32313865 - Klickitat Sawmill PR - Wa

PERIODIC REVIEW

Klickitat Valley Sawmill Facility/Site ID #: 32313865

92 Main Street Klickitat, Washington 98628

Central Region Office

TOXICS CLEANUP PROGRAM

December 2009

Washington Department of Ecology

1.0 INTRODUCTION ..................................................................................................... 1 2.0 SUMMARY OF SITE CONDITIONS ....................................................................... 2

2.1 Site History .......................................................................................................................2 2.2 Site Investigations .............................................................................................................2 2.3 Cleanup Levels ..................................................................................................................4 2.4 Remedial Actions ..............................................................................................................4 2.5 Groundwater Monitoring ..................................................................................................5 2.6 Regulatory Status ..............................................................................................................5 2.7 Restrictive Covenant .........................................................................................................5

3.0 PERIODIC REVIEW ................................................................................................ 7 3.1 Effectiveness of completed cleanup actions .....................................................................7 3.2 New scientific information for individual hazardous substances for mixtures present at

the Site ..............................................................................................................................7 3.3 New applicable state and federal laws for hazardous substances present at the Site .......7 3.4 Current and projected site use ...........................................................................................7 3.5 Availability and practicability of higher preference technologies ....................................7 3.6 Availability of improved analytical techniques to evaluate compliance with cleanup

levels .................................................................................................................................8 4.0 CONCLUSIONS ...................................................................................................... 9

4.1 Next Review ......................................................................................................................9 5.0 REFERENCES ...................................................................................................... 10 6.0 APPENDICES ....................................................................................................... 11

6.1 Vicinity Map ...................................................................................................................12 6.2 Site Plan ..........................................................................................................................13 6.3 Groundwater Monitoring Data ........................................................................................14 6.4 Environmental Covenant ................................................................................................15 6.5 Photo log .........................................................................................................................21


1.0 INTRODUCTION

This document is a review by the Washington State Department of Ecology (Ecology) of post-cleanup site conditions and monitoring data to ensure that human health and the environment are being protected at the Klickitat Valley Sawmill site (Site). Cleanup at this Site was implemented under the Model Toxics Control Act (MTCA) regulations, Chapter 173-340 Washington Administrative Code (WAC).

Cleanup activities at this Site were completed under an Enforcement Order and the Voluntary Cleanup Program (VCP). The cleanup actions resulted in concentrations of gasoline and diesel-range petroleum hydrocarbons (TPH-G and TPH-D, respectively) remaining at the Site in soil that exceed MTCA Method A cleanup levels. The MTCA Method A cleanup levels for soil are established under WAC 173-340-740(2). WAC 173-340-420 (2) requires that Ecology conduct a periodic review of a site every five years under the following conditions:

(a) Whenever the department conducts a cleanup action; (b) Whenever the department approves a cleanup action under an order, agreed order or

consent decree; (c) Or, as resources permit, whenever the department issues a no further action opinion (d) And one of the following conditions exists:

1. Institutional controls or financial assurance are required as part of the cleanup; 2. Where the cleanup level is based on a practical quantitation limit; 3. Where, in the department’s judgment, modifications to the default equations or

assumptions using site-specific information would significantly increase the concentration of hazardous substances remaining at the site after cleanup or the uncertainty in the ecological evaluation or the reliability of the cleanup action is such that additional review is necessary to assure long-term protection of human health and the environment.

When evaluating whether human health and the environment are being protected, the factors the department shall consider include [WAC 173-340-420(4)]:

(a) The effectiveness of ongoing or completed cleanup actions, including the effectiveness of engineered controls and institutional controls in limiting exposure to hazardous substances remaining at the Site;

(b) New scientific information for individual hazardous substances of mixtures present at the Site;

(c) New applicable state and federal laws for hazardous substances present at the Site; (d) Current and projected Site use; (e) Availability and practicability of higher preference technologies; and (f) The availability of improved analytical techniques to evaluate compliance with cleanup

levels. The department shall publish a notice of all periodic reviews in the site register and provide an opportunity for public comment.

Klickitat Valley Sawmill December 2009 Periodic Review Page 2


2.0 SUMMARY OF SITE CONDITIONS

2.1 Site History

The Klickitat Valley Sawmill site is located in Klickitat County in Klickitat, Washington. Following remedial actions at the Site, a restrictive covenant was recorded for the property in 2004 and a no further action determination was issued by Ecology. The no further action determination was rescinded in 2006. A vicinity map is available as Appendix 6.1 and a site plan is available as Appendix 6.2. The Klickitat Valley Sawmill includes approximately 300 acres of land along Snyder Creek. The Site is located adjacent to the town of Klickitat and is surrounded by residential, commercial, and undeveloped properties. Mill operations were limited to the southern end of the Snyder Creek Canyon. Operations included milling of raw timber, shipment of bulk dimensional lumber, and associated maintenance activities. The Site is currently inactive, but remains occupied by vacant buildings remaining from sawmill operations. The sawmill was reportedly established in 1907. From approximately 1908 to the mid-1950s, the mill was owned and operated by the J. Neils family. In the mid-1950s, the St. Regis Paper Company purchased the mill. Champion International Corporation (Champion) purchased the St. Regis Paper Company in 1985 and continued to operate the mill until 1994. In June 1996, Champion sold the property to Klickitat Valley Sawmills (KVS), who elected to not operate the mill and initiated demolition of the mill buildings and sale of mill equipment. The Site changed hands several times prior to foreclosure by Klickitat County for failure to pay back taxes in 2000. Part of the Site was sold to a private party at auction. 2.2 Site Investigations Prior to the 1996 sale of the property to KVS, Champion conducted environmental investigation and site remediation activities as part of their intent to sell the facility as an operable sawmill. Compounds detected in samples from the site include total petroleum hydrocarbon-gasoline (TPH-G), TPH-diesel (TPH-D), pentachlorophenol (PCP), and tetrachloroethene (PCE). Documented TPH and PCE concentrations adjacent to the Paint Shop were addressed during a 1995 soil removal action. In 1994, PCP was identified at a concentration of 38.6 milligrams per kilogram (mg/kg) in one soil sample collected from the former dip tank area. PCP was not detected in an adjacent shallow/deep monitoring well pair (MW-l/pl and MW-l/p2). Given the low concentrations of PCP, no remedial activities were required. In 1997, Ecology representatives resampled the monitoring wells, as well as two municipal wells and an off-site monitoring well. PCP was only detected in one of the on-site wells (MW-l/pl) at an estimated concentration of 0.042 micrograms per liter (ug/L), a level well below the MTCA Method B cleanup level for groundwater of 0.729 ug/L. On September 3, 1997, in response to an anonymous complaint, Ecology conducted an inspection of the sawmill site. Evidence of open and/or unprotected containers of oil and other materials and poor housekeeping practices was observed. Based on these observations and



operational information from former sawmill employees, Ecology determined that a Site Hazard Assessment (SHA) would be required. The SHA was completed by Ecology in April 1998, and the site was ranked a 2 on a scale from 1 to 5 (l = highest relative risk). On November 12, 1997, the Ecology Water Resources Program issued Regulatory Order DE 97WR-411 to the property owner requiring that repairs and maintenance activities be performed on the Log Pond dam. On February 8, 1998, a fire destroyed some of the remaining mill buildings and the Log Pond dam on the eastern portion of the site. Since the fire, floodwaters resulted in sheet flow across portions of the site and created debris dams in the Creek. Sheet flow reportedly eroded, moved, and/or carried away demolition debris and caused the migration of hazardous materials. On March 30, 1998, the Ecology Water Quality Program issued Administrative Order DE 98WQ-C118 to the property owner requiring that they clear debris and restore the Snyder Creek channel and that he collect and analyze sediment samples from the Log Pond at the site. The Ecology Toxics Cleanup Program subsequently issued a June 26, 1998 Enforcement Order (DE 98 TC- C103) to the property owner requiring the performance of a remedial investigation/feasibility study (RI/FS) at the property. There is no record indicating that these actions were ever completed. A second fire in November 1998 destroyed the Planer Building located in the southern portion of the site. In June 2000, International Paper Company bought Champion, and in November 2000, International Paper resumed discussions with Ecology and Klickitat County regarding the conduct of the proposed investigation activities under Ecology's Voluntary Cleanup Program. In February 2001, International Paper submitted formal application to the Voluntary Cleanup Program. International Paper has completed an extensive site-wide investigation at the Klickitat Sawmill. International Paper performed this investigation as well as targeted remediation activities under Ecology's Voluntary Cleanup Program in cooperation with Ecology and Klickitat County. The first phase of the investigation was conducted from May to October 2001. The second phase of site work was conducted in July 2002. The results of the 2001 field investigations did not indicate the presence of significant environmental impacts. Surface water and sediment sampling results did not identify compounds above MTCA regulatory criteria. Similarly, PCP, polychlorinated biphenyls (PCBs), and volatile organic compounds (VOCs) were not detected above MTCA criteria in any of the soil or groundwater water samples collected. Petroleum hydrocarbon compounds were detected at the site but impacts were fairly limited. Similarly, metals impacts were very limited and only lead was found at concentrations that warranted remediation in July 2002. In July 2002, additional characterization activities were conducted at two areas where residual TPH concentrations were high enough to warrant extractable petroleum hydrocarbon/volatile petroleum hydrocarbon (EPH/VPH) sampling to develop MTCA Method C clean-up levels for petroleum mixtures. Additional data was also collected to allow for speciation of chromium (to differentiate between trivalent and hexavalent chromium) at one location.



2.3 Cleanup Levels EPH/VPH sampling was conducted at three areas with petroleum hydrocarbon impacted soil to determine MTCA Method C cleanup levels for petroleum mixtures for the Site. Samples from AOC-4 were determined to have a hazard index (HI) of 0.429 and a cancer risk of 2.69 x 10-6. AOC-8 had a HI of 0.707 and a cancer risk of 7.26 x 10-7. AOC-9 had a HI of 0.0298 and a cancer risk of 5.47 x 10-7. All values were below the direct human contact protection levels of an HI of 1.0 and a cancer risk of 1 x 10-5. Because MTCA Method C cleanup levels were used for the Site, institutional controls were required for a no further action determination to be issued by Ecology. 2.4 Remedial Actions The results of the remedial investigations conducted at the Klickitat Sawmill site indicate that past activities at the site resulted in limited petroleum impacts to soil in three areas: the former Sawmill Building (AOC-4), the former fueling area (AOC-8), and the former Electrical Shop area (AOC-9). Even though soil sampling results indicate that TPH concentrations in AOC-4, AOC-8, and AOC-9 were below MTCA Method C clean-up levels, International Paper performed voluntary soil remediation to address accessible TPH impacts. International paper also removed lead impacted soil from AOC-4. Remedial activities consisted of excavating impacted soils from the vicinity of test pits TP04-B (lead), TP04-C (TPH and lead), TP08-A (TPH), and TP09-C (TPH). Excavation was conducted using a track mounted excavator. Soils were excavated from the site and loaded directly into lined trucks for transportation to the Waste Management Columbia Ridge Landfill (Columbia Ridge) in Arlington, Oregon. During excavation, soils from the excavation sidewalls and base were field screened for visual or olfactory signs of impacts. Once field screening results indicated that petroleum impacts had been removed, excavation was halted and confirmation samples were collected. The confirmation samples were submitted to the laboratory for analysis of suspected contaminants. Following confirmation sampling, excavations were backfilled with clean fill material obtained from the Columbia Ridge facility. Excavations were lined with plastic sheeting prior to backfilling to provide a marker for future reference. Backfill material was placed in the excavation using a front-end loader. Relatively minor quantities of petroleum-impacted soils remain in locations not accessible for excavation in two of the areas: AOC-4 and AOC-8. Remedial investigation results indicate that groundwater in the immediate vicinity of AOC-8 is also impacted with petroleum hydrocarbons, but the vast majority of the hydrocarbon source was removed and the limited groundwater impacts detected at one downgradient well are expected to



dissipate with time. No other groundwater impacts were detected at the site, and there is no evidence of off-site groundwater impacts. 2.5 Groundwater Monitoring In 2004, following remedial activities at the Site, Ecology requested two years of semi-annual ground water monitoring. Samples were collected from MW-104 in April and October of 2004 and 2005. Petroleum hydrocarbon contamination was not detected in any of the samples at concentrations exceeding MTCA Method A cleanup levels. Sample data is available as Appendix 6.3. 2.6 Regulatory Status In May 2006, a no further action determination was issued for the Site following the submittal of the independent remedial action report under the VCP. In June 2006, the no further action determination was rescinded due to the presence of oil-filled transformers in the powerhouse located adjacent to the sawmill. These transformers had reportedly not been tested for PCBs. At the time of the site visit in November 2009, these transformers were no longer present. 2.7 Restrictive Covenant Following sampling activities, an Environmental Covenant was recorded for the Site in 2004. The Environmental Covenant imposes the following limitations:

1. Any disruption of soils located within specific areas (identified below) of these parcels is strictly prohibited unless Ecology authorizes the planned activities in advance of the activity. “Disruption” shall include any soil surface and subsurface intrusive activity whether by hand or mechanical means and includes but is not limited to any drilling, digging, placement of any objects or use of any equipment which deforms or stresses the surface beyond its load bearing capability, piercing the surface with a rod, spike or similar item, bulldozing or earthwork.” A portion of the Property contains petroleum contaminated soil located between test pit (TP) 04D and 04E and the NE, NW and SW Corners of TP-04C. Using MW-107 as a reference point, measure 62.5 feet due Northwest, from this point measure 62.5 feet due South to MW-106. From MW-106, measure 53.75 feet due east to your original starting point of MW-107. Soil contaminated with pentachlorophenol is located within the vicinity ofTP-04A. UsingMW-106 as a reference point, measure out 55 feet due West, which will run parallel to the Power House, then measure due East up to MW-1. From MW-1, measure due Northwest up to your original starting point of MW-106. This restrictive covenant applies to these specific areas of these parcels (mentioned above) and does not apply to the parcels in their entirety. The Owner shall not alter, modify, or remove the existing structure[s] in any manner that may result in the release or exposure



to the environment of that contaminated soil or create a new exposure pathway without prior written approval from Ecology.

2. Any activity on the Property that may interfere with the integrity of the Remedial Action and continued protection of human health and the environment is prohibited.

3. Arty activity on the Property that may result in the release or exposure to the environment of a hazardous substance that remains on the Property as part of the Remedial Action, or create a new exposure pathway, is prohibited without prior written approval from Ecology.

4. The Owner of the property must give thirty (30) day advance written notice to Ecology of the Owner's intent to convey any interest in the Property. No conveyance of title, easement, lease, or other interest in the Property shall be consummated by the Owner without adequate and complete provision for continued monitoring, operation, and maintenance of the Remedial Action.

5. The Owner must restrict leases to uses and activities consistent with the Restrictive Covenant and notify all lessees of the restrictions on the use of the Property.

6. The Owner must notify and obtain approval from Ecology prior to any use of the Property that is inconsistent with the terms of this Restrictive Covenant. Ecology may approve any inconsistent use only after public notice and comment.

7. The Owner shall allow authorized representatives of Ecology the right to enter the Property at reasonable times for the purpose of evaluating the Remedial Action; to tale samples, to inspect remedial actions conducted at the property, and to inspect records that are related to the Remedial Action.

8. The Owner of the Property reserves the right under WAC 173-340-440 to record an instrument that provides that this Restrictive Covenant shall no longer limit use of the Property or be of any further force or effect. However~ such an instrument may be recorded only if Ecology, after public notice and opportunity for comment, concurs.

The Restrictive Covenant is available as Appendix 6.4.



3.0 PERIODIC REVIEW 3.1 Effectiveness of completed cleanup actions Based upon the site visit conducted on November 5, 2009, site access is restricted to the general public. Surface covers consist of concrete, asphalt and compacted gravel and appear sufficient to continue to eliminate exposure pathways (ingestion, contact) to contaminated soils. The Site remains occupied by large vacant buildings that housed former sawmill operations. A photo log is available as Appendix 6.5. The Environmental Covenant for the Site was recorded and is in place. This Environmental Covenant prohibits activities that will result in the release of contaminants contained as part of the cleanup without Ecology’s approval, and prohibits any use of the property that is inconsistent with the Covenant. This Restrictive Covenant serves to assure the long term property use and integrity of the property surface. Contaminated soils likely remain at the Site; however institutional controls and site use prevent exposure to contamination. The presence of old transformers at the Site in 2006 caused the no further action determination to be rescinded. These transformers are no longer present. If documentation can be presented to Ecology to demonstrate that these transformers were disposed of properly, the Site may be eligible for a no further action determination if it is entered into VCP. 3.2 New scientific information for individual hazardous substances

for mixtures present at the Site Cleanup levels at the Site were based on calculated risk for chemicals and/or media. These standards were sufficient to be protective of site-specific conditions. 3.3 New applicable state and federal laws for hazardous substances

present at the Site There are no new relevant state or federal laws for hazardous substances present at the Site. 3.4 Current and projected Site use The Site is currently vacant and zoned for industrial purposes. This use is not likely to have a negative impact on the risk posed by hazardous substances contained at the Site. 3.5 Availability and practicability of higher preference technologies



The remedy implemented included containment of hazardous substances and it continues to be protective of human health and the environment. While higher preference cleanup technologies may be available, they are still not practicable at this Site. 3.6 Availability of improved analytical techniques to evaluate

compliance with cleanup levels The analytical methods used at the time of the remedial actions were capable of detection below MTCA Method A cleanup levels. The presence of improved analytical techniques would not affect decisions or recommendations made for the Site.



4.0 CONCLUSIONS

The remedial option selected for the Site appears to be protective of human health and the environment.

Soil cleanup levels have not been met at the Site; however, under WAC 173-340-740(6)

(d), the cleanup action is determined to comply with cleanup standards, since the long-term integrity of the containment system is ensured and the requirements for containment technologies in WAC 173-340-360(8) have been met.

The Environmental Covenant for the property is in place and will be effective in

protecting public health from exposure to hazardous substances and protecting the integrity of the cleanup action.

The Site may be eligible for a no further action determination through VCP if the transformers previously located at the Site were properly disposed of.

Based on this review, the Department of Ecology has determined that the requirements of the Environmental Covenant are being met. It is the property owner’s responsibility to continue to inspect the Site to assure that the limitations of the Restrictive Covenant are being followed. 4.1 Next Review The next review for the Site will be scheduled five years from the date of this periodic review. In the event that additional cleanup actions or institutional controls are required, the next periodic review will be scheduled five years from the completion of those activities.



5.0 REFERENCES AGI Technologies. Petroleum Hydrocarbon Remediation. September 28, 1995. Ecology. Enforcement Order No. 98 TC-C130. 1998 Ecology. Restrictive Covenant. April 19, 2004. International Paper. April 2005 Follow-up Groundwater Sampling Results. June 17, 2005. Ecology. No Further Action Determination. May 23, 2006. Ecology. No Further Action Determination Rescinded. June 12, 2006. Ecology. Site Visit. November 5, 2009.



6.0 APPENDICES



6.1 Vicinity Map



6.2 Site Plan



6.3 Groundwater Monitoring Data



6.4 Environmental Covenant













6.5 Photo log Photo 1: Old Powerhouse – from the south

Photo 2: Site Buildings – from the south



Photo 3: Snyder Creek Plume – from the north

Photo 4: South End of Site – from the northwest

Documents

32313865 - Klickitat Sawmill PR - Wa