Technical Assistance Grant Program
Case Study 1: Groundwater Contamination in East Multnomah County, OR
Case Study 2: McCormick & Baxter Creosoting Company Site
Appendix A:Impact of Groundwater Contamination in East Multnomah County on the Interlachen Community, Technical Report EWR-3-96.
Appendix B:Groundwater Contamination in East Multnomah County, Interlachen Community Factsheet Series
The EPA Technical Assistance Grant Program has been
around for several years, but there are not many examples of its
use in the Pacific Northwest from which citizens can learn from
when considering applying for a Technical Assistance Grant. The
EPA program is designed to provide citizens with technical assistance
in understanding the issues related to a Superfund site (or proposed
Superfund site) in their community. This report provides an overview
of the Technical Assistance Grant Program with information on
applying for the grant, selecting a Technical Advisor and managing
the grant. Additionally two case studies are reviewed in order
to provide some examples of the process and provide a better understanding
of the steps involved for new communities interested in utilizing
this EPA program. By examining both the TAG process and some examples
of its implementation, interested citizens will be better prepared
for the grant process, the efforts involved, and the benefits
of the grant program.
The U.S. Environmental Protection agency created
the Superfund Technical Assistance Grant (TAG) Program to help
communities and citizens learn about important issues, which affect
their community due to a Superfund site. The program allows the
community to get involved in the Superfund Program to respond
to concerns and risks related to a site. The TAG Program provides
funds for qualified community/citizen groups affected by a Superfund
site to hire a Technical Advisor to help interpret and comment
on site-related information and reports. The Technical Advisor
would review documentation, interpret site-related information,
and then disseminate this information to the community. In turn,
the community would have a better understanding of the site-related
issues and the cleanup process.
The grant process for the Technical Assistance Grant
Program can be overwhelming to citizens who have not been involved
with a grant process before. Descriptions of the various aspects
of the program have been outlined to provide some insight into
the process. Some of the information presented is further explanation
of information presented in four handbooks published by the EPA
regarding the Technical Assistance Grant Program. References to
these handbooks are included at end of this report.
As part of the TAG Program the citizen/community
group (CG) must provide 20% of the total costs of the technical
assistance project. The TAG Program awards grants on a three-year
budget period with a maximum limit for the period set at $50,000.
If the community group is awarded the maximum amount they must
provide 20% of the total project costs, where 80% is the federal
grant source of $50,000. To meet this requirement the EPA allows
the citizen group to utilize in-kind contributions and group funds.
Examples of in-kind contributions are volunteer services, contributions
of supplies, and cash the group spends on products or services.
In order to count volunteer services, the community group would
need to keep track of the hours donated and a base rate at which
the volunteer hours are valued.
A community group can get a waiver from the financial
requirement under unusual circumstances, which would need to be
demonstrated to the EPA. An example would be if the affected communities
were undergoing financial hardship. To request the waiver, the
citizen group would need to submit a written request statement
with the application materials.
In addition to the financial requirements, there
is also an administrative cap of 20% on the total TAG budget,
which includes the federal funds' and the group's matching contribution.
The administrative cap on the grant is designed to ensure the
majority of the funds provided will be used for community technical
assistance.
As part of the application process the EPA will be
evaluating the citizen group's capabilities to manage a grant
adequately and responsibly. This would be partially established
by the citizen group's plans for establishing a grant management
system, the group's scope of work for the project, and information
about the CG's past project experiences. Additionally, the EPA
may decide to set up a meeting with the group to get a better
understanding of how the group operates and to clarify any details
of the application submitted or the hazardous waste site in question.
In addition, the EPA may also evaluate the group's
ability to meet deadlines and complete projects, which would be
required by the EPA through submitting regular progress reports
or holding community meetings. The EPA will also review whether
the group has established adequate procedures for financial accounting
and auditing of the grant funds. The group's ability to raise
contributions may also be a factor in reviewing the group's capabilities.
Lastly, the EPA will evaluate whether the group complies with
civil rights and equal opportunity employment laws.
Technical Assistance Grants are available anytime
during the cleanup process, but the sooner in the process the
citizen group applies the more beneficial it is if they receive
a grant. The earlier a Technical Advisor can review and comment
on reports such as the Remedial Investigation and Feasibility
Study for the site the more prepared the community and Technical
Advisor will be for the subsequent steps in the cleanup process.
The general process for the grant program can be
separated into three phases: applying for the grant, selecting
a Technical Advisor, and managing the grant. The first phase of
the process is applying for the grant and receiving the TAG award
from the EPA. The next phase is to determine the community's technical
needs for the site and use this information to select a Technical
Advisor. Once a Technical Advisor has been chosen and a contract
signed then the work begins for both parties on meeting the community
group's scope of work as outlined in the grant agreement. Through
the rest of the grant budget period the CG would continue to manage
the grant and work with the Technical Advisor. At the end of the
budget period the CG has the option of applying for additional
funds to continue the work or terminate the grant after the budget
period closes.
Flowchart 1 entitled "Technical Assistance Grant
Process" shows the process for applying for a TAG. This process
is also described below.
Applying for the Technical Assistance Grant begins
by submitting a letter of inquiry or phone call to the EPA to
request application materials and information about the program.
In some cases the EPA may solicit the community through newspaper
advertisements to encourage citizen and community groups to come
forward and apply for a TAG.
Once the EPA has been notified of a group's interest
in applying for a TAG, the EPA will then provide 30 days for other
potential groups to come forward and express an interest in the
TAG Program. During this time the initial group can begin filling
out application materials. If after 30 days there is more than
one group interested in receiving a TAG the EPA will encourage
these groups to combine their efforts and create a sole incorporated
nonprofit organization for the purpose of the grant. Since only
one grant is allowed per site it is to the advantage of all groups
to work together. By multiple groups working together for the
purpose of the TAG, more community members would be represented
by the coalition organization, and the work generated by the Technical
Advisor would be disseminated to more people. If a coalition between
several groups can not be achieved, each group is given 30 days
to submit their application materials. After the EPA review process,
only one of these groups would be selected to receive a grant.
The EPA has printed a series of handbooks for the
TAG process which include example forms which have been filled
out and blank forms which can be used when applying. The booklets
also provide more specific details on filling out the application
forms. Before completing the applications, the CG should review
these EPA handbooks.
While in the process of completing the application,
the community / citizen group (CG) should contact their state
intergovernmental grant review person and notify them of the CG's
plans to apply for the EPA TAG. In some states the state government
needs to know what grant funds are coming into the state. The
intergovernmental review person should be able to tell the CG
what requirements need to be met, if any, and whether a copy of
the application needs to be submitted to the state. This should
be completed while applying for the grant because it may require
up to 60 days to fulfill any state requirements and the EPA can't
process the application materials unless there is evidence that
the application was sent to the state. It is important to note
the EPA does not need to hear back from the state to begin processing
the application, but the EPA can't award a grant until the state
has responded to the application materials submitted by the CG.
At this time during the process, if the CG is not incorporated
as nonprofit organization, they should begin the process of applying
and inform the EPA that the process has started. Once the application
materials have been completed several copies should be made. At
least one copy should be kept for the CG's records. Then the original
application materials and two copies should be submitted to the
EPA. The EPA's review of the application materials will take approximately
30 days and within this time they may contact the CG to set up
a meeting or to request further information.
The EPA will then send a written notice to the CG to notify them
whether they will receive a grant. If the grant is approved, the
EPA will have the EPA Grant Award Officer send the CG an award
agreement, which must be signed by the individual in the CG, who
will be responsible for the grant. This must be completed within
three weeks of receiving the grant agreement and then resubmitted
to the EPA. Once the EPA receives the signed agreement, the Grant
Award Officer will sign it and then expenditures against the grant
can be made. The only exception to this is if the community group
has expenses towards incorporation as a nonprofit; these can be
applied to the grant even though they occurred before the grant
agreement was finalized.
Although the majority of the procurement process
described below focuses on selecting a Technical Advisor for the
CG, the same process can be used to select a grant administrator.
The same procurement rules that are established for selecting
a Technical Advisor would also apply when selecting a paid grant
administrator. If the CG is interested in having someone with
past experience manage the grant and keep financial records then
the CG can hire someone to conduct these activities. The only
additional limitation on selecting a grant administrator is there
is a 20% administrative cap on the grant so hiring anyone to manage
the grant would need to fit within this 20% and allow for other
administrative expenses to be covered.
The next step in the TAG process is to select a Technical
Advisor by developing a request for proposals (RFP), i.e., a solicitation
for technical work tasks. In selecting a Technical Advisor, there
are two methods, which can be used, competitive and noncompetitive,
but regardless of the method there are some specific steps the
CG should keep in mind when identifying technical work needs and
determining the most appropriate Technical Advisor for the contract
work. These steps are illustrated in Flowchart 2 entitled "Selecting
a Technical Advisor (TA), Competitive Selection Method" and
Flowchart 3 entitled "Selecting a Technical Advisor (TA),
Noncompetitive Procurement Method". The CG should review
what they know about the hazardous waste site and determine the
questions and issues they would like addressed for their community.
Additionally they may want to research other Superfund sites to
determine if a CG has already utilized the TAG Program for a site
with similar issues. The research conducted will provide the CG
with more insight into what expertise to look for in the Technical
Advisor candidates and what additional qualifications will be
required. Below is a list of some of the areas of expertise a
Technical Advisor may need. This is not an all-inclusive list
and will vary considerably depending on the nature of the site
under study. The Technical Advisor will most likely be a group
of people with varying expertise.
In addition to the Technical Advisor candidates' expertise, it is important to ensure they have the appropriate qualifications to meet the technical work elements outlined in the solicitation developed (see below). A list of required qualifications for any Technical Advisor is outlined below and can be found in the EPA Superfund TAG Handbook: Procurement Using TAG Funds.
Additional qualifications:
Another approach which will help the community determine the skills,
qualifications and expertise the panel should have is to examine
some of the possible tasks the panel may conduct for the community.
The EPA provides an "exhibit list" which provides some
potential work tasks in the EPA handbook on applying for the grant.
Some examples of these tasks are:
There are two ways in which a Technical Advisor can be selected
for meeting the needs of the CG through the TAG Program. The first
method is a competitive method for selecting a Technical Advisor
that dictates a minimum number of quotes the CG must receive based
on the value of the potential contract. The other selection method,
the Noncompetitive Selection Method, is used when it is clear
to the CG there is only one possible candidate for meeting the
CG's technical needs.
The first step in selecting a Technical Advisor is to identify
the technical needs of the CG and larger community for the site.
The technical needs will be partially dictated by the nature of
the hazardous waste site, and partially by the concerns of the
community. After the technical needs have been identified the
CG should then identify potential sources of Technical Advisors
such as consulting firms or academic institutions. Then a solicitation
(request for proposals) should be developed to clearly state the
technical needs and a time frame over which work tasks should
be conducted. The solicitation for proposals should include a
specific set of elements in order for the CG to review adequately
the proposals and select a Technical Advisor. Potential solicitation
elements are:
Once the solicitation has been developed the CG needs to publicize
the information so potential candidates are aware of the request
for proposals. If the group has already investigated potential
sources of Technical Advisors then this information can be used
to solicit the potential candidates. Additionally, the CG needs
to be prepared to send out the solicitation to potential candidates
and answer any questions by potential candidates. Once the proposals
have been received, the CG can begin the process of evaluating
them based on the CG's already established criteria.
For the competitive selection process, the EPA requires at last
two quotations for contract bids between $1,000 and $25,000 and
a minimum of three quotations for contracts valued between $25,000
and $50,000. If the contract is valued at over $50,000 the CG
should contact their Regional EPA Grant Coordinator for the grant
and refer to the EPA TAG Handbook: Procurement - Using TAG
Funds because other federal regulations apply for these larger
contracts.
Regardless of the value of the contract the CG should contact
the EPA to determine if any of the candidates are on the master
list of debarred or suspended contractors. If the contract in
question is valued over $25,000 the potential candidate(s) need
to submit a form called "Certification Regarding Debarment,
Suspension, and Other Responsibility Matters" with their
proposal which would eventually be forwarded to the EPA. In addition,
for contracts over $25,000, the CG will also need to conduct a
cost analysis to assess the cost estimates in the proposals for
appropriateness and for determining profits estimated in the proposals.
For more information on conducting the cost analysis, refer to
the EPA TAG Handbook: Procurement -Using TAG Funds.
While the citizen group is in the process of reviewing the proposals
and selecting a Technical Advisor, all of the criteria used to
eliminate candidates and select a Technical Advisor should be
documented and saved. After the CG has selected a Technical Advisor
they should notify the candidate and send notices to all of the
unsuccessful candidates. At this point the CG and selected Technical
Advisor can negotiate any details related to developing a contract.
For information on suggested elements to include in a contract,
see the following section on using the Noncompetitive Selection
Method.
If the contract value is over $1,000 then a copy of the proposed
contract and documentation from the selection process should be
forwarded to the EPA for review. The EPA will review the contract
to ensure all of the necessary clauses are included (as outlined
in the sample contract in the procurement handbook). Based on
the review the EPA may suggest some modifications to the contract.
Once any modifications are made to the contract, it can be finalized
and signed by both the Technical Advisor and the CG. Once signed,
the Technical Advisor can begin working on the project tasks and
the CG can focus on managing the grant and any community activities
related to the site. After the Technical Advisor selection process
has finished it is important that the CG keep all the documentation
related to selecting the Technical Advisor and any contract information.
As in the case of the competitive selection process, the CG needs
to identify the technical work they would like the Technical Advisor
to accomplish. Before proceeding with this procedure, the CG should
contact the Regional EPA TAG Coordinator to discuss the noncompetitive
process and determine if it is appropriate for the CG to use.
Based on this discussion, if the EPA agrees the situation may
warrant the use of the noncompetitive process, the CG would then
submit a formal Request to Use the Noncompetitive Procurement
Process to the EPA. (Refer to the EPA handbook on procurement).
This form will need to be completed with an explanation for using
the noncompetitive process to select the Technical Advisor. If
the EPA approves the request, the CG would then discuss with the
potential Technical Advisor their technical work needs and any
EPA requirements.
The next step requires the potential Technical Advisor to submit
a proposal to the CG that would meet the technical requirements
discussed above. After this initial proposal is submitted the
CG may then wish to negotiate an agreement further with the potential
Technical Advisor. Regardless of the value of the contract, the
CG needs to check with the EPA to determine if the candidate is
on the master listed of debarred or suspended contractors. Also,
like in the competitive selection process, if the contract is
valued over $25,000, the potential Technical Advisor needs to
submit the form titled "Certification Regarding Debarment,
Suspended and Other Responsibility Matters" to the CG which
then goes to the EPA. In addition, the CG would also have to conduct
a cost analysis for the proposal. This would assess the costs
estimated in the proposal to determine if they are appropriate
and would provide an appropriate estimation of profit. All of
the information that related to the review process for selecting
the candidate should be documented (regardless of the value of
the contract).
At this point in the process, the CG can work with the selected
Technical Advisor to develop and negotiate a contract to conduct
the described work. The contract should have the elements described
below as listed also in the EPA handbook on procurement. First,
the contract should have a section on the nature, scope and extent
of work to be conducted by the contractor. This will establish
a set of agreed upon work tasks for the contractor to complete
and will help in evaluating the contractor's performance at a
future date. A timeline for completing these tasks and work elements
should also be written into the contract to ensure the CG gets
the agreed upon products and services in a timely manner. The
total cost of the contract needs to be specified, and any other
detailed cost estimates should be outlined as well. Payment provisions
should be included in the contract, but before developing this
part of the contract the CG should contact the EPA to get a better
understanding of how the reimbursement process will work and how
the CG will handle paying the contractor. The contract needs to
include provisions for an option to extend the contract or to
terminate the contract under specific circumstances. While in
the process of negotiating the details of the final contract with
the Technical Advisor, the CG needs to determine whether a labor-hour
or fixed price method is going to be used for the contract. Finally
the EPA recommends the CG review the sample contract in the their
handbook on procurement to ensure specific clauses are included
in the contract.
If the contract value is over $1,000 the proposed contract and documentation related to the negotiations with the Technical Advisor need to be submitted to the EPA for review before the contract can be finalized. The EPA will review the materials to ensure specific clauses are incorporated into the contract and to evaluate whether the contract will meet the CG's needs. In addition they will review the proposal and cost justification process. Once this review has been completed and any necessary modifications are made to the contract, it can be finalized. When the final version of the contract has been written the technical assistance contractor and the CG should sign it. If the contract in question is less than $1,000 it does not need to be reviewed by the EPA, but the EPA should be informed of any proposed contract in case they have suggestions or would like to review it. As mentioned in the competitive selection process all documentation related to the selection process and contract development should be retained.
Because the CG is utilizing federal funds through the TAG Program for technical assistance work, the CG needs to make a positive effort to use small, minority owned, or women owned businesses. If the CG needs help in locating any of these types of firms, they should contact the Regional TAG Coordinator. Additionally the CG could check with their local Chamber of Commerce for information on these firms. The EPA handbook on procurement provides details on how these businesses are defined, and lists a set requirements which must be followed in rural areas to ensure qualified small businesses are used whenever possible.
Throughout the process of selecting a Technical Advisor regardless
of the method used, the CG needs to maintain accurate records
of the process. The review process of the Technical Advisor proposals
should be well documented along with reasons for eliminating any
candidates. Any materials related to developing the solicitation
should also be documented and saved. Any cost analyses conducted
or negotiations with Technical Advisor candidates should be documented
as well. These records should be retained and safeguards should
be taken during and after the selection process to ensure business
information such as rates and fees submitted by contractors remain
confidential. The basis for making the final selection of the
Technical Advisor should be documented and any issues negotiated
with the selected candidate in developing the contract should
also be included. The CG should also provide a written justification
in their records for the type of contract used, labor-hour or
fixed price. Lastly, the EPA requires the CG to document a sincere
effort to use small, minority owned or women owned businesses.
Once the Technical Advisor has been selected and
their work has started, the CG begins the grant management phase
of the TAG Program. This phase of the process takes place in parallel
to the Technical Advisor activities and events related directly
to the site. There are three main types of activities, which will
take place during this phase:
Refer to flowchart 4 entitled "Managing the
Technical Assistance Grant" for additional information.
As part of the grant agreement with the EPA, Progress Reports
need to be submitted by the CG on a quarterly basis. The Progress
Reports should be only a couple of pages in length and should
describe the progress achieved over the past several months and
whether the activities are fitting within the approved time schedule
and budget. Any problems encountered or anticipated in the future
should be outlined as well. Lastly, the CG should provide a list
of anticipated activities for the next quarter. The CG could also
include with the report any products developed by the Technical
Advisor or CG to demonstrate their progress. These reports are
submitted to ensure the EPA is updated on the community activities
related to the hazardous waste site, to assess whether the grant
schedule is on track, and to provide a vehicle for the EPA to
offer suggestions or provide assistance along the way in the TAG
Program.
The CG needs to submit Reimbursement Requests to the EPA on a
quarterly basis as well. If the CG has more than $500 in expenses
in a given month the Reimbursement Requests may be submitted more
frequently. For more information on the Reimbursement Requests
see the section on Grant Activities.
Annually in October the CG is responsible for providing an Annual
Minority Owned Business (MBE) Report. This report is designed
to report the amount of money in any contracts that went to MBEs.
Even if the CG did not hire an MBE, the report should still be
submitted to the EPA so they have annual records reporting the
amount of money that went to MBEs. The form used to report the
information is called "MBE/WBE Utilization Under Federal
Grants, Cooperative Agreements and Other Federal Financial Assistance"
(SF334).
An annual Financial Status Report needs to be submitted within
90 days after the grant anniversary date using form SF269. This
report should include details on expenditures over the past year,
and it allows the EPA to assess whether the CG is meeting the
targeted budget outlined in the grant agreement.
The TAG covers a three-year budget period. When the budget period
comes to a close, several additional reports are required in addition
to the ones mentioned above. A Draft Final Project Report by the
CG is due within 90 days before the closing date of the grant
budget period. This report should be approximately three to four
pages in length, and provide a complete summary of the CG's activities
over the entire budget period. Descriptions of the activities
and the progress accomplished should be related back to the project's
purposes and objectives established in the grant agreement.
A final version of the Final Project Report is due within 90 days
after the close of the grant. The final version should be a refined
version of the draft report, incorporating any suggestions or
comments from the EPA's review of the draft. Additionally the
CG may want to include any key products developed by the Technical
Advisor or CG that help illustrate the achievements over the course
of the budget period. The EPA handbook on managing the grant provides
a sample table of contents for the final report.
A Final Financial Status Report needs to be submitted to the EPA
within 90 days after the end of the project period or termination
of the grant. When this report is generated all payments should
be made to contractors and other service providers, and there
should be no outstanding financial transactions. The report should
also include a summary of any unspent funds from the budget period.
This report provides the EPA with a summary of the grant expenditures
over the budget period and allows them to evaluate it against
the budget initially established in the grant agreement. The EPA
handbook on managing the grant provides further details on what
should be included in this report.
The CG is responsible for keeping track of and managing all of
the financial transactions related to the grant. As mentioned
above, Reimbursement Requests are submitted to the EPA quarterly
unless monthly expenses exceed $500. When submitting the Reimbursement
Request, the EPA may take 20 to 30 days to pay the money to the
community group. The CG should to remember that reimbursement
expenses and group contributions to meet the matching community
requirement are not valid until after both the EPA and the CG
have signed the grant agreement. The CG should require all of
their contractors to submit billing packages to the CG when requesting
funds. The billing package will include information on such items
as contractor expense records and progress reports. The CG can
then use this information to assist them in writing Reimbursement
Requests to the EPA, and to check on whether the CG is adhering
to planned budgets and schedules established for the project.
The CG also needs to keep an accurate accounting and record keeping system. The accounting system should be able to keep track of all in-kind contributions, bank account records for the community group, and administrative expenses to ensure the 20% administrative cap on the grant funds is not exceeded. The accounting system should also have a ledger showing all financial transactions completed with supporting documentation and receipts. The CG needs to have a bank account in the name of the group because the EPA writes the reimbursement checks in the name of the CG. The CG would then need to keep all bank records and canceled checks as part of the grant documentation records.
A management system for the overall grant administration needs
to be established for the CG. For example, the system should ensure
all funds, property, and resources for the project should be used
for authorized purposes only (related to the grant project activities).
Additionally, the management system should include conducting
internal audits of the financial records, and the audit results
should be kept as part of the grant records. Internal audits should
be conducted at least once every other year.
In addition to developing a grant management system, the CG needs
to maintain records on many of the activities they conduct throughout
the project budget period. The list below provides some examples
of the records that should be kept by the CG.
All of the records generated from the TAG Program must be stored
for a minimum of ten years after the close of the grant. Before
the CG plans on discarding the documentation after ten years they
need to send a written notification to the EPA to inform them
of their plans.
Besides the activities mentioned above the CG will have their
own set of activities to conduct during the project period. These
activities may be either to keep in touch with the Technical Advisor's
progress, to learn about results from the Technical Advisor, or
to keep the larger community informed of the activities taking
place related to the hazardous waste site.
Depending on the contract established between the
CG and the Technical Advisor, it will be important for the CG
to keep informed of the progress of the Technical Advisor. A framework
should be developed for communication between the CG and Technical
Advisor to keep the CG informed of progress and activities and
for planning future activities.
The CG may want to hold regular group meetings to
keep group leaders and/or the whole group informed of the Technical
Advisor's activities and events related to the site. Additionally,
the CG may want to have regular meetings / open houses with the
larger community to keep local residents affected by the site,
who are not active in the CG, informed about site-related issues.
At specific milestones in the project, the CG may
want the Technical Advisor to attend or host a community meeting
to allow residents and community members to ask the Technical
Advisor questions about the site related issues. This would also
be an opportunity for the Technical Advisor to present findings
or recommendations from the technical document review. The CG
would need to be able to advertise these meetings to the community
and notify key residents affected by the site to encourage them
to attend these meetings to learn more about the hazardous waste
site.
The CG could also inform the community about the
Technical Advisor's progress and other site-related issues by
creating regularly published newsletters, periodic bulletins,
and brief informational factsheets to be distributed. The CG needs
to be able to overlook the activities of any hired contractors
to ensure their needs are met. Lastly, the CG needs to be able
to take the lead in disseminating information to the community
from the Technical Advisor or other sources.
If the CG at any point in the TAG process feels the project objectives or funding need to be modified in the grant agreement, the CG should contact the EPA Award Officer. Changes in the objectives or funding can only be done through a formal amendment to the grant agreement and must be negotiated and signed by the EPA Award Officer. Before implementing any changes of this nature the CG should discuss them with the EPA Regional Office because the EPA is not obligated to provide additional funds or modify the grant agreement.
The TAG Program works on a three year budget period with a maximum
award given of $50,000 for the three years. Depending on the circumstances
of the site the total project period for technical assistance
may last more than one budget period. There are two common scenarios
that may result in the CG renewing the TAG. One scenario is at
the end of the grant budget period if the CG still has money left
over and feels there is a need for additional technical assistance.
In this case the CG can submit a continuation application (SF424)
to the EPA. The other scenario; at the end of the budget period
the CG may feel there is still a need for technical assistance
after the grant period has ended even though there will not be
any funds available. For this case the CG would need to apply
for a grant continuation with additional (new) funding. A continuation
application (SF424) would need to be submitted to the EPA along
with a waiver form to exceed the $50,000 limit for the site if
the CG had already received $50,000 in the first budget period.
In order to apply for a waiver for additional funds beyond $50,000
the site must be on the National Priorities List for Superfund
sites, and not proposed for listing. For additional details on
exceeding the $50,000 limit refer to the EPA TAG handbook on managing
the grant.
Applications for grant continuation should be submitted 90 days
before the close of the current grant budget period to ensure
the EPA has sufficient time to evaluate the application and the
latest grant reports for the current year. The review process
will consider the complexity of the site in question, site-related
issues, and how successful the current grant was managed by the
CG. The application should be submitted along with any Progress
Reports for the current budget period and an estimate of the Financial
Status Report for the current year including any estimation of
unspent funds by the ending date of the grant. A new budget should
be outlined in the application, and a new statement of work should
be developed as well for the application. If the grant is a continuation
to use unspent funds, then the statement of work may be simply
a continuation of the statement of work from the current budget
period.
If the CG needs additional technical assistance and wishes to
retain the same contractor, the procurement process does not need
to be completed again. A new contract would need to be developed
or amendments added to the original contract to reflect the new
budgets, time periods, and an updated scope of work if necessary.
If the scope of work changes for the grant renewal, then the CG
needs to evaluate whether the present contractor has the necessary
skills and expertise for the new tasks. If the contractor does
not have the expertise to perform the new tasks, the CG will need
to repeat the procurement process and select a new Technical Advisor.
The Groundwater Contamination in East Multnomah County
was proposed for listing on the National Priorities List for Superfund
sites. The Friends of Blue and Fairview Lake, a citizen activist
group, applied for and received an EPA Technical Assistance Grant
(TAG) and contracted with Portland State University faculty and
staff to serve as the Technical Advisor and provide a review of
the issues related to the contamination site. For additional information
on this project refer to Appendix A at the end of this report
for a copy of the technical review report produced by the panel
at Portland State University.
The groundwater contamination is located in the Cities
of Fairview and Gresham in East Multnomah County, Oregon, which
is in the eastern part of the Portland metropolitan area. The
region of groundwater contamination can be found within a 2.5
square mile region bounded by NE Halsey Blvd. to the south and
the Columbia River to the north. The study region is also bounded
by NE 178th to the west and by NE 223rd
Ave. to the east.
The Interlachen neighborhood consists of approximately
150 households, which rely on groundwater produced from three
wells in the area. The Lachenview well is located on the north
edge of Fairview Lake at the east end of the Interlachen community
and is the only well that draws groundwater from the Troutdale
Sandstone Aquifer (TSA). At the present time the well is believed
to also be drawing water from the Sand and Gravel Aquifer (SGA)
as well, but it has not been verified. The Interlachen well is
located on the north edge of Fairview Lake, at the center of the
neighborhood. The West Interlachen well is located on the north
edge of Fairview Lake at the west end of the Interlachen community.
Both the Interlachen and West Interlachen wells draw groundwater
from the SGA. These wells can be found east and north of the groundwater
contamination plume described above.
(Excerpted from Appendix A)
In 1963, the first manufacturing building was constructed by Electronic
Specialty Company (ES Co.) a major subcontractor to The Boeing
Company at the time. In 1969 the ES Co. was acquired by International
Controls Corporation, which in turn transferred the Portland plant
to a Boeing subsidiary, Radiation International, Inc. By 1979
Boeing was the sole owner of the facility property and improvements.
In 1979 and 1980, Boeing constructed a wastewater pre-treatment
plant, employee recreation areas, and building 85-105, used for
parts assembly and storage.
From 1981 to 1984, Boeing utilized a surface impoundment for the
temporary storage of rinseate from electroplating and metal finishing
operations prior to transfer to the wastewater treatment plant.
Upon closure of the impoundment in 1985, a Detection Monitoring
Program was implemented as required by DEQ. Six groundwater-monitoring
wells, installed around the perimeter of the impoundment, were
monitored from January 1986 to July 1987. Contaminated groundwater
was found with high levels of trichloroethylene (TCE), 1,1,1-trichloroethane
(TCA), and methyl ethyl ketone (MEK). The monitoring program revealed
that other point sources were suspected due to the elevated levels
of contaminants detected in upgradient monitoring wells.
The Cascade facility was constructed from 1955 to 1956 for the
purpose of manufacturing forklift truck attachments. At the time
the facility included a waterfall paint booth, a parts assembly
area, a maintenance shop, an assembly area for hydraulic cylinders,
two underground storage tanks (USTs) for gasoline storage, and
offices. In 1961, Cascade installed a vapor degreaser near the
hydraulic assembly area for the purpose of cleaning metal parts
with TCE. The degreaser was used continuously until 1975 when
it was removed, and TCE usage was discontinued.
Operations expanded to include nickel and chrome electroplating
in 1963. Chrome and nickel plating operations were discontinued
in 1978, but nickel plating was resumed from 1982 through 1986.
In 1966, another facility expansion included carburizing of forklift
attachments, which continued until 1985, when carburizing was
replaced by purchasing tempered steel.
In 1971, two underground storage tanks were installed to store
waste coolant and oils. Cascade installed a cutting bin drainage
system in 1979 that collected coolant lubricant drippings from
metal cuttings for transfer to the waste coolant tanks. The waste
coolant tanks and cutting bin drainage system were decommissioned
in 1988 under the supervision of DEQ. At that time, approximately
50 cubic yards of contaminated soil was removed and disposed of
at an off site facility. In the fall of the same year Cascade
received a Consent Order from DEQ to conduct additional investigations
into the nature and extent of contamination.
The contamination site is in an area with several
geologic layers. The top layer is called the Troutdale Gravel
Aquifer and does not cover the entire study region. Below this
layer is a confining geologic unit and a second aquifer called
the Troutdale Sandstone Aquifer. Because of the geologic characteristics
of the site and location of the two contamination sources the
cleanup plan has been broken down into several components with
oversight by two different agencies. Issues related to the contamination
in the Troutdale Gravel Aquifer (TGA) at the Boeing Company and
the TGA cleanup plan fall under the EPA to administer oversight.
For the Troutdale Gravel Aquifer at the Cascade Corp. site, the
DEQ is responsible for overseeing the work done to cleanup the
site. For the Troutdale Sandstone Aquifer, regardless of the origin
of the contamination, DEQ is responsible for overseeing the cleanup.
The following compounds are listed as Chemicals of
Concern (COC) for the groundwater contamination at the project
site indicating they may pose a threat to the community's health.
The original chemicals are chlorinated solvents, such as PCE and
TCE, which were used at both sites in vapor degreasers or to clean
metal parts. Some chemicals listed are degradation products of
PCE and TCE. For more information on the chemicals of concern
for the study region also refer to Appendix A.
Public health concerns related to the site involve
the potential exposure in the area to the chemicals of concern
through three pathways. The first is from drinking well water
from the aquifers, which are contaminated with some of these compounds.
The second pathway involves exposure to the compounds through
direct contact with the soil or surface water bodies. Many local
residents use the surface water bodies in the area for swimming,
fishing and water recreation in general. The third pathway is
inhalation of the compounds from either volatilization from surface
water bodies or through cleanup measures, which involve volatilizing
the compounds using air strippers. Community members have also
been concerned about ecological risks to wildlife and aquatic
life.
The timeline is designed to show some of the key
events and documents generated concerning the groundwater contamination
site. This list is not intended to be comprehensive.
| Phase 3, RI/FS, Troutdale Gravel Aquifer, Parts 1 & 2 released. | |
| Final Remedial Investigation and Feasibility Study Work Plan for the Troutdale Sandstone Aquifer released. | |
| Community Relations Plan for EMC Groundwater Contamination issued. | |
| Public Health Assessment for EMC Groundwater Contamination released. | |
| RI & Endangerment Assessment, Troutdale Sandstone Aquifer, Parts 1 & 2 released. | |
| Phase 3, RI/FS, Troutdale Gravel Aquifer, Part 3 released. | |
| TSA Sandstone Gravel Aquifer Data Gap Investigation and Interim Removal Measure Report issued. | |
| EPA announced opportunity for Technical Assistance Grant. | |
| Friends of Blue and Fairview Lake applied for grant. | |
| Friends of Blue and Fairview Lake met with EPA and DEQ to discuss site issues and the grant application. | |
| EPA awarded TAG to Friends of Blue and Fairview Lake. | |
| Friends of Blue and Fairview Lake solicited bids for contracts to serve as a Technical Advisor. | |
| Portland State University and other organizations submitted proposals. | |
|
| Portland State University selected as Technical Advisor by Friends of Blue and Fairview Lake. Contract details negotiated between Friends of Blue and Fairview Lake and PSU Technical Advisor panel chairperson. |
| First panel meeting with the community held at PSU. | |
| Preliminary letter sent to DEQ with PSU Panel findings on technical work done thus far by the potentially responsible parties. | |
|
| Documents released by DEQ and EPA: "Summary of Proposed Cleanup Plan for the TGA at the Cascade Corporation Site", "Summary of the Proposed Cleanup Plan for the TSA", and the staff reports for each proposed cleanup plan. |
| Beginning of the public comment period for the proposed cleanup measures. | |
| DEQ held an informational meeting at PSU for the panel, community and responsible parties about the proposed remediation plans. | |
|
| Panel held a meeting with the community, DEQ, and responsible parties to provide comments on the proposed plan for remediation of the groundwater contamination. Informational factsheets and the Panel's final report were presented. |
| Panel letter and final report submitted to DEQ regarding points of concern on the proposed remediation plans and on the previous technical work done (Appendix A). | |
| End of the public comment period for the proposed cleanup measures. | |
| DEQ released the Remedial Action Record of Decision for the East Multnomah County Groundwater Contamination, Troutdale Sandstone Aquifer. | |
| News bulletin developed for the Friends of Blue and Fairview Lake to raise awareness in the community. | |
| EPA released the Statement of Basis for The Boeing Portland Facility, Troutdale Gravel Aquifer. | |
| Draft Remedial Design and Remedial Action Work Plan, Troutdale Sandstone Aquifer was issued. | |
| DEQ provided comments to the responsible parties on the draft Remedial Action Work Plan. | |
| DEQ released comments to the Draft Remedial Design and Remedial Action Work Plan. | |
| Panel reviewed and submitted comments on the EPA's Statement of Basis, the Boeing Portland Facility, Troutdale Gravel Aquifer. | |
| Panel reviewed Draft Remedial Design and Remedial Action Work Plan for the TSA and DEQ's comments on the Work Plan. | |
The purpose of the panel at Portland State University
was to provide technical assistance to the community to review
and evaluate the work done by consultants and agencies for serious
flaws, which could jeopardize the community's water supply and
surface water system. Additionally the panel will work with the
Friends of Blue and Fairview Lake to educate the community about
the nature of the contamination. Lastly the panel will make recommendations
to the community to protect their water supply and surface water
system, and comment on technical documents to the DEQ and the
EPA on behalf of the Friends of Blue and Fairview Lake to express
technical concerns revealed in the review process.
The panel consisted of six people from Portland State University and for the first year one person from an outside consulting firm. The list below provides a general description of each of the panel member's expertise in their respective fields. The expertise of the Technical Advisor will vary depending on the site characteristics and the needs of the community.
Since the proposed Superfund site has been under investigation
for over ten years prior to the panel at PSU taking on the role
as Technical Advisor, many documents have been produced and were
needed for review. Due to the large number of documents it was
necessary to identify which documents would be vital to understanding
the technical developments that have occurred over the site's
investigation period. By using these documents, the panel would
be able to familiarize themselves with the technical issues in
a reasonable time frame. The document research began by visiting
the Rockwood Public Library, which was near the contamination
site and served as a public repository for technical reports.
The documents obtained from the Rockwood Public Library started
the core of the technical report library, which was to be built
at PSU. This "new" library was designed to facilitate
the panel review process by making the documents very accessible
to the panel. Additionally, the new library would provide another
site where the documents would be accessible to the public.
A bibliography of the library's contents was created and updated
in a database as the library grew. The database was generated
to keep the reports organized and to allow each panel member to
know the contents of the library without actually going through
the library. The database would also allow panel members to search
for documents of interest in the library. If the library did not
have the report, then it could be requested and added to the list
of documents to be obtained. This approach facilitated the document
review and acquirement process for the panel by allowing requests
to be made through electronic mail and searching the library by
computer.
Although the library contained many of the documents that were
generated by the various parties involved with the site, the collection
was far from complete. The next step was to talk with the DEQ
about identifying some of the key documents for review. A DEQ
representative and a panel member went over the bibliography from
the Community Relations Plan to identify the key documents which
should be obtained and reviewed by the panel. The Community Relations
Plan report was chosen because it was the most comprehensive and
recent document concerning the site at the time, which contained
an extensive bibliography of past work regardless of source. Based
on this discussion a list of additional documents was created.
The document list was then broken down by the authors' names.
A panel member then contacted the various authors and requested
assistance in obtaining copies of the documents. Almost all of
the documents generated concerning the site have become public
domain information due to consent order agreements worked out
with the PRPs and the DEQ or the EPA. First the consulting firms
for the PRPs were contacted to request copies of the documents,
but in order to release the information to a third party it became
necessary for the panel to get direct permission from the PRPs.
Because the TAG budget for the first year had only set aside a
specific amount of funds for copying expenses and acquiring the
documents for review, it was important to ensure the panel stayed
within this budget. There was still a large number of documents
to be obtained for review so one of the panel members sent a direct
letter to the two potentially responsible parties asking for permission
to get copies of the documents from the consulting firms. Additionally
the PRPs were asked if they would be willing to donate copies
of the documents to keep down grant expenses for copying. Additionally,
this letter was used because the Technical Advisor was an outside
party reviewing the technical issues related to the site. One
of the two PRPs provided the documents requested for no charge.
In order to get the remaining documents several additional approaches
were taken. Due to the Freedom of Information Act the panel was
able to obtain EPA documents related to the site for free and
allowed to review the documents before copies were generated to
ensure the appropriate information was obtained. In addition,
the DEQ allows citizens to visit their office in downtown Portland
to view documents. The panel was able to work with DEQ and establish
a level of working trust which allowed the panel to temporally
remove copies of the documents from the DEQ office and have copies
made for the panel to add to their library.
By utilizing all of these approaches, a library of almost 200
(presently over 200) technical documents was created for the panel
to use in their review process. During the document collection
and review process, if panel members had specific requests for
technical documents not already on the list to be acquired they
could have them added to the list. An attempt was made to try
to acquire the requested documents as soon as possible. Since
the initial document collection, as new documents were released
the panel was able to obtain a copy from DEQ. As more documents
were added to the library the bibliography database was continuously
updated. Key documents such as the proposed cleanup measures for
the site were added to the library and copies were generated for
the panel members to review them as soon as possible since the
comment periods were brief.
Once documents were obtained, the panel began the process of reviewing
the past technical work. The purpose of this review was to look
for any potential weak areas in the technical assumptions or conclusions
made in the work which would lead to potential hazards for the
Interlachen community or the larger community affected by the
site. Additionally, the review covered potential weak areas that
would influence future work such as the development of the proposed
corrective measures for cleaning up the site. Below is a list
of some questions, which the panel examined when conducting the
technical review and addressed later in their report to the community.
Questions Examined
As part of the review process the panel met on a relatively regular
basis and panel members focused their review efforts in areas
related to their expertise. The panel meetings were used to bring
the various aspect of the groundwater contamination review together
and provide an overall picture of the work that had been done
at the site. The panel meetings were also used to brief one another
on issues such as the geologic stratigraphy of the area, groundwater-modeling
efforts, toxicology issues and remediation strategies for the
site already in progress. These briefings allowed each panel member
to become familiar with issues and interactions at the site not
directly in their field of expertise, but important to the overall
technical review.
The panel used electronic mail extensively to submit comments
or findings throughout the review process to the chairperson or
other panel members. Additionally electronic mail was used to
schedule panel meetings quickly, exchange data, submit elements
of the final review report to the chairperson, discuss issues
and request documents. Electronic mail allowed direct communication
of ideas and comments rapidly, and reduced the amount of time
panel members need to spend on the more logistical side of working
on a panel. In turn the panel member could spend more time focusing
on the actual review of the technical documentation and creating
the review report.
In addition to the panel reviewing the technical work by the PRPs,
DEQ, and others, the panel provided a preliminary set of findings
to DEQ in June of 1996 before DEQ released their proposed cleanup
plans for the site. By submitting these preliminary findings before
DEQ released the cleanup proposals, the panel was aiming to inform
the DEQ of these concerns so they might be addressed in the cleanup
proposals.
Once the cleanup proposals were issued (refer to timeline), the
panel began reviewing and commenting on them. This review process
along with the technical review conducted earlier culminated in
a report on the groundwater contamination to the community, which
made several recommendations concerning the technical work and
the proposed cleanup measures. The report was issued during the
public comment period to allow the CG to review the report, learn
about the panel's conclusions and recommendations, and then be
able to testify at a DEQ public comment session held before the
close of the comment period.
The panel created several products over the first year of the
TAG Program. As the panel continues to work with the community,
future products will be developed to assist in the process of
educating the community about the nature of the contamination
and issues raised from reviewing new documents.
The technical report was a useful document to the community for
several reasons. It provided the community with a brief summary
of the issues related to the site. Although the document was slightly
over 50 pages, it covered many topics of interest to the community
without getting overly detailed. The report also included a bibliography
of all the documents in the library at Portland State University,
which were used in the review process. A glossary of terms was
supplied in the report to identify terminology, which may not
have been familiar to community members. Background information
about the site and how the contamination occurred in the first
place was provided and the introduction provided information about
how the technical work was possible for the Friends of Blue and
Fairview Lake. Additionally, the report included a section that
allowed the community members to have written questions submitted
to the panel, answered and documented in the report.
The Interlachen Community factsheets generated were produced out
of the technical report and were designed to present some of the
key information to the community in an even shorter format. A
series of 12 factsheets were designed to provide an easy to read
overview of the issues related to the site, the proposed recommendations
by DEQ, and the conclusions and recommendations of the panel.
The factsheets were designed to be brief one page informational
sheets for the Friends of Blue and Fairview Lake to use in raising
awareness in the community. These sheets could be used by the
CG for their own community meetings or for their own newsletter
to inform local residents not involved with the CG about the site.
The factsheets can be found in Appendix B.
This first letter sent to DEQ was designed to notify DEQ of the
work the panel was conducting on the site and to illustrate some
of the panel's immediate concerns. The letter was sent out before
DEQ released their proposed cleanup measures for the Troutdale
Gravel Aquifer at the Cascade site and the Troutdale Sandstone
Aquifer.
The panel submitted a second letter to DEQ with their list of
concerns and recommendations on behalf of the Friends of Blue
and Fairview Lake. The letter contained the recommendations incorporated
into the technical report, but through the letter the list became
part of the official record of comments to DEQ concerning the
proposed cleanup measures, leading to a DEQ response to the comments
in the Record of Decision for the site.
The EPA was the responsible agency for overseeing and establishing
the cleanup measures for the TGA for the Boeing Portland Facility.
The panel reviewed the Statement of Basis for the site, which
described the proposed cleanup measures, while keeping in mind
the other cleanup plans proposed by the DEQ. This brief report
was designed to provide the EPA with a list of concerns on the
proposed cleanup measures. The letter and comments from the panel
became part of the official record of comments for the cleanup
measures requiring the EPA to respond to these concerns in the
Record of Decision for the site.
Based on the review report created in October of 1996 by the panel
a brief 2-page news bulletin was created specifically for raising
widespread awareness with the community about the site contamination.
The bulletin covers a summary of the panel's work and conclusions
from the report plus contact information, and a small map illustrating
the location of the contamination plume relative to major surface
features. The bulletin was reviewed by several members of the
Friends of Blue and Fairview Lake to improve its readability and
ensure all of the material would be well understood by the community.
The advantage of this approach for the CG was to have an extremely
brief newsletter that could be mass-produced inexpensively to
inform more people about the groundwater contamination. According
to an interview with members of the Friends of Blue and Fairview
Lake, the bulletin was delivered by hand to more than 300 households
in the site area.
The panel used some of the documents they generated to develop a website as an additional resource. For example Appendix A and Appendix B can both be found on the website. The goal is to provide the larger community with another way to learn more about the groundwater contamination site and some of the work being done at the site. The website also provides the community with periodic updates on some of the products created through the panel's work.
The panel at Portland State University held two of their own community
meetings with the Friends of Blue and Fairview Lake and other
community members. Additionally the panel also hosted a third
meeting at the University for DEQ.
The first community meeting held with the panel was an initial
meeting to introduce the community to the members of the panel.
Additionally this meeting gave the community an opportunity to
learn about the site contamination and the activities the panel
would be conducting for the Friends of Blue and Fairview Lake
and the community. The meeting consisted of one of the leaders
of the Friends of Blue and Fairview Lake introducing the panel
chairperson, who then gave a brief presentation introducing some
of the site issues to the community and described the nature of
the contamination. Then each panel member was introduced and his
or her expertise was presented as it related to the site review
work. The event was held at PSU in an informal setting for the
community where food and drinks were provided.
The next community meeting was held at PSU but was conducted by
DEQ. After the release of the two proposed cleanup plans, DEQ
held a meeting at PSU to present the proposed corrective measures
for both sites in the study region. DEQ provided some background
to the site contamination and reviewed the proposed corrective
measures selected for each site and discussed why they were chosen.
The benefit of this meeting was to allow the DEQ to explain the
proposed cleanup plans for both sites during the public comment
period so when citizens testified at the two public comment period
hearings they would be well informed about the proposed plans.
The DEQ also hoped to answer any questions the citizens or any
other parties might have about the plans rather then waiting until
the public hearings were conducted. By locating the DEQ presentation
at Portland State University, the meeting would be held on a third
party's grounds to help instill a sense of objectiveness in the
meeting proceedings. After the presentation was completed, a formal
question and answer session was held allowing anyone in attendance
to ask DEQ questions about the proposed plans. Then at the close
of the question and answer period the meeting was formally concluded,
but the representatives from the DEQ were available to talk with
anyone informally and address any additional concerns or questions.
The second community meeting the panel held was in October of
1996 before the end of the public comment period on DEQ's proposed
cleanup plans. The meeting was held at the Blue Lake Park House
which is a public building located near the residents affected
by the site. The main purpose of the meeting was for the panel
to present their findings, conclusions and recommendations to
the community. Copies of the panel review report were presented
at the meeting along with copies of the informational factsheets
and a copy of the letter sent to DEQ.
The meeting began with a brief introduction by a representative from the Friends of Blue and Fairview Lake. Then the chairperson of the panel began the presentation by providing a history of the review process, descriptions of the goals of the review, and a description of the panel products. Then each panel member was introduced and provided a brief presentation of their findings relative to their field of expertise. The following topics were presented: groundwater modeling, geologic stratigraphy, geochemistry, toxic risk assessment, and a review of the response to DEQ's proposed cleanup plans. After the presentations were completed there was a question and answer period providing anyone with an opportunity to ask the panel members about their findings and recommendations. Representatives from all of the interested parties were present as well as citizens who live in the area. The Friends of Blue and Fairview Lake provided light fare and drinks for those in attendance and at the close of the meeting informal discussions took place which allowed attendees to talk one-on-one with the panel members. Based on an interview with several members of the Friends of Blue and Fairview Lake, they found this community meeting very beneficial for several reasons:
In addition to the activities above, several other activities
were conducted which were either facilitated by the panel or conducted
in partnership with the Friends of Blue and Fairview Lake. At
the first community meeting, held at PSU, the Friends of Blue
and Fairview Lake arranged to have the meeting videotaped. Then
for the second community meeting, held at the Blue Lake House,
one of the panel members assisted the community group in having
a third party videotape the meeting. The goal behind videotaping
the meetings was to provide an additional tool for the community
group to educate others in the local area about the contamination
and how it affects the residents. The Friends of Blue and Fairview
Lake could also use the videotape to develop their own video to
inform others outside the local community about the activities
related to the site. For example, if an environmental group were
interested in learning more about the nature of the contamination,
the videotape would provide an excellent resource of information.
The downside to this approach was the video footage recorded at
the second community meeting was not a good quality recording,
which made it less useful. Additionally the work involved with
editing video footage and arranging it for other uses can be costly
and time consuming.
Another task conducted by the panel was to develop flyers and
agendas for the community meetings, and the DEQ meeting at PSU.
The flyers were rather straight forward, but were important for
the Friends of Blue and Fairview Lake to encourage as many citizens
as possible to attend the meetings. The idea was to provide key
information about the meetings and use the PSU logo to bring a
certain degree of objectiveness to the meeting flyers and to illustrate
to the community members the meeting would be filled with factual
information regarding the groundwater contamination. By providing
this simple service for the CG, a certain level of integrity and
objectiveness was put forward with the meetings which would hopefully
encourage more citizens to attend.
The chairperson of the panel also testified in front of the Portland
City Council on behalf of the Friends of Blue and Fairview Lake
to explain the panel's conclusions from the technical review and
their recommendations regarding DEQ's proposed cleanup plans for
the site. This testimony was conducted to inform the City of Portland
about the influence of some wells in the Portland Wellfield on
the contamination plume. Since some of the wells in the Portland
Wellfield were close to the contamination plume, their activation
could seriously influence the plume's migration. The Friends of
Blue and Fairview Lake asked the panel chairperson to testify
because the CG wanted to ensure more credibility and a third party
objective point of view on the issue when expressing their concerns
to the Portland City Council.
Between the community meetings, it was important for the Friends
of Blue and Fairview Lake to be in touch with the panel's activities
during the review process. This would allow the community to understand
the issues developing through the review and be able to assess
the project progress when reporting to the EPA on a quarterly
basis. To facilitate the involvement of the community group several
actions were taken.
The panel chairperson served as the main contact between the panel
and the CG and frequently touched base with the CG by phone or
brief informal meetings. Additionally, key members of the Friends
of Blue and Fairview Lake were invited to the panel meetings to
sit in on the latest developments of the review. Frequently, after
the panel meetings the panel chairperson and the graduate student
on the panel would meet with the citizens to answer any questions
about the meeting or address other concerns. The entire panel
made themselves available to the community to answer any questions
or talk about site-related issues. The panel meetings in general
were informal with coffee and tea served and was designed to work
out details of the review process as described above.
Additionally, while in the review process the panel also had citizens submit questions regarding the groundwater contamination site. The panel answered these questions and then forwarded them back to the Friends of Blue and Fairview Lake for their next Friends meeting.
Below is a brief list of some of the major work pieces
the panel will be conducting in the near future, and should not
be considered a comprehensive list.
The McCormick & Baxter Creosoting Company Plant
can be characterized by groundwater, soil, and sediment contamination
along the Willamette River. The University Park Neighborhood Association
and the Friends of Cathedral Park Neighborhood Association formed
the Willamette Associates for Kindness to the Environment in University
Park, WAKE-UP, for the purpose of addressing site-related issues
at the McCormick & Baxter Creosoting Company plant facilities.
WAKE-UP then created a Community Advisory Committee to handle
details related to the site contamination. The CAC then used a
TAG from the EPA to hire a Technical Advisor to review technical
documentation and provide guidance related to the Superfund site.
McCormick & Baxter Creosoting Company operated
a wood treatment plant in North Portland. The site consists of
43 terrestrial acres and another 15 aquatic acres. The site is
located along the Willamette River just upstream from the Burlington
Northern Railroad Bridge. The citizen group mentioned above represents
several communities in the vicinity of the site who may be potentially
affected by the contamination.
The McCormick & Baxter Creosoting Company operated
the wood treatment plant on the site from 1944 to 1991. The company
was founded during World War II to produce treated wood products
with their first cylindrical pressure chamber for treating wood
constructed in 1945. Several other chambers for treating wood
with various chemicals were constructed in the 1950s. An additional
treatment facility was built in 1968 to treat wood with Cellon
but its use was discontinued in 1988.
Wastewater from several plant processes was discharged
to the Willamette River between 1945 and 1969. In addition, other
by-products of plant operations were discharged to the disposal
trench located in the southeastern portion of the site. The company
experienced two major spills at the site in 1950 and 1956, both
of which occurred near the tank farm on the site.
Some stormwater discharges from the site were permitted
under a NPDES permit in 1971, but other storm water discharges
were unpermitted and were discontinued as part of the DEQ's effort
to implement interim site stabilization activities. The waste
disposal area in the western portion of the site was used between
1968 and 1971 to dispose of plant operation sludge and wastes.
After 1978 the wood preservative sludge was disposed of off-site
using a permitted hazardous waste disposal facility and procedures.
Underground storage tanks used for storing chemicals, gasoline
and diesel fuel were removed after 1985.
In 1988 McCormick & Baxter filed for Chapter
11 bankruptcy, and in 1990 DEQ assumed responsibility for completing
investigations and cleanup activities at the site. In 1991 the
company's lending institution took control of its assets and the
company ceased operations. Later in the same year DEQ began implementing
interim remedial activities at the site to prevent any more chemical
releases.
The Department of Environmental Quality is the lead
agency for implementing cleanup measures at the site and for instituting
remedial investigations, feasibility studies and interim corrective
measures at the site. The DEQ and the EPA are working together
under a cooperative agreement established in 1995. The EPA is
providing funding for the site cleanup since it has been listed
as a Superfund site on the National Priorities List.
Below is a list of chemicals of concern for the site
based on historical activities, but should not be considered a
comprehensive list.
The main public health concerns regarding the site
are related to exposure to the chemicals of concern through three
major pathways. There is concern the contaminated groundwater
could migrate off site and hypothetically (no drinking water wells
in the area presently) contaminate drinking water supplies resulting
in potential human ingestion of the chemicals. Additionally, there
is concern people may ingest the chemicals through eating fish
exposed to the contaminants in the Willamette River. A second
pathway of concern is through direct contact to the chemicals
via contaminated soil or sediments at the site. The third pathway
of concern is through inhalation of dust particles from future
uses at the site or from exposure during remedial activities.
The timeline is designed to show some of the key
events and documents generated concerning the McCormick &
Baxter Creosoting site. This list is not intended to be comprehensive.
| McCormick & Baxter Creosoting Company operated wood treatment plant. | |
| DEQ investigates extent of contamination. | |
| Open house held prior to investigations for the project activities and schedule of objectives. | |
| Plant closes and cleanup taken over by DEQ. | |
| Community work group formed with local neighborhoods and environmental groups, met 5 times. Three presentations were done by DEQ about the issue to community groups. | |
| DEQ met with the community work group 2 times. Two presentations done by DEQ about the issue to community groups. | |
| RI/FS completed for the site for DEQ. | |
| DEQ releases proposed cleanup plan for McCormick & Baxter Creosoting Company Site. | |
| DEQ gives public notice of 1992 proposed Cleanup Plan, Comment period opens. | |
| DEQ Public Comment meeting for the proposed cleanup plans. | |
| DEQ hosts second public meeting to explain details on the proposed cleanup plan. | |
| Comment period on proposed cleanup plan closes. | |
| Community work group starts meeting quarterly. | |
| DEQ delayed implementation of the cleanup plan based on 1992 proposal pending listing on the NPL as a Superfund site. | |
| DEQ implemented remedial actions at the site to reduce spread of contamination. | |
| Site put on Superfund National Priorities List now managed and funded by EPA and DEQ. | |
| DEQ gives several more presentations about the site related issues for community groups. | |
| Community Relations Plan for the McCormick & Baxter Creosoting Site, DEQ. | |
| DEQ/EPA issued proposed plan for cleanup and Revised RI/FS report. | |
| Public comment period begins for proposed cleanup plan for the site. | |
| WAKE-UP holds a public forum and open house (Review of the Cleanup Proposal). | |
| Public meeting held by DEQ and EPA regarding the proposed cleanup plan. | |
| Public comment period ends for the proposed cleanup plans for the site. | |
| Review Report on the McCormick & Baxter Creosoting Site Proposed Cleanup Plan and FS using a Technical Assistance Grant from WAKE-UP released. | |
| Record of Decision McCormick & Baxter Creosoting Company Portland Plant by EPA and DEQ. | |
The focus of the Technical Advisor for the McCormick
& Baxter Creosoting Company site was to review the proposed
cleanup measures and feasibility study for the site and educate
the community about the nature of the site contamination. The
Technical Advisor's work culminated in a review report, which
was approved by WAKE-UP and forwarded to DEQ as an official set
of comments on the proposed cleanup measures.
Although there may have been many activities conducted by the
Technical Advisor for WAKE-UP, this report focuses on the activities
related to the proposed cleanup measures for the McCormick &
Baxter site. The proposed cleanup measures were released for public
comment at the end of October in 1995. The Technical Advisor then
reviewed the proposal in detail and held a community meeting with
members of WAKE-UP and others. At the end of the presentation
period there was an opportunity for the citizens to ask the Technical
Advisor questions about the proposed cleanup plan. At the close
of the meeting the community members were able to record their
comments on DEQ's and EPA's proposal on a flip chart which was
then included as an appendix to the review report later published
by the Technical Advisor.
As part of reviewing the proposed cleanup measures and addressing
some of the concerns of the local residents, the Technical Advisor
(SJO Consulting) conducted research in several areas. Their research
focus covered low dose exposure to dioxins, cancer cluster analysis
protocols, epidemiology, and a review of the feasibility of cleaning
up other wood treatment Superfund sites. The review report consisted
of 36 recommendations for DEQ to incorporate or consider before
moving on to the Record of Decision for the site cleanup plan.
Of those recommendations, two resulted in significant changes
to the proposed plan when the ROD was developed.
The first significant change was based on a recommendation which
suggested the Feasibility Study should clarify how the risk assessment
was assigned to the total PAH cleanup level. In response the DEQ
modified their remedial action cleanup level for carcinogenic
PAHs from 500 mg/kg to 100 mg/kg. Additionally through reevaluating
the field screening data and the laboratory tests conducted DEQ
decided to use total carcinogenic PAHs as the remedial action
level to allow a better estimation of the PAHs present in the
system.
The second change to the proposed plan resulted from the determination
the Alternate Concentration Limits (ACLs) for PAHs; PCP and dioxins/furans
exceeded the solubility limits for these chemicals. The calculated
ACLs also conflicted with one of the RAOs, which specifies that
discharges to the river should be minimized and in the case for
heavy metals the ACLs were well above the maximum concentration
limits detected in the groundwater. As a result DEQ lowered the
ACLs for metals.
The main product generated by the Technical Advisor for the CG
WAKE-UP was the Review Report on the proposed cleanup plan and
feasibility study for the site. As mentioned above the report
consisted of many recommendations based on concerns from local
citizens and from reviewing the proposed plan. The report was
generated on behalf of WAKE-UP and submitted to DEQ as a list
of formal comments to the proposed plan during the comment period.
This in turn resulted in the DEQ responding to these comments
in the ROD.
WAKE-UP held several community meetings to get input from local
residents affected by or concerned about the site contamination.
At these meetings the community was given the opportunity to make
comments in writing about the proposed cleanup measures and the
feasibility study conducted. The comments, which came out of these
meetings, were then used to direct the work conducted by the Technical
Advisor and develop the review report described above.
Additionally, the Technical Advisor and the head of the CG, WAKE-UP, co-hosted at least one of these community meetings. At this meeting the community was introduced to the proposed cleanup measures for the site and was given the opportunity to ask the Technical Advisor questions.
Based on the review of the TAG process several conclusions
can be drawn from the review presented. The TAG Program can be
an overwhelming process for new groups getting involved in a Superfund
site or proposed Superfund site. The EPA handbooks provide many
of the details needed to complete the application process, select
a Technical Advisor and manage the grant but the handbooks need
to have more information about the TAG process from a larger perspective.
This could include providing flowcharts similar to the ones created
in this report to better explain the steps necessary in the TAG
process and to show the CG where several steps in the process
occur in parallel. In discussing this issue with the Friends of
Blue and Fairview Lake, members of the group felt the process
was at time "mysterious" because they were unsure of
what steps to follow or how to keep on a project reporting timelines.
Additionally, several points in the handbooks need to be clarified
further and discrepancies between the books should be resolved
Aside from the confusion the CG experienced in the
applying for the grant, the Friends of Blue and Fairview Lake
repeatedly complimented the EPA, in an interview, on their efforts
to provide assistance by answering questions the citizens had
about the process. One way this system might be improved to make
it easier for both parties is to show community groups case studies
of TAG Programs for other sites. The purpose of these case studies,
whether shown on videotape or provided in a report, would allow
the CG to get a better idea of the necessary steps in the process
and to get a better understanding of the documentation and EPA
reporting requirements. This would help the CG members understand
better what information the EPA may be asking for in a particular
report or on a form. Case study reports would also give the CG
an idea of what administrative responsibilities are necessary
for the grant program and allow them to plan from the start how
best to approach managing and carrying out the project.
By providing materials such as flowcharts of the
process, videotapes explaining the process or case studies, and
documented case study reports, a CG would get a considerable insight
into the grant process even before the Technical Advisor is selected.
This might resolve many questions that the citizens contact the
EPA for and could possibly result in more accurate documentation
being submitted to the EPA from the beginning of the grant budget
period.
Another proposal to assist the CG in smoothly progressing
through the grant process might be to have a one time TAG Program
introduction training session to teach the grant recipient about
the work involved in the grant process during the budget period.
This type of training would provide all of the CG members involved
with managing the grant with the same information on how to proceed.
Another aspect of the TAG process involves the community
group's ability to organize and manage the grant. The community
group should be well organized from the beginning of the TAG process
and clearly designate specific people to handle tasks for the
group. This will ensure such things as Progress Reports are done
consistently and accurately on time for the EPA. It would allow
this person to become efficient at writing the Quarterly Progress
Reports, reducing the time spent on them, and allowing other members
to focus on various other tasks. By establishing a system of documentation,
storage and handling, and putting someone in charge of it will
allow documents to be retrieved efficiently and stored safely.
If the documentation related to the grant is maintained by several
different people or not kept in a central location material could
become misplaced through filing or lost all together.
So far the TAG process for the proposed Superfund
site in East Multnomah County, Oregon has been progressing well.
The Program has been successful in proving meaningful technical
review results to be utilized by state and federal agencies involved
in the site and for the community group to learn more about the
site and disseminate the information to the community.
There are several areas where the TAG process for
the groundwater contamination site could be improved. It would
be to the advantage of the CG to brief the panel members of their
efforts to raise awareness in the community. Based on reviewing
the activities over the past year, it is not clear how successful
the efforts by the Friends of Blue and Fairview Lake have been
at educating a wider group of citizens. There also has not been
much discussion about the techniques used to try to achieve this
wider dissemination of information and education of site related
issues. By the Friends of Blue and Fairview Lake providing more
details to the panel about their efforts to educate the community,
the panel may be able to offer suggestions on new approaches or
materials which could be utilized to disseminate factual information
about the site. The panel may even be able to come up with some
simple tools or materials that may help the CG reach more citizens
who are affected by the site. Trying to reach out to more citizens
and get more involvement in the site is a long process of trial
and error to determine the most effective means for a specific
community. There is potential for more partnership between the
CG and the panel on this issue.
One of the key aspects of the TAG Program is the
technical panel interpreting and explaining to the community the
important issues related to the site in a way that the community
can understand it. The panel at PSU has done a good job at educating
the citizens by hosting several community meetings, developing
informational factsheets for the community, and allowing community
members to sit in on panel meetings. One idea, which might help
this process further, is when the panel holds community meetings
to present findings or discusses technical issues; each panel
member who makes a presentation should create lecture note sheets
for the community members in attendance. The lecture note sheets
would consist of a brief page or two of the main points, in bullet
items a presenter is making before the community group and then
provide space for the citizens to take notes. Additionally, the
note sheets would include contact information about the presenter.
This type of information would allow a person to follow the presentation
better, take notes on specific points presented and provide a
reference for them after the meeting has ended. The lecture note
sheets would be kept simple and straight forward, but complete
enough to include the key points of each presentation. If more
than one presenter will be speaking, then separate lecture notes
should be provided for each presenter along with individual contact
information.
Although over the past year the PSU panel has been
serving as the Technical Advisor for the CG and has been actively
participating in events related to the site, the panel is not
in the communication loop for new information. This new information
may include data, findings, upcoming reports or events in the
project. After one year, the panel is familiar with the site-related
issues, but state and federal agencies and the local parties involved
do not notify the panel or the CG about new information or events
until they are about to occur or the next step has already started.
A case in point is the release of the Statement of Basis by the
EPA for the Boeing Portland Facility, Troutdale Gravel Aquifer.
The community group and the panel were not aware of when this
document was being released until after the public comment period
had started. Additionally when new well data are taken in the
field, the panel is not informed of the results of these tests
unless it is by word of mouth. Although the respective agencies
are not required to notify the CG or the panel, it would be in
their best interest to facilitate the project's cleanup process
for the site by assisting in keeping all of the parties involved
in the site up-to-date.
In comparing the two case studies, the approaches used by each Technical Advisor in reviewing the proposed cleanup measures for the respective sites was considerably different. The Technical Advisor for WAKE-UP seemed to focus more on the direct concerns of the affected citizens and less on researching potential weak points in the proposed plan independent of specific inquiries by the citizens. For example, most of the technical work conducted by the Technical Advisor for the Friends of Blue and Fairview Lake covered issues the community may not even have thought of or had the expertise to investigate. These conclusions were in addition to concerns already expressed to the panel earlier and incorporated into the broader picture of the review process. The review report for WAKE-UP focused more directly on the immediate concerns expressed by the citizens and can be seen by comparing the list of recommendations to the appendix of citizens' comments from the open house. Each approach has its own merits, but the approach conducted by the Technical Advisor for the Friends of Blue and Fairview Lake was more comprehensive. It should also be noted though due to the review conducted by the Technical Advisor for WAKE-UP two significant changes were made in the ROD from the proposed cleanup measures. The recommendations from the Technical Advisor for the Friends of Blue and Fairview Lake resulted in three significant changes to ROD for the Cleanup measures related to the TSA.
Overall there were several key points which all community
groups should consider while applying for and managing a TAG.
When the CG selects a Technical Advisor, it is important
they conduct the review carefully. As part of the review process
the CG needs to ensure a potential Technical Advisor meets their
interpretation and technical needs. The CG needs to feel comfortable
working with Technical Advisor and willing to discuss any technical
issues, which develop during the technical review. The Technical
Advisor should also be willing to go beyond what the community
directly sees as concerns. Due to the scientific expertise of
the Technical Advisor it is possible they will discover issues
of concern while conducting the technical review which the community
may not even be aware of as a concern. Both the Technical Advisor
and the CG need to also be able to communicate well and often
to ensure each side needs are met in the contract. The more the
CG works directly with the Technical Advisor the more likely the
products and services from the TA will be useful to the community,
and to the state and federal agencies involved at the site.
Overall, the TAG process can seem overwhelming never
mind the issues related to the Superfund site itself. It is important
for the CG to recognize there are resources available to assist
them through the process. The CG should also recognize a proactive
role is needed in managing the grant and working with the Technical
Advisor. This will ensure both will work smoothly and the results
will clearly benefit the community at large affected by the site.
Superfund Technical Assistance Grant (TAG) Handbook:
Applying for Your Grant. EPA 540-K-93-003,
Publication 9230.1-09A, PB 93-963352
Superfund Technical Assistance Grant (TAG) Handbook:
The Application Forms w/Instructions.
EPA 540-K-93-004, Publication 9230.1-09B, PB 93-963353 Applications:
SF424, SF424A, SF424B, EPA Form 5700-49 & Certification Regarding
Lobbying
Superfund Technical Assistance Grant (TAG) Handbook:
Procurement, Using TAG Funds. EPA 540-K-93-005,
Publication 9230.1-09C, PB 93-963354
Superfund Technical Assistance Grant (TAG) Handbook:
Managing Your Grant. EPA 540-K-93-006,
Publication 9230.1-09D, PB 93-963355
DEQ Remedial Action Record of Decision for the
East Multnomah County Groundwater Contamination Site, Troutdale
Sandstone Aquifer. Oregon Department of
Environmental Quality, Waste Management & Cleanup Division,
December 1996.
Statement of Basis for The Boeing Portland Facility,
Troutdale Gravel Aquifer. The Boeing Company,
ORD 054964481, Issued by the U.S. Environmental Protection Agency,
Region 10, March 1997.
Draft Remedial Design And Remedial Action Work
Plan, Troutdale Sandstone Aquifer, East Multnomah County, Oregon.
Prepared for Cascade Corporation and The Boeing Company, by EMCON,
and Landau Associates, Inc. April 14, 1997
Record of Decision, McCormick and Baxter Creosoting
Company, Portland Plant, Portland, Oregon.
Issued by the U.S. Environmental Protection Agency and Oregon
Department of Environmental Quality, March 1996.
Review Report on McCormick and Baxter Creosoting
Site - Proposed Cleanup Plan and Feasibility Study.
Prepared for Willamette Associates for kindness to the Environment
in University Park, by SJO Consulting Engineers, Inc. January
16, 1996.
Impact of Groundwater Contamination in East Multnomah
County on the Interlachen Community. Prepared
for the Friends of Blue and Fairview Lake by the Portland State
University Technical Advisory Panel. October 28, 1996 (See Appendix
A)
Groundwater Contamination in East Multnomah County,
Interlachen Community Fact Sheet Series.
Prepared for the Friends of Blue and Fairview Lake by Robert Annear
as part of the Portland State University Technical Advisory Panel.
October 28, 1996 (See Appendix B)
2 Interviews conducted with members of the Friends
of Blue and Fairview Lake (Jane Graybill, Chris Noble, Jean Riding,
and Gale Schulz)