Oregon

Oregon Theodore R. Kuiougoski, Governor Department of Environmental Quality Northwest Region 2020 SW Fourth Avenue Portland, OR 97201 (503) 229-5263 FAX (503) 229-6899 TTY (503) 229-5471 May 31,2007 United States Coast Guard 915 Second Ave. Seattle, WA 98174-1067 Attn: Rear Admiral Richard R. Houck Commander 13th Coast Guard District Re: McCormick & Baxter Creosoting Company Superfund Site Request for Establishment of Regulated Navigation Area Dear Rear Admiral Houck: The Oregon Department of Environmental Quality (DEQ) requests the establishment of a Regulated Navigation Area (RNA) at the McCormick & Baxter Creosoting Company Superfund Site (Site) located on the Willamette River at River Mile 7 in Portland, Oregon. This request is pursuant to the Code of Federal Regulations Title 33, Part 165. The proposed RNA is to be used to preserve the integrity of the engineered cap placed over contaminated sediments as part of an Environmental Protection Agency (EPA) Superfund cleanup action. The engineered sediment cap is necessary to protect public health and the environment from contaminated sediments which underlie the cap. This letter proposes to prohibit activities that would cause inappropriate disturbance ofthe sediment cap, which was placed to isolate underlying contaminated sediments. The remainder of this letter provides background for this request, the purpose of the request, and information required for proposing an RNA at the Site. Site Background The Site is located on the northeast shore of the Willamette River in north Portland (Figure 1). The legal address is 6900 North Edgewater Ave., Portland, Oregon 97203, and DEQ's Environmental Cleanup Site Information (ECST) number for this site is 74. The site includes 41 acres ofland and 23 acres of sediments beneath the Willamette River (Figure 2). The McCormick & Baxter Creosoting Company operated between 1944 and 1991, treating wood products with creosote, pentachlorophenol, and inorganic (arsenic, copper, chromium, and zinc) preservative solutions. Historically, process wastewaters were discharged directly to the Willamette River, and other process wastes were dumped in several areas of the Site. Significant concentrations of wood-treating chemicals have been found in soil and groundwater at the site and in river sediments adjacent to the Site. The EPA listed the Site on the National Priorities List (NPL) in June 1994 based on information collected by DEQ between September 1990 and September 1992. The EPA also designated the DEQ as the lead agency for implementing the selected remedy while funding for remedial design and construction was primarily provided by EPA. The DEQ implemented a number of interim removal measures between 1992 and 1994, including plant demolition, sludge and soil removals, and extraction of creosote from the groundwater aquifers. The Record of Decision (ROD) was issued by EPA and DEQ in April 1996 after considering public comments on the Proposed Cleanup Plan. The remedy addressed contaminated groundwater, soil and sediment. A component of the groundwater remedy, initiated in 1994, consisted of an automated creosote extraction and groundwater treatment system. However, due to poor product recovery and high operating costs, the automated system was discontinued in late 2000. Creosote is currently being recovered by passive and manual methods. Approximately 6,200 gallons have been recovered since 1991. A contingency groundwater remedy was implemented in the summer of 2003, with the construction of a combination steel sheet pile and soil Bentonite slurry wall surrounding 18 acres. The purpose of the barrier wall is to prevent migration of creosote to the Willamette River. Implementation of the soil remedy began in March 1999 with the removal of 33,000 tons of highly contaminated soil and debris. The soil remedy was completed in September 2005 following installation of a combination impermeable/earthen cap - the impermeable portion covering the area within the subsurface barrier wall. The sediment remedy was implemented in 2004 and primarily consisted of an armored sand cap placed over 23 acres of contaminated sediment. Construction occurred during the summers of2004 and 2005. Sediment cap construction performed in 2005 followed construction work performed by the City of Portland to stabilized two high pressure sewer lines located within a one-acre portion of the sediment cap. In addition to the sand layer, an oil adsorptive material known as organophyllic clay was used in two creosote seep areas. To protect the cap from erosion, the sand and organophyllic clay were armored with a combination of rock and articulated concrete blocks. Erosional forces evaluated in designing the cap armoring layer included hydraulic-induced stresses due to river currents associated with a 500-year flood, vessel-induced propeller velocities from a tractor tug and McCormick & Baxter Creosoting Company Superfund Site Request jin' Establishment olRNA Page 2014 May3!,2007 various sized recreational boats, wind waves associated with a 100-year wind storm and vessel wakes associated with various boats including a 1Ou-foot fireboat traveling at 14 knots. These forces were evaluated for river level variations due to tidal action and flood currents. Additionally, numerical modeling was used to analyze wave transformation between deep water and the shoreline. The sediment remedy also included the regrading and capping of the riverbank with two feet of topsoil, turf reinforcement matting and herbaceous vegetation. Revegetation of the capped riverbank with native trees and shrubs took place in February 2006 after the soil had been stabilized with the native grasses planted in November 2004. Purpose of Proposed RNA The DEQ is requesting issuance of the RNA in order to prohibit activities that may damage the engineered sediment cap at the Site. Although the sediment cap is designed to withstand a variety of anticipated erosional forces, the cap is susceptible to damage, such as from propeller wash, deployment of barge spuds, deployment and dragging of anchors, and grounding oflarge vessels. If the engineered sediment cap were to be damaged by marine activities, the contaminated sediments which underlie the cap could be released to the river thereby posing an unacceptable threat to public health or the environment. Required Information Specific details, as requested in CFR Title 33 Part 165.5, related to this request are provided below: 1) Name ofperson submitting the request: Nina Deconcini, Administrator, Northwest Region, Oregon Department of Environmental Quality. 2) The location and boundaries of the RNA: See attached Table 1 and Figure 2. 3) Date, Time, and Duration that the RNA should be established: The RNA should be established as soon as possible and last in perpetuity, or until disturbance of the sediment cap is approved by DEQ. 4) Description of the activities planned for the RNA: The RNA should remain open to the public for recreational uses, except as restricted in 5) below. 5) Nature of the restrictions desired: The RNA should prohibit anchoring, spudding, dredging, laying cable, dragging, conducting salvage operations, operating commercial vessels of any size, operating recreational vessels greater than 30 feet in length, operating other vessels in excess of "no wake" speed or the minimum speed needed to maintain steerage, or any other activity which could potentially disturb the riverbed in the designated area. 6) Reason why the restrictions are desired: The proposed restrictions will help ensure the effectiveness of the engineered cap in preventing releases of hazardous substances to the WilJamette River. McCormick & Baxter Creosoting Company Superfund Site Request for Establishment of RNA Page 3 of4 May 31,2007 If you need additional information please contact Kevin Parrett, DEQ 's project manager for this site, at 503-229-6748 or parrett.kevin@de .state.or.us. Please provide Kevin Parrett documentation that this letter has been received and a status update of the rule­ making process to establish the RNA. Sincerely, Nina Deconcini , Administrator Northwest Region Oregon Department of Environmental Quality cc: Nancy Harney, U.S. Environmental Protection Agency David Neander, National Oceanic and Atmospheric Administration Cy Young, Oregon Department of State Lands Randy Henry, Oregon State Marine Board McCormick & Baxter Creosoting Company Superfund Site Request for Establishm ent o/RNA Page 4 0/4 May 31,2007 Table 1 Coordinates for McCormick & Baxter Engineered Sediment Cap Point Northing! Eastlng' 7629056.57 7628957.14 7628605.75 7628363.41 7628169.11 7627695.18 7627658.67 7627292.41 7627241.51 7626669.56 7626549.99 7626682.90 7627013.57 7627090.97 7627250.59 7627304.80 7627461.13 7627601.08 7627564.67 Longitude" 122°44' 17.62422" 122°44' 18.97704" 122°44'24.03169" 122°44'27.43847" 122°44' 30.06096" 122°44'36.84456" 122°44'37.34478" 122°44'42.61478" 122°44'43.37454" 122°44') 1.60)71" 122°44' 53.34107" 122°44' 51.53565" 122°44' 46.83608" Latitude' 45°34'33.86516 1 2 3 4 5 6 7 8 9 10 11 704062.35 703947.94 704246.27 704248.65 703971.23 704286.51 704253.47 704567.28 704680.94 705174.35 705314.21 705474.22 705341.01 705271.98 705450.94 705421.17 705613.23 705610.38 705427.30 45 u34'32.70877" 45°34'35.55704" 45°34'35.51419" 45°34'32.72293" 45°34'35.70476" 45°34'35.36866" 45°34'38.36541 " 45°34'39.47323" 45°34'44.18601" 45°34'45.53353" 45°34'47.14928" 45°34'45.92534" 45°34'45.26528" 45°34'47.07535" 45°34'46.7964 ]" 45°34'48.73486" 45°34'48.74511 " ]2 13 14 122°44'45.72127" 122°44' 43.54778" 122°44' 42.77424" 15 16 17 ]8 19 122°44'40.65207" 122°44'38.68398" 122°44'39.12422" 45°34'46.92819" Notes: 1- Coordinates in North American Datum of 1983 - 91 adj. (NAD83/91), State Plane Coordinate System (SPCS), Oregon North Zone (international feet). 2- Coordinates in NAD83/91 (feet) in degrees, minutes, and seconds format. Figure 1 McCormlc $ca kt t :60 ,Ooo . k & Site Baxter d Superfun Site Vicinity Ma~rfun d Site . & Baxter Sup Mccorml~ortland. Oregon '" Coo:-.USGS ' " 000 ctens.t SlJIV6Yi:?" ~ a ue: 1 'nl1 d'