First Five Year Review Report
for
Ruston/North Tacoma Superfund Site
Ruston and Tacoma, Washington
March 2000
Prepared by:
Region 10
United States Environmental Protection Agency
Seattle, Washington
Approved by: Date:
MicnaeJ F. Gearheard, Director
Environmental Cleanup Office
USEPA Region 10
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Executive Summary
This report is the first five year review for the Ruston/North Tacoma Superfund site (site) which
is located in Ruston and Tacoma, Washington. The site is part of the larger Commencement Bay
Nearshore/Tideflats Superfund site. The Environmental Protection Agency (EPA) is required by law to
conduct this review at least every five years after the beginning of cleanup activities. Cleanup actions at
the site were started in the Spring of 1994. The purpose of the review is to determine whether the
remedy at the site remains protective of human health and the environment.
The site includes approximately 950 acres and comprises an arc of approximately one mile
radius around the Asarco Tacoma smelter (smelter). It consists of the Town of Ruston and a northern
portion of the City of Tacoma, Washington. Land use is primarily residential and includes schools,
playgrounds, and parks. The site includes an estimated population of approximately 4,290 people, and
about 1,820 housing units. Contamination at the site is the result of airborne emissions from smelting
operations and consists primarily of arsenic and lead in surface soils. Smelter slag has also been used by
residents in various applications.
The Record of Decision for the site was signed on June 16, 1993. The goal of the cleanup
actions is to reduce potential exposure by community residents to arsenic and lead contaminated soil,
dust, and slag. EPA and Asarco signed a Consent Decree in May 1995 under which Asarco is
conducting soil sampling and cleanup actions. Soil in excess of the action levels is being excavated and
replaced with clean soil. The action levels are 230 parts per million (ppm) arsenic and 500 ppm lead.
Slag, where it is used in driveways, walkways or other areas as crushed rock, is also being removed. In
areas where soil arsenic concentrations are between 20 ppm - 230 ppm, and lead concentrations are
between 250 ppm - 500 ppm, residents are being provided with educational information on steps that
they can take to reduce potential exposure to this residual contamination. A workgroup, called the
Program for Area Cleanup Education (PACE), is responsible for developing the educational program
and materials.
Properties are first sampled to determine whether they need to be cleaned up, and to what
extent and depth. Excavated soil is then replaced with clean dirt, and properties are landscaped.
Property owners provide permission for the initial sampling, and Asarco coordinates with the owners
on all cleanup and landscaping activities.
The site was divided into four areas or zones. Sampling and cleanup efforts are proceeding
from the most to least contaminated areas. Sampling in zones 1-3 was completed in 1999. Cleanup in
zones 1-3 will be completed in 2003. Sampling of properties in zone 4 has not yet been completed. It is
too early to predict when cleanup in that area will be completed.
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This five year review was prepared by the EPA and reviewed by the Department of Ecology,
the PACE workgroup, several local residents, and others involved in the cleanup process. Findings of
the five year review include the following:
The overall status and progress of the project is consistent with the expectations of the Record
of Decision.
Sampling of individual properties as well as replacement soil and sod has been done in
accordance with the project sampling and analysis plan.
Soil removal and backfill activities are being accomplished in accordance with the Record of
Decision.
Asarco and its contractors are working cooperatively with property owners to resolve any site
specific cleanup issues as they arise.
Community relations activities conducted by Asarco as well as the overall educational program
being implemented by the PACE workgroup is consistent with the Record of Decision.
There is currently no new information about arsenic or lead exposure or toxicity that warrants
reconsideration of the current site action levels for arsenic and lead.
The following recommendations and follow-up actions were noted during the five year review:
Asarco should track property owners who have refused access for sampling or cleanup and
periodically contact those individuals to determine if they have changed their minds.
A subset of properties which have already been cleaned-up should be re-sampled for the
purpose of identifying whether recontamination is a potential issue at the site.
Prior to completion of the cleanup EPA will make a determination about how to address soils in
the steeply sloped area surrounding the Burlington Northern railroad tracks.
EPA will continue to monitor evolving information regarding arsenic toxicity as well as general
changes in risk assessment guidance and policies. If views on arsenic exposure and resulting
risk change significantly, a revised risk assessment may be warranted to determine if changes to
the arsenic action level should be considered.
Overall, the remedy at the Ruston/North Tacoma Superfund site is expected to be protective of
human health and the environment upon completion by achieving the cleanup goals as identified in the
Record of Decision. The site requires ongoing five year reviews. The next review will be conducted
within five years of the completion of this five year review report.
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Table of Contents
Executive Summary
I. Introduction 1
II. Site Chronology 1
III. Background 3
IV. Remedial Actions 5
A. Remedy Selection 5
B. Remedy Implementation 8
1. Sampling Program 8
2. Soil Removal and Backfill Activities 8
3. Community Protection Measures Program 9
C. Operations and Maintenance 9
V. Five Year Review Process 10
VI. Five Year Review Findings 11
A. Overall Status of the Project 11
B. Sampling Program 12
C. Soil Removal and Backfill Activities 12
D. General Community Relations Activities and PACE
Program 14
E. Risk Information Review 18
VII. Assessment 19
A. Overall Status of the Project 19
B. Sampling Program 19
C. Soil Removal and Backfill Activities 19
D. General Community Relations Activities and PACE
Program 21
E. Risk Information Review 21
VIII. Recommendations and Follow-Up Actions 23
IX. Protectiveness Statement 23
X. Next Review 23
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First Five Year Review Report
Ruston/North Tacoma Superfund Site
Ruston and Tacoma, Washington
I. Introduction
The United States Environmental Protection Agency (EPA) Region 10 has conducted the first
five year review of the remedial actions implemented at the Ruston/North Tacoma site in Ruston and
Tacoma, Washington. The Ruston/North Tacoma site is an operable unit of the Commencement Bay
Nearshore/Tideflats (CB N/T) Superfund site. Each part of the CB N/T site is being treated as a
separate site by EPA Region 10 for the purpose of conducting five year reviews. This review was
conducted from January through March, 2000. This report was prepared by the EPA to document the
results of the review. Asarco Incorporated, the responsible party, as well as CH2M Hill, EPA's
oversight contractor, provided information used in preparation of the five year review.
The purpose of this five year review is to determine whether the remedy at the Ruston/North
Tacoma Superfund site will be protective of human health and the environment upon completion. The
methods, findings, and conclusions of the review are documented in this five year review report. In
addition, this report identifies any deficiencies found during the review, and recommendations to
address them.
This review is required by statute. EPA must implement five year reviews consistent with the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA and the NCP
require that a remedial action that results in any hazardous substances, pollutants, or contaminants
remaining at the site shall be reviewed no less often than each five years after the initiation of such
remedial action to assure that human health and the environment are being protected.
This is the first five year review for the Ruston/North Tacoma site. Remedial actions at the site
were initiated in the Spring of 1994. The review is necessary as elevated levels of arsenic and lead will
remain on site in soil in residential yards.
II. Site Chronology
Below is a table which identifies important events and relevant dates at the Ruston/North
Tacoma Superfund site. Interest in the impact of smelter operations on the surrounding residential
community was piqued in the early 1970's, resulting in numerous studies being conducted throughout
the 70's and 80's. As those efforts were numerous, only those studies conducted after NPL listing,
which formed the basis for taking cleanup actions at the site, will be identified below. These studies will
be further discussed in Section HI below.
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Event
Date
NPL Listing
September 1983
Exposure Pathways Study
March 1987
Field Investigation Report, Endangerment
Assessment, and Engineering Evaluation/Cost
Analysis
September 1988
Urinary Arsenic Survey
December 1988
Administrative Order on Consent for Expedited
Response Action
March 1989
Formation of Ruston/North Tacoma Community
Workgroup
Fall 1989
Formation of Ruston/North Tacoma
Coordinating Forum
March 1991
Remedial Investigation, Feasibility Study, and
Risk Assessment
January 1992
Preliminary Remedial Action Objectives
Decision Memorandum
January 1992
Record of Decision (ROD)
June 1993
Unilateral Administrative Order for Remedial
Design/Remedial Action
August 1993
Formation of Community Protection Measures
Workgroup
Fall 1993
Explanation of Significant Difference
November 1993
Remedial Action Start
Spring 1994
Consent Decree for Remedial
Design/Remedial Action
May 1995
Estimated Remedial Action Completion
2003 for properties in zones 1-3 (see
Attachment 1). Unable to estimate completion
date for properties in zone 4 until sampling in that
area is finished.
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III. Background
The Ruston/North Tacoma Study Area, approximately 950 acres, comprises an arc of
approximately one mile radius surrounding the Asarco Tacoma smelter (Asarco smelter) and consists of
the Town of Ruston and a northern portion of the City of Tacoma, Washington (see Attachment 2).
The smelter began operations in 1890 as a lead smelter. Asarco purchased the smelter in 1905
and converted it to a copper smelter in 1912. The smelter specialized in processing ores with high
arsenic concentrations and recovered arsenic trioxide and metallic arsenic as by-products. Operation of
the Asarco smelter for over 95 years resulted in contamination, primarily arsenic and lead, of the
surrounding area. That contamination was the result of airborne emissions from smelting operations. In
recovering copper from ores and concentrates, the smelting process also produced slag, a hard, glassy
material containing elevated concentrations of arsenic, lead, and other metals. Smelter slag has been
used in various locations throughout the community for driveway, walkway, and parking area surfacing,
and in larger pieces for retaining walls and rockeries. Copper smelting operations ceased in 1985, and
the arsenic production plant was closed in 1986. The Asarco smelter facility and sediments adjacent to
the smelter property are being addressed as separate operable units of the CB N/T Superfimd site.
The Study Area land use is primarily residential and includes schools, playgrounds, and parks.
In 1993, EPA estimated that the Study Area included a population of approximately 4,290, and about
1,820 housing units. Commercial development consisting of retail shops and small businesses is limited
in extent and mainly confined to an area along Pearl Street. The Asarco smelter, which ceased
operations in 1985, is located to the northeast of the Study Area and was the principal industrial facility
in the area. The southern portion of Point Defiance Park and Zoo, which extends along a wooded
peninsula to the northwest of the smelter, is located within the Study Area and includes access to the
Vashon Island Ferry. Properties to the southeast of the Study Area, which were previously industrial in
nature, are actively being redeveloped with restaurants, a fishing pier, park areas, and other public uses.
The residential area adjacent to the smelter has been the subject of many investigations over the
past 30 years. Several studies, identified in the table in Section II above, are described in the following
text. Some of these studies formed the basis for a 1989 EPA decision to conduct an Expedited
Response Action (ERA) at several publicly accessible properties in the Study Area.
Exposure Pathways Study
Initiated in 1985 and released in 1987, the Exposure Pathways Study (see Ruston Vashon
Arsenic Exposure Pathways Study, University of Washington, 1987) investigated the pathways
contributing arsenic to the bodies of residents in Tacoma and Vashon/Maury Islands. One of the
objectives of this study was to determine what environmental media required remediation to effectively
reduce the body burden of arsenic in the affected population. The study involved the
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repeated sampling of urine and a number of environmental media for arsenic analyses. It was performed
just at the time when smelter operations ceased. Results of the study indicated that an individual's age
was shown to be significant for determining urinary arsenic levels, with young children most affected.
Arsenic concentrations on children's hands were significantly associated with urinary arsenic
concentrations, and with time spent in contact with soil and house dust. Ingestion of contaminated soil
was identified as the primary route of exposure to arsenic.
Field Investigation Report
In 1988, a detailed investigation (see Field Investigation Report [FIR], Ruston/Vashon
Island Area, Black & Veatch, 1988) of post-shutdown soil contamination in the Study Area was
performed by the Washington State Department of Ecology (Ecology). Approximately 288 soil
samples were collected from residential and non-residential high-use areas (parks, playgrounds, and
vacant lots) within approximately 1 mile of the smelter. The FIR included an evaluation to determine if
soil contamination was related to smelter emissions.
Endangerment Assessment and Engineering Evaluation/Cost Analysis
In conjunction with the FIR, an Endangerment-Assessment (EA) (see Endangerment
Assessment Ruston/Vashon Island Area, Black & Veatch, 1988) and Engineering Evaluation/Cost
Analysis (EE/CA) (see Engineering Evaluation/Cost Analysis of Removal Action Alternatives:
Ruston/Vashon IslandArea, Black & Veatch, 1988) were also performed by Ecology. The EA
evaluated the potential health effects from exposure to smelter-related contamination in soil, house dust,
and air. The EE/CA was developed to evaluate removal action alternatives.
Urinary Arsenic Survey
As a follow-up to the Exposure Pathways Study, an additional urinary arsenic survey (see
Urinary Arsenic Survey, North Tacoma, Washington, Tacoma-Pierce County Health
Department, 1988) was performed by the Tacoma-Pierce County Health Department (TPCHD) of
children ages 2-8 years living within approximately '/2 mile of the smelter. The results indicated that
urinary arsenic levels had generally declined since smelter closure. Some individuals, however, still had
elevated levels.
Expedited Response Action
Of the 20 nonresidential high-use areas identified and sampled as part of the FIR, 11 were
determined to have arsenic concentrations resulting in estimated risks outside of EPA's range of
acceptable risks for carcinogens. In March 1989, EPA and Asarco signed an Administrative Order on
Consent (AOC) for the performance of an ERA. Under the ERA, Asarco agreed to remove three
inches of arsenic-contaminated soil at the 11 nonresidential high-use properties, and replace the
excavated soil with 9 to 12 inches of imported soil. The 11 sites totaled about 15 acres and included
playgrounds, parks, and vacant lots - locations where children were likely to
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spend time playing (see Attachment 3). While additional information was required to fully characterize
the nature and extent of contamination in the residential community, these nonresidential sites were
selected for early remedial action because of elevated concentrations of arsenic in soil, and accessibility
by the public, especially children. Ten of the 11 ERA sites were completed by Asarco under the ERA
AOC. The 11th property was addressed under the ROD as part of the current cleanup.
Remedial Investigation and Risk Assessment
EPA completed a Remedial Investigation and Risk Assessment in January 1992. The RI was
designed to focus on the area most likely to require cleanup, on soils as the primary environmental
medium of concern, and on arsenic as the primary contaminant of concern. During the RI, soil samples
were collected to provide additional information on the distribution of arsenic and other metals
(antimony, cadmium, copper, lead, mercury, selenium, zinc, and silver) in surface and subsurface soils in
the Study Area. The soil sampling results demonstrate the presence of metals above background
concentrations in Study Area soils. The RI data also indicate an overall pattern of decreasing
contaminant concentrations with increasing distance from the smelter, with a directional component
reflecting wind patterns.
In the Risk Assessment, arsenic and lead were determined to be the two contaminants of
primary concern for human health. Other metals did not pose significant risks to individuals even at the
highest levels detected. Of the six exposure scenarios evaluated, the scenario of most concern, that
resulted in the highest exposure potential, was the ingestion of soils and dusts. Arsenic was evaluated
for both cancer (lung and skin) and noncancer (skin hyperpigmentation and skin keratoses) effects. For
lead, the LEAD4 model was used to estimate the potential for a child to exceed a 10 ug/dl blood lead
level. For both arsenic and lead, the estimated exposures and risks in the Study Area exceeded those
levels that generally require remedial action at a Superfund site as defined by EPA in the NCP and
program guidance.
IV. Remedial Actions
A. Remedy Selection
The only Record of Decision (ROD) for the R/NT site was signed on June 16, 1993. The
remedial action objectives and goals, identified in Attachment 4, were based upon the results of the
risk assessment, and a number of other risk management considerations including the scope, costs, and
impact on the community of remedial actions, as well as community acceptance of the remedy. Further
information on how EPA considered these factors in the selection of the action levels for the site can be
found in EPA's January 1992 Ruston/North Tacoma Site Preliminary Remedial Action Objectives
Decision Memorandum.
The action levels identified for cleanup of residential soil were 230 ppm for arsenic and 500
ppm for lead. The arsenic action level of 230 ppm was based on reducing the additional
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potential skin cancer risk to no more than 5 in 10,000, within EPA's acceptable risk range for cancer
causing chemicals.1 The 500 ppm action level for lead was based upon a national goal of reducing
levels in children's blood to no greater than 10 ug/dl, as well as EPA guidance that recommended
establishing soil lead cleanup levels of 500 to 1,000 ppm.
In addition to being protective of human health and the environment, the ROD established the
applicable or relevant and appropriate requirements (ARARs) that had to be met. The Washington
State MTCA cleanup standards were applicable requirements for the Ruston/North Tacoma site. EPA
coordinated with Ecology in evaluating the MTCA requirements. Under MTCA Method A, the soil
cleanup levels for residential areas were 20 ppm for arsenic and 250 ppm for lead. MTCA requires
that some form of action be taken to address contamination above these levels. In evaluating the
available remedial actions to address contamination at this site, Ecology considered the nature and
extent of site contamination, the nature of human health risks, the exposure pathways, and the potential
impacts and costs associated with physical remediation activities in the community. Ecology concluded
that the EPA action level of 230 ppm for soil arsenic represented a best balancing of factors for a level
at which engineering actions (e.g., soil removal) for remediation should begin at this site. Institutional
controls (otherwise known as community protection measures), mostly consisting of educational
measures, were deemed by Ecology to be suitable for protection of human health and the environment
at those locations within the Study Area where soil arsenic concentrations were between the MTCA
cleanup level of 20 ppm and 230 ppm (see Ecology Concurrence with EPA's Record of Decision
for the Ruston/North Tacoma Operable Unit, June 7, 1993, Carol L. Fleshes, Program Manager,
Toxics Cleanup Program). Community protection measures are further discussed in the following
section. For lead, Ecology could elect to use the conservative Method A cleanup level of 250 ppm, or
it could use site-specific information and EPA's biokinetic model to establish a cleanup level (see WAC
173-340-702(6)). Ecology determined that the results of applying the "LEAD4" model supported
setting the soil lead cleanup level under MTCA at 500 ppm for this site.
In their comments on this five year review, Ecology has informed EPA that it has changed its
interpretation of MTCA since the signing of the Ruston/North Tacoma ROD, and that the cleanup
decision no longer complies with the cleanup requirements for residential soils under MTCA.
Specifically, Ecology states that:
"Under WAC 173-340-740(l)(a), some form of "treatment, removal, or containment
remedy " must be employedfor residential soils containing hazardous substances in
excess of soils cleanup levels (e.g., 20 ppm arsenic). We believe this applies to each
exposure unit, that is, each residential property. Under WAC 173-340-440(2),
institutional controls cannot be used as a substitute for cleanup actions that are
1 EPA's "Ruston/North Tacoma Site Preliminary Remedial Action Objectives Decision
Memorandum" documented why an action level corresponding to a 5 x 10~4 level was warranted
based on site-specific considerations.
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otherwise technically possible. In short, we do not believe that reliance on institutional
controls to reduce exposure to and risk from arsenic in surface residential soils at levels
between 20 ppm and 230 ppm counts as a form of "treatment, removal, or containment"
under the applicable regulation. " (see Ecology Comments on the Draft First Five-Year
Review Report, Ruston/North Tacoma Superfund Site, Ruston and Tacoma, Washington,
March 28, 2000, Tim Nord, Toxics Cleanup Program).
Under the National Contingency Plan, EPA is required to consider newly promulgated or
modified requirements after the ROD has been signed to evaluate whether the remedy is still protective
of human health and the environment (55 Federal Register 8757 (March 8, 1990)). Although
Ecology's change in interpretation is not a promulgated change to MTCA, EPA has considered
Ecology's revised position. As explained in Sections VI. E. and VH. E. below (Risk Information
Reviews), EPA believes that the 230 ppm action level for this site is still within EPA's acceptable risk
range for carcinogens given consideration of exposure, technical, and uncertainty factors, and still
protective of human health. Accordingly, EPA is not modifying the action level at this time based on
Ecology's revised interpretation of MTCA.
The selected remedy called for sampling (surface and depth) of individual properties within the
Study Area, and the excavation, removal, and replacement of soil which exceeded the action levels.
Where contamination above the action level remained below a depth of 18 inches, a geotextile fabric or
marker would be placed at the base of the excavation, and replacement soil would serve as a cap or
barrier to the remaining contaminated soil below. A November 29, 1993 Explanation of Significant
Difference provided for the temporary storage of soils excavated from the R/NT site at the Asarco
smelter facility. The March 1995 ROD for the Asarco smelter facility called for the use of those soils as
part of the cap for the smelter site. Slag driveways within the Study Area (as well as other areas where
small, ingestable, pieces of slag were used) would be excavated and replaced with gravel.
The community had an extensive role in the remedy selection process for the site. A community
workgroup, consisting of local area citizens was formed in the Fall of 1989 and continued to meet
approximately monthly through the signing of the ROD in 1993. The workgroup reviewed and
commented on technical and community relations documents and provided input to EPA on remedy
components that would be acceptable to community members. The Ruston/North Tacoma
Coordinating Forum (Forum) formed in March 1991 and met monthly through April 1992. Participants
included elected officials, key agency decision makers, and management and staff of various
organizations that would be involved in or affected by the cleanup project. The purpose of the Forum
was to facilitate discussion and coordination, and to assist in the development and selection of a remedy
that would be implementable in the communities. In addition, community members were involved in the
remedy selection process through public meetings, open houses, interviews, and workshops. A part
time community liaison was also hired to staff a local office, answer questions, and research information
for citizens.
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B. Remedy Implementation
The remedial design for the site was started in the Fall of 1993. Sampling began in October
1993, and cleanup activities were initiated in the Spring of 1994. The Study Area was divided into four
zones, based on known soil arsenic concentrations, in an effort to focus sampling and cleanup activities
on the most contaminated areas first (see Attachment 1). Sampling of all properties in zones 1 - 3, the
preliminary remediation area, is required in the ROD and has been completed. Remedial actions in
zones 1 - 3 are expected to be completed in 2003. Sampling in zone 4 was initiated in 1999 and will
occur where previous soil sample results from the RI or FIR indicated an exceedance of the action
level, at properties surrounding an area that has been identified as exceeding an action level, or
otherwise upon request of the property owner. The extent of action necessary in zone 4 will not be fully
understood until sampling efforts in that zone are complete. The remedy is being implemented by
Asarco. EPA oversees the sampling and cleanup efforts. The remedial actions are described further
below.
1. Sampling Program
Residential properties, dirt alleys, and right-of-ways are sampled to determine whether
they need to be cleaned up, and to what extent. Consent from property owners is sought prior
to the sampling activity, and property owners receive a copy of the sample results indicating
whether cleanup is needed. During the sampling effort each property is first divided into
subunits, and surface and depth samples are collected within each subunit at the 0-1 inch, 1-6
inch, 6-12 inch, and 12- 18 inch depth intervals. Property cleanup decisions are made using a
two-part decision rule by comparing the sample results to the action levels for arsenic and lead
(230 ppm and 500 ppm, respectively). If the property average soil concentration of arsenic
and/or lead at any given depth exceeds the action levels, soil from the entire property is
excavated to that depth. If the property average soil concentration is below the action levels,
but samples in an individual subunit(s) exceed the action levels, soil from that subunit(s) will be
excavated and replaced. Following soil removal, samples are taken again to confirm that soil at
the base of the excavation does not exceed the action levels. If action levels are exceeded at
the base of the excavation, additional excavation will occur. Samples are also collected from
sod and soil to be used for backfill to ensure that they do not exceed the MTCA soil cleanup
levels (regional urban background levels of 20 ppm arsenic and 250 ppm lead).
2. Soil Removal and Backfill Activities
At properties where soil exceeds action levels, soil and sod are excavated and replaced
and the property is relandscaped. Slag driveways, and other areas where slag exists in small
pieces, are also excavated and replaced with gravel. An access agreement for cleanup is
negotiated with the property owner which includes a site map identifying areas where soil and
vegetation will be removed, and how it will be replaced. Utilities are located and land owners
are notified prior to the commencement of cleanup activities
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on their property. Property owners are asked to sign-off on the property map at the completion
of cleanup activities attesting that the work performed meets their satisfaction. Excavated soil is
disposed at the Asarco smelter facility where it will be incorporated into a cap to be placed
over the property. Sample access agreements, notices and letters to residents, and site maps
can be found in the December 6, 1994 Revised Work Plan for Excavation and Removal of
Soils, Ruston and North Tacoma, Washington, prepared by Hydrometrics, Inc. for
ASARCO Incorporated.
3. Community Protection Measures Program
A community protection measures program (institutional controls) was developed for
the Study Area and is being implemented by a program coordinator from the Tacoma Pierce
County Health Department, the coordinator for the Asarco Information Center, and a work
group consisting of representatives from government agencies, a local interest group, local
officials, and Asarco personnel. The program is referred to as PACE - the Program for Area
Cleanup Education. The PACE work group currently meets on a quarterly basis. The objective
of the PACE program is to provide owners and residents in the Study Area with educational
materials and guidance on the management of soils in the area. The PACE program consists of
several components, as follows, which were identified in the ROD:
Measures to control soil disturbances
Soil testing, collection, and disposal program
Measures to maintain the integrity of caps
Development of a property specific data base
Notification to future property owners
Evaluations of the effectiveness of the PACE program
Educational materials are distributed to residents at the time of sampling and cleanup of
their property, through a periodic newsletter distributed to all addresses in the Study Area, as
annual reminders to local utilities, realtors, and private companies who have cause to dig dirt in
the Study Area, and upon request at the Asarco Information Center. The information
distributed by the PACE program is not enforceable upon local residents, and there are no
penalties to residents for failure to comply with any of the printed information.
C. Operations and Maintenance (O&M)
Since the remedy is still being implemented, the site has not yet entered the operations and
maintenance phase and no data is available on actual O&M related issues or costs. Asarco has
minimized the potential need for O&M activities by removing soil above the action levels
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regardless of depth2, thereby reducing the number of capped properties. O&M efforts are anticipated
to be minimal and will focus on the long term components of the PACE program including distribution
of educational materials, maintenance of a property data base, and provisions for soil disposal (see
Attachment 5). Annual costs for the PACE program to date are included in the table below as an
indication of potential future costs to conduct O&M-related educational efforts. These costs do not,
however, include costs associated with long term soil disposal services.
PACE Program Costs to
Date
1994
$90,119.00
1995
$88,885.00
1996
$90,137.00
1997
$47,420.00
1998
$52,258.00
1999
$45,590.00
V. Five Year Review Process
The Ruston/North Tacoma (R/NT) five year review was led by Mary Kay Voytilla, EPA
Remedial Project Manager for the site. The following team members assisted in the review:
• Burt Miller, CH2M Hill oversight contractor
Tod Gold, EPA site attorney
Dana Davoli, EPA risk assessor
Jeannie O'Dell, EPA community relations coordinator
Bruce Cochran, Department of Ecology and PACE member
Tom Aldrich, Asarco project manager and PACE member
Willie Williams, Hydrometrics
• Karen Pickett, Asarco Information Center coordinator and PACE member
Glenn Rollins, Tacoma Pierce County Health Department and PACE member
lone Claggett, Citizens for a Healthy Bay and PACE member
2 According to the ROD and RD/RA Consent Degree, Asarco is legally required to remove
soil only to a maximum depth of 18 inches. If confirmation sampling indicates that contaminants
remain below 18 inches, a geotextile fabric or marker would be placed at the base of the
excavation, the backfilled soil would be considered a "cap," and the capped property subject to
associated community protection measures. However, in those instances where contamination
has been found below 18 inches, Asarco has voluntarily performed further soil removal.
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Charlene Hagen, Town of Ruston and PACE member
Judith Lorbeir, City of Tacoma and PACE member
Judi Schwarz, EPA policy analyst
This five year review consisted of the following activities: a review of relevant documents (see
Attachment 6); interviews with EPA's oversight contractor (CH2M Hill), Asarco, and Asarco's
sampling and cleanup contractor (Hydrometrics); and a review of the draft report by members of the
Program for Area Cleanup Education (PACE) workgroup and several Study Area residents. A specific
site inspection was not conducted for this five year review as EPA conducts oversight of Asarco's
sampling and cleanup activities on a regular basis of one or two days per week, has an ongoing
presence in the community, interacts with residents as cleanup issues or concerns arise, and interacts
with the local governments on a quarterly basis at PACE meetings. In addition, a notice regarding the
forthcoming review was placed in the local newspaper, and an announcement about the purpose and
schedule for the review was made at an Asarco public meeting in February, 2000. The completed
report is available in the information repository. Notice of its completion was placed in the local
newspaper and a brief summary of this report was distributed to community members.
VI. Five Year Review Findings
Below are the findings of the five year review for the Ruston/North Tacoma site. This section is
divided into categories consistent with the significant components of the site work including: overall
status of the project; sampling program; soil removal and backfill activities; and general community
relations activities and PACE program. A review of any new risk-related information since the time of
the ROD is also presented.
A. Overall Status of the Project
Below are findings regarding the overall conduct of the cleanup project as well as current
summary statistics for the sampling and cleanup efforts.
EPA provides oversight of Asarco's sampling and cleanup efforts through its contractor,
CH2M Hill. During the early years of the project, EPA oversight was provided on a full time
basis. Over the years, as Asarco demonstrated its ongoing ability to conduct work in a manner
satisfactory to the Agency, oversight efforts have been reduced. Currently, EPA oversight is
provided one or two days per week. In addition, during the first five years of the project
(1994 - 1998), EPA collected and analyzed split soil samples. Beginning in 1999, and based
uponfive years of acceptable comparisons of EPA's and Asarco's data, this practice ceased.
Split samples may be taken again in the future if the need arises.
In addition to the ongoing project oversight efforts described above, Asarco submits several
different types of reports on an ongoing (annual or semi-annual) basis including
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Project Forecast Reports, Project Completion Reports, and Data Validation reports. The
purpose of these documents is to: 1) identify properties scheduled for sampling and cleanup in
the upcoming construction season; 2) document property cleanups completed during the
previous construction season; and 3) transmit the results of data validated during the previous
construction season. These reports undergo review and comment by EPA and CH2M Hill, and
require the approval of the EPA.
Soil sampling in zones 1-3 (sampling of all properties in these zones is required under the
ROD) was completed by the end of 1998. Soil sampling in 1999 and beyond is focused on
properties in zone 4 (sampling is at the request of the property owners). See Attachment 1.
Cleanup of properties in zones 1 and 2 was completed in 1999. Cleanup of properties in zone
3 is estimated to occur from 2000 - 2003. Cleanup of properties in zone 4 may begin during
2003. As the total number of properties in zone 4 requiring cleanup is currently unknown, it is
impossible at this time to estimate a completion date for cleanup of all properties in the Study
Area.
Summary of cleanup statistics as of December 1999:
Properties sampled (zones 1-3, and some zone 4) 1,695
Number of properties remediated in zones 1-3 7333
Number of properties remaining for cleanup in zones 1-3 573
Number of properties for which property owners have
refused access for sampling or cleanup 17
B. Sampling Program
Based upon a review of site data conducted by Asarco, the following data trends/observations
were noted:
In general, and as predicted by the RI/FS, the further distance from the former smelter stack
(point of emissions), the less the amount of remediation required. This is evidenced by more
partial remediations, and shallower removals at many properties, as cleanup progresses.
Backfill soils have not exceeded the MTCA cleanup levels for arsenic and lead (20 ppm
arsenic and 250 ppm lead), and actual sample results have been significantly lower (see
Attachment 7). Backfill soils and sod have been sampled in accordance with the project
sampling and analysis plan throughout the project.
3 Includes three properties outside of the Study Area which were specifically designated in
the Record of Decision for cleanup due to contamination above the arsenic action level.
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Soil Removal and Backfill Activities
No major problems or issues have arisen during the course of the remedial actions. However,
there have been some recurring items of concern among various homeowners including
drainage, quality of replacement soil, and maintenance of newly placed sod. Asarco has taken
the following steps to respond to these issues:
Drainage: Hydrometrics has met with various residents in regard to drainage within the
properties, and minor drainage improvements have been made, as well as return calls to
discuss or improve drainage after remediation is complete.
Topsoil: The topsoil used is as specified in the work plan, and is tested to ensure compliance.
Lawn care: In order to assist homeowners in maintaining the newly sodded lawns a handout on
proper lawn maintenance was developed and is distributed by Asarco to homeowners at the
time of property cleanup and lawn replacement.
In 1995, Asarco undertook a lawn revitalization project for several lawns on the same block
that had experienced problems. A lawn care service was hired to aerate and perform routine
fertilization for one summer. Asarco consulted with a horticulturist and turf expert from
Washington State University Extension Office in Puyallup (WSU) to advise on proper care. By
the end of the summer, all the lawns involved showed improvement and returned to an
adequate texture and color.
Asarco found that newly remediated lawns required different care than older, established
yards. These yards need to be fertilized and watered more frequently, and periodically aerated
to promote proper growth. During 1998, Asarco set up an ongoing experiment with WSU to
try different types and rates of fertilization on a vacant lot owned by Asarco. WSU has
consulted with their soils, turf and horticultural experts and laid out a grid using several different
types of fertilizers, different application rates and is monitoring watering times, weather, wind
patterns, and mowing height. As results become available, they are posted at the vacant lot.
As envisioned in the project work plan, some areas of the site that qualified for remediation
(had soil arsenic or lead above the action levels) were found to be inaccessible for cleanup,
e.g., some areas under decks, on steep slopes, or in wetland areas. All decks that had
sufficient space to provide access were remediated. In some cases this required hand work to
be performed. There were three decks where access was restricted and cleanup did not
occur. In these and other instances where access was restricted, confirmational sample results
and site plans were provided to the homeowner and incorporated into the project data base
indicating where remediation had and had not occurred. In addition, four steeply sloped areas
have been left vegetated rather than
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disturb the existing root structure and possibly cause erosion problems, and three sites have
had the remediation areas reduced due to wetlands features. In these instances, the site plan
and confirmational sampling results furnished to the property owner and incorporated into the
project data base reflect the decision to not remediate those areas. The PACE brochure
"Property Owner Guidelines and Responsibilities in Remediated Yards " describes
procedures for disposal of soil from these areas in the future if necessary.
While the ROD and project work plan require Asarco to excavate only to a maximum depth of
18 inches, Asarco has voluntarily excavated deeper in those areas where confirmational
sampling indicated soil remaining above the action levels. As of the end of 1999, 111 sites
properties have had excavation beyond 18 inches. Most of this overexcavation has been an
additional 6 inches, but a few sites have been excavated to greater depths. Two subunits were
excavated to 42 inches, and one to 48 inches to reach acceptable levels. A portion on one site
was excavated to 5-1/2 feet to remove visual slag concentrations. This action (performing
additional excavation) was voluntarily taken by Asarco in lieu of capping the properties and
implementing the long term care provisions associated with a capped property.
Asarco has worked with property owners to successfully redevelop 4 of the 10 existing
capped ERA sites, including coordination with property owners' contractors and disposal of
soils from beneath the caps. In these instances, Asarco and the property owners have
implemented the development and coordination procedures as outlined in the PACE brochure
"Property Owner Guidelines and Responsibilities for ERA Sites. "
The ROD identified a steeply sloped portion of the Study Area surrounding the Burlington
Northern railroad tracks (see Attachment 8). Should sampling indicate that this area is in need
of remediation, the ROD noted that excavation would not be possible. Rather, fencing, planting
with low lying shrubs, and application of a geotextile material to provide erosion protection
would be undertaken. Limited sampling has occurred to date in this area due to difficult access.
Of 4 samples collected in this area, one indicates the presence of arsenic and lead in excess of
the action levels. Fencing already existed surrounding most of the area. No further actions have
been taken on this property.
General Community Relations Activities and PACE Program
Asarco operates the Asarco Information Center in Ruston, Washington. On a monthly basis,
the Asarco Information Center receives an average of 170 telephone calls and 30 visitors.
Inquiries include requests to set up meetings regarding cleanup of a specific property, general
questions about cleanup activities, disposal issues, and redevelopment concerns.
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Asarco issues a Soils Bulletin to residents of the Study Area to provide updates and information
regarding the sampling and cleanup activities. Asarco also distributes general information
packets to the public at large upon request which include an overview of the cleanup process, a
soil sampling schedule and map, a questions and answers brochure, and soils handling and
disposal guidelines.
Asarco sends out an annual reminder letter at the start of each remediation season to local
municipalities, utilities, and contractors who conduct excavation operations in the Study Area.
The letter provides a reminder of the ongoing cleanup operations, suggests soil handling
procedures, and includes a map indicating where soils have been tested and/or replaced. An
annual update to the real estate community is also issued by way of an article in the newsletter
of a local real estate association.
Asarco also provides presentations/tours for groups to discuss the history of the smelter and the
various Asarco cleanup projects. Groups have included University of Puget Sound, University
of Washington at Tacoma, Stadium High School, Bainbridge Island Alternative School, Clover
Park Vocational School, Gieger Elementary and Cub Scout Pack #3, Tacoma Community
College, Truman Middle School, Point Defiance Retirement Center, and several garden,
Kiwanis and Rotary Clubs.
The PACE workgroup began meeting in early 1994. For the first several years, as the program
was developing, meetings were held on a monthly basis. Currently, the workgroup meets
quarterly. A list of the educational materials prepared by the PACE work group is included in
Attachment 9. Major activities undertaken and accomplished by the PACE workgroup to date
are summarized below:
The development and distribution of information on measures to control soil
disturbances.
A soil testing, collection, and disposal program for residents to use prior to Asarco's
sampling or cleanup of their property.
The development and distribution of information on measures to maintain the integrity of
caps on properties.
The development of a property specific data base of sampling results and cleanup
efforts on specific properties. Initially, the data base was maintained in paper format
and then shifted to microfiche. Plans are currently underway to computerize the data
base system. The data base can be accessed through the Asarco Information Center,
the City of Tacoma permit office, and the Ruston Town Hall.
The development and distribution of information regarding cleanup and soils-related
issues to current and future property owners.
The development of procedures for using the Tacoma Landfill to dispose of soils
containing less than 230 ppm arsenic.
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The development of an arbitration process for citizens with unresolved concerns about
remediation of their property. The arbitration process has been used once at the site.
Conducted community surveys to assess the level of local knowledge regarding the
Superfimd cleanup process.
Developed guidelines and protocols for the initial health screening program for urinary
arsenic and blood lead testing.
Worked with an official from Tacoma Public Schools to develop curriculum for use in
local public schools. While the full curriculum was not implemented due to completing
educational priorities, elements have occurred, e.g., group tours of the smelter,
community cleanup area, and on-site laboratory.
Assisted the Tacoma Pierce County Health Department in it's Community Assessment
processes for the Ruston and North Tacoma areas to gather perceptions and priorities
of community residents.
Coordinated PACE program efforts with the community health nurse from the Point
Defiance Family Support Center.
Developed procedures to remind citizens planning construction projects that soil under
hard surfaces, e.g., sidewalks, was not removed as part of the cleanup, and the
procedures for handling and disposal of such. This process is being coordinated by the
Tacoma Pierce County Health Department and in conjunction with the permitting
processes for the Town of Ruston and City of Tacoma.
Worked with the Town of Ruston and City of Tacoma to coordinate the development
of procedures for local utilities to use when conducting activities in the Study Area that
involve soil excavation.
The PACE workgroup developed criteria to evaluate the PACE program and assess the
program components as identified in the Record of Decision. PACE program evaluations have
been conducted in November, 1994, July, 1995, May, 1996, July, 1997, and most recently in
May of 1999. The first two evaluations were conducted by a panel of non-workgroup
members from the Tacoma Pierce County Health Department (TPCHD), City of Tacoma,
Asarco, Town of Ruston, Department of Ecology, and the EPA (the panel). Based on the
recommendation of the panel, the third evaluation was conducted by the workgroup members.
The fourth evaluation consisted of an independent peer review conducted by Jerry Cobb of the
Panhandle Health District in Kellogg, Idaho, Patty Kay-Clapper of the Aspen Medical
Community/Smuggler Citizens' Caucus in Aspen, Colorado, and Alice Collingwood of the
Puget Sound Air Pollution Control Authority. The latest evaluation was conducted by
workgroup members.
At the conclusion of each program evaluation, a report or letter of findings was prepared and
discussed among the workgroup members. In addition, a workgroup response to the evaluation
was prepared noting any changes to the PACE program based on the evaluation. It is
anticipated that program evaluations will continue to occur every two years under the domain of
the workgroup as coordinated by the TPCHD. A peer review
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of the program, accomplished by parties outside of the workgroup, will occur again near the
completion of the cleanup efforts and prior to establishment of the long term community
protection measures discussed below and included in Attachment 5.
The conclusion from the latest program evaluation was that while some changes were necessary
to fine tune certain elements of the program, the requirements of the ROD and program scope
of work were being met. See PACE Evaluation Summary, October 15, 1999, Tacoma
Pierce County Health Department. The work group remains interested in the future of the
education program after Study Area cleanup is complete and there is no longer an ongoing
awareness of soil contamination and related issues in the community. The PACE workgroup
developed a list of goals for the establishment of long-term community protection measures, and
plans to have the proposed goals and tasks in place prior to the completion of the Asarco
cleanup project. See Attachment 5.
An additional item noted during the last program evaluation concerns the role of the PACE
program and workgroup in evaluating the effectiveness of its educational activities on changing
the behavior of Study Area residents and thereby reducing residents risks from exposure to soil
containing 20 ppm to 230 ppm arsenic. The Department of Ecology (Ecology) believes that the
success of the PACE program should be evaluated based on a quantitative evaluation/survey of
whether residents have changed their behaviors based on PACE educational materials. Other
workgroup members disagree noting that this approach is overly intrusive in the lives of area
residents, potentially devalues property, does not provide added value for the level of
assurances it may obtain, may unnecessarily frighten and antagonize people, and is much
broader than the communities' and local governments' understanding of the educational
program selected in the ROD. These views of PACE workgroup members have been shared
with Ecology staff in writing, and most recently as a point of discussion at a PACE workgroup
meeting at which the Institutional Controls Coordinator for Ecology's Toxics Cleanup Program
was present (see Summary of November 2, 1999 PACE Meeting, January 3, 2000,
prepared by Tacoma Pierce County Health Department). EPA notes that the current PACE
program evaluation criteria and process, developed by the workgroup and discussed in the
section above, are consistent with the ROD and Community Protection Measures Scope of
Work (see Scope of Work, Community Protection Measures, Ruston/North Tacoma Study
Area, Revised October 21, 1999). Based on workgroup members' comments, and overall
program consistency with the ROD and other project documents, EPA is not implementing at
this time the survey being suggested by Ecology. Ecology is not precluded, however, from
conducting additional evaluative measures under its own regulatory authorities and sharing such
information with the PACE workgroup.
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E. Risk Information Review
EPA has conducted a review of the applicable or relevant and appropriate requirements
(ARARs) identified in the 1993 Ruston/North Tacoma ROD. There were no revisions or amendments
to the ARARs that were determined to affect the protectiveness of the remedy. In addition, a review of
the site baseline risk assessment and Preliminary Remedial Action Objectives Decision
Memorandum was conducted to identify any risk-related information that has changed since the time of
the ROD and that has the potential to call into question the protectiveness of the remedy. The following
section presents the findings of that review.
Exposure pathways: Land use at the site is still primarily residential, potential routes of exposure
to soil contamination remain as indicated in the site baseline risk assessment, and there are no
newly identified contaminants of concern.
Potential for changes in the future to the cancer slope factor and reference dose for arsenic: In
1996, EPA's Office of Water requested that the National Research Council (NRC) review the
arsenic toxicity data base and evaluate the adequacy of EPA's interim maximum contaminant
level for arsenic in drinking water. The NRC's report {Arsenic in Drinking Water, National
Research Council, 1999) reviews new studies on arsenic which strengthen the data on
arsenic's ability to cause cancer when ingested, especially internal cancers, e.g., lung and
bladder. The report also provides data which strengthens conclusions regarding arsenic's ability
to cause non-cancer effects including hyperkeratosis and hyperpigmentaion, as well as other
chronic non-cancer effects (e.g., cardiovascular system, nervous system, and diabetes). There
is some speculation that this data, in the future, could be the basis for changes to the cancer
slope factor and reference dose (toxicity factors) for arsenic as reported in the Agency's
Integrated Risk Information System (IRIS). If such changes are implemented, the new toxicity
factors could differ from those used in the 1992 Ruston/North Tacoma (R/NT) baseline risk
assessment. In such event, Region 10 would review the new information to determine whether
modification of the arsenic action level is necessary in order to maintain protection of human
health and the environment.
Potential for changes in the future to Agency guidance on assessing risks from dermal (skin)
exposure to contaminants: The EPA is currently in the process of updating it's guidance on
assessing risks from dermal exposure to contaminants. When finalized, the new guidance would
likely contain parameters (e.g., contact rate, adsorption factor) that are different from those
used in the 1992 R/NT baseline risk assessment where dermal exposure was not considered to
be a significant pathway of concern.
Agency policy on evaluating health risks to children: In 1995, EPA issued its Policy on
Evaluating Health Risks to Children. This policy notes that the Agency will develop a
"separate" assessment of risks to infants and children where applicable. In the 1992 R/NT
baseline risk assessment, an "integrated" child-adult assessment was conducted.
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As this policy is not retroactive, and was meant to apply only to those assessments started or
revised on or after November 1, 1995, a separate child only risk assessment has not been
conducted for this five year review.
Changes to the integrated exposure uptake biokinetic model for assessing lead exposure: In the
1992 baseline risk assessment for the Ruston/North Tacoma site, EPA used the Agency's
LEAD4 model to evaluate potential lead exposures and risks, and to calculate a 500 parts per
million (ppm) action level for lead. EPA's most recent guidance on lead is summarized in two
directives from EPA's Office of Solid Waste and Emergency Response (OSWER): Revised
Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities,
OSWER Directive #9355.4-12, July 14, 1994; and Clarification to the 1994 Revised
Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities,
OSWER Directive #9200.4-27, August 1998. These directives recommend a screening level
for lead in soil for residential land use of 400 ppm, and the use of the Agency's updated lead
model for the selection of site-specific remediation goals. The soil lead screening level is defined
as "a level of contamination above which there may be enough concern to warrant site-specific
study of risks." The guidance further states that "levels of contamination above the screening
level would not automatically require a removal action, nor designate a site as contaminated."
As this guidance was meant to apply to remedial investigations/feasibility studies conducted
after the guidance was finalized in 1994, and not generally at sites for which risk assessments
had already been completed, EPA did not run the updated model for this five year review.
VII. Assessment
In this section, EPA explains the conclusions of the five year review based upon the information
presented above. The outline for this section follows the same as used in the section above.
A. Overall Status of the Project
Current oversight efforts by EPA are appropriate and commensurate with the level of
experience gained by Asarco and its contractors during the past six years. Actions by EPA to
reduce oversight efforts over time are also consistent with the Agency's related Superfund
reform (see Reducing Federal Oversight at Superfund Sites with Cooperative and
Capable Parties, July 31, 1996, OSWER Directive No. 9200.4-15).
Project Completion Reports, Forecast Reports, and Data Validation reports have been
submitted by Asarco to the Agency on time, and are consistent with the requirements of the
project work plan. Comments or issues raised by EPA or its oversight contractor regarding
property cleanup decisions or data quality issues have been satisfactorily addressed.
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Asarco has completed at least the minimum number of properties required to be sampled and
cleaned-up each year as identified in the project Consent Decree and modified by way of
technical memorandum (see EPA's Response to Asarco's February 1, 1999 Letter
Regarding Requested Schedule Changes for the Tacoma, Washington Asarco Projects,
April 21, 1999, Michelle Pirzadeh, Acting Associate Director, Environmental Cleanup
Office, and EPA 's Response of April 21, 1999 to Asarco's Requested Schedule Change,
August 31, 1999, Thomas L. Aldrich, Asarco/
To date, only 17 property owners have refused access for sampling or cleanup. Fourteen
property owners have refused access for sampling and three for cleanup. The project approach
to these refusals to date has been to meet with property owners and discuss the benefits of
obtaining sampling information or a cleanup, but not to enforce the sampling or cleanup
activities at this time. Over time, as the cleanup has proceeded, property owners have grown
more comfortable with the cleanup process and results, and/or personal situations have
changed, some owners who initially refused access have in fact permitted such to occur. For
example, two of the three property owners who originally refused access for cleanup are now
agreeable. Given the long term nature of the cleanup program, the relatively low number of
refusals, the fact that work is not being held-up by these refusals, and that some refusals are
changing their minds over time, EPA believes that this approach should be continued. At some
point, near the end of the cleanup project, EPA will consider the use of its enforcement
authorities for any remaining refusals. See Section IX Recommendations and Follow-Up
Actions.
B. Sampling Program
Sampling of individual properties as well as replacement soil and sod has been done in
accordance with the project sampling and analysis plan. Evaluations of soil samples split
between EPA and Asarco indicate overall comparability of results. Overall, summary quality
control information shows that project goals for data have been met. For replacement soils,
actual replacement soil sample results have been lower than permissible cleanup levels, i.e.,
MTCA urban background levels of 20 ppm arsenic and 250 ppm lead (see Attachment 7).
C. Soil Removal and Backfill Activities
Soil removal and backfill activities are being accomplished in accordance with the ROD and
project work plan. To date, over one-half of the properties requiring cleanup in zones 1-3 have
been completed. Asarco and its contractors are working cooperatively with property owners to
resolve any site specific issues as they arise. Asarco's willingness to voluntarily excavate deeper
in those areas where contamination remain below 18 inches has minimized the need for long
term measures to protect soil caps. In those few areas where soil caps exist (10 ERA sites),
four properties have been successfully
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redeveloped according to the procedures outlined in the PACE brochure "Property Owner
Guidelines and Responsibilities for ERA Sites
There are no early indicators of potential remedy failure. EPA notes, however, that sampling to
determine whether there has been any recontamination of remediated properties has not
occurred. While this is not a requirement of the ROD or any other project decision document,
EPA recommends that such sampling occur (see Section IX Recommendations and Follow-Up
Actions).
Given the steepness of the area surrounding the Burlington Northern railroad tracks (see
Attachment 8), it may not be practical to implement all components of the remedy as identified
in the ROD, specifically planting with low lying shrubs and application of a geotextile material to
prevent erosion. While fencing and steeply sloped surfaces currently serve to reduce access to
the area, and limited sampling indicates marginal contamination levels, a final decision regarding
the appropriate level of remediation will need to be made. See Section IX Recommendations
and Follow-Up Actions.
F. General Community Relations Activities and PACE Program
Community relations activities conducted by Asarco have met the requirements of the ROD
and have provided various avenues for ongoing coordination and communication with Study
Area property owners.
Requirements of the ROD and program scope of work for implementing community protection
measures are being met through the efforts of the PACE workgroup. See PACE Evaluation
Summary, October 15, 1999, Tacoma Pierce County Health Department.
E. Risk Information Review
EPA's soil arsenic action level of 230 ppm, selected in the 1993 ROD, was based upon
reducing the additional potential skin cancer risk to no more than 5 in 10,000, within EPA's
acceptable risk range for cancer causing chemicals. This action level was set based upon
consideration of exposure, technical, and uncertainty factors, as well as community views as
they were known at the time. This five year review identifies information which could, in the
future, potentially affect the protectiveness of the remedy, and EPA's determination that 230
ppm arsenic was within EPA's acceptable risk range.
A revised risk assessment was not conducted for this five year review as the new and
developing information noted has either not occurred (changes to the toxicity factors for
arsenic), is not final (draft dermal guidance), or was not meant to apply retroactively to already
completed risk assessments (child-only exposure scenarios). EPA Region 10 will
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continue to monitor the IRIS data base for potential future changes to the arsenic toxicity
factors. If changes are made, a recalculation of risk using the new toxicity factors, and
considering any new risk assessment guidance or policies, would be conducted. At that time, an
update to the Ruston/North Tacoma (R/NT) baseline risk assessment would be conducted and
released for public review and comment, a determination would be made as to whether the
remedy at the R/NT site could still be considered to be protective, and this information would
be reported in a future five year review.
In the meantime, EPA notes that any potential future changes to the current arsenic action level
would not likely impact the protective nature of the current cleanup efforts underway since: 1)
properties with the highest arsenic concentrations would still remain the first priority for cleanup,
and 2) soil that is excavated under the current cleanup (in excess of 230 ppm) is replaced with
sod and soil that is below MTCA cleanup levels for arsenic (20 ppm). See Section IX
Recommendations and Follow-up Actions.
EPA's soil lead action level of 500 ppm, selected in the 1993 ROD, was based upon a national
goal of reducing levels of lead in children's blood to not greater than 10 ug/dl, as well as EPA
guidance that recommended establishing soil lead cleanup levels of 500 to 1,000 ppm.
The updated lead model was not run for this five year review for the following reasons: 1) The
policy describing use of the updated model (see OSWER directives 9355.4-12 and 9200.4-
27) was not generally meant to be applied at sites where risk assessments had already been
completed. 2) Study area lead and arsenic levels in soil are highly correlated, a majority of
properties with elevated lead levels are also expected to have elevated arsenic levels that would
trigger cleanup.4 3) In addition, EPA conducted an evaluation of 135 properties cleaned up in
1999 ( see 1999 Semi-Annual Project Completion Report, December 14, 1999, prepared
for Asarco by Hydrometrics, Inc.) to determine the number of properties that had soil
remaining between 400 ppm (soil lead screening level) - 500 ppm lead following cleanup. Only
9 of the 135 properties (roughly 7%) had soil concentrations between 400 - 500 ppm lead.
These concentrations were generally found in one of several subunits on the properties, and at
depth, thus further reducing the potential for human exposure.
As noted above, if it is necessary to conduct a revised risk assessment for this site in the future,
the updated lead model would be included and a further evaluation of site data conducted.
4 During the remedial investigation and feasibility study, EPA estimated that remediation of soil
arsenic above 230 ppm would likely result in remediation of about 80 - 90% of the locations with soil
lead exceeding 500 ppm.
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\TH Recommendations and Follow-Up Actions
EPA has not noted any deficiencies in current site operations which would prevent the remedy
from being protective. However, several items noted in this report are included here so that they can be
tracked for the purpose of the next five year review, and readdressed at that time. They are reported
below in the order that they were discussed in this report.
Asarco should continue to track the property owners who have refused access for sampling or
cleanup. Periodically, at least once per year and prior to the start of remediation, contact should
be made with those individuals to determine if they have changed their minds. If so, those
properties could be added to the list of properties for sampling and cleanup during the current
year as identified in the annual Project Forecast Report which is submitted to EPA by Asarco
by January 31 of each year. EPA will discuss this recommendation with Asarco within six
months of completion of this report so that it can be implemented prior to the 2001 construction
season.
A subset of properties which have already been cleaned-up should be re-sampled for the
purpose of identifying whether recontamination is a potential issue at the site. Although this is
not a requirement of the ROD, EPA will initiate discussions with Asarco within six months of
the completion of this report to add such sampling to the project work plan during the 2000 or
2001 construction season. If Asarco is unable or unwilling to undertake such an effort, EPA will
conduct the sampling itself so that the potential for recontamination can be addressed during the
next five year review.
Prior to completion of the cleanup in the Study Area, and no later than the next five year
review, EPA will make a determination about how to address soils in the steeply sloped area
surrounding the Burlington Northern railroad tracks (see Attachment 8). A combination of
additional field reconnaissance and sampling efforts, enhancements to existing fencing, and
discussions with residents, local officials, and railroad staff regarding use of the area may be
appropriate.
EPA will continue to monitor evolving information regarding arsenic toxicity, as well as general
changes in risk assessment guidance and policies. No later than the next five year review, a
determination will be made as to whether Agency views on arsenic exposure and resulting risk
have changed significantly enough to warrant a revised risk assessment and potential changes to
the arsenic action level for the site.
IX Protectiveness Statement
The remedy at the Ruston/North Tacoma Superfund site is expected to be protective of human
health and the environment upon completion by achieving the remedial action objectives and
remediation goals as identified in the ROD. Immediate threats have been addressed by implementation
of an Expedited Response Action in 1989 - 1990 at 10 nonresidential high-use
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areas, and by dividing the Study Area into zones for the purpose of sampling and cleanup at the most
highly contaminated areas first. Community protection measures, mostly educational in nature, are in
place for those areas which have soil arsenic concentrations between the MTCA cleanup level of 20
ppm and the EPA action level of 230 ppm.
X. Next Review
This site requires ongoing five year reviews. The next review will be conducted within five years
of the completion of this five year review report. The completion date is the date of the signature shown
on the signature cover attached to the front of this report.
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Study Area Zones
Tacoma Yacht Club
N
o
LEGEND
5UrJ» ftf.M <
So- "PDiiKHmpn! CsfTC*ltJ
Cvirrated Sd< Sflosre^-t r^OO
Su "esling Crfmsjlctprt
So- TpifiOq f, ?0CK I by r«MuiiS1 Cin^i
Asarco Plani Sile
Commencement Bay
VJi-»L3L
: "r h
-------
\ IKSfWff
NORTH TACOMA ,?
STUDY AU*~~ •'
-------
-------
Attachment 4
REMEDIAL ACTION OBJECTIVES AND REMEDIATION GOALS
REMEDIAL ACTION
OBJECTIVES
Contaminant
Environmental Media
Exposure Pathway
Exposed Population
Remedial Action
Objectives for Arsenic and
Lead
Arsenic
Soil
Direct contact and
incidental ingestion
Current and future residents
of north Tacoma and Ruston
Lead
Soil
Direct contact and
incidental ingestion
Current and future residents
of north Tacoma and Ruston
Reduce potential exposure of current and future
community residents to soil and dust so that these
exposures will be within acceptable risk levels. Reduce the
potential transport of soil contaminants inside homes or
other buildings where exposures may occur.
REMEDIATION GOALS
Contaminant
Arsenic
Lead
Goal
Contaminant
Concentrations in Soil
Reduce arsenic exposures to
ensure that the upper-bound
lifetime excess cancer risk
to an individual is between
10"4 and 10"6
230 ppm of arsenic
Reduce exposures to lead
to ensure that no individual
has greater than a 5 percent
chance of exceeding a
blood lead level criterion of
10 ng of lead per deciliter
of blood (10 |^g/dL)
500 ppm of lead
-------
Attachment 5
PACE Workgroup Goals for the Establishment
of Long Term Community Protection Measures
Ruston/North Tacoma
DRAFT - Junel998
Task/Goal Frequency jjr'' JPJ? Jr Comments
1) Provide notice prior to
disturbing soli under
hard surfaces
ongoing
P
s
s
Requires developing educational
materials (TPCMO) and IPCHD
tying into Rwstcm and Tacoma's
systems.
2} Maintain an off active
lev#! of awareness for
future generations:
• annual reminders
• historical markers
• communfty events
• educational materials
• Provide educational
resources for handling
soils between 20 ppm
and 230 ppm
Once a year
J>
ongoing
Sponsor unidentified.
s
p
p
ongoing
P
s
s
s
s
3) Monitor effectiveness
of ongoing program
?
p
s
s
s
s
Adjustments to meet changing
needs by committee of TFCHD.
Ecology, Ruston, N. End
Neigfibortiood Assoc, and A&areo
4) Maintain property
specific data base
ongoing
P
»
$
5) Provide sail disposal
service for generated
soils *230 ppm
ongoing
s
p
P = primary responsibility
s = support
G:\LIBSHARBWSTMGT\PROG\ASARCO\FORMS\LTCPM, DOC
-------
Attachment 6
Documents Reviewed
1. Record of Decision, Commencement Bay Nearshore/Tideflats Superfund Site Operable Unit 4,
Ruston/North Tacoma Study Area, Ruston and Tacoma, Washington, EPA Region 10, June
1999
2. Remedial Investigation Report for Ruston/North Tacoma, prepared by Bechtel Environmental,
Inc for EPA, January 1992
3. Feasibility Study Report for Ruston/North Tacoma, prepared by Bechtel Environmental, Inc for
EPA, January 1992
4. Baseline Risk Assessment, Ruston/North Tacoma Operable Unit, Commencement Bay
Nearshore/Tideflats Superfund Site, Tacoma, Washington, prepared for EPA Region 10 by
Gregory Glass and Science Applications International Corporation, January 1992
5. Revised Work Plan for Excavation and Removal of Soils, Ruston and North Tacoma,
Washington, prepared by Hydrometrics, Inc for Asarco, December 5, 1994
6. Ruston/North Tacoma Study Area Consent Decree for Remedial Design/Remedial Action,
May 2, 1995
7. Ruston/North Tacoma Site Preliminary Remedial Action Objectives Decision Memorandum,
EPA, January 1992
8. Scope of Work, Community Protection Measures, Ruston/North Tacoma Study Area, Revised
October 21, 1999
9. Monthly and Quarterly Progress Reports of the PACE Workgroup from 1994 - 1999.
10. PACE Evaluation Summary, Tacoma Pierce County Health Department, October 15, 1999
-------
Attachment 7
ASARCO
received
Thomas L. Aldrich
Site Manager
Tacoma Plant
FEB 1 0 2000
Environmental Cleanup Office
February 9, 2000
Mary Kay Voytilla
US EPA, HE 113
1200 Sixth Avenue
Seattle, WA 98101
RE: Sample Results
Dear Mary Kay,
As per your request, attached are the sample results for sod, topsoil and backfill used in the
Ruston/North Tacoma Residential Remediation Project from 1994 - 1999. If you have any questions,
please don't hesitate to call me.
Respectfully submitted,
Thomas L. Aldrich
Site Manager
Cc: Don Robbins, TSC
Karen Pickett, Asarco
Willie Williams, Hydrometrics
Marcia Newlands, HEWM
ASARCO Incorporated P.O. Box 1677 Tacoma, WA 98401 (253)756-0201
INFORMATION CENTER (253)756-5436 FAX: (253)756-0250
email: TLAIdrich@compuserve.com
-------
Ruston / North Tacoma Sampling Results
Topsoil
SAMPLE
NUMBER
LAB
NUMBER
SAMPLE
DATE
ANALYSIS
DATE
As
(ppm)
Pb
(ppm)
NW CD-BKF -1 -A 1
39338-1
4/8/94
4/11/94
<
1
44
wet chemistry
NW CD-BKF -1 -B1
39338-2
4/8/94
4/11/94
<
1
39
wet chemistry
NW CD-BKF -1 -C1
39338-3
4/8/94
4/11/94
<
1
43
wet chemistry
NW CD-BKF -1 -D1
39338-4
4/8/94
4/11/94
<
1
49
wet chemistry
NWCD-BKF-1-A4
39813-1
4/28/94
4/29/94
<
1
14
wet chemistry
NWCD-BKF-1-B2
39813-2
4/28/94
4/29/94
<
1
23
wet chemistry
NWCD-BKF-1-B3
39813-3
4/28/94
4/29/94
<
1
21
wet chemistry
NWCD-BKF-1-C2
39813-4
4/28/94
4/29/94
<
1
15
wet chemistry
NW CD-BKF -1 -A 1
40811-1
6/7/94
6/8/94
<
1
14
wet chemistry
NW CD-BKF -1 -A 1
94R-04557
8/24/94
8/26/94
<
1
11
NW CD-BKF -1 -A 1
94R-05243
9/22/94
9/22/94
<
1
<6
NWCD-BKF -2-A 1
94R-05244
9/22/94
9/22/94
<
1
13
NW CD-BKF -1 -A 1
94R-05711
10/17/94
10/12/94
<
1
17
NWCD-BKF-3-A1
94R-06716
11/21/94
11/21/94
<
1
67
NWCD-BKF-3-A2
94R-06717
11/21/94
11/21/94
<
1
66
HLOD-9503-001
95R-09766
3/31/95
3/31/95
<
1
<6
HLOD-9503-002
95R-09767
3/31/95
3/31/95
<
1
<6
HLRD-9507-004
95R-03779
7/19/95
7/19/95
<
1
<6
HLRD-9508-005
95R-05440
9/1/95
9/1/95
<6
ASRS-HLRD-200
96R-02212
3/6/96
3/7/96
40
ASRS-HLRD-201
96R-03572
4/30/96
4/30/96
<
1
8
ASRS-HLRD-202
96R-03573
4/30/96
4/30/96
<
1
<6
ASRS-HLRD-203
96R-04568
6/11/96
6/11/96
<
1
64
ASRS-HLRD-204
96R-07188
8/19/96
8/20/96
<
1
40
ASRS-HLRD-205
96R-07189
8/19/96
8/20/96
2
32
ASRS-HLRD-206
96R-10055
10/30/96
11/1/96
6
31
ASRS-HLRD-207
96R-10056
10/30/96
11/1/96
2
21
ASRS-HLRD-210
97R-06113
6/6/97
6/6/97
<
1
<6
ASRS-HLRD-211
97R-06114
6/6/97
6/6/97
<
1
<6
ASRS-HLRD-212
97R-09510
9/26/97
9/26/97
<
1
<6
ASRS-HLRD-300
97R-03338
5/1/97
5/1/97
<
1
<6
HYLD-0398-001
98R-00766
3/14/98
3/27/98
<
1
81
HYLD-0398-002
98R-00767
3/14/98
3/27/98
<
1
57
HLRD-0598-03
98R-01529
5/27/98
5/27/98
<
1
29
HLRD-0998-04
98R-02536
9/10/98
9/10/98
<
1
<6
HLRD-9903-100
99R-00073
3/16/99
3/16/99
<
1
<6
HLRD-9904-101
99R-00708
4/27/99
4/27/99
62
HLRD-9904-101B
87162-02
4/27/99
2/7/00
<
1
32
wet chemistry ret
HLRD-9905-102
99R-01416
5/24/99
5/24/99
<
1
11
HLRD-9905-103
99R-01417
5/24/99
5/24/99
<
1
11
HLRD-9906-104
99R-02428
6/26/99
6/26/99
<
1
14
HLRD-9906-105
99R-02429
6/26/99
6/26/99
<
1
13
HLRD-9909-106
99R-04974
9/11/99
9/11/99
<
1
76
HLRD-9910-107
99R-05927
10/17/99
10/17/99
<
1
24
HLRD-9910-108
99R-05928
10/17/99
10/17/99
<
1
16
HRLD-9910-109
99R-06484
10/29/99
10/29/99
<
1
<6
HLRD-9911-110
99R-07177
11/16/99
11/16/99
<
1
13
HLRD-9911-111
99R-07178
11/16/99
11/16/99
<
1
12
All test results from XRF analysis, unless otherwise noted.
-------
Ruston / North Tacoma Sampling Results
Backfill
SAMPLE
LAB.
SAMPLE
SAMPLE
ANALYSIS
As
Pb
NUMBER
NUMBER
DATE
TIME
DATE
(ppm)
(ppm)
LSNW-BKF-A1
39337-1
4/8/94
4/11/94
<11
<6
wet
LSNW-BKF-B1
39337-2
4/8/94
4/11/94
<11
<6
wet
LSNW-BKF-C1
39337-3
4/8/94
4/11/94
<11
<6
wet
LSNW-BKF-C2
39337-4
4/8/94
4/11/94
<11
<6
wet
LYDS-BKF-1-A1
39920-1
5/3/94
5/6/94
<11
<6
LSNW-SBSL-1-A1
39920-2
5/3/94
5/6/94
<11
<6
LYDS-BKF-1-A1
40461-1
5/24/94
5/25/94
<11
<6
LSNW-SBSL-1-A1
40461-2
5/24/94
5/25/94
<11
<6
LNST-PTRN-1-A1
94R-05902
10/21/94
10/21/94
<11
<6
Lonestar8189CR
94R-03551
7/20/94
7/20/94
<11
<6
PTRN-BKF-1-A1
95-R-09818
4/7/95
1500
4/1/95
<11
<6
LSPS-9504-100
95R-00233
4/18/95
950
4/25/95
<11
<7
LSPS-9504-101
95R-00234
4/18/95
1205
4/25/95
<11
<6
LSNW-SBSL-95054
95R-01890
5/26/95
1300
5/30/95
<11
<6
LSNW-SBSL-95055
95R-01891
5/26/95
1305
5/30/95
<11
<6
LSPS-9507-102
95R-03777
7/18/95
1520
7/24/95
<11
<6
LSPS-9508-103
95R -05441
9/1/95
845
9/13/95
<6
LSPS-9508-103B
87209-02
9/1/95
2/7/00
<11
<6
wet che
ASRS-LLPR-001
96R -02210
3/6/96
1015
3/7/96
<11
<6
ASRS-LLPR-002
96R-02211
3/6/96
1030
3/7/96
<11
<6
ASRS-LLPR-003
96R-02598
3/26/96
1020
3/26/96
<11
<6
ASRS-LLPR-004
96R-02599
3/26/96
1025
3/26/96
<11
<6
ASRS-LLRD-003
96R-03585
5/1/96
1100
5/1/96
<11
<6
ASRS-LLRP-004
96R-03586
5/1/96
1105
5/1/96
<11
<6
ASRS-LLRD-005
96R-05398
6/26/96
1100
6/27/96
<11
<6
ASRS-LLRD-006
96R-05399
6/26/96
1105
6/27/96
<11
<6
ASRS-LLPR-007
96R-07606
8/27/96
1100
8/28/96
<11
<6
ASRS-LLPR-008
96R-07607
8/27/96
1105
8/28/96
<11
<6
ASRS-LLPR-009
96R-09896
10/24/96
1100
10/28/96
<11
<6
ASRS-LLPR-010
96R-09897
10/24/96
1105
10/28/96
<11
<6
ASRS-LLRD-020
97R-02593
3/24/97
1300
3/26/97
<11
<6
ASRS-LLRD-021
97R-02594
3/24/97
1310
3/26/97
<11
<6
ASRS-LLPR-210
97R-06116
6/6/97
1320
6/6/97
<11
<6
ASRS-LLPR-211
97R-09677
10/1/97
1300
10/2/97
<11
<6
LLPR-0398-01
98R -00763
3/12/98
1310
3/13/98
<11
<6
LLPR-0398-02
98R-00764
3/12/98
1315
3/13/98
<11
<6
LLPR-0598-03
98R-01527
5/27/98
1300
5/27/98
<11
<6
LLPR-0598-04
98R-01528
5/27/98
1305
5/27/98
<11
<6
LLPR-0998-05
98R-02535
9/9/98
1310
9/09/98
<11
<6
LLPR-9903-100
99R-00071
3/16/99
1325
3/17/99
<11
<6
LLPR-9903-101
99R-00072
3/16/99
1330
3/17/99
<11
<6
LLPR-9905-102
99R-00832
5/5/99
1110
5/6/99
<11
<6
LLPR-9905-003
99R-01636
5/27/99
1050
5/27/99
<11
<6
LLPR-9907-004
99R-03205
7/23/99
1000
7/23/99
<11
<6
LLPR-9909-005
99R-05291
9/20/99
1105
9/20/99
<11
<6
LLPR-9910-006
99R-06302
10/26/99
1230
10/27/99
<11
<6
LLPR-9911-107
99R-07180
11/17/99
950
11/18/99
<11
<6
LLPR-9911-108
99R-07181
11/17/99
955
11/18/99
<11
<6
All test results from XRF analysis, unless otherwise noted.
-------
Ruston / North Tacoma Sampling Results
Sod
SAMPLE
LAB
SAMPLE
SAMPLE
ANALYSIS
As
Pb
NUMBER
NUMBER
DATE
TIME
DATE
(PPm)
(PPm)
BLCK-BKF-01 -A 1
39186-1
4/1/94
4/11/94
<11
10
wet chemistry
BLCK-BKF-02-A1
39186-2
4/1/94
4/11/94
<11
9
wet chemistry
BLCK-BKF-03-A1
39186-3
4/1/94
4/11/94
<11
10
wet chemistry
BLCK-BKF-04-A1
39186-4
4/1/94
4/11/94
<11
12
wet chemistry
BLCK-BKF-05-A1
39186-5
4/1/94
4/11/94
<11
9
wet chemistry
BLCK-BKF-06-A1
39186-7
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-07-A1
39186-8
4/1/94
4/11/94
130
84
wet chemistry
BLCK-BKF-08-A1
39186-9
4/1/94
4/11/94
<11
12
wet chemistry
BLCK-BKF-09-A1
39186-10
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-10-A1
39186-11
4/1/94
4/11/94
<11
10
wet chemistry
BLCK-BKF-11-A 1
39186-12
4/1/94
4/11/94
<11
9
wet chemistry
BLCK-BKF- 12-A1
39186-13
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-13-A1
39186-14
4/1/94
4/11/94
<11
10
wet chemistry
BLCK-BKF-14-A1
39186-15
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-15-A1
39186-17
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-16-A1
39186-18
4/1/94
4/11/94
<11
12
wet chemistry
BLCK-BKF-17-A1
39186-19
4/1/94
4/11/94
<11
11
wet chemistry
BLCK-BKF-18-A1
39186-20
4/1/94
4/11/94
<11
9
wet chemistry
BLCK-BKF-19-A1
39186-21
4/1/94
4/11/94
<11
10
wet chemistry
BLCK-BKF-20-A1
39186-22
4/1/94
4/11/94
<11
<6
wet chemistry
CTGN-9503-001
95R-09768
3/31/95
1225
3/31/95
<11
<6
CTGN-SOD-9505-4
95R-01892
5/26/95
1425
5/30/95
<11
<6
CTGN-SOD-9507-5
95R-03778
7/18/95
1610
7/24/95
<11
<6
CTGN-SOD-9508-5
95R-05439
9/1/95
740
9/13/95
19
<6
CTGN-SOD-9508-6
95R-05438
9/1/95
735
9/13/95
<6
CTGN-SOD-9508-6B
87209-01
9/1/95
735
2/7/00
<11
9
wet chemistry
ASRS-CTGR-201
96R-03574
4/30/96
955
4/30/96
<11
<6
ASRS-CTGR-202
96R -04569
6/11/96
1120
6/11/96
12
<6
ASRS-CTGR-203
96R-04570
6/11/96
1125
6/11/96
<11
<6
ASRS-CTGR-204
96R-07190
8/19/96
1200
8/20/96
<11
<6
ASRS-CTGR-205
96R-10057
10/30/96
1625
11/1/96
21
<6
ASRS-CTGR-205B
87162-01
10/30/96
1625
2/7/00
17
17
wet chemistry retest
ASRS-CTGR-206
97R-06115
6/6/97
1100
6/6/97
<11
<6
ASRS-CTGR-207
97R-09509
9/26/97
730
9/26/97
<11
<6
ASRS-CTGR-300
97R-03339
5/1/97
1400
5/1/97
<11
<6
CTGR-0398-001
98R-00765
3/14/98
1235
3/27/98
<11
<6
CTGR-0598-03
98R-01530
5/27/98
1525
5/28/98
<11
<6
CTGR-0998-05
98R-02537
9/10/98
935
9/10/98
<11
<6
CTGR-9903-100
99R-00074
3/16/99
1605
3/17/99
<11
<6
CTGR-9904-101
99R-00706
4/27/99
655
5/3/99
<11
<6
CTGR-9904-102
99R-00707
4/27/99
700
5/3/99
<11
<6
CTGR-9905-103
99R-01418
5/24/99
1120
5/25/99
<11
<6
CTGR-9909-104
99R-04975
9/11/99
945
9/14/99
<11
<6
CTGR-9909-105
99R-04976
9/11/99
950
9/14/99
<11
<6
CTGR-9910-106
99 R-06483
10/29/99
1135
11/1/99
<11
<6
CTGR-9911-107
99R-07179
11/16/99
1350
11/18/99
<11
<6
All test results from XRF analysis, unless otherwise noted.
-------
Attachment 8
-------
Attachment 9
List of Informational Brochures Prepared by the Program for Area Cleanup Education
Workgroup
1. Information Regarding Properties that Will Not Require Remediation
2. Background on Soil Sampling
3. Soil Sampling/Replacement questions and Answers
4. Study Area Zones Map
5. Handling and Disposal of Study Area Soils
6. Property Owner Guidelines and Responsibilities in Remediated Yards With Caps
7. Yard Replacement Care and Responsibilities Contract
8. Property Owner Guidelines and Responsibilities for Expedited Response Properties
9. Newly Planted Sod Care
10. Procedure for Out of Sequence Sampling Requests
11. Questions and Answers Regarding Soil Handling Guidelines at the City of Tacoma Landfill
12. Citizens Guide to Arbitration
13. Ruston/North Tacoma Arbitration Rules and Procedures
14. Handling and Disposal of Study Area Soils in Commercial Settings
15. Property Owner Guidelines and Responsibilities in Remediated Yards
-------
iJSSEIj
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, WA 98101
Reply To
Attn Of: ECL-115
March 31, 2000
Mr. Jim Wickes
AT&T/Alascom, Inc.
210 East Bluff Drive
Anchorage, AK 99501
Re: Neklason Lake Radio Relay Site
Dear Mr. Wickes:
The U.S. Environmental Protection Agency (EPA), through its contractor, Ecology and
Environment, conducted sampling of your multi-purpose water well on January 4, 2000. Enclosed are
analytical results for the sample collected. The table includes EPA drinking water standards and results
for each compound/analyte that was detected. The following were not detected in the sample:
semivolatile organic compounds, chlorinated pesticides, polychlorinated biphenyls, gasoline range
organics, and diesel range organics
If you have questions, I can be reached at 206 553-0115 or leblang.deborah@epa.gov.
Sincerely,
]
Site Assessment Manager
Site Assessment/Cleanup Unit II
Enclosure
cc: Greg Light, ADEC, 610 University Avenue, Fairbanks, AK 99709
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Analytical Results
Site Name:
Site Location:
Owner/Representative:
Neklason Lake Radio Relay Site
Palmer, Alaska
Mr. Jim Wickes
AT&T/Alascom, Inc.
210 East Bluff
Anchorage, Alaska 99501 Drive
(907) 264-7343
Sampling Date:
Sampling Medium:
Sample Analyses:
January 4, 2000
Groundwater
Volatile Organic Compounds (EPA Method 8260B)
Semivolatile Organic Compounds (EPA Method 8270)
Chlorinated Pesticides (EPA Method 8081)
Poly chlorinated Biphenyls (EPA Method 8082)
Target Analyte List Metals (EPA 6000 and 7000 Series Methods)
Gasoline Range Organics (ADEC Method AK101) Diesel Range
Organics (ADEC Method AK102)
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ANALYTICAL RESULTS
NEKLASON LAKE RADIO RELAY PRELIMINARY ASSESSMENT
TANACROSS, ALASKA
fag/L)
EPA Sample No.:
00010000
Compound/Analyte
Maximum
Contaminant
Level Goals3
Maximum
Contaminant
Level3
Site Well
Organics
Chloroform
NA
100
2
Inorganics
Aluminum
NA
NA
700
Calcium
NA
NA
51,000
Iron
NA
NA
260
Lead
NA
15
1.4
Magnesium
NA
NA
9,800
Manganese
NA
NA
64
Sodium
NA
NA
3,800
Zinc
NA
NA
91
Key:
a = Values obtained from EPA, Office of Water, Fact Sheet, October 1996 (EPA 822-B-96-002). Internet Address:
http://www.epa.gov/OST/Tools/dwstds-s.html.
EPA = United States Environment Protection Agency.
NA = Not applicable. A value has not been established.
|ig/L = micrograms per liter.
Notes:
Maximum Contaminant Level Goals are defined as non-enforceable concentrations of drinking water contaminants that are
protective of adverse human health effects and allow an adequate margin of safety (EPA 822-B-96-002).
Maximum Contaminant Levels are defined as the maximum permissible level of a contaminant in water which is delivered
to any user of a public water system (EPA 822-B-96-002).
The State of Alaska does not have established drinking water standards for these compounds/analytes (Alaska code
18.AAC.80).
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