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

9/6/10 Monday

• START continued to monitor ambient air for particulates.
• Crushing operations continued.
• Regrading continued along the Corps property perimeter to build up an access road to 3 of the site monitoring wells.
• ERRS continued to sort through the material removing K088, and aluminum metals from the non-hazardous waste stream.
  
  9/7/10 Tuesday

• START continued to monitor ambient air for particulates. 
• ERRS hand picked through the aluminum recycle pile pulling out rocks, K088, and other various materials prior to shipping 29.45 tons of recyclable Aluminum slag out.
• Crushing operations continued, and ERRS crew continue to pick K088, and metals out of the piles
• Regrading concluded along the Corps property perimeter to build up an access road to 3 of the site monitoring wells, and the original fence line was restored. 
• START sampled three surrounding bodies of water, and the Port of Klickitat's community well.  

• ERRS loaded out 26 loads for a total of 861.96 tons of non-regulated aluminum salt cake material that was transported to the Wasco County Landfill
• START continued to monitor ambient air for particulates.    
• Crushing operations continued. ERRS crew continued to sort through the piles pulling out recyclable Aluminum slag, and K088.
• ERRS crews continued to work on restoration of area, and excavation of remaining material
• START sampled three perimeter monitoring wells.

9/9/10

• Crushing operations continued, ERRS crew continue to sort through pile picking out K088, and recyclable aluminum slag.
• START continued to monitor ambient air for particulates.
• Crews working in windy conditions with gusts up to 40mph.
• To date 17744.87 tons of on Aluminum Salt-cake material have been removed from the site.
• ERRS crews continued to work on restoration of area, and excavation of remaining material 

  9/11/10