Deq Site Assessment Program - Strategy Recommendation
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DEQ SITE ASSESSMENT PROGRAM - STRATEGY RECOMMENDATION Site Name: Diversified Marine, Inc. Site CERCLIS Number: (none) DEQ ECSI Number: 3759 Site Address: 1801 N Marine Drive Portland, OR 97217 Recommendation By: Steve Fortuna, Site Assessment Section, DEQ Northwest Region Approved By: Sally Puent, Northwest Region Manager for Solid Waste and Site Assessment Sections Date: July 3, 2003 Background and History The subject site is an approximate 0.8 acre parcel in North Portland, on the south shore of North Portland Harbor, about 500 feet west of the Interstate Highway 5 (I-5) bridge over North Portland Harbor (see Figures 1 and 2). Diversified Marine, Inc., has conducted tug boat and barge building, repair, sandblasting, painting, machine shop, bilge removal, and boat and equipment refueling activities at the site under various names since at least 19901. Work is performed inside of an onshore building, on vessels moored in the river along the site, and in a 200-ton floating dry dock at the site. The site first came to the attention of Site Assessment in January 2003 during an evaluation of the adjoining Former Schooner Creek Boat Works site (ECSI #3526; see Figure 3). Between 1991 and 2002, DEQ received a series of Pollution Complaints alleging that boat building and repair activities at the neighboring Former Schooner Creek Boat Works site were releasing petroleum, solvents, fiberglass dust, and paint wastes, that might threatened water quality in North Portland Harbor (the Columbia River). Several of the reported releases were verified through DEQ follow-up inspections although no source could be located for some of the 1 Diversified Marine, Inc., (Kurt Redd, corporate president) was formed in 1986. It merged with Diversified Mechanical, Inc., (formed in 1992; same corporate president) in 1992. In 1999, Diversified Marine, Inc., changed its name to Portmarco, Inc. (same corporate president). A separate Diversified Marine, Inc., (same corporate president) was formed later the same year. Portmarco and Diversified Marine both operate at the same site, although the site is owned by Whitecap Cove, Inc. (formed in 1998; same corporate president). 1 petroleum sheens observed on the river in the immediate vicinity of the Former Schooner Creek Boat Works site. An examination of information in DEQ’s Pollution Complaint and Spill Reporting files suggested that past boat building and repair activities at the Diversified Marine facility might also have threatened surface water quality and sediment quality in North Portland Harbor (see Table 1). Location The Diversified Marine site is bounded on the north by North Portland Harbor (also called Oregon Slough; a channel of the Columbia River located south of Hayden Island), and on the east by the Former Schooner Creek Boat Works site. Hayden Island lies about 1,000 feet north of the site. The Interstate Highway 5 bridge over North Portland Harbor is located about 500 feet east of the site (see Figures 1, 2 & 3). North Marine Drive and North Pier 99 Street are located along the site’s southern boundary. A paved parking lot for the Multnomah County Fairgrounds and Exposition Center lies directly across North Marine Drive, 100-300 feet south and southwest of the site (see Figure 3). Pollution Complaint History Between 1990 and 2001, DEQ received nine Pollution Complaints and six Spill Reports associated with potential hazardous substance releases at the Diversified Marine facility, or petroleum sheens present on the river directly adjacent to the facility (see Table 1). Five of the Pollution Complaints and one of the Spill Reports involved fugitive dust emissions associated with sandblasting operations at the site. There is concern that sandblasting of boat hulls at the site could have released paint chips and toxic metals at concentrations that could represent a direct threat to the river’s aquatic life, or otherwise accumulated in the river’s sediments. Two other Spill Reports and another Pollution Complaint involved petroleum sheens of unknown origin on North Portland Harbor adjacent to the site. One additional 1998 Spill Report and simultaneous Pollution Complaint were associated with a petroleum release at the site that drained across N Marine Drive onto state highway property located 200 yards from the site. DEQ records indicate that Oregon Department of Transportation (ODOT) responded to the release, although there is no further information in DEQ files regarding the material’s identity, its source, or the nature and extent of cleanup required. Since Diversified Marine site activities include machine shop activities, bilge removal, and boat and equipment refueling activities, it may not be unreasonable to suspect that some of the petroleum contamination observed in the river channel could have originated from on-site activities. Such releases could represent a direct threat to the river’s aquatic life, or otherwise have accumulated in river sediments. 2 Hazardous Waste Generator Activities Although Diversified Marine builds, repairs, sandblasts and paints tugs and barges at the site, and conducts on-site machine shop operations, the company did not report hazardous waste generator activities to DEQ until November 2002. At that time, the company became a one-time generator of 4.7 tons of lead-contaminated rust and scale which had been sandblasted from a ship’s hold. In April 2003, the company registered with DEQ as a Conditionally Exempt Small Quantity Hazardous Waste Generator (CEG). CEGs generate 2.2 pounds or less of acute hazardous wastes, or 220 pounds or less of hazardous waste, or hazardous substance containing spill debris, in one month, and accumulate no more than 2,200 pounds of hazardous waste on-site in any given month. In its most recent report to the State Fire Marshal’s Office, Diversified Marine indicated that welding gases (acetylene, oxygen, argon, and carbon dioxide) are the only hazardous substances stored at their site. Facilities having reportable quantities of hazardous substances on-site at any time must notify the State Fire Marshal under the “Community Right to Know Regulatory Program” (ORS 453.307 - 453.414). Under this program, the reportable quantity for liquid hazardous substances (including paints, oils, petroleum-based fuels, or solvents) is 50 gallons, or more; for solid hazardous substances (such as lime, caustic soda, lead, or other toxic metals), it is 500 pounds, or more; for gaseous hazardous substances (such as acetylene, propane, or oxygen) the reportable quantity or 200 cubic feet, or more2. Enforcement Actions DEQ issued Diversified Marine a Notice of Noncompliance (NON) for an unpermitted discharge to the Columbia River of wastewater used to control sandblasting dust, after a July 1993 Pollution Complaint inspection (Complaint NWR-1993-1201; see Table 1). The City of Portland’s Bureau of Environmental Affairs issued Diversified Marine two Notifications of Violation (NOVs) in March and April 2001, for failing to obtain an industrial storm water control permit for their facility. The following July, DEQ issued the company a NON for failing to apply for the storm water discharge permit. Diversified obtained a storm water discharge permit from DEQ in December 2001, but failed to subsequently submit an associated Storm Water Pollution Control Plan (SWPCP) to DEQ, so in June 20, 2002, DEQ issued Diversified Marine an NOV, and assessed a Civil Penalty, for failure to submit the required SWPCP. Storm Water Monitoring Data 2 For poisons or explosives, the reportable quantities are 5 gallons for liquids, 10 pounds for solids, and 20 cubic feet for gases. 3 Diversified Marine has sampled and analyzed its storm water runoff twice since obtaining its storm water discharge permit. Although contaminant concentrations were within DEQ storm water benchmark values, both samples contained copper and zinc concentrations that slightly exceeded DEQ freshwater Water Quality Criteria, National Recommended Surface Water Quality Criteria, and DEQ Level II Ecological Risk Assessment Screening Benchmark Values for freshwater aquatic life (see Table 2). Storm Water Discharge Permit holders must “strive to meet” storm water discharge benchmark values, but need only update their SWPAP when benchmark values are exceeded. While the concentrations of copper and zinc detected in Diversified Marine’s storm water runoff are well within the respective benchmark values, they exceed those most commonly encountered in DEQ Northwest Region industrial storm water runoff. These test data suggest that soils at the Diversified Marine site are likely contaminated with metals, and that metals in site storm water runoff could accumulate in the river sediments and represent a risk to aquatic life in North Portland Harbor. Site Contaminants of Concern Diversified Marine’s record of Pollution Complaints and Spill Reports suggests that on-site activities could have contaminated site soils and nearby Columbia River sediments with any of a variety of boat building, maintenance, and repair related contaminants, including toxic metals and paint chips containing toxic metals such as copper oxide, organotins, lead, cadmium, chromium, mercury, and zinc; petroleum constituents such as BTEX (benzene, toluene, ethylbenzene, xylenes) and polynuclear aromatic hydrocarbons (PAHs); and other potential organic contaminants such as, phthalates, pentachlorophenol, chlorinated solvents, and possibly polychlorinated biphenyls (PCBs). Contaminant Exposure Pathways The site is located in a narrow, isolated strip of industrial properties on the south bank of North Portland Harbor, along North Marine Drive. The entire site lies within the Columbia River 100- year flood zone (see Figure 4). The Columbia Slough lies about 1 mile south of the site. The area between North Portland Harbor on the north, I-5 on the east, Columbia Slough on the south, and a Burlington Northern – Santa Fe Railroad right-of-way on the west comprises Peninsula Drainage District No. 1. Most of the drainage district is publicly owned wetlands (see Figures 2, 5, and 7). The nearest residence (1531/1601 N Marine Drive) evidently shares the same tax lot as the Former Schooner Creek Boat Works site (see Figure 3).