1.1.1 Incident Category

See initial POLREP.

1.1.2 Site Description

See initial POLREP.

1.1.2.1 Location

See initial POLREP.

1.1.2.2 Description of Threat

See initial POLREP.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

See initial POLREP.

2.1.1 Narrative

2.1.2 Response Actions to Date

Week of 11 Oct: 

Continued excavation of Bays 1 through 5 with concurrent installation of shoring to support safely reaching target excavation depth of 30 feet.  Excavated soil continued to be stored in containment cells awaiting profile sampling results for disposal.  This material will be shipped off-Site for disposal beginning the week of October 23rd.  It is estimated that a total 4,000 cubic yards of contaminated soil, and 750 cubic yards of clean overburden has been excavated to date.

The new water treatment control unit was a help to treatment operations.  Due to the greater than expected quantity of groundwater needing removal from the excavated bays additional storage tanks needed to be ordered and situated on Site until it could be determined that it was safe to discharge treated water to the nearby wetland.  By Friday, 16 October the site hosted approximately seventeen full 20,000 gallon water tanks of treated water.  It is believed that the source of all the extra ground water is the area that was excavated and backfilled as part of the EPA Removal Action in 2009.  The backfill used to backfill that area has a greater capacity to retain water than does native soil and it is hydrologically connected to the new excavation area.  Lab results were received on the morning of Friday 16 October enabling the initial discharge of treated water into the wetland.

During the course of the week it was also discovered that the first three tanks of treated water had pH levels slightly higher than Oregon drinking water standards.  These tanks were treated before the original water treatment control unit was replaced and a significant portion of this water, which was used to start up the water treatment system, came from the municipal water system.  It is believed based on public advisories that City actions to address a valve failure nearby may have increased the pH of City water.  EPA contract crews treated the water to bring the pH down to within acceptable levels.  As of the end of this period an estimated 610,000 gallons of water has been treated.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

Continued excavation of contaminated subsurface soil.  Initial segregation of excavated soil based on hazard class and stockpiling for disposal.  Receive clean fill material (sand and rock).  Ongoing operational monitoring and maintenance of the groundwater treatment system.  Ongoing monitoring and maintenance of construction BMPs.  Discharge of treated water.

2.2.1.2 Next Steps

Continue to plan for and perform the ongoing activities, including close coordination with EPA Remedial Program, ODOT, Clackamas County, and OIW.

2.2.2 Issues

Amount of groundwater pumped from the excavation continues to exceed expectations.

Continued regular communication with shoring subcontractor to maintain site safety will be required.

2.5.1 Safety Officer

Site Safety meetings occur at the beginning of each work day.  No lost-time injuries have been reported.

2.5.2 Liaison Officer

2.5.3 Information Officer

1 EPA OSC

1 EPA RPM (periodic site visits)

1 START

9 ERRS