1.1.1 Incident Category
CERCLA Time Critical Removal Action

1.1.2 Site Description
RAMCO occupied a building located within the Dallesport Industrial Park, where it extracted aluminum from dross it received from primary aluminum smelters.  Dross is a by-product from the primary smelting process, and the major constituents of dross are aluminum, aluminum oxides, mixtures of nitrides, mixtures of chlorides, and traces of other impurities.

1.1.2.2 Description of Threat
The contaminants of concern (cyanide, polycyclic aromatic hydrocarbons [PAHs], ammonia, and metals including aluminum, cobalt, copper, iron, manganese, and vanadium) are potential hazardous substances or pollutants or contaminants as defined by sections 101(14) and 101(33) of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42 U.S.C. section 9601(14) and (33).

The waste material placed in the landfill produced ammonia gas when wet.  The odor of ammonia has been detected in the past during direct push soil sampling, groundwater monitoring, and after rainfall events.

Nitrates, sodium, chloride, and total dissolved solids in groundwater have been measured at levels exceeding primary or secondary water quality standards. Because major salt-forming chemical elements (sodium, calcium, potassium) measured during groundwater sampling exceeded levels of these elements found in seawater, there is a strong indication that salts from the landfill are leaching into groundwater.

Leaching tests performed to determine whether the waste is a Dangerous Waste indicate that metals also could leach from the aluminum waste. However, groundwater monitoring thus far has not shown elevated levels of metals attributable to leaching from the landfill.

2.1.1 Narrative

8/23/10 Monday

• ERRS loaded out 31 truck loads of screened material for a total of 1033.35 tons of material transported to the Wasco County Landfill on this day.
• ERRS continued to sort through the rock stockpile (6" minus) that came from the screening plant, for K088 materials, metal (steel and aluminum dross), which were segregated into separate piles. A second ERRS crew was also separating material at the pre-screening stockpile.  The material that is being separated at the pre-screening pile came from a stockpile that was on the NW wall of the pit.  The stockpile was push up there by a previous contractor.  This material had elevated levels of ammonia, but not >25 ppm.  ERRS crew chose to be in level C respiratory protection for comfort from the ammonia and dust.
• ERRS RM escorted a vender to inspect the aluminum material for possible re-cycling.
• At mid-day ERRS screened material for several hours until the all the pre-screened material was screened that had come from the NW wall stockpile.   
• ERRS returned to moving material from the NW K088 stockpile to the pre-screening pile and separating it.  ERRS had two separating crews working.  There was some elevated ammonia levels, but no detection >25 ppm.
• USCG and START continued to monitor ambient air near the screener discharge pile and around the ERRS crews working to separate material for particulates and ammonia.
  
  8/24/10 Tuesday
    
• ERRS loaded out 18 truck loads for a daily total of 606.76 tons of non-hazardous waste from the screening plant discharge pile that was sent to the Wasco County Landfill.  The cumulative amount to date of non-regulated aluminum salt cake material transported to the Wasco County Landfill from the site is 10771.72 tons.
• ERRS continued to sort through the waste material for K088 materials and metals,(steel and aluminum dross) as it was transferred from the stockpile on the NW wall over to the pre-screening stockpile. The separation operation continued for most of the day.
• ERRS ran the screening plant intermittently during the day as the pre-screening pile would be build back up from the separation activity.  The stock pile of waste material on the NW wall was completely removed and screened by the end of the day. 
• START moved monitoring equipment around the site based upon ERRS activity to monitor for possible ammonia and particulates from the excavation of material from the NW wall, and the separtation and screening operations.  The ERRS ground crew members used level  C because of the ammonia odor.  However, the ammonia levels did not reach the action levels of >25 ppm TWA or a peak of >50 ppm.
  
  8/25/10 Wednesday
• ERRS operated the crusher for majority of the day.
• ERRS moved the screening plant so that the waste material under the screening plant could be excavated.  The excavation included material under the road going into the pit and extended up to approximately 100 yards short of the entrance fence.  Backfill was used to establish a level area for the screening plant.  The screening plant was moved back into the area. 
• USCG and START continued to monitor ambient air for particulates and ammonia.  The newly excavated area did not produce elevated levels of ammonia.