United States Environmental Protection Agency
Region X
POLLUTION REPORT

Subject: 

See Polrep # 2 for Site Description for this Phase II Removal Action.

One EPA OSC, 6 ERRS personnel, 1 USCG PST, and 2 START personnel conducted the following activities:

1. ERRS continued to excavate PCP-contaminated soils from specific areas of the site.  Overall, the rate of excavation slowed down as EPA either achieved cleanup goals or approached the groundwater level.  Most of the excavation performed this period were of specific “hot-spots” where previous confirmation sampling and testing indicated that small areas of contamination remained.
2. START continued to collect soil samples from the excavated areas for on-site field testing and off-site laboratory analyses.  The data obtained from these analyses are being used to determine the extent of contamination in the excavated areas and to sort the contaminated soils into warm (between 8 and 74 mg/kg) and hot (greater than 74 mg/kg) soil stockpiles.
3. ERRS began to load trucks for off-site disposal of contaminated soil.  During this reporting period, a total of 50 truck-and-pup combinations left the site with hot soil for the Waste Management RCRA Subtitle C facility in Arlington, Oregon.  A total of approximately 1651 tons of soil was sent off-site through November 4.  
4. ERRS continued to use oil skimmers to recover free product (diesel / PCP) from groundwater in test pits in the bottom of the main excavation area.  Skimming operations ceased on October 31 with 6 drums (approximately 300 gallons) of product recovered.  
5. ERRS began to backfill excavated areas of the site, including the main excavation pit, the drainage area, and the railroad right of way area.  
6. An ERT hydrologist visited the site to help plan for additional monitoring wells and surface water gages to be installed following the soil excavation phase of the removal, as part of a planned groundwater model that will be prepared for the site.  The ERT hydrologist also assisted EPA with delineation of the product plume and the design of the product recovery system.    
7. ERT, ERRS, and START continued to work on the design of a product recovery system and began installation in and near the product plume area in the main excavation pit.
8. Region 10 OSC Kathy Parker visited the site to perform a QA audit.

1. Excavation of hot and warm soils, guided by field analytical results determined with PCP field test kits.
2. Excavation of PCP/Diesel-contaminated smear zone at bottom of excavations just above product floating on groundwater.
3. Finish design of a product-recovery system to address product floating on groundwater and begin installation.
4. Continue hot soil transportation and disposal and start warm soil transportation and disposal the week of November 6.
5. Soil covering and hydro-seeding of North Stockpile Area is anticipated to start November 16.
6. Additional monitoring wells to aid in the completion of groundwater modeling will be installed starting November 27, 2006.

1. Finalize the excavation of hot and warm soils from the site.
2. Continue to backfill excavated areas.
3. Continue installation of the product-recovery system to address product floating on groundwater.
4. Continue to send hot (> 74 mg/kg) contaminated soil off site for proper disposal.
5. Start transportation and disposal of warm soil (between 8 and 74 mg/kg).

1. Analytical data obtained for the stockpiled soils indicated higher concentrations of individual dioxins/furans than anticipated, which initially indicated that incineration was required for the contaminated soils.  The OSC continued to consult with the EPA RCRA program and the disposal facilities to determine how to treat and dispose of the hot and warm soils and meet the land disposal restrictions.  During the current reporting period, Waste Management agreed to accept the hot soil for treatment, while a determination for direct landfilling of the warm soils continues.  
2. EPA has decided to modify the design requirements for a recovery system to address free product only, rather than being a combined product/groundwater system.  The performance of the system will be evaluated throughout the winter.  If appropriate, the system can be upgraded in the spring to incorporate a groundwater control component.

1.  50 truck-and-pup combinations transported 1,651 tons of hot (>74 mg/kg PCP) soil off site to Waste Management in Arlington, Oregon for disposal during this reporting period.
2.  6 drums of product, recovered from test pits in excavation pit, were transported off site to Clean Harbors on November 1, 2006.
3.  5 drums of PCP sludge, removed from the treatment building prior to demolition, were transported off site to Clean Harbors for incineration on November 1, 2006.