Record of Decision
Remedial Alternative Selection
SITE
Western Processing Company, Inc.
Kent, Washington
DOCUMENTS REVIEWED
I am basing niy decision primarily on the following documents describing
the analysis of the cost and effectiveness of the.remedial alternatives for
the Western Processing site.
- Western Processing Remedial Investigation
- Western Processing Feasibility Study and Executive Summary
- Sunmary of Remedial Alternative Selection
- Responsiveness Sunmary
DESCRIPTION OF SELECTED REMEDY
- Intensive soil sampling and analysis on and off the site during
detailed design.
- Selective excavation of highly contaminated soils and non-soil
materials (drums and buried wastes) in Area I. Off-site disposal of
excavated soils and materials. Excavate, or clean and plug all utility
and process lines in Area I.
- Using the results of the soil sampling and analysis program,
eliminate direct contact threats in the non-Western Processing property
through excavation of all soils which exceed the ADI level or the 1 x
10~5 excess cancer risk level, and through covering/capping all
remaining surface soils with above background concentrations of
priority pollutants. Maintain cover/caps. Excavate utility lines
leaving the Western Processing site. Clean utility manholes/vaults
near the site. Disposal will in Area I or off-site. Actions will be
limited to those off-site soils which may have been contaminanted by
Western Processing. The lead-contaminated house in Area 8 will be
removed or decontaminated.
- Construct a groundwater extraction and pre-treatment plant
- Operate the groundwater extraction and treatment system for a period
of up to five years (Initial phase of system operation.) The purpose
of the groundwater extraction and treatment system shall be to prevent
furthur contaminant discharges via the groundwater to Mill Creek and
the east drain at levels which are harmful to aquatic organisms and to
. prevent the further spread of, and-ff possible, remove the
contamination from the shallow aquifer.
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- Construct, operate, and maintain a stormwater control system
- Intensive monitoring of Mill Creek, the east drain, the groundwater
and the groundwater extraction system performance, combined with tests
and implementation of system modifications such as acid or
sol vent-enhanced leaching of metals from the soil,
- Excavate contaminated Mill Creek sediments
- Bench-scale tests of soil solidification techniques and, if system
performance should dictate, pilot scale tests of in situ solidification
technologies.
- Perform supplemental remedial planning studies if shallow groundwater
contamination beyond the currently contaminated zone or significant .
regional contamination is detected.
DECLARATIONS
Consistent with the Comprehensive Environmental Response Compensation, and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
Part 300), I have determined that the above Description of Selected Remedy
at the Western Processing site is a cost-effective remedy and provides
adequate protection of public health, welfare, and the environment. The
State of Washington has been consulted and agrees with the approved remedy.
In addition, this initial phase of system operation/construction will
require five years to ensure the continued effectiveness of the remedy.
These activities will be considered part of the approved action and eligible
for Trust Fund monies for a period of five years.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the off-site transport, treatment, and secure, disposal
is more cost-effective than other remedial actions, and is necessary to
protect public health, welfare or the environment. All offrsite disposal
shall be in compliance with the policies stated in Jack W. McGraw, Acting
Assistant Administrator, Office of Solid Waste and Emergency Response's Hay
6, 1985 memorandum entitled Procedures for Planning and Implementing
Off-site Response Actions.
If additional remedial actions are determined to be necessary, a Record of
Decision wf11 be prepared for approval of the future remedial action.
Date
Regfonal Administrator
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SUMMARY OF SECOND OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION AT
THE WESTERN PROCESSING COMPANY, INC. SITE,
KENT, WASHINGTON
SITE LOCATION 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 coranercial 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 Green River Valley. Mill Creek, which is
also known as King County Drainage Ditch No. 1, abuts a portion of the
western boundary of the site. Mill Creek eventually reaches the Green
River, which drains to Puget Sound. Surface runoff from the site, if not
controlled, would flow into Mill Creek and other adjacent drainage ditches.,
Small segments of the site adjacent to Mill Creek and other drainage ditches
lie within the 100 year flood zone.
The groundwater table under the site averages about six feet below the
surface. The native soils are generally of moderate to low permeability.
The surficial 40 feet consist of discontinuous lenses of silt, clay and
sand, with a hydraulic conductivity of 1 to 10 feet a day. From 40 to
approximately 200 feet below the surface, there is fine to medium sand with
discontinuous silt lenses and a hydraulic conductivity of 10 to 100
feet/day. A confining layer of at least 200 feet of dense clay and silt
exists below 200 feet. At the valley margins a deeper artesian aquifer
exists below this unit.
There are no wells in the shallow aquifer currently used for drinking water
within a one mile radius of the site. The City of Kent (population 27,000)
has drilled wells into the deeper hydraulically isolated artesian aquifer at
the valley margin less than a mile from the site to develop an additional
drinking water supply for the city. In the past, wells have withdrawn water
for domestic use from the shallow aquifer. However, the background water
quality from some portions of the shallow aquifer would not meet current
drinking water standards, primarily for iron and manganese.
The surface of the site has ,been cleared of most above surface wastes and
contaminated facilities. The site is now graded, and stormwater has been
collected and treated on-site by the potentially responsible parties's
(PRP's) contractor prior to discharge to the Metro sewer system. Subsurface
wastes and contaminanted soils are still in place and include drums of
"foundry sand" and other wastes buried by the owner over many years.
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SITE HISTORY
From 1953 to 1961, the site was leased from its then current owner and
developed and used as a U. S. Army Nike Ariti-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.
Originally Western Processing was a reprocessor of animal by-products and
brewer's yeast. In the 1960'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 had contracts with Western Processing to
handle their wastes. Reviews of historical aerial photos disclose great
changes in the site's uses and structures every few years as Western
Processing's operations changed.
The Kent Fire Department was one of the first agencies to have contact
with Western Processing when fires in the early 19701s 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 prohiciting 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. 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.
EPA inspected the site in March 1981 to determine compliance with the
newly-effective regulatory framework of RCRA. Many violations were
documented. Although the company notified EPA of its hazardous waste
activities pursuant 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.) EPA issued a second
compliance order in June 1982, after another inspection in May '.982
revealed additional significant violations and questionable site
management. 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 amended to include CERCLA
counts against the owner/operator of the site.
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As d follow-up to the earlier DOE 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 wdters around the
site, all of whicn 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 requiring 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 began in September 1982 and concluded in November. In
all, 130 soil samples were taken and 35 groundwater samples were
obtained. The analyses of these samples confirmed that hazardous
substances had been released into the environment, had been leached into
and contaminated the shallow aquifer, and had caused widespread
contamination of the soils at the site.
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
V, 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. 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 immediate 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 requires 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
endangenuent to the environment.
Stormwater management has been, and will continue to be a major problem
until remedial actions are completed. Using State funds, 00E implemented
a stormwater initial remedial measure involving excavation of the gypsum
sludge pond, restacklng 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 orrhold when the bids came in much
higher than the available budget;
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A Focused Feasibility Study for Surface Cleanup was published in May
1984. Through a Phase I Partial Consent Decree, a group of over 190 PRPs
eventually agreed to undertake a surface cleanup and stormwater control
actions. The surface cleanup was completed by November 30, 1984, except
for two trailers of dioxin contaminated material which are still waiting
the PRPs provision of permanent disposal. The PRPs have voluntarily
continued the stormwater collection and treatment system beyond the April
1, 1985 termination date in the Partial Consent Decree. The PRPs have
spent approximately $9 million dollars on the surface cleanup.
Remedial Investigation and Feasibility Study work proceeded simultaneously
with these other actions. Phased Remedial Investigation work began during
the sunmer of 1983. Periodic data releases culminated with the release of
the Remedial Investigation in December 1984. The Feasibility Study was
released in March 1985.
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CURRENT SITE STATUS
Approximately 90 of the 126 priority pollutants have been found in the
soil or groundwater on and off the Western Processing site, or in Mill
Creek. In addition, many tentatively identified compounds have been
listed by the? laboratories. In the Feasibility Study, sixteen of the
priority pollutant compounds were selected as indicators to characterize
the contamination on and off the Western Processing property. These
indicator compounds include metals and representatives of all classes of
organic priority pollutant compounds. Table 1 lists the indicator
contaminants.
Table 2 lists the location of the classes of indicator compounds by their
location within the soil profile. Analysis by CH2M Hill has shown that
over 95% of the contamination at Western Processing is located in the
uppermost 15 feet of soil. In the top 6 feet (above the water table), all
the contamination is located in the soils. In the saturated zone, the
contamination is located in both the groundwater and the soils. Table 3
shows the results of the contaminant distribution analysis for the Western
Processing site and two adjacent properties which have been contaminated.
The Feasibility Study remedial analysis areas are shown in Figure 2.
Areas I and YII are owned by Western Processing Company, Inc..
The groundwater contamination has not migrated significantly from Western
Processing. The highest concentrations of contaminated groundwater are
directly under the property, as shown in Figures 3 and 4. The groundwater
to about 50 or 60 feet below the surface probably discharges into Mill
Creek adjacent to the site, or into the East Drain, which is tributary to
Mill Creek. For the purposes of the Feasibility Study and NDD, this has
been termed the "shallow" groundwater system. EPA's consultants believe
that the lateral extent of the groundwater contamination is bounded by
these waterways, though during the public comment period, a neighboring
property owner's consultants thought that tne existing evidence was not
conclusive.
The groundwater system is complex. While the regional groundwater flow
direction is generally northwest, a groundwater "mound" beneath the site
creates radial, and to some extent, downward, flow from the site. A major
early concern was that this hydraulic head was driving contaminated
groundwater down Into the artesian aquifer currently used as a water
supply. However, after a major effort during the Remedial Investigation
and other studies refined the understanding of this groundwater system,
EPA and EPA's consultants now believe the artesian aquifer does not exist
.below the site and there is no reasonable pathway by which any of this
contamination could reach the deep artlsian drinking water aquifer at the
valley margins. In addition, the current conceptual model of the
effective capture depth of Mill Creek is about 50 to 60 feet below the
surface.
The ^adjacent property owner's consultants believes that the 260 ppb of 1,2
trans-dicloroethene detected in Well 35 has migrated down into the
regional groundwater system from Western Processing and has crossed under
the creek (below the effective capture depth) to his client's property.
This may be considered a worst case analysis. Hart Crowser & Associates,
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an independent EPA contractor, has stated that "The source of this
contamination is unknown in that the hydrogeology of the site would tend
to make it difficult for this contaminant to migrate to these wells from
the Western Processing site." However, to ensure protection of public
health and the environment, this worst case possibility is addressed in
the Recommended Alternative. In addition, 13 additional wells were
drilled in July and August 1985 to the west of the Western Processing
site. Information from these wells will also help resolve this question.
No known present or currently proposed public or industrial water supply
wells could be threatened by this contamination.
Most of the soil contamination is immediately below the site or adjacent
to the site. The maximum concentrations of contamination are generally on
the Western Processing property (Area I), and within the top 6 to 9 feet.
(Table 2). Off-property areas with contamination because of Western
Processing activities include Area IX to the north of the site (former
surface water drainage across S. 196th Street), Area V to the west between
the Western Processing property line and Mill Creek and Areas II and X to
the east of the site between Western Processing and the east drains and
ditches (former surface and subsurface water drainages.) Area VIII has
high surface levels of lead, which may have come from truck traffic making
deliveries of battery chips and other metal containing wastes to Western
Processing. Figures 5 through 9 illustrate the extent of soil
contamination.
The conditions in Mill Creek support the idea that it has received most of
the contamination that has left the Western Processing site over the
years. The concentrations of metals in the stream water and sediments
increase many times as Mill Creek flows by Western Processing. While the
surface water discharges from the Western Processing property has ceased,
contaminated groundwater is still adding pounds of zinc and other priority
pollutants, particularly metals to the creek every day.
Western Processing is not the only source of hazardous substances and
degraded environmental conditions in the area. Area VI is the former site
of another hazardous waste handling firm, Liquid Waste Disposal. This
firm transported hazardous waste liquids. Closure of this site is being
handled by the Washington State Department of Ecology under the delegated
RCRA program. Also, water quality conditions upstream from Western
Processing limit the resource value of Mill Creek with low dissolved
oxygen levels. The concentration of phthalates, some PAH's, and some DOT
derivatives tends to be higher upstream of Western Processing than through
Western Processing, Metal upstream concentrations are also often above
ambient water quality criteria for aquatic organisms.
Endangerment Assessment
Two methods were used in the endangerment assessment to determine the
public health risk presented by the contaminants at Western Processing.
One method was used to address the risks associated with contaminants
known or suspected to be carcinogens; the other method was used to address
risks associated with non-carcinogens. The endangerment assessment
considered all priority pollutants for which there were either cancer
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potencies or Acceptable Daily Intakes (ADIs). For carcinogens, excess
1ifetime cancer risks were calculated by using a procedure that estimates
the increased probability of developing cancer for someone who ingests the
soils or water from Western Processing site over a long period. For
non-carcinogens, there are a few legally enforceable standards (such as
federal or state drinking water standards), as well as other criteria such
as published guidelines that calculate the amount of a particular chemical
that can be ingested without harm.
Assuming that a person works on the site for 40 years, ingestion of the
on-site soils up to 12 feet deep (assuming the maximum concentrations
found on site) would lead to a maximum excess lifetime cancer risk of 2 x
10 , principally from PCB contamination. There is a potential excess
lifetime cancer risk of 5 x 10"' associated with the ingestion of onsite
surface soils with site mean concentrations in a future worker scenario.
An estimated potential cancer risk of 5 x 10"^ is aissociated with the
ingestion of soils if the maximum surface concentrations are used. Excess
lifetime cancer risks in three potential future residential scenarios
ranged from about 0.8 times to 50 times greater than the worker scenarios.
Soils in six off^property areas (II, III, V, VI, and IX and Mill Creek
sediments) also had detected PCB's, though only in surface soils. Areas
VI and IX had at least three reported detections in the surface soils, and
thus an excess cancer risk could be calculated. With the mean and maximum
concentrations and the worker scenario, the potential excess lifetime
cancer risks associated with ingestion of soils are 9 x 10"b and 4 x
10% respectively, in Areas VI and 3 x 10"^ and 5 x 10"^,
respectively, in Area IX. Again, excess lifetime cancer risks in three
residential scenarios would be 0.8 to 50 times greater. However,
residential development in this area is very unlikely.
No known domestic or industrial water supplies are currently affected by
the site. Use of onsite groundwater as a potable water source for a work
place, however, would present an estimated excess lifetime cancer risk of
0.2 using maximum onsite concentrations and 0.008 using mean onsite
concentrations. Cancer risk would increase to an estimated 0.5 if a
residential scenario is used with maximum concentrations and 0.02 if mean
onsite concentrations are used. Organic compounds contribute rpost of this
excess lifetime cancer risk.
A number of ADIs are also exceeded with an assumed consumption of 0.1 gram
of soil per day or 2 liters of groundwater per day. These include lead,
chromium, cadmium, toluene, 1,1,1-Tricholoethane, phenol, mercury, and Bis
(2-ethylhexylJphthalate.
While organic priority pollutant contamination in Mill Creek does not
appear to pose a threat to human health based on recreational use, the
water in Mill Creek near and downstream of Western Processing is likely to
be toxic to a wide variety of aquatic organisms. While Mill Creek may
have once supported salmon runs and trout, only three-spine sticklebacks
have been found in Mill Creek between downtown and Springbrook Creek in
recent years. (Coho salmon and cutthroat trout have been found upstream
of downtown.) Concentrations of several dissolved metals, such as zinc,
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cadmium, copper, and possibly chromium, exceed the ambient water quality
criteria concentrations for the protection of freshwater aquatic organisms
by several orders of magnitude at the Western Processing site, probably as
a result of groundwater flow into Mill Creek from Western Processing.
Sediments in Mill Creek are also contaminated with priority pollutant
metals. The concentrations of organic contaminants in Mill Creek do not
exceed the ambient water quality criteria for the protection of freshwater
aquatic organisms.
These releases will continue unless remedial action is taken.
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ENFORCEMENT
Of the approximately 300 generator and transporter PRPs at the Western
Processing site, over 190 PRPs signed the Phase I Partial Consent Decree
and contributed money towards the surface clean-up work. The Western
Processing Coordinating Committee, representing a large but unknown number
of PRP's, submitted a subsurface clean-up proposal to the government in
October 1984. This proposal was presented to the public (and identified
as the PRPs proposal) as Example Alternative 4 in the Feasibility Study.
Also, the PRPs had their contractor continue to gather data for detailed
design and bid specs for the subsurface clean-up. The Coordinating
Committee has also voluntarily continued the stormwater control actions
beyond the period agreed to in the Partial Consent Decree.
Negotiations for the Phase II remedial action began in late May 1985 and
concluded unsuccessfully in August-September 1985 when the PRPs and the
goverments (EPA and WDOE) failed to agree on a remedy.
The use of the Fund is recommended to ensure a proper remedial action
which will protect the public health and welfare and the environment.
Also, it is recommended that the filed Western Processing case in federal
court be amended to include recoverv of the Goverments' costs.
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ALTERNATIVES EVALUATION
After completion of the remedial investigation, the types of problems
existing at Western Processing were categorized as follows:
- Potential direct human and animal contact with contaminants from
Western Processing.
- Past and potential future contaminated surface water runoff
- Infiltration and subsequent leaching of contaminants from the
unsaturated zone into the groundwater.
- Contaminated groundwater beneath the site
- Contamination of Mill Creek via groundwater migrating from the site
to levels that exceed background or ambient water quality criteria for
aquatic organisms.
Given the nature and extent of contamination on and off the Western
Processing property and the environmental and human health risks that the
contamination poses, a comprehensive list of possible remedial action
technologies that could be used to remedy the contamination was developed.
An initial screening was conducted to identify the technologies that are
proven and most applicable to and feasible for the problems at Western
Processing. The list of suitable technologies was then used to develop a
set of remedial action components that were determined to be particularly
suitable for these problems. None of the remedial action components is
capable by itself of addressing all the problems at Western Processing.
Therefore the components were combined into comprehensive remedial actions
for the detailed analysis of alternatives.
The Feasibility Study contains seven example alternatives which were
developed to mitigate the problems identified in the nature and extent of
contamination and the endangerment assessments. The example alternatives
include a No Action alternative, totally on-site disposal, .totally off-site
disposal, and an alternative which has been developed and proposed by the
PRPs. The PRP's alternative was developed separately from the government
and they used different goals in developing their alternative. While all
seven are feasible alternatives, they are called example alternatives
because there are an infinitely large number of alternatives, particularly
when the possible areal extent of a particular component is considered.
Alternative 4 has only source control measures, Alternative 7 has only
offsite measures, and Alternatives 2, 3, and 5, while generally source
control measures, do include some offsite measures as well.
The example remedial action alternatives were evaluated and compared to
determine their relative cost, and their technical feasibility, public
health, and environmental aspects. Table 4 summarizes the seven
alternatives and the ^valuations. The numbered areas refer to the numbered
parcels in Figure 2.
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the nature and extent of contamination on and off Western Processing is a
function of the type of materials which were released on the site and the
pathways by which those materials were able to move. Each contaminant's
mobility or ability or lack of ability to dissolve into, and move with,
water, greatly affects the extent of contamination of that chemical.
Mobility also affects the relative success a particular example
alternative has in removing that contaminant. As the summary chart shows,
any of these alternatives will work if it is operated for long periods of
time. Such an extended period may not be technically or administratively
practical.
The two-volume Feasibility Study and Executive Summary contains more
information on the screening criteria and the steps used to develop the
alternatives.
One of the findings of the Feasibility Study was that complete excavation
and off-site disposal of contaminated soils would be prohibitively
costly. Also, removal of metals from these soils with the proposed
groundwater extraction and'treatment system is likely to be a very long
term operation. Therefore EPA has reconsidered the potential for in situ
soil treatment technologies.
In situ enhanced leaching would involve lowering the pH and/or adding
other chemicals to the leaching solutions applied either at the site
surface or in the very shallow unsaturated zone. (The acid leaching would
be followed by a neutralization step.) Enhanced leaching allows the
contaminants, particularly the normally very hard to remove metals, to be
removed mucn faster. The preliminary results of soil column tests done by
the PRPs on Western Processing soils have shown that the available zinc
can be reduced about 10 times faster when leached with pH 3.6 water.
Additional capitol costs to implement this technique once the groundwater
extraction system is operating are estimated to be $600,000, assuming that
adequate solution can be applied through an infiltration trench.
Through soil washing, chelating agents, such as EDTA, can also remove the
metal contaminants from the soil. Because of the high cost of the
chemical and potential environmental effects, these chelating agents would
not be used for in situ leaching. Rather, use of these agents would
require digging up the soil, washing the soil in a special on-site unit,
and then replacing the soil. Preliminary results of soil column tests
performed for EPA on Western Processing soils have shown heavy metal
removals of from 15% for nickel to essentially 100% for lead and cadmium.
In-situ stablization is another innovative technique. This uses
stabilization chemicals thoroughly mixed with the contaminated soils to
tie the contaminants in place, Immobilize soil particles, decrease the
permeability of the soil mass in relation to surrounding soils, and
occasionally, to transform certain chemicals Into less toxic forms.
Metals are particularly amenable to this technique. Among the advantages
of this technique are that an extremely hard and stable layer is fornjed
which can serve as a foundation for other structures, such as a cap or a
road. Laboratory scale tests are currently underway using Western
Processing soil. The estimated cost of this technique is $35 per cubic
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yard within 15 feet of the surface, or $9,000,000 for the 11 acre site, 15
feet deep. Long term operational and maintenance expenses are estimated
to De minimal at a properly stabilized site, involving only periodic
performance monitoring.
If either soil stabilization or soil washing technology is chosen in the
future, the ROD will be amended after an oportunity for public comment.
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COMMUNITY RELATIONS
A community relations program has been in place for two years. 00E and EPA
have taken an active role in this plan. The major elements have included:
monthly interagency meetings with tne Kent City Mayor and her staff; public
presentations/meetings 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. Public, interest is sporadically
high, though the City of Kent, certain neighboring property owners, and a
few individuals have had a high level of continued interest.
In mid-March 1985, a letter, a fact sheet, a separate Executive Summary, and
the two volume Feasibi1ity Study was made available to the public. Over 500
letters, fact sheets, and Executive Summaries were sent out. (This includes
the approximately 300 copies which were sent to the PRPs.) Over TOO copies
of the entire Feasibility Study were sent out to individuals, PRPs, and
agencies known to be interested in the site. A dozen copies were made
available through the local public and EPA regional libraries. In addition,
copies were available free from EPA for the asking. The 30 day conment
period closed April 10, 1985. As of April 26, 1985, 19 comment letters had
been received. No letters were identifiable as being from any PRP or the
PRP committee.
A series of four public meetings/workshops were held at the Kent City Hall.
By the second meeting, virtually all attendees were what could be called
"extremely or financially interested parties." Presentations were made by
the PRP's coordinating committee's consultants, a neighboring property
owner's consultants, the owner/operator of Western Processing, the most
active environmentalist, and the fisheries biologist of the local Indian
tribe, as well as by CH2M Hill. The on-going lawsuit between the
neighboring property owner and the PRPs limited, to some extent, the range
of potential exchanges between those two parties. Special small briefings
were held for the affected property owners,-natural resource agencies,
environmentalists, and the press.
The major issues that were raised were:
-Adequacy of the data. Statements were made that there isn't enough
data to answer all the questions or to decide on a remedial action.
The major areas which were affected by this concern are groundwater (Is
there deep groundwater contamination which has reached the regional
flow system?); Mill Creek (How far downstream and how deep are the
sediments contaminated?); and, to a much smaller extent, soil (There
isn't enough information to determine the exact extent (vertical and
horizontal) of contamination so that excavation or capping can be
defined.) During the comment period, most interested parties agreed-
that at least some components of a remedial action, especially
on-property excavation with off-site disposal, could and should begin
while anv missina data are collected. . .
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- Future public participation. Any further information which is
collected needs to be snared with the public and further public input
requested before major decisions are made.
- Property values. The neighboring property owners are greatly
concerned about being able to profitably develop and sell their land.
A major, though not always successful, goal of the public comment period
and meetings was to encourage participants to come up with and to give to
EPA constructive ideas as to how the site should be cleaned up, rather
than to focus on the problems they perceived in the Feasibility Study.
Alternatives which involved excavation and off-site disposal appeared to
be favored, while almost no one gave serious consideration to Alternative
3, the on-property landfill. Improvement of the groundwater was also
favored. However, only very general feedback was given to EPA on what
levels of "clean" were considered important. It appears that clean was
generally assumed to mean background (e.g. upstream) water quality in Mill
Creek, and adequately low soil contamination to allow City and the Health
Department approval of industrial developments. One individual suggested
that extremely stringent soil contamination levels were necessary along
the underground utility corridors where maintenance workers may need
access. Capping and then developing the entire area was suggested by some
others.
Mill Creek appears to be a potentially complex issue. A number of people
suggested that rerouting Mill Creek could be a good solution to the
Western Processing situation. A number of the property owners are
extremely interested in having Mill Creek rerouted so that the existing
creek bed could be filled and their property more easily and fully
developed. Some of the suggestions for moving Mill Creek could make the
extent of shallow groundwater contamination greater and thus would be
detrimental. These alternatives would be environmentally acceptable only
if the existing creek bed would be replaced by a French drain, and if the
French drain was properly maintained. The natural resource" agencies and
the Indian tribe are most concerned that Mill Creek water quality and fish
habitat are improved.
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15
RECOMMENDED ALTERNATIVE
The objectives of any remedial action at the Western Processing site are to:
(1) prevent direct human contact with or ingestion of contaminated soils
either on or off-site; (2) prevent the further spread of and, if possible,
remove the contamination from the shallow aquifer; (3) prevent further
contaminant discharges (via groundwater) to Mill Creek at levels which are
harmful to aquatic organisms; and (4) control contaminated storm water
runoff from the site- The example alternative presented in the Feasibility
Study which includes deep excavation with short-term pumping and treating of
groundwater appears to come closest to meeting all of the objectives, but
its cost is prohibitively high. On the other hand, the results of the
groundwater model used during the Feasibility Study indicate that the
shallow excavation option (with metals laden soils left in the satuated
zone) may permit metals to discharge from the groundwater to Mill Creek at
concentrations harmful to aquatic life for many years after the pump ana
treatment system is turned off and the present hydraulic gradients are
reestablished. Therefore, some intermediate alternative such 4s partial
excavation with some pumping/treatment of groundwater, followed by in situ
stablization of the metals in the soil might ultimately prove to be the most
cost-effective remedy. However, the cost and technical feasibility of in
situ soil stabilization (or other innovative technologies) has not yet been
evaluated and thus cannot be a part of this present remedial action.
Therefore, the proposed remedial action is an interim approach. The
following components are proposed for the present operable unit:
- Intensive soil sampling and analysis on and off the site during
detailed design.
- Selective excavation of highly contaminated soils and non-soil
materials (drums and buried wastes) in Area I toreduce the source
strengh. Off-site disposal of excavated soils and materials.
Excavate, or clean and plug all utility and process lines in Area I.
- Using the results of the soil sampling and analysis program,
eliminate direct contact threats in the non-Western Processing property
through excavation of all soils which exceed the AD I level or the 1 x
10"^ excess cancer risk level, and through covering/capping all
remaining surface soils with above background concentrations of
priority pollutants. Maintain cover/caps. Excavate utility lines
leaving the Western Processing site. Clean utility manholes/vaults
near the site. Disposal will in Area I or off-site. Actions will be
limited to those off-site soils which may have been contamiranted by
Western Processing. The lead-contaminated house in Area 8 will be
removed or decontaminated.
- Construct a groundwater extraction and pre-treatment plant
- Operate the groundwater extraction and treatment system for a period
of up to five years (Initial phase of system operation.) The purpose
of the groundwater extraction and treatment system shall be to prevent
further contaminant discharges via the groundwater to Mill Creek at
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16
levels which are harmful to aquatic organisms and to prevent the
further spread of, and if possible, remove the contamination from, the
shallow aquifer.
- Construct, operate, and maintain a stormwater control system
- Intensive monitoring of Mill Creek, the groundwater and the
groundwater extraction system performance, combined with tests and
implementation of relatively inexpensive system modifications such as
acid or solvent-enhanced leaching of metals from the soil.
- Excavate contaminated Mill Creek sediments.
- Bench-scale tests of soil solidification techniques and, if system
performance should dictate, pilot scale tests of in situ solidification
technologies.
- Perform supplemental remedial planning studies if shallow groundwater
contamination beyond the currently contaminated zone or significant
regional contamination is detected.
The final operable unit should occur after the initial phase of system
operation and might include:
- Continued groundwater extraction.
- In situ solidification of contaminated soils.
- Site close-out with a cap and provisions for long-term monitoring.
- Long-term institutional controls and deed restrictions.
- Alternative concentration limits for groundwater.
Determination of the final operable unit components will be made in another
ROD pending evaluation of the performance of the second operable unit.
Each component is discussed individually below. The discussions include the
recommended alternative and the costs. The cost-effective remedy is one
which effectively mitigates and minimizes threats to and provides adequate
protection o,f public health, welfare and the environment, considering cost,
technology, reliability, administrative and other concerns. Adequate
protection is considered to be> at a minimum, a remedy which attains or
exceeds applicable or relevant Federal public health or environmental
standards. Primary consideration has been given to these standards in the
selection of the recommended alternative. The recommended alternative
combines elements from the different example remedial alternatives examined
in the feasibility study, as well as other elements brought to EPA's
attention during and after the public comment period.
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On-site {Area I) Soils
17
The recommended alternative for Area I consists of: a non-destructive
geophysical subsurface survey of Area I to locate drums, tanks, and buried
utilities, to be followed by probing and sampling as necessary of discovered
items; excavation of abandoned utilities, concentrated non-soil or
containerized wastes, and areas of known PCB concentrations over 50 ppm;
excavation, or pumping out, cleaning, and plugging of buried tanks and
facilities if they cannot be excavated; and a deed or title restriction on
tne use of the site. Testing and sampling to define the excavation would be
done during the remedial design, while the type and design of the cap would
be determined during the next phase of remedial action. The estimated costs
for this alternative are: $625,000 for the sampling and analysis during
detailed design; $5,200,000 for the excavation and other on-site work during
this phase of the remedial action. This cost estimate is based on
excavating and disposing off-site 10,650 cubic yards, or 10% of the material
in tne top six feet. The cost for the excavation and disposal phase is only
an estimate and cannot be accurately determined until the sampling is
completed. These activities will reduce the source strength.
The alternatives considered in the Feasibility Study included leaving wastes
in-place and placing a multilayer RCRA cap over the site, placing all the
material in the unsaturated zone in the double-lined landfill on the site,
and excavating to background with transport and disposal off-site.
Significant contamination is found down to 15 feet. Cleaning to background
would cost more than $164,000,000 (Alternative 5 present worth, based on
disposal costs in Spring 1985). The selected alternative is similar to
Alternative 2, but is more protective. (Alternative 2 placed a RCRA cap
over the site, and excavated only buried containers and utilities.) In
addition to the protections provided by Alternative 2, the recommended
alternative would remove from the site the most hazardous materials and the
materials most likely to make it hard to achieve the groundwater
improvements or cap stability. It differs from Alternative 2 by excavating
some of the waste materials on the site, allowing some of the currently
off-site soil contaminated by Western to be brought back on to the site and
placed under the cap, and postponing placement of the cap until the
groundwater extraction program is completed. It is not known whether the
cap would be compatible with the extension of 72nd Avenue S. or other
development under consideration by the city of Kent.
Off-site soils
The recommended alternative for off-site soils consists of: extensive
additional soil sampling and analysis; excavation of abandoned utilities
leaving Area I; excavation of soils contaminated with PCBs over 2 ppm;
excavation of hot spots (defined below); covering/capping soils above
background; inspection and cleaning of "live" utility line vaults/manholes
which may have been affected by Western Processing; and the removal or
decontamiriation of a lead contaminated house* Additional excavation of
soils with zinc or cadmium or other heavy metal concentrations which may
affect achieving the Mill Creek and shallow-groundwater goals may also be
necessary..
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18
The estimated costs for the recommended alternative are: $1,000,000 for the'
sampling and analysis during detailed design; and $625,000 for tne
excavation, capping/covering and other off-site work. The cost for the
excavation and disposal phase is only an estimate and cannot be determined
until the sampling is completed and decisions are made on what material can
be consolidated on Area I, This estimate assumes that almost all of the
excavated off-site soils will be placed on Area I. (See Selection of
Disposal Facility section.)
The additional soil sampling and analysis would be done during remedial
design. All off-site remedial analysis areas would be sampled except for
Area VI. The sampling program would be phased, with the initial phase
consisting of over 300 sampling locations. The tightest grids and deepest
samples would be in the areas of former overland flow in Areas II, V, and
IX: Table 5 contains more details on the initial phase of the soil sampling
program.
Soils contaminanted from Western Processing activities with above background
priority pollutants will also be covered with materials of permeability less
than or equal to the natural subsoils, unless it is more cost-effective or
practicable to excavate these soils. Excavation of soils with below hot
spot concentrations will be likely in the S. 196th Street ditch and other
drainage ditches, as placing a cover/cap may not be practicable. Off-site
areas with small areas of above background concentrations may be
cost-effective to excavate. The decision on whether tne cover/cap should be
soil or other materials (such as asphalt or concrete) will be mostly
dependent on what alternative will have the lowest maintenance requirement
for a particular property. Discussions with the property owners will also
be a part of this decision. Detailed design work may disclose that, for
certain off-site areas (e.g. Area II), it is more cost-effective to cap the
area, even if certain utilities must be moved.
The exposure assessment/risk analysis approach has been used to set the
action levels for defining hot spots, or the residual contamination which
may be left in place as it will not pose a threat to health or the
environment through any route of exposure. The impacts of the off-site
soils on the groundwater are addressed through the shallow groundwater
component. For direct contact, a hot spot has been defined to be soil with
any one compound exceeding the ADI, or with a cumulative cancer risk in
excess of 1 x 10"®, or PCB concentration above 2 ppm. These cancer risks
are extremely conservative, as they are based on a 40 year exposure, while
the maximum likely exposure to the non-surface soils would be short-term
while placing utilities or foundations on these properties for light
industrial developments. The cover/cap will provide additional protection
against release to the groundwater, surface water, or to the public (through
inhalation.)
Alternatives considered 1n the Feasibility Study for off-property areas for
remedying direct contact were no action, multilayer RCRA capping, and one
foot or three feet of excavation and fill. Other alternatives raised during
or after the comment period include total excavation to the water table, hot
spot excavation in the top 4 feet, excavation to background, and deed or
title restrictions.
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19
The other alternatives for off-property areas are not as protective of
public health or are not cost-effective, or have institutional problems.
For those soils above background, no action and a uniform one foot
excavation are not as protective of public health. A uniform 3 foot
excavation would be more costly than the recommended alternative while
providing fewer public health benefits because there would be less depth of
hot spots removed. The property owners do not want a multilayer RCRA cap on
their properties which may disrupt their development plans for their
properties. As a reflection of community desires, the City of Kent also
strongly supports measures that will allow these properties to be developed.
Selection of Disposal Facility
The proposed alternative involves both on-site and off-site disposal. To
minimize unnecessary utilization of limited double-lined landfill capacity,
and to reduce costs associated with this remedial action, contaminated soils
which are currently off-site and which are not, WDOE extremely hazardous
wastes and which do not contain PCBs may be brought on to Area I for
placement under the eventual cap, and/or to be handled as part of any
in-situ treatment or stabilization. This consolidation of wastes from
releases from Western Processing is considered to be fully compliant with
the applicable and relevent provisions of RCRA. The soils which will be
brought onto Area I will generally be less contaminated than the current
Area I site average soil contamination, and will be a much smaller volume
than the total amount of on-site contaminated soils and wastes, but may be a
larger volume than the soils and wastes which will oe excavated and taken to
off-site disposal from Area I. The placement of off-site soils would be
scheduled to occur after completion of the on-site excavation. A clean
surface (e.g. gravel) would be placed on top of all soil to provide a clean
work surface for the groundwater extraction system. Careful design will be
needed to ensure that the contaminated soil will not add sufficient depth to
interfere with the operation of the well point system.
Off-site transport and disposal of some of the hazardous substances are is
necessary to protect public health, welfare and the environment from a
present or potential risk and to improve the reliability of the proposed .
remedial actions. Excavation and removal to an off-site disposal facility
would include transportation in accordance with DOT regulations, disposal in
a government approved facility, and replacement with clean fill 1f the
excavation 1s not in Area I. Selection of a disposal facility will be In
accordance with the guidelines in the Acting Assistant Administrator, Office
of Solid Waste and Emergency Response, Jack W. McGraw's May 6, 1985
memorandum Procedures for Planning and Implementing Off-site Response
Actions. This policy requires that, among other Items, all off-site
disposal, of hazardous waste must use disposal facilities and units which
have at least two liners and a leachate detection, collection and removal
system above and between the liners. In addition, the facility must have no
significant RCRA violations (as determined by EPA), unless the owner or
.operator of the facility has committed through an enforceable agreement with
the government to correct the problem. The sites must be-inspected within
six months of disposal of the CERCLA waste.
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Shallow Groundwater
20
The recommended alternative for the shallow groundwater component is a
groundwater extraction system in Areas I, II, V, and IX, unless design
studies demonstrate that a smaller array will be sufficient to establish an
inward hydraulic gradient throughout the currently contaminated shallow
groundwater zone. The recommended alternative includes low capital cost in
situ chemical leaching techniques after monitoring the site to ensure that
adequate gradient control has been established and after sufficient
laboratory scale testing. Institutional controls to permanently prevent the
extraction and beneficial use of the zone of contaminated groundwater will
also be necessary prior to site close-out.
The objectives for the shallow groundwater component are: (1) no degradation
of the shallow groundwater beyond the currently contaminated zone, and (2) a
reduction in groundwater contamination concentration to levels that will
protect the aquatic organisms in Mill Creek. (See the Mill Creek component
section.) These objectives will be achieved at least partly by a well-point
groundwater extraction system, with treatment and discharge of the extracted
water to Metro. The clean-up of Western Processing will not be considered
to be complete until these objectives are achieved and continue to be
achieved after termination of tne groundwater extraction system operations.
The alternatives considered in the Feasibility Study included no action,
pump for five years, pump for 30 years, pump for 120 years, and excavate
300,000 cubic yards of soil while pumping for four years. Because of the
unknowns in predicting groundwater and contaminant behavior in this system,
as demonstrated in the analysis in the Feasibility Study, only a phased
remedy for the shallow groundwater component can be addressed at this time.
As described in the Alternatives Considered section, a number of innovative
technologies were brought to EPA's attention after the Feasibility Study was
completed. The preliminary testing column testing for enhanced leaching of
Western Processing soils indicates that metals removal can be accelerated
several times. Leaching solutions applied to the site would be collected by
the well point system. However while these techniques may work in theory or
in lab scale tests, these leaching techniques may have real life practical
or cost-effective limits in the field. Pilot scale tests may be necessary.
Other techniques such as in-situ stabilization may become more feasible over
the next few years and may make it possible to achieve the shallow
groundwater objective by immobilizing the metals rather than removing them.
The initial capitol cost of the selected alternative is estimated to be
$6,800,000 if the treatment plant is designed to handle enhanced leaching.
The annual O&M expenses are estimated to be $1,500,000 to $2,500,000 (in
constant 1985 dollars) for the first 15 years. Fifteen years 1s the
estimated lifespan for the major equipment items. The 04M expenses are
dependent on whether the enhanced leaching system Is operating^ If detailed
design studies disclose that the costs associated with enhanced leaching are
significantly above these estimates, a decision on enhanced leaching will be
postponed to the next phase of remedial action.
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21
The first performance standard - no further degradation of the shallow
groundwater - will be achieved by placing monitoring wells and checking
their water levels and quality. The shallow groundwater flow pattern is
largely controlled by the presence of Mill Creek and the East Drain.
The second performance standard - water quality protective of aquatic
organisms in Mill Creek - is expected to be achievable relatively quickly on
a temporary basis when the groundwater extraction and treatment system
changes hydraulic gradients and stops the groundwater discharge to Mill
Creek. Achieving the standard on a permanent basis (e.g. without the
operation of the groundwater extraction and treatment system) will require a
reduction in the site groundwater concentration of the inorganics with the
largest loading to Mill Creek from the Western Processing site, namely zinc,
cadmium, and possibly chromium. Based on a mass balance/dilution analysis,
CH2M Hill has determined that the groundwater target levels to meet creek
water quality criteria are zinc at 500 ppb and cadmium at 10 ppb. To
achieve these groundwater target levels, over 99 percent of the available
(mobile) zinc and cadmium would have to be removed from the site. Assuming
all of the zinc and cadmium measured at the site is available, over 120
years of groundwater pumping would be required to achieve the required
levels.
Originally, another objective of the shallow groundwater component was to
improve the shallow groundwater at the boundary of Area I to drinking water
standards. However, this standard is may not achievable for technological
reasons. While organic contaminants can be mostly eliminated from the
shallow groundwater system (or reduced below drinking water standards or
criteria) in 5 to 30 years of pumping, some of the inorganics found below
the site could not be reduced to drinking water standards in over 120 years
of pumping, though the technologies which may be necessary to produce
groundwater quality which will protect Mill Creek will also greatly reduce
the concentrations of those inorganics for which there are drinking water
standards.
If groundwater cannot be returned to MCLs or other health based criteria
(e.g. acceptable excess cancer risk levels or ADIs), ACls may be established
in a future ROD. The ACls may utilize" institutional controls.
Institutional controls on both the state and local level may be proposed to
ensure that there will be no threats to public health from this contaminated
groundwater. WOOE may be able to restrict groundwater extracted at rates
over 5000 gpoi, but has no control over domestic sized withdrawals. However,
the Industrial zoning of the area, alternate water supplies, and city
controls should preclude the smaller sized withdrawals.
Forces other than institutional controls are more likely to ensure that no
one withdraws this water for use. The shallow groundwater under the site,
as discussed in the Section on Consistency with Other Environmental Laws, is
not an important groundwater source in the Kent area because of generally
low yield (less than 100 gpm) and poor water quality. Large amounts of
excellent quality, water are available from the City of Kent production and
distribution system. The agency's original concerns .for the threats to the
City-of Kent water supply wells have turned out ta be unfounded, as the
artesian aquifer only exists at the margins of the valley, not below Western
Processing.
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Mill Creek
22
The objective for remedial action in Mill Creek is to eliminate those water
quality conditions in Mill Creek which limit aquatic organisms of concern
and which are caused by Western Processing. This objective will be met by
groundwater control, shallow groundwater quality improvement, and sediment
excavation.
The performance standard is to return Mill Creek waters and sediments to
ambient water quality criteria for aquatic organisms or to upstream (creek
or groundwater) background, whichever is less stringent. However Mill Creek
has a number of unusual conditions which would exist even if Western
Processing were not present. These include background (upstream)
concentrations of certain metals and organics above water quality criteria
for aquatic organisms and background groundwater concentrations which are
also above water quality criteria. The upstream concentrations above
criteria are probably from both other sources of pollutants and the high
natural groundwater concentrations of metals.
The lack of valuable aquatic organisms in Mill Creek is probably more from
the many sources of pollutants and habitat modifications in Mill Creek, than
from the high background groundwater concentrations. The aquatic water
quality criteria are based on the most sensitive species. A review of the
criteria development documents show that the fish of most concern in Mill
Creek - namely salmonids and trout - can live in zinc concentrations much
higher than the Federal water quality criteria. Similar information is
available on cadmium.
The east drain water and sediment quality will also be improved with a
combination of groundwater control, shallow groundwater quality improvement,
and sediment excavation.
In addition, the recommended alternative includes a sediment excavation
program to remove sediments contaminated with metals in a bioavailable form
because of the potential threats to bottom-dwelling or bottom-feeding
organisms. Tin's removal would be planned for after the groundwater control
system has been effective in stopping groundwater discharge from Western
Processing to the creek. At a minimum, the stream length to be excavated
would extend from the upstream end of Area 5 to downstream of the railroad
drainage ditch discharge. Additional downstream areas of known deposition
would be tested for bioavailable metals which came from Western Processing.
Other alternatives for Mill Creek presented in the Feasibility Study were no
action and groundwater control to achieve the water quality criteria but no
sediment excavation. The groundwater control only alternative would be
protective of the environment, but would take longer to remedy the problem.
The groundwater control only alternative would allow natural sediment
transport to clean out the sediments over a number of years. The
recommended alternative is more quickly protective of the environment and is
thus a cost-effective -alternative.
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Storm water controls
23
Storm water must be managed both on and off the Western Processing site,
as well as during and after construction. The PRPs have been collecting
and treating Area I stormwater prior to discharge to the Metro system. If
necessary, a similar system will be continued by EPA and WOOE until
construction begins. During construction on and off the Western
Processing property, all stormwater must be handled according to good
construction practices. This may include collecting and treating the
water prior to discharge. After Area I is capped, clean stormwater will
run off the site, with the rate and quantities consistent with the City of
Kent's stormwater ordinances. The off-property covered/capped areas will
require maintenance to ensure that erosion and sedimentation will not
occur.
Besides no action, there are three other alternatives for handling Area I
stormwater during the groundwater pumping period. (The final RCRA cap
would be placed on the site after pumping is completed.) These are: 1)
continued collection, treatment, and discharge to Metro of the stormwater;
2) a temporary cover/cap on the site which would allow the water running
off the property to be uncontaminated; and 3) store the stormwater on the
site and allow it to infiltrate through the unsaturated zone. The no
action alternative is not protective of public health or the environment.
Collection, treatment, and discharge of the stormwater would have the
highest O&M of any of these alternatives, and would use up a large
percentage of the potential sewer line capacity which will be needed for
discharge of the treated groundwater. Of the other two alternatives, the
infiltration of the rainwater is the recommended alternative because it
will enhance the leaching of the metals and lower the operating costs for
the acid leaching system.
The capitol cost of the recommended alternative is included in the grading
to install the groundwater pumping system.
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24
Monitoring
The recommended alternative includes an extensive monitoring program
designed to monitor the effectiveness of the remedial action, to provide
information for future phases of the remedial action, and to investigate the
deeper regional (50 to 150' deep) groundwater conditions.
This monitoring program will include:
- Nine to twelve well clusters encircling the contaminanted groundwater
zone, with 6 to 8 shallow wells screened at 10 to 30 feet within the
contaminated zone. The well clusters will included wells screened at
10 to 30 feet; 40 to 60 feet; and 80 to 100 feet below the surface. At
least three clusters will include a well screened at 120 to 140 feet
below the surface.
- Mill Creek and East drain water and sediments upstream and downstream
of the Western Processing site.
- Air monitoring for organics and particulates during construction.
Most alternatives in the Feasibility Study had groundwater monitoring. The
no action alternative is not adequately protective of public health and the
environment, and would not comply with the RCRA groundwater protection
strategy.
Monitoring costs are estimated to be $540,000 per year.
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Community Relations
25
A major conment during the puolic comment period on the Feasibility Study
was the interested community's desire to have access to monitoring data and
other information on the status of the site before significant decisions are
made. EPA intends to remain the lead agency for community relations, with
active participation by WDOE and tne contractors.
Activities will include:
- Public presentations on the progress of work on the Western
Processing site, with the frequency and location to be guided by public
interest and the City of Kent. A suggested approach is for monthly
presentations at the City of Kent City Council Workshops throughout the
design and active remedial construction period, with quarterly or
annual presentations during the extended O&M and monitoring periods.
- Preparation and distribution of a public notice and fact sheet at the
completion of engineering design
- Continuation of the information repository at the City of Kent and
EPA Regional library. At a minimum, copies of all public and press
releases; QAed groundwater, surface water, soil, sediment, and air
monitoring data; supplemental remedial planning documents and all other
similar documents will be placed in these repositories promptly.
- Public presentations on the supplemental planning studies, if any are
initiated. Public presentations would, at a minimum, be made during
the design or scoping of the study, and again when the study is
completed and recommendations are made. These public presentations may
be part of the above regular public presentations, with additional
public announcements on the agenda of the presentation.
Other Issues
Any construction in the flood hazard areas in Mill Creek will be designed to
not adversely change flood elevations and to comply as much as practicable
with all applicable local rules, regulations, and ordinances.
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Costs
26
The estimated costs (+50% to -30%) for the recoirenended alternative is:
Detailed design $3,415,000.
(Of which, $1,625,000 is for soil and waste sampling and
analysis.)
Capitol Costs
On-site, soils
Off-site soils
Groundwater pump and treat
Enhanced leaching
Mill Creek excavation
Total
Operation and Maintenance
Annually, during initial phase of system operation
Without ennanced leaching 2,000,000.
With enhanced leaching 3,000,000.
The present worth of the proposed alternative for the five years of initial
system operation is estimated to be $26,300,000, not including detailed
design and soil sampling and analysis.
Most of these costs are based on the data in the Feasbility Study. The
costs for the enhanced leaching and soil sampling programs were developed
after the Feasility Study was completed.
$5,200,000.
625,000.
6,800,000.
2,600,000.
1,300,000.
18,100,000
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27
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The following federal environmental standards are applicable to remedial
actions at trie Western Processing site:
- Hazardous Waste Regulations (RCRA), Subpart G - closure and
post-closure
- Hazardous Waste Regulations (RCRA), Subpart F - Groundwater
protection requirements, including potential ACLs for the most toxic
and persistent chemicals
- Hazardous Waste Regulations (RCRA) relating to compliance at off-site
disposal facilities
- Clean Water Act pretreatment standards for discharge into a publicly
owned treatment works
- TSCA requirements for PCB disposal
- Guidelines for Specification of Qisposal sites for Dredged or Fill
Material
- National Ambient A1r Quality Standards
- Floodplains Executive Order
- OSHA Requirements
- DOT Hazardous Materials Transport Regulations
The following federal environmental standards are relevant to remedial
actions at the Western Processing site:
- Water Quality standards for Mill Creek, as determined by the State of
Washington under tne Clean Water Act, if there is a surface water
discharge
The following federal environmental criteria, guidance, and advisories are
to be considered in remedial actions at the Western Processing site:
- RMCL
- Federal Water Quality Criteria
- EPA's Groundwater Protection Strategy
- Floodplain Executive Order
The following state envlronmental, eriteria, guidance, and advisories are to
be considered In remedial actions at the Western Processing site:
- State groundwater approval
- State How Clean is Clean policy
The RCRA Subpart G - Closure and Post-closure - technical requirements were
applied in a number of different"ways. Example Alternative 2 was designed
to comply with the standards for closure as an existing land disposal unit.
Example Alternative 3 was designed to comply with the standards for closure
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28
as a new land disposal unit. Example Alternative 5 was designed to comply
with the standards for closure for. a storage -facility. The RCRA Subpart F -
Groundwater Protection technical requirements were satisfied in Example
Alternatives 2, 3, and 5.
The recommended alternative is an interim measure. However, the relevent
and applicable standards, criteria, guidance, and advisories have been
considered in the recommended alternative whenever practicable.
Aspects of the recommended alternative which are compliant with the
applicable and relevant portions of RCRA regulations include:
- Groundwater monitoring
- PCB clean-up levels (The 2 ppm off-site level in also consistent
with WDOE policy.)
- Off-site soil cover design and maintenance
- Title/deed restrictions if certain off-site areas are capped instead
of excavated.
Aspects of the recommended alternative which are consistent with the
Assistant Administrator's application of RCRA to the Crystal Chemical CERCLA
site include:
- Consolidation on-site of hazardous substances which have migrated
off-site from Western Processing
- When combined with the recommended alternative's groundwater
actions, the off-site excavation criteria
- In situ stabilization and treatment
Aspects of the recommended alternative for which RCRA compliance will be
determined in the next phase of remedial action include:
- Acceptable shallow groundwater concentration limits.
- On-site cap design.
- Title/deed restrictions in Area I.
The federal Water Quality Criteria for aquatic organisms are used to set the
Mill Creek water quality needs in all Example Alternatives and the
recommended alternative. As described below in the reconmended alternative
section, the recommended alternative is consistent with EPA's Groundwater
Protection Strategy. The shallow groundwater is technically Class II,
though It has some elements of the Class III definition. Alternative water
supplies are available. . *
Other key requirements which will be complied with include: RCRA
requirements at off-site disposal facilities; Clean Water Act pretreatment
-------
29
standards for discharge into a publicly owned treatment works; TSCA
requirements for PC8 disposal; guidelines for the disposal of dredged
material; air quality standards; floodplain protection requirements.; DOE
Hazardous Materials Transport Regulations; and the State of Washington Water
Quality Standards for Mill Creek.
The State of Washington Department of Ecology participated in the
development of the Feasibility Study and has concurred in the recommended
alternative.
-------
30
OPERATION AND MAINTENANCE (Q&M)
The OAM activities required to ensure effectiveness of the remedy include:
Operation of the groundwater extraction and treatment system as long
as necessary
Maintenance of the RCRA on-site cap and off-site caps/covers, and
stonnwater control system for a minimum of 30 years
Long-term monitoring of the shallow and deep groundwater, and Mill
Creek water and sediment quality.
These O&M activities may be required in perpetuity if these or other
remedial actions do not mitigate the releases or if problems are
detected. Alternatively, certain of these activities may be allowed to
cease after EPA has determined that no threats to public health, welfare,
or the environment would occur.
Annual O&M costs witn the operation of the groundwater extraction and
treatment system are estimated to be $2,000,000 to $3,000,000 depending on
whether the enhanced Teaching system is operating. Annual O&M costs would
be lower when the groundwater extraction system ceases operation.
Because this is an interim remedy and the initial phase of system
operation/construction will require up to five years, monitoring and the
operations and maintenance of the pumping system for five years is part of
the remedial action which will be paid for by both the Fund and WOOE. An
EPA/State contract or cooperative agreeement will be the mechanism for
this Q&M. WDOE acknowledges that O&M in future years will be the
responsibility of the state.
-------
31
SCHEDULE
- Complete Enforcement Negotiations
- Approve Remedial Action (sign ROD)
- Award IAG for Remedial Design to COE
- Start Design
- Award Superfund State Contract for Construction
- Advertise for Construction Bids
- Start Construction
- Complete Major On-site Excavation
- Start Groundwater Extraction
September, 1985
September, 1985
October, 1985
November, 1985
April 1986
April 1986
June 1986
August 1986
1987
Fund-financed and state financed actions will be neccessary for stormwater
control actions until construction starts in 1986.
-------
32
FUTURE ACTIONS
The additional remedial activities which are required"to complete the site
response may include:
Supplemental remedial planning and possibly a third operable unit if
the extent of groundwater contamination is not adequately control by
the shallow groundwater extraction and treatment system, if the
contamination in the shallow groundwater is not adequately reduced by
the shallow groundwater extraction and treatment system and in situ
chemical leaching, or if contamination from Western Processing is found
in the regional aquifer.
Site close-out with a cap.
Long-term O&M on the groundwater extraction and treatment system, cap,
cover and stormwater control systems, and monitoring systems.
-------
Table
INDICATOR CONTAMINANTS USED AT wpwrm,
WESTERN PROCESSING
Orqanica
. Inorganics ¦
Volatile Organics: M
1,1, l-Trichloro«thana etal':
Trans-1,2-0ichloroethene Cadmium
Tetrachloroethene Chromium
Trichloroethene copper
Toluene Kickml
Chloroform 21*
Acid Extractable Compounds: nc
2,4-Dim«thylphenol
Phenol
Baae/Neutral Comoounda:
Total PAH'3
Total Phthalatea
Other Organic*s
PCS'a
Oxazolidone
aTotal priority pollutant polycyclic aromatic hydrocarbons
(PAH'S).
Table fl|2
LOCATION OF CHEMICALS WITHIN THE SOIL PROFILE
Indicator
Compounds
Metals
Volatile Organics
Acid Extractables
Baae/Neutrals
Total PAHs
ththalates
Depth Below the
Depth Below the Surface Surface Where Compounds
Where Compounds Were
Moat Frequently found
Q to 9 feet
6 to 9 feet
9 to 21 feet
0 to 3 feet,
0 to 9 feet
were Found in the
Highest Concentrations
. 0 to 9 feet'
6 to 9 feet
9 to 21 feet
0 to 3 feet
Surface soil
PCB* 3
Surface soil
10 feet Con-property)
Surface soil (off-
property)
-------
Table IBM 3
TOTAL MASSES AND SITE AVERAGE CONTAMINANT CONCENTRATIONS
(NONDETECTS » 0) WESTERN PROCESSING, KEN?, WASHINGTON
I
Average
Average
Area
I/II
Total Mass
Total Mass
Total Mass
Average Soli
Average Soil
CrouiulwAttr
Growxfcut**
In Soil
In Soil
In Soli
Concentration
Concentration
Concentration
Concentration
0-6 ft.
6-15 ft.
15-30 ft.
6-15 ft.
15-30 It.
§-15 ft.
15-30 ft.
Contaatnant
<*«ll
(Kq)
•K«i»
(yg/Kg!
lUQ/fcjl
toa/M
cwam"
Volaltles
Phenol
393
724
190
3,929
460
108,583
1,490
Methylene chloride
337
358
61
1,446
148
56,873
48,971
Trans 1,2-dtchloroelhene
0.01
1
1
2
1
30,397
154
Clilorofore
28
99
1
403
3
3,178
3,012
Trlchloroethene
2,245
5,220
17
21,105
43
39,508
7,244
1,1,1-frled1o roethane
376
883
1
3,375
1
31,609
1,014
Toluene
1,016
2,132
22
8,583
52
1,631
314
Tetrachloroethene
148
271
0.3
1,097
I
109
0
Ethylbcnxene
82
203
1
819
3
3
0*
bN/AE
Naphthalene
8,20?
369
4
1,493
11
2
23
Pttenanthrene
22,391
549
0
3,321
0
0
0
PCD
58
279
0
1,138
0
0
0
Pyrene
17,003
83
0
334
0
0
0
Fluoranthene
993
135
0
544
0
0
0
Benio(alanthrancene
1,086
4
0
1?
0
0.3
0
Bis(2-ethyIheiy1|
phlhalale
3,988
3,207
147
13,968
356
< 0
0
(totals
•
Nickel
19,360
20,164
5,103
81,533
12,380
15,139
14,350
Cadalua
4,738
7,778
605
31,451
1,468
2,391
.. 964
Zinc
777,160
494,287
93,713
1,873,331
337,355
126,447
117,687
Chroalua
76,329
164,679
16,681
665,879
40,469
5,349
313
Arsenic
1,311
85S
1,753
3,458
4,351
14
13
Copper
51,022
84,395
10,678
341,350
,25,905
1,331
757
Lead
1,350,394
636,031
5,385
2,564,661
12,833
340
363
-------
Table
Total Mass Total Mass Total Mass
in Soli Id Soil In Soil
0-6 ft. 6-15 ft. 15-30 ft.
Area Contaminant (Kg) (Kg) (Kg)
V Volatlles
Phenol
29
0
Methylene chloride
1
4
163
Trans 1,3-dlchloroethena
0
0.01
1
Chlorofor*
0
0
0
Trlchloroethylene
o.l
J
1
1,1,1-Trichloroethane
0
0
0
Toluene
1
1
4
Tetrachlorothylene
0.02
1
0.1
Elhylbenxene
0
0
0
BN/AE
Naphthalene
0
0
0
Phenarithrene
0.1
0
0
PCB
5
0
0
Pyrene
0.1
0
0
Fluoranthene
0.1
0
0
fienxo(a(anthracene
0
0
0
Blsl2-ethylhexyl)
phthalale
0.01
0.04
0
Metals
Nickel 654 654 951
CadBlua 171 46 16
Zinc 30/64) 7,747 3,321
Chroalu* 1,679 924 699
Arsenic 306 324 813
Copper 1,235 1,172 2,070
Uad 7,057 796 233
(cont.)
Avarag* Soli Average Soil -
Concentration Conoafitratlaj)
6-15 ft. 15-30 It.
Jua^sal
Avaraga ivtnga •
OmadMUr Qroundwatar
Coooaotratloa Concentration
6-15 ft.. 15-30 ft.
Ua^l ftw't)
1,240
60
0.2
0
23
0
20
15
0
0
1,623
3
0
6
0
37
1
0
0
0.06
3
0.06
0.06
0
0
0
0
0
0
0
745,954
, 40(603
147,005
1,213
89,535
3,620
1
163
0
39
123
0
3*787
Bfito
a
44
0
0
0
0
0
0
0
0
23
0
0
0
0
0
10,840
753
128,439
15,318
5,381
19,440
13,199
9,456
162
32,043
8,946
8,Q07
30,590
2,334
1,327
68
18,284
66
5
42
29
461
119
30,876
80
15
24
21
-------
Table >w3(cont.)
t
tots l Mass
in Soil
0-€ ft.
Area Contaalnant (Kg>
II Volatiles
Phenol 0
Methylene chloride 4
Trans 1,2-dlchloroethylene 0
Oi)orofor» 0
Trlchloroelhylene 0.01
1,1,1-Trlehloroethane 0
Toluene 0.03
Tetrachlorothyleive 0
Ethylt>en*ene 0.01
BN/AE
Naphthalene 0.2
Rienanthrene 0.02
PCS 3?
Pyrene 0.3
Fluorantliune 0.1
Bento la)anthracene 0.3
Bis(2-ethyllieiiyl)
phltidldte 1
Metals
Nickel 594
Cadatua 135
2inc 15,478
Chroatua 9,470
Arsenic 333
Copper 2,320
Lead 1,698
total Mass Total Mass Average Soli
In Soil in Sail Coaoifltratlao
6-15 It. 15-30 ft. 6-15 ft.
(Iq) >Kq> (Uq/Kgl
pnMiAiBMammmm MMWMMBW
0 0 0
3 4 67
0 0 0
0 0 0
0.1 0.01 2
0 0 0
0.1 1 3
0 0 0
0.01 0 0.1
0 0 0
0 0 0
0 0 0
0 0 x 0
0 0 0
0 0 0
1 443 10,719
547 728 13,509
81 25 1,993
14,221 7j hi* <5 - .?/ / •
3,767 817 92,928
435 443 10,719
1,738 1,429 42,872
179 142 11,809
f Average Average
Avfra^a Soil Grouuiu«tar Groundwater
Coocmatrttioa Concentration Coaomtftloo
15-30 II. 6-15 11. 15-30(1.
• nyi
0 • 0 • 0
68 30 5
0 118 18
0 0.3 0
0.1 106 46
0 10 7
18 . 0.1 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 0 0
0 o 0
0 0 , 0
6,557 0 0
10,770 540 ' 0
367 94 0
M -i 4, /o /
13,093 .7 0
4,557 0 0
31.161 3 0
i 3,098 0 0
-------
Table 4
SUMMARY OP PUBLIC HEALTH, ENVIRONMENTAL,
AND TECHNICAL EVALUATIONS
Cast Imlllaml
Catania
kll*n>atl»*
Ms ictlaa
CaulUI
-0-
ftunt
I.
kllMlt c«j> mr
llMI I Ml >1, tM •
yertloa or krea V Ifxa*
• 1*1* Iw l»j«r« ts inr
teal Jallllfatlfial,
CwlittM *tenaa*t*r
klatfeafga hm g*m»4
. IIHI Iftto Mil Crmt
Cwll aet
•< "i will altar apyraal-
fcllnialiul
I*pact*
Priority pellataat pllll om-
eaatrallaaa la Hill' Creak iaaa-
atreaa el Nailers freceutM
aacsed dkiaale aad acuta »»•
bleat hIu quality criteria
let aquatic ar«aalaaa, Ibeee
a*l* I oMoalritlMi probably
ere an* aeuld caallaua ta fee
loalc la a aide fMlatyal equk-
lie srgealaaa lai ktiadreda el
r«'«.
merlin petlitlaal acgaats oaat-
eaatralioaa la Hill Creak 4am-
•ueaa el Haalaia tsaoaaalap
At ael eaoaad aaftlaat aatar
Quality criteria tar aquatic
e<«eal*aa,
MImIi la Hill Creak coa-
lala M|k laaeta el priority
(•llulut aalala.
Qaoa beflak, itlt Creak
aeterk wali appraaI* aablaal .
aatar quality crltarU ar back-
erauad Mldmr la ll|l»cl
f»r dlaaatved aalal caelaal-
aeata. CeatMtUaata e*arla«
te kill Creak aadlaaata aad
liOalll laecMa# keck lata
Mill Creak Vetera akf tmlay
•cblaalaf aafctaat eater «al-
liy criteria ar bM*«fauad«
Ifcwild allalaals eaataalaaled
linirt ¦
mJOMMSSULm
¦lonwatar naall aaaali to la
caatact Mlt «wl>alakl«i aalla
Mill tMUftff CVfelttiMkiflB
fftB ill sit* mi* trfjfttiMkl
xaw Mi |«l« Kill cxaak.
t
lallllratlaa mhI4 wallawe ta
tMCft 43MltlMblMMhl#' (ff4MI ftlMF
cmm m* fltrvy ftiMi
liMt iMNMMMUl
U« alia.
fftltxliitli (fW
Haatan Vraoaaatag aaali caa-
tlaaa ta 4lackar«a |Ma Mil
Creak el M la W fgm. tkmm*
¦atar «nlii| k»aialk IM alia
aaal* Nnil «l| «H| llaalf
(I.e., Mlt re*itre aall lr
, a(IUi|9( &0v#Iji IM, immM Nri»
atMriali lapact tun Creak
MkUr «Mllt«l.
Dm na»iag ajataa taeuM alto-
arla<.
tm aatraaalf leaf j»ayl»gt •
lr**leaat« aa4 afalaaa aata-^
tMMM MNl)# INI WW
gal
-------
Table 4*
(continued)
UuwIIh
cp«t imniwui
Fraaaat
CtclUI ' Won*
Public MaalU
>IMCtl
twlmmUl
Tactalcal
JitetL.
-2ttU-
Coatlmiart
(lictirgi Isle bus
IfllM 1100 V«l
¦MllMlRt
Uaallk tad »«<•t» plana
u4 Iralalag pilot to
owitniciliit
Cacatata <11 uiMluiiIri
•oil* no«,oao ci*ic
yards) la JUmj I u4 II
m4 mm lu>l li a polite*
•i viii, «iu ai»*
pitl la Ma ll-ocia,
deufela-llMd, SOU oa-
alia landfill.
Nultlaadla cap e>ar
laedflll Uiaa II,
Iraa II, m4 a perlloa
•I tiaa V laaa bo^li
lllaraatKa )l.
Coot roll*4 ttofavatar
dlacstaigtd lioa carpal
anu lata Mill CimI
Ml a ly 40 yaara tl pnaplng.
Ackla«la« Mill
Malar •laolarla la Lka |iw(4>
¦alar Iw mUI aatxluiti
Mull te aucfc aua lllllcult.
Im UMpla, II mill rabulia
nail torotl 100 (Mil el |ta»-
Ug la acklna IW nklia
alaadail, afcll* Um alaitol
let ImI M( Miai to
tcklaval.
Hi.) fll.t taill allalaata direct huMa
aal aalaal oaalacl ln aaull
be required la nte Uw eoa-
oaaUatleaa al aalala la Um
imatitUi la laxla Ual
Mul4 aal caaaa caatleual la*
tredallea al Mill Craat illai
Ik* I»*plag ifHaa la luraal
•it.
Malar quality yntlaaa la Hill
Ciaal iiyaliaaa al Heater* hr
ceaalag, attck aa laa llaathd
u||H laMla, oaiall caallaaaa
la Hall Ua hablUt «alll|
la Hill Croak.
Mould to Ideatleel la Csa^la
Alternative J. -
Mill Croat altar Ua
*fit*9 U Uml all*
Ctf mm 14 ycaeeal tellltretlea
||
Iraa Ua i— alaralal mm la
toaai l| II, aal * late Ua
liaiatiiUl. Ulaclla* caf
11 (aI tea U Ute wltatl*
U Mt I
Mwi w| al IM
aaall * fnHHUI.
rmil araa*
Usui! (again parawal aaoaaa
la Ma djMNl (NfaiUn.
Haul! ra^alra a II wall «*•
eLructlaa per tel. Cay wall
n«iln nlallNlf aavlaa car
alndlaa tedalfwa.
CauindUa I apart a caull to
altlMtel by «aal nautnctha
iractteM, tut aal mail oaa-
trala, arkatillaf.
hall allalaata llaaftarg* al
raalo^laalel liaakaUi Iraa
Htatefa Hacaaala* la Mill
Craat'aMta Ua pta^laf i|aUa
la avfr«tla«.
t I
Uta ftwla Alteraallva I, aa
aaUapalf lea* paal-eaaalractlaa
HlH traalaaal, aal alt*
aalalaeaara facial wall to ra-
«dial tolan aater «Mllt|
atujirda, criteria, ar tod*
«raw*l laoala could to aat la
mi) craat alter Ua payla«
qiUa la I at aal all.
Nwll ia«Uia Ua aaa
acuaai aa la Baaapla
^Iteraalltm 1.
i type al
Naaall ta«l| tilt KM lectol-
sal ataalarla lar oaaalructlaa
•aal claaura al a aaa toaariaaaa
iaaate laalllll.
Materlala la to aacaaalal toaa
aal fat toaa claaatliel anlar
Uta UttS Qeagaraaa* Hasla Ikfi-.
I at laaa. Ma "Satraaaly laiwl-
aaa Madia" aaf to laalllllel
alUla Maaklaftoa lute.
Cartel* aaunalM aalarlala
«tt aa Kfe/bairla* Iraa*,
•al oaaoaalralol kaalaa aaall''
raqialre apeclel toalia« aal
peealbly dlapoaal moatuaa.
nature uao ol Uo laalllll aal
cappel.area* aaaill la
ynUIIM. '
-------
Table 4
(continued)
Kaaapla
muiwiix
.£ai BtUteft
£s£IM
PltMBl
Hwtk
M116 Naaltk
, < IntitMMW
'4-i. iMm*s£i±±.
S«k
II.':
CoollauM
' ftt Wiir
BTffH
CfouefeaUr inaplsg
unal landfill «4 la
paittaa* t( liw II
lai V, wwtla Uaal-
•*al| fti tlKMip
tat* H*(ib •!•(*¦
1*4 H»l
Itualtol lif
ttMltfe Mtd ptac*
i>4 litUlRg ftlat Is
OM*l(UCl|u. nt* mmm im wi iii*
(twit, kvl nt lnm|M«, ta
MM»ll4l H Ua llalM
lll-wnl «|tn « Aim I.
MfluM f^ilffl #4-«SfttJl CNMtJlN?*
IImi Ctflt «mK iMilili
Mil (•*•!(• rMInI| caa-
CWMtfUSliflP
At luUtlt mM mg wilii» -
ll« mil taataia wmI*
A§t#Iy CO •§ fefcUl Umi
f 4AC Afli (UNt4li fMMbMfclMASJHi
U Ul Mil,
Tba Htf r«0|M>Mi*
bcaiili la luMlf
tl* lo I'l U
Alt* I
tll.l
aunaal
QUI
Mill
II.«
III.* Hoy 14 allatMla IIiki hiia»»
•od aelaal coolacI atUi «||
M»l«a tell* la ism I.
»!'•, drlBkls« alaa-
Oaida, aM SUU'i Isr *11
•leapt «M IMIcMW MtUtC
talk du* U|an4 »IU» ap U
I iaw* al pwaplaf, Hill CfMfc
wl«r
-------
Table 4-
(continued)
c«t jmnioctt
»I«IML|«
I, CtttM
Ollllla el *U
nnillid aalerlal
cubic iiimi i»
« KM
leelltll
etcenelel aeter-
Ul allk kapxlel lilt
Mil, 10 fMl
tutM Uw parla-
, atai el Itw I
Gfeuo0»»t«f puapliig eel
ilamlH ItltlllliM
la liu I (or u; la
% |HI«| null! Ill Ml-
• IU IHltMil, III-
c*»i«a te lklf« or lt<
Graea *!••( (100 «¦)
Alt** It (MUMKllI tf«
4(f4 | Qgg^ini isa
CI
tkjBltUllSlf
MmIIIi and plana
and |Klw Is
ceujlrucllea
1. bctitu li leal la
Iimi I ml II, 1 ImI
In a (MMtiee el lm *
I including IM el* 41 »-
ctoit* Ilea), I l**t la
Arte II. and I loot Is •
pottles el Will,
Ollalle flUjxinl el *11
••c*»atM uluiil
|1U0,0UI «4<1C Itldtl
III * llu*d HU
I will lit
Capital
»l(0.1
Merege
eeauel
OM Ceeti
W.»
HM.O
ft*llc Mullk
—nasi
mil N wl altkia up l»
I y«*f« el IrWUf
Mltr ilululi far atlili
cwll aet to art eaaa If (to
puaplag (H|r«i Mil «U«M
ladeltaltely.
Muuld elLelaete direct km
eitl enIeel Mlicl ¦life all
Mtlaoa aetle wawl<|
Mtlli MllWi.
bcevatloa aeutl to Mill*
claat l« alia* tM laeela mi
aalala la Mill Creak, taclud-
ta* tlac, to mmirtlf *ai
aakleal eater 9*111; criteria
ar bectftetia*, afctctonar U
kl«bar.
Mould elUlaele oaalaalaalal
iUimKi dlecfcar«a l« tieual-
aetar w< Hill Cfaal.
Cm win lint*! ike He-
ctor pa M all wltolllKfl
panlMlii lm tut i wall
to hhmM.
Ike (rtnlM fat llertorpe "al
cmmmImIjA AtoMMktoff fmtJ#
Cms 4fM I wmJUI Imi ftltotofctof*
Dm lafIliraIlea ayatas tket
Atftod (Umi
to# prefraa Mall provide aMI-
4 tOTtf) SVMNM& f VMI
Ik# JbnMi 9 mbm^UnhMmmI #•••»
NmM f«9Nln II aeaU oaaetsw
llea par tel. ImMMIn al
liveralea kerrlar neall rawdra
relatlealy tulii p—aI rati I »a
CflMlfllCttH iflfMMSl# «m|4 to*
(MMl OHMk&CIRQttMl
liwtlM, feet «i mMI
llllll Ml
I|bm14 mtii |B yccciMMfc
ticlMili tarn Umi
£££0 (AOStttMAQI Ml
Mm 94mi to
Km I.
" N> reliable aal preaea Muraa
(¦Ural altaraella*. tgjtmi-
•atelir M faraaal ml all hv
Uelaaltaa la Mil Mall ke
wnnl t| WMtlta, HmiII
frkiaaatiy allalaala raalaa-
l4Nf (BljAlMNIf^fe#
to Mil baa* Urn Araaa I
aal II. tfce alfiwapany e»-
s^tallaaa oeull iMwa iart
aaaraga aatal CMMltrtttat
la aai|a to tocb«rauaa.
to Un> c(Umht mipii
alUraailaw p«44 |» aaa al
' Um ttl * *»* l*-a
• IJf
ftm VilffAGM'MI
fata far tfcla altomtlw la
KIjwII}' IUIM If Gaaal" '
toffttlMc Ittotoi to i«tetof
ItUI QfMMflMktoff to#AtoMAt>c<-
4HWl 60CMM|Mrlij
kf aall aaailtlaaa.
MlrlM laaiilll capacity
to Mt carraatly available la
II* tol mU% Imi
mll*to It tlMNI. ttw
lllfeaal caata aara aatlaatal
'to to HOB per Ua« tot mail.
«a«y aatataatlally.
mparty mil be aattakla far
fatora aaa.
Caayllaa alt|i ICU lackalcel
nwliaMU far claeuia aa a
aterete facility,
a
Mwt praparly aaa auull aet
to reatrlctal.
Be«*le-ltae4 Ktl laaiilll
capacity ll aet cufreally
aeatlakla la uw Hartfeaaat tot
alii ka aeallabla kf aM-lSCt.
tto llapaaal eeata ten eat!-
aatal ta to ilW par taa tot
cent! aary axtotaatlally.
-------
Table 4
(continued)
co»t imi nooti
bn«li
4H«m«ll»«
Csallwrf
b;lM c«o»»«l»0 Mil'
rUI «IU lapMtai Mil
CrouodMUr ftmpUt If
•KtiillMi
Will llllUMl! u4
4Uc*uf«* Is UM blii
¦ |*lM.
¦onllMlag
NMlIb tnd plui
wl pi lei U»
axutmctle*.
£i£Ull
hrtMot
-fisiii-
Fufellc HaalU
*»i»cla
»ul||ClMllf l» M«t lb*
4tiaui niw iii»taf>l« Mi«rn*ll»« ),
», ~, or >1
-0-
¦III Clwk «*4I
•Ot (*>»• • IklMl 10
Utllk.
HiU te
Rill Cr««fc S«4la«flt
Inoiil lillil U(iI
-------
Table 4
(continued)
i.
UltlMlllt
Ceatiauad
Co.t Ollllotn)
CmHI»I
hMut
JSiii.
KDIlc HaalU
tSSSil
-testt.
butiii lliptM «l
aadlaaal Ira* lb* bad
u4 Uuti si Bill CiMk
adjaoasl la ud
.1,100 InI tauloa
si kilira hwuii>|.
(I.Ktt ante fiittl
Cllill 2,100 In( of
IUII CfMt tats 1 putv-
*s4-|>lpa l|llH titll|
a*ca«al|ga li(«rut'
Mlslf so* aeeLk Aiilif
lk mil Mi W (tola U rw
Ikiaugh Uls part af Bill Cnoi
*tfla« Ua SM-aaaU 4iwralaa.
Klu MiumM aacavattaa aa4
rabatotlltallsa, MUI fialll)
prstoltaa upaUata •( Maalara
honum, auck aa Is* 41a*
ael«a4 h||M IhiIi, (Mil
coatlawa (a Itail MIUI
guilty la Mil Cnal.
Da iauoa paalral wmM law
U ravli allactlM tor Utt
iiIIimU U Will
»¦«•—>—taatal,
Cmatt (ulnrilM |wM>
Mli k nvln*.
•KnIInmh «f uu aaaapla
alUmUNt M Mil Um
ItlnMlM «l «MHu*
miiraw «< mrtwlMii.
-------
Tak»le >5"
WtSlERN pftllCESSlNG
DEfilGN I'llilSE SAMPLING PLAN HUll.lNP.
Pf•)
n
¦h.
1 /
i
l
o
o
1
o
1
o
o
o
0
0
0
1
5fi
0
2
174
30
If,
If,
0
IJifi
lh
51
40
i£E
is
340
CO
351
£4
10.2
to
TOTAL SAMPLES
1003
ANALY COSTS
DRILLING COSTS
LABOR COSTS
*5£G,000
1 SO
*at:,, £.40
SUBTOTAL
EXPENSES
SUBTOTAL
CUNT INGENCY / •.
WiAND TOTAL
*706,790
*70,679
*777,469
»/7,747
~ass, ^le i/
U&OU 1 C. NO
I3-riuq -fl5
-------
-------
FIGURE
ANALYSIS AREAS
-------
I«^4 M i n 0 lUlUUjtv'l
• 1 ¦ • ** ¦oilut t I l&Al (.j iimju HAJUJI
figure tmn «*•
INtMCAfOD WttOflll i PQLiAJlAMI UtUlS
in OhountMuauk
-------
_ • -«««»«*
«<°4' © K)OU/l«iU<»JJ
-------
FIGURE #-5 *
SUMMARY OF NATURE ANO EXTENT
INDICATOR VOLAT1LES IN SOILS 0 TO 9 FEET
BELOW GROUNO SURFACE
-------
FIGURE 44
SUMMAHYO* NATURE AND BCT1NT
INDICATOR ADD SXTIUCmKJES IN SOU-'
0 TO 9 FIST BfLOW GfKXJMQ SURWCE
-------
PJQURi $-7 __,,UT
SUMMARY Of NATime ANO BOtHT
TOTOL PAH COMPOUNDS INSOlU
0TO9 FEET BELOW GftOUNO 3UHFKX
-------
FIGURE ft*
SUMMARY Of NtfURlWO C1
TOTAL PHTHAUTESIM SOILS QT0 9F1
BELOW 6R0UN0 SURMGE
-------
FIGURE** 9
SUMMARY Of NATURE AND EXTENT
INOICATOR METALS IN SOILS
0 TO 9 FEET BELOW GROUNO SURFA
------- |