DEPARTMENT OF ECOLOGY

April 29, 1993

TO:

FROM:

Elizabeth McManus

Ecology Solid and Hazardous Waste

Michael J. Spencer

Toxics Cleanup prog~~

SUBJECT: Site Files

I am transmitting to you, at the request of Carol Kraege, site

files for the following ten sites:

Evergreen Products

Georgia Pacific Corporation

Griffey Cleaners

J.H. Baxter and Co., Inc.

Kaiser Aluminum and Chemical Corp.

Maralco Aluminum

Richardson Airways, Inc.

Silicon Metaltech Lab. Site

Walla Walla Farmers Coop

Weyerhauser Box Plant

These have been scored and ranked using the Washington Ranking

Method, and were chosen by Carol and Steve Robb as representative

of the types of sites in which you are interested. Please return

them to me when you have completed your scoring/ranking. You can

contact me at 5-3058 if you have any questions.

MJS:ms

Attachments

cc: Carol Kraege, TCP

Steve Robb, TCP
DEPARTMENT OF ECOLOGY

May 19, 1993

TO: Michael J. Spencer, Toxies Cleanup Program

FROM: N~McManus, Solid and Hazardous Waste Program

SUBJECf: WARM/ten-CAPS comparison

Attached please find the ten-CAPS ranking sheets for eight of the ten sites for which you

provided me files, specifically:

Georgia Pacific Corporation

Griffey Cleaners

J.H. Baxter and Co., Inc.

Kaiser Aluminum and Chemical Corp.

Maralco Aluminum

Richardson Airways, inc.

Silicon Metaltech Lab. Site

Weyerhauser Box Plant

Time constraints have precluded me from ranking all ten sites. I hope the data from

comparison of rankings at eight sites will be sufficient.

As you know, the Solid and Hazardous Waste Program hopes to use this comparison of

rankings to support conversion of ten-CAPS high, medium, low rankings to numerical

WARM rankings of 1, 3, and 5 respectively. Alternatively, numerical ten-CAPS rankings of

o- 30 could be converted to WARM rankings of 1 - 5, where a ten-CAPS ranking of 30

. would be converted to aWARM ranking of 1, a ten-CAPS ranking of 25 to a WARM

ranking of 2, and so on.

Please notify me of your findings regarding this ranking comparison as soon as possible. It

will help the Solid and Hazardous Waste Program's corrective action authorization

application if you could notify me of your findings in writing.

Thank you for your assistance in development of the alternative authorities initiative and this

ranking comparison project. Please contact me at 493-9506 if you have any questions.

EM:sI

Attachments

cc: Tom Loranger

Howard Steeley

o

o

o
Facility Name: Richardson Airways Inc.

Date: May 17, 1993

Facility ID Number: none provided

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent of Contamination

10 points

10 points

5 points

Aerial pesticide applicator. Some rinsed pesticide containers were dumped

into a 12 foot diameter pit and burned. Residual solutions of pesticides

from aerial spray tanks were drained onto a 5 by 40 foot section of ground.

Analysis of samples collected at the spray dumping area indicated Ethyl

Parathion (Parathion) and Methyl Parathion present in surface samples. At

the surface concentrations of Ethyl Parathion were determined to be 19,262

ppm; Methyl Parathion 573 ppm. At a depth of one foot, concentrations of

Ethyl Parathion were determined to be 8.2 ppm; Methyl Parathion .006

ppm. At a depth of two feet, concentrations of Ethyl Parathion were

determined to be 2.2 ppm; Methyl Parathion was not detected. Ethyl

Parathion was also detected in a background sample taken at a depth of 1

foot, concentration .06 ppm. No groundwater monitoring has been

conducted. Given the information on disposal practices, Parathion and

Methyl Parathion may meet the criteria for listed hazardous wastes P089

and P071. Surface levels of Parathion and Methyl Parathion in soil exceed

the MTCA cleanup levels (from Method B Formula Values) of 480 ppm

and 20 ppm respectively.

Category 2: Toxicity of Known or Suspected Releases

Constituents of concern, Parathion and Methyl Parathion have human toxic

factors 100 and 10,000 respectively from the hazardous substances factors

table for CERClA Section 305 hazardous substances.

Category 3: Facility Setting

Both disposal areas are within 500 feet of Bachelor creek. Constituen-ts of

concern are present at the surface.

Total Points Categories 1-3: 25 out of a possible 30.

Priority Assigned: High
Facility Name: Richardson Airways Inc.

Date: May 17, 1993

Facility ID Number: none provided

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for 0

discussion purposes only.

Category 1: Extent of Contamination

10 points

10 points

5 points

Aerial pesticide applicator. Some rinsed pesticide containers were dumped

into a 12 foot diameter pit and burned. Residual solutions of pesticides

from aerial spray tanks were drained onto a 5 by 40 foot section of ground.

Analysis of samples collected at the spray dumping area indicated Ethyl

Parathion (Parathion) and Methyl Parathion present in surface samples. At

the surface concentrations of Ethyl Parathion were determined to be 19,262

ppm; Methyl Parathion 573 ppm. At a depth of one foot, concentrations of

Ethyl Parathion were determined to be 8.2 ppm; Methyl Parathion .006

ppm. At a depth of two feet, concentrations of Ethyl Parathion were

determined to be 2.2 ppm; Methyl Parathion was not detected. Ethyl

Parathion was also detected in a background sample taken at a depth of 1

foot, concentration .06 ppm. No groundwater monitoring has been

conducted. Given the information on disposal practices, Parathion and

Methyl Parathion may meet the criteria for listed hazardous wastes P089

and P07l. Surface levels of Parathion and Methyl Parathion in soil exceed

the MTCA cleanup levels (from Method B Formula Values) of 480 ppm

and 20 ppm respectively.

Category 2: Toxicity of Known or Suspected Releases

Constituents of concern, Parathion and Methyl Parathion have human toxic

factors 100 and 10,000 respectively from the hazardous substances factors

table for CERCLA Section 305 hazardous substances.

Category 3: Facility Setting

Both disposal areas are within 500 feet of Bachelor creek. Constituents of

concern are present in the subsurface and in groundwater. Facilityis

located approximately 400 feet east of Long Lake, and underlain by highly

permeable, sandy soils. The facility is surrounded by primarily residential

usage, with the nearest private drinking well located within .25 miles of the

site. Currently, the site is paved and access is controlled by a fence.

o

Total Points Categories 1-3: 25 out of a possible 30.

Priority Assigned: High

o
Facility Name: Silicon Metaltech Inc. Lab Site

Facility m Number: none provided

Date: May 13, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent of Contamination

5 points

10 points

opoints

Silicon Metaltech is an active silicon smelting plan. When the former

quality control laboratory building was razed mercury contaminated soils

were discovered. The bulk of the soils were removed and placed in plasticlined crates and stored outside. An unknown amount of contaminated soil

remains in the subsurface.

Category 2: Toxicity of Known or Suspected Releases

Constituent of concern, mercury, has a human toxic factor of 10,000 from

the hazardous substances factors table for CERCIA Section 305 hazardous

substances.

Category 3: Facility Setting

Site is in an industrial area. Excavated soils are contained. Constituents of

concern are present in the subsurface.

Total Points Categories 1-3: 15 out of a possible 30.

Priority Assigned: Medium
Facility Name: Kaiser Aluminum and Chemical Corp.

Facillty ID Number: none provided

Date: May 11, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent or Contamination

o

10 points

10 points

10 points

Extensive surficial contamination due to historic, unrestricted on-site land

disposal of 'wet scrubber sludge". Approximate quantity of sludge land

disposed, 64,000 yd' in three general disposal areas. Disposal occurred

from the 19505 to 1974. Releases to soil have been documented. Some

potential for contaminant migration to shallow groundwater. Potential for

migration to adjacent surface water through surficial run-off and/or

groundwater discharge.

Category 2: Toxicity or Known or Suspected Releases

Constituents of concern are PAHs, specifically, Benzo(a)antheracene,

Chrysene, Benzo(b)fluorantene, Benzo(k)fluoranthene, Benzo(a)pyrene,

Indeno(123ed)pyrene, Flouranthene, Pyrene, Benzo(ghi)perylene.

Documented by facility conducted sampling as present in the wet scrubber

sludge and levels sufficient to cause the sludge to fail the Washington state

dangerous waste designation test for persistence. Benzo(a)pyrene "has a

human toxic factor of 10,000 from hazardous substances factors table for

CERCLA Section 305 hazardous substances.

Category 3: Facility Setting

Material of concern, 'wet scrubber sludge" is present at the surface. Public

access to the area is unrestricted resulting in documented direct contact

exposure to citizens. Additionally, exposure to facility workers and 'nearby

residential populations via contaminated windblown dusts has been

documented at levels of concern (according to facility estimations of 2 x 10"'

excess cancer risk to facility workers under average conditions, 1 x lO-s

excess cancer risk to facility workers under "plausible maximum

exposures").

o

Total Points Categories 1-3: 30 out of a possible 30.

Priority Assigned: High

o
Facility Name: Griffey Cleaners, Vancouver

Facility ID Number: none provided

Date: May 11, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent or Contamination

5 points

10 points

5 points

Facility discharged spent stoddard solvent to an underground drum for

"many years" ending approximately 1990 when the drum was pumped out

(30 gallons spent solvent recovered) and removed. According to

information provided by the facility, a temporary liner and pea gravel have

been placed at the site of the excavated drum. Analysis of subsurface soil

samples has documented the presence of acetone (estimated at 7000 ppb),

chlorobenzene (estimated at 6500 ppb), ethylbenzene (at 6300 ppb),

toluene (at 18000 ppb), and xylene (at 49000 ppb), at levels below the state

cleanup formula values (MTCA Method B formula values from Cleanup

standards database). Groundwater quality has not been assessed, however,

groundwater in nearby wells is encountered at 50 to 100 feet BGS. Site

soils are lauren gravelly loam, and believed to be hydraulically connected to

the underlying aquifer. Since contamination exists only in the subsurface,

exposure by direct contact is not likely.

Category 2: Toxicity or Known or Suspected Releases

Constituents of concern, acetone, chlorobenzene, ethylbenzene, toluene,

and xylene, have human toxic factors of 10 to 100 from the hazardous

substances factors table for CERClA Section 305 hazardous substances.

Category 3: Facility Setting

Constituents of concern are present in the subsurface and have potential to

impact groundwater in the large underlying aquifer. Groundwater from the

underlying aquifer is used as a drinking water source, with greater than

65,000 people served by drinking water wells located within two miles of

the site.

Total Points Categories 1-3: 20 out of a possible 30.

Priority Assigned: Medium
Facility Name: Georgia Pacific Corp. Bellingham

Facility ID Number: WAC 00925 2297

Date: May 11, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent of Contamination

o

10 points

10 points

10 points

From 1970 to 1976 the facility discharged mercury containing wastes to an

on-site unlined pond. In July, 1976 1,500,000 gallons of mercury sludge was

removed from the pond, solidified (solidification process utilized 2.4%

sodium silicate by volume and 1.7% portland cement by volume) and

placed in an unlined on-site "landfill". The mercury sludge contained 1.3

ppm leachable mercury using the old EP TOX leach test (1766 ppm total

mercury) and was considered listed hazardous waste K071 and K106. After

removal of the mercury sludge, the old sludge pond was filled with soils.

An unknown quantity of mercury contaminated soil was left in place at the

old sludge pond. It is possible mercury contamination is leaching to

Bellingham Bay, elevated levels of mercury have been documented in Bay

sediments.

Category 2: Toxicity of Known or Suspected Releases

Constituent of concern is mercury which has a human toxic factor of 10,000

from the hazardous substances factors table for CERClA Section 305

hazardous substances.

Category 3: Facility Setting

The facility is located adjacent to Bellingham Bay. It is that mercury_

contamination is leaching to groundwater and via groundwater to

Bellingham Bay from the landfilled solidified mercury sludge and from the

old mercury sludge pond. Groundwater occurs at approximately 20 feet

BGS. Bellingham Bay is used for fishing and shellfishing.

o

Total Points Categories 1-3: 30 out of a possible 30.

Priority Assigned: High

o
Facility Name: Weyerhauser Box Plant

Facility ill Number: none provided

Date: May 13, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent of Contamination

5 points

10 points

5 points

Facility discharged wastewater containing lead to two on-site drainfields

from approximately 1974 to 1979. The old drainfield was used from 1961

to 1974, and received high lead wastewater for one year. The NW

drainfield was used from 1975 to 1980 and received high lead wastewater

for five years. In 1980 the company switched to a product with lower lead

levels. Wastewaters containing lower levels of lead are currently discharged

to a new on-site drainfield. According to facility reports, analysis of

groundwater from four on-site monitoring wells around the NW drainfield

demonstrated lead levels of up to 35 ppb in wells downgradiant from the

drainfield compared to < 2 ppb in the upgradiant well. Analysis of soils in

the NW drainfield indicate lead present at up to 3020 ppm. Lead levels in

groundwater are below Federal drinking water standards (50 ppb) but

above state groundwater cleanup levels (5 ppb, MTCA method A table

value).

Category 2: Toxicity or Known or Suspected Releases

Constituent of concern, lead, has a human toxic factor of 10,000 from the

hazardous substances factors table for CERClA Section 305 hazardous

substances.

Category 3: Facility Setting

Constituents of concern are present in the subsurface and in groundwater,

Facility is located approximately 400 feet east of Long Lake, and underlain

by highly permeable, sandy soils. The facility is surrounded by primarily

residential usage, with the nearest private drinking well located within .25

miles of the site. Currently, the site is paved and access is controlled by a

fence.

Total Points Categories 1-3: 20 out of a possible 30.

Priority Assigned: Medium
Facility Name: JH Baxter and Company

Facility ill Number: none provided

Date: May 11, 1993

Ranked by: Elizabeth McManus (WOO)

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent of Contamination

o

10 points

10 points

10 points

Field screening for pentachlorophenol and phoychlorinated aromatic

hydrocarbons (PAHs) in surface soils detected pentachlorophenol in 57 of

59 samples ranging in concentration from 260 ppb to 380,000 ppb. PAHs

were also detected in 57 of 59 samples in concentrations ranging from 50

ppb to 19,000 ppb. Pentachlorophenol contamination of groundwater has

been documented in concentrations ranging from 1,386 ppb to 399 ppb.

Sediment sampling from an abandoned on-site lagoon (formerly used as a

butt dip tank for pole treating) indicated pentachlorophenol present at

111,185 ppb. Discharge to Lake Washington' has been documented through

analysis of lake sediment samples. '

Category 2: Toxicity of Known or Suspected Releases

Constituent of concern, pentachlorophenol has a human toxic factor of 100 0

from the hazardous substances factors table for CERCIA Section 305

hazardous substances.

Category 3: Facility Setting

Constituents of concern are present at the surface and in groundwater.

Facility is located adjacent to Lake Washington and is trinsected by at least

one unnamed seasonal stream. Facility is located over deposits from May

creek, which discharges to Lake Washington less than .5 miles south of the

site, and shallow groundwater is likely in hydraulic continuity with the lake.

Total Points Categories 1-3: 30 out of a possible 30.

Priority Assigned: High

o
Facility Name: Maralco Aluminum

Date: May 11, 1993

(WOO)

Facility ID Number: none provided

Ranked by: Elizabeth McManus

Site ranking is according to the Region X Corrective Action Priority Ranking System, for

discussion purposes only.

Category 1: Extent oC Contamination

10 points

10 points

5 points

Site is an abandoned aluminum refining/recycling facility. Piles of refining

wastes, including black dross, KBI dross, aluminum oxide and baghouse

dust are located on-site. Wastes are characterized by antimony

concentrations ranging from 2.9 to 107 ppm, chromium concentrations from

21 to 975 ppm, copper concentrations ranging from 198 to 27,800 ppm,

lead concentrations ranging from 2441 to 861 ppm nickel concentrations

ranging from 15 to 438 ppm and zinc concentrations ranging from 1760 to

16,500 ppm. Waste piles are located next to a seasonal creek, which flows

from September to early June. Analysis of sediment samples collected

from the creek indicate antimony present at up to 3.2 ppm, arsenic at up to

19 ppm, cadmium at up to 4.5 ppm, chromium at up to 232 ppm, copper at

up to 1,500 ppm, lead at up to 144 ppm, nickel at up to 74 ppm and zinc at

up to 1,300 ppm. A 96-hour fish toxicity test conducted on an undiluted

sample of surface water collected from the creek adjacent to the black

dross pile resulted in a fish mortality rate of 100% (sufficient to qualify as a

Washington state dangerous waste for fish-toxicity).

Category 2: Toxicity of Known or Suspected Releases

Constituents of concern, antimony, arsenic, cadmium, chromium, copper,

lead, nickel and zinc, have human health toxicity factors of 10,000 from the

hazardous substances factors table for CERCLA Section 305 hazardous

substances.

Category 3: Facility Setting

The facility is located in an industrial area approximately 2 miles north of

the city of Kent. A resident/caretaker lives at the facility, the residence

receives drinking water through the city of Kent water system. The facility

is trisects by a seasonal creek which flows intermittently from September to

early June..

Total Points Categories 1-3: 25 out of a possible 30.

Priority Assigned: High
DEPARTMENT OF ECOLOGY

June 4, 1993 o

TO:

FROM:

Elizabeth McManus

Solid and Hazardous waste Program

Michael J. Spencer 11\) b

Toxics Cleanup progr~

SUBJECT: WARM/Ten-CAPS Ranking Comparison

I received back from you ten-CAPS ranking sheets for eight of the

ten sites for which I had earlier provided Washington Ranking

Method (WARM) scoring files. As shown in the following summary

table, there is not a perfect correlation between the rankings

achieved under WARM, versus those by ten-CAPS:

Total Priority! priority/

WARM Ten-CAPS Ranking Ranking

site name Rank Points Assigned-l Assigned-2

Georgia Pacific Corp. 5 30 High = 1 30 = 1

Griffey Cleaners 5 20 Medium = 3 20 = 3

J.H. Baxter and Co., Inc. 1 30 High = 1 30 = 1 0

Kaiser Alum./Chem. Corp. 4 30 High = 1 30 = 1

Maralco Aluminum 2 25 . High = 1 25 = 2

Richardson Airways Inc. 2 25 High = 1 25 = 2

Silicon Metaltech Lab. site 5 15 Medium = 3 15 = 4

Weyerhauser Box Plant 3 20 Medium = 3 20 = 3

However, several key points can be drawn, even from this rather

small number of sites being compared (you will recall that these

were chosen by Carol Kraege and Steve Robb as representative of

the types of sites in which you are interested): --

• There was a much better discrimination of ten-CAPS

rankings, resulting in a somewhat better agreement with

the associated WARM rank, when the ranking was achieved

through the scale of 30 points = a rank of 1, 25 points

= a 2, 20 points = a 3, etc., than using

high/medium/low equaling a rank of 1/3/5, respectively.

• The ten-CAPS ranking appear to be more conservative

than the WARM, in that the rankings were always equal

to the associated WARM rank, or "higher" - never the

o
opposite. The attached'sketch-figure illustrates this

more graphically.

• The reasons for the divergences from the ideal fit lie,

I think, in the apparent conservativeness of ten-CAPS

versus the more relative nature of WARM rankings, where

the final rank is dependent upon the total number of

applicable migration routes (surface water, air, ground

water) and. their associated pathways (human health,

environmental), along with the quintile placements of

their calculated scores.

Time does not allow me presently to look at each of the

divergences to determine what exactly was the reason, if any?,

that they did not correspond - or even to double check the ones

which did agree to see if they really should have, or if it were

just coincidence. I do think, though, that these initial results

are encouraging and can be built on with rankings of more sites.

Please contact me at 438-3058 for any comments/questions you may

have about these comparisons, and the specifics of any further,

more in-depth, analysis of the data to date which you may .

wish/require.

MS/mjs

Attachment

cc: Carol Kraege, Toxics Cleanup Program

Steve Robb, TCP
') H',&", ~:'-, l.uw :0-

fIJIr-

.. ,.,../

. "<.

) ~~/

~e.t./ c- /.

C

'\L

/

/

3

3

/'

••

/

\ t,

/

/

.f ..

•

•

"