FIFTH FIVE-YEAR REVIEW REPORT FOR ALLIED PLATING, INC. SUPERFUND SITE MULTNOMAH COUNTY, OREGON

PREPARED BY U.S. Environmental Protection Agency Region 10 Seattle, Washington

Approved by: Date Ai @f#- Sheryl Bf:/:!;, Director r 1 Office of Environmental Cleanup Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ...... 5 I. INTRODUCTION ...... 6 Site Background ...... 6 FIVE-YEAR REVIEW SUMMARY FORM ...... 9 IL RESPONSE ACTION SUMMARY ...... 9 Basis for Taking Action ...... 9 Response Actions ...... 10 Status of hnplementation ...... 11 Systems Operations/Operation & Maintenance ...... 14 III. PROGRESS SINCE THE PREVIOUS REVIEW ...... 14 IV. FIVE-YEAR REVIEW PROCESS ...... 14 Community Notification, Community Involvement and Site Interviews ...... 14 Data Review ...... 14 Site Inspection ...... 14 V. TECHNICAL ASSESSMENT ...... 15 QUESTION A: Is the remedy functioning as intended by the decision documents? ...... 15 QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of the remedy selection still valid? ...... 15 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ...... 16 VI. ISSUES/RECOMMENDATIONS ...... 17 VIL PROTECTIVENESS STATEMENT ...... , .. 17 VIII. NEXT REVIEW ...... 17 APPENDIX A- REFERENCE LIST ...... A-1 APPENDIX B - SITE CHRONOLOGY ...... B-1 APPENDIX C- SITE MAPS ...... C-1 APPENDIX D-PRESS NOTICE ...... D-1 APPENDIX E- INTERVIEW FORMS ...... E-1 APPENDIX F - SITE INSPECTION CHECKLIST ...... F-1 APPENDIX G- SITE INSPECTION PHOTOS ...... G-1 APPENDIX H - SCREENING-LEVEL RISK REVIEW ...... H-1

Tables

Table 1: hnpoundment Soil COC Cleanup Goals ...... 10 Table 2: Summary of Planned and/or hnplemented Institutional Controls (!Cs) ...... 12 Table 3: Protectiveness Determinations/Statements from the 2013 FYR Report ...... 14 Table B-1: Site Chronology ...... B-1 Table H-1: Industrial Risk Review - Cleanup Goals in hnpoundment Area ...... H-1 Table H-2: Residential Risk Review - Cleanup Goals in Impoundment Area ...... H-1 Table H-3: Residential Risk Review - Maximum Concentrations Post-Removal in hnpoundment Area ...... H-1

3 Table H-4: Maximum Metals Concentrations in the Layout Area ...... H-2

Figures

Figure 1: Detailed Site Map ...... 8 Figure 2: Institutional Control Map ...... 13 Figure C-1: Site Vicinity Map ...... C-1

4 LIST OF ABBREVIATIONS & ACRONYMS

ARAR Applicable or Relevant and Appropriate Requirement ATCM Airborne Toxics Control Measure CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations coc Contaminant of Concern DEQ Department of Enviromnental Quality EPA United States Environmental Protection Agency FYR Five-Year Review HQ Hazard Quotient IC Institutional Control mg/kg Milligrams per Kilogram NA Not Available NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PFAS Perfluoroalkyl Sulfonate ppm Parts per million PRP Potentially Responsible Party RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROD Record of Decision RPM Remedial Project Manager RSL Regional Screening Level UU/UE Unlimited Use and Unrestricted Exposure

5 I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the enviromnent. The methods, findings and conclusions of reviews are documented in FYR reports such as this one. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them.

The U.S. Enviromnental Protection Agency (The EPA) is preparing this FYR pursuant to the Comprehensive Enviromnental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 Code of Federal Regulations (CFR) Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fifth FYR for the Allied Plating, Inc. Superfund site (the Site). The triggering action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of one operable unit (OU), which is the focus of this FYR. OU! addresses contaminated soil, sludge, surface water and groundwater.

The EPA remedial project manager (RPM) Joe Wallace led the FYR. Participants included Sarah Miller from the Oregon Department of Enviromnental Quality (DEQ) and Sarah Alfano and Alison Cattani from Skeo (the EPA support contractor). The review began on 11/13/2017.

Site Background

The 12-acre Site is part of an industrial and commercial district in northeast Portland, Oregon (Figure C-1). Allied Plating operated a chrome-plating facility at the Site between 1957 and 1984. For over 25 years, the company discharged untreated wastes into an unlined impoundment on site. Plating activities and waste disposal practices contaminated groundwater, surface water, sludge and soil with heavy metals and other hazardous chemicals. The EPA proposed the Site for listing on the Superfund Program's National Priorities List (NPL) in January 1987 and listed the Site on the NPL in February 1990.

There are three main areas that make up the Site: former administrative and storage buildings, the former layout area (the location of the former plating operations building and storage yard), and the impoundment area, which is located in a low-lying area of the Site (Figure I). The Site slopes slightly to the north and the early 1960s drained into the Columbia Slough (Slough), which is located 1,000 feet west of the Site (Figure C-1). Fill activities after 1969 altered the topography and drainage patterns, which caused waste to collect in the impoundment area pond. The impoundment area pond was approximately 3 feet deep. The former impoundment area pond was removed during a removal action (water and sediment base) and backfilled with quarry spalls. Although an additional five to IO feet of fill and additional partial paving has been completed to create a parking lot over the impoundment area, standing watff is occasionally present, since the area remains below surrounding grade. A combined sewer overflow pipeline runs in a northerly direction under the impoundment area to an outfall in the Slough.

The Basic Fire Protection Company, which makes and installs fire prevention sprinkler systems, currently operates on eastern portion of the former administrative area. A freight shipping and hauling company, 5 Star Hauling LLC, uses the western portion of the former administrative area for storage and vehicle parking. The Pacific Coast Fruit Company operates in the former layout area. The former impoundment area is used for truck storage. The Site, which is zoned for industrial uses, is adjacent to industrial and manufacturing businesses to the north, west and east, an apartment building to the southwest, and a hotel and restaurant to the south. The nearest surface water body is the Slough, which merges with the Willamette River and then the Columbia River (Figure C-1). A single unconfined aquifer, the Troutdale Aquifer, is located beneath the Site at about 10 feet below mean sea level; it flows to the northwest. A localized perched shallow aquifer was found above the Troutdale Aquifer

6 beneath the impoundment area only. Drinking water is provided by the City of Portland and does not originate from the site vicinity. Appendix A lists additional resources used in preparation of this FYR Report. Appendix B provides the Site's chronology of events.

7 Figure 1: Detailed Site Map

0 100 200 400 Legend Feet D Approximate Site Areas Sources: Esri, Digita/G/obe, GeoEye, Earthstar Geographies, CNES/Airbus OS, USDA, USGS, AEX, Ge/mapping, Aerogrid, /GN, /GP, swisstopo, the GIS User Community, the 1993 ROD and Figure 2 of the 2013 FYR

() Allied Plating, Inc. Superfund Site NORTH City of Portland, Multnomah County, Oregon

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for infonnational purposes only regarding THE EPA's response actions at the Site.

8 FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION Site Name: Allied Plating, Inc. EPA ID: ORD009051442 Region: 10 State: OR City/Connty: Portland/Multnomah

SITE STATUS

NPL Status: Final Mnltiple OUs? Has the Site achieved constrnction completion? No Yes

REVIEW STATUS

Lead agency: The EPA

Author name: Joe Wallace, with support provided by Skea

Author affiliation: EPA Region I 0 Review period: 11/13/2017 - 9/17/2018 Date of site inspection: 12/14/2017 Type of review: Statutory Review number: 5 Triggering action date: 9/17/2013 Due date (five years after triggering action date): 9/17/2018

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

In 1984, after Allied Plating stopped discharging liquid waste, the impoundment area pond receded, leaving a dry area covered with plating waste. In September 1984, The EPA and Oregon DEQ jointly requested closure and post-closure plans from the current site owner as part of a requirement of a Resource Conservation and Recovery Act (RCRA) permit. In November 1986, The EPA and Oregon DEQ reached an agreement that transferred program jurisdiction from RCRA to Superfund.

In November 1990, The EPA began field work for the Site's remedial investigation (RI). The RI evaluated contamination resulting from the direct discharge of wastewater or dumping of wastes, and the dispersal of these contaminants through the groundwater. The 1990 RI results indicated that site-related groundwater contamination was no longer present in the Troutdale Aquifer above background levels. Manganese was detected above background levels; however, it is not associated with plating operations at the Site. Manganese is prevalent upgradient and downgradient of the Site and is an area-wide problem. One well screened in the shallow perched

9 aquifer beneath the impoundment area exceeded the nickel MCL for drinking water, however, the MCL for nickel was later remanded in 1995. 1 The risk assessment for the Site determined the localized perched aquifer was not a potential drinking water aquifer and it was not included in the future risk assessment conducted as part of the 1990 Rl.

Soil concentrations in the former layout area exhibited relatively low levels of contamination and were well below the industrial remediation standards. For a residential scenario using conservative assumptions, hazard quotients 4 (HQs) were less than 1 and carcinogenic risk was less than Ix 10 . The EPA considers soil in this area to be safe for unrestricted use.

Rl results indicated that site contamination was primarily limited to the impoundment pond area, and a risk assessment determined that the impoundment area was solely responsible for the unacceptable risks associated with the Site through exposure via direct contact and/or ingestion of impoundment area soil, sediment, groundwater and surface water. Contaminants of concern (COCs) include antimony, arsenic, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, nickel and cyanide for soil, and manganese for groundwater. The majority of the risk was associated with antimony, arsenic, copper and nickel.

Response Actions

The Site was evaluated for a potential removal action as part ofthe Superfund Accelerated Cleanup Model Program. After consideration of this evaluation and otherpotential cleanup options, The EPA determined that remediating the impoundment area as a pre-Record of Decision (ROD) removal action was the preferred option. The EPA signed an Action Memorandum in October 1992. The EPA selected risk-based cleanup levels for the impoundment area based on industrial use (Table I). The goal of the removal action was to clean up the Site so that the hazard index would be less than or equal to I, and the excess cancer risk would be less than or equal to 1 x I 04 for the industrial use scenario.

Table 1: Impoundment Soil COC Cleanup Goals coc Removal Action Cleanup Goal (mg/kg)* Antimonv 200 Arsenic 150 CoMer 20,000 Nickel 10,000 Notes: mg/kg - milligrams per kilogram *=cleanup levels were set at¼ of the individual contaminant values equal to a hazard index of 1 (these values were lower than those corresponding to the acceptable cancer risk). The rationale for this approach was that the cleanup would result in a hazard index that, at most, would be 1 (4 x 1/4), assumino an additive effect from the chemicals.

The EPA selected "No Further Action" for the Site's final remedy in the Site's 1993 ROD. The EPA made its decision based on the following information:

• The removal action remediated the impoundment area to below I x I 04 cancer risk and a hazard index of 1 for an industrial use scenario and The EPA expected site usage to remain industrial in the future. • The results of the Rl and risk assessment indicated that all other site areas were below I x I 04 cancer risk and a hazard index of I for all scenarios.

1 Details of the remand can be found in the June 29, 1995, Federal Register (60 FR 33929).

10 • Site-related groundwater contamination was present in one well; nickel was above the drinking water standard at that time.2 The well was screened in the shallow perched aquifer in the vicinity of the impoundment area. The concentration of nickel was expected to drop when the source of contamination was removed (the plating waste). No one is currently drinking the water, and the deed restriction should prevent future use of the groundwater. • Although the manganese in the Troutdale groundwater aquifer poses a potential health threat, the contaminant is widespread in the groundwater in the area and is not related to contaminants originating at the Site.

The ROD indicated that FYRs will be conducted to ensure that site land uses remain industrial.

Status of Implementation

The removal action was completed in November 1992. During the removal action, the impoundment area pond was drained and about 900 tons of contaminated sediment and soil were excavated and disposed of offsite in a hazardous waste landfill. The impoundment area was backfilled with 1 foot of quarry rock and compacted. The impoundment area remained below the surrounding grade, allowing water to accumulate at the lowest point.

Following the removal action, under direction from the EPA, the site owner placed a deed restriction on the former impoundment area to prevent the use of a well for drinking water unless the top of the screened interval is deeper than 20 feet below mean sea level, and the water from the well is tested to ensure tl1at it meets drinking water standards before use.

Since the ROD selected No Further Action for the Site's final remedy, there were no associated implementation activities. The EPA deleted the Site from the NPL in November 1994. With the exception ofFYRs, The EPA has not conducted any activities at the Site since the removal action.

Institutional Control (IC) Review

The June 1993 No Action ROD noted that a deed restriction was placed on the former impoundment area parcels to preclude use of groundwater in April 1993. The objective of the institutional control was to ensure that wells would not be screened in the shallow aquifer zone. The restriction prohibits the use of a well for drinking water unless the top of the screened interval is deeper than 20 feet below mean sea level, and the water from the well is tested to ensure that it meets drinking water standards before use. The deed was located as part of this FYR and the restriction was confirmed to be in place. The 1992 Action Memorandum indicated that a deed restriction would be placed on the Site so that site use remains industrial. The impoundment area is in an area currently zoned for industrial uses3 and its current use is industrial.

2 The EPA remanded the maximum contaminant level for nickel on February 9, 1995. 3 The City of Portland has zoned the Site as heavy industrial (IH) as part of city planning and development standards. 11 Table 2: Summary of 1993 Implemented Institutional Controls (ICs) Media, Engineered Controls, and Areas !Cs Called That Do Not !Cs for in the Impacted IC Title ofIC Instrument Support UU/UE Needed Decision Parcels Objective Implemented and Date Based on Current Document Conditions

Impoundment Area (Parcel Deed restriction, numbers Prevent use of the April 1993 Groundwater Yes Yes R512506730 shallow aquifer. (verified December 2017) and R512507050)

lmpoundment Currently zoned for heavy Area (Parcel Ensure the Site numbers industrial use by the City Soil Yes Yes remains zoned for of Portland (zoning code R512506730 industrial use. IH, Chapter 33.140, and verified November 2017) R512507050)

12 Figure 2: Institutional Control Map

0 100 200 400 Legend Feet [:=] Approximate Parcel Boundaries Sources: Esri, Digita/G/obe, GeoEye, Earthstar ~ Area Covered by Groundwater Use Restriction Geographies, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, /GN, /GP, swisstopo, the G/S User Community, the 1993 ROD and Figure 3 of the 2013 FYR.

() Allied Plating, Inc. Superfund Site ~Skeo· NORTH City of Portland, Multnomah County, Oregon

Disclaimer: This map and any boundaty lines within the map are approximate and subject to change. The map is not a survey. The map is for infonnational purposes only regarding the EPA's response actions at the Site.

13 Svstems Operations/Operation & Maintenance (O&M)

Beyond ensuring that the institutional controls remain in place, there are no O&M activities associated with the Site.

III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determination from the previous FYR.

Table 3: Protectiveness Determinations/Statements from the 2013 FYR Report Protectiveness .. OU# Protectiveness Statement Determination The remedy remains protective of Site wide Protective human health and the enviromnent.

There were no issues and recommendations in the previous FYR.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Communitv Involvement and Site Interviews

A public notice was made available by a newspaper posting in The Oregonian on 12/13/2017 (Appendix D). It stated that the FYR was underway and invited the public to submit any comments to the EPA. The results of the review and the report will be made available at the Site's information repository, Portland State University Library, located at 1845 SW Park Avenue in Portland, Oregon (library).

During the FYR process, interviews were conducted to document any perceived problems or successes with the remedy that has been implemented to date. The interviews are summarized below and included in Appendix E.

Oregon DEQ representative Sarah Miller indicated that the remedy appears to be effective for human exposure. However, she stated that the storm water pathway should be evaluated to determine if any remaining contamination drains to the Columbia Slough via the on-site catch basins and storm water system.

The EPA interviewed two current site tenants. Neither tenant was aware of the former environmental issues at the Site and reported no effects on surrounding communities. Both individuals indicated that theft and trespassing have occurred.

Data Review No data have been collected at the Site since the previous FYR.

Site Inspection The site inspection took place on 12/14/2017. Participants included the EPA RPM Joe Wallace, Sarah Miller from Oregon DEQ, and Sarah Alfano and Treat Suomi from the EPA support contractor Skeo. A representative from Pacific Coast Fruit Company also participated in the site inspection. The purpose of the inspection was to assess the protectiveness of the remedy. Site visit participants met with a representative of the Pacific Coast Fruit Company, one of the two businesses that currently operates on site, to discuss its site operations and to tour the Site. Participants toured and photographed the former impoundment area, the former layout area, and the administrative and storage building area (now occupied by the Basic Fire Protection Company). The former impoundment area is now a truck storage area. This area had standing water and appeared to have poor drainage. The ponding was thought to have been from the last rain in the area, which had been a week or more before the site inspection. Other site areas were well maintained by current business operations on site. Discussions and

14 interviews were conducted with operators of current businesses at the Site including Pacific Coast Fruit Company and 5 Star Hauling. Current site uses are consistent with industrial use. Site inspection participants also met with staff at the Basic Fire Protection Company building but they did not complete an interview form.

After the site inspection, representatives from Skeo visited the information repository. Site records were not readily available at the library at that time. When contacted in March 2018, the newly hired govermnent librarian was able to locate information on the Site. The EPA will work with the librarian to make sure site documents are available to the community. The Site Inspection Checklist and photographs are provided in Appendix F and Appendix G, respectively.

V. TECHNICAL ASSESSMENT

QUESTION A: Is the remedy functioning as intended by the decision documents?

Question A Summary: Yes, the remedy is functioning as intended by the decision documents. Contaminated soils and sludge were excavated from the impoundment area during the pre-ROD removal action and the area was backfilled with quarry spalls and later with additional fill and compacted gravel, and was partially paved. The impoundment area was remediated to industrial use standards. Current and anticipated future land use and zoning at the Site is industrial. The 1992 Action Memorandum indicated a deed restriction would be used to ensure industrial uses on site in the future. However, the deed restriction was not a requirement in the 1993 ROD, which indicated that the FYRs and zoning regulations would ensure that site uses remain industrial. The site is currently zoned industrial.

A groundwater use restriction is in place for the impoundment area and appears to be functioning as intended. There are no drinking water wells in the impoundment area. The Site was observed to be in good condition during the site inspection. The impoundment area remains slightly below grade and retains shallow water intermittently.

QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

Question B Summarv: Yes, the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of the remedy remain valid. Exposure at the Site was based on direct contact and ingestion of soil and groundwater, which remain valid. Removal action cleanup levels for the impoundment area were based on acceptable risk for industrial use. A screening-level risk assessment was conducted on the cleanup levels (Appendix H, Table H-1). The cleanup levels remain valid, with HQs less than 1 and excess cancer risk less than 1 x 104 for the industrial use scenario. Removal Action Cleanup Goals in the impoundment area and the maximum concentrations post-removal action were also compared with residential regional screening levels (RSLs) (Appendix H, Table H-2 and H-3). The results indicate that the cancer and non-cancer risks are outside the EPA's acceptable risk range for some contaminants when compared to the RSLs for residential use. However, the RSLs are not intended to be cleanup goals and are conservative. The highest concentrations in the layout area were also compared to residential RSLs to ensure this area remains safe for residential use (Table H-4, Appendix H). The results indicated the maximum contamination is well below the EPA's acceptable risk range for cancer and that the HQ is less than 1 for non­ cancer risks for all contaminants except for nickel. The maximum concentration of nickel slightly exceeds the non-cancer HQ of 1 (Table H-4). Since this is based on the maximum concentration of nickel and is only slightly above an HQ of 1, the overall risk level at the former layout area is expected to be below the HQ of 1.

The objective of the pre-ROD removal action, to attain cleanup levels in the impoundment area, was met and the area was covered with compacted gravel.

15 Perfluoroalkyl Sulfonate (PF AS)4 In evaluating the likelihood that PFAS may have been used at the Site, The EPA considered the following information. First, Allied Plating closed in 1984, two years prior to California's first steps requiring PFAS to address airborne hexavalent chrome at chrome-plating facilities. There would have been an additional cost to use these suppressants and, without the requirement in place, it would have been unlikely for a company to invest in the method so close to going out of business. Second, emission controls were not required for chrome-plating facilities until 1988, four years after operations ceased. Finally, throughout its years of operations, the City and State repeatedly cited Allied Plating for failure to operate in line with environmental regulations. Based on these facts, the EPA has determined that it is unlikely that a chemical fume suppressant such as PFAS would have been used at the Site.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

There is one question about the Site that has come to light since the previous FYR, but it does not impact the protectiveness of the remedy. The item is described below.

Storm water Drainage to Columbia Slough The Site is located within a City of Portland storm water outfall drainage basin. The City of Portland is currently working with Oregon DEQ under an intergovernmental agreement to improve sediment quality in the slough to levels that are protective of human health and the environment. As part of this agreement, the City is required to identify current and historical upland contaminant sources within the municipal storm water system.

The City requested that the EPA address: • Storm water discharges from the area of the Allied Plating facility into the City's storm water conveyance system. • Contaminated groundwater infiltration into the City's storm water conveyance system and subsequent discharge to the Slough. • Contaminated groundwater discharges to the Slough via preferential migration in storm utility line backfill. • Tracking of contaminated material ( e.g., soil, debris, particulates) from the Site into City rights-of-way and subsequent migration to the Slough.

During the 1990 RI, surface water and sediment samples collected from the Slough did not indicate significant trends in metals concentrations that could be associated with releases from the Site. Prior to 1969, wastes were discharged to the Slough via the outfall swale. At that time, the swale was abandoned and filled in, and the impoundment area pond was created. During the RI, soil samples from the former outfall swale contained cadmium, chromium and copper in excess of surface soil background levels. The RI concluded that these metals concentrations were from pre-backfilling plating discharge or from other industrial sources. The bottom sediment metal concentrations in the Slough were similar up gradient and downgradient of the Site. Additionally, a combined sewer overflow pipeline ( constructed in 1928) runs in a northerly direction under the impoundment area to an outfall in the Slough. During the removal action, a remote-control video camera was used to inspect the pipeline. The pipeline was still in good condition and it was concluded that the pipeline was not acting as a conduit for drainage from the pond.

4 In 1986, chromium was first officially listed as a toxic air contaminant by the California EPA Air Resources Board. In 1988, and amended in 1998, Airborne Toxics Control Measures (ATCMs) requiring a 99 percent reduction in airborne hexavalent chrome were adopted for chrome-plating facilities (Cal EPA, ATCM, August 2006). One common method used to reduce chromium emissions was to apply a chemical fume suppressant to the surface of the vats, reducing the surface tension and suppressing the release of fumes into the air. Fluorinated or per-fluorinated compounds (including PFAS) were commonly used as surfactants (U.S. EPA, 1998). PFAS are manmade substances that are highly mobile in groundwater, persistent in the environment and toxic when inhaled. 16 Slough water and sediment contamination was not determined to be a site-related issue during remedial investigations. The remedy is functioning as intended and has been assessed, as required, by FYRs. The EPA is willing to work with the City and/or State to determine if any actions should be taken under the Superfund program. However, at this time, the EPA has no evidence that additional CERCLA work is necessary to address the State's concerns and believes that those concerns are outside ofCERCLA's scope ofremediation. The EPA has concluded that the site continues to be protective for industrial uses and that the responsibility for additional storm water controls rests with the current land owner /operators.

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the FYR: . OU!

Issues and Recommendations Identified in the FYR: None

VII. PROTECTIVENESS STATEMENT

Site nide ProtectiYeness Statement Protectiveness Determination: Protective Protectiveness Statement: The remedy is protective of human health and the environment because contaminated soil was removed from the Site, cleanup goals were attained and site use is restricted as intended by the remedy.

VIII. NEXT REVIEW

The next FYR Report for the Allied Plating, Inc. Superfund site is required five years from the completion date of this review.

17 APPENDIX A - REFERENCE LIST

Draft Feasibility Study, Allied Plating Site, Portland, Oregon. Prepared by URS Consultants, Inc. for THE EPA Region 10. May 1992.

Fourth Five-Year Review Report for Allied Plating, Inc. Superfund Site, Portland, Oregon. THE EPA Region I 0. September 2013.

Record of Decision, Decision Summary, and Responsiveness Summary for No Further Action, Allied Plating Superfund Site. THE EPA Region I 0. June 1993.

Request for Removal Action at Allied Plating NPL Site, Portland, Multnomah County, Oregon. THE EPA Region I 0. October I 992.

Second Five-Year Review Report, Allied Plating, Inc. Superfund Site, Portland, Oregon. THE EPA Region I 0. September 2003.

Third Five-Year Review Report for Allied Plating, Inc. Superfund Site, Portland Oregon. THE EPA Region I 0. September 2008.

A-1 APPENDIX B - SITE CHRONOLOGY

Table B-1: Site Chronology

Event Date Allied Plating operated at the Site 1957 - 1984 Allied Plating discharged wastes to the Slough via the outfall swale 1957-1969 Allied Plating abandoned the outfall swale and created the impoundment 1969 area pond THE EPA and Oregon DEQ jointly requested closure and post-closure September 1984 plans from the current site owner as part of a requirement of a RCRA permit THE EPA and Oregon DEQ reached an agreement transferring program November 1986 jurisdiction from RCRA to Superfund THE EPA listed the Site on the NPL February 2, 1990 THE EPA began the Site's RI November 1990 THE EPA finalized the Site's Feasibility Study May 13, 1992 THE EPA signed an Action Memorandum October 16, 1992 THE EPA conducted a removal action at the Site October- November 1992 Site owner placed a deed restriction on impoundment parcels April 23, 1993 THE EPA signed No Further Action ROD June 29, 1993 THE EPA deleted the Site from the NPL November 14, 1994 THE EPA remanded the M CL for nickel June 29, 1995 THE EPA issued the Site's first FYR Report July I, 1998 THE EPA issued the Site's second FYR Report September 8, 2003 THE EPA issued the Site's third FYR Report September 30, 2008 THE EPA issued the Site's fourth FYR Report September 17, 2013

B-1 APPENDIX C - SITE MAPS Figure C-1: Site Vicinity Map

Portland, OR AlliedPlating, lnJ• Superfund Site-

Port!1ncl

30

0 250 500 1,000 Legend Feet Sources: Esri, Delorme, AND, Tele Atlas, First American, • Approximate Site Areas UNEP-WCMC, USGS, Esri, Digita/G/obe, GeoEye, Ealthstar Geographies, CNES/Airbus DS, USDA, USGS, AEX, Ge/mapping, Aerogrid, IGN, /GP, swisstopo, the G/S User Community and Figure 2 of the 2013 FYR. 0 Allied Plating, Inc. Superfund Site ~Skeo· NORTH City of Portland, Multnomah County, Oregon

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding THE EPA's response actions at the Site.

C-1 APPENDIX D - PRESS NOTICE

&EPA Allied Plating, Inc., Portland 1;:,ri,;.,,,""'' Site Visit December 14, 2017 Cleanup to be Reviewed The Fifth Five-Year Review of the environmental cleanup at the Allied Plating, Inc., a 12-acre Superfund Site near the Columbia Slough in Portland, Oregon is underway. EPA will be conducting an inspection of the Site on December 14, 2017. The Final FYR will be published prior to September, 2018 and will be available at the Portland State University Library. If you have observations, information or concerns pertinent to EPA's FYR investigation, or would !ike to be Interviewed as a part of the FYR process, please contact Joe Wallace, EPA Remedial Project Manager on or before January 15, 2018. Site Status Allied Plating, a chrome-plating facility, operated between 1957 and 1984. Discharge of liquid wastes from the plating operation to a pond on Site was the main source of contamination. Metals in the wastewater precipitated out, leaving a layer of contamination on the bottom of the pond. Site cleanup activities in 1992 removed 1,100 cubic yards of contaminated soil and sludge from the bottom of the dewatered pond, after which the pond was backfilled with quarry spalls. Since then, five feet or more of additional fill and paving of the pond area has occurred to facilitate its use for truck parking. Deed restrictions on the Site property prohibit the use of shallow groundwater for drinking water. Currently, the site is used for commercial/industrial purposes. For more information: Visit the site page: https://www.epa.gov/superfund/allied-plating Visit the library: Portland State University Library, 1845 SW Park Avenue Contact Joe Wallace, Project Manager; [email protected]; 206-553-4470 TDD and/orTIY users call the Federal Relay Service at 1-800-877-8339. Then please give the operator phone number 206-553-4470, Joe Wallace.

Oregonian (Portland)

D-1 APPENDIX E - INTERVIEW FORMS

Allied Plating, Inc. Superfund Site Five-Year Review Interview Form Site Name: Allied Plating, Inc. THE EPA ID ORD009051442 No.:

Subject Name: Sarah Miller Affiliation: Oregon DEO Subject Contact Information: Time: Date: 1/12/17 Interview Location: Interview Format (circle one): In Person Phone Email Other: Interview Category: State Agency

I. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

Reuse activities appear to be appropriate.

2. What is your assessment of the current performance of the remedy in place at the Site?

The remedy appears to be effective for human direct contact exposure. However, the storm water pathway for the property should to be evaluated to determine if the Site drains to the Slough via the on-site catch basins and the City of Portland's storm water system. The Columbia Slough Sediment Cleanup site contains a variety of contaminants in Slough sediments, including metals. Upland source control is a component of the ROD. It appears the former layout area was never remediated as soil concentrations met human health direct contact risk concentrations. However, a cursory review of Allied Plating documents indicates that soil concentrations in the former layout area would not meet Columbia Slough Sediment Source Control screening levels for chromium, copper and nickel.

Maximum Layout Area Columbia Slough Source Control Contaminant Concentration (nnm) Screeninl' Value (nnm) Chromium 165 76 Co ...... er 794 54 Nickel 1,930 47 Notes: nnm ~ narts ner million

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents in the past five years?

None that I am aware of.

4. Has your office conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities.

None that I am aware of.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site's remedy?

No specific changes in state laws. However, THE EPA may want to evaluate if the site discharges to the Columbia Slough Sediment cleanup site as part of its review.

E-1 6. Are you aware of any changes in projected land use(s) at the Site?

No.

E-2 Allied Plating, Inc. Superfund Site Five-Year Review Interview Form Site Name: Allied Plating, Inc. THE EPA ID ORD009051442 No.: Interviewer Name: Sarah Alfano Affiliation: Skeo Subject Name: Site operator/Tenant Affiliation: Pacific Coast Fruit Company Subject Contact Information: Time: Date: 12/14/17 Interview Location: At the Pacific Coast Fruit Company facility Interview Format (circle one): In Person Phone Mail Other: Interview Category: Site Operator/Tenant

I. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

Not before today.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

I'm not aware of the project.

3. What have been the effects of the Site on the surrounding community, if any?

No effects.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing?

Trespassing and theft.

5. Has THE EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can THE EPA best provide site-related information in the future?

There hasn't been communication but the best way would be through owners and in person.

6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what purpose(s) is your private well used?

No, just city water.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

No.

E-3 Allied Plating, Inc. Superfund Site Five-Year Review Interview Form Site Name: Allied Plating. Inc. THE EPA ID ORD009051442 No.: Interviewer Name: Sarah Alfano Affiliation: Skeo Subject Name: Site operator/Tenant Affiliation: 5 Star Hauling LLC Subject Contact Information: Time: Date: 12/14/17 Interview Location: Interview Format (circle one): In Person Phone Mail Other: Interview Category: Site Operator/Tenant

I. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place to date?

I am not aware.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)?

There are no issues.

3. What have been the effects of the Site on the surrounding community, if any?

There were no effects.

4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency response, vandalism or trespassing?

Yes, there have been problems with theft.

5. Has THE EPA kept involved parties and surrounding neighbors informed of activities at the Site? How can THE EPA best provide site-related information in the future?

The best way to be in touch would be by email.

6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so, for what purpose(s) is your private well used?

No.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

No suggestions about the project but more officers patrolling the area could help with general safety.

E-4 APPENDIX F - SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION Site Name: Allied Platino, Inc. Date of Insoection: 12/14/17 Location and Region: Portland. OR, Region I 0 THE EPA ID: ORD009051442 Agency, Office or Company Leading the Five-Year Weather/Temperature: 40s and sunny Review: THE EPA Re0 ion I 0 Remedy Includes: (Check all that apply) D Landfill cover/containment D Monitored natural attenuation D Access controls D Groundwater containment IZ] Institutional controls D Vertical barrier walls D Groundwater pump and treatment D Surface water collection and treatment IZ] Other: No Further Action ROD Attachments: IZ] Inspection team roster attached D Site map attached II. INTERVIEWS (check all that apply) L O&M Site Manager ------Name Title Date Interviewed D at site D at office D by phone Phone: -- Problems, suggestions D Report attached: 2. O&M Staff ------Name Title Date Interviewed D at site D at office D by phone Phone: -- Problems/suggestions D Report attached: 3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency __ Contact ------Name Title Date Phone No. Problems/suggestions D Report attached: __

Agency __ Contact __Name ------Title Date Phone No. Problems/suggestions D Report attached: __

Agency __ Contact ------Name Title Date Phone No. Problems/suggestions D Report attached: __

Agency __ Contact ------Name Title Date Phone No. Problems/suggestions D Report attached: __

Agency __ Contact

F-1 Name Title Date Phone No. Problemslsuooestions D Reoort attached: 4. Other Interviews ( optional) D Report attached: __ Two interviews were conducted on site, John Olsen with Pacific Coast Fruit Company and Dennis Malimon by phone as the site operator for 5star Hauling.

III. ON-SITE DOCU\VIENTS AND RECORDS VERIFIED (check all that apply)

I. O&M Documents D O&Mmanual D Readily available D Up to date [gj NIA D As-built drawings D Readily available D Up to date [gj NIA D Maintenance logs D Readily available D Up to date [gj NIA Remarks: No documents are keQt on site. THE EPA maintains the administrative record and there are no ongoing O&M activities. 2. Site-Specific Health and Safety Plan D Readily available D Up to date [gj NIA D Contingency plan/emergency response plan D Readily available D Up to date [gj NIA

Remarks: No documents are keQt on site. THE EPA maintains the administrative record and there are no ongoing O&M activities. 3. O&M and OSHA Training Records D Readily available D Up to date [gj NIA Remarks: No documents are keQt on site. THE EPA maintains the administrative record and there are no ongoing O&M activities.

4. Permits and Service Agreements D Air discharge permit D Readily available D Up to date [gj NIA D Effluent discharge D Readily available D Up to date [gj NIA D Waste disposal, POTW D Readily available D Up to date [gj NIA D Other permits: Oregon DEQ inguired about D Readily available D Up to date [gjNIA a storm.water 2ennit but this was not Qart of the THE EP A-reguired remedy.

Remarks: -- 5. Gas Generation Records D Readily available D Up to date [gj NIA

Remarks: -- 6. Settlement Monument Records D Readily available D Up to date [gj NIA

Remarks: -- 7. Groundwater Monitoring Records D Readily available D Up to date [gj NIA Remarks: -- 8. Leachate Extraction Records D Readily available D Up to date [gjNIA Remarks: -- 9. Discharge Compliance Records • Air D Readily available D Up to date [gj NIA D Water (effluent) D Readily available D Up to date [gj NIA F-2 Remarks:

10. Daily Access/Security Logs D Readily available D Up to date IZ'JN/A Remarks:

IV. O&M COSTS (No O&M Required or Performed During Last Five Years)

I. O&M Organization D State in-house D Contractor for state D PRP in-house D Contractor for PRP D Federal facility in-house D Contractor for Federal facility D THE EPA contractor 2. O&M Cost Records D Readily available D Up to date D Funding mechanism/agreement in place IZJ Unavailable Original O&M cost estimate: D Breakdown attached 3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons: /No O&M reguired or 11erformed during last five years) V. ACCESS AND INSTITUTIONAL CONTROLS IZJ Applicable • NIA A. Fencing I. Fencing Damaged D Location shown on site map D Gates secured • NIA Remarks: Industrial fencing around several areas.

B. Other Access Restrictions I. Signs and Other Security Measures D Location shown on site map IZJ NIA Remarks: Signs unrelated to the remedy were :gosted to :grevent tres:gassing.

C. Institutional Controls (I Cs)

I. Implementation and Enforcement Site conditions imply !Cs not properly implemented OYes IZJ No • NIA Site conditions imply !Cs not being fully enforced • Yes IZJ No • NIA Type of monitoring (e.g., self-reporting, drive by): FYRs Frequency: five years or as needed Responsible party/agency: THE EPA Contact ------Name Title Date Phone no. Reporting is up to date OYes • No IZ'JN/A Reports are verified by the lead agency • Yes • No IZJ NIA Specific requirements in deed or decision documents have been met IZJ Yes • No • NIA Violations have been reported OYes • No IZJ NIA Other problems or suggestions: D Report attached

F-3 2. Adequacy [2J !Cs are adequate D I Cs are inadequate • NIA Remarks: Groundwater restrictions are in Qlace in the iJnQoundment area and FYRs ensure industrial nse continues in imQoundment area. as reguired by the ROD. D. General

I. Vandalism/Trespassing D Location shown on site map D No vandalism evident Remarks: T resQassing and theft is an issue atthe Site but has not imQacted the remedy. 2. Land Use Changes On Site [2J NIA Remarks: 3. Land Use Changes Off Site [2J NIA Remarks:

VI. GENERAL SITE CONDITIONS A. Roads [2J Applicable • NIA I. Roads Damaged D Location shown on site map [2J Roads adequate • NIA Remarks: B. Other Site Conditions Remarks: X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

The EPA issued a No Further Action ROD. XI. OVERALL OBSERVATIONS A. Jmnlementation of the Remedv Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish ( e.g., to contain contaminant plume, minimize infiltration and gas emissions).

The EPA issued a ROD which selected No Further Action after a removal action. Groundwater use restrictions are in'11lace and the area is zoned for industrial uses. The remedy alillears to be functioning as intended· there are no observable ex.,;.osures of containiilated soils or ,_.oundwater. B. Adeauacv of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. There are no current O&M Jlrocedures. C. Earlv Indicators of Potential Remedv Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled the repairs that suggest that the protectiveness of the remedy may be compromised in the future. None. D. O~~ortunities for Ontimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. None observed.

F-4 APPENDIX G- SITE INSPECTION PHOTOS

Former layout area, current Pacific Coast Truck and Trailer RAir facility.

Impoundment area with sitting water, facing west.

G-1 Impoundment area, facing east, toward Martin Luther King, Jr. Boulevard.

Former Allied Plating office building area, now Basic Fire Protection Company facility.

G-2 APPENDIX H - SCREENING-LEVEL RISK REVIEW

Table H-1: Industrial Risk Review - lmpoundment Area Cleanup Goals Removal EPA Industrial RSL' Industrial Risk Level coc Action (=a/Im\ Cleanup Goal 1 X 10·6 1 X 10·6 HQ=l Non-cancer (mu/Im) Risk Risk• HO' Antimonv 200 NA 470 NA 0.4

Arsenic 150 3 480 5 X 10-5 0.3 Conner 20,000 NA 47,000 NA 0.4

7 Nickel 10,000 64,000 22,000 1.6 X 10" 0.5 Notes: NA= not available a. Current RSLs, dated November 2017, are available athttps://www.TheEPA.gov/risk/regional- screening-levels-rsls-generic-tables-november-2017 (accessed 12/21/2017). b. Cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on I x 10-• risk: cancer risk= (remedial goal+ cancer RSL) x 10·6• c. The non-cancer HQ was calculated using the following equation: HQ= (remedial ooal + non-cancer RSL).

Table H-2: Residential Risk Review - lmpoundment Area Cleanup Goals Removal EPA Residential RSV Residential Risk Level Action

4 Arsenic 150 0.68 35 2.2 X 10 4.3 Co ..... "'er 20,000 NA 3,100 NA 6.5

Nickel 10,000 15,000 1,500 6.7 X 10"7 6.7 Notes: NA= not available Bold = exceeds The EP A's acceptable risk range of I x 10·6 to I x I 04 and an HQ of I. a. Current RSLs, dated November 2017, are available at https:l/www.TheEPA.gov/risk/regional- screening-levels-rsls-generic-tables-november-2017 (accessed 12/21/2017). b. Cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on I x 10·6 risk: cancer risk= (remedial goal+ cancer RSL) x 10·6• C. The non-cancer HQ was calculated using the following equation: HQ = (remedial ooal + non-cancer RSLl.

Table H-3: Residential Risk Review - Maximum Concentrations in Impoundment Area Post Removal' THE EPA Residential RSL• Maximum Im: /ka\ Residential Risk Level coc Concentration 1 X 10-6 1 X 10-6 (mg/kg) HQ=l Non-cancer Risk Risk• HO' Antimonv 37 NA 31 NA 1.2

5 Maximum concentration data from Table IO in the 1993 ROD. H-1 THE EPA Residential RSL' Maximuni. , , Residential Risk Level coc Concentration 1 X 10"6 1 X 10"6 Non-cancer (mg/kg) HQ=l Risk Risk• HO'

Arsenic 41 0.68 35 6 X J0·5 1.2

Cadmium 5 2,100 71 2.4 X J0·9 0.1 Chromium' 5,590 NA 120,000 NA 0.05 Conner 12,000 NA 3,100 NA 3.9 Lead 234 NA NA NA NA

Nickel' 5,410 15,000 1,500 3.6 X 10"6 3.6 Cyanide 97 NA NA NA NA Notes: NA= not available Bold= exceeds The EPA's acceptable risk range of I x 104 to I x 10·• and an HQ of I. a. Current RSLs, dated November 2017, are available at https://www.TheEPA.gov/risk/regional- screening-levels-rsls-generic-tables-november-2017 (accessed 12/21/2017). b. Cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on l x 10·6 risk: cancer risk= (remedial goal+ cancer RSL) x 10·6. C. The non-cancer HQ was calculated using the following equation: HQ= (remedial goal+ non-cancer RSL). d. RSL is for chromium III soluble salts. e. RSL is for nickel-soluble salts.

Table H-4: Maximum Metals Concentrations in Former Layout Area' . . THE EPA Residential RSL' Maximum (nl! /ko\ Residential Risk Level coc Concentration 1 X 10"' 1 xrn·• Non-cancer (mg/kg) HQ=l Risk Risk• HO' Chromiumd 165 NA 120,000 NA 0.001 Conner 794 NA 3,100 NA 0.3

Nickel' 1,930 15,000 1,500 J.3 X J0·7 1.3 Notes: NA= not available a. Current RSLs, dated November 2017, are available at https://www.TbeEPA.gov/risk/regional- screening-levels-rsls-generic-tables-november-2017 (accessed 12/21/2017). b. Cancer risks were calculated using the following equation, based on the fact that RSLs are derived based on l x 10·6 risk: 6 cancer risk= (remedial goal+ cancer RSL) x J0· • C. The non-cancer HQ was calculated using the following equation: HQ= (remedial goal+ non-cancer RSL). d. RSL is for chromium III. e. RSL is for nickel-soluble salts.

6 Maximum concentrations reported in 1993 ROD. H-2