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Record of Decision:
Western Processing Site, WA
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TECHNICAL R6PO«T DATA
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~4fORT NO.
EPA/ROD/R10-84 /003
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SUPERFUND RECORD OF DECISION
Western Processing, Inc. WA
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08/05/84
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12. SPONSORING AGINCY NAMI ANO AOORSSS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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Final ROD Report
14. SPONSORING AGCNCV COOt
800/00
It. ABSTRACT "
The Western Processing site occupies approximately 13 acres in Kent and King
Counties, WA. Originally Western Processing was a reprocessor of animal byproducts
and brewer's yeast. In the 1960's the business expanded to recycle, reclaim, treat
and dispose of industrial wastes, including waste oils, electroplating wastes,
waste pickle liquor, battery acids, flue dust, pesticides, spent solvents, and
zinc dross. The facility is presently inactive and consists of 10 buildings in poor
repair, a solvent recycling plant, a fertiliser-plant, 72 bulk storage tanks of
varying capacities, drum storage areas with 2,000 partially filled drums and 3,600
empty drums, piles of flue dust, and battery chips. The soil and ground water samples
confirmed that hazardous substances had been released into the environment. Among
the more hazardous contaminants found on or below the site are chloroform, benzene,
1,2 -dichloroethane, trichloroethylene, phenol, arsenic, cadmium and cyanides.
The surface clean-up and stormwater control project is the first operable unit
of the overall remedial action at the sit*. The main elements of the selected
alternative include: characterize all materials identified for remova; removal of
all bulk liquids, drummed liquids, and waste piles to a permitted off-site facility
for disposal or incineration; removal and proper disposal of all transforraers and
substation equipment; demolition and removal to a permitted off-site facility of all
on site buildings &.dismantling of all on-site bulk storage tanks. Capital Cost S5.0
Ifvev Mirns ar r^i-n^n i
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Record of Decision
Western Processing, Inc., WA
Contaminated media: gw, soil
Key contaminants: oils, acids, solvents,
pesticides, VOCs, metals, TCE, DCE,
arsenic, cadmium, cyanides
IS. OlSTRISUTIOM STATIMSNT
is. StCVJRiTY ClASS (T»U$ Htpont
None
1
». SSCURITY CUASS fpu» pf)
None
73. 'RtCl
If A 222S-I <*•». 4-771
E A 0 0 0 2
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-/-
ENFORCEMENT DECISION MEMORANDUM
FIRST OPERABLE UNIT OP REMEDIAL ACTION SELECTION
Sitei Western Processing Company, Inc., King County,
Kent, Washington
ANALYSIS REVIEWED
I have reviewed the following documents describing the
analysis of the cost-effectiveness for the Phase I remedial
measures for the Western Processing Site.
1. Summary of First Operable Unit Remedial Alternative
Selection at the Western Processing Site.
2. Draft Final Focused Feasibility Study for Surface Cleanup,
June 4, 1984, by CH2M Hill, and amended on June 15, in the
Detailed Analysis Condeptual Design for Surface Cleanup.
3. Proposal for Surface Remedial Activities, prepared by
Chemical Waste Management, Inc., ENRAC Division, June 26,
1984, for Western Processing Coordinating Committee.
4. Memorandum dated July 12, 1984, from Robert G. Courson to
Jerry Schwartz and Madeline Nawar on Recycling of Liquids
from WP during PRP removal.
5. Memorandum dated June 22, 1984, from George Hofer to
Judi Schwarz on CSSI Facility In Arlington, OR.
DESCRIPTION OF SELECTED ALTERNATIVE
The main elements of the selected alternative include:
I. On-site and perimeter sonitoring of air quality during
remedial activities.
II. Removal of all bulk liquids, drummed liquids, and waste
piles to a permitted off-site facility for disposal or
Incineration.
III. Removal and proper disposal of all transformers and
substation equipment.
IV. Demolition and removal to a permitted off-site facility
of all on-site buildings.
V. Dismantling of all on-site bulk storage tanks. If tanks
are determined to be structurally sound, such tanks will
be thoroughly cleaned and sold for scrap metal.
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VI. All other surface debris will be removed end disposed.
VII. Stormwater will b* controlled and treated prior to discharge
before, during, and after the surface cleanup. After the
initial pond removal, an on-site treatment plant will be
set up and operated.
Each solid waste pile shall be removed down to the existing
grade level at the site location on which it was situated. The
exception will be the accumulated "gyp" pond pile. Op to 750
cubic yards of soil below existing grade level will be removed
in addition to the pile itself. This depression will form a
storm water accumulation area for use subsequent to the surface
cleanup. Adjacent areas to th« South will be graded to provide
drainage to the area. The estimated cost for total response
action is reported to be approximately $9 million.
DECLARATION
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CPR Part 300), 1 have determined that the
above remedial measures for the Western Processing Site will
effectively mitigate and minimize damage to, and provide for
current and future protection of public health, welfare and
the environment. The State of Washington has.been consulted and
agrees with the selected remedy.
I have also determined that the action being taken which
includes the off-site transport of contaminated materials to
a RCRA approved facility is the least costly alternative when
compared to the other remedial options reviewed, and is necessary
to protect public health, welfare, or the environemnt.
Assistant Administrator
Office of Solid Waste and
Emergency Response
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SUMMARY OF FIRST OPERABLE UNIT REf€DIAL ALTERNATIVE SELECTION AT
THE WESTERN PROCESSING CONPANY, INC. SITE,
KENT, WASHINGTON
SITE LXATION AND DESCRIPTION
Western Processing Company, Inc. is located at 7215 South 196th Street in
Kent, King County, Washington. The facility covers approximately thirteen
acres in Section 1, Township 22 North, Range 4 East (WM). The general
area around the site is rapidly developing for commercial and industrial
purposes although there is a limited amount of agricultural and
residential use in the vicinity. One family lived across the street in a
rented house until May 1984. A vicinity map is provided as Figure 1; a
site map is provided as Figure 2.
The site is flat and lies in the flood plain of the Green River, which
drains to Puget Sound. Mill Creek abuts a portion of the western boundary
of the site, and eventually reaches the Green River. Surface runoff from
the site reached Mill Creek both directly and indirectly, through seeps,
springs and surrounding drainage ditches.
Underlyi ng the site is an aquifer, the upper limit of which ranges from
three to twelve feet below the surface. Deeper portions of this aquifer
underlie a discontinuous set of clay lenses, to a depth of at least 170
feet. A deeper artesian aquifer may exist below an undefined thickness of
confining layers of silt and clay in the vicinity of the site. There are
no wells currently used for drinking water within a one mile radius of the
site, but the City of Kent (population 27,000) has drilled wells into the
deeper portions of the aquifer less than a mile from the site in an
attempt to develop a drinking water supply for the city. Other wells have
withdrawn water for domestic use from the shallower aquifer in the past.
The ground water system is complex. While the regional groundwater flow
direction is generally north and west, a groundwater "mound" beneath the
site creates radial, and possibly downward, flow from the site, and may
have created a hydraulic head driving contaminated groundwater down into
lower portions of the aquifer. The native soils are generally of moderate
to low permeability, though the fill materials on the site are generally
highly permeable.
The facility presently consists of 10 buildings, including a small
laboratory , a solvent recycling plant, a fertilizer plant, at least 72
bulk storage tanks of varying capacities, several drum storage areas which
still contain at least 2000 non-empty drums, piles of flue dust, battery
chips, and over 3,600 empty drums, construction debris, a system of
concrete surface impoundments, and berms and fences. The buildings and
other items are in poor repair. Approximatly 2 acres of the site are
newly paved, covered, and bermed from Washington Department of Ecology
(DOE) activity in October 1983. A two acre-feet stormwater lake has
accumulated in the typographic low spot in the center of the site because
the owner/operator's illegal discharges of untreated stormwater to Mill
Creek have ceased.
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SITE HISTORY
2
From 1953 to 1961, the site was leased from its then current owner and
developed and used as a U. S. Army Nike Anti-Aircraft Artillery facility.
In 1961, the property was sold to Western Processing Company, Inc, which
had been founded by Garmt J. Nieuwenhuis in Seattle in 1957. Western
Processing Company is still owned and operated by Mr. Nieuwenhuis, though
over the years his wife, son, and at least one other person have been
officers of the corporation at various times.
Originally Western Processing was a reprocessor of animal byproducts and
brewer's yeast. In the I960's the business expanded to recycle, reclaim,
treat and.dispose of many industrial wastes, including waste oils,
electroplating wastes, waste pickle liquor, battery acids, steel mill flue
dust, pesticides, spent solvents, and zinc dross. Some of the Pacific
Northwest's largest industries, such as the Boeing Company, had contracts
for Western Processing to handle their wastes.
Operations included heavy metals recovery, waste solvent recovery, acids
and caustics neutralization, chemical recombination to produce zinc
chloride and lead chromate, reclamation of ferrous sulfide in fertilizer
production, electrolytic destruction of cyanides, reclamation of metal
finishing byproducts, and pickle liquor reprocessing.
Reviews of historical aerial photos disclose great changes in the site's
uses and structures every few years as Western Processing's operations
changed. Reproductions of some of these photos are attached as Figures 2,
3, and 4. In addition, it is believed that the original ground level was
covered and raised by the materials added to the site. The aerial photo
in Figure 3 shows the site shortly before it was closed down.
The Kent Fire Department was one of the first agencies to have contact
with Western Processing when fires in the early 1970's brought the
conditions at the site to their attention. The Washington State
Department of Ecology (DOE), and its predecessor agency, the Pollution
Control Commission, have monitored and attempted to control wastewater
discharges from Western Processing for many years. Discharges were
regulated by permit until late 1981. At that time Western Processing had
failed to construct wastewater discharge control facilities as required by
permit, and, in 1982, elevated metals concentrations were detected in Mill
Creek adjacent to the site. In August 1982, the King County Superior
Court, acting on a DOE motion, issued an order prohibiting further
discharges of zinc contaminated water from Western Processing into Mill
Creek. The company was ordered to partially close and to remove
zinc-laden wastes from the site at that time. The company appealed this
order and the issues are still outstanding in state courts. Several other
local agencies, including the Puget Sound Air Pollution Control Agency,
and the Seattle-King County Health Department have or have had pending
regulatory actions or concerns with the company.
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EPA's first major regulatory involvement with Western Processing came
through the RCRA program. (In the late 1970's SPCC actions had been taken
by EPA against the company.) EPA inspected the site in March 1981 to
determine compliance with the newly-effective regulatory scheme of RCRA.
Many violations were documented. Although the company notified EPA of its
hazardous waste activities prusuant to RCRA Section 3010, an
administrative order in May 1981 and substantial negotiations thereafter
were necessary to convince the company to submit a Part A application.
(The company claimed that as a "recycler" they did not have to comply with
RCRA. ) Subsequent negotiations between Western Processing and EPA
resulted in little progress toward correcting the violations. EPA issued
a second compliance order in June 1982, after another inspection in May
1982 revealed additional significant violations and questionable site
management. This second order assessed a $210,000 civil penalty. In
February 1983, EPA filed suit in Federal District Court seeking, inter
alia, injunctive relief and civil penalties concerning the RCRA
violations. This case has since been adrc>ended to include CERCLA counts
against the owner/operator of the site.
As a follow-up to the earlier State and local stream surveys for metals,
in May 1982, EPA conducted a stream survey around Western Processing.
Twenty-six priority pollutants were found in the surface waters around the
site, all of which were subsequently found on-site. In July 1982 the site
was added to the National Priorities List.
In August 1982, EPA issued a RCRA 3013 order to the site owners/operators
to investigate the effects of their past practices on soil, surface water
and groundwater. When the owners/operators did not comply (due to alleged
financial inability), EPA undertook the investigation and ordered them to
reimburse the Agency for its expenses.
The investigation, which entailed the drilling of 32 on-site wells and six
off-site wells from 15 to 30 feet deep at 30 locations, began in September
1982 and concluded in November. In all, 130 soil samples were taken and
35 groundwater samples were obtained from the wells.
The analyses of these samples confirmed that hazardous substances had been
released into the environment, had been leached into and contaminated the
subsurface aquifer, and had caused widespread contamination of the soils
at the site. Samples of groundwater beneath the site contained 32
priority pollutants, of which eight are carcinogens. Soil samples on and
beneath the site contained 49 priority pollutants, of which nine are
carcinogens and twelve more are suspected carcinogens. Water and sediment
samples taken from Mill Creek contained 41 priority pollutants, of which
11 are carcinogens and 8 more are suspected carcinogens. Tests showed
that hazardous substances had spread throughout the aquifer beneath the
site and its environs to a depth of at least 170 feet and throughout the
soil beneath the site to a depth of at.least 15 feet. At least 19 of the
soil samples and six of the groundwater samples were defined as hazardous
wastes by the standards of RCRA regulations. Among the more hazardous
E A 0 0 0 7
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4.
contaminants found on or below the site are chloroform, benzene,
1,2-dichloroetnane, benzo-a-anthracene, benzo-b-fl uoranthene,
tri chl oroettylene, phenanthrene, naphthalene, fluorene, chrysene, pyrene,
trans-1,2-dichlorethene, 1,1,1 -trichloroethane, toluene, phenol, arsenic,
chromium, cadmium, lead, mercury, and cyanides.
When preliminary results of the Fall 1982 investigation became available
in early April 1983, EPA issued a CERCLA Section 106 order requiring the
owners/operators to cease operations immediately and to provide assurances
that they would and could clean up the site. When the assurances were not
made, EPA used Superfund money to conduct an immediate removal.
The immediate removal began in late April 1983 and was completed on July
1 , 1983. The removal project cost $1.4 million. The purpose of the
project was to eliminate the extremely high hazards of the site and to
stabilize the site as much as possible to prevent additional degradation
of the soil and groundwater. Table 1 is a summary of the material taken
from the site. Large quantities (920,000 gallons plus 1,944 cubic yards)
of the most hazardous substances on the site were removed. Attempts were
made to find users for the materials, but most were sent to approved
hazardous waste disposal sites. Many other hazardous substances were
stabilized and left on the site.
Once the emergency removal was completed, EPA went back to court to ensure
that the owner/operator would not start up operations which could undo the
work which had been done. A preliminary injunction was issued which
prohibits the owner from receiving or processing materials, gives EPA and
its representatives site access, and which required EPA's prior approval
for all activities the owner/operator may wish to perform on the site.
The judge also specifically found that the site was an imminent and
substantial endangerment to the environment.
Stormwater management was going to continue to be a major problem until
the site was completely cleared and cleaned. Using State funds, DOE
implemented a stormwater initial remedial measure involving excavation of
the gypsum sludge pond, restacki ng and covering the material, and paving a
2 acre portion of the site. A cooperative agreement for a stormwater IRM
to handle stormwater control over a larger portion of the site was signed
in December 1983, but the project was put on hold when the bids came in
much higher than the available budget.
EA0008
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5.
Table 1
MATERIALS REMOVED FROM THE WESTERN PROCESSING SITE
DURING THE APRIL - JULY 1983 IMf€DIATE REMOVAL
1. SOLIDIFIED PAINT SLUDGES/FLAMMABLES
1,900 cubic yards
2. FLAMMABLE LIQUIDS IN BULK AND DRUMS
59,000 gallons
3. COMBUSTIBLE LIQUIDS IN BULK
85,000 gallons
4. RECYCLED SOLVENTS
25,000 gallons
5. CORROSIVE LIQUIDS IN BULK AND DRUMS
50,000 gallons
6. NON-CORROSIVE OXIDIZERS IN DRUMS
660 gallons
7. PCB LIQUIDS AND PCS CONTAMINATED MATERIALS
127 drums
8. WASTE WATER FROM PONDS
250,000 gallons
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CURRENT SITE STATUS
6
The Section 3013 study described above in the Site Hi story section
confirmed that hazardous substances had been released into the
environment, had been leached into and contaminated the aquifer beneath
the site, and had caused widespread contamination of the soils at the site.
Table 3 includes a list of the wastes still on the surface of the site.
The materials identification and classification task of the focused
feasibility study for the current surface clean-up project identifies 28
classes of materials still on the site. Volumes for the various wastes
were estimated from previous information and a field reconnaissance done
during the past two months.
A recent aerial photo (Figure 4) displays the current condition of the
site.
The onsite drums vary from 2000 full drums stacked on pallets to
6,000 empty drums stored randomly in piles. The condition of
the drums ranges from good (ie, perhaps structually suitable for
transporting offsite) to currently leaking.
The tanks holding approximately 500,000 gallons of fluids and
sludges have no current evidence of leakage, though some minor
leaks were noted during the past winter. The tops of some tanks
are unstable or non-existant.
The waste piles of approximately 3,000 cubic yards of battery
chips and approximately 2,000 cubic yards of flue dust are
uncovered, though the new gypsum pile has an engineered plastic
cover top and bottom. The battery chips and flue dust contain
significant quantities of leachable lead and zinc.
Approximately 2 acre-feet of water has accumulated in the center
of the site because of a naturally occurring low point in the
site topography and the ceasation of the owner's illegal
discharges which used to keep the site drained.
Miscellaneous equipment and debris, including 4,000 used wooden
pallets, are scattered throughout the site.
The 10 buildings are in generally poor condition.
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The exact lateral and vertical extent of the subsurface contamination is
now being determined. Tests to date show that hazardous substances have
spread throughout the aquifer beneath the site and its environs to a depth
of over 100 feet and throughout the soil beneath the site to a depth of at
least fifteen feet. Additional soil boring and well construction
activities are being conducted to further define the extent of
contamination. Preliminary results lead the region to believe that
widespread surface soil contamination exists to the north and west of the
si te.
Contaminants can and probably are continuing to leave the site through a
variety of pathways. While the native soil is of moderate to low
permeability, fill material on the site is generally very permeable and
the depth to groundwater is shallow - as little as 6 to 10 feet. As far
as can be determined, this shallow aquifer is not currently used as a
source of domestic water in the area, though several old wells have been
located. A large percentage of the population in the area is served from
wells drawing from the deeper aquifer.
Except in the newly paved clean area, hazardous materials can easily enter
the soil column, groundwater, and through nearby seeps and springs, the
surface water. Fugitive dust containing high concentrations of lead, zinc
and other metals has been collected across the street from the site. The
zinc, and other contaminants in the stream have left the stream largely
devoid of aquatic life in recent years.
Direct contact with contaminated materials from the site may be occuri ng
both on and off the site. The surrounding area is rapidly being developed
for industrial and commercial uses, including those plots generally
downwind from the site. A jogging path is adjacent to the site to the
east. A family which includes a young child resided across the street
from the Western Processing gate until May 1984.
On-site access is restricted to EPA and state employees and contractors,
and to persons whom the owner authorizes access. EPA has maintained a
daily to weekly surveillance of the site since July 1983.
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ENFORCEMENT
8
Reports submitted by Western Processing to EPA and state agencies, as well
as Western Processing business records obtained as part of the Section 106
administrative order, were used in the spring and summer of 1983 to
identify over 300 generators and transporters who contributed material to
Western Processing. 225 notice letters were sent in May and June 1983,
with an additional 100 notice letters sent in October 1983. These letters
notified the generators and transporters that they may be liable for all
monies spent by the government and requested answers to five questions
regarding their shipments to Western Processing within 30 days. Responses
to EPA's notice/Section 104e letters gave EPA the names of some other
potentially responsible parties (PRPs) as well as enlarging the
information base available to EPA on specific shipments.
The period following the notice letters also provided an oportunity to
educate the PRPs about the seriousness of the problems at the site and
their responsibilies under CERCLA as generators and transporters.
The first large meeting with the PRPs took place on January 1 1, 1984.
After the government's presentation was completed, the PRPs took the
oportunity to begin to set up an organizational structure. Preliminary
negotiations/talks continued with an ad hoc PRP committee until May 1984.
These preliminary talks primarily concerned exchange of information, and
EPA's plans.
The extensive computer data base put together by EPA's contractor
Techlaw/Intera has been used to provide information to the PRPs. A
transaction listing has been sent to individual PRPs only after EPA
receives a signed affividat stating the PRP has searched their files, has
provided a summary of all relevant information to EPA, and will give EPA
reasonable access to the original information. A list showing the total
quantities taken to the site by each PRP has been provided to all PRPs and
is being used by the PRP committee to apportion costs. This data base has
also been invaluable in resolving issues of whether we have correctly
identified a particular PRP.
EPA's and DOE's decision to move forward and ensure that the surface of
the site is cleared during the summer of 1984 was the impetus which
accelerated the pace of negotiations. On April 11,1984 a letter was sent
to all PRPs stating that the PRPs had until June 18, 1984 to agree to
undertake the surface clearance or the government will do it and seek cost
recovery. In early May, the PRPs met among themselves and set up a
coordination committee as well as special subcommittees. On May 30, 1984,
a proposed plan for surface clearance which had been approved by the PRPs
technical subcommittee, was presented to the government. On June 19, 1984
agreement in principal on the concent decree was reached between the
government and the participating PRPs. The PRPs intend to start work
before the consent decree has been accepted by the courts in order to take
advantage of the summer's drier conditions.
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9
ALTERNATIVES EVALUATION
The objectives of this surface clean-up project, a first operable unit of
the remedial action are:
1. Eliminate or reduce the threat of release of additional hazardous
substances into the surface water, groundwater, soils and the air.
2. Prevent or eliminate direct contact hazards for the people who
must go on. the site for remedial investigation and site surveillance
activities, and for potential fire or emergency response actions.
3. Allow the design and implementation of additional and more
wideranging and effective stormwater control to reduce the release of
hazardous substances into the ground and surface water.
4. Prepare the surface of the site during this construction season
so that the subsequest remedial actions on the site can begin earlier
and possibly be completed during the next construction season.
Subsequent remedial actions will consider groundwater, subsurface and
off-site contamination.
Identification of surface clean-up remedial action alternatives
The PRPs submitted a surface clean-up plan to the government on May 30,
1984. The same week, a Focused Feasibility Study (FFS) was completed by
CH2M Hill and released to the public. The PRP plan and the FFS both came
to similar conclusions as to the feasible and cost-effective alternatives
for the surface clean-up. All alternatives are source control measures.
This discussion of alternatives is based on the FFS only.
The objective of the FFS was to use the critiria outlined in the National
Contingency Plan to determine the alternatives with the greatest
feasibility of application at Western Processing. For a first step,
remedial action alternatives for each of the 28 categories of wastes
described above were developed on a waste-by-waste basis. The
alternatives were selected for evaluation if they could apply to the waste
types identified at Western Processing, could be used cost effectively
with the volumes of each waste currently onsite, could be implemented
during this construction season, and were a proven technology. The types
of alternatives that met these first criteria are listed in Table 2 and
are described below.
1. No tetion
An alternative considered for all waste materials on the Western
Processing site was that of "no action". This option was not considered
to be a feasible alternative for any of the hazardous or liquid materials
on the site.
EA0013
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10.
No-action was deemed to be an unacceptable alternative for any type of
drummed or tanked liquid waste, because of the high probability that
additional surface water or groundwater pollution eventually will occur if
liquids are allowed to remain onsite. Many drums and tanks are already in
poor condition, additional deterioriation is certain to happen with time.
In addition, accidents or vandalism of the drums or tanks could occur. If
these materials spill on the ground as a result of container failure,
surface and groundwater pollution will undoubtedly occur.
Many of the solid materials on site either contain leachable or
particulate sized hazardous substances or are contaminated by hazardous
substances. No action for these materials is unacceptable because they
will continue to be a source of release of hazardous substances to the
environment, particularly the groundwater.
A major problem with leaving anything on the surface of the site is that
it would interfer with achieving two of the goals of the remedial action.
First, materials on the surface of the site would interfere with the
implementation of a better stormwater control program. Second, because
the soil is very contaminated, all materials will have to be removed from
the surface of the site for the second phase of the remedial action, which
is planned to begin next year.
2. On site Treatment
The Western Processing site contains contaminated water resulting from
previous cleanup operations and from rainwater falling on contaminated
surfaces, such as in empty tanks and on the ground surface. More
contaminated water will be generated over the summer from additional rain
and decontamination water. One option for removing this waste is to treat
it on-site in order to remove most of the contaminants and then discharge
the water to the sewer or the Mill Creek. Mobile treatment equipment is
readily available for this type of cleanup operation. This alternative
will be part of the aqueous waste removal and the storm water control
project.
3. Offsite Treatment
Several aqueous wastes located on the Western Processing site are be
suitable for offsite treatment and disposal. The water is contaminated
with low concentrations of heavy metals, as well as a wide variety of
organic contaminants. Several offsite treatment facilities in the local
area are capable of treating this water to remove the metals and organics,
making it suitable for discharge to the sewer or surface water. In
addition, these facilities are equippted to neutralize corrosive materials
for di scharge. This alternative is proposed for the initial removal of
the stormwater currently ponded on site.
EAO 014
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11.
4. Non-hazardous Waste Landfill
The Washington State Solid Waste Management, Recovery and Recycling Act
assigns local governments the responsibility for handling the disposal of
solid wastes. Local health departments are assigned the enforcement
function subject to standards established by the State Department of
Ecology (Minimum Functional Standards for Solid Waste Handling--Washington
Administrative Code 173-301 ) or standards adopted by the local health
department of equivalent or greater stringency. King County contains
landfills operated by the County, the City of Seattle, small
municipalities, and private industry. None of these landfills accepts
wastes classified as dangerous by the State. None of the landfills in
Snohomish County (north of King County) or Pierce County (south of King
County) accept dangerous or hazardous wastes.
The various landfills all have different specifications regarding the
acceptable levels of contamination, size, and physical properties of the
wastes they will accept. In addition each may arbitrarily decide not to
accept any particular waste. Most of these landfills have vocal local
citizen groups monitoring their operations.
Solid materials which are suitable for clearing, such as tires, may be
disposed of in these local landfills. Other, more porous materials, such
as pallets and certain building material s, were determined not to be
suitable for disposal in the non-hazardous landfills. The testing and
cleaning costs, combined with the uncertainty of the materials ever being
allowed into the landfills, result in this not being a reliable and
feasible alternative.
5. Hazardous Waste Landfill
Most of the materials on the surface of the Western Processing site are
substances that cannot be recycled and that have contaminants high enough
to be designated by the WDOE Dangerous Waste Regulations (WAC 173-303) as
dangerous or extremely hazardous and thus must be treated or disposed of
by an approved treatment, storage, and disposal (TSD) facility.
Under the EPA hazardous waste regulations, hazardous waste landfills are
designated as one type of TSD facility. Hazardous waste in the State of
Washington can be stored and disposed of by two types of facilities:
dangerous waste landfills and extremely hazardous waste landfills. There
are currently no dangerous waste landfills in Washington that could accept
waste such as has been identified at Western Processing, nor does
Washington have an extremely hazardous waste landfill. Currently,
dangerous and extremely hazardous wastes in Washington are sent out of
state to EPA-approved hazardous waste landfills, the closest being in
Arlington, Oregon.
This alternative is the recommended alternative for most of the waste
types found on the Western Processing site.
EAO 0 1 5
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12.
6. Discharge to Metro
The Municipality of Metropolitan Seattle (Metro) is the agency responsible
for the sewage treatment activities and water quality monitoring in King
County. Metro operates and maintains the sewage treatment plants (and
main trunk sewer lines) in King County. The cities around Seattle are
responsible for the lines entering Metro's trunk lines and for issuing
permits for sewer hookups. Each city in turn must meet Metro's
requirements. Metro's Industrial Waste Section issues discharge permits
and monitors industrial companies discharging into the system. The
Industrial Waste section also has enforcement authority and issues fines
to companies that do not conform to their discharge permit requirements.
Discharge from Western Processing would flow to Metro's Renton secondary
treatment plant and subsequently be discharged into the Duwamish River.
Metro's Renton treatment plant has an NPDES permit from the EPA for its
discharge into the Duwamish River. Factors controlling the dischharge to
the Metro system include Metro's compliance with its WDOE NPDES permit,
the Renton plant's treatment capabilities, and safety factors for
maintaining the sewer lines. These factors force strict limitations on
the maximum levels of contaminated, dangerous, or hazardous wastewater
discharged into the Metro's system.
This alternative may be part of the aqueous waste removal and stormwater
control project.
7. Discharge to Mill Creek
This alternative may also be part of the aqueous waste removal and
stormwater control project. An NPDES penmit issued by WDOE must be
obtained and the wastes treated to the permit discharge criteria. The
regulations in the permit will cover basic EPA requirements as well as any
more stringent requirements that might be imposed by state or local
agencies.
8. Incineration/Fuel Source
A portion of the hazardous materials stored at Western Processing are
flammable and could be destroyed by commercial hazardous waste
incineration. Hazardous waste incineration is the process of burning the
material in a high-temperature furnace with a long residence time. The
units are usually equipped with a caustic scrubber to remove particulates
and acidic gases. CH2M Hill, as part of the FFS, was unable to locate any
commercial hazardous waste incinerators in the Pacific Northwest.
An alternative to commercial hazardous waste incineration of these wastes
would be to burn them and recover their fuel value. There are, however, a
number of limitations in the types of acceptable combustion devices
available and the suitability of materials onsite for use as fuels. For
example, some of the "synfuel s" are contaminated with methylene chloride.
Some of the "synfuel" materials, if still pure "oxazolidone", may be
suitable for incineration at a cement kilm in California. The original
generator of this "oxazolidone" currently disposes of this waste at this
kilm.
EAO 016
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13.
A third alternative would be ocean incineration. The At Sea incinerator
ships are being constructed in nearly Tacoma, Washington. However, there
have been many delays in At Sea's clearance for a test burn. The FFS did
not recommend this alternative because of timing and regulatory
uncertainities.
9. Recycle/Reuse
The Western Processing site contains some waste materials that could be
recycled or resued. Solids in this category include pallets, empty drums,
empty tanks, scrap steel, and zinc oxide, among others. Most liquids that
potentally could be recycled were removed from the site during the
immediate removal last summer. The owner of the site has sold or removed
much of the zinc material to foreign and domestic recyclers since last
summer. Both the FFS and the PRPs plan include selling off any tanks
which are still sound and that can be properly cleaned. Some of the
sludges at the bottoms of the tanks may not be easily removable.
However, there are some major limitations on recycling the materials from
this site. Based on the testing completed to date, it appears that most
wastes onsite are cross-contaminated with other wastes. The operational
practices of Western Processing apparently involved mixing different
wastes to obtain a resultant product. In addition, the storage practices
of Western Processing would also likely cause cross-contamination.
In the processing of performing the FFS, CH2M Hill contacted virtually
every possible reputable recycler or reuser of material from Western
Processing. In these contacts there were three consistant issues. The
local recyclers are not interested in taking any of the wastes from
Western Processing unless 1) the material is thoroughly characterized, 2)
the material is highly uniform, 3) EPA'will quarentee them freedom from
any liability and will assure payment of any losses, and 4) there is
absolutely no publicity. These are not conditions that can be met.
10. Detonation
Detonation is applicable only to those wastes that are explosive or
potentially reactive. The only wastes that might be explosive in nature
are selected laboratory chemicals. For these wastes, detontation is
likely to be the only acceptable disposal alternative.
11. Containment
In some instances hazardous materials on the Western Processing site could
perhaps be stabilized and left on the site. Under this alternative the
hazardous waste would either be treated to render it nonhazardous and then
incorporated into the site closure plan, or would be left untreated for
final closure if the contaminants were solids and less hazardous than the
underlyi ng soils.
EAO 017
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14.
A major problem with this alternative is that these materials would still
be a in the way for any stormwater control plan as well as for the next
phase of site clean-up. Significant regulatory hurdles exist because DOE
has a hazardous landfill moratorium until 1986. The non-uniformity and
cross-contamination of wastes also make this alternative unrealiable.
12. Return to Manufacturer
For materials onsite that are still in original, unopened, and undamaged
containers, it might be.possible to return the material or product to its
manufacturer. This option is not feasible for wastes that were generated
onsite by'combining the incoming materials. Specific wastes that might
meet thi s cri teri a i nclude:
F1 ectovarathane wood treatment products located on the pallets
near the entrance to the facility
Drums of foaming agent located near the southeast corner of the
facility
The manufacturers of these substances (also known as the generators) have
not made any serious steps to try and get these items off the site. They
have had over a year to do so. Also, the containers are not generally
damaged by the weather and thus can no longer be sold as new product.
13. Release to Responsible Party
For wastes whose responsible parties can be clearly identified,
consideration was given to encouraging the responsible party to remove and
treat the waste at their own expense. Only one PRP is actively pursueing
this option at this time for it's "oxazolidone". With this consent decree
now negotiated, it is up to the PRP to negotiate an acceptable arrangement
with the PRP committee.
Application of alternatives to particular wastes
In the FFS, the application of these alternatives to the specific waste
types was done in two steps. The first step used qualitative engineering,
economic, environmental, and institutional factors to eliminate less
feasible remedial actions. The engineering considerations included
technical feasibility, demonstrated application and reliability,
consistency with project needs, safety, schedule, and logistics. An
economic analysis was done on an approximate-cost basis and included
capital, operation and maintenance, and total costs. The environmental
considerations included short- and long-term environmental impacts and
public health effects. The institutional factors consisted of permit
requirements, contract negotiation, and risk potential.
The second level of screening considered costs in a more quantitative
manner through the use of order-of-tnagnitude costs. These costs compared
the potential value of recycling and reuse (as fuels) versus the cost of
sampling and classifying the wastes enough to determine their value.
Because the site is often unworkable once the rainy season starts,
E A 0 0 1 8
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15.
schedule was also a screening criterion. Disposal of the materials as
hazardous waste was the baseline against which all alternative actions
were measured.
Table 3 shows the results of this screening. Several of the initial
alternatives were combined to provide a particular feasible alternative
for a particular waste. For example, on-site treatment (cleaning) may be
necessary before drums, tanks and other metal items can be recycled.
Water treated on-site would be discharged to the Metro system or Hill
Creek.
All alternatives surviving this second level of screening are intended to
fully comply with all Federal and State environmental laws and
regulations, though compliance is easier to demonstrate with some
alternatives such as disposal of all materials at a hazardous waste
1andfi11.
Based on the limited testing completed to date, it appears that most
wastes onsite are cross-contaminated with other wastes. The operational
practices of Western Processing apparently involved mixing different
wastes to obtain a resultant product. In addition, the storage practices
of Western Processing would also likely cause cross-contamination. This
cross-contamination affects the selection of the feasible and appropriate
remedial actions. Local recyclers are not interested in taking any of the
wastes unless: the material is thoroughly characterized and is highly
uniform; EPA will quarantee freedom from liability and payment of losses,
and absolutely no publicity. These are not conditions EPA can meet. The
reputation of the site and the frequent cross-contamination also affects
the feasibility of disposal in non-hazardous waste landfills and
i ncinerators.
EAOO 1 9
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16.
Identification of stormwater control remdial action alternatives
In the September 1983 focused feasibility study for stormwater control,
the feasible alternatives were greatly limited by the presence of the
various wastes, their containers and the buildings. For example,
regrading the central and southern portions of the site were not
possible. Their removal from the Western Processing site will result in a
site where stormwater (surface water) will be easier to manage and control.
A continuing major concern will be the release of water which has become
contaminated through contact with and leaching through the heavily
contaminated soils on the site. The stormwater control actions are
intended to prevent the release of additional hazardous substances into
the environment until the subsurface remedial action is under construction.
The alternatives considered by EPA for stormwater control included:
* Grade the site to collect the water, transfer the water to an
offsite treatment facility, treatment, and discharge to Metro.
* Grade the site to collect the water, on-site treatment, and
discharge to Metro.
* Grade the site to collect the water, on-site treatment, and
discharge to Mill Creek.
* Grade the site, place an interim impervious cap on the site, and
discharge to Mill Creek without treatment.
* Grade the site to collect the water, no treatment, water discharge
by percolation and evaporation only.
* No action.
The alternative proposed by the PRPs is to grade the site to collect the
water, on-site treatment, and discharge to Metro or Mill Creek. The
initial removal of the ponded water already on-site would be by
collection, transfer to an off-site treatment facility, treatment and
di scharge.
All alternatives, except for possibly the no action and discharge by
percolation and evaporation alternatives, would comply with all other
Federal and State environmental laws. For these two alternatives in a
worst case situation, such as an extraordinarily long period of rain or
berm instability, the capacity of the current ponded area could be exceed
and water would be discharged to Mill Creek not in compliance with a NPDES
permit. An immediate removal measure would then be necesssary to transfer
the water to an off-site treatment facility for treatment and discharge.
EA0020
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17.
EPA's screening process included technical feasibility and reliability,
public health and environmental concerns, institutional concerns, public
acceptable, and cost effectiveness.
Prior analysis had shown that the treatment options were very expensive
and they had been screened out at the early stages of the September 1983
FFS. However, a number of new facts and situations have made it
worthwhile to consider again. The results of recent sampling has shown
the stormwater to potentially require less treatment than previously
anticipated. The need for, and level of, treatment and the selection of
the discharge point (Metro or Mill Creek) will depend on the quality of
the water before and after treatment, and the regulatory requirements.
Another different situation is that the waste removal activities described
above may well involve some type of onsite treatment with discharge to
Metro for the water based wastes. Therefore there may now be an economy
of seal e.
Discharge to the Metro sanitary sewer would have be an interim solution.
Discharge of stromwater to the sanitary sewer system is not desirable
since it adds to the "wet weather" flow depends on an already overloaded
system. However, for Western Processing, the on-site ponding could buffer
the flow peaks. Discharges could be scheduled for times when the flow in
the Metro system is not at a peak.
Discharge to Mill Creek could be a less costly alternative than
discharging to Metro if the NPDES permit requirements can be established
in a timely manner. Processing of similar permits is taking up to 180
days currently. The on-site treatment process would be similar for
discharge to either Metro or Mill Creek.
In the past, the state has used their discretion in whether to issue an
NPDES permit when only clean stormwater is being discharged to Mill
Creek. An impervious cap with discharge of the untreated but
non-contaminated stormwater to Mill Creek is the current condition in the
two acre project the Washington DOE constructed on the site last fall.
While the capital costs are higher than the on-site and off-site treatment
alternatives, the 0&M costs are significant lower. Since subsurface
cleanup is planned for next year, these higher capitol costs are not
justified.
From a public health and environmental protection consideration, the three
alternatives described above would have similar impacts. None of the
three would have significant adverse impacts. All three would reduce the
environmental and public health and welfare impacts of the Western
Processing storm water. All three would take advantage of a site now
cleared of surface obstructions while minimizing the discharge of
hazardous substances to both surface and subsurface water.
EA0021
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18,
The no action and the discharge only through percolation and evaporation
alternatives are very similar. The central and southern portions of the
site currently discharge only through percolation and evaporation. The
primary difference between these two alternative is how water will be
dealt with in the north end of the site, the amount of on-site storage
which could be available, and the permeability under any new potential
pond areas.
The no action and the discharge only through percolation and evaporation
would also have similar public health, welfare and environmental impacts.
The continued ponded of water on the site will continue to restrict
investigations and future subsurface clean-up of the site. Stormwater
would continue to become contaminated and would continue to recharge the
groundwater in the local area, and would perhaps continue to exaggerate
the "mounding effect." Contaminated stormwater would continue to reach
Mill Creek through seeps and springs. Kbwever both these alternatives
have potentially much lower capital and O&M costs than the first three
alternative s.
EAO 0 2 2
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COMMUNITY RELATIONS
19
A community relations program has been in place for almost a year. Both
DOE and EPA take an active role in this plan. The major elements have
included: monthly interagency meetings with the Kent City Mayor and her
staff; public presentations/toeetings whenever the city or city council has
requested it; press releases at all major events, such as the release of
data or reports, or the start of particular on-site activities; wide
distribution of press releases and fact sheets; and the availability of
government staff by phone to respond to questions from the public. "Though
public interest was very high last summer during the emergency removal,
for the last eight months only a few individuals and the City of Kent have
evidenced'their continued interest.
In early June 1984, a press release, a fact sheet, and the Focused
Feasibility Study was made available to the public. Over 300 press
releases and fact sheets were sent out. Over 50 copies of the Focused
Feasibility Study were sent out to individuals and agencies known to be
interested in the site, and six copies were made available through the
local public and EPA Regional libraries. In addition, copies were
available free from EPA for the asking. The three week comment period
closed on June 22, 1984.
A well-attended public meeting was held using the City of Kent's Workshop
forum on June 11, 1984. Besides the city council and staff, only four
other persons spoke. Host comments addressed the speed (too slow over
all, too fast on this first operable unit) and scope (why can't the entire
off-site and subsurface clean-up be done now too) of the proposed action,
as well as the reputation of the PRPs rumored contractor (Chemical Waste
Management, Inc.). As of June 22, only one additional written comment had
been received, in which Metro clarified it's proposed discharge
requirements. No comments were received which addressed the details of
the proposed action or the proposed disposal locations or methods, except
for one person who wanted EPA to try his new glass-making idea.
Because active negotiations were underway, EPA did not release any details
of the PRP's plan, except to say that the PRP plan was similar in it's
final result. Because the DOJ public comment period will begin after the
PRPs initiate the clean-up, the PRPs are taking the initiative to set up
small meetings with interested individuals and organizations. Most of
these meetings are scheduled for the week of June 25. .
E A 0 0 2 3
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20
CONSISTENCY WITH OTHER ENVIRONfOTAL LAWS
The alternatives described above will comply with all Federal, State and
local laws and regulations. Environmental laws which could apply to this
action include:
RCRA. This program has been delegated to the State of Washington.
On-site activities will comply with state regulations. DOE expects
to have a representative on-site at all times to ensure compliance.
Off-site disposal of hazardous and dangerous waste will have to occur
out-of-state. The nearest facility which can take a majority of the
materials from the site is the CSS I site in Arlington, Oregon. The
Oregon Department of Environmental Quality has been delegated interim
authorization under RCRA. DEQ's last inspection of the Arlington
facility was on May 30, 1984. No violations of state licence
conditions were noted by the State. EPA is currently reviewing the
facility's Part B application.
The cost of proving that a particular waste is not hazardous under
federal or state regulations (or of cleaning the waste and then
proving it is not hazardous) is often higher than disposal at a
hazardous waste dispoal facility. Lower levels of proof, while then
allowing additional recycling or potentially disposal at municpal
landfills, would probably not be publicly acceptable.
TSCA. TSCA would apply to the handling and disposal of all PCB
contaminated material s. All TSCA procedures will be followed.
CWA. The Clean Water Act will apply to the disposal of certain
liquids on the site, the disposal of the ponded stormwater on the
site, and the disposal of stormwater after the site is cleared. The
alternatives for the disposal of the liquids on the site and the
already ponded water are either to treat the water on site or to take
the liquids off-site for treatment. Both alternatives will probably
then include the discharge of the the treated water to the Metro
sewers and sewage treatment plants or other state waters. All
requirements of the Metro pre-treatment permit or State NPDES permit
wil1 be met.
The Clean Water Act will also come into play with the disposal of
stormwater after the site is cleared. If the site is graded and then
covered with a clean and impermeable layer, the water may be
discharged to Mill Creek as clean storm water, much as the water from
the DOE paved portion is currently being discharged. The NPDES
permit program is delegated to DOE. If the site is not covered (or
if a particular drainage basin of the site is not covered) this water
will either be ponded on the site or collected for treatment prior to
discharge to Metro or surface water in compliance with the any Metro
pre-treatment requirements or State NPDES permit.
E A 0 0 2 4
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21.
RECOMMENDED ALTERNATIVE
The recommended alternative is cost-effective, i.e. the lowest cost
alternative that is technologically feasible and reliable and which
effectively mitigates and minimizes the damage to, and provides adequate
protection of, public health, welfare or the environment. In this case,
cost effectiveness includes the concept of being cost-effective for the
overall site clean-up, not just the costs of this stage.
The recommended alternative is to follow the PRPs proposed plan. The main
elements of this plan include:
1. Site preparation to provide for support and decontamination
facilities.
2. Characterize all materials identified for removal.
3. Removal of al 1 bulk liquids, drummed liquids, and waste piles to
a permitted off-site facility. Negotiations among the PRPs may
result in a large portion of the "synfuels" being incinerated in a
cement kilm.
4. Removal and proper disposal of all transformers and substation
equipment. Proper disposal will depend on the PCB levels in the
transf ormers.
5. Demolition and removal of all on-site buildings.
6. Dismantling of all on-site bulk storage tanks. If tanks are
determined to be structurally sound, such tanks will be thoroughly
cleaned and sold for scrap metal.
7. All other surface debris will be removed and disposed.
8. Stormwater will be controlled and treated prior to discharge
before, during, and after the surface clean-up. After initial pond
removal, an on-site treatment plant will be set up and operated. The
PRPs will continue to handle stormwater control until April 1, 1985.
The no action alternative is not acceptable, primarily because it will not
mitigate and minimize the damage to, nor provide adequate protection of,
public health, welfare, or the environment. It is also not acceptable
because it would delay final site clean-up by at least a year because this
material would have be removed before the next stage of clean-up could
begin. Since surface clean-up requires an entire contruction season,
there would have to be an additional year before sub-surface clean-up
could begin..
E A 0 0 2 5
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The major problems with most other alternatives for the wastes are both
regulatory compliance (in fonm or substance) and institutional
feasibility. For example, recycling is not feasible if no recyclers will
take the material because of their fear of future liability. Because of
the local notoriety of the-site, proving a substance from Western
Processing is not hazardous and thus legally suitable to be disposed of in
a municipal landfill is often more expensive and less reliable than simply
disposing of the material in a hazardous waste landfill.
EAO 0 2 6
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23.
OPERATIONS AND MAINTENANCE
O&M will be necessary only for the stormwater control portion of the
project. O&M activities will includes operation of the treatment plant,
and monitoring the site's berms to ensure that there is no surface
discharge. The PRPs will be responsible for all such O&M until April 1,
1984 or three months after they finish the site clean-up, whichever comes
later. The PRPs are also responsible for leaving the ponds drained.
Subsurface and off-site remidial actions are planned to begin next summer,
and stormwater will have to managed as part of that activity.
E A 0 0 2 7
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24.
FUTURE ACTIONS
This surface clean-up and stormwater control project is the first operable
unit of the overall remedial action at this site. The draft RI/FS for the
rest of the remedial actions (subsurface and groundwater alternatives, and
off-site contamination and needs) will be available in September 1984. No
information is currently available on what the possible feasibile
alternatives will be, but a common element in all scenarios previous
looked at (except for the no action alternative) included a complete
surface clearance as a necessary first step. Tne data on the extent of
off-site contamination is now just coming in. An extensive public comment
period on this larger, and more controversial stage, is expected.
Negotiations will be continuing with the PRPs throughout the surface
clear-up project, and if necessary, into the fall.
E A 0 0 2 8
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Figure 1
VICINITY MAP
E A 0 0 2 9
-------
Figure 2
o
m
o
o
<
w
•OU«C«! CMWMll OICDMMnMHCf .IU>, IM4
LOCATIONS OF
WASTE MATERIALS,
MAY 1984
-------
. * i.
\ >
> I
Figure 3
WESTERN PROCESSING
IN OPERATION
OCTOBER 1982
EAOO 31
-------
Table 2
FOCUSED FEASABILITY STUDY
POTENTIAL REMEDIAL ALTERNATIVES AND TECHNOLOGIES
Disposal Alternative
Onsite Treatment
Technologies Considered '
Carbon adsorption
Air stripping
Precipitation/filtration/
clarification
Drying/dewatering
Sedimentation
Distillation
Solidification
Neutralization
Evaporation
Biological oxidation
Chemical oxidation/reduction
Rinsing/steam cleaning
Chipping/crushing
Liquid/liquid extraction
Encapsulation
Sludge conditioning (e.g.,
with fly ash)
2. Offsite Treatment
3. Nonhazardous Waste
Landfill
4. Hazardous Waste Landfill
Same potential technologies
as for onsite treatment
Repackaging and/or onsite
or offsite treatment may
be required.
Partial solidification of
liquids and/or repackaging
may be required.
EA0032
-------
1 . 'V. I
Disposal Alternative
5. Discharge to Metro
6. Discharge to Mill Creek
7. Incineration/Fuel
Source
8. Recycle or reuse
9. Detonation
10. Containment
11. Return to Manufacturer
12. Release to Responsible
Party
13. No action
Technologies Considered
Onsite or offsite pre-
treatment may be required.
See the technologies for
onsite treatment above.
Onsite pretreatment will
likely be required to meet
discharge limitations. See
the technologies for onsite
treatment above.
Hog fuel boiler (wood)
Cement kiln
Hazardous waste incinerator
(e.g., at-sea incinerator)
Industrial boilers (oil
fired)
Onsite portable boiler
Steam clean onsite; cut,
crush, chip, onsite; repack-
age onsite; salvage, sell,
give away.
Solidification, burial,
crushing, chipping
2
EAO 0 3 3
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WESTERN PROCESSING SURFACE CLEARANCE PROJECT
Waste Type*
Current Estimated
Quantity
Disposal Alternates
Hast likely Alternatives lass Llkaly, but still Passible
Alternatl was
A. Corrosive liquids
202,966 gallons
B, Sludge fnom corrosive tanks 20,190 gallons
C. Isopropyl alcohol mixture Unknown
D, Flue dust
E. Battery chips
F. Zinc oxlcfe
6. Foaming agent
H. Vbod pallets
I, Printing Inks, tars, oils,
and greases
J, Tires
K. Nail coatings-
L, Unki.iwns
Onslte traatrant and discharge
to ftetro
Haul to offslte treatnant facH Ity
Haul to hazarcbus waste landfill
Onslte treatment and discharge
to Mjtro
2,900 cubic yards Haul to hazardous waste landfill
Onslte use In final site closure
2,100 cubic yards Offslte recycle/reclaim
129 tons
2,690 gal Ions
80 tons
20,300 gal Ions
I ton
3,000 gal Ions
Unkmwn
Haul to hazarcbus waste landfill
Haul to hazarcbus waste landfill
Haul to hazarcbus waste landfill
Haul to hazardous waste landfill
Haul to hazarcbus waste landfill
Solidify and haul to hazar
-------
Current Estimated
Waste Type Quant Ity
M. Transformers 5 to 10 tons
N. "Synfuels"
I. 60-welght bunkar oil
87,131 gallons
2. High arsenic content 235,104 gallons
3. Mixed llcjjlds
53,476 gal Ions
4. Liquids with msthylene
chloride
128,065 gallons
5. Caustic liquids
7,899 gal Ions
6. Unknowns
0. Gypsum pi le
P. Fluids In gypsum pile
148,219 gal Ions
10,128 cubic yards
Unknown
0. Sludge from bottom of tanks 101,900 gallons
Disposal Alternatives
tost Likely Alternatives Less Likely, but still Feasible
Alternatives
Haul to hazardous waste landfill
Off site Incineration
Onslte or offslte treatment of liquids and recycles casings
Onslte drain and flush. Incinerate liquids, haul casings to nunlcpal landfill
Haul to hazarcbus waste landfill
fteuse as fuel
Haul to hazardous waste landfill
Dilute and recycle for pressure creosotlng
Haul to hazardous waste landfill
ffeuse as fuel
Haul to hazardous waste landfill
Offslte treatmant and recycle
Haul to hazarcbus waste landfill
feu se
Same as abova
/
Haul to hazarcbus waste landfill Haul to municipal landfill
Onslte treatment and discharge Haul to hazarcbus waste landfill
to Ntatro
Offslte tneatmant
Haul to hazarcbus waste landfill
-------
Currant Estimated
Watte Typo
R. Tanks and scrap ratal
S. Rondjd water and (faran
water from operations
T. Nonnacyclable solvents
U. Crystallized solids
V. Laboratory chemicals
W. Ffestlcl&s
X. Paint waste, varnishes,
and stains
Y. Flammable lltyjlds
Z. Concrete blocks
M. Do mo I It Ion dsbrls
BB. Empty drums
V-
*
J I
Quant I ty
Unknown
.9 Mill Ion gal Ions
(plus an estimated
.9 mill Ion gal Ions
Iron clooronoo
activities)
3,690 gal Ions
96,720 cubic (oat
Unknown
5 to 7 tons
30,000 to
90,000 gal Ions
10,000 gallons
B,937 cubic fast
Unknown
6,000 drums
3.
Disposal Alternatives
tost Likely Alternatives Lass Likely, but still Feasible
Altarnat Ives
Stean claan, sail whole and/or ait
and sell as scrap
Ons Ita treat rant and discharge
to Kit no
Offiltu troatounl
llaul to hazardous waste landfill Solidity and haul to hazardous waste
landfill
llaul to hazardous waste landfill
Others, depending on nature of material
I
Haul to hazardous waste landfill
Explosives must be detonated
Haul to hazardous waste landfill
Haul to hazardous waste landfill
Haul to hazardous waste landfill Solldlgy and haul to hazardous waste
landfill
Steam clean and use onslta In final closure
Haul to hazardous waste landfill
Haul to hazardous waste landfill i
Steam claan and recycle (metal tools and equipment only.)
Steam claan and haul to municipal landfill (natal tools and equIpmant only.)
Haul to hazardous waste landfill. Haul to hazardous waste landfill as Is
crushad onslta
(to cycle
Haul to hazardous waste landfill m
o
o
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pa
Haul to hazardous waste landfill
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