RI report by Wilson (EPA), Sceva (EPA),
E&.E, Watson (EPA)
Letter re Washington DOE's comments on
final draft Remedial Investigation
reports prepared by Applied Geotechnology
Letter re significant data gap In
Remedial Investigation Report by
Applied Geotechnology
Letter re EPA comments on final draft RI
Draft final report - supplemental ground
water investigation, RI/FS, Tacoma Tar
Pits
Final report - supplemental groundwater
investigation, RI/FS, lacoma Tar Pits
Final draft - Vol. 1, Remedial
Investigation Report, Tacoma Tar Pits
7/23/85
8/6/85
8/8/85 4
Geotechnology
4/14/86 15
4/16/86
4/85 2
Ceotechnology
5/86 9
Geotechnology
Megan White, WDOE
Wayne Grotheer, EPA
5/7/87
46
7/7/87 45
3/86 189
John Catts, Harding Lawson Wayne Grotheer, EPA
Assocs.
Wayne Grotheer, EPA
John Osborn, EPA
Megan White, WDOE
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Harding Lawson Assocs. for
CH2MH111
Harding Lawson Assocs. for
CH2MH111
Applied Geotechnology on behalf
of Washington Natural Gas,
Joseph Simon & Sons, Hygrade
Food Products, Burlington Northern
Railroad
Hark Adams, Applied
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Mark Adams, Applied
Mark Adams, Applied
-------
Doc I
File
type/Description
00000054. Remedial Investigation Reports, Final dratt - Vol. 2, Remedial
Folder 2, di.ifts and comments Investigation Reports Appendices,
Xacoma Tar Pits
Author/Organization
Addressee/Organization
OOOOOOSS. Risk assessment/feasibility
study, Folder 1
00000056. Risk assessment/feasibility
study, Folder 1
OOOOOOS7. Risk .jssessiiient/feaslbillty
study, Foldei 1
jB. KI:.K .i:,ou:,:,iuulU
bludy, Fuldci 1
OOOOOU59. Risk auseiJMiieiU
sUidy, Folder 1
00000060. Risk iiyi-c-oiinuiit
study, Folder 1
00000061. Risk assessment/feasibility
study, Folder 1
00000062. Risk assessment/feasibility
study, Folder 1
00000063. Risk assessment/feasibility
study, Folder 1
6/85
2/28/86
3/8/86
3/18/86
3/26/86
Progress report - feasibility study
Draft - interim deliverables Risk
Assessment and Feasibility Study
for the lacoma Historical Coal
Gasification site
Letter re review of interim RA/FS
deliverables, Xacoma Tar Pits
Letter re Washington DOE's comment
on interim RA/FS deliverable prepared
by Envirospheie Company
Letter re EPA comment on draft RA/FS
Letter r Envirosphere's response to
comments on contaminant selection
and risk levels RA/FS. Xacoma Historical Coal
Gasification Site & attached letter, 3/19/86,
Pavlou to Grotheer, re response to
review comments on interim RA/FS
deliverables - Xacoma Historical Coal
Gasification
Letter and attachments re EPA comments 6/10/86
on draft risk assessment
Draft - RA/FS of the Xacoma Historical 4/86
Coal Gasification Site
Letter and attachments re Washington DOE's 7/15/86
comments on draft Risk Assessment
66
71
3
3
7
9
Applied Geotechnology on behalf
of Washington Natural Gas,
Joseph Simon & Sons, Hygrade
Food Products, Burlington
Northern Railroad
Howard, Needles,lawmen &
Bergendoff, Mackey Smith
Envirosphere Company on
behalf of Washington Natural
Gas, Joseph Simon & Sons,
Hygrade Food Products,
Burlington Northern Railroad
John Catts, Harding Lawson
Associates
Megan White, WDOE
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Envirosphere
David Bradley, WDOE
Applied Geotechnology
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Spyros Pavlou,
Envirosphere
Spyros Pavlou,
Envirosphere
Spyros Pavlou,
Envirosphere
Washington Natural
Gas, Simon & Sons,
Hygrade Food Products,
Burlington Northern
Railroad
Spyros Pavlou,
Envirosphere
-------
Due*
File
Type/Description
Date
Author/Organization Addressee/Organization
0000006
-------
Doc*
File
Type/Description
Date
* Pages
Author/Organization
Addressee/Organization
00000074. RA/RI/FS Correspondence
00000075. RA/RJ/FS Correspondence
00000076. RA/RI/FS Correspondence
00000077. RA/KI/FS Correspondence
00000078. RA/RI/FS Correspondence
HA/KI/KS Correspondence
OOOOUU80. RA/RI/FS Correspondence
00000081, RA/RI/FS Correspondence
00000082. RA/RI/FS Correspondence
00000083. RA/RI/FS Correspondence
0000008'.. RA/RI/FS Correspondence
00000085. RA/RI/FS Correspondence
00000086. RA/RI/FS Correspondence
Memo and attachment re defining main 2/21/84
points of surface water discharge and
monitoring water quality & flow for RI
Letter re proposed consent order
No. 1084-06-08-106
Letter re consent order No.
1084-06-08-106 for RIPS
Letter re RI/FS request for consent
for access to Joseph Simon & Sons sites
Decision memorandum re EPA's decision
to proceed with RI/FS
Site safety plan for RI
Letter re Proposed Administrative Order
on Consent for Privately Funded RI/FS
Letter re Proposed Administrative Order
on Consent for Privately Funded RI/FS
Letter re Proposed Administrative Order
on Consent for Privately Funded RI/FS
Letter re Proposed Administrative Order
on Consent for Privately Funded RI/FS
Memo re Addendum to Decision Memorandum
of 8./24/B4 re EPA's decision to proceed
with RI/FS
Letter re response to EPA decision 9/17/84
to reject Proposed Administrative.Order
on Consent
Letter re EPA rejection of Administrative 9/28/84
Order on Consent & Decision to Proceed with
EPA's RI/FS
James Mitchell, Tacoma-
Plerce County Health Dcpt.
Doug Pierce, Tacoma-
Plerce County Health Dept.
8/2/84
8/13/84
8/23/84
8/24/84
9/9/84
9/11/84
9/11/84
9/11/84
9/11/84
9/14/84
1
2
2
5
3
2
2
2
2
1
John Haralll, EPA
Jeffrey Lcppo,
Bogle & Gates
David llclneck, EPA
Wayne Crotheer, EPA
Environmental Research
Group, Inc., Donald
Woods - Cltl
James Everts, EPA
James Everts, EPA
James Everts, F.PA
James Everts, EPA
Wayne Crotheer, EPA
Charles Blumenfeld,
Bogle & Gates
Dayld Helneck, EPA
Jeffrey Leppo,
Bogle & Gates
Jim Everts, EPA
Unknown
James Beard, Doug Inn
F.hlke & Assocs.
Charles Brown,
Burlington Northern,
Inc.
Charles lUumenfeld,
Bogle (, C.i l os
Timothy Hogan,
Washington Natural Gas
James Everts, EPA
Charles Blumenfeld,
Bogle & Gates
James Everts, EPA
James Everts, EPA
Timothy Hogan,
Washington Natural Gas
8
-------
Doc*
File
lype/Deacription
Date
Au thor/Organ1za tIon
Addressee/Organization
00000087. RA/K1/FS Correspondence
00000086. RA/RI/KS Correspondence
00000089. RA/R1/FS Correspondence
00000090. RA/K1/FS Correspondence
tiui.iii ii'i] |. A (.. I . | :, i .,, | u.i|.iinJi:ncc
OOOuoU'^. KA/Kl/hS Correspondence
00000093. KA/KI/tS Correspondence
00000094. RA/K1/KS Correspondence
«*
00000095. RA/RI/KS Correspondence
00000096. RA/R1/FS Correspondence
00000097. RA/R1/FS Correspondence
LetCer and attachments re consent for 9/16/84
access to property
Letter re access by EPA to property 'of 9/21/84
Hygrade Food Products
Letter re rejection of Consent Order by 9/26/84
EPA and possibility of reopening of
discussions about a privately-financed
RI/FS
Letter in response to proposal re 10/10/84
reopening of discussions fur a privately-
financed RI/FS
Consent for access to property with. 9/20/84
attached inaps
Memo re addendum to decision memo 10/16/84
re EPA'u decision to proceed with RI/FS
Memo re concurrence on issuance of 11/1/84
Cercla 106(fl) administrative ordi
on consent
Letter and attachment re need for S/8/8S
additional soil-borings at Tar Pita
site and impact of delays in submitting
proposed second and third round testing
procedure
Letter re response to proposal for S/9/8S
second and third round sampling
parameters and request certain information
re possible data gaps in RI/FS
Letter re review of Applied Geotechnology 5/13/85
progress report No. 4 and second and
third round sampling plan
Letter re second and third round 5/65
sampling
Wayne Grotheer, EPA
James Beard of Douglas
B.M. EhIke 6. Assocs.
Charles Blumenfeld, Bogle
ft Gates
James Everts, EPA
Oily of Tacoma
Wayne Crotheer, EPA
Francis Biros, EPA
David Hetneck, EPA
Wayne Grotheer, EPA
Robert Cower, City of
Xacoma, Property right-
of-way Manager
David Helneck, EPA
Ernesta Barnes, EPA
Charles Blumenfeld,
Bogle & Gates
KPA
James Everts, EPA
Ernesta Barnes, EPA
Charles Blumenfeld,
Bogle & Gates
Mark Adams, Applied
Technology
John Catts, Harding Lawson Wayne Crotheer, EPA
Associates
Wayne Grotheer, EPA
Mark Adams, Applied
Geotechnology
-------
Doc*
File
Type/Description
Date
* Pages
Author/Organ)zatIon
Addressee/Organization
00000098. RA/RI/FS Correspondence
00000099. RA/RI/FS Correspondence
00000100. RA/RI/FS Correspondence
00000101. RA/RI/FS Correspondence
uuouulu.!. KA/kl/Ks Cuirespondcnce
00000103. KA/R1/FS Correspondence
00000101*. RA/RI/FS Correspondence
00000105. RA/RI/FS Correspondence
00000106. RA/RI/FS Correspondence
00000107. RA/RI/FS Correspondence
00000108. RA/RI/FS Correspondence
00000109. RA/RI/FS Correspondence
00000110. RA/RI/FS Correspondence
Cover letter (without attachments) re 6/26/65 1
EPA guidance relating to RI/FS
Letter and attachments re revised 7/22/85 5
project schedule and additional
data needs re RI/FS
Letter and attachments re revised W1WB6 3
schedule for completion of RI/FS
Letter re disapproval of proposed 5/30/86 12
modifications to work plan for RI/FS and
and attached letter from Applied
Geotechnology re additional two deep
wells
Letter re request for installation
of two additional deep wells
Letter re additional monitoring wells'
Letter re two additional monitoring
wells
Letter re additional monitoring wells
Letter re two deep monitoring wells
Letter and attached maps re EPA 8/8/86 6
request to Burlington Northern for access
to property
Letter re EPA request to Union Pacific 2
Railroad for access to property
Letter and attached maps re EPA'a request 8/19/86 5
to Union Pacific Railroad for access
to property
Letter and attached maps re consent for 9/2/86 5
access to Union Pacific Railroad's
property
5/7/86
7/15/86
7/15/86
6/18/86
8/6/86
3
3
3
2
1
David llelneck, EPA
David llelneck, El'A
Timothy Hogan, Washington
Natural Gas
Timothy Hogan, Washington
Natural Gas and Charles
Dlumenfeld, Bogle & Gates
Mark Adams, Applied Geo-
technology
Charles Findley, EPA
Charles Findley, EPA
Charles Findley, EPA
Timothy Hogan, Washington
Natural Gas and Charles
Blumenfeld, Bogle & Gates
David Helneck, EPA
David Helneck, EPA
Jeffrey Asay, Union
Pacific Railroad
Jeffrey Asay, Union
Pacific Railroad
Charles Blumenfeld,
Bogle & Gates
Charles Blumenfeld,
Bogle & Gates
DavidfHelneck, EPA
Wayne Crotheer, EPA
Wayne Grotheer, EPA
Charles Blumenfeld,
Bogle & Gates
Timothy Hogan,
Washington Natural Gas
Timothy Hogan,
Washington Natural Gas
Charles Findley, EPA
Michael Cook, Burlington
Northern, Inc.
Jeffrey Asay, Union
Pacific Railroad
David llelneck, EPA
David Helnlck, EPA
10
-------
Doc»
Kile
Type/Description
Date
* Pages
Author/Organization
Addressee/Organization
00000111. RA/RI/FS Correspondence
00000112. RA/RI/FS Correspondence
00000113. RA/RI/FS Correspondence
00000114. RA/RI/.FS Correspondence
Uoouullb. l'A/M/1-j correspondence
0000011/. RA/KI/FS Correspondence
00000118. KA/K1/FS Consent Orders
w
00000119. Contract Management Documents
00000120. Contract Management Documents
00000121. Contract Management Documents
00000122. 'Contract Management Documents
Letter re consent for access to Union' 9/12/86 1
Pacific Railroad property
Letter re selection of drilling sub- 9/18/86 14
contractor for InstnHut Ion of two
monitoring wells/attached proposal and
bid Information
Letter re EPA request for consent for 9/23/86 1
access to Burlington Northern property
Letter re EPA'a request to Burlington 10/1/86 1
Northern for consent for access to
property
1-eCler and at laclimenta re revised list of 4/7/87 3
of final candidate alternatives, Tacoma
Historical Gasification site
Letter re delay In submittal of Rl 6/19/87 1
Letter re EPA comment on revised Hat 5/87 3
of candidate alternatives
Administrative Order on consent 1.1/1/84 33
11084-06-06-106 with attached work
plan RI/FS
EPA Summary Evaluation Report (SER) 10/28/86 12
with attachments of description 6f
activities and performance, SER
Statement of Work, lacoraa lar Pits 6/30/86 2
Site Well Installation and sampling
Letter: Progress report on work for 8/11/86 2
new wells on Tar Pits site
Bid documents for groundwater monitoring 9/2/86 Al
well Installation
David Helneck, EPA
John Catts, Harding
Lawson Associates
David Helneck, EPA
David Helneck, EPA
Matthew Schulz,
Envlrosphere
Mark Adams, Applied
Geotechnology
Wayne Grotheer, EPA
Ernest B. Barnes, EPA
Jeffrey Asay, Union
Pacific Railroad
Wayne Grotheer, EPA
Mel Burda, Burlington
Northern
John Catts, Harding
Lawson & Assocs.
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Matthew Sennit?.,
Envlrosphere
Joseph Simon & Sons,' Inc.,
Washington Natural Gas
Company, Burlington
Northern Railroad, Hygrade
Food Products
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Kathleen Nleson, CH2M11111 Wayne Orotheer, EPA
Harding Lawson Assocs.
11
-------
Doc*
Type/Description
00000126. Quality Assurance Project Plan Letter re comments on draft QAPP
00000127. Quality Assurance Project Plan Quality Assurance Project Plan
Remedial Investigation Feasibility
Study - draft
00000128, Quality Assurance Project Plan Quality Assurance Project Plan
Remedial Investigation Feasibility
Study
00000129. Quality Assurance Project Plan Utter re clarification RI/FS/QAPP
00000130. Quality Assurance Project Plan Letter re Cercla Administrative Order
No. 1084-06-08-106 (Quality Assurance
for sampling data)
UOOU01jl.
00000132.
000001jj.
00000134.
00000135.
00000136.
00000137.
'.'•. I 1 i 1 .- c I'lOJCCt H Jil
A.-,.,in jnce Project Plan
^uulity Assurance Project Plan
Quality Assurance Project Plan
Public Health Assessment
Memorandum
Reference materials or listing
of guidance documents
Community relations and news
releases
Letter re soil resistivity survey
and soil borings witli attachments/map
Quality Assurance Project Plan/Remedial
Investigation/Feasibility Study
Letter re comments on QAPP; bid document,
technical workplan
Workplan; Quality Assurance Project Plan/
Remedial Investigation/Feasibility Study
Memo re preliminary health assessment,
Xacoma Xar Pits site (SI-86-219)/Health
Assessment and Consultation Report
Re Xacoma Xar Pits RI/FS--consistency
with SARA requirements
Guidances for administrative records
located in EPA regional files
News releases "For Immediate Release,"
Commencement Bay and the Xar Pits
Date t Pages
9/21/84
9/26/86 49
10/19/84 53
10/24/84 2
11/27/84 3
12/5/84 4
2/85 60
8/22/86 2
9/2/86 7
12/17/86 18
3/12/87 3
2
7/15/83 2
Author/Organization Addreasee/Orfianizatton
Wayne Grotheer, EPA
Harding Lawson Associates
Kathleen Nleaon, CH2MH111
David Heineck, EPA
Mark Adams, Applied
Geotechnology, Inc.
Applied Geotechnology,
Inc.
Wayne Grotheer, EPA
John Catts, Harding
Lawson Associates
Director, Department of
Health & Human Services
Wayne Grotheer, EPA
EPA
DOE
John G. Catts, Harding
Lawson Associates
CH2MTU11
Harding Lawson Associates CH2MH111, EPA
Wayne Grotheer, EPA
Charles Blumenfeld,
Bogle & Gates; Xiroothy
J. Hogan, Washington
Natural Gas
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Kathleen Nleson, CH2MH1
CH2MH111, EPA
Joel Mulder, EPA
12
-------
Doc*
File
Type/Description
Date * Pages
Author/Organization Addressee/Organization
OOOU013B. Community re Lilians and news Letter re citizen advisory committee with 6/30/83 3
releases with attached list of members
00000139. Community relations and news
releases
00000140. Community relations and news
releases
OOU00141. Community relations and news
releases .
000001A ^. Community lelaliuns and news
I u li:.i..u:,
UUOUOI'. J. Coiiiiiiiiui I )' ie hit ions and news
IV IcJSUb
00001)144. Community relations and news
releases
00000145. Community relations and news
releases
00000146. Newspaper articles
00000147. Newspaper articles
00000148. Newspaper aitiiles
00000149. Newspaper articles
00000150. News paper articles
00000151. Newspaper articles
00000152. Newspaper anicles
Letter to all interested citizens re
investigation of soil and groundwater in
South Tacoma
Memo and attached community relations 2/27/87
plan
Fact sheet and letter to all interested 9/84 3
citizens
News release re EPA work on Xacoma Tar 10/24/84 3
Pits
News releases re property owners agreement 11/14/84 1
to perform Superfund investigation
Superfund citizens advisory committee 7/22/86 11
agenda, with attachments including graphs
and maps
PCB cleanup press release
Bright Future for Gas Industry Forecast
Here
Natural gas pipeline already halfway here
Industrial leaders
Gas company is 50 years old this month
Terrible! Tide flats to tar pits
Toxins found in Tar Pits
Gunk delays spur work
3/23/87 2
9/9/54 1
1
1
1
7/23/83 1
7/23/83 1
5/17/84 1
Doug Pierce, Environmental
Health Division, Tacoraa-
Pierce County Health Dept.
Phil Wong, EPA
Judy Schwarz, EPA
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Wayne Grotheer, EPA
Tacoma-Pierce County
Health Dept.
D. Cohen, EPA
Tacoma Public Library files
Tacoma Public Library files
Tacoma Public Library files
Tacoma News Tribune, Tacoma Public
Library files
The News Tribune, Tacoma, WA
Pierce County Herald,
Puyallup, WA
The News Tribune, Tacoma, WA
Jim Krull, WDOE
Interested citizens
Daphne Gimme11, Superfum
Community Relations
Coordinator
Interested citizens
13
-------
Doc I
File
Type/Description
Date
Author/Organization
Addressee/Organization
00000153. Newspaper articles
00000154. Newspaper articles
00000155. Ireatablllty studies
00000156. Trealablllty studies
'li r.ii.iM 1 Hy studies
00000161. 'lie.itdlii IHy studies
00000162. Treatublllty studies
00000163. Treatabllity studies
00000164. Pilot/bench studies
EPA set to spend $410,000 on Tar Pits 9/13/84 1
Tar Pits face cleanup 11/3/84 1
Memo re SITE (Superfund Innovative 11/12/86 1
Technology Evaluation) program,
nomination of Superfund sites
Superfund innovative technology 11
evaluation program; description of
technology process demonstrated -
electric pyrolyzer
WestInghuuse Electric Hyrolyzer general 1/21/b/ 2
Information re use al Tar I'lt site
Letter re Westlnghouse program 5/4/B7 2
participation with electric pyrolyzer
Memo re teleconference with Region 10, 2/6/87 3
Westlnghouse and OERR on demonstration of
the pyrolyzer at Tacoma Tar Pit aite
Status of EPA evaluation of site 3/B7 39
nominations for the SITE program.
Attached: SITE operations plan
Memo re answers to incineration tough 4/6/87 4
questions for the electric pyrolyzer/
Tacoma Tar Pits site demonstration.
Attached: incineration tough questions
Memo re coordination meeting for 3/18/87 4
Weatlnghouae pyrolyzer/Iacoroa Tar Pita
SITE demonstration. Attached agenda
and list of participants.
Letter re comments on soil stabilization 2/5/87 6
pilot study proposal with attached memos
from Megan White, WDOE, and from
Mike Gallagher
Jeff Weathereby, The News
Tribune, Tacoma, WA
Pierce County Herald, Puyallup,
WA
James Evert, EPA
EPA
K. H. Gepco, Manager,
Westlnghouse electric
pyrolyzer
Linda Galer, EPA
EPA
Linda Galer, EPA
Linda Galer, EPA
David Bradley, WDOE
Donald C. White, EPA
Ronald D. Hill, EPA
John Klngscott, EPA
Tin Prlncefleld, EPA
Wayne Grotheer, EPA, Russ
Sepco, Westlnghouse,
Nonna Lewis, ORD
Wayne Grotheer, EPA
14
-------
uoc*
File
jrype/Descrtptlon
Dace
t Pages
Author/Organization
Addressee/Organization
00000165. Applicable or relevant and
appropriate requirements
00000166. Lab reports/raw data
00000167. Lab reports/raw data
OOOOOH8. Lab reports/raw data
00000110. l.db reports/raw data
00000171. Lab reports/raw data
00000172. Lab reports/raw data
00000173. Lab reports/rjw daca
0000017'., Lab reports/raw dat.i
00000175. Lab repuria/raw data
00000176. Lab reports/raw data
Letter with enclosed listing of state 5/18/87 8
ARARS
Olympla Environmental Laboratory data 9/11/81 8
summary with attached Inspection reports,
news release
Letter re laboratory analysis notice for 6/14/83 13
la coma Tar Pits with attached water
samples and lab report
Letter re laboratory analysis notice for 6/14/83 11
for Tacoraa Tar Pits with attached water
samples and sediment samples
Letter and attached coxlclty report 9/9/83 2
Organic traffic reports and chain of 10/29/84 29
custody records, Case No. 3467
Letter with attached lab results (location 1/8/65 77
of lab results, EPA regional file)
Letter re Tar Pits RI/FS #14880.002 1/8/85 48
with attached test results (test results
located at EPA regional file)
Organic analysis data sheet (located 2/13/85 51
at EPA regional file)
Letter with attached test results and 1/28/85 53
quality control data (lab results at EPA
EPA regional file)
Letter with attached analytical results 2/5/85 53
414880.002 (lab results located at EPA
regional file)
Letter regarding EPA contract 68-01-6851 2/6/85 307
with attached data report (data at EPA
regional file)
David Bradley, WDOE
G. Freeman, WDOE
Robert A. Poss, EPA
Robert A, Poss, EPA
M. L. Cook, Burlington.
Northern Railroad
EPA
Analytical Technologies
John W. Strand, Analytical
Technologies, Inc.
EPA
John W. Strand, Analytical
Technologies, Inc.
John W. Strand, Analytical
Technologies, Inc.
William H. Vick, Science
Applications International
Corp.
Dr. Spyros Pavlou,
Envlrosphere
Michall L. Cook,
Burllfigton Northern
Railroad
Philip Simon, Joseph
Simon & Sons
EPA
Science Applications,
Inc.
Applied Geotechnology,
Inc.
Applied Geotechnology
Applied Geotechnology
Applied Geotechnology
John Osborn, EPA
15
-------
Due*
File
Type/Description
Date
Pages
Author /Oryan tzat ion
Addressee/Organization
00000177. Lab reports/raw data
00000178. Ub reports/raw data
00000179. Ub reports/raw data
OOOOOIBO. Lab reports/raw data
uuoOOIUl. I JL iu|'ui ii/r.iw data
00000182. l.ab ruporls/raw data
00000183. l.ab reports/taw data
0000018'*. Lab reports/raw data
00000185. Lab reports/raw data
000001B6. Lab reports/raw data
00000187. Lab reports/raw data
U00001BB. Lab reports/Liu data
Letter regarding Tar Pits RI/FS with 2/11/65 25
attached test results and quality control
data (lab results located at EPA
regional file)
Transmlttal nemo with enclosed copies . 2/19/85 18
of rough field logs from Tar Pits soil
boring 114880.002
Letter with attached test results and 2/18/85 54
Quality control data *14880.002
(lab reports located at EPA regional file)
Report of evaluation oC case 3467, 3/1/85 8
Tacoraa Tar Pits data
Letter with enclosed data sheets, sample 3/4/85 23
TP-HCI-W1. (Data sheets located at
EPA regional files)
Letter with attachment data #14880.002 3/6/85 2
Letter with attached test results and 3/15/85 32
quality control data *14860.002 (lab
reports at EPA regional files)
Report of evaluation of the case 3467, 3/25/85 15
Tacoraa lar Pits data. (Data at EPA
regional files.)
Organtcs analysis data (data at EPA 320
regional files)
Transmittal nemo with attached map 3/27/85 2
showing extent of coal tars
Tacoraa lar Pit sample identification 4/12/65 27
with attachments. (Data at EPA regional
files.) Case * 3759.
Letter with attachments re sample 7/8/85 6
analysis. (Data at EPA regional file)
James Bentley, Analytical Applied Ceotechnology
Technologies, Inc.
Mark Adams, Applied Ceo-
technology, Inc.
John W. Strand, Analytical
Technologies, Inc.
G. Muth, EPA
John W. strand, Analytical
Technologies, Inc.
John W. Strand, Analytical
Technologies
John W. Strand, Analytical
Technologies
Gerald Muth, EPA
EPA
John C. Catts, Harding
Lawson & Assoc.
Sharon Hudson BJork,
Analytical Technologies,
Inc.
Wayne Grotheer, EPA
Mark Adam, Applied
Ceotechnology, Inc.
Mark Adams, Applied
Geotechnology, Inc.
Applied Geotechnology
Applied Geotechnology
Wayne Grotheer, EPA
Mark Adams, Applied
Ceotechnology
16
-------
Doc*
File
00000189. Lab reports/raw data
00000190. Lab reports/raw data
00000191. Lab reports/raw data
Type/Description
(IUUU0192. l.jb
data
OUOUUlvl. I dL Icfxi ij/tdw ddld
Lab i ciJui is/raw data
Lub igju.,1 L:;/raw data
00000196. Lab reports/raw data
00000197. Lab reports/raw data
00000198. Lab reports/raw data
0000019V. Lab reports/raw data
Letter with attachments re sample
analyses. (Data at EPA regional ft lea)
Memo re quality assurance of Case 3467
(organlcs) with attached comments re
laboratory performance. (Data at EPA
regional file.)
Letter with attached sample results and
quality control data. (Data at EPA
regional file.)
Letter with attached sample results.
(Data at EPA regional file.)
Memo re quality assurance of Case 37S9
(VOAa and BNAs) with attached
comments on data qualifications. (Data
at EPA regional file.)
Letter with attached sample analyses.
(Data at EPA regional file)
Letter with attached sample analyses.
(Data at EPA regional file)
Letter with attached sample analyses,
(Data at EPA regional file.)
Memo with attachments re quality assurance
of case 3467 (inorganics and Antons).
(Data at EPA regional file.)
Memo re quality assurance of: case 3759
(organics) with attachments re data
qualifications
Sample numbers, location, depth and date,
with attachments re quality assurance
of Case 3467 (inorganics)
7/8/85 21
7/10/85 12
7/11/85 13
7/11/85 12
7/15/85 14
7/15/85 10
7/22/85 44
8/2/85 7
8/16/85 9
8/13/85 15
Author/Organization
Sharon Hudson BJork,
Analytical Technologies,
Inc.
Lynn Cullford, Andrew
llaffery, Ecology &
Environment, Inc.
Sharon Hudson Bjork,
Analytical Technologies
Sharon Hudson BJork,
Analytical technologies
Roger HcGlnls, Andrew
llafferty, Ecology &
Env i ronment a , Inc.
Analytical Technologies
Sharon Hudson Bjork, Ana-
lytical Technologies, Inc.
Analytical Technologies,
Inc.
Roger McGinls, Andrew
llafferty, Ecology &
Environment, Inc.
John Ryding, Andrew
llafferty, Ecology &
Environments, Inc.
Cathy Helnrlch, John
Osborn, EPA
Addressee/Organization
Mark Adaas, Applied
Geotechnology
John Osborn, EPA
Mark Adans, Applied
Geotechnology
Hark Adans, Applied
Ceotechnology
John Osborn, EPA
Mark Adams, Applied
Geotechnology
Mark Adams, Applied
Geotechnology
Mark Adans, Barbara
Trljo, Applied Geo-
technology
John Osborn, EPA
John Osborn, EPA
Roger McClnnls,
Andrew Hafferty,
Ecology & Environment,
Inc.
17
-------
Doc*
Kile
Type/Description
Date * Pages
Author/Organization
Addressee/Organization
00000200. Ub reports/raw data
00000201. Lab reports/raw data
00000202. l.ab reports/raw data
00000203. Lab reports/raw data
000002O'.. I.ab reports/raw data
0000020b. I.till i e|)ui is/raw data
00000206. Contract. Management
Documents
00000207. Lab reports/raw data
00000208. Lab reports/raw data
00000209. Lab reports/raw data
00000210. Lab reports/raw data
00000211. Lab reports/raw data
Memo re quality assurance of case
3630 (organics) with attached comments
re data qualifications. (Data at
EPA regional file.)
Memo re quality assurance of case 3630
(Inorganics) with attached comments re
data qualification. (Data at EPA regional
file.)
Sample project analysis results JTEC-0770.
Well at Hygrade Pre-chlorination tap.
(Data at EPA regional file.)
Letter with attached analytic data
Letter with attached sample analyses
and quality control data. (Data at EPA
regional file.)
Letter with attached sample analyses and
and quality control data. (Data at EPA
regional file.)
Work Assignment Form.
tion of work
Attached descrip-
Letter with attached sample analyses
and quality control data. (Data at
EPA regional file.)
Letter with attached sample analyses
and quality control data. (Data at
EPA regional file.)
Letter with attached preliminary
calculation of particulate matter
emissions.
Letter with attachments re sample
analyses. (Data at EPA regional file.)
Letter with attached sample analyses and
and quality control data. (Data at
EPA regional file.)
8/23/85 29
8/23/85 7
9/18/85 64
9/24/85 12
10/21/85 8
11/1/85 4
8/8/86 2
11/11/85 16
11/13/85 9
11/13/85 8
11/12/85 21
11/14/85 8
Lynn Gullford, Andrew
Hafferty
Roger McCinnls, Andrew
Hafferty, Ecology &
Environment, Inc.
EPA Lab
Mark A. Adams, Applied
Geotechnology
Sharon Hudson Bjork,
Analytical Technologies,
Inc.
Hair K. Augsburger,
Analytical Technologies,
Inc.
CIUM Hill
Prepared for EPA
Tialr K. Augsburger,
Analytical Technologies,
Inc.
Tialr K. Augsburger,
Analytical Technologies,
Inc.
Walter J. Russell, Air
Quality Consulting Services
Analytical Technologies,
Inc.
EPA
John Osborn, EPA
Wayne Grotheer, EPA
Applied Ceotechnology
Inc.
Applied Geotechnology
Inc.
Applied Geotechnology
Inc.
Applied Geotechnology
Inc.
Wayne Grotheer, EPA
Applied Geotechnology
Inc.
Tiair K. Augsburger, Applied Geotechnology
Analytical Technologies, Inc. Inc.
18
-------
Hoc*
file
Type/Description
Date
Author/Organization
Addressee/Organization
00000212. Lab reports/raw data
00000213. Lab reports/raw data
00000214. Lab reports/raw data
00000215. Lob reports/raw data
*
00000216. l.ab i <;|>orts/raw data
*>> w." ' , i I il I • | I I .. , J .IW 'irfld
OUUOUilt). 1 .ill i f|>ui tb/i'uw data
00000-119. t.ab rcpui (../raw datu
00000220. l.ab repurts/ruw data
00000221. Lab reports/raw data
00000222. Lab reporta/raw data
00000223. Lab reports/raw data
0000022**. Lab reports/raw data
00000225. Lab reports/raw data
00000226. Lab reports/raw data
00000227. Lab reports/raw data
Letter with attached sample analyaes 11/21/85 11
and quality control data. (Data at EPA
Regional file.)
Letter with attachments re sample analyses. 11/21/85 21
(Data at EPA regional file.)
Letter with attachment a re sample analyses. 11/21/85 17
(Data at EPA regional file.)
Letter with attached sample test results 1985 23
114888.002. (Data at EPA regional file.)
Letter with attached quality control 1/13/86 40
deliverables. (Data at EPA regional file.)
Letter with attached sample results and 8/22/86 8
quality control data.
List of result qualifiers for non- 10/23/86 8
numeric results with sample project
analysis results
List of result qualifiers for non- 12/21/86 7
numeric results with attached sample
project analysis results. Sample No.
86434550-4.
Sample project analysis results. 3/31/67 10
Sample No. 8/060020*29.
List of result qualifiers for non- 4/9/87 11
numeric results with attached sample
project analysis. Sample No. 87060020-29.
Sediment sample test results. No date 10
Sediment sample test results. No date 10
Water sample test results No date 10
Mater sample test results No date 10
Table regarding material categories t\o date 1
Field logs of boring 10/26/84 6
liair K. Augsburger, Applied Ceotechnology,
Analytical Technologies, Inc. Inc.
Analytical Technologies
Analytical Technologies
Applied Geotechnology
ApplieU Geotechnology
T
John W. Strand, Analytical Applied Geotechnology
Technologies
Michael Hlggins, Mark King, Mark Adams, Applied
Analytical Technologies Geotechnology
X. J. Hogan, Washington
Natural Gas
EPA
EPA
EPA Lab
EPA Lab
Unknown
Unknown
Unknown
Unknown
Unknown
Harding, Lawaor, Associates
Wayne Grotheer, EPA
19
-------
Due*
File
Type/Description
Date » Pages Author/Organization Addressee/Organization
OU000226. Maps and pliulos
00000229. Haps and photos
00000230. Maps and photos
00000231. Haps and photos
(KIU00232. M.i|'S iihJ phulos
00000233. Maps and photos
0000023*1. Maps and phocos
00000235. Maps and pliocos
00000236. Maps and photos
00000237. Maps arid photos
00000238. Maps and photos
00000239. Maps and photos
lacona Gas Company building
locations. (Map located at EPA
regional file)
Aerial photograph. (Map located at
EPA regional file.)
Station piping, Xacooa plot plan.
(Hap located at EPA regional file.)
Tacoroa station piping regulations,
headers. (Hap located at EPA regional
file.)
Tacoraa station piping building and
piping details.. (Hap located at EPA
regional file.)
lacoma station piping building and
piping details. (Map located at EPA
regional file.)
Building location drawing, lacoma
station. (Map located at EPA regional
file.)
lacona station regulator buildings,
plan and elevation. (Map located at
EPA regional file.)
lacoma station regulator buildings,
details. (Map located at EPA regional
file.)
Station piping, lacona station piping
details. '(Map located at EPA regional
file.)
lacoma station piping details. (Map
located at EPA regional file.)
Station piping, lacoma details. (Map
located at EPA regional file.)
9/10/23 1 Byflesby Engineering and
Management Corp.
1953 1 Unknown
6/20/56 1 Washington Natural Gas Co,
6/22/56 7 Washington Natural Gas Co.
6/25/56 1 Washington Natural Gas Co.
7/2/56 1 Washington Natural Gas Co.
7/5/56 1 Washington Natural Gas Co.
7/6/56 1 Washington Natural Gas Co.
7/9/56 1 Washington Natural Gas Co.
7/14/56 1 Washington Natural Gas Co.
7/16/56 1 Washington Natural Gas Co.
7/17/56 1 Washington Natural Gas Co.
20
-------
Uocl
File
Type/Deacrlptlon
Date
Author/Organization
Addressee/Organization
0000021.0. Maps and photos
00000241. Maps and photos
00000242. Maps and photos
00000243. Maps and photos
.ii.l i I .o t Ob
000002'iU. M. ,p-, .HI d
00000249. M.i|,b Jiid photos
00000250. Maps and photos
00000251. Maps and photos
00000252. Maps and photos
00000253. Maps and photos
00000254. Maps and photos
00000255. Maps und phutcs
Tacoma station valve and piping schematic. 10/18/61
(Map located at EPA regional office.)
Plane atatlon valve and piping schematic. 10/18/61
(Map located at EPA regional office.)
Property of Washington Natural Gaa Co. 3/24/64
plant. (Map located at EPA regional file.)
Diagram showing plat boundary of old 2/30/65
Tacoma Gas Company property. (Map located
at EPA regional file.)
Property of Washington Natural Gas Co. 3/7/68
plant. (Hap located at EPA regional flic.)
Hup (located at tl'A regional file)
Drawing (located at EPA regional file)
Surface drainage and surface water sample
locations
Proposed well locations
Map, SUfc. Sec. 3 XWP20N. R E W.M.
(Located at EPA regional file)
Diagram, spur track agreement.
Diagram (located at EPA regional'file)
Diagram of Investigation stations.
(Located at EPA regional file.)
Map, NEfc. Sec 4 IWP 20 N. R.3E W.M. No date
(Located at EPA regional file.)
Diagram (located at EPA regional file) No date
Aerial photograph (located at EPA regional No date
file)
No dJtu
No date
1/84
1/84
No date
No date
No date
No date
1
1
1
1
1
1
Washington Natural Gas Co.
Washington Natural Gas Co.
Washington Natural Gas Co.
Washington Natural Gas Co.
Washington Natural Gas Co.
HI.in Book, City of Tacoma
Unknown
Harding, Lawson Assocs.
Harding, Lawson ASSOCB.
Plan Book, City of Tacoma
Unknown
Unknown
Applied Ceotechnology, Inc.
Plan Book, City of Tacoma
Unknown
Unknown
21
-------
Due*
Type/Description
Date * Pages
Author/Organization Addressee/Organization
00000256. Maps and photos
00000257. Maps ami photos
00000258. Maps and photos
00000259. Maps ami photos
00000260. Maps and photos
00000261. Correspondence, miscellaneous
00000262. Convspondunce, miscellaneous
uiH;OuJ{, J. i >,i 11 ,,|.. h.K ni_c , luJ sec 1 lant-'OUS
000002b'i. ULhci documents and info.
00000265. Other documents and info.
00000266. Other documents and info.
0000026B. Contract management documents
00000269. Contract management documents
00000270. Contract management documents
00000271. Contract management documents
00000272. Contract management documents
Aerial photo (located at EPA regional file) No date
No date
Assessment of Commencement Bay, Tar
Pits, site location and vicinity map
Site location map, location and
vicinity map
Aerial photos (located at EPA Regional
file)
Superfund sites map
Memoranda with attachments regarding
problems with CLP data from the EAL Corp.
Letter with attached copies of water
resource permit and certificate of
ground water right
Letter re recycling of tar by Burlington
Northern
Letter with attached list of Super fund
sites and aerial photos
File review checklist for Hygrade Corp.
and site data
Site data inspection report
Technical status report re work assignment
#095-0611.0 (CU2MU111)
Technical status report re work assignment
#095-0611.0 (CH2MU111)
Technical status reprot re work assignment
#095-0611.0 (CH2MHL11)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
No date 1
No date 19
No date
3/25/86
8/9/83
2/20/8*4
10/4/83
4/6/83
2/4/87
10/13/86
11/12/86
12/15/86
1/15/87
2/12/87
1
3
3
5
2
2
2
2
2
Unknown
Kennedy Jenks, Engineers
Harding Lawson Associates
Unknown
Unknown
Joyce Crosson, EPA
Frank L. Kirk, Hygrade
Food Products Corp.
M. L. Cook, Burlington
Northern Railroad
Judi Schwarz, EPA
Jim Everts, EPA
Judi Schwarz, EPA
Phil Wong, EPA
Timothy J. Hogan,
Washington Natural G;>
Thomas A. Tobln
WDOE, Mike Blum, Paul Ritchie
S. J. llahn, EPA
S. J. Hahn, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
22
-------
Doc*
File
00000273."""Contract management documents
00000274. Contract management documents
00000275. Contract management documents
00000276. Contract management documents
00000277. Contract management documents
00000278. Contract management documents
Cuiitraci management documents
00000260. Contract management documents
00000281. Contract management documents
00000282. NFL listing and comments
00000283. NFL Hating and comments
0000028**. Haps and photos
00000285. Risk Assessment/Feasibility
Study Folder 2
Type/Description
Date # Pages
Technical status report re work assignment
#095-0611.0 (CH2MHI11)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
Technical status report re work assignment
#095-0611.0 (CH2MH111)
EPA Summary Evaluation Report (SER)
with attached description of activities
and performance (CH2M11111)
Award Fee Performance Event Report Parts
1 and 2 (CH2MH111)
EPA Summary Evaluation Report (SER)
(CH2MH111)
Breakdown of Harding Lawson Associates'
budget estimate
Federal Register, Vol. 47, No. 251, NPL
proposed rules and listing of sites
Federal Register, Vol. 46, No. 175, NPL
3/16/87 2
4/17/87 2
5/13/87 2
6/17/87 2
7/13/87 2
3/16/87 3
7/13/87 2
7/7/87 1
No date 1
12/30/82
9/8/83
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
J. Stoupa, EPA
Wayne Grotheer,
Wayne Grotheer,
Wayne Grotheer,
Unknown
EPA
EPA
EPA
EPA
EPA
Addressee/OrRanizai
list
Aerial photographs of Tacoma Tar Pits.
Two containers, 26 slides each. (Slides
located at EPA Regional file.)
Letter re Review and Comments on "Risk
Assessment of the Tacoma Historical Coal
Gasification Site" Final Report dated
July 1987
8/14/87
John Catts, Harding
Lawson Associates
Wayne Grotheer,
23
-------
Doc*
Type/ljescription
00000286. Risk Assessment/Feasibility
Study Folder 'I
00000287, Risk Assessraent/Feasibl lity
Study Folder 2
00000288. Risk Assessment/Feasibility
Study Folder 2
OOOOOZH'J. Kiak A:;M :,:.iu«;n( /K<;,isi bl I 1 ly
• l >-l, I 1 I
00000291.
Study !• older 2
00000292. Remedial Investigation
He port, Folder 3, Final
Letter re Review and Comments on Risk
Assessment (Final) and Feasibility Study
(draft); with attached memo from David
Lincoln/SEA to Joan Stoupa/SEA re Review
of Tacoma Coal Gasslflcation Risk Assess-
ment (8/U/87)
Letter re Review and Comments on "Feasi-
bility Study of Tacoma Historical Coal
Gasification Site," dated July 1987
Memo re Review of Risk Assessment
(July 198?) and comments on previous
drafts
Letter re Comments on draft Feasibility
Study (July 1987)
H. IPO it: cummer)Ib and evdUutiuii of tech-
nologies proposed in the feasibility study
tor permanent site remediation; attached
article from Journal of Environmental
Engineering. "Evaluating Asphalt Cap
tag
Elfi
Effectiveness at Superfund Sites.
1967)
(June,
8/17/87
8/21/87
8/25/87
Letter re Review and Comments by EPA and
WDOE on draft Feasibility Study submitted
August 3, 1987} attached partial copies of
same letter to 1) Douglas EhIke, 2) Charles
Blumerfeld, Bogle & Gates, 3) Tin Hogan,
Washington Natural Gas
Vol. 1 Remedial Investigation, Final
Report, Tacoma Tar Pits, Tacoma,
Washington.
9/U/87 13
9/87
251
Au thor/Organ izat ion
Joan Stoupa,
CII2M Hill
John Catts, Harding
Lawson Associates
Dana Davoli, Health
& Environmental
Assessment, EPA
Megan White, WDOE
John Barich, Bob
Stamnes, ESD, EPA
Wayne Grotheer, EPA
Applied Geotechnology
Inc., on behalf of
Washington Natural Gas,
Joseph Simon & Sons,
Hygrade Food Products,
Burlington Northern
Railroad.
Addressee/Organization
Wayne Grotheer, EPA
Wayne Crotheer, EPA
e Grotheer, EPA
Wayne Grotheer, EPA
Lee Marshall, EPA
Michael Cook,
Burlington Northern
Railroad
24
-------
Doc*
File
Type/Description
00000293. Lab Reports/Raw Data
0000029*.. Ub Reports/Raw Data
00000295. Lab Reports/Raw Data
00000296. Ub Reports/Raw Data
00000297. Lab Reports/Raw Data
UUUUut-.lt). I ill. IM-JH.I I ;,/KdU Uilta
00000^99. Lab Rupoi is/Raw Data
00000300. l,nb Reports/Raw Data
00000301. Lab Reports/Raw Data
00000302. Lab Reports/Raw Dat;i
00000303. Lab Reports/Raw Data
Data Package: Case 13467 located at
EPA hanchester Lab.
Data Package: Case 13467 located at
EPA Manchester Lab.
Data Package: Case #3467 located at
EPA Manchester Lab.
Data Packages: Case #3759 located at
EPA Manchester Lab.
Data Package: Case #3579 located at
EPA Manchester Lab.
Data Package: Case #3630 located at
EPA Manchester Lab.
Data Package: Case #3759 for sample
Nos. MJ0969 through MJ0980 located at
EPA Manchester Lab.
Data Package: Case #3467 for sample
Nos. MF0901 through MJ0908 located at
EPA Manchester Lab.
Shipping
Date:
11/06/84
Shipping
Date:
11/06/84
Shipping
Date:
11/07/84
Shipping
Date:
01/07 /B5 6,
01/08/85
Shipping
Date:
01/08/85
Shipping
Date:
12/07/84
Sampling
Date:
1/14/85 -
1/16/85
Sampling
Date:
10/26/84
Summation forms re parameter hazards for 87
sample numbers 87060020 through 87060029
Summation form for parameter hazards 85
for sample No. 85220650.
Summation forms for parameter hazards 86
for sample Nos. 86434550 through 66434554
Date # Pages Author/Organization
Versar Lab
Rocky Mtn. Lab
Cambridge Lab
EAL
Versar Lab
Wilson Lab
Harding Lawson
Associates, Ecology &
Environment
Harding Lawson
Associates, Ecology 6>
Environment
10 EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Lab
Addressee/Organization
EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Lab
. EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Lab
EPA Manchester Lab
25
-------
Itoc*
File
Type/Description
Date * Pages Author/Organization Addressee/Organization
00000304. Lab Reports/Raw Data
00000305 Lab Reports/Raw Data
00000306. Lab Reports/Raw U.il.i
00000307, Lab Reports/K.iw Data
00000308 Community Relations and
news releases
00000309 Reiimdial Invuut lf.ition
Reports K.ldcr 3, Final
OUOOUJIU lk A^coMiiuiii/iuaslbllity
stud) , 1-uKlui 'i
00000311 Risk Assessment/feasibility
study, Folder 2
00000312 Risk Asscs.smcnt/ic«isibillty
study, Koldt.-r 2
00000313 Risk Assessment/feasibility
study, Folder 2
00000314 Proposed Plan for Remedial
Action
00000315 Proposed Plan lor Remedial
Action
Sample analysis results for sample
Nos. 85220650 through 85220663.
Sample analysis results for sample
Nos. 85230450 through 85230455.
Sample analysis results for sample
Nos. 86434550 through 86434554.
Sample analysis results for sample
Nos. 87060020 through 87060029.
EPA fact sheet: Superfund Project
Update
Addendum to Remedial Investigation
(RI) Report
Addendum to Risk Assessment
Addendum to Ihe Feasibility Study
Feasibility Study, Final Report
Cover letter re: attached response
to comments on the Feasibility Study
Proposed Plan for Remedial Action
Memo re: Proposed Remedial Action
5/29/85 21
6/3/85 9
10/23/86 5
2/4/87 10
11/10/87 5
No date 4
No date 4
No date 2
7/87 422
10/22/87 42
11/4/87 17
11/13/87 1
EPA Lab Region X
EPA Lab Region X
EPA Lab Region X
EPA Lab Region X
EPA
EPA
-EPA
EPA
Envirosphere Company
Spyros P. Pavlou,
Envirosphere Company
EPA
Joel Mulder, A1SDR, EPA/
CDC Lia!«on
Record
Record
Record
Washington Natural Gas
Company, Joseph Simon and
Sons, Inc., Hygrade Food
Products Corp., Burlingtoi
Northern Railroad Company
Wayne Grotheer, EPA
Lee Marshall, EPA
26
-------
File
Type/Description
Dace # Pages
Au thor/Organ tza t ion
Addressee/Organization
J00003H. Proposed Plan lor Remedial
Action
)OOOU317 Proposed Plan tor Remedial
Action
J0000318 Proposed I'ldii lot Remedial
Action
10000319 Proposed Plan for Remedial
Action
JOUOOJ21J Proposed I'l.in lur Remedial
hi i i tin
IUOOOJ.'!) Purposed PI.in li/i Remedial
A i. L iuli
KJU00322 Not leu Lotiois iind Responses
10000323 Notice l.etteis and Responses
)OC00324 Notice Kellers and Responses
)0000325 Notice Letters and Responses
J0000326 Notice Letters and Responses
Presentation for Proposed Plan for
Remedial Action: Public hearing
transcript..
Letter re: Public hearing on proposed
plan.
Memo re: ATSDR review of Proposed
Plan.
Memo re: Comments on Proposed Plan
Letter re attached letter concerning
NPL listing and state requirements
for selection of remedy
Letter re notice letters to property
owners and utilities, and attached
comments on Proposed Plan
Memo re: notice to responsible parties
with attached list of potentially respon-
sible party attendance at 7/82 meeting.
Letter re: response to notification
of potential responsibility.
Letter of notification re potential
responsibility and request for atten-
dance at meeting.
Letter of notification re potential
responsibility and request for atten-
dance at meeting.
Letter of notification re potential
responsibility and request for atten-
dance at meeting.
11/18/87 19
11/13/87 1
11/13/87 1
11/30/87 2
12/04/87 2
12/4/87 3
3/20/82 2
5/4/82 1
7/20/82 2
7/20/82 2
7/20/82 2
Lee Marshall, EPA
Timothy Brincefield, EPA
Timothy J. Hogan,
Washington Natural Gaa
Joel Mulder, ATSDR, EPA/
CDC Liaison
Chief, Health Sciences
Branch Office of Health
Assessment, ATSDR
Lee Marshall, EPA
Charles R. Blumenfeld,
Bogle & Gates
John R. Spencer, EPA
T. J. Hogan, Washington
Natural Gas
Robert A. Poss, EPA
Robert A. Poss, EPA
James M. Everts for
Robert A. Poas, EPA
Lee Marshall, EPA
Lee Marshall, EPA
Joel
Mulder, ATSDR,
EPA/CDC Liaison
Timothy J. Hogan,
Washington Natural Gas
Lee Marshall, EPA
William A. Sullivan, Jr.,
EPA
Ms. Kathy L. ..umnerlee,
U.S. EPA, Washington, D.C
Timothy J. Hogan, Washing
Natural Gas
Phillip Simon, Joseph Siiij
& Sons
Frank Kirk, Hygrade Food
Products Corp.
27
-------
Uoc#
File
Type/Description
Date * Pages
Author/Organization
Addressee/Organization
0000032/ Notice U-IUT.S and Responses
Letter re: request to undertake site 7/30/82
investigation.
Robert A. Poss, EPA
Timothy Hogan, Washington
Natural Gas
.10000328 Notice Letters and Responses
00000329 Notice Letters ami Responses
00000330 Notice Letters and Responses
0000033) Notice Letters and Responses
JUUUU)).' f;>'li<.u U-il i i.; .n.d Responses
0000033j Notice Letters and Responses
00000334 Notice Letters and Responses
00000335 Notice Letter:; and Responses
00000336 Notice Letters and Responses
00000337 Notice Letters and Responses
00000338 Notice Letters and Responses
Letter re: request to undertake site 7/30/82 2
investigation.
Letter re: request to undertake site 7/30/82 2
investigation.
Letter of notification re: potential 8/10/82 3
responsibility.
Letter of notification re potential 8/13/82 3
responsibility and request for atten-
dance at meeting.
Letter of notification re potential 8/13/82 2
responsibility.
Letter of notification re potential 8/13/82 2
responsibility and request for attendance
at meeting.
Letter re: request to undertake site • 8/24/82 2
investigation.
Letter re: request to undertake site 8/24/82 2
investigation.
Letter requesting information with 10/19/82 3
attached list of historical information.
Letter of response to request for 11/5/82 2
Information.
Letter re previous notification of 11/08/83 2
potential responsibility and EPA review.
of study by Kennedy/Jenks Engineers
Robert A. Poss, EPA
Robert A. Poss, EPA
John R. Spencer, EPA
Robert A. Poss, EPA
John R. Spenser, EPA
Robert A. Poss, EPA
Robert A. Poss, EPA
Robert A. Poss, EPA
Robert A. Poss, EPA
T. J. Hogan, Washington
Natural Gas
Robert A. Poss, EPA
Frank Kirk, Hygrade Food
Products Corp.
Phillip Simon, Joseph
Simon & Sons
Earif Curry, Burlington
Northern Railroad
Earl Curry, Burlington
Northern Railroad
Jeff S. Asay, Union
Pacific Railroad Company
Jeff S. Asay, Union
Pacific Railroad Company
Jeff S. Asay, Union
Pacific Railroad Company
Michael L. Cook,
Burlington Northern Railr
Robert R. Gulliver,
Washington Natural Gas
Robert A. Poss, EPA
Robert R. Gulliver, Washl
Natural Gas
28
-------
Doc*
File
Typg/Descrlption
Date * Pages
Author/Organization
Addressee/Organization
00000339 Notice Letters and Responses
Letter re previous notification of
potential responsibility and EPA review
of study by Kennedy/Jenks Engineers.
11/08/83 2
Robert A. Poss, EPA
Jeff S. Asay, Union
Pacific Railroad
000003AO Notice Letters and Responses
00000341 Notice Letters and Responses
000003V2 Notice Letters and Responses
JUUUUJ'. 3 hch.cJiul I nvu j I 1 t;.. 'II
K..puili>, Kuhlci 3, final
Letter re previous notification of * 11/08/83 2
potential responsibility and EPA
review of study by Kennedy/Jenks
Engineers.
Letter re previous notification of 11/08/83 2
potential responsibility and EPA
review of study by Kennedy/Jenks
Engineers.
Letter re previous notification of 11/08/83 2
potential responsibility and EPA,
review of study by Kennedy/Jenks
Engineers.
Volume 2, Remedial Investigation Final 9/87 280
Report.
Robert A. Poss, EPA
Robert A. Poss, EPA
Robert A. Poss, EPA
Ceotechnology, Inc.
Frank L. Kirk, Hygrade
Food Products Corp.
Phillip Simon, Joseph
Simon & Sons, Inc.
Mike Cook, Burlington
Northern Railroad
Prepared for Washington
Natural Gas Corp., Joseph
Simon & Sons, Inc., Hygrad
Food Products Corp.,
Burlington Northern Railro
Company.
29
-------
DOCUMENTS DELETED FROM TAR PITS ADMINISTRATIVE RECORD
DOC. *
FILE
00000006. Pre-Superfund Information
00000123. Contract management doc.
00000124. Contract management doc.
00000160. Contract roanagment doc.
0000012S. Contract management doc.
SUBJECT/TITLE
Request for authorization to retire
Contract Pricing proposal, 9/5/86, 4 pp.,
Selluan, CH2M1U11/Moore, EPA
Technical status report 6/17/87, 42 pp.,
CH2MHlll/Catts, Harding Lawson Assocs.
Technical status report 7/13/87, 5 pp.,
CH2MH11I/Catts, Harding Lawson Assocs.
Exhibit I: Breakdown of HLA's budget
estimate, 5 pp., Harding Lawson Assocs.
REASON REMOVED
Duplicate of Doc. *2
Confidential business information
Several TSR Included under Doc. 400000194.
They wre separated and given Individual
document numbers (see Doc. 000000268-00000277).
Same reason for removal as for Doc. #00000194 above,
Confidential business information
30
-------
APPENDIX II
RESPONSIVENESS SUMMARY
TACOMA TAR PITS
TACOMA, WASHINGTON
This community relations responsiveness summary is divided into the
following sections:
Section A Overview. This section discusses the EPA selected alternative
for corrective action, and public reaction to this alternative.
Section 8 Background on Community Involvement and Concerns. This section
provides a brief history of community interest and concerns
raised during remedial planning activities at the Tacoma Tar
Pits.
Section C Summary of Comments Received During the Public Comment Period
and EPA's Responses to the Comments. Both written and oral
comments are categorized. EPA's responses to these comments
are also provided.
Section D Remaining Concerns. This section describes-remaining community
concerns that.EPA should take into consideration in conducting
the remedial design and remedial action at the Tacoma Tar Pits
site.
-------
A. OVERVIEW
A group"of Potentially Responsible Parties (PRPs) Including Washington
Natural Gas Company, Joseph Simon and Sons, Inc., Hygrade Food Products, Inc.
and Burlington Northern Railroad Company, with oversight by the EPA and
Ecology performed the RI/FS at the Tacoma Tar Pits site in Tacoma,
Washington.
In 1924, a coal gasification plant was built on the site. This plant
operated until 1956 during which time, waste materials from the coal
gasification process were disposed of on-site. Demolition of the plant began
in 1965 and was completed by 1966. During the dismantling and demolition
procedure, some waste materials and process equipment were left in place. In
1967. the property was purchased and metal recycling operations were
Initiated. This operation introduced a variety of organic and heavy metal
contaminants to soils on site.
The selected remedial alternative resulted from modification, primarily
in the areas of quantity of material to be stabilized and site boundary
definition, of the remedial alternative recommended by the above named PRPs.
These modifications were required by EPA and Ecology. This modified remedial
action includes excavation and stabilization of contaminated soils and capping
of the stabilized soil matrix. This alternative is described in more detail
in the Decision Summary and the Feasibility Study.
This Responsiveness Summary describes concerns which the community has
expressed in regards :o problems at the site and the recommended cleanup
alternative. Very few oublic comments were made at the public hearing on
November 18, 1987, and :ne comment was received from the PRPs during the
public meeting. The "v/d 'up Indian tribe provided written comments following
the close of the pub! : ::~ment period. Because their comments were of
-------
sufficient Importance a response was nonetheless prepared. Verbal comments
centered around the proven effectiveness of the stabilization process and the
need for groundwater extraction and treatment.
WrittefTcomments were received from the above named PRPs during the
public comment period. Concerns included the need to identify additional PRPs
and the extent of excavation and treatment.
The lack of public concern may, in part, be a result of the fact that the
site is located within a heavily industrialized area, with no adjacent
residential community.
-------
B. BACKGROUND ON COMMUNITY INVOLVEMENT
i
There has not been much specific community interest in the Tacoma Tar
Pits site, except for the directly affected businesses. Most community
involvement has focused on the greater Commencement Bay site, of which this is
a part. The directly affected businesses agreed to conduct the remedial
Investigation and feasibility study in 1984.
The news media covered EPA's 1984 remedial Investigation start and
subsequent responsible party takeover of the investigation.
The Commencement Bay Citizens Advisory Committee has discussed the site
several times with the site manager. The most recent discussion was on
September 10, 1987, when rne Agency presented the draft RI and FS results.
The focus of their concens have been cleanup levels on and off the site, the
basis for those levels, and who would pay the cost of cleanup.
c-
1) Citizens have requested to know the proposed cleanup levels on and
off the site and .the basis for those levels.
EPA Response: The specific levels proposed were explained In detail, and
are explained elsewhere in this document. The levels are based on
applicable, relevant: and appropriate requirements in federal and state
law.
2) Citizens have requested to know who would pay the cost of cleanup.
EPA Response: Responsible parties are conducting the RI/FS. The agency
will seek to have •-•?"n oay for cleanup as well as for EPA's own costs.
-------
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES TO THE COMMENTS
Comments from members of the public, primarily several PRPs, regarding
the selected remedial alternative are summarized below. Comments are grouped
Into those generated during the public meeting and those received in writing
during the formal public comment period.
The public comment period ran from November 6, 1987. to December 6, 1987,
(30 days). A public meeting was held at Pierce County Health Department on
Wednesday evening November 18, 1987, to explain the results of the site
investigations and to discuss the recommended remedial alternatives.
Comments Made During the Public Meeting
1. A concern was raised regarding the extent of contamination of local
groundwater and why no action was to be taken to clean up this resource.
Agency Response - The RI results show that the two upper zones of
groundwater (aquifers) contain waters that are contaminated. The third
aquifer appears to be free of contamination. The- shallow ground water is
not currently used as a potable resource, nor is it expected to be used
as a resource in the future due to salinity, low yield and the
characteristically high dissolved solids. Local groundwater supply wells
are completed at depths much greater than the vertical extent of
contamination. Therefore, groundwater extraction and treatment is not
included within the selected alternative. However, if monitoring
suggests that contaminants are being discharged off-site at
concentrations exceeding performance standards, a hydrogeologic
investigation of design study for groundwater extraction and treatment
will be initiated.
-------
2. A concern was raised with regard to the effectiveness of the
stabilization process for immobilizing contaminants.
Agency Response - Although the cement/polymer stabilization process is a
provert-technique.for immobilization of heavy metals, this technique has
not been conclusively proven to be effective in immobilizing organic
contaminants in coal tars. Therefore, both laboratory and bench scale
treatability studies will be performed during the design phase of the
remedial action to ensure the process will be effective and permanent.
During laboratory scale studies, the proper mixture of components and
additives will be determined such that maximum contaminant immobilization
is achieved. During bench scale studies, the Teachability of the
stabilized matrix will be evaluated following adequate curing and aging.
As an option to stabilization of all contaminated soils, the soils/tars
containing the highest tar content (EHW) may be considered for an
alternate type of treatment/disposal (i.e., incineration) 1f the
stabilization process is found to be ineffective for the waste matrix.
The volume of this EHW would be relatively small and this would
significantly reduce the average organic carbon content of the soil to be
stabilized.
3. A question was raised regarding the property to the east of East River
Street, and whether contaminants existed beneath this property.
Agency Response - Historical information suggests that tars were not
directly placed in this location. However, overland flow of wastes or
wastewaters from the coal gasification plant did occur in this location.
When groundwater monitoring well AGI-1D was constructed, visible evidence
of tar-related materials was observed. Therefore, some degree of soil
contamination is present east of East River Steet.
Written Comments from the PRPs
4. The record should reflect that additional potentially responsible parties
beyond the undersigned have been identified for the Tacoma Tar Pit site.
These additional potentially responsible parties should be promptly notified
of their potential liability associated with the site pursuant to Section 122
of CERCLA so that they may have a meaningful opportunity to participate in
decisions regarding the remediation of the site.
-------
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES TO THE COMMENTS
Comments from members of the public, primarily several PRPs, regarding
the selected remedial alternative are summarized below. Comments are grouped
Into those generated during the public meeting and those received in writing
during the formal public comment period.
The public comment period ran from November 6, 1987, to December 6, 1987,
(30 days). A public meeting was held at Pierce County Health Department on
Wednesday evening November 18, 1987, to explain the results of the site
Investigations and to discuss the recommended remedial alternatives.
Comments Made During the Public Meeting
1. A concern was raised regarding the extent of contamination of local
groundwater and why no action was to be taken to clean up this resource,.
Agency Response - The RI results show that the two upper zones of
groundwater (aquifers) contain waters that are contaminated. The third
aquifer appears to be free of contamination. The shallow ground water is
not currently used.as a potable resource, nor is it expected to be used
as a resource in the future due to salinity, low yield and the
characteristically high dissolved solids. Local groundwater supply wells
are completed at depths much greater than the vertical extent of
contamination. Therefore, groundwater extraction and treatment is not
included within the selected alternative. However, if monitoring
suggests that contaminants are being discharged off-site at
concentrations exceeding performance standards, a hydrogeologic
investigation of design study for groundwater extraction and treatment
will be initiated.
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Agency Response - EPA and Ecology agree that to the extent additional
responsible parties are Identified, such parties should be notified
consistent with the requirements of SARA. The EPA will perform this
activity In a timely fashion.
5. Several attempts have been made to clarify the extent of material that
will be excavated and treated under the proposed remediation plan. Your
letter of December 1, 1987, states that PAH .contaminated material containing
1n excess of 1 percent PAH must be excavated and treated in order to satisfy
the "State requirement that all extremely hazardous wastes are removed from
the site or treated...". The PAH contaminated materials have remained
undisturbed at the site for over 30 years. There is no applicable state
requirement nor is there any relevant and appropriate requirement under the
State's Waste Management laws or the regulations thereunder that mandates
removal and treatment of all extremely hazardous material at the site. These
points are further clarified under the State's newly enacted laws dealing with
Hazardous Waste Sites—Cleanup Operations, Senate Bill No. 6805. Section 29
of the new law amends the Hazardous Waste Management laws, chapter RCW 70.105,
with the addition of the following language:
A person conducting a remedial action pursuant to an approved settlement
agreement or the department conducting a remedial action or the department
conducting a remedial action under Chapter 70. RCW (Section 1 though 25 of
this act) is exempt from the procedural and substantive requirements of this
chapter, (emphasis added).
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We attempted to resolve this Issue by agreeing to modify Alternative 13
to Include treatment of all tar and sludge beneath the ponds and the pit which
exceeded 1 percent PAH. This practical solution was offered not because of
our recognition of the need to remove or treat extremely hazardous waste, but
rather as a recognition that the structural Integrity of the stabilized
material may require treatment of unstable tar and sludge in any event.
EPA's proposed plan should be clarified by deleting any reference to
excavation and treatment of extremely hazardous waste and, Instead, refer to
the excavation and treatment of the tar and sludge beneath the ponds and the
pit which exceed 1 nrcent PAH concentration. The clarification does not in
any way detract from the level of protection afforded human health and the
environment by the selected alternative yet it provides a higher level of
certainty that the quantities of material and estimated cost described in
Alternative 13 are accurate..
Agency Response - It is the EPA's and Ecology's opinion that all material
classified as EHW (>1 percent PAH) should be removed from the site
regardless of location. This material should be excavated in the
vicinity of the tar pit, ponds, and tar boil until levels less than 1
percent PAH are reached. Historical data suggests that a tar layer may
be present under portion of the site other than these areas. In most
areas, this tar may be present at depths of less than 3 feet, in which
case, it would be excavated under the "shallow soil" criteria. If,
however, tar material exceeding 1 percent PAH is found to be present at
depths of greater than 3 feet, this material should be removed and
treated in addition to the shallow soils.
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If this severely contaminated material 1s left In place, the total
quantity of contaminants left 1n contact with local groundwater would be
significantly Increased and the effectiveness of the site cleanup may be
significantly decreased. The statutory mandate In CERCLA, as amended by
SARA, for treatment of contaminants to the maximum extent practicable is
also met by the stabilization of all EHW found at the site during
remedlaTTon.
All EHW materials should be treated in a similar fashion. Materials
classified as EHWs left beneath the site in areas other than the pit,
ponds, and tar boil area would Interact with the environment in a fashion
similar to EHWs at these three locations if these locations were merely
capped. This is considered unacceptable and all on-slte EHW should be
dealt with in a consistent fashion.
6. Written comments from the Puyallup Indian Tribe received after the close
of the public comment period.
On December 17, 1987 EPA received a letter from Thomas Deming for the
Puyallup Tribe of Indians dated 5 December 1987. The letter was postmarked
December 16, 1987. It should be noted that the public comment period closed
December 6, 1987- Although the letter was received after the close of the
comment period, ERA had not completed the final drafting of the responsiveness
summary. Therefore, without regard for formal determination of the
acceptability of the letter (given its timing), EPA will respond to the
specific issues raised by Mr. Deming for the Puyallup Tribes.
Comment - Tacoma Tar Pits site is within the boundaries of the Puyallup
Reservation and, therefore, the remedial action chosen must include special
consideration in protecting the environment and natural resources which are
integral components of tribal life.
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Agency Response - A review of BIA map dated 1977 Indicates that the site
Is not located within the reservation boundary set forth and recognized
at that time. Although the question of lands claimed or under legal
dispute cannot be answered by this ROD action, EPA is required by SARA to
cons1de£ environmental impacts and natural resources (and has in this
Instance) when selecting remedial action, whether the site is located on
reservation property or not.
Comment - alternative #13 is not consistent with the federal trust
responsibilities and thus must be reevaluated to assure complete cleanup.
Also, the remedial alternative fails to adequately remedy groundwater problems.
Agency Response - Without addressing the legal issues of federal trust
responsibilities and whether they apply at this site, it should be
emphasized again that EPA has selected a remedy that is protective of
public and environmental health. The remedy selected meets the
standards, criteria, and other requirements of SARA and the NCP,
including technical feasibility, institutional considerations, and
cost-effective cleanup. As indicated above, water quality considerations
will be protected 5y the remediation in conjunction with the enhanced
groundwater monitoring. Measures for additional remediation will be
considered on an as needed basis.
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D. REMAINING CONCERNS
Several Issues concerning design parameters have been discussed but have
not yet been totally resolved. These will be addressed 1n the subsequent
design pha$e__pf this project and Include:
Treatabllity of relatively pure coal tars by the stabilization process or
alternative treatment/disposal methods
Criteria to be used to evaluate the effectiveness of the stabilization
process during laboratory and bench scale studies
The number of additional monitoring wells needed to establish a
groundwater monitoring network in lieu of groundwater extraction and
treatment.
Criteria for determining the necessity for groundwater extraction and
treatment be evaluated.
Performance of remediation to minimize possible disruptions to on-site
operations.
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APPENDIX III
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
The Superfund Amendments *nd Reauthorlzation Act of 1986 (SARA) Includes
provisions for the selection and preference of remedial actions. Excavation
and off-site land disposal options are least favored when on-site treatment
options are available. Emphasis Is placed on alternatives which permanently
treat or Immobilize contamination.
Requirements for cleanup of waste sites are Identified in terms of
Applicable or Relevant and Appropriate Requirements (ARARs). Applicable
requirements are those standards or requirements which specifically address a
hazardous substance, pollutant, or contaminant, remedial action, location, or
other circumstance at a CERCLA site. For example, discharges of water to the
navigable waterway are regulated under the National Pollution Discharge-
Elimination System (NPDES) program of the Clean Water Act. Relevant and
Appropriate requirements are those, that apply because-conditions at the site
sufficiently resemble conditions for which the requirements were developed.
The Federal Resource Conservation and Recovery Act (RCRA) is an example of a
law that is "relevant and appropriate" to the Tacoma Tar Pits site. This law
is not applicable because the site was never given interim status nor issued a
permit for handling solid waste. Nevertheless, the site sufficiently
resembles a landfill as defined in 40 CFR 260 that waste handling standards
may apply. While SARA requires that all ARARs be met, or in limited
circumstances waived, the procedural requirements of such laws are waived for
actions conducted entirely on site. Thus permits are not required.
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State standards must be attained during remedial action under SARA if
such standards were promulgated under state law that is more stringent than
federal requirements, were identified to EPA in a timely manner, and are
legally applicable or relevant and appropriate to the contaminants of
concern. Most importantly, SARA requires that cleanup of a site ensure that
the public health and environment are protected. It also requires that
alternative remedies must be weighed in the selection process.
ARARs which may apply to this site are listed in the Feasibility Study
and are presented here again with situations to which they may pertain. The
specific provisions of ARARs that may be pertinent to a particular alternative
are discussed when the alternatives are evaluated.
Federal Laws and Regulations
Resource Conservation and Recovery Act (RCRAX42 USC 6901), Subtitle C:
Part -B permit. The use of certain treatment systems, in particular
waste incinerators, requires the preparation of a Part B permit
application. Information on the site such as geotechnical and
hydrological conditions must be included along with intended uses of
the site.
Groundwater Protection (40 CFR 264, Subpart F). Pertains to
groundwater monitoring, hazardous constituents, concentration limits,
points of compPance, and corrective action. A program of
groundwater monitoring must be implemented to detect the presence of
contaminants a: :ne point of compliance, which is usually at site
boundaries. If roncentrations of particular compounds are detected
above designate; '
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Landfills (40 CFR 264. Subpart N). Provisions pertaining to the
capping, monitoring, closure, and post-closure care of the site. A
final cover must be placed which minimizes the migration of liquids
through the landfill, requires minimal maintenance, promotes
dr.ainage, and minimizes degradation of the surface, accommodates,
settling and subsidence without the loss of effectiveness, and has a
permeability less than the underlying materials. The cap must be
Inspected and maintained, and groundwater monitoring conducted.
Incinerators (40 CFR 264. Subpart OHRCRA. Subtitle C, Section
3003). Provisions pertaining to the testing, performance standards,
operation, monitoring, and closure of incinerators, including mobile
Incinerators. Wastes to be burned must be chemically analyzed; trial
burns must be performed; the incinerator must be operated to achieve
a destruction and removal efficiency (DRE) of 99.99 percent for
Principal Organic Hazardous Constituents (POHCs); air emissions must
be monitored, hydrogen chloride must be controlled to the less
stringent of 99 percent removal or 1.8 kg per hour, and particulate
emissions must not exceed 180 mg per dry standard cubic meter, and
upon closure all wastes and waste residues must be removed. A Part B
permit application must be submitted and approved prior to the use of
an incinerator, except for test burns.
Clean Mater Act (CWAX33 USC 1251):
National Pollution Discharge Elimination System (NPDESX40CFR 1^22).
These regulations govern point source discharges into navigable
waterways such as the Puyallup River. Limits on the concentrations
of contaminants which may be discharged are determined on a
case-by-case basis.
Federal Hater Quality Criteria:
Water quality criteria are established which are limits on the
concentration of compounds of fresh and marine waters. These
criteria may apply to discharges into off-site surface water. The
action levels include water quality criteria for on-site and boundary
surface waters.
Safe Drinking Water Act (SDNA)(42 USC 300):
Drinking Water Standards (40 CFR 141). Maximum contaminant levels
(MCLs) must be attained for sources of drinking water. The MCL for
lead (50 ppm) was included in the action levels. Drinking water
regulations are relevant and appropriate to the lower aquifers at the
site.
Department of Transportation. Parts 171 to 173:
Transport, packaging, labeling, placarding, and manifesting of
hazardous wasre shioments. These regulations apply to the off-site
shipment of contaminated soils and perhaps spent activated ci.-bon.
Waste materials Tiust be identified, loaded in non-leaking containers,
labeled and placarded as appropriate for the contents, and manifested
to verify that :ne shipments -aaches its intended destination.
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Toxic Substances Control Act (TSCAX15 USC 2601 )x :
Records, reporting, storage, handling. Incineration, and landfill Ing
of PCB-containIng wastes. (40 CFR 761.60-.79). These regulations
apply to disposal or incineration of excavated PCB-contamlnated
matFMals. .-C-B materials which are disposed of prior to February 17,
1978, are considered to be in service and do not require excavation
for disposal. Incineration of excavated PCB-containing materials
must destroy 99.9999 percent of the PCBs. The incinerator must be
approved and be operated under specific conditions. Materials
containing less than 50 ppm PCBs may be disposed in a sanitary
landfill.
Excavated materials containing PCBs at concentrations of 50 pm or greater
when disposed must be placed in a chemical waste landfill. Several conditions
must be met by a chemical waste landfill approved for PCS disposal: The
landfill must be located in impermeable formations; synthetic liners may be
required if the permeability of the underlying soil is judged to be excessive;
the landfill must be located above historic groundwater levels and away from
floodplains, shorelands, and groundwater recharge areas; flood protection must
be provided; it must be located in areas of low to high relief to minimrze
erosion; surface waters and groundwater must be monitored at least for PCBs,
chlorinated organics, specific conductance, and pH; a leachate collection and
monitoring system must be installed; the landfill must be operated with proper
record-keeping and handling, and incompatible or ignitable wastes are not
allowed; fences must be placed around the site, site roads must be maintained,
and hazardous conditions due to spilled or windblown materials must be
prevented.
State Regulations:
The state of Washington can develop its own hazardous waste regulations,
provided they are at least as stringent as Federal regulations. For the most
part, state hazardous waste regulations parallel the federal regulations.
Therefore, the comparable state regulations are not repeated. There are some
notable differences, however, which are discussea below.
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Designation of Dangerous Haste (DM) and Extremely Hazardous Haste (EHNKWAC
17-303-081 to 103):
The state definition of a hazardous waste Incorporates EPA
designation of hazardous waste which Is based on the compound being
specifically listed as such, or on the waste exhibiting the
properties of reactivity, ignitability, corroslvity, or Extraction
Procedure (EP) toxicity. Ecology distinguishes hazardous waste as
Extremely Hazardous Waste (EHW) or Dangerous Waste
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Criteria are established for fecal conform bacteria, dissolved
oxygen, total dissolved gas, temperature, pH, and turbidity. In
addition, concentrations of contaminants must be below levels which
may adversely affect human health, the environment, or uses of the
water body.
The criteria and classifications of the State Water Quality
Standards do not apply within a dilution zone defined by Ecology.
Within the dilution zone, fish and shellfish must not be killed or
aesthetic values diminished.
NPOES Permits (administered by the state under WAC 173-216):
Discharges of water to off-site navigable waterways may require an
NPOES permit. The concentration limits of contaminant discharges
are determined on a case-by-case basis.
Water Pollution Control and Discharge Standards (90.48. 90.52. and 90.54 RCW):
Waters of the state of Washington, which include surface water and
groundwater, are to be protected to maximize their beneficial use.
Materials and substances which might enter these waters must receive
prior treatment with known, available, and reasonable methods.
Protection of Upper Aquifer Zones (WAC 173-154):
Upper Aquifers and Upper Aquifer zones must be protected to the
extent practicable to avoid depletions, excessive water level
declines, or reductions in water quality in order to preserve the
water for domestic, stockwater, and similar uses, and preserve •
spring and"stream flow.
State Water Code (90.03 RCW) and Water Rights (90.14 RCW):
These laws specify the conditions and extracting surface water or
groundwater for nondomestic uses. Basically, water extraction must
be consistent with beneficial uses of the resources and must not be
wasteful. Groundwater extraction wells, which may be used to
control the migration of contamination via groundwater, must comply
with the substantive requirements necessary to obtain a water rights
permit. Water rights laws may pertain if groundwater is extracted
for treatment.
Water Well Construction (13.104 RCW and WAC 173-360):
Minimum standards exist for water well construction, construction
reports, and examination and licensing contractors and operators.
These standards may apply if extraction wells are installed.
Submissions of Plans and Reports (WAC 173-240):
Ecology must -ev;ew plans for wastewater treatment facilities.
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A1r Quality. General Emission Standards (HAC 173-400-040(5)):
Contaminant air emissions from any sources must not be detrimental
to the health, safety, or welfare of any person and must not damage
any property or business. Emissions from incinerators must satisfy
""ttlls requirement.
Air Emissions. New Source Review (NAG 173-400 and 173-403):
Emissions of toxic air contaminants from new sources undergo a
review process in which the contaminants are Identified, the best
available control technology (BACT) is determined, estimates are
made of the maximum ambient air concentration (MAAC), and an
acceptable ambient level (AA1) established. Based on these
findings, a new source may be approved or disapproved. New source
review applies to hazardous waste incinerators.
Incinerators (NAC 173-303-670):
The state regulations regarding incinerators are comparable to
Federal Regulations. In addition, regulations of the local air
pollution control authority pertain. In the Tacoma area, the Puget
Sound Air Pollution Control Authority (PSAPCA) has jurisdiction.
According to PSAPCA regulations, particulate emissions are limited
to 0.01 grains per standard dry cubic feet of air (gr/sdcf) compared
to 0.08 required under federal regulations. Also, BACT must be
used. Because Tacoma is a containment area for particulate matter,
emissions must be less than 50 pounds per hour. Exceedence of this
level requires the "purchase" of emission offsets at 1.1 times the
emission rate.
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