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^EPA Superfund Record of Decision:

Western Processing Site. WA

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08/05/84 Stn'EHFtJND RECORD OF DECISION • . ^ t W O W M I N C O M C A N I J A T I O N C 0 0 « Westem P r o c e s s i n g , I n c . WA

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The Western Processing site occupies approximately 13 acres in Kent and King Counties, WA. Originally Westem Processing was a reprocessor of axiimal byproducts and brewer's yeast. In the 1960's the business expanded to recycle, reclaim, treat jmd dispose of industrial wastes, including waste oils, electroplating wastes, waste pickle liqvior, battery acids, flue dust, pesticides, spent solvents, and zinc dross. The facility is presently inactive and consists of 10 buildings in poor repair, a solvent recycling pleuit, a fertilixer-plant, 72 boUc storage tanks of varying capacities, drun storage areas with 2,000 partially filled drums and 3,600 empty drums, piles of flue dust, and battery chips. The soil and ground water samples confirmed that hazardous substances had b«en released into the environment. Among the more hazairdous contaminants found on or below the site are chloroform, benzene, 1,2 -dichloroethane, trichloroethylene, phenol, arsenic, cadmium and cyaxvides.

The surface clean-tjp and stomwater control project is the first operable unit of the overall remedial action at tbe site. The main elements of the selected alternative include: characterize all materials identified for remova; removal of all bulk liquids, drumned liquids, and waste piles to a permitted off-site facility for disposal or incineration; renoval and proper disposal of all transfonaers and substation equipment; denolitibn and removal to a permitted off-site facility of all on site btiildincs ^^dlsaantling of all on-site bulk storage tanks. Capital Cost $5.0 m

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Record of Decision Westem Processing, Inc., HA Contaminated media: gw, soil Key contaminants: oils, acids, solvents,

p e s t i c i d e s , V O C s , m e t a l s , T C E , D C E ,

a r s e n i c , cadmium, cyanides

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ENFORCEMENT DECISION MEMORANDUM

FIRST OPERABLE UNIT OP REMEDIAL ACTION SELECTION

Site? Western Processing Coapany, Inc., King County, Kent, Washington

ANALYSIS REVIEWED

I have reviewed the followinc) documents describinq the analysis of the cost-effectiveness for ths Phase I remedial measures for the Western Processing Site.

1. Summary of First Operable Dnit Itemedial Alternative Selection at the Western Processing Site.

2. Draft Final Focused Feasibility Study for Surface Cleanup, June 4, 1984, by CH2M Hill, and amended on June 15, in the Detailed Analysis Condeptual Design for Surface Cleanup.

3. Proposal for Surface Renedial Activities^ prepared by Chemical Waste Manageaent, Inc., ENRAC Division, June 26, 1984, for Western Processing Coordinating Committee.

4. Memorandum dated July 12» 1984» from Robert G. Courson to Jerry Schwartz and Madeline Nawar on Recycling of Liquids from WP during PRP removal.

5. Memorandum dated June 22, 1984, from George Hofer to Judi Schwarz on CSSI Facility In Arlington, OR.

DESCRIPTION OF SELECTED ALTERNATIVE

The main elements of the selected alternative include:

I, On-site and perimeter aonitoring of air quality during remedial activities.

II. Removal of all bulk liquids, druaned liquids, and waste piles to a permitted off-sit« facility for disposal or incineration.

III. Removal and proper dis{>osal of all transformers and substation equipment.

IV. Demolition and removal to a permitted off-site facility of all on-site buildings.

V. Dismantling of all on-site bulk storage tanks. If tanks are determined to be structurally sound, such tanks will be thoroughly cleaned and sold for scrap metal.

EA0003

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VI. All other surfacs debris will bs removed and disposed.

VII. Stomwater will b« controlled and treated prior to discharge bsfors, during, and aftsr the surface cleanup. After the Initial pond rsaovsl, an on-site treatment plant will be sst up and opsratsd.

Each solid vasts pile shall b« removed down to the existing grade level at ths sits location on which it was situated. The exception will b« ths aceuaulatsd *gyp" pond pile. Op to 750 cubic yards of soil bslow sxisting grade level will be removed in addition to ths pils itself. This dspression will forn a storm wstsr accxmulation arsa for use subsequsnt to the surface cleanup. Adjacsnt arsas to ths South will be gradsd to provide drainage to ths arsa. Ths sstimatsd cost for total response action is reported to bs approxiaiately $9 Billion.

DECLARATION

Consistent with ths Coaprshsnsive Environmental Response» Compensation and Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR Part 300), I have determined that the above remedial aeasures for ths Western Processing Site will affectively aitigats and ainisizs damags to, and provide for current and futurs protsction of public hsalth, welfare and the environment. The State of Washington has.been consulted and agrees with ths sslsctsd rsasdy.

I havs also dstsrainsd that ths action being taken which includes the off-sits transport of contaminated materials to a -RCRA approved facility is ths Isast costly alternative when compared to the other remedial options reviewed, and is necessary to protect public hsalth, wslfars, or ths snvironemnt.

)at Xse'M. Thoaas,DateeAssistant Administrator Office of Solid Waste and Eaergency Response

EA0004

SLMMARY OF FIRST OPERABLE UNIT RENEDIAL ALTERNATIVE SELECTION AT THE WESTERN PRXESSING COt̂ ANY, INC. SITE,

KENT, WASHINGTON

SITE LXATION AND DESCRIPTION

Western Processing Company, Inc. i s located a t 7215 South 196th Street i n Kent, King County, Washington. The f a c i l i t y covers approximately th i r teen acres in Section 1, Township 22 North, Range 4 East (WH). The general area around the s i te i s rapidly developing for commercial and industr ia l purposes although there i s a l im i ted amount o f agr icu l tu ra l and residential use in the v i c i n i t y . One family l i v e d across the street i n a rented house un t i l May 1984. A v i c i n i t y map i s provided as Figure 1 ; a s i t e map i s provided as Figure 2.

The s i te i s f l a t and l i e s in the f lood p la in of the Green River, which drains to Puget Sound. Mi l l Creek abuts a port ion of the western boundary of the s i t e , and eventually reaches the Green River. Surface runoff from the s i t e reached Mi l l Creek both d i rec t l y and i n d i r e c t l y , through seeps, springs and surrounding drainage ditches.

Lhderlying the s i te i s an aqui fer , the upper l i m i t of which ranges from three to twelve feet below the surface. Deeper port ions of th i s aquifer underlie a discontinuous set of clay lenses, to a depth of a t least 170 feet . A deeper artesian aquifer may ex is t below an undefined thickness of confining layers of s i l t and clay in the v i c i n i t y of the s i t e . There are no wells current ly used for drinking water w i th in a one mile radius of the s i t e , but the City of Kent (population 27,000) has d r i l l e d wells in to the deeper portions of the aquifer less than a mile from the s i t e in an attempt to develop a drinking water supply fo r the c i t y . Other wel ls have withdrawn water for domestic use from the shallower aquifer i n the past.

The ground water system i s complex. While the regional groundwater flow di rect ion i s generally north and west, a groundwater "mound" beneath the s i te creates rad ia l , and possibly downward, flow from the s i t e , and may have created a hydraulic head dr iv ing contaminated groundwater down in to lower portions of the aquifer. The native so i l s are generally of moderate to low permeabil i ty, though the f i l l materials on the s i t e are generally highly permeable.

The f a c i l i t y presently consists of 10 bui ld ings, including a small laboratory , a solvent recycling p lant , a f e r t i l i z e r p lant , at least 72 bulk storage tanks of varying capacit ies, several drum storage areas which s t i l l contain a t least 2000 non-empty drums, p i l es of f lue dust, battery chips, and over 3,600 empty drums, construction debris, a system of concrete surface Impoundments, and benns and fences. The buildings and other items are in poor repair. Approximatly 2 acres of the s i te are newly paved, covered, and bermed from Washington Department of Ecology (DOE) a c t i v i t y In October 1983. A two acre- feet stormwater lake has accumulated i n the typographic low spot i n the center of the s i t e because the owner/operator's i l l ega l discharges of untreated stormwater to M i l l Creek have ceased.

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K,I SITE HISTORY

From 1953 to 1961, the s i te was leased from i t s then current owner and developed and used as a U. S. Army Nike Ant i -A i rc ra f t A r t i l l e r y f a c i l i t y . 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 s t i l l owned and operated by Mr. Nieuwenhuis, though over the years his w i fe , son, and at leas t one other person have been of f icers of the corporation at various times.

Originally Western Processing was a reprocessor of animal byproducts and brewer's yeast. In the 1960's the business expanded to recycle, reclaim, t reat and.dispose of many industr ia l wastes. Including waste o i l s , electroplat ing wastes, waste pickle l iquor , battery acids, steel m i l l f lue dust, pesticides, spent solvents, and zinc dross. Some of the Pacific Northwest's largest industr ies, such as the Boeing Company, had contracts for Western Processing to handle the i r wastes.

Operations included heavy metals recovery, waste solvent recovery, acids and caustics neut ra l iza t ion, chemical recombination to produce zinc chloride and lead chromate, reclamation of ferrous su l f ide in f e r t i l i z e r production, e lec t ro l y t i c destruction of cyanides, reclamation of metal f in ishing byproducts, and pickle l iquor reprocessing.

Reviews of h is tor ica l aerial photos disclose great changes in the s i t e ' s uses and structures every few years as Western Processing's operations changed. Reproductions of some of these photos are attached as Figures 2, 3, and 4. In addi t ion, i t i s believed that the or ig inal ground level was covered and raised by the materials added to the s i t e . The aer ia l photo in Figure 3 shows the s i te short ly before i t was closed down.

The Kent Fire Department was one of the f i r s t agencies to have contact with Western Processing when f i r es In the early 1970's brought the conditions at the s i te to the i r a t tent ion. The Washington State Department of Ecology (DOE), and i t s predecessor agency, the Pol lut ion Control Commission, have monitored and attempted to control wastewater discharges from Western Processing for many years. Discharges were regulated by permit un t i l la te 1981. At that time Western Processing had fa i led to construct wastewater discharge control f a c i l i t i e s as required by permit, and, in 1982, elevated metals concentrations were detected i n Mi l l Creek adjacent to the s i te . In August 1982, the King County Superior Court, acting on a DOE motion. Issued an order prohibi t ing further discharges of zinc contaminated water from Western Processing i n to M i l l Creek. The company was ordered to pa r t i a l l y close and to remove zinc-laden wastes from the s i t e at that time. The company appealed th i s order and the issues are s t i l l outstanding i n state courts. Several other local agencies. Including the Puget Sound Air Pol lut ion Control Agency, and the Seattle-King County Hsalth Department have or have had pending regulatory actions or concerns with the company.

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EPA's f i r s t major regulatory involvement with Western Processing came through the RCRA program. (In the la te 1970's SPCC actions had been taken by EPA against the company.) EPA inspected the s i te in March 1981 to determine compliance with the newly-effective regulatory scheme of RCRA. t*lany violat ions were documented. Although the company not i f ied EPA of i t s hazardous waste ac t i v i t i es prusuant to RCRA Section 3010, an administrative order i n f*lay 1981 and substantial negotiations thereafter were necessary to convince the company to submit a Part A appl icat ion. (The company claimed that as a "recycler" they did not have to comply wi th RCRA. ) Subsequent negotiations between Western Processing and EPA resulted i n l i t t l e progress toward correcting the v io la t ions. EPA Issued a second compliance order in June 1982, after another inspection in May 1982 revealed addit ional s ign i f i can t v io lat ions and questionable s i te management. This second order assessed a $210,000 c i v i l penalty. In February 1983, EPA f i l e d su i t in Federal D i s t r i c t Court seeking, in te r a l i a , in junct ive r e l i e f and c i v i l penalties concerning the RCRA v io lat ions. This case has since been adnyended to include CERCLA counts against the owner/operator of the s i t e .

As a follow-up to the ear l ie r State and local stream surveys for metals, in May 1982, EPA conducted a stream survey around Western Processing. Twenty-six p r i o r i t y pol lutants were found in the surface waters around the s i t e , a l l of which were subsequently found on-s i te . In July 1982 the s i t e was added to the National Pr io r i t ies L is t .

In August 1982, EPA issued a RCRA 3013 order to the s i te owners/operators to investigate the effects of the i r past practices on s o i l , surface water and groundwater. When the owners/operators d id not comply (due to alleged f inancial i n a b i l i t y ) , EPA undertook the invest igat ion and ordered them to reimburse the Agency for i t s expenses.

The invest igat ion, which entai led the d r i l l i n g of 32 on-si te wells and six o f f - s i t e wel ls from 15 to 30 feet deep at 30 locat ions, began in September 1982 and concluded in November. In a l l , 130 so i l samples were taken and 35 groundwater samples were obtained from the wel ls .

The analyses of these samples confirmed that hazardous substances had been released in to the environment, had been leached in to and contaminated the subsurface aqui fer , and had caused widespread contamination of the so i ls a t the s i t e . Samples of groundwater beneath the s i te contained 32 p r io r i t y po l lu tants , of which eight are carcinogens. Soil samples on and beneath the s i te contained 49 p r i o r i t y pol lutants, of which nine are carcinogens and twelve more are suspected carcinogens. Water and sediment samples taken from Mi l l Creek contained 41 p r i o r i t y pol lutants, of which 11 are carcinogens and 8 more are suspected carcinogens. Tests showed that hazardous substances had spread throughout the aquifer beneath the s i te and i t s environs to a depth of a t least 170 feet and throughout the soi l beneath the s i te to a depth of a t . leas t 15 feet . At least 19 of the soi l samples and six of the groundwater samples were defined as hazardous wastes by the standards of RCRA regulations. Among the more hazardous

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contaminants found on or below the s i t e are chloroform, benzene, 1,2-dichloroethane, benzo-a-anthracene, benzo-b-fl uoranthene, t r ichloroet l iy lene, phenanthrene, naphthalene, f luorene, chrysene, pyrene, trans-1,2-d1chlorethene, 1,1.1-tr ichloroethane, toluene, phenol, arsenic, chromium, cadmium, lead, mercury, and cyanides.

When preliminary results of the Fall 1982 invest igat ion became available i n early Apri l 1983, EPA issued a CERCLA Section 106 order requir ing the owners/operators to cease operations immediately and to provide assurances that they would and could clean up the s i t e . When the assurances were not made, EPA used Superfund money to conduct an immediate removal.

The immediate removal began i n la te Apri l 1983 and was completed on July 1 , 1983. The removal project cost $1.4 m i l l i o n . The purpose of the project was to eliminate the extremely high hazards of the s i t e and to s tab i l i ze the s i t e as much as possible to prevent addit ional degradation of the so i l and groundwater. Table 1 i s a summary of the material taken from the s i t e . Large quantit ies (920,000 gallons plus 1,944 cubic yards) of the most hazardous substances on the s i t e were removed. Attempts were made to f ind users for the materials, but most were sent to approved hazardous waste disposal s i tes . Many other hazardous substances were s tab i l ized and l e f t on the s i t e .

Once the emergency removal was completed, EPA went back to court to ensure that the owner/operator would not s ta r t up operations which could undo the work which had been done. A preliminary in junct ion was issued which prohibi ts the owner from receiving or processing mater ials, gives EPA and i t s representatives s i te access, and which required EPA's p r io r approval fo r a l l a c t i v i t i e s the owner/operator may wish to perfomi on the s i t e . The judge also speci f ica l ly found that the s i te was an imminent and substantial endangerment to the environment.

Stormwater management was going to continue to be a major problem un t i l the s i t e was completely cleared and cleaned. Using State funds, DOE Implemented a stormwater i n i t i a l remedial measure involving excavation of the gypsum sludge pond, restacking and covering the mater ia l , and paving a 2 acre port ion of the s i te . A cooperative agreement for a stormwater IRM to handle stormwater control over a larger portion of the s i t e was signed i n December 1983, but the project was put on hold when the bids came in much higher than the available budget.

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Table 1

MATERIALS REMOVED FROM THE WESTERN PROCESSING SITE DURING THE APRIL - JULY 1983 IMfCDIATE REMOVAL

1 . SOLIDIFIED PAINT SLUDGES/FLAMMABLES

1,900 cubic yards

2. FLAMMABLE LIQUIDS IN BULK AND DRUMS

59,000 ga l lons

3. COMBUSTIBLE LIQUIDS IN BULK

85,000 ga l lons

4. RECYCLED SOLVENTS

25,000 ga l lons

5. CORROSIVE LIQUIDS IN BULK ANO DRmS

50,000 ga l lons

6. NON-CORROSIVE OXIDIZERS IN DRUMS

660 ga l lons

7. PCB LIQUIDS AND PCB C0NT/»1INATED MATERIALS

127 drums

8. WASTE WATER FROM PONDS

250,000 gallons

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CURRENT SITE STATUS

The Section 3013 study described above i n the Si te History section confirmed that hazardous substances had been released in to the environment, had been leached in to and contaminated the aquifer beneath the s i t e , and had caused widespread contamination of the so i ls a t the s i t e .

Table 3 includes a l i s t of the wastes s t i l l on the surface of the s i t e . The materials i den t i f i ca t i on and c lass i f i ca t ion task of the focused f eas i b i l i t y study for the current surface clean-up project i den t i f i es 28 classes of materials s t i l l on the s i t e . Volumes for the various wastes were estimated from previous inforiTiatlon and a f i e l d reconnaissance done during the past two months.

A recent aer ial photo (Figure 4) displays the current condit ion of the s i t e .

The onsite drums vary from 2000 f u l l drums stacked on pal le ts to 6,000 empty drums stored randomly in p i l e s . The condit ion of the drums ranges from good ( i e , perhaps s t ruc tua l ly suitable fo r transporting o f f s i t e ) to current ly leaking.

The tanks holding approximately 500,000 gallons of f l u i d s and sludges have no current evidence of leakage, though some minor leaks were noted during the past winter. The tops of some tanks are unstable or non-existant.

The waste p i les of approximately 3,000 cubic yards of battery chips and approximately 2,000 cubic yards of f lue dust are uncovered, though the new gypsum p i l e has an engineered p las t ic cover top and bottom. The battery chips and f lue dust contain s ign i f i can t quant i t ies of leachable lead and zinc.

Approximately 2 acre-feet of water has accumulated i n the center of the s i t e because of a natural ly occurring low point i n the s i t e topography and the ceasation of the owner's i l l e g a l discharges which used to keep the s i t e drained.

Miscellaneous equipment and debr is , including 4,000 used wooden pa l le ts , are scattered throughout the s i t e .

The 10 bui ldings are i n generally poor condi t ion.

E A O O I O

The exact la te ra l and ver t ica l extent of the subsurface contamination i s now being detemiined. Tests to date show that hazardous substances have spread throughout the aquifer beneath the s i t e and i t s environs to a depth of over 100 feet and throughout the so i l beneath the s i te to a depth of at least f i f t een feet . Additional soi l boring and well construction a c t i v i t i e s are being conducted to further define the extent of contamination. Preliminary results lead the region to believe that widespread surface so i l contamination exists to the north and west of the s i t e .

Contaminants can and probably are continuing to leave the s i te through a var iety o f pathways. While the native so i l i s of moderate to low permeabil i ty, f i l l material on the s i te i s generally very permeable and the depth to groundwater i s shallow - as l i t t l e as 6 to 10 feet . As far as can be determined, t h i s shallow aquifer i s not current ly used as a source of domestic water in the area, though several old wells have been located. A large percentage of the population in the area i s served from wells drawing from the deeper aquifer.

Except in the newly paved clean area, hazardous materials can easi ly enter the so i l column, groundwater, and through nearby seeps and springs, the surface water. Fugitive dust containing high concentrations of lead, zinc and other metals has been col lected across the street from the s i t e . The zinc, and other contaminants in the stream have l e f t the stream largely devoid of aquatic l i f e in recent years.

Direct contact with contaminated materials from the s i te may be occuring both on and o f f the s i t e . The surrounding area i s rapidly being developed for indust r ia l and commercial uses, including those plots generally downwind from the s i t e . A jogging path i s adjacent to the s i te to the east. A family which includes a young ch i l d resided across the street from the Western Processing gate un t i l May 1984.

On-site access i s res t r i c ted to EPA and state employees and contractors, and to persons whom the owner authorizes access. EPA has maintained a dai ly to weekly surveil lance of the s i te since July 1983.

E A O O l l

ENFORCEMENT

Reports submitted by Western Processing to EPA and state agencies, as well as Western Processing business records obtained as part of the Section 106 administrative order, were used in the spring and summer of 1983 to ident i fy over 300 generators and transporters who contr ibuted material to Western Processing. 225 notice l e t t e r s were sent in'Hay and June 1983, with an additional 100 notice l e t t e r s sent i n October 1983. These l e t te rs no t i f ied the generators and transporters that they may be l i a b l e for a l l monies spent by the government and requested answers to f i v e questions regarding their shipments to Western Processing wi th in 30 days. Responses to EPA's notice/Section 104e l e t t e r s gave EPA the names of some other potent ia l ly responsible part ies (PRPs) as well as enlarging the information base available to EPA on specif ic shipments.

The period following the notice l e t t e r s also provided an oportunity to educate the PRPs about the seriousness of the problems at the s i te and the i r responsibil ies under CERCLA as generators and transporters.

The f i r s t large meeting with the PRPs took place on January 1 1 , 1984. After the government's presentation was completed, the PRPs took the oportunity to begin to set up an organizational structure. Preliminary negotiat ions/talks continued with an ad hoc PRP committee u n t i l May 1984. These preliminary ta lks primari ly concerned exchange of information, and EPA's plans.

The extensive computer data base put together by EPA's contractor Techlaw/Intera has been used to provide information to the PRPs. A transaction l i s t i n g has been sent to individual PRPs only a f te r EPA receives a signed a f f i v i d a t s tat ing the PRP has searched the i r f i l e s , has provided a summary of a l l relevant information to EPA, and w i l l give EPA reasonable access to the or iginal information. A l i s t showing the to ta l quantit ies taken to the s i te by each PRP has been provided to a l l PRPs and i s being used by the PRP committee to apportion costs. This data base has also been invaluable i n resolving issues of whether we have correct ly ident i f ied a part icular PRP.

EPA's and DOE's decision to move forward and ensure tha t the surface of the s i te i s cleared during the summer of 1984 was the impetus which accelerated the pace of negotiations. On Apr i l 11,1984 a l e t t e r was sent to a l l PRPs stat ing that the PRPs had un t i l June 18, 1984 to agree to undertake the surface clearance or the government w i l l do i t ahd seek cost recovery. In early May, the PRPs met among themselves and set up a coordination committee as well as special subcommittees. On May 30, 1984, a proposed plan for surface clearance which had been approved by the PRPs technical subcommittee, was presented to the government. On June 19, 1984 agreement in principal on the concent decree was reached between the government and the par t ic ipat ing PRPs. The PRPs intend to s ta r t work before the consent decree has been accepted by the courts i n order to take advantage of the summer's dr ier condit ions.

BA0012

ALTERNATIVES EVALUATION

The objectives of th i s surface clean-up pro ject , a f i r s t operable un i t of the remedial action are:

1. Eliminate or reduce the threat of release of additional hazardous substances in to the surface water, groundwater, soi ls and the a i r .

2. Prevent or eliminate d i rec t contact hazards for the people who must go on the s i te for remedial invest igat ion and s i te surveillance a c t i v i t i e s , and for potential f i r e or emergency response actions.

3. Allow the design and implementation of additional and more wideranging and effect ive stormwater control to reduce the release of hazardous substances into the ground and surface water.

4. Prepare the surface of the s i t e during th is construction season so that the subsequest remedial actions on the s i te can begin ear l ie r and possibly be completed during the next construction season. Subsequent remedial actions w i l l consider groundwater, subsurface and o f f - s i t e contamination.

Iden t i f i ca t ion of surface clean-up remedial act ion al ternat ives

The PRPs submitted a surface clean-up plan to the government on May 30, 1984. The same week, a Focused Feasib i l i ty Study (FFS) was completed by CH2I'1 H i l l and released to the publ ic. The PRP plan and the FFS both came to s imi lar conclusions as to the feasible and cost-ef fect ive al ternat ives for the surface clean-up. Al l a l ternat ives are source control measures. This discussion of alternatives i s based an the FFS only.

The objective of the FFS was to use the c r i t i r i a outl ined i n the National Contingency Plan to determine the al ternat ives wi th the greatest f e a s i b i l i t y of application at Western Processing. For a f i r s t step, remedial action alternatives for each of the 28 categories of wastes described above were developed on a waste-by-waste basis. The al ternat ives were selected for evaluation i f they could apply to the waste types iden t i f i ed at Western Processing, could be used cost e f fec t ive ly wi th the volumes of each waste current ly ons i te , could be implemented during th is construction season, and were a proven technology. The types of a l ternat ives that met these f i r s t c r i t e r i a are l i s ted in Table 2 and are described below.

1. No A:tion

An al ternat ive considered for a l l waste materials on the Western Processing s i t e was that of "no act ion" . This option was not considered to be a feasible alternative for any of the hazardous or l i qu id materials on the s i t e .

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No-action was deemed to be an unacceptable a l ternat ive fo r any type of drummed or tanked l i q u i d waste, because of the high probabi l i ty that additional surface water or groundwater po l lu t ion eventually w i l l occur i f l iqu ids are allowed to remain onsi te. Many drums and tanks are already in poor condi t ion, addit ional de te r io r ia t ion i s cer ta in to happen wi th t ime. In addit ion, accidents or vandalism of the drums or tanks could occur. I f these materials sp i l l on the ground as a resul t of container f a i l u r e , surface and groundwater po l lu t ion w i l l undoubtedly occur.

f^ny of the so l id materials on s i te ei ther contain leachable or part iculate sized hazardous substances or are contaminated by hazardous substances. No action fo r these materials i s unacceptable because they w i l l continue to be a source of release of hazardous substances to the environment, par t icu lar ly the groundwater.

A major problem with leaving anything on the surface of the s i te i s that i t would in te r fe r with achieving two of the goals of the remedial act ion. F i r s t , materials on the surface of the s i t e would in ter fere with the implementation of a bet ter stormwater control program. Second, because the soi l i s very contaminated, a l l materials w i l l have to be removed from the surface of the s i t e for the second phase of the remedial ac t ion, which is planned to begin next year.

2. On s i te Treatment

The Western Processing s i t e contains contaminated water resul t ing from previous cleanup operations and from rainwater f a l l i n g on contaminated surfaces, such as in empty tanks and on the ground surface. More contaminated water w i l l be generated over the summer from addit ional ra in and decontamination water. One option fo r removing t h i s waste i s to t r ea t i t on-si te in order to remove most of the contaminants and then discharge the water to the sewer or the M i l l Creek. Mobile treatment equipment i s readily available fo r th is type of cleanup operation. This a l ternat ive w i l l be part of the aqueous waste removal and the storm water control project.

3. Offs i te Treatment

Several aqueous wastes located on the Western Processing s i t e are be suitable for o f f s i t e treatment and disposal. The water i s contaminated with low concentrations of heavy metals, as well as a wide var ie ty of organic contaminants. Several o f f s i t e treatment f a c i l i t i e s in the local area are capable of t reat ing t h i s water to remove the metals and organics, making i t suitable for discharge to the sewer or surface water. In addit ion, these f a c i l i t i e s are equippted to neutral ize corrosive materials for discharge. This a l ternat ive i s proposed for the i n i t i a l removal of the stormwater current ly ponded on s i t e .

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4. Non-hazardous Waste Landfi l l

The Washington State Solid Waste Management, Recovery and Recycling Act assigns local governments the responsibi l i ty for handling the disposal of sol id wastes. Local health departments are assigned the enforcement function subject to standards established by the State Department of Ecology (Minimum Functional Standards for Solid Waste Handling--Washington Administrative Code 173-301) or standards adopted by the local health department of equivalent or greater stringency. King County contains l a n d f i l l s operated by the County, the City of Seatt le, small municipal i t ies, and private Industry. None of these l a n d f i l l s accepts wastes c lass i f i ed as dangerous by the State, \tor\e of the l a n d f i l l s i n Snohomish County (north of King County) or Pierce County (south of King County) accept dangerous or hazardous wastes.

The various l a n d f i l l s a l l have d i f ferent specif icat ions regarding the acceptable levels of contamination, s ize, and physical properties of the wastes they w i l l accept. In addition each may a r b i t r a r i l y decide not to accept any par t icu lar waste. Most of these l a n d f i l l s have vocal local c i t izen groups monitoring the i r operations.

Solid materials which are suitable for c lear ing, such as t i r e s , may be disposed of i n these local l a n d f i l l s . Other, more porous materials, such as pal lets and certa in bui lding material s, were detemiined not to be suitable for disposal i n the non-hazardous l a n d f i l l s . The testing and cleaning costs, combined wi th the uncertainty of the materials ever being allowed in to the l a n d f i l l s , resul t in t h i s not being a re l iab le and feasible a l te rnat ive .

5. Hazardous Waste Landf i l l

Most of the materials on the surface of the Western Processing s i te are substances that cannot be recycled and that have contaminants high enough to be designated by the WDOE Dangerous Waste Regulations (WAC 173-303) as dangerous or extremely hazardous and thus must be treated or disposed of by an approved treatment, storage, and disposal (TSD) f a c i l i t y .

Under the EPA hazardous waste regulations, hazardous waste l a n d f i l l s are designated as one type of TSD f a c i l i t y . Hazardous waste in the State of Washington can be stored and disposed of by two types of f a c i l i t i e s : dangerous waste l a n d f i l l s and extremely hazardous waste l a n d f i l l s . There are current ly no dangerous waste l a n d f i l l s in Washington that could accept waste such as has been iden t i f i ed at Western Processing, nor does Washington have an extremely hazardous waste l a n d f i l l . Currently, dangerous and extremely hazardous wastes i n Washington are sent out of state to EPA-approved hazardous waste l a n d f i l l s , the closest being i n Arl ing ton, Oregon.

This a l ternat ive i s the reconroended al ternat ive for most of the waste types found on the Western Processing s i t e .

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6. Discharge to Metro

The Municipal i ty of Metropolitan Seattle (Metro) i s the agency responsible for the sewage treatment a c t i v i t i e s and water qua l i ty monitoring in King County. Metro operates and maintains the sewage treatment plants (and main trunk sewer l ines) i n King County. The c i t i e s around Seattle are responsible for the l ines entering Metro's trunk l ines and fo r issuing permits for sewer hookups. Each c i t y i n turn must meet Metro's requirements. Metro's Industr ia l Waste Section issues discharge permits and monitors indust r ia l companies discharging in to the system. The Industr ial Waste section also has enforcement author i ty and issues fines to companies that do not conform to the i r discharge permit requirements.

Discharge from Western Processing would flow to Metro's Ronton secondary treatment plant and subsequently be discharged in to the Duwamish River. Metro's Renton treatment plant has an NPDES permit from the EPA for I t s discharge in to the Duwamish River. Factors con t ro l l i ng the dischharge to the Metro system include Metro's compliance with i t s WDOE NPDES permit, the Renton p lan t 's treatment capab i l i t i es , and safety factors for maintaining the sewer l ines. These factors force s t r i c t l im i ta t ions on the maximum levels of contaminated, dangerous, or hazardous wastewater discharged in to the Metro's system.

This a l ternat ive may be part of the aqueous waste removal and stormwater control project .

7. Discharge to M i l l Creek

This a l ternat ive may also be part of the aqueous waste removal and stormwater control project. An NPDES permit issued by WDOE must be obtained and the wastes treated to the permit discharge c r i t e r i a . The regulations i n the permit w i l l cover basic EPA requirements as well as any more str ingent requirements that might be imposed by state or local agencies.

8. Incineration/Fuel Source

A port ion of the hazardous materials stored at Western Processing are flammable and could be destroyed by commercial hazardous waste incinerat ion. Hazardous waste incinerat ion i s the process of burning the material in a high-temperature furnace wi th a long residence t ime. The units are usually equipped with a caustic scrubber to remove part iculates and acidic gases. CH2M H i l l , as part of the FFS, was unable to locate any commercial hazardous waste Incinerators i n the Paci f ic Northwest.

An a l ternat ive to commercial hazardous waste inc inerat ion of these wastes would be to burn them and recover the i r fuel value. There are, however, a number of l im i ta t i ons i n the types of acceptable combustion devices available and the s u i t a b i l i t y of materials onsite for use as fue ls . For example, some of the "synfuel s" are contaminated wi th methylene chloride. Some of the "synfuel" materials, i f s t i l l pure "oxazolidone", may be suitable for inc inerat ion a t a cement k i lm i n Cal i forn ia. The or ig inal generator of t h i s "oxazolidone" current ly disposes of t h i s waste at th is k i lm.

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A th i rd a l ternat ive would be ocean incinerat ion. The At Sea incinerator ships are being constructed in nearly Tacoma, Washington. However, there have been many delays in At Sea's clearance for a tes t burn. The FFS did not recommend th i s alternative because of timing and regulatory uncer ta in i t ies.

9. Recycle/Reuse

The Western Processing s i te contains some waste materials that could be recycled or resued. Solids in th is category include pa l l e t s , empty drums, empty tanks, scrap steel , and zinc oxide, among others. Most l iqu ids that potental ly could be recycled were removed from the s i t e during the immediate removal l as t sunmer. The owner of the s i te has sold or removed much of the zinc material to foreign and domestic recyclers since l as t summer. Both the FFS and the PRPs plan include se l l ing o f f any tanks which are s t i l l sound and that can be properly cleaned. Some of the sludges at the bottoms of the tanks may not be easi ly removable.

However, there are some major l im i ta t ions on recycl ing the materials from th is s i t e . Based on the testing completed to date, i t appears that most wastes onsite are cross-contaminated wi th other wastes. The operational practices of Western Processing apparently involved mixing d i f fe ren t wastes to obtain a resultant product. In addi t ion, the storage practices of Western Processing would also l i k e l y cause cross-contamination.

In the processing of performing the FFS, CH2M Hi l l contacted v i r t ua l l y every possible reputable recycler or reuser of material from Western Processing. In these contacts there were three consistant issues. The local recyclers are not interested in taking any of the wastes from Western Processing unless 1) the material i s thoroughly characterized, 2) the material i s highly uniform, 3) EPA'will quarentee them freedom from any l i a b i l i t y and w i l l assure payment of any losses, and 4) there i s absolutely no pub l i c i t y . These are not conditions that can be met.

10. Detonation

Detonation i s applicable only to those wastes that are explosive or potent ia l ly react ive. The only wastes that might be explosive in nature are selected laboratory chemicals. For these wastes, detontation i s l i k e l y to be the only acceptable disposal a l te rnat ive .

11. Containment

In some instances hazardous materials on the Western Processing s i t e could perhaps be s tab i l ized and l e f t on the s i t e . Under th is a l ternat ive the hazardous waste would either be treated to render i t nonhazardous and then incorporated in to the s i te closure plan, or would be l e f t untreated for f ina l closure i f the contaminants were solids and less hazardous than the underlyi ng so i l s .

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A major problem with th is a l ternat ive i s that these materials would s t i l l be a in the way for any stormwater control plan as well as for the next phase of s i t e clean-up. Signi f icant regulatory hurdles exist because DOE has a hazardous l a n d f i l l moratorium un t i l 1986. The non-uniformity and cross-contamination of wastes also make th i s a l ternat ive unrealiable.

12. Return to f^nufacturer

For materials onsite that are s t i l l i n o r ig ina l , unopened, and undamaged containers, i t might be,possible to return the material or product to i t s manufacturer. This option i s not feasible for wastes that were generated onsite by'combining the incoming mater ia ls . Specif ic wastes that might meet t h i s c r i t e r i a Include:

Fl ectovara thane wood treatment products located on the pal le ts near the entrance to the f a c i l i t y

Drums of foaming agent located near the southeast corner of the f a c i l i t y

The manufacturers of these substances (also known as the generators) have not made any serious steps to t ry and get these items o f f the s i t e . They have had over a year to do so. Also, the containers are not generally damaged by the weather and thus can no longer be sold as new product.

13. Release to Responsible Party

For wastes whose responsible parties can be c lear ly i den t i f i ed , consideration was given to encouraging the responsible party to remove and t reat the waste a t the i r own expense. Only one PRP i s act ively pursueing th is option a t th is time for i t ' s "oxazolidone". With th i s consent decree now negotiated, i t i s up to the PRP to negotiate an acceptable arrangement with the PRP committee.

Application of al ternat ives to par t icu lar wastes

In the FFS, the appl icat ion of these al ternat ives to the specif ic waste types was done i n two steps. The f i r s t step used qua l i ta t i ve engineering, economic, environmental, and i ns t i t u t i ona l factors to eliminate less feasible remedial actions. The engineering considerations included technical f e a s i b i l i t y , demonstrated appl icat ion and r e l i a b i l i t y , consistency wi th project needs, safety , schedule, and l og i s t i cs . An economic analysis was done on an approximate-cost basis and included c a p i t a l , operation and maintenance, and to ta l costs. The environmental considerations included short- and long-term environmental Impacts and public health e f fec ts . The i ns t i t u t i ona l factors consisted of permit requirements, contract negotiat ion, and r isk po tent ia l .

The second level of screening considered costs in a more quantitat ive manner through the use of order-of-magnitude costs. These costs compared the potent ial value of recycling and reuse (as fuels) versus the cost of sampling and classi fy ing the wastes enough to determine thei r value. Because the s i t e i s often unworkable once the rainy season s ta r t s ,

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schedule was also a screening c r i t e r i on . Disposal of the materials as hazardous waste was the baseline against which a l l a l ternat ive actions were measured.

Table 3 shows the resul ts of th i s screening. Several of the i n i t i a l alternatives were combined to provide a par t icu lar feasib le a l ternat ive for a part icular waste. For example, on-s i te treatment (cleaning) may be necessary before drums, tanks and other metal items can be recycled. Water treated on-si te would be discharged to the Metro system or M i l l Creek.

Al l al ternat ives surviving th i s second level of screening are intended to f u l l y comply with a l l Federal and State environmental laws and regulations, though compliance i s easier to demonstrate with some alternatives such as disposal of a l l materials at a hazardous waste 1andfi11.

Based on the l imi ted testing completed to date, i t appears that most wastes onsite are cross-contaminated with other wastes. The operational practices of Western Processing apparently involved mixing d i f fe ren t wastes to obtain a resultant product. In add i t ion , the storage practices of Western Processing would also l i k e l y cause cross-contamination. This cross<ontamination af fects the selection of the feas ib le and appropriate remedial actions. Local recyclers are not interested in taking any of the wastes unless: the material i s thoroughly characterized and is highly uniform; EPA w i l l quarantee freedom from l i a b i l i t y and payment of losses, and absolutely no pub l i c i t y . These are not condit ions EPA can meet. The reputation of the s i te and the frequent cross-contamination also af fects the f e a s i b i l i t y of disposal in non-hazardous waste l a n d f i l l s and i ncinerators.

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Identification of stormwater control remdial action alternatives

In the September 1983 focused feas ibi l i ty study for stormwater control, the feasible al ternatives were greatly limited by the presence of the various wastes, their containers and the buildings. For example, regrading the central and southern portions of the s i t e were not possible. Their removal from the Western Processing s i t e will resul t in a s i t e where stormwater (surface water) will be easier to manage and control,

A continuing major concern will be the release of water which has become contaminated through contact with and leaching through the heavily contaminated so i l s on the s i t e . The stormwater control actions are intended to prevent the release of additional hazardous substances into the environment until the subsurface remedial action i s under construction.

The a l ternat ives considered by EPA for stormwater control included:

* Grade the s i t e to col lec t the water, transfer the water to an offs i te treatment f ac i l i t y , treatment, and discharge to Metro.

* Grade the s i t e to col lec t the water, on-si te treatment, and discharge to Metro.

* Grade the s i t e to col lect the water, on-si te treatment, and discharge to Mill Creek.

* Grade the s i t e , place an interim impervious cap on the s i t e , and discharge to Mill Creek without treatment.

* Grade the s i t e to col lect the water, no treatment, water discharge by percolation and evaporation only.

* No action.

The al ternat ive proposed by the PRPs i s to grade the s i t e to col lect the water, on-s i te treatment, and discharge to Metro or Mill Creek. The in i t i a l removal of the ponded water already on-s i te would be by collection, transfer to an off-s i te treatment fac i l i ty , treatment and discharge.

All a l ternat ives , except for possibly the no action and discharge by percolation and evaporation a l ternat ives , would comply with al l other Federal and State environmental laws. For these two al ternatives in a worst case s i tua t ion , such as an extraordinarily long period of rain or berm i n s t a b i l i t y , the capacity of the current ponded area could be exceed and water would be discharged to Mill Creek not In compliance with a NPDES permit. An immediate removal measure would then be necesssary to transfer the water to an off-s i te treatment fac i l i ty for treatment and discharge.

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EPA's screening process included technical f e a s i b i l i t y and r e l i a b i l i t y , public health and environmental concerns, i ns t i t u t i ona l concerns, public acceptable, and cost effectiveness.

Prior analysis had shown that the treatment options were very expensive and they had been screened out a t the ear ly stages of the September 1983 FFS. However, a number of new facts and s i tuat ions have made i t worthwhile to consider again. The results of recent sampling has shown the stormwater to potent ia l ly require less treatm.ent than previously anticipated. The need fo r , and level o f , treatment and the selection of the discharge point (Metro or M i l l Creek) w i l l depend on the qua l i ty of the water before and a f te r treatment, and the regulatory requirements. Another d i f fe rent s i tuat ion i s that the waste removal a c t i v i t i e s described above may well involve some type of onsite treatment wi th discharge to Metro for the water based wastes. Therefore there may now be an economy of scale.

Discharge to the Metro sanitary sewer would have be an inter im solut ion. Discharge of stromwater to the sanitary sewer system i s not desirable since i t adds to the "wet weather" flow depends on an already overloaded system. However, for Western Processing, the on-s i te ponding could buffer the flow peaks. Discharges could be scheduled fo r times when the flow in the T'fetro system i s not a t a peak.

Discharge to Mi l l Creek could be a less cost ly a l ternat ive than discharging to Metro i f the NPDES permit requirements can be established in a timely manner. Processing of s imi lar permits i s taking up to 180 days current ly . The on-s i te treatment process would be s imi lar for discharge to either Metro or M i l l Creek,

In the past, the state has used the i r d iscret ion i n whether to issue an NPDES permit when only clean stormwater i s being discharged to M i l l Creek, An impervious cap wi th discharge of the untreated but non-contaminated stormwater to M i l l Creek i s the current condit ion in the two acre project the Washington DOE constructed on the s i t e l a s t f a l l . While the capital costs are higher than the on-s i te and o f f - s i t e treatment a l ternat ives, the O&M costs are s ign i f i can t lower. Since subsurface cleanup i s planned for next year, these higher capi to l costs are not j u s t i f i e d .

From a public health and environmental protect ion consideration, the three alternat ives described above would have s imi la r impacts. None of the three would have s ign i f i can t adverse Impacts. Al l three would reduce the environmental and public health and welfare Impacts of the Western Processing stomi water. A l l three would take advantage of a s i t e now cleared of surface obstructions while minimizing the discharge of hazardous substances t o both surface and subsurface water.

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The no action and the discharge only through percolation and evaporation alternatives are very similar. The central and southern portions of the s i t e currently discharge only through percolation and evaporation. The primary difference between these two alternative i s how water will be dealt with in the north end of the s i t e , the amount of on-site storage which could be available, and the permeability under any new potential pond areas.

The no action and the discharge only through percolation and evaporation would also have similar public health, welfare and environmental impacts. The continued ponded of water on the s i t e will continue to r e s t r i c t investigations and future subsurface clean-up of the s i t e , Stormwater would continue to become contaminated and would continue to recharge the groundwater in the local area, and would perhaps continue to exaggerate the "mounding effect." Contaminated stormwater would continue to reach Mill Creek through seeps and springs. However both these alternatives have potentially much lower capital and O&M costs than the f i r s t three al ternat ives.

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19 C0Mr4UNITY RELATIONS

A community re lat ions program has been in place for almost a year. Both DOE and EPA take an act ive role in th is plan. The major elements have included: monthly interagency meetings with the Kent City Mayor and her s t a f f ; public presentations/ineetings whenever the c i t y or c i t y council has requested i t ; press releases at a l l major events, such as the release of data or reports, or the s ta r t of part icular on-s i te a c t i v i t i e s ; wide d is t r ibu t ion of press releases and fac t sheets; and the a v a i l a b i l i t y of government s ta f f by phone to respond to questions from the publ ic. Though public in terest was very high las t summer during the emergency removal, for the l as t eight months only a few indiv iduals and the City of Kent have evidenced the i r continued in teres t .

In early June 1984, a press release, a fact sheet, and the Focused Feas ib i l i ty Study was made available to the publ ic . Over 300 press releases and fact sheets were sent out. Over 50 copies of the Focused Feas ib i l i ty Study were sent out to indiv iduals and agencies known to be interested i n the s i t e , and s ix copies were made avai lable through the local public and EPA Regional l ib ran 'es . In addi t ion, copies were available free from EPA for the asking. The three week comment period closed on June 22, 1984.

A well-attended public meeting was held using the City of Kent's Workshop forum on June 1 1 , 1984. Besides the c i t y council and s t a f f , only four other persons spoke. Most comments addressed the speed (too slow over a l l , too fast on th is f i r s t operable un i t ) and scope (why can ' t the en t i re o f f - s i t e and subsurface clean-up be done now too) of the proposed act ion, as well as the reputation of the PRPs rumored contractor (Chemical Waste Management, I n c . ) . As of June 22, only one addit ional wr i t ten comment had been received, in which Metro c l a r i f i e d i t ' s proposed discharge requirements. No comments were received which addressed the deta i ls of the proposed action or the proposed disposal locat ions or methods, except for one person who wanted EPA to try his new glass-making idea.

Because act ive negotiations were underway, EPA d id not release any de ta i l s of the PRP's plan, except to say that the PRP plan was s imi lar in i t ' s f ina l resul t . Because the DOJ public comment period w i l l begin a f te r the PRPs I n i t i a t e the clean-up, the PRPs are taking the i n i t i a t i v e to set up small meetings wi th interested indiv iduals and organizations. Most of these meetings are scheduled for the week of June 25. .

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CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS

The alternat ives described above w i l l comply wi th a l l Federal, State and local laws and regulations. Environmental laws which could apply to th is action include:

RCRA. This program has been delegated to the State of Washington, On-site ac t i v i t i es w i l l comply wi th state regulations. DOE expects to have a representative on-si te a t a l l times to ensure compliance.

Of f -s i te disposal of hazardous and dangerous waste w i l l have to occur out-of-state. The nearest f a c i l i t y which can take a major i ty of the materials from the s i te i s the CSSI s i te in Ar l ington, Oregon. The Oregon Department of Environmental Quality has been delegated interim authorization under RCRA. DEQ's l a s t inspection of the Arlington f a c i l i t y was on Hay 30, 1984. No v io lat ions of state l icence conditions were noted by the State. EPA i s current ly reviewing the f a c i l i t y ' s Part B application.

The cost of proving that a par t icu lar waste i s not hazardous under federal or state regulations (or of cleaning the waste and then proving i t i s not hazardous) i s often higher than disposal at a hazardous waste dispoal f a c i l i t y . Lower levels of proof, while then allowing additional recycling or potent ia l ly disposal a t municpal l a n d f i l l s , would probably not be publ ic ly acceptable.

TSCA. TSCA would apply to the handling and disposal of a l l PCB contaminated material s. All TSCA procedures w i l l be fol lowed.

CWA, The Clean Water Act w i l l apply to the disposal of cer ta in l iqu ids on the s i t e , the disposal of the ponded stormwater on the s i t e , and the disposal of stormwater af ter the s i t e is cleared. The al ternat ives for the disposal of the l iqu ids on the s i te and the already ponded water are ei ther to t rea t the water on s i t e or to take the l iqu ids o f f - s i t e for treatment. Both al ternat ives w i l l probably then include the discharge of the the treated water to the Metro sewers and sewage treatment plants or other state waters. Al l requirements of the Metro pre-treatment permit or State NPDES permit w i l l be met.

The Clean Water Act w i l l also come in to play with the disposal of stormwater a f ter the s i te i s cleared. I f the s i t e i s graded and then covered with a clean and impermeable layer, the water may be discharged to Mi l l Creek as clean storm water, much as the water from the DOE paved port ion is current ly being discharged. The NPDES permit program Is delegated to DOE. I f the s i t e i s not covered (or i f a part icular drainage basin of the s i t e i s not covered) th i s water w i l l e i ther be ponded on the s i t e or col lected for treatment pr ior to discharge to Metro or surface water i n compliance with the any Metro pre-treatment requirements or State NPDES permit.

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RECOMt€NDED ALTERNATIVE

The recommended al ternat ive i s cos t -e f fec t ive , i . e . the lowest cost a l ternat ive that i s tedinological ly feasib le and re l iab le and which e f fec t ive ly mit igates and minimizes the damage t o , and provides adequate protection o f , public heal th, welfare or the environment. In th is case, cost effectiveness includes the concept of being cost-ef fect ive for the overal l s i t e clean-up, not j u s t the costs of th is stage.

The recommended al ternat ive i s to fo l low the PRPs proposed plan. The main elements of th is plan include:

1. Site preparation to provide fo r support and decontamination f a c i l i t i e s .

2. Characterize a l l materials i den t i f i ed for removal,

3. Removal of a l l bulk l i q u i d s , drummed l i q u i d s , and waste p i les to a permitted o f f - s i t e f a c i l i t y . Negotiations among the PRPs may resul t i n a large portion of the "synfuel s" being incinerated in a cement k i lm.

4. Removal and proper disposal of a l l transformers and substation equipment. Proper disposal w i l l depend on the PCB levels in the transformers.

5. Demolition and removal of a l l on-si te bui ldings.

6. Dismantling of a l l on-s i te bulk storage tanks. I f tanks are determined to be s t ruc tura l ly sound, such tanks w i l l be thoroughly cleaned and sold for scrap metal .

7. A l l other surface debris w i l l be removed and disposed.

8. Stormwater w i l l be contro l led and treated pr ior to discharge before, dur ing, and af ter the surface clean-up. After i n i t i a l pond removal, an on-s i te treatment plant w i l l be set up and operated. The PRPs w i l l continue to handle stormwater control un t i l Apri l 1 , 1985.

The no action a l ternat ive is not acceptable, pr imari ly because i t w i l l not mit igate and minimize the damage t o , nor provide adequate protection o f , public heal th , wel fare, or the environment. I t i s also not acceptable because i t would delay f i na l s i t e clean-up by at least a year because t h i s material would have be removed before the next stage of clean-up could begin. Since surface clean-up requires an entire contruction season, there would have to be an addit ional year before sub-surface clean-up could begin. .

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The major problems with most other a l ternat ives for the wastes are both regulatory compliance ( in form or substance) and ins t i tu t iona l f e a s i b i l i t y . For example, recycling i s not feasible i f no recyclers w i l l take the material because of the i r fear of future l i a b i l i t y . Because of the local notoriety of the-s i te , proving a substance from Western Processing is not hazardous and thus lega l ly sui table to be disposed of i n a municipal l a n d f i l l i s often more expensive and less re l iab le than simply disposing of the material i n a hazardous waste l a n d f i l l .

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23.

OPERATIONS AND MAINTENANCE

O&M w i l l be necessary only for the stormwater control port ion of the project. O&M a c t i v i t i e s w i l l includes operation of the treatment p lant , and monitoring the s i te ' s berms to ensure that there i s no surface discharge. The PRPs w i l l be responsible for al 1 such O&M un t i l April 1 , 1984 or three months af ter they f i n i sh the s i te clean-up, whichever comes la te r . The PRPs are also responsible for leaving the ponds drained. Subsurface and o f f - s i t e remidial actions are planned to begin next summer, and stormwater w i l l have to managed as part of that a c t i v i t y .

E A 0 0 2 7

24.

FUTURE ACTIONS

This surface clean-up and stormwater control pro ject i s the f i r s t operable uni t of the overal l remedial act ion a t th is s i t e . The draf t RI/FS for the rest of the remedial actions (subsurface and groundwater a l ternat ives, and o f f - s i t e contamination and needs) w i l l be avai lable i n September 1984, No information i s current ly avai lable on what the possible feas ib i le al ternat ives w i l l be, but a common element in a l l scenarios previous looked at (except for the no action al ternat ive) included a complete surface clearance as a necessary f i r s t step. Tne data on the extent of o f f - s i t e contamination i s now j u s t coming i n . An extensive public comment period on th is larger , and more controversial stage, i s expected. Negotiations w i l l be continuing with the PRPs throughout the surface clear-up project , and i f necessary, in to the f a l l .

E A 0 0 2 8

0.

•4 • . Figure 1

VICINITY MAP

E A 0 0 2 9

Figure 2

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LOCATIONS OF WASTE MATERIALS. MAY 1984

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Figure 3

WESTERN PROCESSING IN OPERATION, OCTOBER 1982

E A 0 0 3 1

> I

Table 2

FOCUSED FEASABILITY STUDY POTENTIAL REMEDIAL ALTERNATIVES AND TECHNOLOGIES

Disposal Alternative

Onsite Treatment

Technologies Considered

Carbon adsorption

Air stripping

Precipitation/filtration/ clarification

Drying/dewatering

Sedimentation

Distillation

Solidification

Neutralization

Evaporation

Biological oxidation

Chemical oxidation/reduction

Rinsing/steam cleaning

Chipping/crushing

Licjuid/liquid extraction

Encapsulation

Sludge conditioning (e.g., with fly ash)

2. Offsite Treatment

3. Nonhazardous Waste Landfill

4. Hazardous Waste Landfill

Same potential technologies as for onsite treatment

Repackaging and/or onsite or offsite treatment may be required.

Partial solidification of liquids and/or repackaging may be required.

EA0032

\ t ' V t

Disposal Alternative

5. Discharge to Metro

6. Discharge to Mill Creek

7. Incineration/Fuel Source

8. Recycle or reuse

9. Detonation

10. Containment

11. Return to Manufacturer

12. Release to Responsible Party

13. No action

Technologies Considered

Onsite or offsite pretreatment may be required. See the technologies for onsite treatment above.

Onsite pretreatment will likely be required to meet discharge limitations. See the technologies for onsite treatment above.

Hog fuel boiler (wood) Cement kiln Hazardous waste incinerator

(e.g., at-sea incinerator) Industrial boilers (oil fired)

Onsite portable boiler

Steam clean onsite; cut, crush, chip, onsite; repackage onsite; salvage, sell, give away.

Solidification, burial, crushing, chipping

EA0033

WESTERN PROCESSING SURFACE aEARANCE PROJECT

A,

Waste Typa

Oorroslve l i q u i d s

Current Est imatedQuant i ty

202,966 gal Ions

DI tposa l

Mast L I ka l y A l t e r n a t i v e s

Onsite t rsa t tnant and d ischarge t o f tot ro

Haul t o o f f s i t e t r e a t n a n t f a c i l i t y

A l t e r n a t l ' o s

I B S S L I K a l / , bot s t i l l Feas ib le A l t e rna t lN«s

Haul t o hazardous waste l a n d f i l l

PO o o <

B. Sludge from o o r r o s l \ « tanks 20,190 ga l l ons Haul t o hazardous waste l a n d f i l l S o l i d i f y and haul

l a n d f i l l

t o hazardous waste

C. Isopropy l a losho l m ix tu re Unknown Onsite t rea tmentt o Mstro

and discharge Haul t o hazardous waste l a n d f i l l

D, Flue dust 2,900 cub ic yards Haul t o hazardous waste

Onsite use In f i n a l s i t e

l a n d f i l l

c losure

Onsite use as s o l i d i f i c a t i o n agen t ,

haul t o hazardous waste l a n d f i l l

(Please t o genera tor o f waste cr

E. Ba t t e r y ch ips 2,100 cub ic yards O f f s i t e r e c y c l e / r e c l a i m Haul t o hazardous waste l a n d f i l l CO

Fto lease t o {pna ra to r o f waste

F. Z inc ox lcb 129 tons Haul t o hazardous waste l a n d f i l l

6 . Foaming agent 2,690 gal Ions Haul t o hazardous waste l a n d f i l l r e t u r n t o manufacturer

Rs lease t o generator o f waste

H. Vbod p a l l e t s 80 tons Haul t o hazardsus waste l a n d f i l l

I , P r i n t i n g i nks ,

ahd greases

t a r s , o i l s , 20,300 ga l l ons Maul to hazardous waste l a n d f i l l re lease t o generator

i

o f waste

J , T i res I t o n Clean and sal I /g i ve away Haul t o hazardous waste l a n d f i l l

Steam c l e a n , haul t o mun ic ipa l l a n d f i l l

K. Na i l ooatlngs^ 3.000 ga l l ons Haul t o hazardous waste l a n d f i l l

L. Unki..2ttns Unknown Haul t o hazardous waste l a n d f i l l Others, depending on c h a r a c t e r i s t i c s

^.

Waste Type

M. Transformers

N. "Syn fue l s "

I . 60-w9lght bunker o i l

2. High a rsen ic content

3. Mixed l l ( | j | d s

4 . L i q u i d s w i t h msthylene c h l o r i d e

5 . Caust ic l i q u i d s

6 . Unknowns

0 . O/psum p i le

P. F l u i d s In gypsum p i l e

0 . Slodga from bottom o f t anks

Current Est imated Quant I t y

5 t o 10 tons

87,131 ga l l ons

235,104 g a l l o n s

53,476 gal Ions

128,069 gal Ions

7,899 gal Ions

148.219 ga l l ons

10.128 cubic yards

Unknown

101,900 g a l l o n s

Disposal A l t e r n a t i v e s

Most L i k s l y A l t e r n a t i v e s Less L I k a l y , but s t i l l Feas ib le A l t e r n a t i v e s

in m o

Haul t o hazardous waste l a n d f i l l o <

O f f s i t e I n c i n e r a t i o n

Onsite o r o f f s i t e t rea tment o f l i q u i d s and recyc les cas ings

Onsite d r a i n and f l u s h . Inc ine ra te l i q u i d s , haul cas ings to municpal l a n d f i l l


Rjusa as fue l


D i l u t e and recyc le f o r pressure c reoso t l ng


F^usa as fue l


O f f s i t e t r e a t n e n t and recyc le


Iteusa

Sane as abovAs

Haul t o hazardous waste l a n d f i l l Haul t o mun ic ipa l l a n d f i l l

Onsite t rea tment and discharge Haul t o hazardous waste l a n d f i l l t o f fe t ro

O f f s i t e t rea tmant


t -"̂ .*

3.

Disposal A l t e rna t i ves

Current Estimated H>st L Ika ly A l t e rna t i ves Less L I k a l y , but s t i l l Feasible Watte Type Quant i ty A l t e rna t i ves

R. Tanks and scrap metal Unknown Ste an c l ean , s e l l whole a n d ^ ^ cut Haul t o hazardous waste l a n d f i l l and sel I as scrap o

o <

S. Boncbd water and daoon .9 a l i i Ion gal Ions Onslta t reatment and discharge Haul t o hazardous waste l a n d f i l l

water from opera t ions (p lus an a s t l n a t e d t o I totro .5 a l l I Ion ga l lons I ron cloaroncu O f f i l l u t m a t n i n t a c t i v i t i e s )

T. Honrecyclable solvents 3.690 gal lons Haul t o hazardous waste l a n d f i l l S o l i d i t y and haul t o hazardous waste l a n d f i l l

U. C rys ta l I Ized so l i ds 96.720 cubic feet Haul to hazardous waste l a n d f i l l

Others, depending on nature o f Mater ia l

V. Laboratory chealcals Unknown Haul t o hozardous waste l a n d f i l l

Explosives nust be detonated

W. F^s t l c l cbs 9 t o 7 tons Haul t o hazardous waste l a n d f i l l

X, Paint waste, varn ishes, 30,000 t o Haul t o hazardous waste l a n d f i l l and s t a i n * 90,000 ga l lons

10.000 gal lons Haul t o hazardous waste l a n d f i l l So l l d l gy and haul t o hazardous waste Y. Flammable l l t y j i ds l a n d f i l l

B.937 cubic feat Steam clean and use o n s i t e In f i n a l c losure Z. Oancrete blocks


AA. Oomol l t lon dsbr ls Unknown Haul t o hazardous waste l a n d f i l l i

Steam c lean and recyc le (metal t o o l s and equlposnt o n i y . )

Steam clean and haul t o nun lc lpa l l a n d f i l l (na ta l t o o l s and equIpnant o n l y . )

BB. Bnpty drums 6.000 druMS Haul t o hazardous waste l a n d f i l l . Haul t o hazardous waste l a n d f i l l as Is crushed ons i t e

(to cycle

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