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

8/26/10 Thursday

• ERRS loader out 25 loads for a total of 819 tons of  non-regulated aluminum salt cake material transported to the Wasco County Landfill. 
• ERRS re-positioned the screening plant and made the needed adjustments to start screening materials.  Screened until mid-afternoon.
• ERRS brought in the contractor for the crusher to complete a welding repair on the bottom plates of the feeder shaker box. 
• ERRS started crushing material at mid-afternoon and continued until the end of the 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).
• START continued to monitor ambient air near the crusher and around the ERRS crew working at the rock separating stockpile.
  
  8/27/10 Friday
    
• ERRS loader out 30 loads for a total of 981.83 tons of  non-regulated aluminum salt cake material that was transported to the Wasco County Landfill. 
• ERRS ran the crusher for a short period in the morning, but stopped and started screening material to replenish the stockpile being loaded out.   The screening plant was operated until noon.
• After lunch, ERRS operated the crusher for the rest of the day.
• ERRS continued to sort through the rock stockpile for K088 materials and metals,(steel and aluminum dross), that was produced from the screening plant operations in the morning. 
• START monitored ambient air for particulates near the screened discharge stockpile and 25 yards downwind of the rock separation operations and crusher.  START place ammonia monitoring equipment next to the screening plant. 
  
  8/28/10 Saturday
• ERRS excavated additional material in the pit area near the pre-screening pile.  The material was pushed up into the pre-screening area to be screened.
• ERRS screened for about two hours to re-plenish the screened stockpile with enough material to be loaded out on Monday.  ERRS returned to running the crusher for the rest of the day. 
•  EERS started to excavate backfill material from off the site to the east.  A 1 1/2 hoseline was used to control the dust. 
• USCG and START continued to monitor ambient air for particulates and ammonia.  The newly excavated material in the pit area did have elevated ammonia, but not >25 ppm.  There were elevated levels of ammonia peaking at 38 ppm at the base screening discharge pile.  
  
  

• The temperatures for this operational period have been in the mid to upper 80's and even as low as the 70's in the morning hours.  This reduces the concern of heat stress for ERRS's crew members.