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

8/30/10 Monday

• ERRS loaded out 21 loads for a total of 685.53 tons of  non-regulated aluminum salt cake material transported to the Wasco County Landfill. 
• ERRS and the sub-contractor moved the crusher out of the removal area and staged it just outside the entrance.  The crusher was moved so the area under it could be excavated and the material pushed up into the pre-screening stockpile. 
• ERRS screened material throughout most of the afternoon.
• ERRS excavated more dross material from the bottom of the pit and at the same time excavated to visually clean soil around the pit on the east side. 
• START monitored ambient air near the base of the screening plant discharge stockpile, downwind from the pre-screening pile and excavation area just to the east of the pile.
  
  8/31/10 Tuesday
    
• ERRS loaded out 32 loads for a total of 1062.15 tons of  non-regulated aluminum salt cake material that was transported to the Wasco County Landfill. 
• ERRS ran the screening plant all day.
• ERRS continued to sort through the rock stockpile being produced by the screening for K088 materials and metals,(steel and aluminum dross). 
• START monitored ambient air for particulates and ammonia near the screened discharge stockpile and downwind of the rock separation operations.  The ammonia content inside the boxes of two loaded trucks were taken to confirm that the trucks were not leaving the site with elevated ammonia > 25 ppm. 
  
  9/1/10 Wednesday
•  ERRS loaded out 26 truck loads for a total of 851.44 tons of  non-regulated aluminum salt cake material that was transported to the Wasco County Landfill. The cumulative tonnage to date removed from this site is 15172.41 tons. 
• On the east end of the pit, ERRS excavated down to the bottom of the pit and found river rock that was level under the dross. The dross material was pushed up into the pre-screening area to be screened. 
• ERRS excavated material, moving from the east end of the pit towards the screening plant, cleaning the walls of the pit as they moved back towards the screening plant. 
• ERRS worked from the dross material while visually cleaning the wall and bottom of the pit.
• 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 of the screening discharge pile from material freshly screened in the morning.  Ammonia levels dropped down as the material gets aerated during the screening process.