REMEDIATION SYSTEM EVALUATION

     MCCORMICK AND BAXTER
         SUPERFUND SITE
        PORTLAND, OREGON
Report of the Remediation System Evaluation,
       Site Visit Conducted at the
   McCormick and Baxter Superfund Site
         August 23-24, 2001


 Final Report Submitted to Region 10
         February 8, 2002
                       \
                        LLJ
                PRO'

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                                        NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) and the United States Army Corps
of Engineers (USAGE) for the U.S. Environmental Protection Agency (U.S. EPA). Work conducted by
GeoTrans, including preparation of this report, was performed under Dynamac Contract No. 68-C-99-
256, Subcontract No. 91517.  Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.

This document (EPA 542-R-02-008r) may be downloaded from EPA's Technology Innovation Office
website at www.epa.gov/tio or www.cluin.org/rse.

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                               EXECUTIVE SUMMARY
The McCormick and Baxter Creosoting Company, Portland Plant, Superfund Site is located adjacent to
the Willamette River in Portland, Oregon and addresses contamination of soil, groundwater, and river
sediments stemming from creosoting operations between 1944 and October 1991. The site lies between a
bluff and the river and consists of 43 acres of land and over 15 acres of river sediments. The site is
bordered by industrial properties along the river and by a residential areas on the bluff. A Burlington
Northern Railroad spur crosses the western portion of the property, and a Union Pacific Railroad crosses
the northeastern portion of the site below the bluff.  The site consists of three operable units for
addressing contamination: one each for soil, groundwater, and river sediments.

Current subsurface contamination at the site exists predominantly as NAPL that is migrating in
subsurface "stringers" toward the river. Observations by the site team indicate that NAPL occasionally
discharges directly into the river from seeps located on the shore. Dissolved groundwater concentrations
for all constituents are below the alternate cleanup levels for groundwater; thus, emphasis is placed on
removing and retarding migrating NAPL.

A Remediation System Evaluation (RSE) was conducted on the system in August 2001. A RSE
involves a team of expert hydrogeologists and engineers, independent of the site, conducting a third-party
review of site operations. The evaluation includes reviewing site documents, visiting the site for up to 1.5
days, and compiling a report that includes recommendations to improve the system.

The RSE was intended to evaluate the pump-and-treat and NAPL collection systems associated with the
groundwater operable  unit; however, these interim remedies have been discontinued and emphasis is now
placed on alternate strategies for containment of groundwater and NAPL contamination. This RSE
report, therefore, summarizes the  groundwater remedies to date but offers recommendations to improve
effectiveness, reduce life-cycle costs, and gain site close-out that are in line with the selected alternate
strategies. Many of these recommendations occurred during discussions with site managers at the  site
visit and in subsequent conference calls and took the form of both constructive criticism of proposed
strategies, contribution of additional strategies, and approaches to implementing the selected remedial
actions.

The primary remedial  strategies discussed by the site managers and the RSE team included a vertical
barrier wall, a permeable sediment cap, a targeted sediment cap with selected materials designated for
NAPL seep areas, and cutoff trenches.  In addition to discussing these strategies the RSE also made the
following recommendations:

        The selected strategies should be  implemented in a phased approach with defined schedules and
        budgets. The construction and implementation of one strategy may provide additional
        information pertinent to the design and implementation of the other strategies  or may alter site
        conditions.

        Detailed cost-benefit analyses should be conducted to best determine the most appropriate
        variations on the proposed strategies, especially with respect to the sediment cap. These cost-
        benefit analyses among the various sediment cap options should be based on life-cycle costs and
        should incorporate for each option the initial cost, estimated frequency for replacing cap
        materials in NAPL seep areas, and cost of replacing those materials.

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The site managers should proceed with implementation in an experimental approach. Monitoring
and evaluation of the site conditions after implementation will provide detailed information
regarding the remedy's performance. In the case of the sediment cap, this information may
reveal specific NAPL seep areas and estimates of the time required for the NAPL to
breakthrough the cap. In case the cap is compromised by seeping NAPL, this information could
be useful in determining the areas of the cap to be replaced and, through further cost-benefit
analyses, the type of material to be used in those compromised areas.
                                       11

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                                      PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response
(OERR).  The objective of this project is to conduct Remediation System Evaluations (RSEs) of pump-
and-treat systems at Superfund sites that are "Fund-lead" (i.e., financed by USEPA). RSEs are to be
conducted for up to two systems in each EPA Region with the exception of Regions 4 and 5, which
already had similar evaluations in a pilot project.

The following organizations are implementing this project.
            Organization
   Key Contact
         Contact Information
 USEPA Technology Innovation
 Office
 (USEPA TIO)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax: 617-918-8417
yager.kathleen@epa.gov
 USEPA Office of Emergency and
 Remedial Response
 (OERR)
Paul Nadeau
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Mail Code 5201G
phone: 703-603-8794
fax:703-603-9112
nadeau.paul@epa.gov
 GeoTrans, Inc.
 (Contractor to USEPA TIO)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc. com
 Army Corp of Engineers:
 Hazardous, Toxic, and Radioactive
 Waste Center of Expertise
 (USAGE HTRW CX)
Dave Becker
12565 W. Center Road
Omaha, NE 68144-3869
(402)697-2655
Fax: (402) 691-2673
dave.j.becker@nwd02.usace.army.mil
                                            in

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The project team is grateful for the help provided by the following EPA Project Liaisons.
 Region 1    Darryl Luce and Larry Brill
 Region 2    Diana Curt
 Region 3    Kathy Davies
 Region 4    Kay Wischkaemper
 Region 5    Dion Novak
Region 6     Vincent Malott
Region 7     Mary Peterson
Region 8     Armando Saenz and Richard Muza
Region 9     Herb Levine
Region 10    Bernie Zavala
They were vital in selecting the Fund-lead P&T systems to be evaluated and facilitating communication
between the project team and the Remedial Project Managers (RPM's).
                                             IV

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                             TABLE OF CONTENTS
EXECUTIVE SUMMARY	i

PREFACE 	iii

TABLE OF CONTENTS	  v

1.0 INTRODUCTION	  1
       1.1    PURPOSE	  1
       1.2    TEAM COMPOSITION	  2
       1.3    DOCUMENTS REVIEWED	  2
       1.4    PERSONS CONTACTED                        	  3
       1.5    SITE LOCATION, HISTORY, AND CHARACTERISTICS 	  4
             1.5.1   LOCATION AND HISTORY	  4
             1.5.2   POTENTIAL SOURCES	  4
             1.5.3   HYDROGEOLOGIC SETTING	  5
             1.5.4   DESCRIPTION OF GROUND WATER PLUME	  5

2.0  SYSTEM DESCRIPTION	  6
       2.1    SYSTEM OVERVIEW	  6
       2.2    EXTRACTION SYSTEM	  6
       2.3    TREATMENT SYSTEM	  6

3.0  SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE  CRITERIA	  7
       3.1    CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA	  7
       3.2    OPERABLE UNIT CLEANUP GOALS	  8

4.0  FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT	  9
       4.1    FINDINGS 	  9
       4.2    SUBSURFACE PERFORMANCE AND RESPONSE  	  9
             4.2.1   WATERLEVELS 	  9
             4.2.2   CONTAMINANT LEVELS 	  9
       4.3    COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS	  10
       4.4    RECURRING PROBLEMS ORISSUES	  10
       4.5    SAFETYRECORD 	  10

5.0  EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT  11
       5.1    GROUND WATER 	  11
       5.2    SURFACE WATER	  11
       5.3    AIR	  11
       5.4    SOILS 	  12
       5.5    WETLANDS AND SEDIMENTS 	  12

6.0  RECOMMENDATIONS	  13
       6.1    CONTRIBUTION OF RSE TEAM TO DISCUSSIONS REGARDING REMEDIAL DESIGN	  13
       6.2    DECISION OF THE SITE MANAGERS	  15
       6.3    ADDITIONAL RECOMMENDATIONS FROM THE RSE TEAM  	  16
             6.3.1   IMPLEMENT STRATEGIES IN PHASES WITH DEFINED SCHEDULES AND BUDGETS 	  16
             6.3.2   TAKE AN EXPERIMENTAL APPROACH AND APPLY LESSONS LEARNED	  16
             6.3.3   EXPAND PERMEABILITY MODELING AND CONDUCT A COST BENEFIT ANALYSIS OF
                    VARIOUS SEDIMENT CAPS	  17

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        6.4     UNUSED EQUIPMENT  	  18

7.0  SUMMARY	  19


List of Figures

Figure 1-1       A map of the McCormick and Baxter property and the surrounding area

Figure 1-2       Layout of the McCormick and Baxter property indicating former facility structures, primary
                contaminant source areas, pertinent site features, and approximate location of the proposed
                vertical barrier wall
                                                   VI

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                                 1.0 INTRODUCTION
1.1           PURPOSE

In the OSWER Directive No. 9200.0-33, Transmittal of Final FYOO - FY01 Superfund Reforms Strategy,
dated July 7,2000, the Office of Solid Waste and Emergency Response outlined a commitment to
optimize Fund-lead pump-and-treat systems. To fulfill this commitment, the US Environmental
Protection Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and
Remedial Response (OERR), through a nationwide project, is assisting the ten EPA Regions in
evaluating their Fund-lead operating pump-and-treat systems. This nationwide project is a continuation
of a demonstration project in which the Fund-lead pump-and-treat systems in Regions 4  and 5 were
screened and two sites from each of the two Regions were evaluated.  It is also part of a larger effort by
TIO to provide USEPA Regions with various means for optimization, including screening tools for
identifying sites likely to benefit from optimization and computer modeling optimization tools for pump
and treat systems.

This nationwide project identifies all Fund-lead pump-and-treat systems in EPA Regions 1 through 3 and
6 through  10, collects and reports baseline cost and performance data, and evaluates up to two sites per
Region.  The site evaluations are conducted by EPA-TIO contractors,  GeoTrans, Inc. and the United
States Army Corps of Engineers (USAGE), using a process called a Remediation System Evaluation
(RSE), which was developed by USAGE.  The RSE process is meant to evaluate performance and
effectiveness (as required under the NCP, i.e., and "five-year" review), identify cost savings through
changes in operation and technology, assure clear and realistic remediation goals and an exit strategy,
and verify adequate maintenance of Government owned equipment.

The McCormick and Baxter Superfund Site was chosen to receive an RSE based on an initial  screening
of the pump-and-treat systems managed by USEPA Region 10 as well as discussions with the  Superfund
Reform  Initiative Project Liaison for that Region.  This site has high operation costs relative to the cost
of an RSE and a long projected operating life.  This report provides a brief background on the site and
current operations, a summary of the observations made during a site visit, and recommendations for
changes and additional studies. The cost impacts of the recommendations are also discussed.

A report on the overall results from the RSEs conducted for this system and other Fund-lead P&T
systems  throughout the nation will also be prepared and will identify lessons learned and typical costs
savings.

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1.2
TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:

       Frank Bales, Chemical Engineer, USAGE, Kansas City District
       Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
       Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
       Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
1.3
DOCUMENTS REVIEWED
          Author
                  Date
                    Title
 PTI Environmental
 Services
                  9/1992
Remedial Investigation Report, McCormick and
Baxter Creosoting Company
 US EPA
                 3/1/1996
Record of Decision, McCormick and Baxter
Creosoting Company, Portland Plant, Portland,
Oregon
 Ecology and Environment
                 10/1997
Draft Remedial Action Conceptual Site Model and
Data Gap Evaluation Report, McCormick and
Baxter Creosoting Company, Portland Plant
 US EPA
                 3/1/1998
Amended Record of Decision, McCormick and
Baxter Creosoting Company, Portland Plant,
Portland, Oregon
 ODEQ
                4/30/1998
Quarterly Progress Report for the McCormick and
Baxter Creosoting NPL site, January 1 through
March 31, 1998
 Ecology and Environment
                  3/1999
Remedial Action Groundwater Data Summary
Report, McCormick and Baxter Creosoting
Company, Portland Plant, Portland, Oregon
 Ecology and Environment
                  3/1999
Remedial Actions Semiannual Report, July 1, 1998
through December 31, 1998, McCormick and
Baxter Creosoting Company, Portland, Oregon
 ODEQ
                5/19/1999
Quarterly Progress Report for the McCormick and
Baxter Creosoting NPL site, January 1 through
March 31, 1999
 Ecology and Environment
                 11/1999
Remedial Actions Semiannual Report, January 1,
1999 through June 30, 1999, McCormick and
Baxter Creosoting Company, Portland, Oregon
 Ecology and Environment
                 4/2000
Remedial Actions Semiannual Report, July 1, 1999
through December 31, 1999, McCormick and
Baxter Creosoting Company, Portland, Oregon

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          Author
 ODEQ
                   Date

                4/27/2000
	Title	

Quarterly Progress Report for the McCormick and
Baxter Creosoting NPL site, January 1 through
March 31,2000
 Ecology and Environment
                  8/2000
Remedial Actions Semiannual Report, January 1,
2000 through June 30, 2000, McCormick and
Baxter Creosoting Company, Portland, Oregon
 ODEQ
                  9/2000
Remedial Action Report for the McCormick and
Baxter Creosoting Company Site, Portland Plant,
Interim Groundwater Treatment System Operable
Unit(OUl)
 Ecology and Environment
                  3/2001
Remedial Actions Semiannual Report, July 1, 2000
through December 31, 2000, McCormick and
Baxter Creosoting Company, Portland, Oregon
 ODEQ
                5/21/2001
Quarterly Progress Report for the McCormick and
Baxter Creosoting NPL site, January 1 through
March 31,2001
 Ecology and Environment
                  8/2001
Remedial Actions Semiannual Report, January 1,
2001 through June 30, 2001, McCormick and
Baxter Creosoting Company, Portland, Oregon
 ODEQ
                  9/2001
Draft First Five-Year Review Report for
McCormick and Baxter Creosoting Company
Superfund Site, Portland, Multnomah County,
Oregon
1.4
PERSONS CONTACTED
The following individuals were present for the RSE site visit:

       Al Goodman, RPM, USEPA Region X
       John Montgomery,  Project Manager, Ecology and Environment
       Kevin Parrett, Site Manager, Oregon Department of Environmental Quality
       Bernard Zavala, Hydrologist, USEPA Region X

In addition, the following individuals provided information to the RSE team during conference calls
subsequent to the RSE site visit:

       Susan Gardner, Sediment Engineer, Ecology and Environment
       Mark Ochsner, Project Hydrogeologist, Ecology and Environment
       Michael Easterly, Engineer, USAGE, Seattle District

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1.5           SITE LOCATION, HISTORY, AND CHARACTERISTICS

1.5.1          LOCATION AND HISTORY

The McCormick and Baxter Creosoting Company, Portland Plant, Superfund Site is located on the
Willamette River in Portland, Oregon and addresses contamination of soil, groundwater, and river
sediments from creosoting operations between 1944 and October 1991.  The site lies between a bluff and
the river and consists of 43 acres of land and over 15 acres of river sediments. The site is bordered by
industrial properties along the river and by a residential areas on the bluff. A Burlington North Railroad
spur crosses the western portion of the property, and a Union Pacific Railroad crosses the northeastern
portion of the site below the bluff. Figure 1-1 provides a map of the area.

The site consists of three operable units for addressing contamination: one each for soil, groundwater,
and river sediment. This RSE was intended to evaluate the pump-and-treat systems associated with the
groundwater operable unit; however, these aspects of the remedy have been replaced by manual
skimming of NAPL and emphasis is now placed on other components of the remedy outlined in the
ROD, such as a vertical barrier wall and a sediment cap. This RSE report, therefore, summarizes the
groundwater remedies to date but offers recommendations in line with the selected remedial actions.

1.5.2          POTENTIAL SOURCES

Operations at the McCormick and Baxter facility included use of creosote and pentachlorophenol (PCP)
in oil, as well as compounds containing chromium, arsenic, copper, and zinc. Three main source areas
exist: the tank farm area (TFA), central process area (CPA), and former waste disposal area (FWDA).
Process wastes were discharged to the TFA until  1971 and to the FWDA between  1968 and 1971. In
addition to these three primary source areas,  a number of other smaller former disposal areas were
located throughout the site, and between 1950 and 1965 wastes including creosote and PCP were applied
on site for dust suppression.  Four outfalls were in use during facility operations.  One was used for
wastewater, and three were used for stormwater.  A number of spills may have also occurred throughout
the history of the facility along the docks serving as potential sources to the existing river sediment
contamination. The locations of the primary source areas and other pertinent site features are depicted in
Figure 1-2.

Onsite soil within four feet of the surface with contamination above action levels were removed and
remaining site features were demolished in the first phase of the soil operable unit. The draft Remedial
Design Data Summary Report, E&E, November 1997, indicates that soils below the four-foot removal
level still have concentrations above the contamination action level. A soil cap will be installed upon
implementation of the groundwater remedy. An enhanced NAPL recovery system  specified in the ROD
was constructed through upgrades and enhancements to an interim groundwater treatment system
initiated in 1994 and operating at the time of the ROD. The enhanced system consisted of total fluids
extraction in the TFA at a rate of up to  10 gpm and pure-phase NAPL extraction in the TFA and FWDA
at varying rates (from January through June 1999, approximately 100 gallons of NAPL were recovered).
In September 2000, total fluids extraction and treatment and  automated NAPL recovery were
discontinued due to relatively high cost of operation for the relatively small amount of NAPL recovered.
Manual NAPL recovery with skimmers continued, however, because manual recovery provided similar
effectiveness for a lower cost.

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1.5.3           HYDROGEOLOGIC SETTING

The site is located on an area that was constructed by placement of borrowed material, perhaps including
dredged material, along mile 7 of the Willamette River during the early 1900s. The site is generally flat
and lies between a 120-foot high bluff along the northeastern border and the Willamette River to the
southwest.  A sandy beach along the river is exposed during the majority of the year but is submerged
during high river stages that typically occur in the late winter and early spring.

Surface elevations on site range from 29 to 36 feet above mean sea level (MSL) with the land surface
sloped toward the river. The site also includes 15 acres of river sediments. Fill that is composed of fine
to medium  grained sands, with areas near the TFA also consisting of sawdust and wood chips, extends
for 20 to 30 feet below ground surface. Alluvial sand and silt deposits exist beneath this fill and have a
thickness of nearly 100 feet near the bluff to the northeast and 0 feet in places near the river to the
southwest.  Beneath the silt layer is an intermediate aquifer that varies in thickness. In the central
process area it is 12  feet thick and in the TFA, where the overlying silt layer is over 100 feet thick, it is
nonexistent. Near the river, this intermediate zone is connected with the deeper zone which is primarily
alluvial sands consisting of fine to medium grained alluvial sand. This intermediate aquifer is
approximately 50 feet thick  and is hydraulically connected to the deeper aquifer near the river.

Groundwater in the area is generally 20 to 25 feet below ground surface and flows toward the river
during much of the year. Reversal of flow from the river toward  the site occurs near the river during high
water periods in the  late winter and spring when the river stage is higher than the groundwater elevation.

1.5.4           DESCRIPTION OF GROUND WATER PLUME

Current subsurface contamination at the site exists predominantly as NAPL that is migrating in
subsurface  "stringers" toward the river and is occasionally discharging into the river through seeps in the
Willamette Cove area and along the riverfront upstream from the railroad bridge. Dissolved groundwater
concentrations for all constituents are below the alternate cleanup levels for groundwater; thus, emphasis
is placed on removing and retarding migrating NAPL.  The primary visible seep is located along the
beach in Willamette Cove. Additional smaller seeps are reported along the beach on the riverfront.
Seeps are predominantly at water surface, but it is suspected that seeps may continue beneath the water
surface.

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                           2.0  SYSTEM DESCRIPTION
2.1           SYSTEM OVERVIEW

The interim remedy for the groundwater operable unit has consisted of 2 automated NAPL recovery
systems operating from 1996 to October 2000. These systems were located in the Former Waste
Disposal Area (FWDA) in the southwest corner of the site and the Tank Farm Area (TFA) about 1,000
feet to the east of the FWDA in the center of the site.  Until 1998, the TFA system was operated as a total
fluids extraction system with 3 extraction wells and included a dissolved air flotation unit (DAF) for
treatment.  The system was operated as a pilot system 40 hours/week during this time.  As this system
required extensive operating oversight without commensurate recovery advantages, it was replaced with
a system similar to that at the FWDA. These systems allowed full time automated NAPL recovery with
minimal coproduced groundwater to treat and discharge.  Both the TFA and FWDA systems then
continued operation until  September 2000 when total fluids extraction and treatment and automated
NAPL recovery were discontinued due to relatively high cost of operation for the  relatively small amount
of NAPL recovered.
2.2           EXTRACTION SYSTEM

During the last full semiannual period (first half of 2000) in which the continuous systems were run, the
FWDA NAPL extraction system included 6 extraction wells and the TFA NAPL extraction system
included 9 extraction wells. Pneumatic submersible pumps were used in each of the continuous system
extraction wells. The total fluid flow rates during this period were about 2.6 gpm for the TFA and 0.5
gpm for the FWDA.  NAPL removed during this period amounted to 136.56 gallons. During the first
half of 2001, with the continuous systems shut down and only passive collection and manual extraction,
NAPL recovery has been reduced to 10.38 gallons. This reduction in recovered NAPL could also be
partially due to drought conditions during 2001. The total amount of NAPL extracted since  recorded
collection began in December  1995 is about 2000 gallons. On average, through 2001 NAPL recovery
costs have been approximately $800 per gallon of recovered NAPL.
2.3           TREATMENT SYSTEM

Both the TFA and FWDA systems consisted of phase separation, particulate filtration, anthracite/clay
filtration, granular activated carbon adsorption and metals adsorbent resin (Aqua-Fix from ATA
Technologies). System component sizes, interconnections and controls were not examined for this effort
as operation of the systems has been suspended. During their operation weekly effluent samples were
taken from the treatment system. During the first half of 2000, each system's effluent exceeded the
copper discharge standard one time and was below the allowable pH range numerous times.

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      3.0  SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
                                      CRITERIA
3.1           CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA

The remedial action objectives as presented in the 1996 Record of Decision for each of the operable units
are summarized in the following list:

Soil Operable Unit

       Prevent human exposure through direct contact or incidental ingestion to contaminated surface
       and near-surface soil that would result in an excess lifetime cancer risk above 1 x 10~6 for
       individual compounds; above 1 x 10~5 for additive carcinogenic compounds; or above a Hazard
       Index of 1 for noncarcinogenic compounds in an industrial land use scenario.

•      Prevent storm water run-off containing contaminated soil from reaching the Willamette River.
Groundwater Operable Unit

•      Prevent human exposure to or ingestion of groundwater with contaminant concentrations in
       excess of federal and state drinking water standards or protective levels.

•      Minimize further vertical migration of NAPL to the deep aquifer

•      Prevent groundwater discharges to the Willamette River that contain dissolved contaminants that
       would result in contaminant concentrations within the river in excess of background
       concentrations or in excess of water quality criteria for aquatic organisms.

•      Minimize NAPL discharges to the Willamette River beach and adjacent sediment to protect
       human health and the environment.

•      Remove mobile NAPL to the extent practicable to reduce the continuing source of groundwater
       contamination and potential for discharge to the Willamette River sediment.
Sediment Operable Unit

•      Prevent humans and aquatic organisms from direct contact with contaminated sediment.

•      Minimize releases of contaminants from sediment that might result in contamination of the
       Willamette River in excess of federal and state ambient water quality criteria.

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3.2
OPERABLE UNIT CLEANUP GOALS
The cleanup levels as presented in the September 2001 5-year review for each of the operable units are
summarized below:

Soil Operable Unit
Contaminant
arsenic
PCP
carcinogenic PAHs
dioxin/furans
Cleanup Goal
(mg/kg)
8
50
1
4xlO'5
Groundwater Operable Unit

Because of the extensive NAPL contamination, it is not technically practicable to restore the
groundwater under the site to drinking water quality; therefore, site-specific alternate concentration limits
(ACLs) for the contaminants that are consistent with CERCLA Section 121(d)(2)(B)(ii) and are
protective of the environment were developed.
Contaminant
total PAHs
PCP
dioxin/furans
arsenic, chromium, copper, and zinc
Cleanup Goal
(mjj/L)
43
5
2xlO'7
1 (each)
Sediment Operable Unit
Contaminant
arsenic
PCP
carcinogenic PAHs
dioxins/furans
Cleanup Goal
(mg/kg)
12
100
2
0.008

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    4.0  FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1           FINDINGS

The RSE team found that operation of the two automated NAPL extraction systems and the total fluids
extraction system had been suspended for valid reasons. The EPA, Oregon DEQ and contractor Ecology
& Environment considered the effectiveness of the systems in meeting the ROD goals versus the cost to
continue to operate the system.  They determined that the systems provided minimal benefit above
skimming and manual removal but cost twice as much. The group is currently considering a barrier wall,
sediment cap, and cutoff trenches to intercept NAPL seeps.
4.2           SUBSURFACE PERFORMANCE AND RESPONSE

4.2.1          WATER LEVELS

Monitoring wells that contain LNAPL and DNAPL are gaged on a weekly basis for NAPL. Wells which
have not historically contained NAPL are gaged monthly. The gaging events include over 50 wells.
Water level measurements indicate that shallow groundwater generally moves from the site towards the
river, but gradient reversals occur near the river with rising river levels. Daily groundwater fluctuations
of several feet are common in wells due to river elevation changes and precipitation.

Hydraulic containment of groundwater beyond several feet from an extraction well was not part of the
automated system goal, and the minimal volume extracted by the systems did not influence overall site
groundwater flow or NAPL seepage. NAPL seeps from the subsurface to the Willamette River have
been observed sporadically at the site. No seepage had been noted by site managers for a few years, but a
seep of over 100 feet in length along the beach in the Willamette Cove area was noted in May 2001 and
has continued throughout the summer.

NAPL thicknesses and the number of wells containing NAPL have decreased substantially since removal
efforts began. In June 2001, LNAPL was present in 15 of the 40 wells gaged with an average thickness
in the 15 wells of approximately 0.4 feet. The highest measured thickness was 1.54 feet, which was
measured in a well in the FWDA. The other two highest measured thicknesses were 0.98 and 1.47 feet,
both of which were measured in wells in the TFA.

4.2.2          CONTAMINANT LEVELS

Groundwater samples are collected semiannually from about 12 monitoring wells in the shallow,
intermediate and deep groundwater zones. Samples are analyzed for metals and SVOCs including PCP,
with select analysis for dioxin/furan compounds. During the last 2 sampling events, ACLs were
exceeded once for zinc in one well and once for total PAHs in another well.  ACLs for this site are at
relatively high levels due to site specific characteristics.  The ACL for total PAHs of 43 mg/1 is not likely
to be exceeded unless NAPL is directly impacting the sample.

NAPL contamination exists throughout the site but primarily in the TFA and FWDA. Migration of
NAPL offsite is also evident in active seeps, especially into Willamette Cove, and in sediment cores from

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the remedial investigation in 1992. Quantitative analyses of sediment cores revealed concentrations as
high as 8,200 mg/kg for low molecular weight PAHs and 2,000 mg/kg for high molecular weight PAHs
approximately 200 feet from the shore and at a depth of approximately 9 feet (core K6c).  Qualitative
analyses reported evidence of creosote contamination (either sheen or odor) at depths exceeding 40 feet
below the river bed (cores K5C, L1C, and L5C).
4.3           COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
              MONTHLY COSTS

Currently about $5,000 per month is spent on NAPL gaging and collection activities. This is the majority
of the approximately $100,000 per year being spent on site O&M activities. The balance is spent on
semiannual reporting and project management.  During the operation of the automated systems more than
$200,000 additionally was required for O&M. This sum was necessary even after the dissolved air
flotation (DAF) treatment was abandoned to reduce operating costs.

The site has a budget of $1.3 million for design from July 2001 through the end of the design, including
project administration, community involvement, and cultural resources. These costs should take the
project through the final design, including procurement, contract language, and a package for bidding. A
health and safety plan would then be made site specific for additional cost. Including the pre-July 2001
design costs, the total cost of design is approximately $2 million. The total estimated cost for the barrier
wall is $2.5 million and for the sediment cap is $4.2 million (including bulkhead removal, mobilization
and demobilization, monitoring well abandonment, removal of pilings, a sand cap, armoring, regrading
the steep parts of the  shoreline, administration, oversight, construction documents, and a 45%
contingency.

Thus, the estimated design costs by the end of 2001 will be approximately 30% of the cost. At the time
of the RSE in late August 2001, however, the material for the sediment cap and wall as well as many
other design details had not yet been determined suggesting the likelihood that additional design costs
will be incurred in 2002 potentially increasing design costs well beyond the current 30%.
4.4           RECURRING PROBLEMS OR ISSUES

NAPL discharge to the river sediment has not been controlled by the remediation efforts based on visual
observation and sediment sampling data.
4.5           SAFETY RECORD

A fire unrelated to site activities occurred in 2001 along the railroad line along the bluff to the northeast
of the site. No injuries associated with this fire or site activities have been reported.
                                             10

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     5.0  EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
                      HEALTH AND THE ENVIRONMENT
5.1
GROUND WATER
Groundwater at the site is impacted by site-related contamination but is not used for drinking water.
Contaminated groundwater is generally below the site-specific ACLs. The following table presents the
results from water quality monitoring in wells along the riverfront or Willamette Cove.
ACL
EW-19s
MW-LRs
MW-3s
MW-4s
MW-81
MW-131
MW-25s
MW-35s
Arsenic
(ug/L)
1,000
40
14
3.5
9.5
180
26
20
1U
Copper
(ug/L)
1,000
2U
9
2U
2U
2.06
2U
2U
1U
Chromium
(ug/L)
1,000
1U
1U
1.7
1.7
1.2
1.3
2U
1U
Zinc
(ug/L)
1,000
5U
5U
5
5U
5U
5U
5U
5U
PCP
(ug/L)
5,000
530J
100UJ
1U
1U
2,500UJ
1U
7J
1U
PAHs
(ug/L)
43,000
6,OOOJ
5,600J
0.1
24
108,000
0.5
2,200
0.2U
CPAHs
(ug/L)
-
5J
0.3J
0.2U
0.2U
46J
0.2U
1UJ
0.2U
TCDD
(ug/L)
2xl04
2xl04
5xlO'5
-
-
-
-
-
-
U = compound was analyzed for, but not detected. The corresponding value is the reporting limit.
J = concentration value is estimated
TCDD = 2,3,7,8 tetrachlorodibenzo-p-dioxin toxic equivalency quotient by EPA method 1613
5.2
SURFACE WATER
The ODEQ site manager indicated that surface water sampling above the river sediments showed
contaminant concentrations below the ambient water quality criteria. Sporadic seeps of NAPL along the
beach, however, provide a continuing source of contamination to river sediments and surface water along
the site. The seeps appear limited to the shoreline but may exist in areas that are submerged throughout
the year.
5.3
AIR
Air is not directly impacted by site activities.
                                             11

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5.4           SOILS

Surface and subsurface contaminated soils to a depth of 4 feet have been removed through excavation
activities and offsite disposal. The final phase of the soil operable unit (i.e., the soil cap), however, will
not be installed until the groundwater remedy is implemented.  Subsurface soil is still a source of
dissolved contamination of groundwater.  This contamination is evident at various locations along the
beach within a few inches of the surface.
5.5           WETLANDS AND SEDIMENTS

Approximately 15 acres of river sediments are impacted by site-related contamination.  Some of this
contamination may result from historical spills during unloading operations at the former docks and other
sediment contamination results from NAPL seeps.
                                             12

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                             6.0  RECOMMENDATIONS
The RSE team found the site management dedicated to success of the remedial action and eager to
receive technical assistance in considering the remedial strategy for the site.  In consultation with the site
contractor, the site management suspended operation of the automated NAPL collection systems as they
were ineffective in achieving the Remedial Action Objectives and opted to continue with the less costly
passive and manual NAPL collection. In considering the future course of the site and potential remedial
strategies, the site management enlisted a permeability modeler from USAGE and openly welcomed and
encouraged the RSE team's contributions during and after the RSE site visit and subsequent conference
calls.
6.1           CONTRIBUTION OF RSE TEAM TO DISCUSSIONS REGARDING
              REMEDIAL DESIGN

Because site activities no longer include an operating pump-and-treat system, the RSE team provides
recommendations regarding alternate remedial strategies with focus on improving effectiveness, reducing
life-cycle costs, and gaining site close-out. Many of these recommendations occurred during discussions
with site managers at the site visit and in subsequent conference calls and took the form of both
constructive criticism of proposed strategies and contribution of additional strategies.

Because groundwater sampled without the presence of NAPL meets ACLs, the primary concern
for the site managers and the RSE team is to determine a cost effective strategy for preventing the
migration of NAPL into the Willamette River and reducing exposure to contaminated sediments. Below
are descriptions of the predominant strategies  discussed by the site managers and the RSE team. These
descriptions represent the collective thoughts of the site managers, engineers, and RSE team as discussed
over the course of the RSE. They are not the sole ideas and/or recommendations of the RSE team.

Vertical Barrier Wall: A vertical barrier is being considered by the site managers to prevent migration
of LNAPL and to some extent DNAPL, from the source areas.  Downgradient (partially encompassing)
or totally enclosing configurations have been discussed for the application.  The totally enclosing
configuration could increase the cost by approximately $500,000 but offers no tangible benefit over the
downgradient location. A totally encompassing wall may even require more maintenance than a partially
enclosing wall because water would potentially have to be extracted and treated from the totally
encompassing wall to offset natural recharge.  A groundwater model for the site, however, suggests such
extraction would not be necessary due to a lack of a competent aquitard in the FWDA.  Wells or drains
upgradient of the wall can be used to help collect product although barrier walls do not necessarily
increase the ability for NAPL extraction.

       Advantages: A properly constructed barrier wall may provide containment of LNAPL on the
       former McCormick and Baxter property at a low maintenance cost.

       Disadvantages: A significant but unqualified percentage of mobile NAPL has already migrated
       past the wall location and could continue to discharge to the river for several years after wall
       installation.  In some areas, including  the FWDA and 100 feet between MW26s and MW-30s
       (according to Figure 4-25 in the  1992  Remedial Investigation Report), a barrier wall cannot be
       keyed into an underlying low permeability layer since none exists, and DNAPL migration in

                                              13

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       these areas will not be controlled. With the wall in place, DNAPL migration to the river should
       be limited because the wall (which extends 48 feet below mean sea level) is designed to be
       deeper than the bottom of the navigation channel in the river (40 to 43 feet below mean sea
       level).

       Cost estimates: As presented by the site managers and engineers, a downgradient (partially
       encompassing) slurry barrier wall over 2,000 feet in length and up to 80 feet deep is estimated to
       cost approximately $2 million and a sheet pile barrier wall with a similar configuration is
       estimated to cost approximately $3 million.

Permeable Sediment Capping: A permeable sediment cap with dredged material from the Columbia
River has been considered by the site managers to cover contaminated river sediments and prevent
exposure to contaminants.

       Advantages: Dredged material from the Columbia River could be  used as a permeable sediment
       cap that would cover contaminated sediment, effectively preventing exposure, at least
       temporarily, to sediments contaminated by previous spills of wood treating chemicals.

       Disadvantages: Permeability modeling conducted by USAGE indicates that in areas of NAPL
       seeps, breakthrough of NAPL through such a cap would likely occur in two months to two years.
       Thus, in areas where sediments are contaminated by seeps, regular dredging, offsite disposal, and
       replacement of cap material may be required.  In addition, evidence suggests that both scour and
       sediment deposition occur in the areas where the cap would be placed.  Thus, the potential exists
       for contaminated sediments to be re-exposed after cap placement.

       Cost estimates: Based on a rough cost of $30 per cubic yard and a 3-foot sediment cap that
       covers  15 acres, a permeable  sediment cap will cost approximately $2 million. The costs of
       regular maintenance would be dependent on the area of the cap that will be compromised by
       breakthrough of NAPL seepage, on rate with which this breakthrough occurs, and on the rate of
       scouring of cap material.

Targeted Sediment Cap: Also under consideration is a sediment cap  made predominantly of permeable
material but consisting of another material in targeted NAPL seepage areas. Three options were
proposed for the seepage-area material: semi-impermeable dredged materials from the Willamette River,
organophyllic material (adsorptive materials), and impermeable material. Each of these options is geared
toward trading  upfront costs in cap construction for a reduction in costs associated with regular
maintenance or replacement of cap materials due to NAPL breakthrough in the seepage areas.  Because
an impermeable cap would require submerged drains to prevent migration around the impermeable
material and such drains may be challenging to construct and maintain given the debris in the river during
high water periods, the site managers are not considering an impermeable cap.

       Advantages: A targeted cap could accomplish the exposure prevention goal, at least temporarily,
       and may reduce the frequency of replacing cap materials in NAPL  seepage areas.

       Disadvantages: Issues with construction are the primary concern because semi-impermeable
       material will likely include silts or fine sands that may be difficult to place on the river bed. In
       addition, if the semi-impermeable material is significantly less permeable than the surrounding
       material, then the NAPL may migrate around the semi-impermeable material as it would with an
       impermeable cap. Like the semi-impermeable material, the adsorptive materials could be
                                              14

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       scoured if proper armoring is not included. The adsorptive materials are also significantly more
       expensive than semi-impermeable dredged material.

       Cost estimates: The costs associated with this option have not been quantified.

Cutoff Trenches: Cutoff trenches installed along the shore are under consideration to prevent further
migration of NAPL that would be beyond the reach of an installed barrier wall. NAPL in these trenches
could either be collected with adsorptive material or possibly through manual collection through sumps.

       Advantages: A distance of up to 50 feet would separate the proposed barrier wall and the
       riverfront. This option may help both with containment and collection of NAPL in that area at
       depths of up to 10 feet, thereby potentially reducing or eliminating NAPL seeps through the river
       sediments.

       Disadvantages: Regular maintenance of such trenches would be required. These trenches or
       drains would be submerged during high water periods making maintenance difficult during those
       periods.  The sump risers would have to be protected. The use of adsorptive material would
       increase the costs of the trenches both for the initial construction and for the periodic
       replacement of the adsorptive material.

       Cost estimates: Installing trenches approximately 300 feet long and 20 feet deep with a
       perforated header and sumps  could be installed with standard equipment and costs less than
       $150,000. Shallower trenches would cost less. Maintenance costs will depend on the amount of
       NAPL that is collected and disposed of offsite.

Hydraulic Control: Control of LNAPL migration is possible if enough groundwater is withdrawn from
the aquifer to  form a capture zone at the TFA and FWDA. The volume pumped would be significantly
greater than the discontinued system treated.  Treating a greater volume of groundwater was previously
pilot tested  at the site and discontinued due to the amount of operator attention required.  Constructing
and operating a full scale treatment system would be extremely expensive, and DNAPL migration would
not be addressed by the hydraulic control.
6.2           DECISION OF THE SITE MANAGERS

The site managers (ODEQ and EPA Region 10) are seriously considering a combination of the above
strategies.

According to the site managers, a barrier wall will be installed and will likely have a configuration
similar to that shown in Figure 1-2.  It will be keyed into the low permeability layer in most areas where
one exists but will be "hanging" in areas like the FWDA where the low permeability layer does not exist.
The site managers expect the wall to contain the unquantified amount of NAPL remaining onsite.
Efforts, however, may be required to prevent migration of NAPL through the "hanging" portions of the
wall.  Due to the  lower installation costs, site managers will likely have the wall constructed of a
bentonite slurry rather than sheet piling.

Because the planned barrier wall will be approximately 50 feet from the from the edge of the river and
500 feet from the outer limit of the NAPL contaminated sediments, a significant amount of mobile NAPL
may exist beyond the influence of the wall and may continue to impact the river through seeps. To
contain some of this NAPL, interceptor trenches may be  installed along the beach in both the Willamette

                                              15

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Cove area and along the river front. These trenches, if installed, would be approximately 10 feet deep
and 40 feet long, filled with an adsorptive/sequestering material, and then capped. It is assumed that no
further O&M would be required with the exception of occasionally collecting bore samples to determine
the remaining capacity of the material.  Eventual replacement of this material may be required when it
has reached its adsorptive capacity.

Finally, a sediment cap will be installed to prevent exposure to contaminated sediments. Site managers
are considering a cap primarily constructed of readily available, permeable material with semi-
impermeable material in the NAPL seep areas in the Willamette Cove, adsorptive material in the NAPL
seep areas along the riverfront, and armoring to prevent scouring.  The performance of these materials
would be evaluated during O&M and future modifications and replacement of compromised cap material
would be made based on lessons learned from these evaluations.

Thus, based on the costs estimates provided by the site managers and contractors, the groundwater and
remedial strategies selected by the site managers will likely exceed $7 million to implement. Additional
costs, similar to those currently incurred (approximately $100,000 per year), likely will be necessary for
gaging monitoring points, project management, and reporting.
6.3           ADDITIONAL RECOMMENDATIONS FROM THE RSE TEAM

The following recommendations are made subsequent to the RSE visit and conference calls with the site
managers and are also aimed at improving effectiveness, reducing life-cycle costs, and gaining site
closeout.

6.3.1          IMPLEMENT STRATEGIES IN PHASES WITH DEFINED SCHEDULES AND BUDGETS

Consistent with the site management's decision, the RSE team recommends a phased approach to
implementing these strategies as construction or implementation of one element may change the design
parameters of the other units or yield valuable site information pertinent to the implementation of the
other elements. For example, construction of the barrier wall may indicate the vertical extent and
location of NAPL seeps.  Such information would be useful in the  final design and implementation of
possible cutoff trenches or the sediment cap. Such information would also be useful in designing a
monitoring program for evaluating the effectiveness of the implemented strategies. Given the timeframe
of implementation presented by the site managers, the barrier wall will hopefully be installed in Spring of
2002, and installation of the cap may wait until the winter or the following summer. Thus, ample time
will be available to incorporate information gained through wall construction or through monitoring of
site conditions after the wall is constructed.

A work plan including key activities and decision points schedules, design budgets, and construction cost
estimates should be developed if it has not been already.

6.3.2          TAKE AN EXPERIMENTAL APPROACH AND APPLY LESSONS LEARNED

The RSE team agrees with the site managers that lessons learned at various stages of the project should
be incorporated in future  modifications.  Applying knowledge learned from the construction of the
barrier wall to the construction of the  sediment cap or potential intercept trenches (as discussed in
Section 6.3.1) serves as an example of this approach. However, an initial approach should be agreed
upon and implementation begun since at this point characterization and research are as complete as
feasible.

                                             16

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Monitoring and evaluation of site conditions after the wall and cap are in place will improve
characterization and also provide lessons for future modifications, if needed. For example, the seep
locations have not been fully characterized because areas contaminated by spills and by seeps cannot
easily be distinguished. If a properly constructed sediment cap is chosen, implemented, and monitored,
then exposure to river sediments contaminated by spills should be significantly reduced or eliminated.  If
the seeps continue after the installation of the barrier wall, then the locations where the surface of the cap
material is contaminated should indicate seep areas. A monitoring program should therefore indicate the
location of the seeps and the approximate time to breakthrough, providing additional information for
determining the best approach for addressing the seep areas in the future. If seep areas are found to be
limited to shallow areas, shallow intercept trenches may be effective at capturing the migrating NAPL.
However, if seep areas are prevalent throughout the cap area, another approach may be beneficial, such
as an impermeable cap with drains installed to prevent migration around the cap.

Caution should be given to drawing conclusions from  uncontrolled experiments such as using various cap
materials in different locations. For example, the adsorptive material proposed for the cap along the
riverfront may appear to outperform the dredged material from the Willamette River for the Willamette
Cove area.  However, this difference in performance could be due to the characteristics specific of the
respective seeps rather than the materials.

6.3.3           EXPAND PERMEABILITY MODELING AND CONDUCT A COST BENEFIT ANALYSIS OF
               VARIOUS SEDIMENT CAPS

Permeability modeling has been conducted for a cap constructed from dredged material  from the
Columbia River and three model scenarios: a fixed NAPL seepage rate, NAPL driven by groundwater
flux, and NAPL driven by buoyancy. Due to a lack of reliable data available on the properties of the
NAPL, NAPL saturation, and the seepage rate at the McCormick  and Baxter site, a number of
assumptions were used in deriving the modeling parameters. The groundwater flux scenario, did
however, use information obtained from a site-specific groundwater flow model. These assumptions
have resulted in a relatively broad range of expected time for NAPL to breakthrough the cap (ranging
from 2 months for NAPL driven by buoyancy to 2 years for NAPL driven by groundwate flux).
Although broad, this range of breakthrough times does assist in determining the appropriate cap.

A couple of additional inexpensive (i.e., less than $10,000 total) simplistic studies with the same model
should be conducted to determine the sensitivity of NAPL breakthrough time with respect to cap
material, with special attention to the finer cap material proposed for use in the Willamette Cove area and
the adsorptive material proposed for the riverfront. The results of such studies would assist in a cost-
benefit analysis of various caps.

A cost-benefit analysis should be conducted to help determine the best cap material. The primary factors
in this analysis should include the following parameters:

•      initial cost of installation

•      estimated time to breakthrough

•      estimated replacement costs as a function of area requiring replacement and material to  be
       replaced

Assuming each material is replaced sufficiently often to maintain effectiveness, the cap material (e.g.,
dredged material from Columbia River or Willamette River dredge or adsorptive material) with  the


                                              17

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lowest life-cycle cost will likely be the best choice for the sediment cap.  Such an analysis may or may
not indicate that the upfront costs of an adsorptive material may sufficiently reduce the frequency of
replacement in seep areas such that life-cycle costs associated with this material are less than life-cycle
costs associated with a material requiring more frequent replacement.

It should be noted that this cost-benefit analysis and the currently employed permeability model can only
be used as a tool to provide estimates.  Certain assumptions used in the modeling may turn out to be false
and factors not considered in model development may affect the results.  For example, if the fine
materials used from the Willamette River dredged material are placed over seep areas and have a
hydraulic conductivity significantly lower than that of the surrounding cap material (e.g. sand from
Columbia River dredged material) then a substantial portion of the NAPL may migrate around this more
impermeable material as it would with a fully impermeable cap. In addition, the seep areas have not been
and likely will not be completely defined before installation of the cap, and even if they are, conditions
may change after installation of the wall or with variations annual rainfall.
6.4           UNUSED EQUIPMENT

With the termination of the NAPL collection systems and the total fluids extraction and treatment, the
site may have government-owned equipment that is no longer required for site activities. If continued
use of government-owned equipment is no longer required, the site managers should consider making it
available to other Fund-lead sites. USAGE has a program designed to help the transfer of unused
government equipment from Fund-lead sites to other Fund-lead sites where the equipment can be used.
The contact for this program is

Lindsey K. Lien, PE
U.S. Army Corps of Engineers
12565 West Center Road
Omaha, NE 68144-3869
(402)  697-2580
Lindsey.K.Lien@nwd02.usace.army.mil
                                              18

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                                     7.0  SUMMARY
The RSE process for the McCormick and Baxter site succeeded in providing recommendations to
improve effectiveness and reduce life-cycle costs.  These recommendations applied to the site as a whole
rather than to the extraction and treatment systems which had been discontinued.  Given that site
managers were engaged in determining the alternate remedial strategies to be employed to at the site, the
RSE team provided recommendations with respect to these strategies.  Many of the recommendations
occurred during discussions with site managers during the site visit and in subsequent conference calls
and took the form of both constructive criticism of proposed strategies and contribution of additional
strategies.

The RSE team also encourages implementing strategies in a phased approach with defined schedules and
budgets, conducting detailed cost-benefit analyses various options, and applying knowledge learned from
monitoring and evaluation to future modifications to the remedy. Because  decisions regarding the future
remedial strategies at the site were arrived through group discussions between site managers, site
engineers, and the RSE team, the RSE team cannot be credited with the final decision or specific aspects
of the proposed solution.  Rather, the RSE team can be credited with assisting the site managers by
providing an independent review of proposed strategies and offering expertise and knowledge gained
from other sites.
                                               19

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FIGURES

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                FIGURE 1-1. A MAP OF THE McCORMICK AND BAXTER PROPERTY AND THE SURROUNDING AREA.
                                                                        McCORMICK & BAXTER I    S
                                                                               SITE
                     SCALE IN  FEET
(Figure Modified from Figure 1-1 of the McCormick and Baxter Creosotiiig Company Remedial Investigation Report, PTI Environmental Services,
September 1992).

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  FIGURE 1-2. LAYOUT OF THE McCORMICK AND BAXTER PROERTY INDICATING FORMER FACILITY STRUCTURES, PRIMARY CONTAMINANT SOURCE
  AREAS, PERTINENT SITE FEATURES, AND APPROXIMATE LOCATION OF THE PROPOSED VERTICAL BARRIER WALL.
                            BUNKER
                              OIL
                             AREA
                                                            TREATED
                                                             LOG
                                                            STORAGE
TREATED
  LOG
STORAGE
                                                            RETORT 2
                                                           i-RETORT 1
                                                                                SITE BOUNDARY
                                                                       PENTACHLOROPHENOL
                                                                          MIXING SHED
                                                                                   SOUTHEAST WASTE
                                                                                   DISPOSAL POND
                                                                                   AND TRENCH
                                    CELLON AREA
                                       WASH
                                                                             PROPOSED  BARRIER
                                                                             WALL LOCATION
                                                                  TANK FARM
                                                                  AREA (TEA)
                                                   CENTRAL
                                                   PROCESS
                                                     AREA
                                                                       McCORM CK & BAXTER S TE
                                                                CREOSOTE
                                                                  TANK
                                                              PENTACHLOROPHENOL
                                                                 STORAGE AREA
                                      HAZARDOUS
                                        WASTE
                                       STORAGE
                                        AREA
                                             NAPL SEEP
                                               AREA  ..
                       FORMER  *.
                       DISPOSAL
                      LOCATION-
                                                                                                     OUTFALL 004
                                                                                                     (STORM WATER)
                                                      OUTFALL 003
                                                      (STORM  WATER)
                                                              OUTFALL 001
                                                            !(COOLING WATER)
                                                                                          WILLAMETTE  RIVER
                     FORMER
                      WASTE
                   DISPOSAL AREA
                      (FWDA)
                                                                                    LEGEND

                                                                                    SITE FENCING

                                                                                    GRAVEL AREA

                                                                                    EXISTING STRUCTURE
                                           OUTFALL  002
                                          (STORM WATER)
                             NAPL SEEP
                               AREA
            ROCK ISLAND
             (SEASONAL)
                                                                           SCALE  IN FEET
WILLAMETTE
COVE NAPL !
  SEEP
         I
                                                                                                               FORMER STRUCTURE
                                                                                                               OR AREA
(Figure compiled from Figure 1-2 of the McConnick and Baxter Creosoting Company Remedial Investigation Report, PTI Environmental Services, September 1992
and Figure 1-3 of the Record of Decision, McConnick and Baxter Creosoting Company Superfund Site, Portland, Oregon, March 1996).

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                                                             Solid Waste and
                                                             Emergency Response
                                                             (5102G)
542-R-02-008r
October 2002
vwwv.clu-in.org/rse
www.epa.gov/tio
U.S. EPA National Service Center
for Environmental Publications
P.O. Box 42419
Cincinnati, OH 45242-2419

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