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

9/2/10 Thursday

• ERRS loaded out 30 loads for a total of 995.41 tons of  non-regulated aluminum salt cake material that was transported to the Wasco County Landfill. 
• ERRS screened material throughout most of the morning.
• ERRS excavated the remainder of material from the pit and cleaned up the walls. The ruminate of the dross was pushed up to be screened.
• ERRS continued to sort through the rock stockpile being produced by the screening for K088 materials and metals,(steel and aluminum dross). 
• ERRS decontaminated the screening plant and the radial stacker.   
• START monitored ambient air downwind from where ERRS was loading out trucks from the screening discharge stockpile for ammonia.
  
  9/3/10 Friday
    
• ERRS loaded out 22 loads for a daily total of 715 tons of  non-regulated aluminum salt cake material that was transported to the Wasco County Landfill. 
• ERRS re-positioned the crusher just inside the entrance gate to crush the remaining rock produced from the screening plant.
• 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 the screened discharge stockpile and downwind of the rock separation operations.   
  
  9/4/10 Saturday
• The cumulative tonnage to date removed from this site is 16,883 tons. 
• START continued to monitor ambient air for particulates.    
• Crusing oprations continued. 
• Rregrading continued along the Corps property perimiter to build up an access road to 3 of the site monitoring wells. 
• Continued clearing of minor debris/pockets suing hand tools along the canyon side walls.
• Hight winds ontinued with 25+ mph sustained winds.