[Federal Register Volume 79, Number 31 (Friday, February 14, 2014)]
[Rules and Regulations]
[Pages 8861-8863]
[FR Doc No: 2014-03173]

=======================================================================
-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R06-OAR-2011-0528; FRL-9906-60-Region 6]

Approval and Promulgation of Implementation Plans; Texas;
Revisions to the New Source Review (NSR) State Implementation Plan
(SIP); Standard Permit for Oil and Gas Facilities and Standard Permit
Applicability

AGENCY: Environmental Protection Agency (EPA).

ACTION: Final rule.

-----------------------------------------------------------------------

SUMMARY: The Environmental Protection Agency (EPA) is approving the
revisions to the Texas New Source Review (NSR) State Implementation
Plan (SIP) submitted by the Texas Commission on Environmental Quality
(TCEQ) on September 20, 1995; April 19, 1996; July 22, 1998; and
September 11, 2000. These revisions to the Texas SIP establish the
Standard Permit for Installation and/or Modification of Oil and Gas
Facilities. EPA is also approving non-substantive revisions to the
Texas Standard Permit SIP rules relating to applicability, submitted on
February 1, 2006, and March 11, 2011. EPA is taking these actions in
accordance with section 110 of the Clean Air Act (CAA).

DATES: This final rule is effective on March 17, 2014.

ADDRESSES: EPA has established a docket for this action under Docket ID
No. EPA-R06-OAR-2011-0528. All documents in the docket are listed on
the http://www.regulations.gov Web site. Although listed in the index,
some information is not publicly available, e.g., Confidential Business
Information or other information whose disclosure is restricted by
statute. Certain other material, such as copyrighted material, is not
placed on the Internet and will be publicly available only in hard copy
form. Publicly available docket materials are available either
electronically through http://www.regulations.gov or in hard copy at
the Air Planning Section (6PD-L), Environmental Protection Agency, 1445
Ross Avenue, Suite 700, Dallas, Texas 75202-2733. Contact the person
listed in the FOR FURTHER INFORMATION CONTACT paragraph below to make
an appointment.

FOR FURTHER INFORMATION CONTACT: Adina Wiley, Air Permits Section (6PD-
R), telephone<PHONE_NUMBER>, email<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION: Throughout this document wherever ``we,''
``us,'' or ``our'' is used, we mean the EPA.

Table of Contents

I. Background
II. Response to Comments
III. Final Action
IV. Statutory and Executive Order Reviews

I. Background

    The background for today's action is discussed in detail in our
December 24, 2013, proposal (78 FR 77261). In that notice, we proposed
to approve four submittals from the State of Texas as revisions to the
Texas New Source Review (NSR) State Implementation Plan (SIP) that
incorporate the Standard Permit for Installation and/or Modification of
Oil and Gas Facilities (hereafter referred to as the ``Oil and Gas
Standard Permit''). Texas initially submitted the Standard Permit
provisions on September 20, 1995, and submitted subsequent revisions to
those provisions on April 19, 1996; July 22, 1998; and September 11,
2000. The proposed approval and accompanying Technical Support Document
explain the existing SIP-approved Standard Permit Program in Texas;
give a summary of each of the submittals being addressed in this
action; and explain how those submittals comply with the applicable
federal requirements. The proposal further explains that the Oil and
Gas Standard Permit includes standardized conditions for the emission
units located at oil and gas facilities that may be authorized by the
Standard Permit. If a proposed project at an oil and gas facility
includes any emission units that are not explicitly covered by the Oil
and Gas Standard Permit, the permit applicant must obtain another type
of Standard Permit authorization, a permit-by-rule (PBR) or, if
necessary, case-by-case NSR permitting for authorization.
    In the December 24, 2013 proposal, we also proposed to approve
submittals from the State of Texas as a revision to the NSR SIP that
contain non-substantive changes to the applicability

provisions of the Standard Permits SIP permitting program. Texas
submitted revisions to the Standard Permit applicability provisions on
February 1, 2006 and resubmitted them on March 11, 2011.

II. Response to Comments

    We received comments from the Texas Commission on Environmental
Quality (TCEQ) and the Texas Pipeline Association (TPA) on our December
24, 2013 proposal. The comments we received can be accessed from the
www.regulations.gov Web site (Docket No. EPA-R06-OAR-2011-0528).
Generally, both the TCEQ and TPA were supportive of our proposed action
and expressed agreement with our analysis. However, each commenter
provided the following information concerning our proposed rulemaking
for which EPA would like to provide clarification.
    Comment 1: The TCEQ notes that the commission adopts standard
permits in an open meeting, for which notice is posted at least seven
days in advance and which provides additional opportunity for public
comment on the standard permit. Further, registration is required for
the Oil and Gas Standard Permit.
    Response 1: EPA acknowledges the TCEQ's support of our rulemaking
and appreciates the additional information provided by the TCEQ
regarding the rules and processes for implementing the Standard Permit
program. We agree that, in addition to a public hearing, the TCEQ is
required to adopt Rule Standard Permits in an open meeting and post
notice of the open meeting seven days in advance of the event. The
public meetings provided the public with an additional opportunity for
public comment on the Oil and Gas Standard Permit as adopted and
amended. EPA has prepared a Supplement to the Technical Support
Document to include the clarification from TCEQ. This Supplement to the
Technical Support Document is available in our rulemaking docket, EPA-
R06-OAR-2011-0528. EPA also recognizes that applicants must register
the use of the Standard Permit.
    Comment 2: The TPA commented that ``Through incorporation by
reference in TCEQ's Non-Rule Standard Permit, the terms of the Oil and
Gas Standard Permit continue to authorize existing and unchanged
facilities throughout the State of Texas and new projects and dependent
facilities in all Texas counties except for 15 counties located in the
Barnett Shale area.''
    Response 2: EPA acknowledges the support of the TPA for our
rulemaking, but must clarify and correct that statement made in Comment
2 above. The Oil and Gas Standard Permit addressed in this action is a
separate Minor NSR permit mechanism from the Non-Rule Standard Permit
for Oil and Gas. While similar source categories are authorized under
each, the Non-Rule Standard Permit for Oil and Gas applies only to the
15 counties in the Barnett Shale region. The Oil and Gas Standard
Permit applies throughout the State of Texas, with the exception of the
15 counties, for the listed categories of sources. Additionally, Texas
promulgated this Oil and Gas Standard Permit by regulation at 30 TAC
116.620, and it is not incorporated into the Non-Rule Standard Permit,
which was developed through a separate process under the SIP.\1\
---------------------------------------------------------------------------

    \1\ Texas adopted the Non-Rule Standard Permit in accordance
with 30 TAC Section116.601(a)(2). EPA approved this process for
Texas to adopt non-rule standard permits into the Texas SIP on
November 14, 2003. 68 FR 64543.
---------------------------------------------------------------------------

III. Final Action

    We are approving SIP submittals from the State of Texas for the
Minor NSR Oil and Gas Standard Permit at 30 TAC Section 116.620 as
submitted September 20, 1995; April 19, 1996; July 22, 1998; and
September 11, 2000. The types of emission units that may be authorized
by this section are the following: Internal combustion engines (ICEs),
natural gas turbines (NG turbines), flares, other combustion units
(design heat input >40 million BTU per hour), natural gas glycol
dehydration units, storage tanks, separators, condensers, vapor
recovery units, process vents, and process fugitives. We are also
approving the submittals for the Standard Permit SIP rules making non-
substantive changes to the Standard Permit applicability provisions in
30 TAC Sections 116.610(a) and (b) as submitted February 1, 2006, and
resubmitted March 11, 2011. We are approving these SIP revisions in
accordance with section 110 of the CAA.

IV. Statutory and Executive Order Reviews

    Under the CAA, the Administrator is required to approve a SIP
submission that complies with the provisions of the Clean Air Act and
applicable Federal regulations. 42 U.S.C. 7410(k); 40 CFR 52.02(a).
Thus, in reviewing SIP submissions, EPA's role is to approve state
choices, provided that they meet the criteria of the Clean Air Act.
Accordingly, this action merely approves state law as meeting Federal
requirements and does not impose additional requirements beyond those
imposed by state law. For that reason, this action:
     Is not a ``significant regulatory action'' subject to
review by the Office of Management and Budget under Executive Order
12866 (58 FR 51735, October 4, 1993);
     does not impose an information collection burden under the
provisions of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.);
     is certified as not having a significant economic impact
on a substantial number of small entities under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.);
     does not contain any unfunded mandate or significantly or
uniquely affect small governments, as described in the Unfunded
Mandates Reform Act of 1995 (Pub. L. 104-4);
     does not have Federalism implications as specified in
Executive Order 13132 (64 FR 43255, August 10, 1999);
     is not an economically significant regulatory action based
on health or safety risks subject to Executive Order 13045 (62 FR
19885, April 23, 1997);
     is not a significant regulatory action subject to
Executive Order 13211 (66 FR 28355, May 22, 2001);
     is not subject to requirements of section 12(d) of the
National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272
note) because application of those requirements would be inconsistent
with the Clean Air Act; and
     does not provide EPA with the discretionary authority to
address, as appropriate, disproportionate human health or environmental
effects, using practicable and legally permissible methods, under
Executive Order 12898 (59 FR 7629, February 16, 1994).

In addition, this rule does not have tribal implications as specified
by Executive Order 13175 (65 FR 67249, November 9, 2000), because the
SIP is not approved to apply in Indian country located in the state,
and EPA notes that it will not impose substantial direct costs on
tribal governments or preempt tribal law.
    The Congressional Review Act, 5 U.S.C. section 801 et seq., as
added by the Small Business Regulatory Enforcement Fairness Act of
1996, generally provides that before a rule may take effect, the agency
promulgating the rule must submit a rule report, which includes a copy
of the rule, to each House of the Congress and to the Comptroller
General of the United States. EPA will submit a report containing this
action and other required information to the U.S. Senate,

the U.S. House of Representatives, and the Comptroller General of the
United States prior to publication of the rule in the Federal Register.
A major rule cannot take effect until 60 days after it is published in
the Federal Register. This action is not a ``major rule'' as defined by
5 U.S.C. 804(2).
    Under section 307(b)(1) of the Clean Air Act, petitions for
judicial review of this action must be filed in the United States Court
of Appeals for the appropriate circuit by April 15, 2014. Filing a
petition for reconsideration by the Administrator of this final rule
does not affect the finality of this action for the purposes of
judicial review nor does it extend the time within which a petition for
judicial review may be filed, and shall not postpone the effectiveness
of such rule or action. This action may not be challenged later in
proceedings to enforce its requirements. (See section 307(b)(2).)

List of Subjects in 40 CFR Part 52

    Environmental protection, Air pollution control, Carbon monoxide,
Incorporation by reference, Hydrocarbons, Intergovernmental relations,
Lead, Nitrogen oxides, Ozone, Particulate matter, Reporting and
recordkeeping requirements, Sulfur oxides, Volatile organic compounds.

    Dated: February 3, 2014.
Ron Curry,
Regional Administrator, Region 6.

    40 CFR Part 52 is amended as follows:

PART 52--APPROVAL AND PROMULGATION OF IMPLEMENTATION PLANS

0
1. The authority citation for part 52 continues to read as follows:

    Authority: 42 U.S.C. 7401 et seq.

Subpart SS--Texas

0
2. The table in Sec.  52.2270(c) titled ``EPA Approved Regulations in
the Texas SIP'' is amended by revising the entry for 116.610 and adding
a new entry for Section 116.620 immediately after the entry for Section
116.615.
    The amendments read as follows:

Sec.  52.2270  Identification of plan.

* * * * *
    (c) * * *

                                    EPA Approved Regulations in the Texas SIP
----------------------------------------------------------------------------------------------------------------
                                                          State
                                                        approval/
         State citation              Title/subject      submittal    EPA approval date         Explanation
                                                           date
----------------------------------------------------------------------------------------------------------------

                                                  * * * * * * *
----------------------------------------------------------------------------------------------------------------
          Chapter 116 (Reg 6)--Control of Air Pollution by Permits for New Construction or Modification
----------------------------------------------------------------------------------------------------------------

                                                  * * * * * * *
----------------------------------------------------------------------------------------------------------------
                                         Subchapter F--Standard Permits
----------------------------------------------------------------------------------------------------------------

                                                  * * * * * * *
Section 116.610.................  Applicability......    1/11/2006  2/14/2014 [Insert    The SIP does not
                                                                     FR page number       include subsection
                                                                     where document       116.610(d).
                                                                     begins].

                                                  * * * * * * *
Section 116.620.................  Installation and/or     8/9/2000  2/14/2014 [Insert    The types of emission
                                   Modification of                   FR page number       units that may be
                                   Oil and Gas                       where document       authorized by this
                                   Facilities.                       begins].             section are the
                                                                                following:
                                                                                Internal
                                                                                combustion engines
                                                                                (ICEs),
                                                                                Natural gas
                                                                                turbines (NG
                                                                                turbines),
                                                                                Flares,
                                                                                Other
                                                                                combustion units
                                                                                (design heat input
                                                                                >40 million BTU per
                                                                                hour),
                                                                                Natural gas
                                                                                glycol dehydration
                                                                                units,
                                                                                Storage
                                                                                tanks,
                                                                                Separators,
                                                                                Condensers,
                                                                                Vapor
                                                                                recovery units,
                                                                                Process
                                                                                vents, and
                                                                                Process
                                                                                fugitives

                                                  * * * * * * *
----------------------------------------------------------------------------------------------------------------

* * * * *
[FR Doc. 2014-03173 Filed 2-13-14; 8:45 am]
BILLING CODE 6560-50-P


A 1 Overview _______________________________________________________________ 2 Interpretation of Standards ________________________________________________ 4 Lead ______________________________________________________________________ 5 Organics ___________________________________________________________________ 6 Source Analysis _________________________________________________________ 7 Industrial Discharges_________________________________________________________ 7 Combined Sewer Overflows ( CSOs) ____________________________________________ 8 Storm water ________________________________________________________________ 9 Types of Storm water Permits ___________________________________________ 9 Storm water Pb data __________________________________________________ 11 Estimate of Annual Lead Load __________________________________________ 13 Storm water Organics Data ____________________________________________ 16 Groundwater ______________________________________________________________ 18 Monitoring Well Results_______________________________________________ 19 Pollutant Loading Estimates____________________________________________ 20 Contaminated Sites _________________________________________________________ 20 NuWay Oil Site______________________________________________________ 24 St. Johns Landfill ____________________________________________________ 27 Sediment Partitioning _______________________________________________________ 28 Air Deposition _____________________________________________________________ 30 Oregon Steel: _______________________________________________________ 31 Spills _____________________________________________________________________ 35 Illicit Discharges____________________________________________________________ 35 Summary of Pb Loads _______________________________________________________ 36 References ____________________________________________________________ 38 A 2 Sources of Toxics to the Columbia Slough Overview The Columbia Slough is on DEQ's 1994/ 1996 303( d) list of water quality limited waterbodies for the following chemicals:

  DDT and metabolites   Dioxins   Lead   PCBs Impairment of beneficial uses by DDT and its metabolites, dioxin and PCBs is demonstrated by occurrence in fish tissue. Review of fish tissue data indicates that dieldrin is also present at elevated levels. Water column data provides evidence of impairment by lead. Because of their presence on the 303( d) list, these chemicals will be referred to as 303( d) chemicals. General information on the sources, fate and transport of each is provided below.

DDT and its metabolites 4,4' DDT, also known simply as DDT, is a low cost broad spectrum insecticide that was banned in the U. S. in 1972 although it is still being used in some tropical countries. Over time DDT breaks down to form DDE and DDD, which are also associated with toxicological effects. All are subject to photodegradation or redeposition by rain or dry deposition, and are widely dispersed by erosion, runoff and volatilization. On land, they preferentially bind to soil and sediment. In water they are subject to sedimentation, volatilization, photodegradation, and uptake into the food chain. Release of these compounds to water is primarily via transport of particulates contained in runoff. Both DDT and DDE bioaccumulate in organisms, particularly in fatty tissues, and levels are subject to increase as they advance up the food chain.

Due to extensive past use of DDT worldwide and the persistence of DDT and its metabolites, these materials are virtually ubiquitous in the environment, and have been detected in virtually all media. They are continually being transformed and redistributed in the environment ( EPA 1993, Meyer 1990, U. S. Public Health Service 1988).

Dieldrin Dieldrin was widely used in the United States from 1950 to 1974 as a broad spectrum pesticide, primarily on termites and other soil dwelling insects and on cotton, corn, and citrus crops. It is a metabolite of aldrin, thus the environmental concentrations of dieldrin are a cumulative result of the historic use of both aldrin and dieldrin. EPA A 3 banned the production and most major uses of dieldrin in 1974, and in 1987 all uses of dieldrin were voluntarily canceled by industry. Dieldrin is extremely persistent in the environment, and by means of bioaccumulation it is concentrated many times as it moves up the food chain. Its persistence is due to its extremely low volatility and low solubility in water resulting in a high affinity for fat ( EPA 1993, Meyer 1990).

Dioxins Dioxins are a family of compounds, the most hazardous of which is 2,3,7,8 TCDD. Dioxins may be produced as a byproduct of incomplete combustion whenever chlorine is contained in the fuel source. Some specific examples of sources include chlorinebleaching pulp mills, municipal and medical waste incinerators, secondary smelters which recover metal from waste products such as scrap automobiles, and wood treaters using pentachlorophenol. Dioxins are also found in sludges at major municipal wastewater treatment plants. These are most likely from industrial sources discharging to the treatment plants since the temperatures associated with sewage treatment processes are not sufficient to produce dioxins. Dioxins found in treatment plant sludges may also have been conveyed there by storm water.

Dioxins have been a contaminant in a number of compounds formerly manufactured as broad spectrum herbicides, the best known being Agent Orange. The association of dioxins with certain herbicides has provided a route of entry into the environment through the use of those herbicides and by the improper disposal of chemical wastes associated with herbicide production. Because 2,3,7,8 TCDD is an extremely stable substance that begins to thermally decompose only when heated to its boiling point, 930 ° F, and because it readily dissolves in fatty tissues, it is highly persistent in the food chain ( EPA 1991, 1992,1993, 1994, Meyer 1990).

Lead Historically, lead has had a number of industrial uses. It has been used in paints, in solder and as a gasoline additive. As recently as the mid 1980s, the primary source of lead in the environment was the combustion of gasoline; however, use of lead in U. S. gasoline has fallen sharply in recent years. The maximum amount of lead now allowed in unleaded gasoline is 0.1 g/ gal. Because lead has been associated with the combustion of gasoline, it is found in urban runoff. About 75% of houses and apartments built before 1978 in the United States contain lead paint, which may also contribute to the lead found in urban runoff. At present, lead is used primarily in batteries, electric cable coverings, some exterior paints, ammunition, and sound barriers. Currently, the major points of entry of lead into the environment are from mining and smelting operations, and from fly ash resulting from coal combustion ( EPA 1993, Meyer 1990, Dennis O'Neill, Metro, pers. comm. ). A 4 PCBs PCBs were once used extensively by industry as insulating fluids in electrical transformers and capacitors, as plasticizers, as lubricants, as fluids in vacuum pumps and compressors, and as heat transfer and hydraulic fluids. They were never intended to be released directly into the environment. Prior to 1979, the disposal of PCBs and PCB containing equipment was not subject to federal regulation, and approximately 1.25 billion pounds was purchased by U. S. industry. Their production and use in the United States were banned by the EPA in July 1979. PCBs are extremely persistent in the environment and are bioaccumulated throughout the food chain ( EPA 1993, Meyer 1990).

DDT ( and by extension, its metabolites), dieldrin and PCBs have been banned by the EPA. Their presence in the Slough environment is likely the result of past practices. The same is true to a lesser extent for lead and dioxin. Car emissions contain less lead than they used to owing to the increased use of unleaded gasoline, and dioxin production associated with pulp and paper mills has been reduced in recent years.

The sources analyzed in this document include the following:

  industrial discharges   combined sewer overflows   municipal storm water   industrial storm water   groundwater   contaminated sites   contaminated sediment   air deposition   spills   illicit discharges Additional sources may include: agriculture activities, sumps, septic tanks and illegal dumping. Data is not currently available to quantify the loads from theses sources. TMDLs include a margin of safety to account for this uncertainty, and monitoring requirements will be established to provide data needed to reduce uncertainty.

Interpretation of Standards Lead appears on the 303( d) list for the Columbia Slough because it is detected in the water column at levels which exceed the OAR Table 20 chronic criteria for the protection of freshwater aquatic life. The organic chemicals appear on the list because they are detected in fish tissue at levels which exceed screening values developed from the OAR Table 20 criteria. These values were developed for the protection of human health from exposure to contaminated fish. A 5 The specific application of standards for each of the 303( d) parameter and the interpretation of data for evaluating sources is discussed in the following sections.

Lead When interpreting information on sources of lead to the Columbia Slough, it is important to consider both the dissolved and total lead concentrations. Lead can be present in the water column in both forms, with the solid form being adsorbed onto sediment particles in the water column. The ratio of the sorbed to dissolved concentration is known as the partition coefficient and it varies with the presence of suspended solids according to the following equation ( EPA TMDL):

Kp = Cp/ SS Cd where Kp = partitioning coefficient Cp = concentration of solids Cd = concentration in solution SS = suspended solids concentration Because lead in the solid form adsorbs onto sediment particles, total lead levels will generally be higher in a water column characterized by high suspended solids. As settling occurs, or as TSS levels in the water column otherwise become diluted, lead that was formerly adsorbed onto particulate matter in the water column may partition into the dissolved form. Therefore it is important to consider both total lead and dissolved lead concentrations when evaluating sources of lead to the Slough.

When total lead data is available and appropriate partitioning equations are available, dissolved lead concentrations can be calculated. However, to develop the partitioning coefficient for the Columbia Slough lower detection limits for total lead are needed. For this reason, dissolved lead values are evaluated to determine compliance with the chronic criteria for the protection of aquatic life. The City of Portland Bureau of Environmental Services ( BES) has collected 296 dissolved Pb and hardness samples from all reaches of the Slough, throughout all seasons.

The chronic criteria is defined as the four day average concentration not to be exceeded once every three years. There is insufficient data with which to calculate 4 day averages directly, so the existing data is compared directly to the criteria. Using the hardness measured with each sample, a total lead criteria is calculated according to the following equation:

total lead criteria ( Table 20) = e ( 1.273[ ln( hardness)] 4.705)

( EPA 1986) A 6 EPA recommends the use of the dissolved metal criteria. Total metal criteria can be converted to a dissolved metal criteria via the use of a conversion factor ( CF). The equation for Pb is as follows:

CF = 1.46203  [ ln( hardness)( 0.145712) ( EPA 1996).

Using these equations, a criteria was calculated for each hardness and dissolved Pb sample. From the frequency distribution of the criteria the 5th percentile criteria was calculated to be 0.0012 mg/ L dissolved Pb. The 5th percentile represents a " worst case" assumption ( EPA, 1995).

Figure 1: dissolved Pb criteria Dissolved Pb criteria, frequency distribution 0 10 20 30 40 50 60 0.0 01 0.0012 0.0014 0.0016 0.0018 0.002 0.0022 0.0024 0.0026 0.0028 0.003 Mo r e frequency 0 20 40 60 80 100 120 Cumulative frequency Organics The 303( d) list organic chemicals are detected in fish tissue rather than in the water column. The appearance of these organics in fish tissue is the result of bioconcentration and biomagnification. Bioconcentration is the term used to describe the uptake and retention of pollutants directly from the water mass by organisms, through tissues such as the gills or epithelial tissues. Biomagnification is the process whereby pollutants are passed from one trophic level to another and exhibit increasing concentrations in organisms related to their trophic status ( Connell, 1984).

There is insufficient information at present to allow the development of a quantitative relationship between water column concentrations in the Columbia Slough and concentrations of organics in fish tissue. Therefore, for this phase of the TMDL process it will be assumed that if the OAR Table 20 chronic criteria for the protection of aquatic life are not violated, then fish tissue concentrations will also be below levels necessary to demonstrate impairment of beneficial uses. A 7 Source Analysis Industrial Discharges Lead is the only 303( d) chemical which is monitored as a requirement under industrial discharge permits issued in the Slough watershed.

There are 27 permitted non storm water industrial discharges to the Columbia Slough. Of these, 22 have general permits and 5 individual permits. General permits apply to industrial categories that can meet the general conditions assumed to cause negligible degradation of water quality.

Table 1 contains a summary of the active industrial in the Columbia Slough watershed. Information on what is monitored under the various types of discharge permits is included for completeness.

Table 1 Summary of General Permits for Industrial Discharges to the Columbia Slough Permit Type Expiration Date Description Parameters Reported1 No. of Active Permits GEN01 7/ 31/ 2001 cooling water/ heat pumps flow, temperature, pH, chlorine 8 GEN02 12/ 31/ 1995 filter backwash settleable solids, pH 2 GEN13 12/ 31/ 1999 oily storm water runoff flow, oil and grease, oxygenated fuel additives ( ethanol and/ or methyl t butyl ether) 2 GEN15 6/ 30/ 2000 petroleum hydrocarbons cleanup flow, pH, total petroleum hydrocarbons, benzene, BETX2, lead3 4 GEN17 12/ 31/ 1997 vehicle wash water pH and oil & grease OR pH, arsenic, chromium VI, copper, lead, zinc4 3 total number of general permits: 22 1All metals are measured as total. Requirements to measure the dissolved portion are not currently in place. 2BETX stands for benzene, ethylbenzene, toluene and xylene. 3Monitoring for lead is not required for all permit holders. 4The latter set of parameters applies to cleaning operations using strong acids, caustics, or other metal brighteners. None of the current permit holders fall into this category.

Only the GEN15 ( petroleum hydrocarbons cleanup) and GEN17 ( vehicle wash water) permits currently require monitoring for lead, and then only under certain circumstances. Under the GEN15 permit, ongoing monitoring for lead is required when detectable levels of lead have been found in the influent to the treatment system. Under the GEN17 permit, monitoring is required for those facilities that have cleaning operations using strong acids, caustics, or other metal brighteners. None of the 3 discharges indicated in Table 2 fall into this category, therefore they are exempt from monitoring for lead.

It should be noted that while monitoring for lead can be required under these permits, the permits do not currently contain actual limits for lead. The intent of the monitoring requirements is simply to collect data for one permit cycle and then the need for an A 8 effluent limit will be evaluated as these general permits come up for renewal. At this time, it is anticipated that when the GEN17 permit is renewed it will contain permit limits for lead. Additional detail on the GEN15 permit holders discharging to the Columbia Slough is summarized in Table 2.

Table 2 Summary of GEN15A Permits in the Columbia Slough Watershed Permit Holder Location Comments Case Corporation 1745 NE Columbia Blvd., Portland Site is impacted by gasoline and diesel. No lead has been detected at this site, therefore monitoring for lead is not required1.

General Motors Corporation 9225 NE Airport Way, Portland This facility discharged about 1 gpm from 10/ 95 to 10/ 96. 100 ppb of total lead was detected in one of the on site wells. Jubitz Truck Stop 10210 N. Vancouver Way, Portland This cleanup site involves a diesel fuel discharge only.

Unocal Station # 6139 985 E. Burnside Street, Gresham Involves a diesel fuel discharge only, therefore monitoring for lead is not required.

1Don Pettit, DEQ, pers. comm.

Using the Pb concentration associated with the discharge that existed between 10/ 95 and 10/ 96, an annual Pb load can be calculated as follows:

100 ug/ l x 1 gpm x 3.79 l/ gal x 1400 min/ day 365 days/ yr x 1 kg/ 109 ug = 0.19 kg/ yr = 5x 10 4 kg/ day All of the 5 individual permits are classified as minor discharges ( less than 1 million gallons per day) and none require monitoring for 303( d) parameters. Two are for treated groundwater, and require testing for volatile organic compounds. Both of these permits are currently under review, and monitoring requirements may be expanded. Two more of the 5 discharges go to the City of Portland's municipal storm water system, and they are being rerouted to the City's sanitary system ( Michael Pronold, BES, pers. comm.).

Combined Sewer Overflows ( CSOs)

There are 13 CSO outfalls located on the Lower Slough. The CSOs are currently regulated under the NPDES program as well as an Amended Stipulation and Final Order ( ASFO) which the Department and the City of Portland entered into in 1994. Under the terms of the ASFO, the CSOs are to be effectively removed from the Columbia Slough by A 9 December 1, 2000. Because the justification for removing CSOs has been based on the quantities of bacteria they discharge, and because a schedule has been developed for CSO removal, little monitoring has been done that would help quantify non bacterial pollutant loads associated with CSOs.

In April of 1991, samples were collected from one CSO outfall to the Columbia Slough. Information on the outfall is summarized below.

Table 3 Monitored Combined Sewer Overflow Data ( BES 1992)

Basin Receiving Stream Size ( acres) Predominan t Land Use % Impervio us Surface Total Pb Vancouver Columbia Slough 255 residential 45 24.4 ug/ L Monitoring did not include hardness or dissolved lead concentrations. The total lead value exceeds the chronic criteria for dissolved lead (= 1.2 ug/ l,) by a substantial margin.

Although there were no detects of DDT and its metabolites, dieldrin or PCBs in the CSO effluent, the detection limits for all of these chemicals were above the chronic criteria . Since sampling of these chemicals has not been extensive and detection limits have been high, it cannot be concluded that they are not present in any quantities in CSOs No information is available with which to estimate dioxin loads to the Slough.

In addition to sampling results for CSO effluent, modeling of CSO pollutant levels has been done by OTAK as part of the CSO Management Plan. Results of this modeling estimate the annual loading rate of lead to the Slough to be 149 lbs/ yr ( BES 1993). This is very close to the value of 185 lb provided by CH2MHill in the Waterbody Assessment, Part II ( CH2MHill 1995). An average of these values, or 167 lbs/ yr ( 75.7 kg/ yr) is used as the estimated annual total lead load from CSOs.

Storm water Types of Storm water Permits Two types of permits are issued for the control of storm water: municipal permits and industrial permits. In addition, in a few cases, NPDES permits issued for the control of process wastewater have been modified to contain storm water requirements.

Municipal Separate Storm Sewer System ( MS4) permits, also known as municipal permits, are issued to municipalities, drainage districts and other entities with jurisdiction A 10 over separate storm sewer systems in metropolitan urban areas. MS4 permits can have several co applicants, each of whom will be responsible for some portion of the permitted area. Two municipal permits have been issued for the Columbia Slough watershed and will be referred to as either the Portland MS4 permit or the Gresham MS4 permit.

The Portland MS4 permit holders are as follows:

  City of Portland   Multnomah County   Port of Portland   Oregon Department of Transportation   Multnomah Drainage District # 1   Peninsula Drainage District # 1   Peninsula Drainage District # 2 The Gresham MS4 permit holders are as follows:

  City of Gresham   City of Fairview   Multnomah County   Oregon Department of Transportation Both permits were issued by DEQ on September 7, 1995. The areas covered by the two permits are summarized below.

Table 4 Areas Covered by MS4 Permits in the Columbia Slough Watershed Permit Holder Permit Area ( acres) Col. Sl. Area ( acres) % of Col. Sl. Watershed Source of Information Portland et al 44,307 16,971 81% MS4 Permit App., Table 3 37 Gresham et al 38,310 3,860 19% MS4 Permit App., Tables 5 4 totals: 82,617 20,831 100%

Monitoring requirements for MS4 permit holders are described in the MS4 permit applications. To summarize, catchments representative of particular land uses ( for example, commercial, industrial, or residential) are monitored during 3 winter storm events and one summer storm event. Parameters measured include conventional pollutants as well as metals. The 1996 annual reports for both MS4 permits issued in the Slough watershed contain the results of all monitoring performed since 1991. A 11 Industrial storm water permits, which are also known as general permits, are issued for particular categories of activities or facilities, such as construction sites or metal scrap yards. Whether or not a particular industrial activity needs a permit will depend on its SIC ( Standard Industrial Classification) code. Monitoring requirements vary by permit type, but generally include pH, oil and grease, BOD, TSS and metals. Metals include arsenic, cadmium, chromium, copper, iron, lead, manganese, mercury, nickel, and zinc. Only total metal concentrations are measured.

Storm water Pb data The following table summarizes the extent of storm water monitoring for lead.

Table 5 Extent of Storm water Monitoring for Lead Portland MS4 Gresham MS4 Industria l No. of Monitoring Stations 10 4 741 No. of Storm Events Monitored 18 3 2/ yr No. samples analyzed for total lead 119 11 466 No. samples analyzed for dissolved lead 119 none none No. samples analyzed for hardness 111 none none 1Each permit holder is required to monitor one site.

Monitoring under the Gresham MS4 permit and the industrial permits did not include dissolved lead. These results can be converted to dissolved lead by using the following equation that gives total lead in terms of the percentage of dissolved lead. This equation was developed from data collected under the Portland MS4 permit ( DEQ, 1996.):

Pbdiss/ Pbtot = 3.036 x TSS^ 0.7846 ( eq. 1) A 12 Monitoring results for municipal and industrial storm water are shown below, along with the results of calculations using equation ( 1).

Table 6 Monitoring Results for Lead Portland MS4 Gresham MS4 Industrial No. Detects ( rate, %) Total Lead 118 ( 99%) 11 ( 100%) 425 ( 100%) Dissolved Lead 79 ( 66%) not analyzed not analyzed Maximum Total Lead 0.290 0.031 7.001 Dissolved Lead 0.100 N/ A N/ A Minimum Concentration Total Lead 0.001 0.004 0.001 Dissolved Lead 0.001 N/ A N/ A Mean Total Lead 0.048 0.023 0.112 Dissolved Lead 0.005 N/ A N/ A Median Total Lead 0.029 0.009 0.023 Dissolved Lead 0.003 N/ A N/ A 1This value may be an outlier. The next highest value is 2.67 mg/ l.

Figure 2 shows the frequency distributions for total Pb data collected by the MS4 and industrial permit holders. A 13 Figure 2 Total Pb frequency distribution As can be seen from Figure 2, the frequency distributions for the 3 datasets vary markedly. In particular, concentrations associated with industrial permits are significantly higher than concentrations associated with MS4 permits.

Estimate of Annual Lead Load MS4 Pb load The MS4 permit applications summarize storm water loading information for a statistically average year. The following table summarizes the estimated annual Pb load to the Columbia Slough. Comparison of Frequency Distributions of Total Lead Data Note: the top tw o values for the industrial permits have been deleted to make the graph more readable. The values are 7 mg/ l and 2.67 mg/ l.

0 0.2 0.4 0.6 0.8 1 1.2 1.4 0.00 20.00 40.00 60.00 80.00 100.00 120.00 Frequency Total Lead Concentration ( mg/ l) Gresham MS4 Portland MS4 Industrial Permits A 14 Table 7 Summary of Total Lead Loads As Estimated in MS4 Annual Reports Permit Holder Columbia Slough ( lbs/ yr) Entire Permit Area ( lbs/ yr) Source of Information Portland et al 2196 ( est.) ( 996 kg/ yr) 4274 ( 1939 kg/ yr) Annual Compliance Report, Section VIII Monitoring Program, Table 4 7 Gresham et al 298 ( 135 kg/ yr) 1,592 ( 722 kg/ yr) NPDES MS4 Permit No. 101315 Annual Report, Table 3 8 A specific lead load to the Columbia Slough is not contained in the Annual Report for the Portland MS4 permit, however an estimate was arrived at based on information contained in the permit application. The permit application states that the lead load from the entire permit area is 4,640 lbs/ yr, of which 2387 lbs/ yr is discharged to the Slough ( Table 3 37 of the permit application). In the 1996 Annual Compliance Report, the lead load from the entire permit area was adjusted to 4,274 lbs/ yr, a reduction of 8%. This correction yields a total lead load to the Slough from the area covered by the Portland MS4 of 2196 lbs/ yr (= 92% of 2387 lbs/ yr). The lead load is estimated as 298 lb/ year in the Gresham permit application. The estimate is based on an event mean concentration of 0.02 mg/ l and an annual runoff volume of 5,474 acre ft per year. Combining the total lead load from both permits, an annual estimate of 2494 lbs/ yr ( 1131 kg/ yr) is obtained.

This is very close to the modeled total lead load to the Columbia Slough reported in the Waterbody Assessment, Part II, done by CH2MHill in 1995. The total value obtained from Figures 6 19, 20 and 21 is 2463.5 lbs/ yr.

Breakdown by Land Use The Portland MS4 permit application breaks down the contributions of lead by land use. These results are summarized below. It should be noted that these numbers do not describe the watershed as a whole, since the Portland MS4 only covers about 80% of the total watershed. They also do not reflect the modifications that have been made to the pollutant loading model upon which the MS4 permit application is based. This table is intended to give a general sense of the relative contributions from different land uses. A 15 Table 8 Lead Loads Associated with Various Land Uses for the Portland MS4 Permit Area Draining to the Columbia Slough Land Use Category Area ( acres) % of Total Lead Load ( lbs/ yr) % of Total Residential ( light) 1541.5 9 124.1 5 Residential ( heavy) 171.8 1 22 1 Industrial 2322.6 14 724.8 30 Commercial 2827.7 17 1370.2 58 Parks & Open Space 2303.5 14 7.6 0 Vacant 7220.3 43 24 1 Traffic Corridor 379.5 3 110.4 5 totals: 16766.9 100 2383.1 100 Source: Portland MS4 permit application, Tables B 1 and C 1.

Industrial Pb Load The contribution of lead from permitted industrial sites can be calculated using the following equation ( EPA 1992):

Area x Annual Rainfall x Runoff Coefficient x Pollutant Concentration = Annual Pollutant Load The annual rainfall for the watershed is given in Table 3 12 of the Portland MS4 permit application as 34.3 inches per year, and the runoff coefficient for industrial areas is given in Table 3 13 as 0.68.

A search of the files for general storm water permits resulted in areas for 52 of the sites. If the permit area associated with the Port of Portland is excluded because the Port of Portland is a co applicant of the Portland MS4 permit, the total area associated with industrial permits, not counting those issued for construction projects, is 977 acres. This calculation assumes that the area represents 100% of the facilities that require industrial storm water permits.

The pollutant load associated with the areas that are currently covered by general industrial permits can be estimated using an event mean concentration for industrial areas. The mean pollutant concentration reported in Table 3 14 of the Portland MS4 permit application is 0.059 mg/ l. The Gresham MS4 permit application contains monitoring results from a residential area and an area that is half industrial and half residential, and A 16 these suggest that the concentration associated with industrial areas is 0.06 mg/ l. For this phase of the TMDL process, a value of 0.06 mg/ l will be used to approximate the concentration of lead found in runoff from industrial areas.

Using the above estimates, the annual lead load associated with the permitted industrial area can be calculated as follows:

977 acres x 34.3 inches/ yr x 0.68 x 0.06 mg/ l total Pb x 43560 sq. ft/ acre x 1 ft/ 12 in x 28.317 l/ cu ft x 1 kg/ 106 mg = 141 kg/ yr Storm water Organics Data Monitoring for the 303( d) organics has been conducted primarily by the DMAs for the MS4 permits and the St. John's landfill closure. There are currently no non storm water discharges of 303( d) organics from industrial sources to the Slough. Monitoring under industrial storm water permits focuses primarily on metals, so no data are available from these permittees for organic pollutants. Monitoring under the municipal permits is more extensive. Under the Gresham MS4 permit, testing for DDD, DDE, DDT, dieldrin and PCBs is limited to one storm event during which samples were collected at 4 different locations. Dioxin was not monitored. There were no detects of these pollutants1 ( City of Gresham, May 1993). Monitoring for the Portland MS4 permit includes 28 samples, with 5 samples above the detection limit. All analyses had detection limits above the OAR Table 20 criteria. Results are presented below:

Table 9: Detects of 303( d) Organics in Storm water Parameter Land Use Concentration ( det. limit) mg/ l 4,4' DDT Residential 0.09 ( 0.07) 4,4' DDT Mixed 0.7 ( 0.4) 4,4' DDE Residential 0.04 ( 0.04) 4,4' DDE Mixed 0.15 ( 0.1) dieldrin Mixed 0.1 ( 0.1)

There have so far been no detects of PCBs in storm water monitored under the Portland MS4 permit. The detection limits for PCBs ranged from 0.3 to 3.0 ug/ L. As part of the Columbia Slough Sediment Remediation Project, additional monitoring has been conducted in storm water pipes draining to Buffalo Slough.

1 detection limits were: DDD = 1.0 ug/ L, DDE = 0.5 ug/ L, DDT = 0.5 ug/ L, dieldrin = 0.5 ug/ L, Aroclor 1221 = 3.0 ug/ L, all other aroclor = 1.0 ug/ L A 17 Sampling occurred during dry event and storm event. The dry event sediment samples were collected in mid summer when no storm water flows were present. Sediment sample SW 3 was collected and composited from the two storm water catch basins that discharge into the storm water pipe. These results are summarized in Table 10.

Table 10: Dry Weather Sediment Sampling Results ( ug/ kg) 2 ( BES, May 1997)

Parameter SW 3 dieldrin 2.92 (. 10) DDE 14.20 (. 08) DDD ND (. 07) DDT ND (. 11) PCBs 35.40 ( 6.84)

The storm water samples were collected in October when conditions met the requirements of a representative storm ( BES, May 1997). These samples were collected in manholes ( SW 1, SW 2 and SW 6) or a catch basin ( SW 3) above the outfalls. There was no receiving water inflow in these samples ( Chris Prescott, BES, personal communication, 1998). Detection limits for storm water were on the order of 1 ng/ l. Typical detection limits for storm water are 1000 to 10,000 ng/ l. These results are summarized below.

Table 11: Storm Water Sampling Results ( ng/ L) ( BES, May 1997) 3 Parameter SW 1 SW 2 SW 3 SW 6 dieldrin ND (. 51) ND (. 54) 2.32 (. 5) ND DDE ND (. 44) 1.17 (. 46) 5.60 (. 42) ND DDD 1.93 ( 1.23) ND ( 1.3) 3.62 ( 1.19) ND DDT 1.28 (. 94) 12.89 (. 99) 24.05 (. 91) ND PCBs ND ( 1.96 3.92) ND (. 82 4.13) ND (. 79 3.79) ND The storm water data indicates that storm water is a source of pesticides. Results from the dry weather sediment sample at SW 3 indicate that sediment associated with storm water is contributing PCBs to the Buffalo Slough as well as dieldrin and DDE. Additional monitoring will be conducted by the City of Portland to verify this conclusion. Fugacity modeling has been conducted using the results of the Buffalo Slough monitoring. The fugacity model is a compartment model and contaminants are assumed to be in compartments that represent areas of the environment, such as surface water, algae or fish tissue. The results of this modeling indicate that storm water sediment is the likely source of contamination of fish tissue. Without storm water control any remediation may not be effective. However, this modeling was based on one sample result and additional modeling will be conducted when additional storm water samples are collected.

2 Detection limit in parentheses 3 PCB data has a range of detection limits depending on Aroclor analyzed, SW 6 detection limits not recorded. A 18 Industrial Storm Water Permits  Organics Monitoring Storm water monitoring for industrial permits focuses primarily on metals, and does not include 303( d) organics.

Summary of Storm water Information Based on information obtained under the general storm water permits and the MS4 permits issued in the Columbia Slough watershed, the following observations can be made:

  The total lead load to the Columbia Slough is estimated in the MS4 permits to be 1131 kg/ yr. Of this, 141 kg/ yr is estimated to come from areas covered by industrial permits.

  Sampling for the other parameters found to impair beneficial uses in the Columbia Slough has been infrequent, and so far, only the pesticides have been detected. Current information is insufficient for developing pollutant loads associated with any of the 303( d) organics. With lower detection limits, it may be possible to develop pollutant loads.

Groundwater Several of the 303( d) parameters are hydrophobic, which means they tend to adsorb strongly to soil particles and are comparatively less likely to be found in groundwater. DDT, PCBs and dioxin are all considered to be hydrophobic. This characteristic is expressed quantitatively in terms of the retardation factor. In a report " Characterization of Subsoil Properties Affecting the Transport of Toxic Metals, Ammonia, and Hydrophobic Organic Compounds at the St. Johns Landfill Site" ( Fish, 1994), Dr. William Fish states:

" Calculated retardation factors for selected priority pollutant organic compounds range from less than 20 for the more soluble compounds such as toluene or chlorobenzene, to hundreds or even thousands for hydrophobic compounds such as PAHs, PCBs, and dioxins..."

In the same report, Dr. Fish points out that lead will have retardation factors much larger than those observed for nickel and copper, which are typically in the range of 10 to 30.

It should be noted that a high retardation factor does not preclude the possibility of contamination by a hydrophobic substance, it simply reduces the rate at which it will move through soil. A 19 General Characterization Groundwater to the Slough has been monitored less frequently than storm water, however groundwater quality is also less dynamic than storm water. Information on groundwater quality in the vicinity of the Columbia Slough is available from the city of Portland Water Bureau. Monitoring has also been performed by DEQ and USGS on a more limited basis. Information on groundwater in the vicinity of contaminated sites is also available, and is available through DEQ's Environmental Cleanup Site Information ( ECSI) database. This information is summarized in the following sections.

Monitoring Well Results The City of Portland Water Bureau maintains 8 monitoring wells in the vicinity of the Columbia Slough. These wells are located in the Troutdale Sand and Gravel Aquifer ( TSA) which is the source of groundwater to the Columbia Slough. Of the 303( d) parameters, only total lead is currently monitored.

A total of 57 total lead samples were collected in these wells from 1984 through 1996, with between 2 and 11 samples collected at each site. The detection limit was 0.001 mg/ l, and lead was detected in 8 of the 57 samples. Of these 8 values, 5 were at the detection limit, 1 value was equal to 0.002 mg/ l and 2 values were equal to 0.003 mg/ l. According to Cathy Casson of the Water Bureau, lead is generally only detected when the pumps are first started and may be the result of leaching from the pumps In 1991, DEQ collected data from 14 wells located in East Multnomah County in the vicinity of Fairview Lake. The detection limits ranged from 5 ug/ l to 7 ug/ l. The results are summarized below.

Table 12 Summary of DEQ Well Monitoring Data Parameter No. of Samples No. of Detects Total Lead 5 1 (= 5 ug/ l) Dissolved Lead 20 0 Dieldrin 27 0 DDT 27 0 DDE 27 0 DDD 27 0 The lack of detects may reflect the relatively high detection limits associated with this sampling effort.

On 7/ 27/ 95, the USGS collected samples from five wells in parks along N. Columbia Blvd. from about N. Portland Rd. to NE 33rd Drive ( Nancy Hendrickson, BES, pers. comm.). A 20 The results for dissolved lead, DDE and Dieldrin showed no detects. The detection limits were 1 ug/ l, 6 ng/ l and 1 ng/ l respectively. These detection limits are unusually low, and are well below the chronic criteria for these chemicals. No tests were done for dioxin or PCBs.

Pollutant Loading Estimates Loading estimates for total lead can be developed from the data collected by the USGS. Using values set at ½ the detection limit, the dissolved lead concentration is 0.5 ug/ L.

In Part II of the Waterbody Assessment, the annual flow of groundwater to the Columbia Slough is estimated to be 1.86x 109 cu ft/ yr. The annual rate of dissolved lead loading is calculated as follows:

( 0.5ug/ l) x ( 1.86x 109 cu ft/ yr) x ( 28.317 l/ cu ft) x ( 1 kg/ 106 mg) x ( 1mg/ 103ug) = 26 kg/ yr or 0.07 kg/ day.

Contaminated Sites As of August 28, 1996, there were 106 sites listed in DEQ's Environmental Cleanup Site Information System ( ECSI) for the Columbia Slough study area. In addition to sites from which a release of hazardous materials has been confirmed, this list also contains sites that have since been found to not pose a risk to groundwater or surface water, as well as sites that have been cleaned up. It also contains sites that upon closer examination turn out to not drain to the Columbia Slough. In other words, not all 106 sites in ECSI are likely to impact water quality in the Columbia Slough.

The following tables contain the sites listed in the database that have indications of the presence of a 303( d) parameter. The status line describes the present status of the site, i. e. the site actually drains to the Columbia River, or data review indicated insufficient information to develop a load estimate at this time, etc. A 21 PCBs COMMON NAME ADDRESS NAME MEDIUM Possible Data STATUS Oregon Waste Systems  Proposed Transfer Station 11535 N Force ST PCB 1221 GW 10.8 ppm drains to Columbia River Portland ( City of)  Columbia BLVD POTW 5001 N Columbia BLVD PCB 1254 OT 50.27 ppm does not drain to Slough Columbia Slough 31.5 miles of waterway PCBs SE 520 ppb ( LS) load developed and sediment partitioning allocation in TMDL Columbia Slough Consolidation Conduit PCBs SL this site is not an active cleanup site, DEQ has been working with the City of Portland to characterize any areas of contamination along the alignment so that the media can be properly managed during construction.

Lamm Property  Site 2 4065 N Suttle RD PCBs SL 10 ppm and less drains to Columbia River Malarkey Roofing Co. 3131 N Columbia BLVD PCB 1242 SL 7.2 ppm site remediated in 1989 and 1990 Morrison Oil Co. 3747 N Suttle RD PCBs SL 7 ppm drains to Oregon Slough General Electric Industrial Co. 2410 N Columbia BLVD PCB 1221 SL 1 to 5 ppm PCB levels lower than cleanup action level of 0.7 mg/ kg ( OARS 340 122 045) ( average PCB 1254 =. 28 mg/ kg,

PCB 1260 0.19 mg/ kg data from 7/ 19/ 96)

Schnitzer Property  N Kerby AVE 8520 N Kerby AVE PCB 1221 SL 0.8 ppm PCB from soil sample taken from 2 feet below surface,

below asphalt so no surface runoff contamination possible,

no groundwater samples were taken, no load calculated NW Cast/ Universal Silver 9233 N Calvert Ave. PCB SL Nu Way Oil Co. 7039 NE 46th AVE PCB 1242 SL 0.7 ppm load and allocation in TMDL Nu Way Oil Co. 7039 NE 46th AVE PCB 1260 SL 1.5 ppm load and allocation in TMDL N Marine DR Extension  North Portland N Marine DR PCBs SL drains to Columbia River Pacific Meat Co. 2701 N Newark St PCB SE/ SL medium codes:

GW = groundwater OT = other ( sludge)

SE= instream sediment SL = soil A 22 DDT, p, p' COMMON NAME ADDRESS MEDIUM Possible Data STATUS Rhone Poulenc  N Marine DR 4429 N Suttle RD GW up to 88 ppb does not drain to Columbia Slough Rhone Poulenc  N Marine DR 4429 N Suttle RD SE up to 1,200 ppb does not drain to Columbia Slough Rhone Poulenc  N Marine DR 4429 N Suttle RD SL up to 3,100,000 ppb does not drain to Columbia Slough Dieldrin COMMON NAME ADDRESS MEDIUM Possible Data STATUS Rhone Poulenc  N Marine DR 4429 N Suttle RD SL up to 100,000 ppb does not drain to Columbia Slough Rhone Poulenc  N Marine DR 4429 N Suttle RD GW up to 1.9 ppb does not drain to Columbia Slough medium codes:

GW = groundwater OT = other ( sludge)

SE= instream sediment SL = soil A 23 Lead COMMON NAME ADDRESS MEDIUM Possible Data STATUS Oregon Waste Systems  Proposed Transfer Station 11535 N Force ST GW 1.2  41 ug/ L drains to Columbia River St. John's Landfill 9363 N Columbia BLVD GW 4.4 ppm load developed and allocation in TMDL Oregon National Guard  PDX Airport # 1 Southwest portion of airport GW 2.175 ppm in 1989 no metals were detected at levels above regulatory thresholds, site under review by DEQ DeWitt Construction 10910 NE Holman ST GW 1.08 PPM data from an unfiltered, turbid groundwater sample.

Filtered sample was a non detect with a detection limit of 0.002 mg/ L Nu Way Oil Co. 7039 NE 46th AVE GW 0.033 ppm load developed and allocation in TMDL Schnitzer Property  N Kerby AVE 8520 N Kerby AVE GW .006 ppm groundwater Pb level lower than drinking water standard, no load calculated St. John's Landfill 9363 N Columbia BLVD OT 10.2 ppm landfill leachate Nu Way Oil Co. 7039 NE 46th AVE SE up to 20,500 ppm ( est) this data from lagoon, which has since been remediated load developed and allocation in TMDL using data from 8/ 12/ 97 for other sections of site with exposed soil JB's Quality Metal Inc. 7715 NE 21st AVE SE 54 1500 ppm 1500 ppm sample from soils removed in 1992/ 1993, currently has no further action status in cleanup program Columbia Slough 31.5 miles of waterway SE 510 ppm ( LS) load developed and sediment partitioning allocation in TMDL DeWitt Construction 10910 NE Holman ST SL 188 ppm Pb present at background levels, no load calculated Fernley Tire Fire 5411 NE Portland Hwy SL 240 ppm Pb present at background soil levels, no load calculated Flightcraft 7505 NE Airport WAY SL 1.6 mg/ l 5/ 94 data showed no groundwater contamination Holman Redevelopment Area  Parcel 249 10835 NE Holman ST SL 3,140 ppm site remediated in 1992, no further action recommended by clean up staff Lamm 1 4101 N Suttle RD SL 414 ppm drains to Columbia River Lamm Property  Site 2 4065 N Suttle RD SL 93 ppm ( in a composite drains to Columbia River of 4 surface samples)

Malarkey Roofing Co. 3131 N Columbia BLVD SL 1500 ppm site remediated in 1989 and 1990 Mt. Hood Metals 9645 N Columbia Blvd GW/ OT active voluntary clean up project Morrison Oil Co. 3747 N Suttle RD SL 30 ppm drains to Oregon Slough Oregon National Guard  PDX Airport # 1 Southwest portion of airport SL 46 ppm Pb present at background soil levels, no load calculated,

site under review by DEQ Oregon Waste Systems  Proposed Transfer Station 11535 N Force ST SL 3.5  235 mg/ kg drains to Columbia River Pacific Meat Co. 2701 N Newark St SE Redi Strip of Oregon 9940 N Vancouver WAY SL 25 ppm EP Tox. data to date has been EP toxicity, so no load developed in site response program, sampling will occur by Spring 1998, including sampling of drainage ditches and groundwater Schnitzer Property  N Kerby AVE 8520 N Kerby AVE SL 290 ppm Pb present at background soil levels, no load calculated medium codes:

GW = groundwater OT = other SE= instream sediment SL = soil A 24 Where sufficient data was available to develop a load and allocation, such estimates were completed. The calculations for these sites follow.

The NuWay Oil site has been found to have the highest concentration of both lead and PCBs reported for any site in the Slough watershed. The maximum detected PCB soil concentration is 29 mg/ kg ( data from Bill Dana, DEQ, 9/ 8/ 97). The average concentration of Pb in the process area of the site is 1532 mg/ kg ( data from Bill Dana, DEQ, 9/ 8/ 97).

NuWay Oil Site NuWay Oil Groundwater Load The NuWay Oil site is located immediately adjacent to the Whitaker Slough immediately upstream of the confluence with the mainstem. In order to estimate pollutant loading associated with groundwater from this site, it is first necessary to establish groundwater velocity. This can be calculated from Darcy's Law ( Todd, 1980), which is as follows:

v = K * ( dh/ dL)

where v = velocity K = hydraulic conductivity dh/ dL = hydraulic gradient The hydraulic gradient was calculated from on site well information ( NuWay) to be 3 x 10 4 ft/ ft. The hydraulic conductivity is a function of soil type. The site was found to have soils that were a mixture of sand, silt and clay. The hydraulic conductivity of such soils is typically 10 2 to 10 3 m/ day ( Mavis Kent, DEQ, pers. comm.). If the higher value is used in order to be conservative, the result is:

v = ( 10 2 m/ day) * ( 1ft / 0.3048m) * ( 3 x 10 4 ft/ ft) = 9.84 x 10 6 ft/ day The rate of groundwater flow from the site can be calculated as follows:

Q = v * length of site along the Slough * depth The length of the NuWay site along the Whitaker Slough is about 400 ft. If the contamination is assumed to run the entire length of the site and to extend to a depth of 20 ft., then the rate of groundwater flow from this volume of soil will be:

Q = ( 9.84 x 10 6 ft/ day) x ( 400 ft.) x ( 20 ft.) = 0.08 cu ft/ day Groundwater data from April/ May 1997, July 1997 and November 1997 was used to obtain an estimate of the groundwater load of Pb and PCBs to the Slough. Five Pb A 25 samples were taken during this time and had two non detects ( at detection limits of 0.1 mg/ L and 0.005 mg/ L, respectively) and three detects at 12.2 ug/ L, 15 ug/ L and 18.6 ug/ L. With the non detects set at ½ the detection limit, the average Pb concentration is 0.02 mg/ L.

Using the average groundwater concentration, the loading rate is calculated as follows:

Lead loading rate = ( 0.08 cu ft/ day) x ( 0.02 mg/ l) x ( 28.317 l/ cu ft) x ( 1 kg/ 106 mg)= 4.53 x 10  8 kg/ day or 1.65 x 10 5 kg/ yr total Pb PCB data from the same time period were non detects at a detection limit of 0.0001 0.0003 mg/ L. Using ½ the detection limit of 0.00015 mg/ L, the annual loading rate is 3.4x 10 10 kg/ day or 1.24 x 10 7 kg/ year. Retardation factors have not been included in either of these calculations.

From this analysis, it appears that the loading rate of lead and PCBs from NuWay Oil to the Columbia Slough via groundwater is not large, even if retardation factors are not taken into account. Yet contamination levels at this site, particularly with respect to lead; are very high.

NuWay Oil Storm water Load The NuWay Oil Site can be divided into two sections; the lagoon area and the process area. The lagoon area has been excavated and capped. The process area is scheduled for remediation, which may include soil excavation. There is also an area around the lagoon, which has been sampled and is covered with gravel. Annual Pb loads from surface erosion from both the process area and the area around the capped lagoon ( non process areas) can be estimated with the Universal Soil Loss Equation ( USLE) and the measured Pb soil levels.

Using the Universal Soil Loss Equation, the soil loss from the site is calculated as follows ( EPA, 1985): X = 1.29 E( K)( 1s) C( P) where: X = average annual soil loss by sheet and rill erosion in t/ ha E = rainfall/ runoff erosivity index ( 102 m tonne cm/ ha hr), from map of average annual erosivity indices ( pg. 163) K = soil erodibility ( t/ ha per unit of E), table of erodibility per soil type ( pg. 165) 1s = topographic factor C = cover management factor, table of C factors for a construction site ( pg. 168) P = supporting practice factor, table ( pg. 172) The topographic factor, 1s, is calculated as follows ( EPA, 1985): 1s = ( 0.045x) b( 65.41sin2  + 4.56 sin  + 0.065) The slope angle is obtained from percent slope, s by:   = tan 1 ( s/ 100) A 26 ( percent slope estimates from Ken Cameron, DEQ, personal communication)

The annual watershed solid phase chemical load in rural runoff ( kg/ yr) is then calculated by: Ls = .001( Sd)( Cs)( X)( A) where: Sd is the sediment delivery ratio and is a function of the drainage area = 0.35 ( pg. 178) Cs is the solid phase chemical concentration in sediment = average of 1073 mg/ kg for non process area and 1532 mg/ kg for process area ( Bill Dana, DEQ, personal communication) X is the soil loss from the eroded area, calculated using the USLE A is the acreage of the eroded area = 30,000 ft2 == 0.28 ha ( Ken Cameron, DEQ, personal communication)

The following table summarizes the input parameters and the annual Pb load from the process and non process areas:

Table 13 E K s 1s C P X Cs A Sd Ls process 86.75 .16 2% 0.162 8 1 1 2.916 1532 0.28 .35 .438 nonprocess 86.75 .16 0% 0.058 0.05 1 0.519 1073 0.28 .35 .005 The USLE predicts soil loss from sheet and rill erosion, but does not predict erosion from gullies, streambanks or landslides. ( Vesilind, 1982).

An estimate of the PCB load from the NuWay Oil Site can also be calculated using the USLE. Using average Aroclor 1260 concentrations for the process area of 3.74 mg/ kg and non process area of 1.65 mg/ kg ( Bill Dana, DEQ, personal communication), an estimate of the PCB load can be made. Only Aroclor 1260 data was used as the other PCBs were present at detection levels. The Aroclor 1260 loads are then 8.4 x 10 6 kg/ yr and 1.1 x 10 3 kg/ yr, for the non process and process areas, respectively.

Nu Way Oil Sediment Partitioning Current erosion estimates may not reflect previous loads, as much of the site has been excavated, regraded and covered with gravel. Instream sediment Pb levels are high ( BES memo to DEQ, 9/ 11/ 97) and may continue to contribute to violations of the Pb criteria due to sediment partitioning. In the SLRA ( Parametrix, 1995), sediment flux from contaminated sediment was estimated. The maximum estimated sediment flux value for Pb ( 5.5 x 10 4 mg/ L, Parametrix 1995) was obtained for a sample from Whitaker Slough. Using this value, an estimate of the annual load to Whitaker Slough is possible. The SLRA ( Parametrix, 1995) estimates the average flow of Whitaker Slough to be 55 ft3/ sec or 1.74 x 109 ft3/ yr.

( 5.5 x 10 4 mg/ l) x ( 1.74 x 109 cu ft/ yr) x ( 28.317 l/ cu ft) x ( 1 kg/ 106 mg) = 27.1 kg/ yr A 27 St. Johns Landfill Priority pollutants are monitored yearly at 9 wells around the St. Johns Landfill. Some of the nine wells sampled may change year to year. Results of this monitoring, since October 1993, are summarized below ( Paul Vandenburg, METRO, pers. comm.):   Lead  the average concentration of total lead found in monitoring wells is 0.0183 mg/ l ( Metro 1995 and Dennis O'Neill, pers. comm.):   PCBs  have not been detected in any of 36 samples that have been tested for each of the seven Aroclor ( PCB) classes ( detection limit was 0.5 ug/ L for Aroclors other than 1221, Aroclor 1221 had a detection limit of 2 ug/ L, Table 20 PCB criteria = 0.079 ng/ L)). 4   DDT, DDE and DDD  none of these compounds have been detected in any of the 36 samples tested since October 1993 ( detection limit for DDT was 0.1 ug/ L, DDE detection limit was 0.04 ug/ L, DDD detection limit was 0.05 ug/ L, Table 20 DDT criteria = 0.024 ng/ L).

  Dieldrin  no dieldrin has been detected in any of 36 samples tested since October 1993 ( detection limit was 0.04 ug/ L, Table 20 criteria = 0.071 ng/ L).

  Dioxin  No well samples have been taken for dioxin. Fish samples taken from the reach of the Slough near the landfill showed levels of dioxin comparable to levels in fish taken from other parts of the Slough and the Columbia and Willamette Rivers. This indicates that there is no local source of dioxin in the area of the landfill. ( Parametrix, July 1995) ( Table 20 dioxin criteria = 1.3 x 10 5 ng/ L).

The lack of detects with respect to PCBs, DDT and dieldrin in the St. Johns Landfill monitoring wells should not be taken as evidence that they are not present at the site. The low detection frequency is more likely to be reflective of the tendency of these parameters to adsorb onto sediment particles. This reduces the rate at which they are likely to leave the site. Initial results of modeling conducted as part of landfill closure indicate that with the cap installed, pollutant loads from St. Johns Landfill are negligible. Additional work is currently being conducted by the DEQ solid waste program to verify the assumptions of the model and the accuracy of the predictions.

Annual Pb load: The lateral flow rate is estimated to be 0.05 to 0.08 cfs.

0.08 ft3/ sec X 0.0183 mg/ L Pb X 28.317 L/ ft3 X ( 1kg/ 106 mg) X ( 60 sec/ 1 min) X ( 60 min/ hr) X ( 24 hr/ day) = 3.6 x 10 3 kg/ day = 1.31 kg/ yr of lead to the Slough from the St. Johns Landfill.

4 Aroclor 1221 detection limit changed to 0.4 ug/ L in August 1995, for all other Aroclors the detection limit changed to 0.1 ug/ L in August 1995. A 28 Riedel Site DEQ performed limited monitoring from 1989 to 1993 at 7 different locations on the Nashpit landfill. This landfill was closed in 1991, and is now known as the Riedel site. Results of monitoring are shown below.

Table 14 Summary of Monitoring at Nashpit Landfill ( Riedel)

Parameter No. of Samples No. of Detects Concentrations ( mg/ l) Total Lead 10 3 0.011 to 0.018 Dissolved Lead 33 0 NA DDT, DDE, DDD 4 0 NA Dieldrin 4 1 0.006 As indicated in the table, lead ( total) and dieldrin have all been detected at the Riedel site. The sample found to contain these pollutants was collected in the landfill leachate sump. Leachate from this sump is directed to the Columbia Blvd. treatment plant and is highly unlikely to impact the Slough. The source of the dieldrin may not be the landfill itself, but rather the site located next to the landfill which was formerly a pesticide storing or manufacturing facility ( Tim Spencer, DEQ, pers. comm.).

Lead levels appear to be higher than those associated with groundwater samples collected from the city groundwater monitoring wells but it is not clear at this time whether or not levels seen are due to contamination at the landfill.

To summarize the information available on the Riedel site, at this time it appears that the landfill is associated with higher than usual levels of lead and that dieldrin may be associated with this site. There is insufficient information with which to estimate pollutant loads to the Slough.

Sediment Partitioning Sediments within the Columbia Slough can also be a source of pollutants because some of the pollutants can enter the water column via partitioning. Predictions of water column concentrations of various pollutants have been developed ( SLRA 2/ 95, Chris Prescott, BES, pers. comm.). Interstitial water concentrations of the organic chemicals were predicted based on the theory that organic chemicals tend to preferentially bind to the organic carbon fraction of sediment, where an assumed equilibrium concentration is achieved between the sediment organic carbon and interstitial water concentration over time. The organic carbon normalized partition coefficient ( Koc) was used to estimate the organic constituent concentration in the sediment interstitial water. Surface water concentrations were calculated based on the flux of organic constituents from the A 29 interstitial water to the surface water. ( SLRA, 2/ 95, Appendix D). By multiplying the surface water concentrations by the annual flow through the Columbia Slough, overall mass loads can be developed. The Waterbody Assessment ( CH2MHill, 1995) gives the total annual flow to the Columbia Slough, not counting tidal inflow from the Willamette, as 1.48 x 108 m3/ yr. Water column concentrations are calculated as follows:

total annual inflow ( m3 / yr) x predicted median water column concentrations ( mg/ L) x ( 1000 L/ 1 m3) x ( 1 kg/ 106 mg)) = pollutant load ( kg/ yr)

Predicted median water column concentrations and associated pollutant loads are listed below.

Table 15 Predicted Median Water Column Concentrations and Pollutant Loads Parameter Predicted Median Water Column Conc. ( mg/ l) Pollutant Load kg/ yr DDT 4.87 x 10 13 DDE 7.17 x 10 13 DDD 1.2 x 10 12 total value: 2.4 x 10 12 3.55 x 10 7 Dieldrin 2.67 x 10 11 3.95 x 10 6 Dioxin no value available1 PCB Aroclors Aroclor 1016 9.1 x 10 11 Aroclor 1221 1.14 x 10 10 Aroclor 1232 5.14 x 10 11 Aroclor 1248 4.08 x 10 11 Aroclor 1254 4.76 x 10 12 Aroclor 1260 9.59 x 10 11 Aroclor total : 3.98 x 10 10 1 x 10 4 Lead 2.056 X 10 7 0.030 1Sediments have not been tested for dioxin.

Due to the toxicity and bioaccumulation of these chemicals, a low instream concentration causes fish tissue concentrations to exceed consumption advisory levels. A 30 Air Deposition Of the toxic parameters for which the Slough is listed, only lead and dioxins are associated with current as well as past air emissions. Other parameters were associated to some extent with past emissions. Specifically, DDT and dieldrin were manufactured by Rhone Poulenc on North Marine Drive until the early 1970s. PCB releases were likely associated with the burning of PCB contaminated waste oil, prior to the phasing out of this method of disposal in the 1970s.

Dioxin Sources: Of the activities and industries that could result in air emissions of dioxin, the EPA currently only requires monitoring of pulp and paper industries. Though there are pulp and paper plants located on the Columbia River, there are no such industries located along the Columbia Slough. The nearest facility to the Columbia Slough would be the James River facility in Camas, Washington. It would be difficult to translate an air emission in Camas to a loading rates to the Columbia Slough because of the multiple transport mechanisms.

Lead Sources: Though the airshed for the Columbia Slough is not as well  defined as the watershed, for the purposes of this discussion it will be assumed that the industries and activities most likely to impact the Slough are those located within Multnomah County. The industries covered by the Department's ACPD ( Air Contaminant Discharge Permit) that are likely to emit lead include the following:

  metal casting ( foundry operations)   battery manufacturing   battery recycling   metals recycling The current Source List maintained by DEQ's Air Quality Division lists 16 companies located in Multnomah County as falling into one of these categories. A search of the Air Quality Division permit files revealed that most of these companies either no longer exist or no longer engage in an activity associated with lead emissions. The companies that are currently discharging are all metal casting/ foundry operations, and they are listed in Table 23. Only Columbia Steel Casting and Oregon Steel Mills are actually located within the Columbia Slough watershed. The ESCO plants are included because of the possibility that air emissions from these plants may migrate into the Columbia Slough watershed. A 31 Table 16 List of Companies with Lead Air Emissions AQ File No. Name Address Process Type Est. Lead Emissions 1 26 1869 Columbia Steel Casting 10425 N. Bloss Steel Foundry < 1200 26 2067 ESCO, Plant 3 2211 NW Brewer Steel Foundry < 1200 26 2068 ESCO, Plant 1 2141 NW 25th Avenue Steel Foundry < 1200 26 1865 Oregon Steel Mills 14400 N Rivergate Blvd. Steel Foundry < 2200 1Units are lbs/ yr. Values were reported as tons per year, but have been converted.

Of the four companies listed, only Oregon Steel has provided an actual estimate of lead emissions to DEQ. The values provided for the other discharges are based on the significant emission rate for lead from foundries, which has been estimated by EPA to be less than 1200 lbs/ yr.

The reason there is comparatively little information on lead emissions associated with these facilities is that lead is not considered by the EPA to be a pollutant of significance for metal casting operations and so it has not provided an emission factor for lead for metal casting operations. Since DEQ only requires monitoring for parameters for which EPA provides emission factors, no monitoring data is available for most of the foundries listed above.

Oregon Steel:

DEQ has information on lead emissions from Oregon Steel because it is large enough to be required to apply for a permit under Title V. Title V came into effect under the Clean Air Act Amendments enacted in 1990. Title V sources are those that discharge more than 100 tons/ yr of the criteria pollutants, or more than 10 tons/ yr of a particular criteria pollutant, or more than 25 tons/ yr total of more than one criteria pollutant. Lead is a criteria pollutant. Title V sources are required to quantify all emissions of criteria pollutants in excess of 0.6 tons/ yr.

Oregon Steel applied for a permit in 1995. Their permit application states that they currently emit 2200 lbs/ yr of lead. They have asked to be permitted to discharge 4600 lbs/ year. A 32 The plant is located on the Willamette River approximately 1.5 miles from the mouth of the Columbia Slough. An estimate of the annual Pb load to the Columbia Slough watershed can be made by calculating the load due to dry and wet deposition of emitted particulates. Particulates, if sufficiently large, will be removed from the air by simple settling due to gravity ( dry deposition). The settling velocity can be calculated using Stoke's law. Due to turbulence in the atmosphere, particles less than 20 um will seldom settle out by gravity ( Vesilind et al, 1982). Pollutants may also be removed from the air by precipitation ( wet deposition); rain falls through the air and the air pollutants dissolve in the rain droplets.

Wet deposition may be estimated by the following equation: ( EPA 1985)

L = 10 C* P* A where: L = load of the pollutant delivered to the receptor area as wet deposition ( mass/ sec) C = concentration of pollutant in precipitation ( mass/ liter) P = precipitation rate ( cm/ sec) A = projected receptor area ( m2) 10 = conversion factor Quarterly emission reports provided by Oregon Steel were reviewed for input data ( 1993 1996). The report contained the emission rate of Pb in lb/ hr. The outlet flowrate from the stack was reported as cubic foot/ minute ( standard, dry). The concentration ( g/ L) of Pb in the emission was calculated as emission rate divided by flow rate: ( lb/ hr)( 1hr/ 60 min)( min/ ft3)( 35.3 ft3/ m3)( 454 gr/ lb)( 1m3/ 1000L) = g/ L The precipitation was calculated as the annual average precipitation for the period of 1987 1997. The projected receptor area was the Columbia Slough drainage basin, 40, 000 acres. Using the EPA equation, the annual Pb load from wet deposition was calculated as: 90% = 10.6 kg/ yr 50% = 4.4 kg/ yr 10% = 0.99 kg/ yr The percentile range was calculated with the varying flow rates and Pb emission concentrations as reported in the quarterly emissions reports.

Using the 50% annual estimate, an estimate of the quantity of Pb that would land on the Columbia Slough water surface may be calculated. This calculation assumes that Pb that is not deposited on the Slough surface water is deposited on land and accounted for in the storm water load. As stated above, the Slough drainage basin is 40,000 acres. An estimate of the Columbia Slough surface area is contained in a memo from Scott Wells to the City of Portland ( September 27, 1995). At approximately 6 feet water level, the surface area is estimated as 0.51 x 106 m2. The relative area of surface water to drainage basin is calculated as follows: A 33 Surface water: 0.51 x 106 m2 Drainage basin: 40,000 acres X 43560 ft2/ acre X 1 m2/ 10.76 ft2 = 1.62 x 108 m2 Ratio = 0.51 x 106 m2/ 1.62 x 108 m2 = 0.0031 The annual wet deposition to the surface of the Columbia Slough is 4.4 kg/ yr x 0.0031= 0.014 kg/ yr The wet deposition equation was used with the following assumptions: 1. The concentration of Pb emitted from the stack is the concentration of Pb in the precipitation, i. e. 100% of the Pb emitted goes to the precipitation. 2. No gradient in the precipitation concentration is assumed. 3. The airshed actually covered by the plume was not calculated, therefore all the Pb emitted may not fall within the Columbia Slough watershed. 4. The emission of the Pb is constant. 5. The average annual precipitation was used, there may be peak loading periods.

Dry deposition may also be calculated for this source using the following equation ( EPA 1985): L = Vd * Cp * A * f where: L = load of the pollutant delivered to the receptor surface as dry deposition ( mass/ sec) Vd = settling velocity ( m/ sec) Cp = concentration of atmospheric particulates ( mass/ m3) A = projected receptor area ( m2) f = fraction ( by mass) of the pollutant in the particulates Settling velocity, Vd, is calculated using Stoke's law: Vd = g( ad) 2(     a) / 18 u where: Vd = settling velocity ( cm/ sec) g = acceleration of gravity, 981.46 ( cm/ sec2) d = particle diameter ( micro meters)   = particle density (~ 2 g/ cm2)  a = density of air ( 0.001243 g/ cm3 at 10C) u = viscosity of air ( 0.000177 g/ cm sec at 10C)

The particle diameters are < 10 um, likely 2 um ( Greg Grunow, DEQ, personal communication). Using these diameters, the settling velocity varied from 1.93 E  12 m/ sec ( 10 um) to 7.71 E 14 m/ sec ( 2 um). Using these settling velocities, the concentration of particulates in the emissions and the fraction of Pb in the particulates, the dry deposition of Pb to the Columbia Slough drainage basin was calculated. The results are summarized below: A 34 Table 17: Air Deposition of Pb percentil e 2 um 10 um 10 % 3.82 X 10 6 kg/ yr 9.55 X 10 5 kg/ yr 50% 1.16 X 10 5 kg/ yr 2.9 X 10 4 kg/ yr 90% 1.64 X 10 5 kg/ yr 4.1 X 10 4 kg/ yr Using the ratio of relative area of Columbia Slough surface water to the drainage area, the annual dry deposition Pb load to the surface water can be calculated. 2.9 x 10 4 kg/ yr X 0.0031 = 8.99 x 10 7 kg/ yr The dry deposition equation was used with the following assumptions: 1. The particle density was not known, and assumed to be 2 g/ cm3. 2. The viscosity of air and the density of air were not temperature corrected. 3. The Pb emitted with the particulates was accounted for in the wet deposition calculation, so double counting of Pb load from the source may occur.

Past Lead Sources: Information on past sources is contained in the following table. Lead emissions again reflect the Best Professional Judgment of DEQ Air Quality staff. The sites associated with these closed plants may release airborne dust contaminated with lead. Only Zusman Metals Co. is actually located within the Columbia Slough watershed. The others are included because air emissions from these plants may have migrated into the Columbia Slough watershed.

Table 18: List of Companies with Past Lead Emissions AQ File No. Name Address Process Type Est. Lead Emission s 26 1866 Gould's Metals 5909 NW 61st Lead Oxide Closed 1984 < 0.6 tpy 26 1864 Pacific Steel Foundry 1979 NW Vaughn Foundry closed in 1972 < 0.1 tpy 26 2072 Zusman Metals Co. ( Incinerator) 1525 NE Columbia Blvd. Wire Recycler closed 1984 < 0.2 tpy A 35 Spills DEQ has been maintaining records on reported spill events since 1987. A computerized database has been developed and it contains records of all spill events that have occurred since 1994, with some events from 1994 as well. Since 1994, 38 spill events have been reported in the Columbia Slough watershed. The substance released is only listed for 5 of these, and none are on the 303( d) list for the Slough. The substances released are described variously as food waste, oil ( gasoline and diesel), sewage and process water.

No pollutant loads for 303( d) toxics can be associated with spills based on this information.

Illicit Discharges The cities of Portland, Fairview and Gresham are required to monitor for illicit discharges under the terms of the MS4 ( Municipal Separate Storm Sewer System) permit. Though these programs have been effective in reducing pollutant loads to the Slough, the parameters measured under them do not include 303( d) parameters. A 36 Summary of Pb Loads Lead loads associated with various sources in the Columbia Slough are summarized below.

Table 19: Summary of Total Metal Loads to the Columbia Slough ( kg/ yr) Source Lead Industrial Discharges 0.19 Combined Sewer Overflows 75.7 Storm water ( total) 1131 MS4 area only 9905 Industrial permitted area only 141 Groundwater6 Overall loading 26 NuWay Oil Site ( to Whitaker Slough) groundwater sediment partitioning soil erosion process area soil erosion  non process area 1.65 x 10 5 27.1 0.438 0.005 St. John's Landfill 1.31 Miscellaneous Sediment Partitioning 0.030 Air Deposition7 Oregon Steel wet deposition Oregon Steel dry deposition 0.014 8.99 x 10 7 Spills estimate not available Illicit Discharges estimate not available Total of Estimates: 1262 5 The calculated total Pb load minus the load associated with industrial areas. 6 Dissolved Pb concentration 7 Using the 50th percentile mass load. A 37 Table 20 Summary of PCBs Loads to the Columbia Slough ( kg/ yr)

Source PCBs NuWay Oil Site groundwater 1.24 x 10 7 soil erosion  process area ( Aroclor 1260) 1.1 x 10 3 soil erosion  non process area ( Aroclor 1260) 8.4 x 10 6 Sediment Partitioning8 DDD, DDE, DDT ( total value) 3.55 x 10 7 Dieldrin 3.95 x 10 6 Aroclor total 1 x 10 4 8 Calculated by multiplying the daily load ( Table 15) by 365 days/ year. A 38 References BES 1992. Combined Sewer Overflow Management Plan, CSO Characterization Report, City of Portland, Bureau of Environmental Services, December 1992.

BES 1993. Combined Sewer Management Plan, Volume 2, Technical Appendices, Technical Memorandum 5.3, City of Portland, Bureau of Environmental Services, June 1993.

BES 1997. Columbia Slough Sediment Project, Focused Feasibility Study Report For Buffalo Slough, May 1997, Final Draft, City of Portland, OR.

BES, memo to DEQ, Upstream Contributions to Sediment Contamination at the NuWay Oil Site, September 11, 1997.

Cameron, Ken, DEQ, personal communication regarding area, slope and soil characteristics of NUWay Oil Site, 9/ 12/ 97.

CH2MHill 92. Water Quality Monitoring Program Results, Technical Memorandum 5.4A to the City of Portland from CH2MHill, 9/ 2/ 92.

CH2MHill 1995. Waterbody Assessment, Columbia Slough TMDL Development, Part II, prepared by CH2MHill for City of Portland, 1995.

Connell, Deff, W., Miller, Gregory, J., Chemistry and Toxicology of Pollution, John Wiley and Sons, 1984.

Dana, Bill, DEQ, fax, soil sample results from NuWay Oil Site, 9/ 8/ 97, samples analyzed by Ecology and Environment.

DEQ 1996. Memo from Bob Baumgartner dated 1/ 8/ 96.

EPA 1985, Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water  Part 1, September 1985, EPA/ 600/ 6 85/ 002a.

EPA 1986. EPA Gold Book.

EPA 1991. Columbia River Dioxin TMDL, EPA Region 10, February 1991.

EPA 1992. U. S. Environmental Protection Agency ( EPA), Office of Wastewater Enforcement and Compliance. November 1992. Guidance Manual for the Preparation of A 39 Part 2 of the NPDES Permit Applications for Discharges from Municipal Separate Storm water Systems. Pre Print. EPA 833 B 92 002. Washington, D. C.

EPA 1993. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume 1, Fish Sampling and Analysis EPA 823 R 93 002.

EPA 1994. Dioxin Facts/ Scientific Highlights from Draft Reassessment, USEPA, September 1994.

EPA 1995. Use of Ambient Data and Antidegradation in Calculating Wasteload Allocations, memo, Wastewater Management and Enforcement Branch, July 1995.

EPA 1996. The Metals Translator: Guidance for Calculating A Total Recoverable Permit Limit from a Dissolved Criterion, Office of Water, EPA 823 B 96 007, June 1996.

EPA TMDL. EPA TMDL Regional Workshop, December 6 8, 1994, presented for US EPA Region X, Seattle, Washington, workshop proceedings.

Fish, William, " Characterization of Subsoil Properties Affecting the Transport of Toxic Metals, Ammonia, and Hydrophobic Organic Compounds at the St. Johns Landfill Site, " 1994.

Gresham, City of, Part II, National Discharge Elimination System Municipal Storm Water Permit Application, Prepared for the Oregon Department of Environmental Quality, May 17, 1993.

Metro 1995. " Controlling Seepage from St. Johns Landfill to Surrounding Surface Water", Solid Waste Department, Engineering and Analysis Division., May 1995.

Meyer, Eugene. Chemistry of Hazardous Materials, 2nd Edition, published by Brady Prentice Hall Career & Technology, New Jersey, 1990.

Oregon Steel Mills, Source Evaluation Reports, Electric Arc Furnace Baghouse Outlet, 1993 1996, prepared by Horizon Engineering for Oregon Steel Mills.

Parametrix, Columbia Slough Sediment Remedial Investigation/ Feasibility Studies, Screening Level Risk Assessment Addendum, prepared for City of Portland, Bureau of Environmental Services, July 5, 1995.

Portland MS4. Annual Compliance Report, NPDES MS4 Section VIII Monitoring Program, prepared for Oregon DEQ, September 1, 1996, submitted by City of Portland and co applicants. A 40 Prescott, Chris, discussion of results of SLRA report and Buffalo Slough Sediment Remediation Project, April, 1997.

Pronold, Michael, BES, personal communication regarding storm water permits, 1996.

SLRA 2/ 95. Columbia Slough Sediment Project, Screening Level Risk Assessment Report, prepared by Parametrix for City of Portland, Bureau of Environmental Services, February 1995.

Todd, David Keith. Groundwater Hydrology, Second Edition, published by John Wiley and Sons Incorporated, 1980.

U. S. Public Health Service. Toxicological Profile for p, p DDT, p, p DDE, p, p DDD, prepared by Clement Associates under contract no. 205 88 0608 for the Agency for Toxic Substances and Disease Registry, U. S. Public Health Service in collaboration with the U. S. Environmental Public Agency, December 1988. Draft for Public Comment.

Vandenberg, Paul, METRO, personal communication regarding recent ( since 10/ 93) priority pollutant sampling at the St. John's Landfill, June 17, 1997.

Vesiland, P. Aarne, Peirce, J. Jeffrey, Environmental Engineering, published by Ann Arbor Science Publishers, 1982.

Wells, Scott, Berger, Chris, PSU Civil Engineering Department, Memo to Mary Abrams, BES, Dawn Saunders, CH2MHill, Sonja Biorn Hansen, DEQ, Tim Hayford, MCDD1, Re: Upper Columbia Slough Shading, September 27, 1995.