RECORD OF DECISION
STORMWATER SOURCE CONTROL MEASURES
FOR THE
EVRAZ OREGON STEEL MILLS SITE PORTLAND, OREGON
Prepared By
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY Northwest Region Office
•
December 2010 TABLE OF CONTENTS
1. INTRODUCTION...... !
1.1 INTRODUCTION...... ! 1.2 SCOPE AND ROLE OF THE PROPOSED SOURCE CONTROL ACTION...... 1
2. SITE HISTORY DESCRIPTION...... 3
2.1 SITE LOCATION AND LAND USE...... 3
2.2 PHYSICAL SETTING...... 3
2.2.7 C/wnate...... ^
2.2.2 GeoloQ'/Hydrogeology...... 3
2.3 fflSTORICAL FACILITY OPERATIONS...... 3
2.4 STORMWATER SYSTEM AND ASSOCIATED MIGRATION PATHWAYS...... ^
2.5 CONTAMINANTS OF POTENTIAL CONCERN ...... 5
3. REGULATORY HISTORY...... ^
4. HAZARDOUS SUBSTANCE RELEASES...... 11
5. SOURCE CONTROL EVALUATION...... 12
5.1 NATURE AND EXTENT OF CONTAMINATION...... 12
5.2 PRIORITY FOR SOUCE CONTROL...... 12
5.3 FACTORS CONSIDERED IN DEVELOPING SOURCE CONTROL OPTIONS ...... 12
6. PEER REVIEW SUMMARY...... 13
7. SOURCE CONTROL OPTIONS...... 14
7.1 SOURCE CONTROL OBJECTIVES ...... 14
7.2 AREA TO BE ADDRESSED...... 14 7.3 SOURCE CONTROL OPTIONS CONSIDERED AND IMPLEMENTED ...... 14
7.3.1 Removal/Treaf merit...... 15
7.3.2 Prevefifirig Contact...... 16
7.3.3 Reducing Stonmvafer Flow ...... 16
7.3.4 End of Pipe Trealment...... 17
8. EVALUATION OF SOURCE CONTROL OPTIONS...... 18
8.1 EVALUATION CRITERIA...... 18
8.2 EVALUATION OF ALTERNATIVES...... 18
8.2.1 Effectivenesshi Achievmg Protection...... 18
8.2.2 Long-fei-m Reliability...... 19
8.2.3 Implemenfabilify...... 19
8.2.4 Implementation Risk...... 19
8.2.5 Reasonableness ofCost...... A9
8.2.6 TTo/^ote...... ^
9. SELECTED SOURCE CONTROL ACTION...... 21
9.1 SELECTED ACTION...... 21
9.2 DESCRIPTION OF SELECTED ACTION...... 21
9.3 LONG-TERMMANAGEMENT/MONITORING...... 22 10. PUBLIC NOTICE AND COMMENT...... 24
11. DOCUMENTATION OF SIGNIFICANT CHANGE ...... 25
12. STATUTORY DETERMINATIONS...... 26
13. SIGNATURE...... !?
14. ADMININSTRATIVE RECORD INDEX...... 28
Figures (following text) 1 Vicinity Map 2 Site Plan 3 Stormwater Basin Layout 4 Surface Soil and Catch Basin Sample Locations 5 Soil Removal Areas 6 Stormwater End-of-pipe Treatment System Layout 7 Stormwater Clarification Basin Plan View 8 Stormwater Clarification Basin Cross-Section
Tables {following figures) 1 Surface Soil Sample Results Summary 2 Catch Basin and Stormwater Sampling Summary 3 Stormwater comparison
Appendix A EOS Stormwater Pollution Control Plan
11 1. INTRODUCTION
1.1 INTRODUCTION
This document presents the selected source control measures for stormwater at the Evraz Oregon Steel (EOS) facility located at 14400 Rivergate Avenue, Portland, Oregon. The selected measures address contaminants associated with upland soils and facilities that are entrained in stormwater runoff and transported to the Lower Willamette River. Separate proposals are being developed to address erosion of contaminated bank soils and contaminated groundwater migration from the EOS facility.
The site location is shown in Figure 1. This decision was made in accordance with the Portland Harbor Joint Source Control Strategy (December 2005).
The selected source control measure is based on the administrative record for this site. A copy of the Administrative Record Index is included in Section 10. This report summarizes the more detailed information contained in the Remedial Investigation (RI), and Source Control Evaluation reports pertinent to this action that were completed by EOS under a Voluntary Agreement with the Oregon Department of Environmental Quality (DEQ) (2000).
1.2 SCOPE AND ROLE OF THE SELECTED SOURCE CONTROL ACTION
The selected source control action addresses contaminated soil entrained in stormwater runoff. Metals, polychlorinated biphenyls (PCBs), and polycyclic aromatic hydrocarbons (PAHs) are present in site soils and have been detected in catch basin solids at concentrations exceeding Portland Harbor Joint Source Control Strategy screening level values (SLVs) for river sediment. Elevated concentrations of PCBs and metals have also been detected in sediment adjacent to the site.
The selected source control action consists of the following elements:
• Removal of localized areas of contaminated soil. • Paving areas where feasible. • Best management practices implementation. • End-of-pipe treatment for the majority of stormwater leaving the facility.
The structural source control measures listed above (soil removal, paving and treatment) have been
1 implemented over the past four years while the EOS facility underwent major site renovations. This report describes the rationale for selecting these measures and their current status. Detailed descriptions of these actions are provided in the Source Control Evaluation ofStormwater (RETEC. 2006b).
DEQ is requiring EOS to evaluate the effectiveness of these measures relative to the potential for future stormwater discharges to contaminate Willamette River sediments. DEQ is also requiring EOS to evaluate the potential toxicity of the coagulant used in the stormwater treatment system. EOS is currently implementing these evaluations under DEQ-approved workplans (AECOM. 2009b. and AECOM. 201 Ob.). 2. SITE HISTORY AND DESCRIPTION
2.1 SITE LOCATION AND LAND USE
The EOS site is situated on the eastern bank of the Willamette River in the Rivergate industrial area of Portland, Oregon (Figure 1). The property consists of approximately 145 acres, with a physical address of 14400 North Rivergate Boulevard, Portland, Oregon. The site is located at approximately River Mile 2 of the Willamette River which is part of the Portland Harbor Superfund Site Study Area.
A site plan of the facility is provided in Figure 2. The EOS site is used for manufacturing steel slabs, plates, coils, and spiral weld pipe from scrap metal (historically) and purchased steel slabs (current process). The property is surrounded by other industrial manufacturing and transfer facilities to the north, east and south. Ramsey Lake and associated wetlands are located further to the east.
2.2 PHYSICAL SETTING
2.2.1 Climate
Average annual gross precipitation for the area is approximately 40 — 45 inches/year. The majority of the precipitation falls between October and March, with July being the driest month and December the wettest.
2.2.2 Geology/Hydrogeology
The area now occupied by the EOS facility is an historic floodplain between the Willamette and Columbia Rivers and is located approximately two miles upstream of the confluence of these rivers. The native deposits at the site consist of sands, silty sands and silts generally characteristic of river floodplains. The native deposits are overlain by various types of fill including dredge fill which is similar to the native deposits, slag-soil fill, and other localized fill units ranging in composition from silty sand to slag aggregate fill.
2.3 HISTORICAL FACILITY OPERATIONS
Prior to 1942, the EOS property was vacant. The historical changes in land surfaces in this area can be followed using topographic maps and aerial photographs dating back to 1929. In 1918, an island labeled as the Post Office Bar was identified offshore of the current EOS location. A large water body, Ramsey Lake, and its adjoining wetlands occupied much of the Rivergate Area. Between 1929 and 1940 the Post Office Bar appears depositional and becomes attached to the river's edge. Filling of the Rivergate Area including the EOS property began in 1942.
During the time of Port ownership (1942 to 1967) filling continued and the Port authorized Shaver Transportation and others to operate an oil sump, called the Ramsey Lake Sump, on the property. The former sump was used for the disposal of ship bilge water and other waste oils and fluids. No known industrial activities occurred at the site between the closure of the former oil sump (1960) and construction of the steel mill, which was completed in 1969.
The property was purchased by Gilmore Steel Mills (a predecessor of EOS) from the Port of Portland in 1967. Since 1969, the facility has been used for steel production and related ancillary operations. The EOS facility includes several large industrial process buildings (combination plate rolling mill, a pipe and coating mill, cut to length facility, melt shop, surface processing and maintenance), a cooling pond, office buildings, parking lots, and material processing and staging areas (Figure 2). The melt shop was idled in May 2003 and the pipe and coating mill is currently idle due to market conditions. Currently, EOS manufactures finished steel products from steel slabs.
A shear referred to as the Mosely Shear was historically located in the southeastern comer of the EOS facility. Hydraulic oil and associated PCBs were released from this facility during the early years of its operation. In April 2006 EOS conducted a removal action in this area of soil containing free-phase hydraulic oil and PCBs at concentrations that exceeded 7.5 parts per million (ppm).
2.4 STORMWATER SYSTEM AND ASSOCIATED MIGRATION PATHWAYS
Sites adjacent to a water body typically have four primary routes through which upland sources can result in contamination of the water body: direct discharge (including that from overwater activities), erosion of soil from the shoreline areas, migration of contaminants via groundwater discharge, and release of contamination associated with stormwater discharge. The focus of this source control proposal is release of contamination associated with stormwater discharge.
All stormwater from the facility either drains by sheet flow to a system of catch basins and storm sewers or percolates into unpaved ground surfaces. The storm sewers historically conveyed runoff to three outfalls. Prior to 2009, the Central Outfall 001 and Northern Outfall 003 discharged stormwater directly to the Willamette River. Flow to these outfalls is now treated and flows through a clarification basin located on the northwestern corner of the facility prior to discharge at the Northern Outfall 003. The Central Outfall 001 now is only available for use in emergency situations when the capacity of the existing system is overwhelmed and is referred to as the Central Emergency Outfall 001. The Rivergate Outfall 002 discharges stormwater to a City of Portland storm sewer located in N. Rivergate Boulevard. This sewer carries water south along N. Rivergate Blvd then westward at N. Ramsey Blvd and discharges into the Willamette River via City of Portland Outfall 53A. Flow to the Rivergate Outfall 002, with the exception of pipe mill roof runoff, is treated using sand filtration and bioswales prior to discharge. Some incidental stormwater also discharges (under NPDES permit #101007, File #64905) to the Willamette River as part of the plant service water effluent discharged at the waste water outfall, designated 001. Figure 3 shows the current locations, configurations, and surface areas of drainage basins on the EOS Rivergate property as determined by analysis of surface topography. More detail on pervious and impervious areas at the site can be found in Figure 2 ofEOSs Stormwater Pollution Control Plan (Appendix A).
Activities that occur at the site that have exposure to stormwater occur in the three drainage basin as follows :0
• Northern Outfall 003 - Combination rolling mill, coating mill, pipe mill, cut to length facility, melt shop, surface processing, and maintenance. • Rivergate Outfall 002 - Pipe transport and pipe storage, roof runoff from pipe mill, and employee parking. • Infiltration - Pipe transport and pipe storage and materials processing.
Media of potential concern for the stormwater discharge pathway being addressed in this document consist of contaminated surface soil that may become entrained in the stormwater as it flows across the site, contaminated gi-oundwater that discharges through the stormwater system due to subsurface piping failures, and the stormwater itself.
2.5 CONTAMINANTS OF POTENTIAL CONCERN
The long history of industrial activity at this site has resulted in contamination of surface soil and groundwater with a variety of contaminants. The primary media of concern for the stormwater evaluation are surface soil that may be entrained in stomrwater run-off, storm system sediments, and groundwater that may infiltrate the stormwater system piping. Based on current and historical site use, contaminants of interest at the site included semi-volatile organic compounds, volatile organic compounds, polycyclic aromatic hydrocarbons, polychlorinated biphenyls, fuels, and metals. In addition, tributyl tin and dioxins (due to burning off of oil) were considered contaminants of interest in the historical oil sump area and were analyzed for in a limited number of subsurface samples since this area is covered with fill. These contaminants were not carried forward as contaminants of potential concern as they were not detected at concentrations exceeding the relevant screening levels.
Soil Because the historical oil sumps were filled (Exponent 200 Ib), soil contamination associated with this source is subsurface and unlikely to impact stormwater other than via groundwater intrusion into the stormwater system. Petroleum hydrocarbons were detected in groundwater samples in this area. Non-aqueous phase liquid was not observed in monitoring well samples collected from the top of the water column (floating product or LNAPL) within the wells or from the sump located below the screened interval in the wells (sinking product or DNAPL) prior to pumping from the well. Stormwater drainage from the majority of the former oil sump area is routed through the new stormwater treatment system prior to discharge. Forty-eight surface soil samples (0 to 3 feet bgs) have been collected at the EOS facility since 2002. PCBs, metals (arsenic, cadmium, chromium, lead, and manganese), and indeno(l,2,3- cd)pyrene were detected in these surface soil samples at generally low levels but at concentrations exceeding Portland Harbor Joint Source Control Screening Level Values (SLVs). The SLVs for upland soil or stormwater sediment include toxicity and bioaccumulation screening level values. A summary of the concentrations ofchemicals detected in surface soil samples, and applicable SLVs, is presented in Table 1 ; sample locations are shown in Figure 4. The following bullets summarize results for chemicals detected at concentrations greater than the applicable SLV :
• PCBs: Total PCB concentrations in twelve of the forty-eight samples collected exceeded both the bioaccumulative (0.00039 ppm) and toxicity (0.676 ppm) SLVs. Detected values ranged from 0.011 ppm to 4.48 ppm, with the exception of one reading of 430 ppm adjacent to the main electrical substation where historical releases have been documented. This area has subsequently been paved. • Metals: Metals concentrations have been measured in five surface and numerous subsurface soil samples. In the five surface soil samples, copper and zinc did not exceed the SLVs. Chromium and manganese concentrations exceeded the toxicity SLVs (1 11 ppm and 1,100 ppm respectively) in one to three of the samples. Arsenic, cadmium, and lead concentrations exceeded the bioaccumulation SLVs (7 ppm, 1 ppm, and 17 ppm respectively) in one to two samples, but not the toxicity SLVs. Detected values ranged from 27.8 to 335 ppm for chromium, 478 to 3,090 ppm for manganese, 4.48 to 9.49 ppm for arsenic, 0.48 to 1.06 ppm for cadmium, 8.07 to 33.7 ppm for lead, and 68 to 192 ppm for
zinc. • PAHs: One PAH compound (indeno(l,2,3-cd)pyrene) was detected above its respective toxicity SLV of 0.1 ppm in one of the five surface soil samples analyzed for PAHs. Detected values ofindeno(l,2,3-cd)pyrene ranged from 0.056 to 0.15 ppm. • TPH: There are no SLVs specified for petroleum compounds. The DEQ identified a generic risk-based concentration (RBC) for diesel-range hydrocarbons of 23,000 ppm for a construction worker scenario (DEQ 2003). The maximum detected value of diesel-range hydrocarbons in surface soil was 7,000 ppm, below the RBC value. Total petroleum hydrocarbons (TPH) residual range, were detected in all 18 samples analyzed; detected values ranged from 50.5 to 24,000 ppm.
Catch Basin Sediments As part of the 2004 Phase I investigation, sediments were collected from 16 catch basins located throughout the facility and analyzed for metals, petroleum hydrocarbons, PCBs, and PAHs. Concentration summaries for chemicals detected in catch basin solid samples and applicable SLVs, are presented in Table 2; sample locations are shown in Figure 4. The following bullets summarize results for chemicals detected at concentrations greater than applicable SLVs:
This excludes soil samples collected to characterize Mosely Shear soil excavation, as detailed in Mosely Shear Hot Spot Removal Completion Report (Retec 2006c). The SLV screening levels are based on the protection of aquatic ecological receptors and human receptors based on consumption of fish. The PCB, metals, and PAH concentrations at the site (with the exception of the one PCB concentration of 430 ppm discussed below) are below risk-based levels for the protection of industrial workers. 6 • PCBs: Total PCB concentrations exceeded the toxicity SLV (0.676 ppm) in five of the sixteen locations. All detected values were above the bioaccumulative SLV (0.00039 ppm). Detected values ranged from 0.018 ppm to 2.13 ppm. • Metals: The cadmium concentration exceeded both the toxicity and bioaccumulation SLVs (4.98 ppm and 1 ppm, respectively) in one location and the lead concentration (detected at up to 670 ppm) exceeded both the toxicity and bioaccumulation SLVs (128 ppm and 17 ppm, respectively) in two locations. Chromium (detected at up to 7,000 ppm), copper, manganese (detected at up to 68,000 ppm), and zinc concentrations exceeded their respective toxicity SLVs (111 ppm, 149 ppm, 1,100 ppm, and 459 ppm, respectively) in over half of the locations. Arsenic concentrations did not exceed the toxicity SLV, but exceeded the bioaccumulation SLV (7 ppm) in four locations. • PAHs: Two PAH compounds (benzo(g,h,i)perylene and chrysene) were detected above their respective toxicity SLVs of 0.3 and 1.29 ppm in one location and indeno(l,2,3- cd)pyrene was detected above its toxicity SLV of 0.1 ppm in five locations. Pyrene was detected above both its toxicity and bioaccumulation SLVs of 1.52 and 1.9 ppm, respectively, in five locations. • TPH: TPH was detected in all catch basin samples at concentrations ranging from 9.9 to 1500 ppm diesel range hydrocarbons and 67 to 7,900 ppm residual range hydrocarbons.
Groundwater Groundwater is known to infiltrate the stormwater pipes in the Outfall 001 basin, as is evidenced by the presence of dry weather flow in the pipes. In 2002, dry weather flow discharging from Outfall 001 was sampled to evaluate whether contaminated groundwater is infiltrating into the stormwater system and needed to be taken into consideration in the design and evaluation of the new treatment system. These samples contained concentrations of manganese that exceeded the SLV (Exponent 2004a). Manganese concentrations (up to 2,100 ppb; SLV of 50 ppb - based on the National Secondary Drinking Water Standard ) appeared to be consistent with background concentrations measured at monitoring wells installed on the eastern property boundary of the site and concentrations detected regionally in the Columbia Slough Watershed (Parsons 2007). Consequently, it was concluded that groundwater infiltration was not having an adverse impact on stormwater discharging at the Central Emergency Outfall 001. This flow is now directed through the new stormwater treatment system.
At two locations on the site (referred to as Area U, (station W-2), an electrical vault on the south side of the rolling mill; and Area V, (station W-3), a subsurface vault at the east end of the shipping bay), groundwater that collects in subsurface vaults is pumped to the stormwater system (Figure 4). Water samples were collected from these locations to evaluate if they are contributing contaminants to the stormwater system that discharges to Northern Outfall 003 (Exponent 2004a). The sample collected from Area U on March 21, 2003 contained no organic compounds, and metals were detected at concentrations consistent with naturally occurring levels. The sample collected from Area V on October 1 8, 2002 contained metals at elevated concentrations; however, the sample was
National Secondary Drinking Water Regulations are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to water systems but does not require systems to comply. 7 very turbid and filtered analyses indicated dissolved metals were below levels of concern. Petroleum hydrocarbons and some volatile organic compounds were also detected. PAHs and PCBs were not analyzed due to limited sample volume. This groundwater is now directed through the new stormwater treatment system prior to discharge. 3. REGULATORY HISTORY
EOS is authorized to discharge stormwater under a 1200Z Industrial Stormwater General Permit. The permit requires them to develop and implement a Stormwater Pollution Control Plan (Appendix A) which describes the best management practices (BMPs), spill prevention and response procedures, preventative maintenance, employee education and monitoring practices they implement at the site.
From 1997 until 2007, EOS sampled effluent from each of its three outfalls two times per year and analyzed it for pH, total suspended solids (TSS), oil and grease (O&G), copper, lead, and zinc. In 2007, under its new 1200Z permit, EOS began sampling for the same parameters four times per year. In 2009, when Central Outfall 001 was diverted to the treatment pond, sampling at Central Outfall 001 ceased. Sampling results indicated periodic exceedences of TSS and copper benchmarks prior to the addition of stormwater treatment in 2007. With the exception of two benchmark exceedances ofTSS related to optimization testing of the new treatment system, sampling results have been below benchmarks since the first phase of the stormwater treatment system was operational in May 2007. DEQ is currently in the process of determining if the new stormwater treatment system installed at the site to address stormwater that previously discharged through OFs 001 and 003 will require an individual stormwater permit.
The facility also operates a service water treatment system consisting of a cooling pond, a bank of sand filters, and a storage tank. Water, primarily from the Willamette River (surface water withdrawal Permit No. S37537), is circulated within the plant for contact and non-contact cooling. The service water is re-circulated, treated and reused; periodically small amounts are discharged to the Willamette River under an NPDES permit (Permit No. 101007, File No. 64905) through the wastewater outfall 001 (Figure 3).
EOS has two closed landfills on site referred to as the East and West Landfills. The West Landfill (SWD Permit No. 1174) was closed in 1995 and the landfill permit terminated in 1997. DEQ approved reconfiguration of the landfill to accommodate a rail line in 2005. The East Landfill was closed in 2001 and the permit CNo. 2612) terminated in 2002. In 2005, DEQ granted a Solid Waste Letter of Authorization (SW LA No. 1326) to EOS to allow them to reconfigure the East landfill to accommodate the rail line and to add contaminated soil generated as a result of construction activities to the landfill.
EOS is currently working with DEQ to complete source control activities at the Site under the June 2000 Voluntary Remedial Investigation Source Control Measures Agreement (Voluntary Agreement) between DEQ and EOS (DEQ 2000). EOS has conducted site-wide remedial investigation activities since entering into the Voluntary Agreement including records review, mapping, surface and subsurface soil sampling, monitoring well installation, groundwater sampling, 9 risk assessment and feasibility evaluations.
10 4. HAZARDOUS SUBSTANCE RELEASES
As indicated in Section 2.5, the long history of filling and industrial activity at this site has lead to releases of hazardous substances to soil. These substances have sorbed to the surface soil particles and some of these particles have become entrained in stormwater which ultimately exits the facility. As identified in the Phase I Remedial Investigation Report (Exponent 2004a), site chemicals of interest include metals, diesel- and residual-range hydrocarbons, PAHs, and PCBs. As shown in Table 2, maximum detected concentration of metals, PCBs, and certain PAHs (benzo(g,h,i)perylene, chrysene, indeno(l,2,3-cd)pyrene, and pyrene) exceeded SLVs in catch basin solids. Diesel and residual-range hydrocarbons were also detected but there are no SLVs for these compounds.
11 5. SOURCE CONTROL EVALUATION
5.1 NATURE AND EXTENT OF CONTAMINATION
Catch basin data indicate the presence of metals, PCBs, and certain PAHs at concentrations exceeding SLVs throughout the facility. These data appear to correlate with stormwater solids data collected from the Central Emergency Outfall 001 by the Lower Willamette Group as part of the Portland Harbor remedial investigation in 2007 (Anchor & Integral 2008). See Table 3 for a summary of the data. The catch basin data and a general understanding of site activities suggest that sources of contamination at the facility are diffuse with contaminant concentrations that are moderately elevated. The contaminants of concern for this pathway have low solubility and tend to adhere to soil particles.
5.2 PRIORITY FOR SOURCE CONTROL
The stormwater pathway was determined to be a high priority for source control based on exceedances ofSLVs in catch basin samples, stormwater samples, and stormwater solids.
5.3 FACTORS CONSIDERED IN DEVELOPING SOURCE CONTROL OPTIONS
The following factors were considered in evaluating the adequacy of the existing data for supporting a source control action for stormwater at the EOS site:
1. The data indicate that the primary source of contamination to stormwater at this site is upland soil contamination resulting from historical industrial and filling activities. 2. Except for isolated areas, metal and PCB impacts in soil are diffuse as opposed to concentrated in identifiable deposits that are amenable to focused removal or other remedial actions. 3. Paving all areas that drain to the storm system is not feasible due to the extreme weight of loads transported throughout the facility. 4. Dry weather storm drain flows and drain inspections indicate that groundwater infiltration occurs within portions of the storm drain system but the engineering required to isolate the system from groundwater infiltration was found to be very difficult due to accessibility of the impacted piping.
Based on these factors, source control options for stormwater at the EOS facility focused on reducing solids loading from each drainage basin through implementation of best management practices and installation of a stormwater treatment system.
12 6. PEER REVIEW SUMMARY
Technical documents produced during the investigation and source control evaluation and documentation of implemented stormwater treatment facilities for EOS stormwater have been reviewed by a technical team at DEQ. The team consists of the project manager, the cleanup program stormwater coordinator, a toxicologist, and an engineer. The team supports the proposed source control action.
13 7. SOURCE CONTROL OPTIONS
7.1 SOURCE CONTROL OBJECTIVES
The source control objectives for stormwater at the EOS site are:
• Reduce the amount of solids and associated contaminants entrained in stormwater runoff from the EOS facility.
• Reduce contaminant concentrations in stormwater to levels protective of aquatic life and fish consumption exposures.
7.2 AREA TO BE ADDRESSED
All onsite areas exposed to stormwater runoff are addressed by this action. This essentially encompasses the entire facility east of the berm along the riverbank with the exception of areas that directly infiltrate and those areas that drain to the industrial cooling pond (covered under EOS's individual NPDES discharge permit). The shoreline area between the berm and the Willamette River is addressed in a separate source control evaluation.
7.3 SOURCE CONTROL OPTIONS CONSIDERED AND IMPLEMENTED
Several response action technologies were considered in developing the selected approach for stormwater control. Generally, remedial options for stormwater include: treating or removing contaminant sources, preventing exposure of contaminants to stormwater, reducing stormwater runoff, and treating stormwater at the end of the pipe prior to discharge. Because of the large area and on-going industrial activity at this site, and considering the factors outlined in Section 5.3, elements of all of these options have been integrated into the stormwater source control remedy developed for the EOS site, the most significant element being end-of-pipe treatment, as described in the following sections.
Since preparation of the Stormwater Source Control Evaluation in 2006, EOS has implemented several of these remedial options as interim actions and best management practices.
14 7.3.1 Removal/Treatment
Surface soil throughout the EOS facility has been found to contain COCs at concentrations that exceed SLVs for stormwater. Removal actions have been completed at the areas shown on Figure 5 to address more concentrated zones of contamination:
1. Soil Pile Removal. A large soil pile generated as a result of construction work on site (soil pile #1) (approximately 62,000 cubic yards; RETEC 2007b) was removed from the northern portion of the facility. The soil pile had elevated concentration of PCBs, diesel and residual range petroleum hydrocarbons, and metals (copper, lead, nickel, and zinc). This soil was placed in the onsite landfill during its reconstruction in late 2005 and early 2006. The DEQ permitted landfill is capped and the soil is no longer a potential source to stormwater. 2. Surface Soil Removal. Additional surface soil was excavated from north of the rolling mill and scrap yard areas and consolidated into two piles (soil piles #2 and #3) with a total approximate volume of 21,000 cubic yards; (RETEC 2007b). The soil had elevated concentrations of PCBs, diesel and residual range petroleum hydrocarbons, and selected metals. This soil was placed in the east landfill during its reconstruction in late 2005 and early 2006. The DEQ permitted landfill is capped and the soil is no longer a potential source to stormwater. 3. Spiral Pipe Mill Construction. Approximately 3,000 cubic yards of hydrocarbon- impacted soil were generated during the construction of the pipe mill facility. This soil was disposed of in the east landfill during its reconstruction in late 2005 and early 2006. The DEQ permitted landfill is capped and the soil is no longer a potential source to stormwater. 4. Mosely Shear Interim Action. Surface and subsurface soil from the former location of the Mosely Shear was considered a hot spot due to potentially mobile nonaqueous phase liquid (NAPL). Approximately 850 to 900 cubic yards of soil were removed from this area in 2006 as part of an interim action prior to renovation. The surface and subsurface soil contained PCB and diesel and residual range hydrocarbon contamination above screening levels. The soil was disposed of off-site and is no longer a potential source to stonnwater (RETEC 2006c). 5. North Fence Soil Removal. Approximately 240 cubic yards of petroleum- contaminated soil were removed in 1997 following the cleanup of a spill from an above ground tank. The soil was sent off-site for incineration. An additional 120 tons of soil were removed in 1996 when an underground storage tank was decommissioned. DEQ provided a no further action letter for both removals on January 5, 2005. The site is no longer a potential source of contamination to stormwater. 6. Coating Mill Soil Removal. Surface and subsurface soil was removed from the footprint of the coating mill during plant renovation. Approximately 1,800 cubic yards of PCB and petroleum hydrocarbon-impacted soil were removed during the summer of 2006 and disposed ofoff-site.
15 7.3.2 Preventing Contact
EOS implemented a number of actions that will prevent stormwater from coming into contact with contaminated soil. Several areas of the plant have been capped as part of plant renovation in mid-2000. The pipe mill and coating mill were constructed over large areas of the southern portion of the EOS facility. Paving was completed in ancillary areas to these buildings, in portions of the pipe storage area, and in the employee parking area and access road. Figure 2 shows the current site configuration at the EOS facility including buildings and areas that are paved. As discussed above, some parts of the Site remain unpaved because widespread paving of the EOS facility is not feasible due to the extreme weight of loads transported throughout the facility.
The area immediately adjacent to the main substation, including sample location S-2 with elevated PCB concentrations, was paved in 2009. The substation is currently energized to support mill operations and features a fence and a lined secondary containment system. It is likely that PCB contaminated soil remains within the fenced substation under the lined secondary containment area but removal of all contaminated soils is not feasible at this time due to the substation's active role in powering the main plant. The source control evaluation originally considered a soil removal in the vicinity of sample S-2; however, the limited amount of soil, the recently installed asphalt cap outside the fence, and lined containment system inside the fence provide sufficient assurance that the substation area is not a pathway for entrainment of contaminants in stormwater.
The source control evaluation for stormwater identified other portions of the facility where paving could be considered to prevent stormwater contact, especially in heavy traffic areas where the potential for entrainment of solids in stormwater is higher. Paving has been considered and deemed not necessary as these areas are within the drainage basins being addressed through end- of-pipe treatment or best management practices.
7.3.3 Reducing Stormwater Flow
There are a multitude of best management practices (BMPs) that can be utilized to reduce stormwater flow from a facility, including a variety of detention and infiltration facilities. Most require space and access to install and maintain the facilities which is limited in many areas at the EOS facility due to existing plant infrastructure and on-going industrial activities. However, EOS has implemented several BMPs as shown in Figure 2 and described below:
1. Sand Filter and Bioswales. All stormwater runoff which drains to the Rivergate Outfall (002), with the exception of pipe mill roof runoff, passes through a sand filter or bioswale, both constructed in 2007 as part of the construction of the new pipe mill. Bioswales were constructed in 2007 between parking rows in the employee parking area, which drains to the Rivergate Outfall 002. 2. Infiltration. The eastern portion of the pipe transport and storage area and slab storage area were re-graded and configured with bioswales in 2007 to infiltrate stormwater runoff.
16 3. In-Line Passive Stormwater Treatment System. A Vortechnics treatment system was installed in 2000 upstream of the Northern Stormwater Pump Station. This system uses hydrodynamics and filters to remove particles from the stormwater flow. A Vortechnics/Stormfilter treatment chain was installed in 2006 during the Pipe Mill construction immediately west of the Pipe Mill. While these systems are still inline, the treatment components are not active because these functions are addressed by the end- of-pipe treatment system.
The source control evaluation also considered implementation of additional best management practices in the basin that drains to the Northern Outfall 003 including storm drain repairs to reduce groundwater infiltration, decommissioning catch basins in unpaved areas, and grading near manholes to minimize surface water intrusion. These repairs and upgrades were problematic. The broken storm drain line where the majority of the groundwater infiltration occurs could not feasibly be repaired due to inaccessibility. The damaged drain is located at depth between two large structures in an area where steel slabs are continuously stored and transferred. Continued operations in this slab storage area are integral to plant operation. Decommissioning catch basins, grading near manholes, and other BMP retrofits were problematic due to the complexity of the built environment, and the operational impacts associated with access and BMP inspection/maintenance challenges. As discussed in Section 7.3.4, the groundwater infiltration and stormwater drainage associated with these areas are more effectively addressed through an end-of-pipe treatment system.
7.3.4 End-of-pipe Treatment
Because of limitations imposed by the presence of operating industrial infrastructure, the pervasiveness of moderately elevated contaminant levels in soil throughout the facility, and the nature of the industrial activities which prevent implementation of certain stormwater controls (e.g., paving), end-of-pipe treatment was determined to be the appropriate stormwater management and treatment strategy for large areas of the EOS facility. The end-of-pipe treatment is in addition to the source management activities described above. Stormwater that previously discharged to the Central Emergency Outfall 001 and Northern Outfall 003 has been redirected to a stormwater clarification basin where, with the addition of a flocculant and reduced water flow rates, solids settle prior to discharge at the Northern Outfall 003 (Figure 6). Pilot testing conducted on the system from 2007 to 2009 indicated significant reductions in TSS and associated contaminants. Prior to the end-of-pipe treatment system, TSS averaged 200 ppm (2001 to 2006) while during the final pilot study, TSS averaged 32 ppm (AECOM 2009a). A loading evaluation of the stormwater discharge is currently underway.
17 8. EVALUATION OF SOURCE CONTROL OPTIONS
8.1 EVALUATION CRITERIA
The feasibility of source control options was evaluated in the Source Control Evaluation Report (RETEC 2006). Protectiveness of the approach is reviewed based on the standards set forth in OAR 340-122-0040 and consistency with the Portland Harbor Joint Source Control Strategy, and options were assessed using the following remedial factors set forth and defined in OAR 340- 122-0090(3):
- Effectiveness in achieving protection.
Long-term reliability.
- Implementability.
Implementation Risk.
- Reasonableness of Cost.
In addition, there is a preference for treatment or removal of "hot spots" of contamination as defined in OAR 340-122-0115(32) and OAR 340-122-0090(4).
The alternatives evaluation for stormwater source control is unique in that there typically are not discrete, unique options that can be compared to each other. Instead, appropriate techniques are identified and integrated into a comprehensive approach considering the evaluation criteria listed above.
8.2 EVALUATION OF ALTERNATIVES
This section evaluates the source control measures appropriate for the EOS facility based on the factors described in Section 8.1.
8.2.1 Effectiveness in achieving protection
Removal and capping of selected areas effectively removes the associated contaminated soil from the stormwater discharge pathway. Implementation of BMPs, reducing stormwater runoff to the extent practicable, and finally, directing the majority of facility stormwater runoffto end- of-pipe treatment is expected to be effective in minimizing the potential for contaminant 18 migration to the river via stormwater discharge. The contaminants of concern at the EOS facility sorb strongly to soil and are present in stormwater primarily via entrainment of contaminated soil particles. The BMPs and end-of-pipe treatment are expected to substantially reduce the amount of solids in the stormwater that discharges to the Willamette River and correspondingly reduce the pollutant load.
8.2.2 Long-term reliability
The combination of stormwater management techniques developed for the EOS facility is expected to be reliable over the long-term. However, it is recognized that reliability is dependent on maintenance of BMPs and the clarification basin. Regular maintenance of BMPs, including filtration trenches, swales, and catch basin filters, is generally required to maintain effectiveness. The end-of-pipe treatment system, pumps, and treatment chemical supplies must be maintained and the clarification basin will require periodic dredging and appropriate disposal of accumulated solids. Long-term operating and maintenance procedures will be documented in EOS's stormwater pollution control plan required by and enforceable under EOS's NPDES Industrial Stormwater General Permit.
8.2.3 Implementability
The structural BMPs have been implemented, generally as part of new construction projects. Redirecting the majority of stormwater flow at the site to the settling pond involved substantial construction impacts due to the need to install large pumps and modify piping infrastructure. However, the technology involved is standard and readily attainable. Administrative implementability associated with permitting is being addressed through coordination with DEQ's Water Quality program. As indicated in Appendix A, all actions described in this proposal are documented in BOS's Stormwater Pollution Control Plan submitted under their 1200Z General Stormwater Discharge Permit.
8.2.4 Implementation risk
Implementation risk primarily stems from construction hazards associated with construction and operation of large equipment and excavations.
8.2.5 Reasonableness of cost
The approximate cost for all stormwater source control activities is $3.5 million. This includes stormwater source control related studies, development of the pilot study, and design, permitting and construction of stormwater BMPs and the end-of-pipe treatment system. Ongoing operation and maintenance costs are expected to be on the order of $60,000 per year. These costs are considered reasonable for achieving the desired reduction in release of contaminants to the Willamette River.
8.2.6 Hot Spots
It is difficult to define hot spots based on impacts associated with discharge of contaminated stormwater since the impact of the discharge on the receiving body is complicated by the need to 19 model how those contaminants are deposited and accumulate in the river and biological receptors. As documented in Section 7.3, several removals have been conducted at the site to address contamination that was highly concentrated or mobile. These actions and the implementation of end-of-pipe treatment for the majority of facility stormwater are considered to meet the criteria of treating or removing site hot spots for the purposes of the stormwater evaluation.
20 9. SELECTED SOURCE CONTROL ACTION
9.1 SELECTED ACTION
DEQ selects a combination of BMPs and end-of-pipe treatment to control contaminant releases via stormwater at the EOS facility.
9.2 DESCRIPTION OF SELECTED ACTION
There are two stormwater discharge points from the site. At the Rivergate Outfall 002, certain structural best management practices were implemented in the context of the construction of the new spiral pipe mill (installing sand filter, constructing bioswales and regrading to promote infiltration). These were discussed in Section 7 and are described in the attached Stormwater Pollution Control Plan (Appendix A) prepared by EOS as required under their NPDES Industrial Stormwater General Permit. These BMPs address stonnwater source control in the 002 drainage basin.
In addition to those BMPs, EOS completed soil removal and capping/containment actions, as described in Section 7, to prevent contact of stormwater with contaminated soils in certain areas throughout the site.
At the Northern Outfall 003, a treatment system has been installed to collect and treat stormwater runoff from areas of the facility that previously drained to the Central 001 and Northern 003 Outfalls. The treatment system consists of two pump stations, a coagulant injection system and a clarification pond (see Figure 6) that operates in the following steps:
1. Following passage through stormwater drainage pipes, stormwater will enter lift stations (wet wells) equipped with a level-controlled duplex pump system.
2. From the lift stations the stormwater is pumped into a 42-inch line carrying stormwater to the stormwater clarification basin. Just beyond each lift station, treatment chemical is injected into the stormwater flow to encourage particulate coagulation and flocculation. Operation of the chemical metering pumps coincides with operation of the lift station pumps. The treatment chemical mixes and reacts with the stormwater in the length of pipe between the injection point and discharge to the stormwater clarification basin. The coagulant being used is a cationic polymer (RO-295; CCI Chemical Corp.) and the target dose is 2 ppm. EOS is working with DEQ to conduct testing to evaluate the potential toxicity of this chemical.
21 3. Water level in the stormwater clarification basin is controlled to a maximum elevation of 29 feet at the southern outlet point yielding an average operating depth of approximately 3.5 feet, an adequate depth for clarification purposes based on the volume of water this will result in retaining and associated retention time for a 100-year storm event. Within the basin, water "snakes" around three concrete block weirs (flowing generally north to south). Flocculated solids settle out primarily at the north end of the basin. The clarified water enters an outfall structure at the south end of the basin and flows back to the main stem of the existing storm drain that discharges to the Northern Outfall 003.
Plan view and cross-sections of the clarification basin are shown in Figures 7 and 8, respectively. The current configuration is designed to retain and treat stormwater up to a 100-year storm event. Hydrologic modeling and supporting data are provided in EOS's Stormwater Source Control Evaluation (RETEC 2006b). Maximum flow estimated for a 100-year event is approximately 24,000 gallons per minute (gpm). Considering there are two pumps at each lift station with the capacity to pump at 8,000 gpm each (32,000 gpm collectively), flow rate projected for a 100- year event could be pumped to the clarification basin. Retention times in the clarification system for a range of storm events were estimated using a plug flow model. This evaluation is documented in EOS's Phase Two Pilot Study work Plan for End-of-Pipe Treatment (ENSR/AECOM 2008). The modeling indicates that retention times of from 12 to 50 minutes would be achieved under this scenario. Jar testing performed with various coagulants indicated that settling would likely occur in less than 10 minutes (AECOM 201 Ob).
9.3 LONG-TERM MANAGEMENT/MONITORING
Because Northern Outfall 003 remains a discharge point under EOS's stormwater NPDES 1200- Z permit, EOS will continue to monitor at that outfall four times per year for monitoring parameters specified in the permit. However, some initial monitoring and potentially ongoing monitoring of additional parameters will be required to ensure the system is effective at controlling stormwater contaminant sources. EOS conducted pilot testing of the system after the northern drainage basin was connected to the end-of-pipe treatment in 2007. Some modifications to the system were made and the central drainage basin was connected at the end of 2008 followed by another round of pilot testing. Pilot tests involved collecting stormwater samples at facility locations prior to the clarification basin and at the Northern Outfall 003. Seven storm events meeting the following criteria specified in the Framework for Portland Harbor Storm Water Screening Evaluations (DEQ 2005) were monitored over the two-year period:
• Antecedent dry period of at least 24 hours, • Minimum predicted rainfall volume of > 0.2 inches per event, and • Expected duration of storm event of at least 3 hours.
Storms monitored during the pilot tests ranged from 0.29 inches to 0.95 inches over a 24 hour period. Samples were analyzed for TSS, PCBs, metals, and PAHs. Turbidity was reduced from levels that ranged up to over 600 NTUs entering the system to less than 50 NTUs exiting the outfall (AECOM 2009a). Data indicated order-of-magnitude reductions in TSS levels from those 22 measured pre-treatment system. Chemical concentration data collected from Outfall 001 as part of the Portland Harbor investigation prior to end-of-pipe treatment is presented in Table 3 with the corresponding concentrations detected at Outfall 003 during the pilot tests. With the exception of cadmium, copper, lead, zinc, and total PCBs; all contaminants were below JSCS SLVs for stormwater at the discharge point. Cadmium, copper, lead, and zinc exceedances were less than an order of magnitude. While the total PCBs concentration exceeded the bioaccumulative SLV, concentrations of individual Aroclors were below the corresponding toxicity SLVs.
EOS is in the process of conducting a comprehensive stormwater loading evaluation for its facility in the 2010/2011 water year. Data generated from this study will be used to assess contaminant loading to the Willamette River from stormwater discharge at the facility and provide the basis for determining the need, if any, for further action to address source control for stormwater at the site, aside from the long-term management and monitoring that will continue under EOS's 1200-Z stormwater NPDES permit.
The loading evaluation will include the following:
1. Stormwater grab samples from four storm events at the Rivergate Outfall 002 analyzed for organic compounds and metals. 2. Flow-weighted composite whole water stormwater samples from three storm events at the Northern Outfall 003 analyzed for organic compounds and metals. 3. Dry weather grab samples from three sample events at the Northern Outfall 003 analyzed for organic compounds and metals.
In addition to the monitoring described above, the stormwater treatment system will require periodic inspection and solids removal. This will include annual evaluation of accumulated solids and removal when they reach a depth of 12 inches. The three stormwater clarification basin cells will be cleaned using a vactor truck, parked to the west of the basin on an existing access road. Solids will be removed by extending the vacuum hose into the cells without driving into the basin.
Also, if the basin remains unlined, groundwater monitoring will be conducted for such time as is necessary to resolve whether this pathway is significant and poses any risk. These long-term maintenance and monitoring measures will be documented in EOS's Stormwater Pollution Control Plan (SWPCP) which is required and enforceable under its NPDES Industrial Stormwater General Permit. DEQ will consider whether an Equitable Easement and Servitude will be needed to cover any long term monitoring requirements that cannot be implemented through the SWPCP and to address continued maintenance of stormwater control should site use change such that a permit is no longer required.
23 10. PUBLIC NOTICE AND COMMENTS
DEQ's notice of the proposed source control action was published on November 1, 2010 in the Secretary of State's Bulletin, and The Oregonian. Copies of the Staff Report for Proposed Source Control Action, and other documents that make up the Administrative Record were made available for public review at DEQ's Northwest Region offices in Portland and DEQ's web page. The public comment period began November 1 and ended November 30,2010.
DEQ received comments from the City of Portland Bureau of Environmental Services. The City expressed support for the proposed source control action and noted two clarifications to the proposal. The City pointed out somewhat inconsistent language describing the treatment of stormwater flowing to Rivergate Outfall 002. The Record of Decision consistently indicates that all stormwater runoff which drains to the Rivergate Outfall (002), with the exception of pipe mill roof runoff, passes through a sand filter or bioswale. Secondly the City noted that Figure 3 showing the site stormwater basins did not accurately include runoff from the administrative office and associated parking located just east of N. Rivergate Blvd. This figure has been revised accordingly.
No other comments were received.
24 11. DOCUMENTATION OF SIGNIFICANT CHANGE
No changes were made to the proposed remedy described in the Source Control Proposal that went out for public comment.
25 12. STATUTORY DETERMINATIONS
The selected stormwater source control action for the EOS site is protective, and reflects the best balance of trade-offs considering treatment of hot spots, effectiveness, long-term reliability, implementability, implementation risk, and reasonableness of cost. Long-term monitoring and maintenance will be required to ensure the remedy remains protective over time. The selected action, therefore satisfies the requirements ofORS 465.314 and OAR 340-122-0090.
26 13. SIGNATURE
Nina DeConcini, Administrator Date Northwest Region Department of Environmental Quality
27 14. ADMINSTRATIVE RECORD INDEX
The Administrative Record consists of the documents on which the selected source control measures for the site are based. The primary documents used in evaluating source control alternatives for stormwater at the EOS site are listed below. Additional background and supporting information can be found in the EOS project file located at DEQ Northwest Region Office, 2020 SW 4th Ave, Portland, Oregon.
SITE-SPECIFIC DOCUMENTS
AECOM. 2009b. Stormwater Loading Work Plan, prepared for Evraz Oregon Steel Portland, October 2009.
AECOM. 2009c. Stormwater Loading Work Plan Addendum, prepared for Evraz Oregon Steel Mill, Portland, AECOM Environment, October 26,2009.
AECOM. 2009a. Phase Two Pilot Study Report for End-ofPipe Stormwater Treatment Central (001) and Northern (003) Outfalls, prepared for Evraz Oregon Steel, Portland Oregon, August 2009.
AECOM. 201 Oa. Draft Evraz Oregon Steel Upland Human Health Risk Assessment Work Plan, Evraz Oregon Steel Mill, Portland, Oregon, AECOM Environment, February 12, 2010.
AECOM. 201 Ob. Evraz Oregon Steel - Work Plan to Complete Whole Effluent Toxicity (WET) testing ofStormwater at the Northern Outfall (003), June 11, 2010.
Anchor & Integral. 2008. Portland Harbor RI/FS. Round 3A & 3B Stormwater Data Report. Prepared for the Lower Willamette Group. Anchor Environmental, L.L.C. and Integral Consulting, Inc. September 2008.
ENSR/AECOM. 2008. Phase Two Pilot Study Work Plan for End-of-Pipe Stormwater Treatment, prepared for Evraz Oregon Steel Portland, October 2008.
Evmz Inc. 2009. Stormwater Pollution Control Plan, General Permit 1200Z, File No. 64905. May 2009.
Exponent. 2001a. Pre-Remedial Field Activities Data Report, Oregon Steel Mills Inc., Portland, Oregon. February 2001.
28 Exponent. 200 Ib. Pre-Remedial Investigation Historical Investigation Report, Oregon Steel Mills Inc., Portland, Oregon. March 21,2001.
Exponent. 2002. Pre-Remedial Investigation Assessment Report, Oregon Steel Mills Inc., Portland, Oregon. January 2002.
Exponent. 2004a. Phase I Remedial Investigation Report, Oregon Steel Mills Inc., Portland, Oregon. Exponent, March 2004.
Exponent. 2004b. Phase IIA Remedial Investigation Soil and Slag Soil-Fill Sampling Data Report, Oregon Steel Mills Inc., Portland, Oregon. June 2004.
Hart Crowser. 1994. Scrap Yard Assessment report, Oregon Steel Mills, Portland, Oregon. Prepared for Heller, Ehrman, White and McAuliffe. Dated December 13, 1994. (DEQ00114050DEQ001144). Hart Crowser, Inc. Portland, Oregon.
Oregon Department of Environmental Quality-Oregon Steel Mills Inc. 2000. Voluntary Agreement for Remedial Investigation and Source Control Measures. DEQ No. WPMVC-NWR-00-10.
Parsons. 2007. Results of Columbia Slough Porewater Survey, Former UCC/Elkem Site, Portland, OR. January 2007.
RETEC. 2006a. Coating Mill Baseline Soil and Groundwater Sampling Results Letter, Oregon Steel Mills, Inc., Portland Oregon Mill, The RETEC Group, Inc., July 7, 2006.
RETEC. 2006b. Source Control Evaluation of Stormwater, Oregon Steel Mills, Inc., Portland Oregon Mill, August, 2006.
RETEC. 2006c. Mosely Shear Hot Spot Removal Completion Report, Oregon Steel Mills, Inc., Portland Oregon Mill, The RETEC Group, Inc., September 20, 2006
RETEC. 2007a. Pilot Study Work Plan for End-of Pipe Stormwater Treatment Outfall 003, prepared for Evraz, Oregon Steel Portland, February 2007.
RETEC. 2007b. Landfill Construction Report, Oregon Steel Mills Inc., Portland, Oregon. Mill, The RETEC Group, Inc., May 2007.
STATE OF OREGON
Oregon's Environmental Cleanup Laws, Oregon Revised Statutes 465.200-.900, as amended by the Oregon Legislature in 1995.
Oregon's Hazardous Substance Remedial Action Rules, Oregon Administrative Rules, Chapter 340, Division 122, adopted by the Environmental Quality Commission in 1997.
GUIDANCE AND TECHNICAL INFORMATION
29 DEQ. 2009. Guidance for Evaluating the Stormwater pathway at Upland Sites. November 2009.
DEQ-U.S. Environmental Protection Agency. 2005. Portland Harbor Joint Source Control Strategy, December 2005.
DEQ. 2003. Risk-based decision making for the remediation of petroleum-contaminated sites. September 22, 2003.
DEQ. 1998. Guidance for Conducting Feasibility Studies. July 1998.
DEQ. 1998. Guidance for Identification of Hot Spots. April 1998.
USEPA. 1988. Guidance for Conducting Remedial Investigation and Feasibility Studies Under CERCLA. Office of Emergency and Remedial Response. OSWER Directive 9355.3-01. October 1988.
30 File: M:\Evraz OSM\Stormwater Source Control Proposal vicinity map.dwg Layout: FIGURE 1 User: marshalle Plotted: Apr 13, 2010 - 7:57am Xrefs:
:^yK^' ^ ~ MEAN HIGH WATER LEVEL 9.6ft NGVD RAILROAD SWALE BUILDING/STRUCTURE EXISTING/PROPOSED PAVEMENT/CONCRETE AREA DRAINS TO COOUNG POND VEGETATION LANDFILL GRASS COVER » WATER WELL
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ENVIRONMENTAL SAMPLE LOCATIONS A RETEC BORING (2005) • PHASE I Rl SAMPLING (2002) Approximate expansion of former R; Sump Area by year (based on aeriaE photography): + PHASE IIA Rl SAMPLING (2003) l^t^ 4- BERM SAMPLE LOCATIONS m i s-j^-—i,L1i. • RETEC M05ELEY SHEAR TEST PIT (2006) MAPPEOtftGeOWAPHK.lW. JP^^SSS; \ S3C3 LYNMTOOO DRIVE, W. tAFArETIE, (N47008 A UNDERGROUND VAULT SAMPLE LOCATIONS DATE OF mmocawwt ww i.aooa MAP COUPLED ST PHOTOCWWMETTOC UBHCS6 ^ STORM DRAIN SAMPLE LOCATIONS
EVRAZ OREQON STEEL MILLS PORTLAND, OREQON SURFACE SOIL AND CATCH BASIN AICOM SAMPLE LOCATIONS SCALE IN FEET NORTH FENCE SOIL REMOVAL SOIL PILE #1
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^ r^Tc: ,,R,°U HCLT SHOP H.HCE cfe §Sfc?Y •C7 LESENO MATING WiL ESTIMATED SOIL REMOVAL AREA PIPE HILLHILL COATING MILL __._- PROPERTY BOUNDARY SOIL REMOVAI .._ MEAN HIGH WATER LEVEL 9.6ft NGVD TOPOGRAPHY (5' CONTOUR) NGW29 /-' RAILROAD PIPE MILL SOIL REMOVAL- (Removal area estir to be within boundary) IMOSELY SHEAR INTERIM FACTION SOIL REMOVAL SOIL REMOVAL AREAS 5303LV>W(000 0"wt-;l"';.L^r"'^m"'' EVRA2 OREGON STEE^MILLS "PORTLAND, OREGON Sssz""™ rFJGURE5_ AJCOM SCALE [N FEET CONCRETE BLOCK WEIRS PYP) (WSR OPDtlNCS SHADED UL-Z (Km MANHOLE WTH SLUICE _------BASIN OUTFALL PIPING GATE) STORKWATER PIPING "t^s;PUMP MONITORING LOCATION •''^^MWATEfrjftui^u^-- FLOW DIRECTION CENTRAL PUMP STATION EVRAZ OREGON STEEL MILL PORTLAND. OREGON STORMWATER END.OF-PIPE TREATMENT SYSTEM LAYOUT 60150686-203 I DRWN: E.M./SEA TOP OF BLOCK WE'R ELEV. 29 FT CONCRETE BLOCK WEIR WIDTH OF WEiR IS 1 FULL BLOCK OR 2.45 H TOP OF BLOCK 0£V, 33 FT AND LENGTH OF WDR IS 14.7 FEET. .MANHOLE COVER RIM ELEV 34.66' 40 ^ ^^^l^UF 40 MANHOLE ROADWAY 3 <5 ?=:ES=E |Z;,:pT.]^u.^, E -^c _££——— ^C&'IWKAWN:: BASH =^YP?= ^—'"e&TfOt 0+00 0+50 t+00 1+50 AS-BUILT TOP OF BLOCK WEIR ELEV. 29 FT FULL BLOCKS FROM - CONCRETE BLOCK WGR WIDTH 36" FROM ULTRA BLOCKS. 1NC ' OF WEtR iS 1 FULL BLOCK OR 2.45 FT VANCOUVER, WA OR STORUWATER AND LENGTH OF WEIR IS U.7 FFEJ. APPROVED EOUIVALEW CLARinCATlON 8AS!N =^:=F=^SW- -TOP^OF)::Bkoei^ElEv^B^r^ r^^d- 20 -^ ^_^:::\:^ ^)W^===^^^ EXISTING 10 ===^^^ [t6N;::BASiN::::::::::::::::;:::::=::::| ::::::^:::::^ 10 ^ws -:CLAF 36" PVC TO NORTHERN 0 OUTFAU- 003 NOTE: THC D BLOCK SIZES USED TO CONSTRUCT WEfR ARE FULL STANDARD, HALF STANDARD, 4 CROSS BEAM. AND BAT CAP. 3. VERTiCAL TOLERANCES FOR WE!RS SHALL BE ± 2 iNCHES. 36 INCH PIPE TRENCH DETAiL NOTES: AS-BUtLT CONDITIONS DEPiCTED ON SCALE: i'»T THESE DRAWINGS AREAPPROXSMATE tM 5. EXCAVATE CLARIFICATION BASIN SIDES AND 80FTOM. AS NECESSARY, TO SET BLOCKS. OVER EXCAVATE AS NEEDED TO ACHIEVE DESIGNED LEXAT10N. CHANGES FROM THE ELEVATIONS. PROVIDE 1 FOOT THICK 3/4" GRAVEL AS BEDDING MATERIAL FOR BLOCKS IN BOTTOM OF CLARIFICATiON BASIN. CONSTRUCTION DRAWIMGS WERE PROVIDED BY HAND WRnTEN MARK-UPS. 2. AS-BUtLT GRADES SHOWN ARE BASED ON DESIGN CONTOURS MOT SURVEY DATA. EVRAZ INC. NA CONCRETE BLOCK WEIR CROSS SECTiONS REVISED DRAWING STORM DRAIN 2008 SCALE: 1"» 20' PREPARED BY: j/22/o') I CONSTRUCTION DETAILS I AECOM SHEET 2 OF 3 '137-550 |[T-°81879 15 Table 1 Summary of Surface Soil (0-3 feet >cis) Results Contaminants of Potential Concern Sui imary Statistics Sample Type Samples Detects Non-Detects Exceedsnces Max Detected Max Concentration Average PHSL PHSL (bio- Chemical Name Unit Action Level Unit Concentration Location Det Concentration (toxicity) accumulation) Metals Chromium mg/Kg Ill mg/kg 4 4 0 2 335 S-57a 130.025 Manganese mg/Kg 1100 mg/kg 4 4 0 2 3090 S-57a 1336.750 Arsenic mg/Kg 33 7 mg/kg 4 4 0 1 9.49 S-57a 6.530 Cadmium mg/Kg 4.98 1 mg/kg 4 2 2 1 1.06 S-57a 0.770 Copper mg/Kg 149 mg/kg 4 4 0 0 130 S-57a 48.950 Lead mg/Kg 128 17 mg/kg 4 4 0 1 33.7 S-59a 15.255 Zinc mg/Kg^ 459 mg/kg 4 4 0 0 192 S-59a 102.425 PCBs Aroclor 1016 mg/kg .S3 mg/kg 48 0 48 0 Aroclor 1221 mg/kg 48 0 48 0 Aroclor 1232 mg/kg 48 0 48 0 Aroclor 1242 mg/kg 48 0 48 0 Aroclor 1248 mg/kg 1.5 mg/kg 48 21 27 2 3.6 S-29 0.471 Aroclor 1254 mg/kg .3 mg/kg 48 14 34 5 2.8 S-2 0.493 Aroclor 1260 mg/kg .2 mg/kg 48 23 25 10 430 S-2 19.090 Total PCB (Calculated) 1 mg/kg .676 .00039 mg/kg 48 41 7 41 430 S-2 11.118 PAHs 2-Methylnaphthalene mg/kg .2 mg/kg 5 2 3 0 0.11 S-16 0.079 Acenaphthene mg/kg .3 mg/kg 5 2 3 0 0.074 S-16 0.042 Acenaphthylene mg/kg .2 mg/kg 5 1 4 0 0.023 B-37 0.023 Anthracene mg/kg .845 mg/kg 5 1 4 0 0.023 B-37 0.023 Benzo(a)anthracene mg/kg 1.05 mg/kg 5 3 2 0 0.07 B-37 0.038 Benzo(a)pyrene mg/kg 1.45 mg/kg 5 2 3 0 0.15 B-37 0.096 Benzo(b)fluoranthene mg/kg 5 3 2 0 0.1 B-37 0.059 Benzo(g,h,i)perylene mg/kg .3 mg/kg 1 1 0 0 0.2 B-37 0.200 Benzo(k)fluoranthene mg/kg 13 mg/kg 5 2 3 0 0.095 B-37 0.072 Chrysene mg/kg 1.29 mg/kg 5 3 2 0 0.11 B-37 0.057 Dibenz(a,h)anthracene mg/kg 1.3 mg/kg 5 1 4 0 0.019 B-37 0.019 Dibenzofuran mg/kg 1 1 0 0 0.0054 B-37 0.005 Fluoranthene mg/kg 2.23 37 mg/kg 5 5 0 0 0.26 S-16 0.080 Fluorene mg/kg .536 mg/kg 5 1 4 0 0.0085 B-37 0.009 lndeno(l,2,3-cd)pyrene mg/kg .1 mg/kg 5 2 3 1 0.15 B-37 0.103 Naphthalene mg/kg .561 mg/kg 5 2 3 0 0.17 S-16 0.134 Phenanthrene mg/kg 1.17 mg/kg 5 3 2 0 0.23 S-16 0.116 Pyrene mg/kg 1.52 1.9 mg/kg 5 3 2 0 0.14 B-37 0.063 NWTPH-Dx Diesel Range B mg/kg 17 17 0 0 7000 S-16 487.188 Residual Range C mg/kg 17 17 0 0 24000 S-16 1734.294 Diesel Range Hydrocarbons mg/Kg 1 1 0 0 430 TP19 Residual Range Organics (RRj mg/Kg 1 1 0 0 1200 TP195 Table 2 Summary of Catch Basin Results Summary Statistics Max Detected Max Concentration Average PHSL PHSLfbio- Chemical Name Unit Action Level unit (toxicity) accumulation) Samples Detects Exceedances Concentration Location Det Concentration Metals Arsenic mg/kg 33 7 mg/kg 18 18 4 12 SD-S 5.588 Cadmium mg/kg 4.98 1 mg/kg 18 13 10 14 SD-16 2.931 Chromium mg/kg Ill mg/kg 18 IS 18 7000 SD-7 2194.706 Copper mg/kg 149 mg/kg 18 18 11 460 SD-16 208.412 Lead mg/kg 128 17 mg/kg 18 IS 16 670 SD-16 132.529 Manganese mg/kg 1100 mg/kg IS 18 18 68000 SD-7 19300.000 Mercury mg/kg 1.06 0.07 18 18 0 0.17 SD-5 0.078 Nickel mg/kg 48.6 18 18 0 170 SD-16 69.778 Zinc mg/kg 459 mg/kg IS 18 9 2400 SD-16 850.SS6 PCBs Aroclor 1016 mg/kg .53 mg/kg 16 0 0 Aroclor 1221 mg/kg 16 0 0 Aroclor 1232 mg/kg 16 0 0 Aroclor 1242 mg/kg 16 0 0 Aroclor 1248 mg/kg 1.5 mg/kg 16 8 0 1.5 SD-1 0.677 Aroclor 1254 mg/kg .3 mg/kg 16 10 2 0.63 SD-1 0.187 Aroclor 1260 mg/kg .2 mg/kg 16 0 0 Total PCB (Calculated) mg/kg .676 .00039 mg/kg 16 16 16 2.13 SD-1 0.455 PAHs 2-Methylnaphthalene mg/kg .2 mg/kg 17 9 0 0.19 SD-5 0.084 Acenaphthene mg/kg .3 mg/kg 17 6 0 0.11 SD-3 0.074 Acenaphthylene mg/kg .2 mg/kg 17 0 0 Anthracene mg/kg .845 mg/kg 17 10 0 0.22 SD-5 0.077 Benzo(a)anthracene mg/kg 1.05 mg/kg 17 14 0 0.58 SD-5 0.152 Benzo(a)pyrene mg/kg 1.45 mg/kg 17 12 0 0.37 SD-5 0.150 Benzo(b)fluoranthene mg/kg 17 14 0 1 SD-5 0.252 Benzo(g,h,i)perylene mg/kg .3 mg/kg 17 13 1 0.55 SD-5 0.191 Benzo(k)fluoranthene mg/kg 13 mg/kg 17 12 0 0.54 SD-5 0.153 Chrysene mg/kg 1.29 mg/kg 17 16 1 1.3 SD-5 0.274 Dibenz(a,h)anthracene mg/kg 1.3 mg/kg 17 4 0 0.076 SD-20 0.060 Fluoranthene mg/kg 2.23 37 mg/kg 17 16 0 1.5 SD-5 0.319 Fluorene mg/kg .536 mg/kg 17 8 0 0.11 SD-5 0.069 lndeno(l,2,3-cd)pyrene mg/kg .1 mg/kg 17 7 5 0.23 SD-3 0.155 Naphthalene mg/kg .561 mg/kg 17 9 0 0.2 SD-5 0.112 Phenanthrene mg/kg 1.17 mg/kg 17 16 0 0.99 SD-5 0.237 Pyrene mg/kg 1.52 1.9 mg/kg 17 16 . 1 2.2 SD-5 0.462 NWTPH-DX Diesel Range B mg/kg 18 .18 0 1500 SD-16 365.772 Residual Range C mg/kg 18 18 0 7900 SD-16 2207.611 Total PCBs equai to sum of detected PCB arocior values or the highest method reporting limit if al! PCS arociors are non-detect Table 3 Stormwater Comparison Compound itormwater Average ** Stormwater (ug/L) 'ortland Harbor RI/FS Pilot test data awqc 're-pilot 3/07 to 5/07 Spring 2009 Averages ug/L 2-Methylnaphthalene 0.035 ND Acenaphthene 0.041 0.027 Acenaphthylene 0.007825 ND Aluminum Anthracene 0.012 Antimony Arochlor 1248 0.0104 Arochlor1254 0.0056 Arsenic 4.965 0.14 Benzo(a)anthracene 0.03525 Benzo(a)pyrene 0.022 0.018 Benzo(b)fluoranthene 0.048 Benzo(g,h,i)perylene 0.03175 Benzo(k)fluoranthene 0.0135 Bis(2-ethylhexyl) phthalate 1.345 ND Butylbenzyl phthalate 0.5525 Cadmium 1 0.166 Chromium 99.6 31.2 11 Chrysene 0.0595 0.014 Copper 35.0E 5.63 3.6 Dibutyl phthalate ND Diethyl phthalate 0.18 Dimethyl phthalate ND Di-n-octyl phthalate ND Fluoranthene 0.152£ 0.06 Fluorene 0.031E 0.012 lndeno(1,2,3-cd)pyrene ND Lead 47.e 3.8 MCPA 17.87£ MCPP 16.77E Naphthalene 0.0807E 0.024 Nickel 11.E 3.81 PCB Congener sum 0.27S 0.000064 Phenanthrene 0.1222E 0.052 Pyrene 0.154E 0.053 Zinc 108.9E 3S * Stormwater data summary Central OF (001). Data collected by the Lower Willamette Group. ** Metals are total TSS 1996 - 2007 TSS 2009 average 186 - 216 mg/L 31.9 mg/L > -D T3 fD =5 Q- x > =S EVRAZ EVRAZINCNA mal Stormwater Pollution Control Plan Evraz Inc. NA General Permit 1200Z File No. 64905 Evraz Oregon Steel - Rivergate Site 14400 North Rivergate Drive Portland, Oregon 97203 Multnomah County Site Contact: Drew Gilpin Ph.(503)978-6189 May 28, 2009 Table of Contents Introduction...... 1-1 1.1 General Plant Information...... 1-1 1.2 EOS Commitment to Stormwater Pollution Control...... 1-1 1.3 Preparation and Implementation of SWPCP...... 1-1 1.4 Certification of Plan...... 1-2 Site Description...... ^-! 2.1 General Site Location ...... 2-1 2.2 Description of Industrial Activities...... 2-1 2.2.1 Steel Manufacturing...... 2-1 2.2.2 Material Storage...... 2-2 2.2.3 Shipping and Receiving...... 2-2 2.2.4 Service Water Treatment System...... 2-2 2.2.5 Truck and Vehicle Maintenance ...... 2-3 2.2.6 Fueling...... 2-3 2.2.7 Parking...... 2-3 2.3 StormwaterOutfalls...... 2-3 2.3.1 Central Emergency Outfall 001 ...... 2-3 2.3.2 Rivergate Outfall 002...... 2-4 2.3.3 Northern Outfall 003...... 2-4 2.4 Drainage Basin Descriptions...... 2-4 2.4.1 Drainage Basin A...... 2-5 2.4.2 Drainage Basin B...... 2-5 2.4.3 Drainage Basin C...... 2-5 2.4.4 Drainage Basin D...... 2-5 2.4.5 Drainage Basin E ...... 2-5 2.4.6 Drainage Basin F...... 2-6 2.4.7 Drainage Basin G...... 2-6 2.4.8 Drainage Basin H...... 2-6 2.4.9 Drainage Basin I...... 2-6 2.5 Reasonable Potential Stormwater Pollutants ...... 2-6 2.6 Groundwater Discharged to Stormwater System...... 2-6 Site Controls for Stormwater Pollution Prevention...... 3-7 3.1 Stormwater Best Management Practices ...... 3-7 3.1.1 Containment...... 3-7 3.1.2 Oil and Grease...... 3-7 3.1.3 Waste Chemicals and Material Disposal ...... 3-8 3.1.4 Debris, Erosion and Sediment Control ...... 3-8 3.1.5 Stormwater Diversion...... 3-9 3.1.6 Covering Activities...... 3-9 3.1.7 Good Housekeeping Practices ...... 3-9 3.2 Spill Prevention and Response...... 3-9 3.3 Preventive Maintenance Measures ...... 3-10 3.4 Employee Education and Training...... 3-11 Record Keeping and Internal Reporting Procedures...... 4-11 1 Tables Table 1 Identification of Potential Pollutants Maps Figure 1 Vicinity Map Figure 2 Site Map - Layout of Drainage Basins and Stormwater System Figure 3 Stormwater Surface Are Flow Direction Appendices Appendix A Example of Spill Notification and Response Procedures and Report Form Appendix B Example of Stormwater Site Control Inspection Forms Appendix C Example of Stormwater and Spill Prevention Training Outline 1 Introduction This Stormwater Pollution Control Plan (SWPCP) covers the operations of the Evraz Inc. NA, Evraz Oregon Steel facility (EOS), located at 14400 North Rivergate Drive, in Portland, Oregon. The plan was prepared in accordance with the requirements of the Oregon Department of Environmental Quality (DEQ) National Pollutant Discharge Elimination System (NPDES) Stormwater Discharge General Permit Number 1200-Z issued to EOS under File Number 64905. This Plan describes the facility and its operations, identifies potential sources of stormwater pollution, describes control measures that are in place to prevent and/or treat stormwater pollution, and provides for annual plan review. This plan is an update of the previous stormwater pollution control plan (dated May 2, 2007) and is retained on file in the facility Environmental Department office at all times. 1.1 General Plant Information Figure 1 shows the geographic location of the EOS Rivergate facility. EOS manufactures steel plate and intermediate plate products at the Rivergate facility. The major operations at the facility are plate rolling, cutting, surface processing, and spiral weld pipe manufacturing. The primary support operations at the plant are maintenance, service water treatment, and transport of materials and products. The facility currently employs approximately 500 people. The facility has a Standard Industrial Classification (SIC) code of 3312: Steel Works, and Rolling Mills. Pipe manufacturing has the additional classification of 3317: Steel Pipe and Tubes. 1.2 EOS Commitment to Stormwater Pollution Control EOS maintains a written corporate environmental policy statement that clearly outlines the company's commitment to comply with all relevant environmental laws and regulations, and to educate employees accordingly has developed and implemented an Environmental Management System modeled after ISO 14000 standards. EOS routinely reviews and evaluates products used in processing, fabrication, and maintenance for hazardous contents and, where possible, replaces with non-hazardous substitutes. 1.3 Preparation and Implementation of SWPCP The Stormwater Pollution Prevention Team is responsible for developing, preparing, implementing, maintaining, and revising this SWPCP. The members of the team are knowledgeable in stormwater management and familiar with the operations of the facility and compliance with environmental regulations. The team members are: Mr. Drew Gilpin - Manager of Energy and Environment Office Phone: (503)978-6189 Ms. Debbie Deetz-Silva - Environmental Specialist Office Phone: (503) 978-6044 1-1 These team members have the responsibility to: • Oversee day-to-day environmental compliance and SWPCP implementation at the facility • Develop and direct stormwater compliance programs for EOS • Prepare budgets and schedules for implementation of pollution control measures as specified in the SWPCP • Maintain and submit required reports and records • Train employees • Supervise stormwater inspections and regular site compliance evaluations. 1.4 Certification of Plan I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to ensure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, tme, accurate, and complete, I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Certification by Plant Owner/Operator Signature: Name: DrewJ^flpin Title: Manager ofBnergy and Environment Date: , ^/^/^ -77T " Company: Evraz Oregon Steel ^. 1-2 2 Site Description 2.1 General Site Location The Plant is located at 14400 N. Rivergate Boulevard, in Portland, Oregon in the Rivergate industrial area on the Willamette River (Figure 1) less than a mile south of the confluence of the Willamette and Columbia Rivers. The Plant occupies approximately 145 acres bordered on the north by the Port of Portland's potash handling facility at Terminal 5, on the east by the Union Pacific railroad tracks, on the south by N. Ramsey Boulevard and a bulk storage facility owned by Simplot, and on the west by the Willamette River. The main access road to the site is Rivergate Boulevard with entry from the south. Rail spurs connect the site to Union Pacific railroad tracks. A site map (Figure 2) identifies drainage patterns, buildings, paved (impervious) areas, unpaved (pervious) areas and drainage basins on the EOS Rivergate property. The figure identifies significant structural control systems for stormwater pollution control, the location of wells and wetland and other significant features of the site. The site is predominantly flat in operational areas except for two existing permitted solid waste landfills in the northern portion of the site and an earthen berm along the riverfront. 2.2 Description of Industrial Activities Current industrial activities conducted at the EOS Rivergate facility are primarily associated with the manufacture of steel plate, coil and intermediate plate steel products from steel slabs. This section describes the industrial activities associated with steel manufacturing at the Rivergate facility. 2.2.1 Steel Manufacturing Steel slabs are barged to the Port of Portland Terminal 6 and transported to the EOS Rivergate facility via truck. EOS receives steel slabs as the raw material that feeds the steckel Rolling Mill. Steel slabs are heated in a natural gas fired reheat furnace and mechanically rolled into plate or coil products. The plate product is stored and distributed to customers from the shipping bays via truck or rail. Some plate product may be sent to Surface Processing on site for further surface preparation or off site to the EOS Heat Treating facility. The coil product is sold "as is" or transferred to ancillary production facilities including the coil processing line (Cut-to-Length), spiral Pipe Mill located on the Rivergate site or the Structural Tubing Mill located off site. Coil product sent the offsite Structural Tubing Mill is used to make various sizes of structural tubing. The onsite Cut-to-Length line mechanically uncoils the steel coils and the leveled steel is sheared into plate section lengths and trimmed as specified by the customer. The onsite Pipe Mill runs coiled steel through a splitter and then spiral wound and welded into pipe sections. The pipe is then processed through a Pipe Coating facility also located on site (see Figure 2). Except for limited processing of scrap metal, loading and unloading of some steel products, all steel manufacturing operations occur under cover in buildings and do not come into contact with stormwater. 2-1 The Melt Shop is currently idle (ceased operations in 2003). When the facility does operate, scrap metal from both on-site and off-site sources is processed through the Melt Shop in an electric arc furnace and cast into steel slabs. Other ancillary operations (described below) that support the manufacturing process include material storage, shipping and receiving, service water treatment system, truck and vehicle maintenance, fueling and general parking. 2.2.2 Material Storage To the maximum extent practical, materials are confined to specific storage or processing locations (Figure 2). Scrap metal is processed (sized and sorted) and stored in the north eastern area of the site and sold or recycled. Mill scale is stockpiled in the north eastern area of the site and sold. Wood wastes are sorted in this same area and is processed (chipped) and recycled by an outside vendor. Petroleum contaminated soils (when generated) are stored on an impervious surface and kept covered until arrangements are made for offsite transportation and disposal. Steel slabs, finished steel products (plate, coil, pipe), and some process-related equipment are stored outside and uncovered in other designated areas of the site. Significant materials stored on-site include gasoline diesel and kerosene fuels, propane, water treatment chemicals, water treatment solids, paints and coatings, petroleum products, used oil, antifreeze, flux an spent flux, These materials are stored in buildings or designated cover areas with secondary containment where practicable. Other materials are typically stored inside storage areas at various locations throughout the facility. Table 1 identifies and describes significant materials that are stored, used treated or disposed of in a manner that could potentially allow exposure to stormwater. 2.2.3 Shipping and Receiving Generally products and materials brought to the facility by truck or rail include (but are not limited to) steel slabs, petroleum products, water treatment chemicals, store warehouse products and materials, and steel coatings. Steel products (coil, pipe and plate) are shipped off-site by rail and truck. The primary locations where products are loaded for shipment are the shipping bays at the east end of the Rolling Mill, the Cut-to-Length facility, pipe storage and Surface Processing. 2.2.4 Service Water Treatment System The service water treatment system located north and west of the Pipe Mill building (Figure 2) treats process contact cooling water used in manufacturing operations. The primary unit operation of the treatment system is sand filtration to remove particulate matter. As required to manage process water quality characteristics and cooling pond water levels, treated process water is occasionally discharged to the Willamette River through a separate outfall in accordance with NPDES waste discharge permit number 101007. As shown in Figure 2, a small amount of surface area east of the cooling pond drains stormwater to the cooling pond where it becomes part of the process water stream. 2-2 2.2.5 Truck and Vehicle Maintenance Several types of mobile equipment are used at the facility. Mobile cranes, switch engines, trucks, back hoes, fork lifts, and front-end leaders are examples. Maintenance of facility vehicles is conducted indoors in the Maintenance Shop building located north of pipe storage area (Figure 2). New and used petroleum materials are stored indoors or under cover in this area of the site. Used oil and used antifreeze are properly contained and stored prior to off-site transfer and recycling in accordance with state and federal regulations. EOS vehicles are cleaned on the steam cleaning pad located at the carpenter shop between the Maintenance Shop and Surface Processing Buildings (Figure 2). The wash water is collected, treated through an oil water separator, and discharged to the City of Portland sanitary sewer under Industrial Wastewater Discharge Permit number 300.008. 2.2.6 Fueling Gasoline, kerosene and diesel fuels are stored in and dispensed from aboveground tanks at the southeast comer of the Rolling Mill. Fueling is performed on an engineered containment pad and fuel tanks are outfitted with overfill and spill alarm systems. Any fuel spills onto of the containment pad are directed to an oil/water separator where oil is trapped and can be vacuumed before discharge to the sanitary sewer. 2.2.7 Parking Employee parking for the administration building is located north of that building. Parking for the majority of plant employees is located north of Surface Processing (Figure 2). The stormwater vegetated swale system for the parking surface was designed in accordance with the City of Portland Stormwater Management Manual (SWMM). 2.3 Stormwater Outfalls All stormwater is contained on site and either drains by sheet flow to a system of catch basins and through treatment systems or percolates into unpaved ground surfaces. The storm sewer system conveys runoff to the Northern Outfall 003 and Rivergate Outfall 002 as shown in Figure 2. Northern Outfall 003 discharges stormwater directly to the Willamette River. Rivergate Outfall 002 discharges stormwater to a City of Portland storm sewer system. A third outfall, Central Emergency Outfall 001, has been inactive since February, 2009. The Central Emergency Outfall 001 can discharge directly to the Willamette River in the event of an extreme situation and only after a guillotine gate is manually opened. The EOS storm sewer pipes are typically constructed from reinforced concrete except for Northern Outfall 003 where newer sections are constructed with high density polyethylene (HDPE), and the inactive Central Emergency Outfall 001 interconnect to the treatment system that is constructed ofHDPE & steel pipe. 2.3.1 Central Emergency Outfall 001 Central Emergency Outfall 001 has been inactive since February, 2009. Storm water from drainage basins B, C, D is directed to the Central Pump Station located up the pipe from the Central Emergency Outfall 001. The Central Pump Station pumps accumulated 2-3 storm water to the end of pipe treatment system and ultimately discharges through the Northern Outfall 003. There is a guillotine gate that can be manually opened to allow flow through the Central Emergency Outfall 001 in the event of an extreme storm event (greater than 100 year storm) or other situation that would require such emergency measures. 2.3.2 Rivergate Outfall 002 Rivergate Outfall 002 discharges stormwater to a City of Portland storm sewer system. Roof runoff from the Pipe Mill building and discharge from the pipe storage yard that is treated through a sand filter system are discharged to the City of Portland storm sewer system. Swale treated stormwater from the employee parking lot and storm water from the administration parking lot area is discharged into the City storm sewer line in the turn-a- round at the end ofRivergatejust west of the EOS Administration building. The City's storm sewer pipe travels south down Rivergate and is combined with other storm water from other industrial areas at N. Ramsey Blvd. and ultimately discharges into the Willamette River via City of Portland Outfall 053A. The estimated amount of impervious surface area acres that drains to Rivergate Outfall 002 is 8.2 acres. The estimated amount ofpervious surface area acres that drains to the Rivergate Outfall 002 is 1 .2 acres. The sampling location for storm water monitoring is the manhole directly northeast of the sand filter just inside the entrance gate west of the Administration building (Figure 2). 2.3.3 Northern Outfall 003 Northern Outfall 003 discharges directly to the Willamette River through a pipe located on the riverbank approximately 400 feet south of the northern property boundary. Upstream of the discharge location is a comprehensive treatment system where the majority of the suspended solids settle out in a clarification basin prior to discharge. Water is mechanically pumped at the Central Pump Station to the treatment system prior to discharge through Northern Outfall 003 The estimated amount of impervious surface area acres that drains to Northern Outfall 003 is 33.6 acres. The estimated amount ofpervious surface area acres that drains to the Northern Outfall 003 is 63.2 acres. The sampling location for storm water monitoring is the outfall pipe as it discharges to the Willamette River (Figure 2). 2.4 Drainage Basin Descriptions Figure 2 shows the estimated locations, configurations, and surface areas of drainage basins on the EOS Rivergate property as determined by analysis of surface topography. Collected runoff from basins A through E, G and I discharge to one of the two active stormwater outfalls. Runofffrom basins F and H infiltrate into the ground. 2-4 2.4.1 Drainage Basin A Drainage Basin A services the northern side of the facility, including the north side of the Rolling Mill, Cut-To-Length facility, coil storage, and runoff from southern portions of the landfills. This outfall was renovated in 1997 in conjunction with the construction of the steckel Rolling Mill. At that time, a Vortechnics'" system was installed at the end of the drainage line to treat the stormwater. After the Vortechnics"" system, stormwater is mechanically pumped at the Northern Pump Station to the end of pipe treatment system prior to discharge through Northern Outfall 003. 2.4.2 Drainage Basin B Drainage Basin B occupies the central manufacturing area of the site including the northern portion of the Melt Shop (currently idled) and southern portion of the Rolling Mill. A significant portion of the area between the Rolling Mill and Melt Shop buildings is used for temporary slab storage prior to rolling. Groundwater infiltrates into compromised storm water pipes in the slab storage area. Stormwater runoff and groundwater infiltrating compromised storm water pipes is mechanically pumped at the Central Pump Station to the end of pipe treatment system prior to discharge through Northern Outfall 003. 2.4.3 Drainage Basin C Drainage Basin C occupies a large track in the southwest portion of the property extending from the southern half of the Melt Shop to the Pipe Mill and from the earthen berm along the riverbank to Surface Processing. All surface runoff in this area drains to the Central Pump Station or percolates into the ground as portions of the basin area remain unpaved. Storm water from this area is mechanically pumped at the Central Pump Station to the end of pipe treatment system prior to discharge through Northern Outfall 003. 2.4.4 Drainage Basin D Drainage Basin D is occupied by the Pipe Mill, and a portion of the Coating Mill. The land surface within Drainage Basin D is generally not paved. Roof runoff from the Pipe Mill building is split. Approximately 20% of Pipe Mill roof runoff drains to the Central Pump Station and is pumped to the end of pipe treatment system and discharges through Northern Outfall 003. Approximately 80% of the Pipe Mill roof runoff drains to the Rivergate Outfall 002. The ground surface runoff in Drainage Basin D is collected and directed west to treatment equipment (sequential Vortechs™ and Stormfilter™) for reduction of suspended solids prior to being pumped at the Central Pump Station to the end of pipe treatment system and discharged through Northern Outfall 003. 2.4.5 Drainage Basin E Drainage Basin E is an unpaved basin that covers the far northeastern corridor of the facility. A drain line was installed to convey percolated stormwater originating in the material processing area (east of the East Landfill) and runoff from the north side of the East Landfill. This water is conveyed west t prior to being pumped at the Northern Pump Station to the end of pipe treatment system and discharged through Northern Outfall 003. 2-5 2.4.6 Drainage Basin F Drainage Basin F is unpaved and does not contain stormwater management infrastructure. Runoff in this area collects in topographic lows and infiltrates the ground surface. 2.4.7 Drainage Basin G Drainage Basin G features the employee parking lot constructed in 2007. Stormwater runoff from the parking lot drains through and is treated within interior vegetated swales. Following treatment, the runoffis discharged to the Rivergate Outfall 002. 2.4.8 Drainage Basin H Drainage Basin H was redeveloped in 2007 for onsite transport and storage of pipe. All runoff collected within Basin H is directed south to an infiltration basin and does not discharge to any outfall. 2.4.9 Drainage Basin I Drainage Basin I was redeveloped in 2007 for onsite transport and storage of pipe. Runoff in Basin I is treated sequentially through a vegetated swale and sand filter before being discharged to Rivergate Outfall 002. 2.5 Reasonable Potential Stormwater Pollutants Table 1 lists the operational areas that have stormwater runoff contributing flow to the outfalls, describes industrial activities in each area that have a potential exposure to stormwater, lists the potential pollutants, and indicates the outfall(s) to which each area drains. Figure 2 identifies the various operations and their locations. Although all of the following materials are handled, used, and stored in accordance with best management practices (BMPs), there are materials (to the extent known by the permittee) that have been handled, or stored, at the facility in a manner which could allow exposure to stormwater. These include: steel slabs; other finished steel products (coil, pipe); scrap metal, slag, oil and chemical products for vehicle and equipment maintenance; used oil and chemicals from vehicle and equipment maintenance; trash (stored in dumpsters); baghouse dust; gasoline, kerosene and diesel fuels; equipment storage; paints; spent flux and mill scale. The use and disposal of significant materials and potential pollutants are listed according to source area in Table 1. 2.6 Groundwater Discharged to Stormwater System Groundwater infiltrates the storm sewer system at various system pipe joints and sleeve connections as well as fracture points that are below the groundwater level. Groundwater infiltration is negligible in Drainage Basin D that discharges to Rivergate Outfall 002. Significant groundwater infiltration has been observed in Drainage Basins B and C (video inspection and dry weather flow). Modest dry weather flows are also observed in Drainage Basin A. Groundwater infiltration from in the storm sewer system these drainage basins (B, C and A) is ultimately pumped at the Central and Northern Pump Stations to the end of pipe treatment system and discharged through Northern Outfall 003. 2-6 In addition, groundwater that accumulates in the No. 1 Shear Electrical Vault is pumped to the storm sewer and ultimately pumped at the Central Pump Station to the end of pipe treatment system and discharged through Northern Outfall 003. Also, seasonally shallow groundwater is discharged from two sumps at the east end of the Rolling Mill (Shipping) to the storm drain system that is directed to the Northern Pump Station to the end of pipe treatment system and discharged through Northern Outfall 003. 3 Site Controls for Stormwater Pollution Prevention This section describes the appropriate stormwater pollution site controls that have been developed, implemented and maintained for the EOS Rivergate site. The purpose of these site controls is to minimize the amount of pollutants in stormwater discharged from the facility. 3.1 Stormwater Best Management Practices A variety of stormwater pollution controls, structural modifications and management practices have been implemented to minimize pollution of stomrwater runoff from the Evraz Oregon Steel - Rivergate site. Existing stormwater best management practices (BMPs) are described as follows: 3.1.1 Containment Topographic barriers prevent stormwater discharges from portions of the site (e.g., Drainage Basin F and H). Stormwater in these basins percolates into the ground. Drip pans, where feasible, are placed under equipment and vehicles to capture leaks. A containment pad for fueling is engineered and installed to contain a large release of fuel (gasoline, diesel and kerosene). The fueling containment pad is designed with an oil/water separator and discharges to the sanitary sewer system. Hazardous substances are stored as required within berms, or other secondary containment devices (indoor storage areas and buildings) to prevent leaks and spills from entering the storm drain system. Discharges from the sandblasting and steam cleaning area east of the Maintenance Building are collected and treated through an oil/water separator prior to discharge to the City sanitary sewer. The main substation (South of the Melt Shop) has an engineered liner and berm system that prevents transformer releases from this area entering the storm drain system. 3.1.2 Oil and Grease Petroleum products and spent or recyclable petroleum materials are contained, labeled, stored and managed in designated areas. There are no routine operations in exposed areas where oil/water separators, booms or skimmers are needed to manage oil and grease residues to the storm drain system. 3-7 The end-of-pipe treatment system installed just up the pipe from Northern Outfall 003 includes a clarification basin. The clarification basin consists of three partitioned sections of an earthen basin. Each of the partitioned sections is equipped with a hard boom as a preventative measure to capture any petroleum prior to discharge in the event of release of oil to the storm sewer system. In addition, at the southern end of the third partitioned section of the clarification basin, prior to discharge to the Northern Outfall 003 there is installed a "goose neck" oil/water separator system. 3.1.3 Waste Chemicals and Material Disposal Wastes and recyclable materials (e.g., used oil, water treatment solids, antifreeze) are properly contained and stored in designated areas. Wastes and chemicals are managed according to State and Federal regulations. 3.1.4 Debris, Erosion and Sediment Control An end-of-pipe treatment system has been installed up the pipe from the Northern Outfall 003 to collect and treat stormwater runoff from Drainage Basins A, B, C, D and E. Stormwater accumulation in lift station sumps at the end of drainage basins A, B, C, D and E activates submersible stormwater pumps which send the water to the treatment system. The Central and Northern Pump Stations deliver stormwater to the north end of the clarification basin at a constant rate. Chemical metering pumps activate simultaneously and inject chemical coagulant into the stormwater as it passes through the system. The coagulant and stormwater combine in the delivery pipe between the injection point and the point at which the amended stormwater discharges to the north end of the clarification basin. The clarification basin consists of three partitioned sections of an earthen basin. The basin provides hydraulic retention of >30 minutes at the maximum lift station pumping rate. This allows for sufficient settling of suspended solids prior to discharge through the Northern Outfall 003. Over-dosing of treatment chemical cannot occur because the treatment chemical is metered at a constant rate and is injected only during a storm event when the lift station pumps are activated. At the southern end of the third partitioned section of the clarification basin, prior to discharge to the Northern Outfall 003 there is installed a "goose neck" oil/water separator system. Where economically feasible, road surfaces are paved. This prevents soil erosion and transport into the storm sewer system. All paved areas are inspected and mechanically swept routinely to prevent excessive buildup of soil tracked or wind-blown onto the pavement from adjacent unpaved surfaces. Unpaved areas are wetted during extended dry periods to control dust formation and transport. Storm drain inlets (catch basins) are inspected and cleaned as needed, based on results of monthly drainage inspections. Fabric filters are used where necessary to reduce sediment intake. Vegetated swales have been incorporated into the employee parking area Drainage basin G. A vegetated swales and sand filter treats stormwater from Drainage Basin I. An infiltration basin collects stormwater from Drainage Basin H and does not discharge to any outfall. 3-8 3.1.5 Stormwater Diversion Manufacturing operations are performed in buildings which prevents direct contact with potential pollutants. The small petroleum fueling pad near the southeast comer of the Rolling Mill Shipping Bay is plumbed to an oil/water separator before discharge to sanitary sewer to prevent releases from entering the stormwater system. Wash water from steam cleaning and sandblasting operations at the Maintenance Building is collected, pretreated, and discharged to City sanitary sewer under Industrial Wastewater Discharge Permit number 300.008. 3.1.6 Covering Activities Most manufacturing and maintenance operations are conducted inside buildings. Roof coverings have been constructed at several areas throughout the facility: • Oil storage area at the north side of the maintenance shop • Oil recycling area at the Rolling Mill scale pit. Oily or greasy equipment items are stored under cover. If these materials must be stored outdoors, they are kept covered when practical and feasible. Hazardous substances and recyclable materials are stored indoors or in closed containers. 3.1.7 Good Housekeeping Practices Paved areas of the site (mainly roads) are routinely swept using a powered mobile sweeper to reduce the potential for pollutant loading to the storm sewer. Spills and leaks around the site are promptly addressed (see Section 3.2). A vehicle and mobile equipment maintenance program is implemented. Most routine maintenance is performed on site inside the Maintenance Shop (see Section 3.3). Dry methods (e.g., sweeping or vacuuming instead of washing) are used in maintenance areas for cleaning in areas where stormwater could be impacted. Trash receptacles (dumpsters) are located throughout the facility to minimize accumulations of litter and debris. EOS maintains a recycling program for recyclable materials such as paper, cardboard and wood and scrap metal. 3.2 Spill Prevention and Response Potential causes of spills or leaks at the Rivergate facility could include equipment or vehicle leaks, container failures, and materials handling activities. Frequent inspections of storage areas, manufacturing/process areas, regular equipment and vehicles maintenance and an education program, reduce the likelihood for spills and help ensure that identified spills are cleaned up immediately before entering the storm drain system. Emergency spill kits are located throughout the Plant. In the event of a spill, these kits are available for spill cleanup and to prevent the spill from reaching the storm drain system. In addition, large quantities of absorbent materials are kept in stock at the stores 3-9 warehouse. Outside contractors are utilized when necessary for incidents that need additional assistance or expertise. The Central and Northern Pump Stations deliver stormwater from a majority of the facility to the north end of the end of pipe treatment system clarification basin. The clarification basin consists of three partitioned sections of an earthen basin. Each of the partitioned sections is equipped with a hard boom as a preventative measure to capture any petroleum prior to discharge in the event of release of oil to the storm sewer system. In addition, at the southern end of the third partitioned section of the clarification basin, prior to discharge to the Northern Outfall 003 there is installed a "goose neck" oil/water separator system. Small or de nv'ninnis oil releases that do not pose a known and verifiable threat to surface waters (i.e. small areas of stained gravel in vehicle or equipment storage areas) are addressed when practical and subject to the judgment of on-site personnel. EOS will continue to evaluate and implement measures to eliminate or minimize the number and extent of these minor or de mminnis releases. Oregon Revised Statute 465.605(10) requires notification of a spill of a reportable quantity on land of one barrel (42 gallons) or any quantity of oil that would produce a visible sheen on navigable waters of the state. If a spill occurs that meets the reportable criteria, regulatory authorities (DEQ, US Coast Guard, EPA and City of Portland) are notified of the incident. EOS maintains on site procedures used for cleanup and notification of spills. These procedures are described in Appendix A. 3.3 Preventive Maintenance Measures A preventive maintenance program is implemented at the Rivergate facility and involves the regular inspections, cleaning, and any necessary repair of equipment and stormwater management structures, along with other activities that reduce the likelihood of spills and leaks including: 1. Monthly inspections of areas where there is a potential for materials or industrial activities could impact the storm water system. Sample copies of the stormwater inspection forms are located in Appendix B. 2. Monthly inspections of storm water control systems including the end of pipe treatment system, vegetated swales, sand filter system, storm water catch basin system. Sample copies of the stormwater inspection forms are located in Appendix B. 3. Periodic maintenance (cleaning, catch basin filter replacement, pump inspections, structural repairs) is performed on the various storm water treatment system infrastructures. Frequency is determined by results of inspections or as needed upon discovery. All periodic maintenance is performed in a manor as to prevent discharges of pollutants. 3-10 3.4 Employee Education and Training EOS educates and trains operating and maintenance personnel (and supervisors) on the importance and benefits of stormwater pollution prevention, elements of the SWPCP, and spill prevention and response procedures. Training occurs when an employee is initially hired and annually there after. Site tenants also receive regular storm water training and a copy of this plan. A typical EOS stormwater training plan is outlined in Appendix C. Training addresses actions and conditions that cause stormwater pollution, effective implementation of the control measures presented in this plan, proper inspection, handling, and storage procedures to prevent stormwater pollution, applicable inspection and maintenance programs and spill response procedures. Information related to stormwater pollution prevention is also presented, as appropriate, at departmental meetings. Training records are maintained at the environmental office. 4 Record Keeping and Internal Reporting Procedures This SWPCP, all inspection and site compliance evaluation records, related training records, records of spills and corrective action, preventative maintenance records and monitoring results will be retained at the facility as required. Reporting activities will include tabulating sampling data and submitting a report to the DEQ Northwest Regional Office and the City of Portland Bureau of Environmental Services on approved forms by July 15 of each year. These records maintained on site in accordance with applicable record retention policies and will be made available, upon request, to DEQ or authorized representatives of the DEQ i.e. the City of Portland. 4-11 0» a- ® w Table 1. Identification of Potential Pollutants Activities with Potential Significant Materials with a Storm Water Facilities Exposure to Stormwater Potential Exposure to Stormwater Potential Pollutants Outfall(s) Rolling Mill Steel Product Manufacture, Petroleum Products, Steel Products TSS, Metals, TPH 003 Storage, Equipment Use Mill Scale, slag Cut-To-Length Truck/Rail product loading Steel Products, slag TSS, Metals 003 Equipment use Shipping Truck/Rail product loading Steel Products TSS, Metals 003 Equipment use Surface Processing Crane Operation, Plate Coating Steel Products, Coatings TSS, Metals 002 Steel Product Management Pipe Mill Steel Product Manufacture, Steel Products, Spent Flux Metals,TSS 001 and 002 Storage, Equipment Use Maintenance Equipment and Vehicle Fueling, Petroleum Products, TSS, Metals, TPH 00 land 002 Steam Cleaning, Sand Blasting, Sand Blast Media, Chemicals from Equipment Maintenance and Equipment Maintenance Activities. Storage TSS - Total Suspended Solids TPH - Total Petroleum Hydrocarbons Page 1 of 1 Figures File: H:\18713\18713S137.dwg Layout: FIGURE 2-1 User: astenberg Plotted: Jan 27, 2006 - 11:1 Sam Xref's: ^ / -a _ s y ^ -. ^ <--s. . ' IIs ^H.*^-^^--; l/L/^t'",, 1 -t YA t> ""•'-. § f? I /~^ II 4- I S Li__-^.^ _____ L S 3 BOWIDARY ~S~~~~-^ 3 LEGEND CATCH BASIN BOUNDARY MEAN HIGH WATER LEVEL 9.6ft NGVD RAILROAD STORM DRAIN SYSTEM SWALE DRAINAGE FLOW DIRECTION ^3 BUILDINC/STRUCTURE EXISTING/PROPOSED PAVEMENT/CONCREJE AFiEA DRAINS TO COOLING POND VEGETATION r—i LANDFILL GRASS COVER 4- SAMPLE POINT * WATER WELL DRAINAGE BASIN SURFACE AREAS (ACRES) TSTH- TSTH- OBAINUSE TOTAL AREA BUILDINGS BASIN PAVEMENT IMPERVIOUS PERVIOUS 24.7 6.5 1.8 B.3 16.4 B 13.6 6.3 1.8 8.1 5.5 c 27.3 6.6 8.3 14.9 12. D' 15.5 6.7 1.68 8.38 6.9; E 20.3 0.1 0 0.1 20. F 14.1 0 0.4 0.4 13. G 1.8 0 1.06 1.06 0.7-' H 14.6 0.06 6.n 6.17 8.4; -S.2 0 2.15 2.2 1.0 TOTAL 135 2S 23 50 B5 • SPIRAL PIPE MILL BUILDING AREA - 240.300 ft*. ZOS OF SPIRAL PIPE MILL ROOF RUNOFF DISCHARGES TO NORTHERN OUTFALL 003 AND BOX DISCHARGES TO R1VERGATE OUTFALL 002. SURFACE AREA (ACRES) DRAINING T 0 EACH OUTFALL OUTFALL CENTRAL EMERGENCY RIVERGATE NORTHERN SURFACE 001 002 003 TOTAL PERVIOUS 0 1.2 63.2 64 IMPERVIOUS 0 8.2 33.6 42 VORTECHNICS"' AND STORMFILTER"' TOTAL 0 a 97 105 TREATMENT UNITS NOTE: BASINS F AND H (28.7 ACRES) DO NOT DRAIN TO OUTFALLS 1) RIVERGATE 002 INCLUDES BASINS G.l AND B07: OF PIPE MILL ROOF RUNOFF. 2) NORTHERN 003 INCLUDES BASINS A.B.C.D.E AND 203: OF PIPE MILL ROOF RUNOFF. PREPARED BY: T 'v~a~ CENTRAL AECOM PUMP / T / ZT STATION L/7 '^ FROM ^ EMPLOYEE rn PARKING fes? ^ ///' REVISION ^. // EVRAZ EVRAZ INC. NA FROM SURFACE EVRAZ FIGURE 2 I DO NOT SCALE DRAWING I 1 PROCESSING OREGON STEEL i •5/20/QS LAYOUT OF DRAINAGE BASINS PORTLAND LP/FTC AND STORMWATER SYSTEM INSET OF PIPING 137-550 ID-81943 — — CATCH BASIN BOUNDARY MEAN HIGH WATER LEVEL 9.6ft NGVD RAILROAD STORM DRAIN SYSTEM SWALE BUILOING/STRUCTURE DdSTINC/PROPOSED PAVEMENT/CONCRETE AREA DRAINS TO COOLING POND VEGETATION LANDFILL GRASS COVER SAMPLE POINT WATEFi WELL SURFACE RUNOFF FLOW DIRECTION NATURAL GAS METER/ DISTRIBUTION STATION PREPARED BY: AECOM ^=^2^—=y8 EVRAZ FIGURE 3 OREGON STEEL STORMWATER SURFACE AREA PORTLAND FLOW DIRECTION Appendix A Spill Notification and Response Procedures and Report Form APPENDIX A Spill Notification and Response Procedures Evraz Oregon Steel Incidental Releases of Petroleum Products Procedures Potential Spill Sources: • Delivery of gasoline, diesel, and kerosene fuel. • Use of ASTs and fueling equipment. • Electrical equipment leakage/failure. • Releases from motorized vehicles. • Hydraulic systems leakage/failure. • Release from drums and totes of petroleum products. Employee Responsibilities: Notify shift supervisor. Obtain proper personal protective equipment, if necessary. Cover storm and sewer drains if located in immediate spill area. Stop the source of the release. Contain the spill by use of proper materials. Clean up release immediately. Label drums containing cleanup debris. Keep an accurate log of actions taken for completing Spill Report Form. Inform Emergency Coordinator of actions taken. Refer inquiries from the press to the Emergency Coordinator. If the release cannot be handled by employees and becomes an emergency situation requiring additional assistance, contact the Emergency Coordinator IMMEDIATELY. Supervisor Responsibilities: Notify Environmental Department (Storm Water Pollution Prevention Team). Notify General Supervisor. Inform Environmental Department of actions taken. Assist where applicable with response actions. Keep an accurate log of actions taken for completing Spill Report Form (Appendix A). Refer any inquiries from the media (if inquires are made) to the upper management. Environmental Department (Storm Water PollutionJlrevention Team) Responsibilities: If necessary, immediately report incident to regulatory authorities. Utilize outside contractors if necessary to address the spill. Review Spill Report Form. Maintain contact with EOS Management. Refer any inquires from the media (if inquires are made) to upper Management. Compile any necessary reports and submit to regulatory authorities as required. Maintain spill report records as required Maintain necessary Storm Water Pollution Control Plans and Spill Prevention Plans. Notification Requirements and Reportable Quantities Evraz Oregon Steel Portland, Oregon Notify h % . 0 ISI^S-'•a ° •§ T ? pSlllSi 2'"3 S-Sog £1! Petroleum Product Any quantity that produces a visible sheen x x x on surface water If more than the reportable quantity is released, then notification procedures must be initiated. Other spills reportable quantities found in: 1) 40 CFR 117.3 -RQ 2) 40 CFR 302.4 - Hazardous Substances RQ Spill Report Form Instructions: This form is to be completed by the supervisor within 24 hours after incident. This information is necessary not only for a record of the event, but also to provide the data required to develop better spill control procedures. If more space is needed for an answer, please use additional paper. 1. Record date and time of the spill. 2. Describe weather conditions and state approximate temperature and precipitation status at time of spill and any significant changes. 3. Identify the substance spilled (i.e., diesel fuel, gasoline, motor oil, hydraulic oil, EAF dust, etc.). Estimate the volume in gallons for liquids and in pounds for solids. 4. Tell where the spill occurred, being as accurate as possible; use references to building, if applicable. 5. Explain the cause of the spill as thoroughly as possible, including employees and equipment involved. 6. Describe the type of surface the spill was on and estimate the dimension of the affected area. 7. Describe what was done to contain or mitigate the effects of the spill. List who participated in the cleanup and what cleanup actions were taken. 8. Describe the materials and volumes taken to disposal and give location and date of disposal. 9. Describe the extent of any injuries and how they came about. Describe any physical damage or loss. Were there emergency services used? 10. Print your name. Sign the form. OREGON STEEIUIUS SPILIINVESTIGBTIOH REPORT Contact Drew Gilpin or Debbie Deetz Silva (see numbers below) immediately when spills occur. ALL spills must be investigated and this written report submitted to the Environmental Department -PERSON REPORTING SPILL TO COMPLETE THIS PART OF FORM- NAME OF PERSON FILLING OUT THIS REPORT: DATE OF SPILL: TIME OF SPILL: _ D AM D PM WEATHER CONDITIONS AT THE TIME OF SPILL: MATERIAL SPILLED: QUANTITY SPILLED: SPILL LOCATION: CAUSE OF SPILL: AREA(S) AFFECTED (proximity to storm drain): AFFECTED EQUIP1VIENT (leaking equipment, hydraulics, hoses, product/vvaste containers) CORRECTIVE ACTIONS TAKEN: (Was the spill cleaned up? How? Were storm drains protected by booms? Were storm drains checked for contamination? Was leaking equipment fixed?) HOW WAS CONTAMINATED MATERIALS DISPOSED OF: NAME OF EMPLOYEE(S) INVOLVED: SIGNATURE of person filling out this report: _ DATE: Immediate Notification numbers are the following: DrewGilpin OSM ext. 978-6189 Debbie Deetz OSM ext. 978-6044 Cell # 503-784-2784 Cell # 503-539-2287 -AFFECTED S^^^^^ TO COMPLETE THIS PART OF FORM- WAS ENVRIONMENTAL NOTIFIED OF THE SPILL: U YES U NO WHEN WAS ENVIRONMENTAL NOTIFIED? DATE: TIME: D AM D PM YES I| NO Were there any injuries to employees in relationship to the spill? If YES explain: D YES D NO Did any of the spilled material enter a Storm Drain? If YES please describe: II YES II NO Were outside contractors services utilized to clean up the spill: (IMS, Spencer Env., FOSS) If yes please describe: Corrective action taken to prevent recurrence of this type of spill: Were any procedures or OSM policies violated that resulted in the spill? II YES II NO Signature: General Supervisor: Date Signature: Department Manager: Date —ENVIRONMENTAL DEFT. TO COMPLETE THIS PART OF FORM" YES D NO Were Regulatory Authorities Notified? If yes fill in the following: Name of Agency Phone Number Name of Person Contacted Date Contacted Time Contacted Oregon DEQ OERS NRC Other (describe) OTHER COMMENTS: Signature of Environmental Department;:ment: DATE: I:\Portland\WATER\Stormwater\Rivergate\SWPCP\SWPCP 4-2009\Appendices\Appd A Spill Report Form.doc Appendix B Example of Stormwater Site Control Inspection Forms Evraz Oregon Steel Mills - Stormwater Inspection Form: Swale, Infiltration Basin Heat Treat Facility Date: Inspector: Weather: North Side Swale West End East End Evidence of Significant Erosion (Y/N) Vegetation in Good Condition (Y/N) Swale Outlets Free of Obstructions (Y/N) Evraz Oregon Steel Mills - Stormwater Catch Basin Inspection Form Date: Inspector: Weather: Catch Basin ID | XXX XXX XXX XXX XXX XXX XXX XXX XXX Visually Inspected 0//N) I Service required fcheck all that aDDlv) Insert replacement) Solids removal I Surface regrading Catch Basin I D | XXX XXX XXX XXX XXX XXX XXX XXX XXX Visually Inspected 0//N) I Service required (check all that apDlv) Insert replacement] Solids removal I Surface regradingl Catch Basin I D | XXX XXX XXX XXX XXX XXX XXX XXX XXX Visually Inspected O^N)| Service required (check all that apDlv) Insert replacement] Solids removal I Surface regradingl Catch Basin I D I XXX XXX XXX XXX XXX XXX XXX XXX XXX Visually Inspected CI//N)| Service required (check all that apply) Insert replacementl Solids removal I Surface regradingl Evraz Oregon Steel Mills - Clarification Basin Inspection Form Date Inspector Weather Is there a sheen in the basin? (Y/N) Are there floating solids in the basin? (Y/N) Is Debris obstructing the outlet? (Y/N) Is water flowing through the oil/water separator? (Y/N/ or if no discharge, N/A) Is water overflowing the oil/water separator? (Y/N/ or if no discharge, N/A) Note any damage or anything out-of-ordinary observed COMMENTS: Evraz Oregon Steel Mills - Stormfilter Equipment Inspection Form Date Inspector Weather Months Media in Service Oil and Grease in Forebay fWN) Sediment Depth in Forebay (in.) Sediment Depth on Vault Floor (in.) StormwaterflowC^/N) Cartridges Submerged (Y/N) Overflow or Bypass Occurring (Y/N) Note any damage observed Evraz Oregon Steel Mills - Stormwater Inspection Form: Swale, Infiltration Basin Heat Treat Facility Date: Inspector: Weather: North Side Swale West End East End Evidence of Significant Erosion (Y/N) Vegetation in Good Condition (Y/N) Swale Outlets Free of Obstructions (Y/N) ATTACHMENT 1 FERROALLOY and the CUT-TO-LENGTH FACILITY STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection^ Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-CTL-1 outside Catch Basins SW-CTL-2 Dutside hydraulic systems, gear boxes, bearings SW-CTL-3 Dutdoor drip pans and containment equipment SW-CTL-4 Beneral spillage (other than petroleum) SW-CTL-5 3etroleum staining and releases SW-CTL-6 3ebris and trash, general housekeeping Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. ATTACHMENT 1 SCRAP PROCESSING STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection:. Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-DJJ-1 3utside hydraulic systems, gear boxes, bearings SW-DJJ-2 outdoor drip pans and containment equipment SW-DJJ-3 Seneral spillage (other than petroleum) SW-DJJ-4 3etroleum staining and releases SW-DJJ-5 debris and trash, general housekeeping Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. ATTACHMENT 1 MELT SHOP STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection:. Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-ST-1 Datch basins SW-ST-2 ^/lold resurfacing (Carter Day) baghouse SW-ST-3 Vacuum degasser SW-ST^l Southwest corner of Melt Shop building SW-ST-5 slab Yard areas SW-ST-6 3utside hydraulic systems, gear boxes, bearings SW-ST-7 3utdoor drip pans and containment equipment SW-ST-8 General spillage (other than petroleum) SW-ST-9 3etroleum staining and releases SW-ST-10 Debris and trash, general housekeeping Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. ATTACHMENT 1 ROLLING MILL STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection:. Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-RM-1 31d scale pit/Shear SW-RM-2 Mew scale pit SW-RM-3 Scrap conveyor area (outside) SW-RM-4 Dutside hydraulic systems, gear boxes, bearings SW-RM-5 Dutdoor drip pans and containment equipment SW-RM-6 Seneral spillage (other than petroleum) SW-RM-7 :>etroleum staining and releases SW-RM-8 3ebris and trash, general housekeeping SW-RM-9 ^atch Basins at Gas/DieseI Fueling Pad Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. ATTACHMENT 1 CENTRAL SHOP / UTILITIES DEPARTMENT STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection: Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-CSU-1 311/water separator and steam clean area SW-CSU- 2 Jsed oil storage (north side Shop) SW-CSU- 3 Dutside hydraulic systems, gear boxes, bearings SW-CSU-4 3utdoor drip pans and containment equipment SW-CSU- 5 Seneral spillage (other than petroleum) SW-CSU-6 :>etroleum staining and releases SW-CSU-7 Debris and trash, general housekeeping Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. ATTACHMENT 1 SURFACE PROCESSING DEPARTMENT STORMWATER POLLUTION CONTROL INSPECTION Date of Inspection^ Inspector Signature: Status Reference Inspection Not Number Area OK Deficient Applicable SW-SPD-1 3PD baghouse SW-SPD-2 spent shot storage bin SW-SPD-3 Dutside hydraulic systems, gear boxes, bearings SW-SPD-4 3utdoor drip pans and containment equipment SW-SPD-5 Seneral spillage (other than petroleum) SW-SPD-6 3etroleum staining and releases SW-SPD-7 Debris and trash, general housekeeping Important: Ensure that if you note "Deficient" you provide a description of the issue noted on Attachment 4, complete with reference number, and corrective action, if applicable. Euraz Oregon Steel - Bivergate ]Vlonthly Storm Drain Outfall Inspections: Monthly Visual Monitoring will be conducted while discliarging occurs (during a storm event). Was Storm Water Floating Solids Oil & EOS discharging (associated with Grease Date of Initials of Outfall Location: during the industrial activities) Sheen Inspection Inspector inspection? (Y/N) (Y/N) (Y/N) Central End of pipe on riverbank Emergency west of Hand Outfall Scarfing 001 Tables Open trench piping in Rivergate manholejust Outfall 002 west of employee parking exit End of pipe on riverbank Northern west of Cut Outfall 003 to Length and NW of curve in Haul Road Comments: Monthly inspections of the storm drain system will include visual inspections of storm water catch basins as appropriate. Each month, selected catch basins will be inspected. Routine cleaning and maintenance will be scheduled, where appropriate based on inspections. Floating Solids Oil & Grease Location Description (associated with Date of Initials of Catch Basin Area Sheen and/or Number: industrial activities) Inspection Inspector (Y/N) (Y/N) Plate Mill (PM) Plate Mill (PM) Shipping (SH) SPD (SP) Melt Shop (MS) Melt Shop (MS) Utilities (U) Admin. (AD) l:\Portland\WATER\Stormwater\Rivergate\SWPCP\SWPCP 4-2009V\ppendicesV\ppd B Outfall Visual Montirong.doc Comments: l:\Portland\WATER\Stormwater\Rivergate\SWPCP\SWPCP 4-2009V\ppendicesV\ppd B Outfall Visual Montirong.doc Appendix C Example of Stormwater and Spill Prevention Training Outline 'OREBOW SnSM. MIUS Portland Steelworks STORM WATER AND ENVIRONMENTAL TRAINING 1) Stormwater Permits • Congress passed Clean Water Act in 1972. This law later required industrial sources of stormwater runoffto get permits for stormwater discharge to surface water like the Willamette River. • OSM has three permits for stormwater discharge: one each for PSW, Heat Treat; and CST. 2) Storm Water Pollution Control Plan (SWPCP) Our stormwater discharge permits require us to keep a stormwater pollution control plan. This plan is available for employees to review and the environmental department encourages you to do so. The plan includes: • Description of the facility • Types of potential Storm Water pollutants • Description and drawings of the facilities storm drain system • Facility storm water controls • Monitoring procedures and • Best Management Practices (BMPs) 3) Stormwater Outfall Monitoring The Environmental Department collects Storm Water Samples and conducts required monitoring. We analyze the water for several pollutants. If we find there is an exceedance of the state benchmarks for a pollutant, we review our stormwater plan and take appropriate action. 4) Controls Stormwater discharge controls come in two categories: Engineered controls and Best Management Practices (BMPs). The Environmental Department coordinates Engineering Controls, but it is up to ALL EMPLOYEES to ensure you practice BMPs on a daily basis while you work. Engineering Controls Best Management Practices (BMPs) » Berms or curbs around hydraulic , Inspect catch basins around your rooms work site. IF YOU SEE » Paving projects ANYTHING OTHER THAN » Catch basin improvement RAINWATER, CONTACT Projects YOUR SUPERVISOR » Other projects that improve or ^ Use containment for oil, fuel, or protect stormwater quality, hazardous material. » CONTACT ENVIRONMENTAL , HOUSEKEEPING ^YOU.HAVEANYIDEAS . Use Drip Pans FOR AN ENGINEERING : ^ CONTROL INYOU'R AREA - ^^M^ge,m!nt^.^ » REPAIR leaking equipment ASAP and report any spills. 5) Spills and Cleanups • Stop the leak • Contain the spill/clean up spill • NOTIFY YOUR SUPERVISOR - do not hide the spill, no matter how small. • Fill out spill report. 6) Waste material & LABELING (Non-Hazardous) as to contents: • oil & grease; • absorbent materials (pads, socks kitty litter); Note: greasy, oily rags and gloves can also be put with spent absorbent material. • grease bags; • oil filters; • oily debris; • skimmer pond liquids (bulk recycling, ie pumped); • water treatment wastes (bulk disposal) • surface processing paint wastes • woody debris, pallets, used RR ties, and oily soil are disposed of in bins near the old IMS building (now the PSW gym). 7) AIR Discharge Permit Operations in the pipe mill, plate mill, CST, heat treating, and coating facilities discharge air pollutants such as dust and gasses into the air. These operations are permitted under various federal and state air permits. These permits allow us to release the permitted amount of each pollutant under certain conditions, including the proper operation of air pollution control devices when they are in place. It is every employees responsibility to NOTIFY YOUR SUPERVISOR and ENVIRONMENTAL IF: • You see thick smoke from plant operations (except from mobile equipment - forklifts, trucks, etc.). • You notice that a control device (i.e. baghouse, cyclone, thermal oxidizer) is not working properly, a bag is broken (on a baghouse), or is disconnected. Wednesday, January 7 - Regular meeting, 8:30 a.m. to 4:30 p.m. • Portland, DEQ headquarters, 811 SW 6th Avenue o Meeting space: EQC-A, meals/break space: EQC-B SRifflSS WtSBKI |liFe|sent^i'(f)| |Bai|8| 9:45 Action item: Bond sale authorization Jim Roys and Jim Harris Item taken out of order - Proposed approval 15 min for authorization to engage in a bond sale for the Clean Water State Revolving Fund loan program 10 K Informational item: Budget and legislative Jim Roys, Greg Aldrich and Palmer Item taken out of order - Updates about state 90min updates Mason and federal legislative and budget matters of interest to the commission 11:30 Action item: Budget certification Jim Roys Item taken out of order- The commission 5 min must certify DEQ's budget before submittals to the state's Department of Administrative Sem'ces. MSKiElBM 12:30 p.m. D Action item: Title V proposed fee increase Jerry Ebersole Proposed fee increase for Title V permits 30min 1 Informational item: Air quality permitting Jill Inahara Information about proposed rule revisions in 60 min program updates and rule revisions early 2015 that will update the air quality permitting program. iliSSSB 2:15 Action item: Clean Fuels Program Phase David Collier and Cory-Ann Wind Proposed action for Phase 2 rules of the Clean 60 min 2 proposed rules Fue/s Program. 3:15 Informational item: Director's report Director Pedersen Director Pedersen will present written and 60 min verbal updates on agency, state and federal matters of interest to the commission 4:15 H Informational item: Commissioner reports Commissioners will present verbal updates UPDATED 12/30/14 - Contact: Stephanie Caldera: 503-229-5301 Time Item Topic Presenters) Background 15 min about their activities of interest for the commission and DEQ ;4:30;'p,,rn.T..-"^ ^RecessfuntilTHur6day,Jan.8,2p15 5:30^.^ Optibnah Social dinnerfor -LGrafi^;ZBZ^l^agi^^Ep%»7c^ 'coinmissioners^and.staTf v ; Thursday, January 8 - Regular meeting, 9 a.m. to 1 p.m. • Portland, DEQ headquarters, 81 1 SW 6th Avenue o Meeting space: EQC-A, meals/break space: EQC-B n'ihne.U^' Item ^T6picy-¥:,(,'.;..X:.''^'-^ ^&,;9Prcsenter(s) . . •- :*ft1'tBacRground-t^'»^m»^: 8a.m. Pre-meeting light breakfast for commissioners 9 I Public forum With conference line connections at the 60 min Medford and Bend DEQ offices 10 c Informational item: Total Dissolved Gas Gene Foster and Paula Calvert, DEQ, Item taken out of order - Informational item 105 min standard modification for the U.S. Army with a panel of guests from the U.S. Army regarding requested standard modification for Includes a Corps of Engineers Corps of Engineers, Bonneville Power total dissolved gas at four lower Columbia 15-minute Administration and Fish Passage Center River dams operated by the Corps for fish break as passage and spill season 2015-2020 needed 11:45^.m; adjourn public^meeting t1:45'^i:' -/ya Lunch :SmdaexecUtivesession .75 Next meeting: April 15-16, location to be determined UPDATED 12/30/14 - Contact: Stephanie Caldera: 503-229-5301