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.
                                                                  1 of 36

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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.
                                                                2 of  36

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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

                                                                  3 of 36

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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.
                                                                 4 of 36

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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.
                                                                  6 of  36

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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
                                                                 3 of  36

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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.
                                                                 9 of 36

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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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                                    (•II	  MC»
                                                                                    ••IT
               OLD FILL
                 SAND
                                                                                                                                      ••14
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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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                                                                                                                       \
                                                                  by
                                     IAMII • HHOI ftii.l 1^ 1AMI1 ttJUItM
Figure 5 - Lead Distribution In
Surface Soils and Tars

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     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.
                                                                 13 of 36

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                             \\
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                                                            \  r
                                       (   Jb
                                        1  b
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  /




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l IMIIK I I'A •pill Ul Alt)
                                                                                                                                      \
                                                                                                                        ISM
              AI>>«O»IMAC«
                            Ifllll
                 liO   3UO
                         • «»• M«p (t«v*lOD*a Irgm |  ? 10 ••(!•! phQlOt by

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                         IAMO 6 JUIUI «iiJ li (AMO
Figure 7 - Total PAH
Concentration in Sand Aquifer

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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
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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

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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.

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                                 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.
                                                                 19 of 36

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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.
                                                                 20 of  36

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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.

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                   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

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                                   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.

-------
     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).

-------
     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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