March 5, 2007 Also sent by e-mail
Mr. Ted McCall
McCall Oil and Chemical Corporation
5480 NW Front Avenue
Portland, Oregon 97210
RE: Stormwater Plan
McCall Oil Site
ECSI No. 134
Dear Mr. McCall:
The Department of Environmental Quality (DEQ) reviewed the February 2, 2007 Stormwater and Catch Basin Sediment Sampling Plan for the McCall Oil and Chemical Site and has the following comments.
General Comments
1. Since the initial stormwater evaluation at the subject site conducted between 2000-2005 as part of the Remedial Investigation (RI), the DEQ issued the Portland Harbor Joint Source Control Strategy (JSCS, 12/05) that details how the stormwater pathway should be evaluated at Portland Harbor sites. In addition, the DEQ is working together with the City of Portland Bureau of Environmental Services (BES) in evaluating the stormwater pathway at Portland Harbor sites that discharge into the City’s conveyance system; BES comments are included in this letter. Therefore, there are additional stormwater evaluation requirements and additional parties involved since the previous RI sampling activities, and the stormwater plan needs to better explain and justify the proposed sampling locations and analytes.
2. Please provide a comprehensive stormwater drainage map for the entire facility that delineates all stormwater drainage basins and shows all catch basins, piped and non-piped conveyance systems (with flow directions), and outfalls. This information and the rationale for each proposed sampling location are needed to evaluate whether sampling locations are representative of site runoff.
3. Based on: 1) the multiple types of chemicals stored, packaged, and distributed at the Brenntag facility; 2) requirements described in the JSCS and subsequent fact sheets (see: http://www.deq.state.or.us/lq/cu/nwr/PortlandHarbor/stormwater.htm, including analyses for polychlorinated biphenyls (PCBs) and phthalates at all Portland Harbor site); and 3) constituents identified in the LWG Round 2 Data Report in the Outfall 22 draft initial area of potential concern (PCBs and pesticides), the full suite of semi-volatile organics (including all phthalates), metals (including manganese, mercury, nickel, and silver) and pesticides should be added to the analyte list for stormwater and catch basin samples.
4. Please evaluate the potential for groundwater contamination to enter City storm water pipes and/or preferentially flow along more permeable backfill material. The first level of evaluation should include a comparison of seasonal groundwater elevations compared to the pipe elevations.
Specific Comments
Stormwater Sampling
5. The proposed plan includes two rounds of stormwater sampling (on page 1) instead of the four rounds prescribed in the JSCS; the plan indicates fours rounds on page 3. It is not clear how or if the existing data will be used in the stormwater evaluation considering the expanded analyte list and JSCS requirements. Considering our late start within the current rainy season, the DEQ recommends collecting samples monthly starting in March 2007 and continuing until the dry season or four sample rounds have been conducted.
6. Please conduct TSS analyses on storm water samples.
7. Evaluate potential overland stormwater flow with direct discharge to the Willamette River (i.e., over the bank; in the vicinity of GP-14, for example) in areas where surface soil constituents exceed JSCS erodible soil screening levels (PECs).
Catch Basin Sediment Sampling
8. If insufficient sediment is available in the bottom of a particular catch basin (the preferred sampling location), then a sediment sample should be collected from the catch basin filter. Pre-sampling photographs of the catch basins and filters should be taken to support this.
Reporting
9. Stormwater and sediment analytical results should be compared to appropriate JSCS screening levels, which form the basis for evaluating the need for source control actions. Analyte reporting limits should be less than the JSCS screening levels to the extent practically achieved by the lab.
Please submit a revised stormwater plan that addresses these comments by March 23, 2007 and plan to collect your first samples by the end of March. Please call me at (503) 229-5326 if you have questions.
Sincerely,
Tom Gainer, P.E.
Project Manager
Portland Harbor Section
cc: John Edwards, Anchor Environmental
Linda Scheffler, BES