HomeMy WebLinkAbout700 N. Ennis 700 N Ennis F91-76(5)1
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FILING FEE:
U� �N FILE NO. :
RECEIPT NO. :
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APPI_1CATION J#X I TNT
ALA N N 1 NC' FOR PORT ANGELES
PLANNING DEPARTMENT
SHORELINE SU13STANTI
AL DEVELOPMENT, .
CONDITIONAL USE, or VARIANCE PERMITS
TO THE APPLICANT: This is an application for a substantial development.
conditional use, or variance permit, as authorized by the Shoreline Management
Act of 1971. It is suggested that you check with appropriate local, State or
Federal officials to determine whether your project falls within any other
permit systems.
a• AP Piicant' s Name _Rayonier Inc. - Port Angeles gill
b. Daytime phone 360-457-
3391
2. Mailing Address: 700 North Ennis. Port AnaPles. WA 98362
3.a. Relation of Applicant to Property:__ OWnpr
(i.e. , owner, purchaser, lessee, etc.)
b. If Lessee, Attach a Copy of Your Lease Document.
4. Name and Address of Owner, if Other than Applicant:
=• Seneral Location of Proposed Project: Rayonier facility at the
Foot of Ennis Street.
6. Legal Description of Property:
a. Street Address: , 700 North Ennis Street
b. Legal Description: See attached Exhibit I.
c. Harbor Area Lease No. ;if Applicable)
7. Name of Water Area and/or Wetlands Within Which Development is Proposed:
Port Angeles Harbor - Strait of Juan de Fuca
Y
Shoreline Application
Face
8. Current Use of Property with Existing Improvement:
a. Name or Type: Pulp mill producing chemical cellulose
Characteristics of use: Heavy industrial - pulp mill and associated
facilities
c. Time in Operation: Since 1930's
d. deed/Reason for Shoreline Location: Integral to the pulp manufacturing
process
e. Existing Improvements (Buildings, Rip Rap, Retaining Walls, Piers, Floats,
Pilings) :- NA
9. Description of Proposed Use:
a. Name/Type: Site dismantling
b. Characteristics of use: Future use is unknown - See attached plan for
dismantling
_. Need/Reason for Proximity to Shoreline: NA
d. Effect of Public Access Upon Proposed Use: No change in public access -
currently no public access is allowed - private property
e. Proposed Improvements (Buildings, Fill, Rip Rap, Retaining Walls, Piers,
Docks, Floats, Pilings) : Dismantling as per attached plan
Applicant
Date
Rayonier
January 16, 1997
Port Angeles Planning Department
PO Box 1150
Port Angeles, WA 98362
Re: Shoreline and Building Permit application
Enclosed are a Building Permit - Preapplication and an Application for
Shoreline Substantial Development for the proposed dismantling of the Rayonier
Port Angeles Pulp Mill . Included with the applications are the work plan
specifications, two general site drawings, and the site drawing showing the
individual work areas as designated in the specifications. In order to
provide comprehensive information for the permit review, the application
assumes the eventual removal of all existing buildings and structures.
For clarity, these permit applications do not include:
1) work below ground level ;
2) any work in the water below the high tide mark; or
3) removal of the dock, except structures above the level of the decking.
Following completion of the dismantling, a complete environmental site
assessment will be done and necessary remedial action taken based on the site
assessment. Rayonier will apply for any additional permits necessary before
commencing remediation activities. During the dismantling project, Rayonier
will retain all current regulatory permits, which include the NPDES permit
requiring the control of all water discharges from the site, including
stormwater. All wastes generated during the work will be disposed of in
accordance with federal and state regulations.
Rayonier's current plans are for total dismantling of the facility; however,
we have not ruled out other possibilities. In the event that these plans
change, we will immediately notify you. Since total mill dismantling is the
most likely course of action, we are asking that you process the attached
applications expeditiously.
In the event you need any further information in order to proceed with the
permitting process, please do not hesitate to call me.
Sincerely,
� uL
Brian D. Jones
Environmental Superintendent
(360) 457-2352 Fax: (360) 457-2493
Enclosures
ru
specs%wjc\0043
RAYONIER hIC.
Port Angeles Mill
January 10, 1997
Revised 1/14/97
WORK PLAN FOR PT JLP MILL DISMANTLIN
The intent of this work plan is to describe the dismantling project at the Rayonier Mill in Port
Angeles, Washington.
PC or r.VaAbK—L&e-4
The Mill will go through the normal sequence of shutting d wn, with an emphasis on cleanup of all
systems. As a part of this cleanup, all tanks. including the S L storage lagoon, will be thoroughly
tlushed and cleaned. Treatment facilities will remain operational through cleanup and into the
dismantling work.
A Contractor will be selected to perform the dismantling work. The buildings, structures,and
equipment foundations will, in general. be removed down to the ground floor or grade except as
otherwise noted. Dismantling for each dismantling area will include utilities and process piping.
All asphalt paving is to remain in place.
Removal of buried sewers, process piping, utilities, etc. will not be included unless otherwise
noted. The Contractor will mark such lines for future identification where they emerge from or
enter the ground. slabs, or foundations.
In general. all dismantling work will be done during daylight hours, Monday through Friday,with
weekend work subject to approval of the Owner.
The site has been divided into smaller areas for coordination reasons as outlined on the attached
drawing D-
_ 9217 Dismantling Areas/Plot Plan. ° he numerical sequence of these areas has
nothing to do with the dismantling sequence.
It is the Owner's intent to remove as much of the hazardous material initially as is feasibly
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possible. Emphasis will p p 11 be placed on removing major wood buildings first to reduce fire daggers
during the remainder of the dismantling project. The Filter Plant(Area 6), Secondary Treatment
(Area 1), and the Dock(Area 9), will be the last areas of work, and dismantling in these area will
only proceed upon written authorization as provided by the Owner. The dismantling Contractor
will be working in several areas at once, and the sequence will be upon mutual agreement of the
Owner and Contractor and is subject to change during the course of the project.
I. DISMANTLING AREAS
A. area 1– econriary Tree
1. Remove all buildings, structures, equipment, tanks, and systems in this area
III
including the 69 kv substation and all miscellaneous equipment stored in this
area.
2. Remove chip truck dump.
3. Removu pulpmill pump station in Area 5 and asbuciated above-ground sewer
lines.
4. Underground vaults to remain.
5. Remove 69 kv overhead line and poles to pole at west side of filter plant area.
Rayonier to provide for isolation.
6. Yard lighting to remain.
B. area 2—Primary Treatment
1. Remove all buildings, structures. tanks. equipment. and systems including the
CLO, generator area. warehouses. chlorine. and SO, storage tanks, lime slaker
equipment. primary clarifier to grade. and all associated above-ground piping.
2. Outfall, foam tank. and influent wet well are to remain.
4
3. Remove all miscellaneous material stored on ground to east end of property.
7 4. Do not remove the two bridges across Ennis Creek.
? 5. Remove SSL lagoon dike material.
C. ,Area 31—Pulp Finishing and Roll Storms=e
1. Remove all buildings. structures. equipment. tanks. and systems in this area
except main sewer line to treatment facilities which will be removed with
Area 1.
7 2. Do not remove bridge at mouth of Ennis Creek until released by the Engineer.
3. Remove all wood flooring in these buildings along with associated pile cap and
7 floor foists. Piling to remain as well as any supports for main sewer lines under
I T
these buildings.
2 4. Remove elevated roadway along east wall of finishing room. Rayonier will
relocate oil recovery system equipment.
D. area 4—Offices-. honc
1. Remove all buildings, equipment. structures. tanks. and systems in the area
including the Beanery, Credit Union, and truck scales.
2. Yard lighting to remain.
2
E. .Area 5—Screen-Bleach-Machine
1. Remove all equipment, structures, tanks. and systems in this area except the
pulpmill pump station which Lill be removed with Area 1.
2. Protect exposed sewer lines near pulpmill pump station north of machine room.
—7 3. Remove all wood flooring and supports, i.e., pile caps. Leave piling as is.
4. Concrete floors in the screen. bleach, machine, and pulp warehouse are to
remain.
5. Any residual pulp stock will be transported to a mill site designated by the
Engineer.
F. Area 6—Filter Plant Area
1. Remove all buildings, structures. equipment, tanks. and systems in this area
except overhead 69 kv power lines.
2. Timing for the removal of the water tower will be determined by the Engineer.
3. Removal of filter media will be done by others.
4. Concrete slabs on grade to remain.
G. Area 7—Acid Plant-Dige ers-B1 wpits
1. Remove all equipment, tanks, structures. and systems in this area north
of Maintenance shops and east of the roadway to the dock. including
the acid plant. digester building, and blowpits.
2. Remove all tanks to existing concrete bases.
3. Remove all pile caps and supports under blowpits; leave piling under
blowpits.
H. Area 8—Chip Screening and Storage
1. Remove all equipment, structures, tanks and systems in this area including the
chip truck dump equipment.
2. Remove overhead conveyors and associated structures to logical cutoff point
between dismantling areas, i.e., transfer tower or building walls. ,
I Remove all wood flooring and supports, i.e. pile caps. Leave piling as is.
Concrete floor areas on grade to remain.
3
4. Do not Lcmove main overhead pipe trestle that n►.,s from power/iecovery east
to south side of
k chip storage. The solid sewer on this trestle must be maintained
until the woodmill pump station is removed.
�. .any residuai chips will be removed by the Contractor to a mill-site designated
by the Engineer.
I. area 9—Dock
1. Remove all buildings, structures, tanks, equipment. and slabs.
Remove timber support structures, fire lines, conduits, and miscellaneous
piping.
J. area 10—Recovers,
1. Remove all equipment. structures, buildings, tanks. stack, and systems in this
area including the absorber cooler and associated systems, Brinks filters,and
ductwork to stack.
'. Do not remove main pipeway between powerhouse and recovery that runs east
to chip storage area until fire water, air. and power are no longer required at
this end of the Mill.
3. Do not remove central substation until woodmill pump station is out of service.
4. The dismantling of the recovery stack will be done only after all adjacent
structures have been removed.
K. .-area 1 1—Powerhouse-Sludge-Utility Tie Substation
1. Remove all buildings, structures. tanks. equipment and systems in this area
AIL- S including miscellaneous shops and bulkheads at the hog fuel area. Remove
� ,/ elevated diesel tanks and concrete,support structure.
2. Remove ammonia tanks and three fuel tanks including elevated foundations at
the south end of this area.
Remove fuel oil storage tank: Rayonier will provide for cleaning of tank
interior.
-l. Do not remove used oil storage shed.
r V
Remove 69 kv overhead line and structures up to pole at filter plant.Rayonier
will provide for isolation at pole.
6. Remove remaining utility systems as dock removal progresses to point that fire
systems are no longer required.
4
7. Remove raw water pump house. woodmill pump station. and main east-west
pipe trestle.
8. Remove all above-ground piping from pump house to filter plant.
9. Remove hog fuel reclaimer and all equipment in pit associated with this
system.
10. Remove wood decking west of turbine room.
11. Do not remove city sewer pump station at southeast corner of hog fuel pile.
L. Area 12—Woodmill
1. Remove all equipment. structures, and systems in this area at the extreme west
end of the site except the raw water pump house. waterline and the woodmill
pump station. which will be removed with Area 11 work.
-. Remove retaining wall in south end of log yard.
Remove pipe piles in log storage area south of Auto Shop.
4. Remove hog fuel conveyor to powerhouse to support at west side of roadway
between woodmill and powerhouse. 15 kv power conduits to recovery
substation must remain until the woodmill pump station is out of service.
Remove overhead chip conveyor to transfer tower.
6. Remove log bundle lift equipment on west side of yard.
7. Yard lighting and poles to remain.
[I. ASRFSTnS MATERIAL REM VA
The Contractor will remove all asbestos and asbestos-containing materials (ACM)from the
`7 work areas identified through site survey information as provided by Owner. ACM is
c known to exist in piping and equipment insulation. roofing, siding, and paint.
The Contractor will be certified as required by the State of Washington for the removal,
handling, and transport of asbestos and/or other hazardous materials. A copy of worker
certifications is to be submitted to Rayonier Engineering Department prior to start of work.
Contractor will provide all required labor, equipment, and supervision to abate the above
listed material.
Contractor will receive from Rayonier all information, including sample documentation,
from previous hazardous bulk sampling surveys.
5
Work involving asbestos requires that a 10-day prior notice oL intent to remove and.
encapsulate asbestos be filed with the Washington State Department of Labor and
Industries. In addition. a 10-day prior notification of dismantling and renovation is required
to be filed with the State Department of Ecology. A sample of these forms is attached
Contractor is responsible for submitting and obtaining all asbestos removal permits with a
copy sent to.Ravonier Engineering Department.
It is expected that Contractor's asbestos removal and handling procedures will meet all
federal and state regulatory requirements and will be at least comparable to Port Angeles
Division's asbestos removal and handling safety procedures dated August 12, 19%.
A copy of all records and tests will be submitted to Rayonier in a timely manner.
Previous asbestos bulk sample surveys have identified items or areas containing ACM and
their locations. These items will not be sampled again.
Rayonier will provide bulk dumpsters for ACM.
Rayonier will be responsible for the off-site transportation and disposal of asbestos-
containing materials. Contractor will deposit ACM, properly sealed. into asbestos
r dumpsters located adjacent to plant buildings. Contractor will notify the Engineer 24 hours
in advance of the need to have an asbestos dumpster removed and emptied.
III. LEAD MA"T'RRTAT REMOVAL
The Contractor will remove all lead and lead-containing materials from the work
areas identified through site survey information as provided by Owner. Lead and
c lead-containing material is knownto exist in equipment, piping, and paint. The
following items apply to this work:
A. The Contractor will provide for worker safety and lead abatement measures
during the dismantling per OSHA and WISHA regulatory guidelines.
B. The Contractor will be certified as required by the State of Washington for the
removal. handling, and transport of lead-containing materials. A copy of work
certifications to be submitted to Rayonier Engineering Department prior to start
of work.
C. It will be the responsibility of the Contractor to obtain any and all required
permits for this work.
D. Contractor to provide Rayonier with a detailed work plan including containment
and air monitoring procedures prior to start of work. The work plan is to include
a description of the required
special collectionifiltration of waste streams
generated by this work.
Rayonier will provide for disposal of all lead and lead-containing material.
E. Contractor will provide for all air monitoring throughout the abatement period.
6
t
F. Contractor will maintain on-site documentation of airborne lead levels and
employee exposures for the duration of the abatement period.
G. Copies of all tests required including air monitoring, personnel exposure levels,
etc., will be submitted to Rayonier in a timely manner.
H. Rayonier will provide bulk dumpsters for all lead-containing material. The
Contractor will deposit all lead-containing material, properly sealed, into bulk
'7 dumpsters. Rayonier will be responsible for off-site transportation and disposal
of all lead-containing materials.
IV. HAZARDOUS MAIERIAi c
Owner has inspected existing buildings, equipment, and materials related to the work
outlined herein and has identified the following materials which are classified as hazardous or
are a safety or environmental concern:
A. Asbestos material exists in varying amounts throughout the Mill. A detailed survey will
be provided to the Contractor.
B. Certain vessels' linings are known to contain a lead-based material such as litharge.A
detailed survey will be provided to the Contractor.
C. Some transformers containing residual levels of PCBs are still in service on the Mill site.
A detailed list of these locations will be provided to the Contractor. Rayonier will test
samples of concrete flooring in the areas of transformers and provide results to the
Contractor. Concrete flooring in these areas will not be removed until testing results are
available.
D. Treated wood may be present in walkways, bulkheads, or building components,i.e.,
Penta, creosote, CCA, etc.
E. Paints used may have contained lead and primers may have contained zinc. Respiratory
protection should be considered during any operations involving flame cutting.A
detailed survey will be provided to the Contractor.
F. Greases and oils used for lubrication and hydraulic systems are present. Rayonier will
drain gearboxes, pumps,and systems of all fluids except those agreed to with Contractor
that must remain in service.
Contractor will conduct an independent inspection. If the Contractor believes additional
hazardous materials are present,the Contractor will stop work in any area where exposure to
such hazardous materials is likely. The Engineer will evaluate the situation and determine
how the work will proceed.
Owner will be responsible for extraordinary costs associated with such additional hazardous
materials. Such costs may include testing,removal,transport,and disposal fees.
7
V. 03UMR'S RESPONSTBIIITY
The following items of work will remain the responsibility of the Owner:
A. Testing for hazardous materials prior to start of dismantling work�1 subject to Contractor I
verification.
B. Disposal of lubricants, oils, and greases which are removed from equipment by
Contractor.
C. Draining and disposal of all PCB-containing fluids from transformers. NOTE:
Contractor will remove drained transformers (9) from buildings and load on trucks
supplied by others for transport to final disposition.
D. Off-site transport and disposal of all hazardous materials including asbestos and lead,or
any materials classified as a hazardous waste, in compliance with all federal and state
laws and regulations regarding transportation and disposal of hazardous materials.
E. Off-site transport and disposal of nonhazardous rubbish and nonsalvageable material.
Contractor will stockpile segregated material at locations on the mill property as
designated by the Engineer.
F. All required piping and electrical alterations to existing mill systems that may be
required to keep essential equipment operating during the early phases of mill
dismantling.
G. All below grade remediation of soils, etc., as well as dismantling of underground
piping, conduit, and piling.
H. Installation of security fencing at mill property boundaries: Contractor will provide for
and maintain security fencing around active dismantling work areas.
Attachment:
Drawing D-92137 Dismantling Areas/Plot Plan
8
Shoreline Application
Page 4
12. (To be completed by local official.) Nature of the existing shoreline.
(Describe type of shoreline, such as marine, stream, lake, lagoon, marsh,
bog, swamp, flood plain, floodway, delta; type of beach, such as accretion,
erosion, high bank, low bank, or dike; material such as sand, gravel, mud,
clay, rock rip rap, and extent and type of bulkheading, if any) :
13. (To be completed by local official.) In the event that any of the proposed
buildings or structures will exceed a height of thirty-five feet above the
average grade level, indicate the approximate location of and number of
residential units, existing and potential, that will have an obstructed
view.
14. (To be completed by local official.) If the application involves a
conditional use or variance, set forth in full that portion of the Master
Program which provides that the proposed use may be a conditional use, or,
in the case of a variance, from which the variance is being sought.
Reviewer:
Date:
', -,,r � `j' is��,, .,' •�.: /I ;, 'I �. ' ..
' � ,♦ � �. . �Ali ,?�.
40
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• ' ••� X11 �� '. ��'y; j' -
IWILUING VE. .411' - PREAPPLICATION
hwAr C,a.TOlebt�Ej
•`_ rMU Mr•c
Thr Building Prrmi, - l'rroppllcallon newt be f,&d out coayrletel y.
Pka.e type or print in ink. If you have any questions.please call 417-4815
Applicant and/or Agent:
Ra crier Inc - Port Angeles Hi11 Phone: 360-457-3391
Y
()wner: Rayonier Inc. 1'hone. 360-457_457_3391
Address: 700 North Ennis Street City: Port Angeles, Wa Zip: 98362
ArcWtect/Engineer: Bill Jensen Phone: 360-457-3391
Contractor License #: Exp: Phone:
Address: City: Zip:
PROJECT ADDRESS: 700 North Ennis Street, Port Angeles, WA . ZONING
LEGAL DESCRIPTION:Lot: Block: Subdivision:
See attached Exhibit I
nTE OF WORK: SIZEWALUATION:
3 Residential a Ncw Constr. o Rcroof ❑ Woodstovc 526.855* SF.Q S 2.28 /SF. -S 1 .200,000
Multi-family o Addition a Movc o Garage $F.@ S__/SF. -S
I Commrnaal ❑ Rcmodcl a Demolition o Dock SF.®S------/SF. `S
a Repair a Sign o TOTAL VALUATION S
aRIEFDESCRIPTIONOFTIEPROJECT: Dismantling of all structimPc nt'^nc
fur ri�manrlinre attached
* Sq ft is estimated buildings (including multiple floors)
COMMERCIAIJRE8IDENTIAL: Ooarpancy Group: O&Waat Load: Construction Type:_
,40.of Stories: Lot Size: %Lot Coverage: '
ixisting Lot Coverage: /sq.R+Proposed Lot Coverage: /sq.R TOTAL LOT COVERAGE: /sq.fi
?LANNING USE ONLY. APPROVALS: BPS
es:
'omits Required: Not
•,tax.Height Setbacks: Zoaing' DPW
lite Plan and Use Approved by. Date: FIRE
SA/WedwWs):o Yes a No SEPA Chocklist required?a Yes o No Otho: OTHER
'REAPPUCATION SUBMITTAL• your man and sift pima mud beyN d oat oonf&*to be meed for revkw The Building
livision can provide you with morn dcWlod information on the apprication ad plan submitW roquit==(S-
i UILDING PERMIT APPLICATION SUBMITTAL- Your eompletod application.site plan(for additions)and building construction
clans arc to be wbcnitted to the Building Division Any addition tamer than 500 sq.R.will need a PreappQcatton Revkw.
1ALUATION OF CONSTRUCTION: Ia allcats,a valuation amount must be entered by the apphoonl. This figure will be reviewed and
"ay be mvised by the Building Div.to comply with auitint foe whodules. Contact the Permit Coordinator at 4174815 for assistance.
'LAN CHECK FEE: Yotr plan dw&foe me is duc at the tithe building permit application and construction Piens ane aubmittod Allotha
«mit fea are duc at the firm of permit isstianoc.
-X-PIRATION OF PLAN REVIEW, U no permit is issued within ISO days of the date of applicatim dus application will expire by
f14110nt The Building Ottiaal can extad the am for action by the applicant up to 180 days,on written request by the applicant(soc Soction
01(d)of the Uniform Building Code.current edition). No Appliation,=be extetdod more flan once.
lK^rbY out%1 thw I hair nod and examined this application and bow the same to be true and corn-and/am authorised to apply for
"1 pernrlt. l underwand It 4 not the City's legal rrsponslbdl/v to determine what permits an nrqulrrd; l/ rrmatru the applicant's
•fpont/blllty to determine what permlts arts requ/rrd and to obtain sur
Apptloaw Date: /7
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Rayonier Port Angeles Mill
Closure and Site Conversion Facts
I. Rayonier's Approach to the Site Conversion Process
Rayonier will work hard to minimize the impact of the site conversion on the
community and will meet or exceed all environmental requirements necessary for the
next potential use of the site.We will continue to assist mill employees with transition
needs,ensure the health and safety of those involved in the site conversion process,and
continue to support the community's effort to make the site a local asset. Rayonier is:
• Experienced in site conversion and clean-up in Washington state with Rayonier's
former Grays Harbor pulp and paper mill.That effort received the approval of the
Washington state Department of Ecology and was completed in a timely manner;
• Limiting site dismantling activities to normal weekday business hours,and will
be minimizing dust and noise potential to the extent possible.
• Expecting the Port Angeles process to be straightforward as it was in Grays
Harbor,with no significant environmental issues anticipated. Rayonier has
extensive knowledge of the site,having owned the property since 1929;
• Recycling as much of the material on the site as possible,including structural
wood and valuable metals like stainless steel,copper and steel. Equipment that can
be used at other Rayonier locations will be transferred.
• Approaching the Port Angeles pulp mill site conversion in the same manner as
we address safety issues,which recently resulted in the Port Angeles worksite
being nationally recognized as one of the safest in the country;
• Working closely with appropriate agencies through the site conversion process;
• Contracting with a regional firm highly experienced in pulp mill and industrial
site dismantling,which will have employees on site for several months.Safety and
environmental specialists will be on-site,with Rayonier employees supervising all
activities.
II.Dismantling Activities Are Designed to Minimize Community Impacts
• Dismantling operations will occur during normal business hours Monday through
Friday,with no activity scheduled for weekends.
• Vehicle traffic will be minimized to the extent possible.Much of the larger,
recyclable material will be transported from the site by barge.
• No unusual odors should occur during the site clean-up and dismantling,dust
control measures will be taken and noise will be limited to the extent possible.
1 3/4/97
III.Planned Actions to Protect the Environment
• Rayonier is working closely with appropriate agencies on the site conversion and
clean-up process. A site assessment will be completed after dismantling is
completed,and a site remediation plan will be developed with the Washington state
Department of Ecology in accordance with the state Model Toxic Control Act.The
remediation plan will be based on the what is known about the potential use(s) of
the site at that time.The Department of Ecology will assess the effectiveness of
whatever actions are taken and certify the site when the process is completed. No
significant issues are anticipated at this time.
• Long-established processes and procedures employed during routine
maintenance shut-downs will be used in the clean-up and site conversion process.
The mill has extensive experience in these processes.
• As much material as possible will be recycled or put to beneficial use on the mill
site,reducing the impact on landfill space.Major recyclable material on site includes
structural wood that can be re-milled and metal(stainless steel,copper,steel).
Concrete will be crushed and used for paving material or fill on the mill site.
• All chemicals used in pulp production will be removed prior to dismantling.On-
site quantities of the major chemicals used in pulp production--chlorine,sulfur
dioxide and ammonia--will either be used in production or sold to manufacturers.
• The wastewater treatment system will be in operation throughout the site
dismantling phase.
• All waste will be dealt with properly.Non-hazardous waste will be taken to
Rayonier or general purpose landfills. Approximately 85 percent of materials to be
disposed of is wood debris,10 percent roofing,drywall,plastic and fiberglass and
five percent brick and tile. Residue from everyday substances such as turpentine and
cleaning solvents will be disposed of at designated disposal sites. Lab testing of
materials that may be considered hazardous will be done to ensure proper disposal.
IV.Timing of the Closure/Site Conversion Process
• February 28:Pulp production ends.
• March 1:Two-week clean-up begins to clean production process equipment and
remove chemicals used in the process.
• Mid-March:Number of employees on site to begin to taper off,with salaried
Rayonier employees and a small group of contractors only on site after April 18.
• May: Dismantling begins and is expected to last approximately 12-16 months.
Several dozen structures,totaling more than 500,000 square feet,are to be
dismantled at a cost of about $1.7 million. Near the end of the dismantling,the
mill's 300 foot stack will be taken down.
• 1998: Environmental site evaluation begins,after the surface structures have been
dismantled to their foundations.An evaluation of any potential remediation efforts
2 3/4/97
needed for the next potential use(s) of the site will be made,if anything is known
about the site's potential at that time. It will be based on soil and groundwater
testing throughout the site,using state and federal agency-approved procedures.
• 1998-99:If site evaluation indicates any remediation needs to be done,it will occur
in accordance with state procedures.
• Post-remediation:If site remediation is required and completed to the satisfaction of
the Washington state Department of Ecology,the site will be certified as meeting
DOE's standards.
3 3/4/97
RAYONIER MATERIALS HANDLING PLAN
PORT ANGELES MILL DISMANTLING
1. General Mill Cleanup
Pulping Chemicals
Technical Laboratory
Departmental Areas
Hazardous Waste Collection and Removal
Empty Containers
Creosote Treated Wood
Antifreeze
Used Shop Rags
Chlorofluorocarbons
Parts Washer Solvents
Used Paint Solvents
Lead Contaminated Waste
Lead Acid Batteries
Mercury Containing Thermostats
Used Oil
2. Mill Demolition
Inspections
Shutdown
Contractor
Finals
Asbestos Removal
Lead Removal
PCB Electrical Equipment
3. Materials Handling
Items
Stockpiling
Stormwater
Rubbish
4. Quality Control and Assurance
Contractor
Rayonier
5. Record Keeping
AGENDA
Agency Meeting
March 4, 1997
10:00 AM - 1 :00 PM (Lunch will be served)
GREETINGS-- Mark Johnson, General Manager
INTRODUCTIONS AROUND THE TABLE
GENERAL OVERVIEW-- Mark Johnson
• Why we called everyone together
• Where we are to date
• Overall long-term plan
• Why the approach in two phases
• Contractor selection
• Project timing
POINTS THAT NEED CLARIFICATION BASED ON COMMENTS AND
CORRESPONDENCE
• Future land use and economic impact -- Mark Johnson
• Waterfront Trail -- Mark Johnson
• Mechanics of dismantling of the mill -- Bill Jensen/Bill Cassinelli
Noise / dust/ hours of operation
• Spill control and containment -- Brian Jones
• Waste handling -- Paul Perlwitz/Brian Jones
• Contractor's overview, how we do it -- Iconco
OPEN QUESTIONS AND ANSWERS
Rayonier SEPA Review Other Agency Contacts:
Marc Crooks, DOE, Industrial Section--(360)407-6934
Charles Gale, DOE, Assistant to the Regional Director--(360)407-6309
Chuck Matthews, DOE, Solid Waste-- (360)407-6383
Chris Mathews, DOE, Hydrogeologist-- (360)407-6388
Jeffree Stewart, DOE, Shorelands-- (360) 407-6521
Barbara Ritchie, DOE, SEPA--(360)407-6922
Leon Wilhelm, DOE, Hazardous Materials-- (360) 407-6362
Mark Bentley, DOE, Wetlands-- (360)407-7269
Rebecca Lawson, DOE, Toxic Cleanup Program-- (360) 407-6255
Mike Watson, EPA-- (206) 553-6901
Cara Steiner Reiley, EPA-- (206) 553-1142
EPA, Superfund-- (206) 553-2104
Army Corps of Engineers-- (206) 764-3495
Lisa Randlette,DNR--(360) 902-1085
Martha Hurd, DNR-- (360) 374-6131 or 1-800-527-3305 ext 2804
Wayne Fitzwater, DNR, Aquatic Land Manager-- (360)457-9673
Tammy Allen, DNR, Sediment Section--(360) 902-1068
Robert Burkle, Fish&Wildlife, Area Habitat Biologist-- (360) 249-1217
Tim Rymer, Fish&Wildlife
Bob Martin, Clallam County, DCD -- (360) 417-2323
Andy Brastad, Clallam County, Environmental Health-- (360)417-2415
Andy Meyer, Clallam County, Planning-- (360)417-2326
Tobi Maggi, Clallam County, Planning-- (360)417-2324
Ken Sweeney,Port of Port Angeles,Planning and Environmental Manager-- (360) 417-3452
Carol Brown, Elwha Klallam Tribe-- (360)452-8471 ext 135
Jamestown SYJallam Tribe-- (360) 683-1109
Brian Jones, Rayonier, Environmental Superintendent -- (360)457-2352
Paul Perlwitz, Rayonier, Environmental Specialist-- (360)457-2442
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Marc E.Crooks, P.E.
Pulp&Paper Mill SPeciali5t
Department of Ecology 360/407.6934
Central Programs AX_ 1407.6904:
PO box 47706 mcra461 may=rva.gov
Olympia.WA 98504-7706
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CITY OF PORT ANGELES ,J
ANM/M� 7
EAWRONMENTAL CHECKLIST
1997
pL
PLANNING DEPARTMENT
Purpose of Checklist:
The State Environmental policy Act(SEPA),Chapter 43.21 C RCW,requires all governmental agencies to oonsider the
environmental impacts of a proposal before making decisions. An environmental impact statement(EIS)must be prepared for all
proposals with probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide
tnfomation to help you and the agency identify impacts from vour proposal(and to reduce or avoid impacts from the proposal,if it
can be done)and to help the agency decide whether an EIS is required.
Instructions for Applicants.-
This
pplicants:This environmental checklist asks you to describe some basic information about vour proposal. Governmental agencies use
this checklist to determine whether the environmental impacts of your proposal are significant,requiring preparation of an EIS.
answer the questions briefly,with the most precise inionnauon known.or give the best description you can.
You must answer each question accurately and carefully to the best of your knowledge. In most cases you should be able to answer
the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer,
or if a question does not apply to vour proposal,write"do not know"or"does not apply"(N/A). Complete answers to the questions
now may avoid unnecessary delays later.
Some questions ask about governmental regulations,such as Zoning,shoreline,and landmark designations. Answer these
questions if you can. If you have problems please contact the City Planning Department where employees can assist you.
The checklist questionsapply to all parts of your proposal,even if you plan to do them over a period of time or an diff rent
parcels of land Attach any additional information that v011 help describe your proposal or its environmental effects. The agency to
which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to
determining if there may be significant adverse impact.
BACKGROUND
1. Name of proposed project: Di smantl i ng of Rayoni er Port Angel es Mi 11
A. Address or general location of site: 700 North Ennis - Foot of Ennis Street
Port Angeles, WA 98362
2. Name, address, and phone number of applicant: Rayonier Inc.
700 North Ennis
Port Angeles, WA 98362
I Name, address and phone number of contact person if other than applicant: N/A
4. Date checklist prepared:
5. Agency requesting checklist: CITY OF PORT ANGELES
6. Proposed timing or schedule(including phasing, if applicable):
Dismantling to begin in April 1997
Environmental Checklist EVALUATION FOR
Page 2 AGENCY USE ONLY
k What is the long term objective of this proposal?
Complete dismantling of all site structures
B. How does this project relate to long-term plans?
Unknown
7. Do you have any plans for future additions, expansion, or further activity
related to or connected with this proposal? If yes, explain.
Dismantling of site structures
8. List any environmental information you know about that has been prepared,
or will be prepared, directly related to this proposal:
Site has an NPDES permit which includes stormwater
management, EPA waste ID
9. Do you know whether applications are pending for governmental approvals
of other proposals directly affecting the property covered by your proposal?
If yes, explain.
Building permit for dismantling
Shoreline permit
10. List any government approvals or permits that will be needed for your
proposal, if known.
Building permit - local
Shoreline permit - local
11. Give brief; complete description of your proposal, including the proposed uses
and the size of the project and site. There are several questions later in this
checklist that ask you to describe certain aspects of your proposal. You do
not need to repeat those answers on this page. (Lead agencies may modify
this form to include additional specific information on project description.)
The proposed project is for the dismantling of all
existing structures on the site to ground level . No plans
have been made for future use of the property. See
attached specifications for dismantling.
I
h
Environmental Checklist
Page 3 EVALUATION FOR
AGENCY USE ONLY
12. Location of the proposal. Give sufficient information for a person to
understand the precise location of your proposed project, including a street
address, if any, and section, township, and range, if known. If a proposal
would occur over a range of area, provide the range or boundaries of the
site(s). Provide a legal description, site plan, vicinity map, and topographic
map, if reasonably available. While you should submit any plans required by
the agency, you are not required to duplicate maps or detailed plans submitted
with any permit applications related to this checklist.
The structures to be dismantled are located on the
Rayonier 80-acre site at the foot of Ennis Street.
A site plan with topographic details is included.
PROJECT SPECIFIC ACTIONS:
Complete this section if your proposal involves a project specific action such as a
subdivision, new construction, a new or expanding business, a site specific rezone
(not area-wide), a conditional use permit, a shoreline permit, or similar action:
ENVIRONMENT
1. Earth
A. General description of the site (circle one):
(9)rolling, hilly, steep slopes, mountainous,
other Flat with some structures on the bluff above
the main facility
B. What is the steepest slope on the site (approximate percent
slope)?
2:1 -- Bluff areas
C. What general types of soils are found on the site (for
example,clay, sand, gravel, peat, muck)? If you know the
classification of agricultural soils, specify them and note any
prime farmland.
Clay, sand, gravel
D. Are there surface indications or history of unstable soils in the
immediate vicinity? If so, describe.
The bluff above the facility to the south has shown
instability in the past.
E. Describe the purpose, type, and approximate quantities of any
filling or grading proposed. Indicate source of fill:
No filling or grading proposed for Phase I.
F. Could erosion occur as a result of clearing, construction, or use?
If so, generally describe.
No -- stormwater is currently controlled on-site
and will continue to be controlled.
1
Environmental Checklist EVALUATION FOR
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G. About what percent of the site will be covered with impervious
surfaces after project construction (for example, asphalt or
buildings)? No change. No new impervious areas are
to be constructed. Possibly less impervious surface
due to removal of roofs over permible surfaces.
H. Proposed measures to reduce or control erosion, or other
impacts to the earth, if any:
Stormwater will continue to be controlled.
2. Air
A. What types of emissions to the air would result from the proposal
(i.e., dust, automobile, odors, industrial wood smoke) during
construction and when the project is completed? If any, generally
describe and give approximate quantities if known. Emissions from
heavy equipment should be the same as if the facility
was operating. Dust from the dismantling should be
the only other emission.
B. Are there any off-site sources of emissions or odor that may
affect your proposal? If so, generally describe. None anticipated.
Overall emission should be reduced.
C. Proposed measures to reduce or control emissions or other
impacts to air, if any: Dust control wi l l -be monitored and
control implemented as necessary.
3. Water
A. Surface:
1.) Is there any surface water body on or in the immediate
vicinity of the site (including year-round and seasonal streams,
saltwater, lakes, ponds, wetlands)? If yes, describe type and provide
names. If appropriate, state what stream or river it flows into.
Ennis Creek - flows into Port Angeles Harbor
Port Angeles Harbor - Strait of Juan de Fuca
2.) Will the project require any work over, in, or adjacent to
(within 200 feet) the described waters? If yes, please describe and
attach available plans. Yes - several structures are within
200 feet. See attached site plan and specifications.
3.) Estimate the amount of fill and dredge material that would
be placed in or removed from surface water or wetlands and indicate the
area of the site that would be affected. Indicate the source of fill
material: No work will be done in surface waters or
wetlands.
4.) Will the proposal require surface water withdrawals or
diversions? Give general description, purpose, and approximate
quantities if known.
No surface water withdrawals t orals or diversions.
i
Environmental Checklist EVALUAITON FOR
Page 5AGENCY USE ONLY
5.) Does the proposal lie within a 100-year floodplain? If so,
note location on the site pian. No
6.) Does the proposal involve any discharges of waste
materials to surface waters? If so, describe the type of waste and
anticipated volume of discharge. Site has an NPDES permit to
discharge material . Discharge under the current permit
will be substantially reduced.
B. Ground:
1.) Will ground water be withdrawn, or will water be
discharged to ground water? Give general description, purpose, and
approximate quantities if known. No ground water will be
withdrawn or discharged.
2.) Describe waste material that will be discharged into the
ground from septic tanks or other sources, if any (for example:
Domestic sewage; industrial, containing chemicals; agricultural
wastes; etc.). Describe the general size of the system, the number of
such systems, the number of houses to be served(if applicable), or the
number of animals or humans the system(s) are expected to serve.
Domestic sewer is hooked into the City treatment
system.
C. Water Runoff(including storm water):
1.) Describe the source of runoff(including storm water) and
method of collection and disposal. if any(include quantities. if known).
Where will this water flow? Will the water flow into other waters?
If so, describe. Stormwater is collected and treated on-site
prior to discharge. The NPDES permit for the site
includes all discharges.
2.) Could waste materials enter ground or surface waters?
If so, generally describe. All is collected.
D. Proposed measures to reduce or control surface, ground, and
runoff water impacts, if any: Al l runoff water wi 11 be col l ected
as per the NPDES permit.
4. Plants
A. Check or circle the type of vegetation found on the site:
x _deciduous tree• alder maal ashen, other
Enviro=ental Checklist EVALUATION FOR
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x evergreen tree: fir edar, pine, other
x shrubs
_ x grass
pasture
crop or grain
x wet soil plants: cattail,buttercup, bullrush, skunk cabbage, other
water plants: water lily, eelgrass, milfoil, other
Other types of vegetation
B. What kind and amount of vegetation will be removed or altered?
Shrub around structures will be removed. Nothing
else will be altered.
C. List threatened or endangered species known to be on or near
the site. No known plant threatened or endangered exist
on site.
D. Proposed landscaping, use of native plants, or other measures to
preserve or enhance vegetation on the site, if any.
Not applicable at this time.
5. Animals
A. Circle any birds and animals which have been observed on or
near the site or are known to be on or near the site:
Birds: aw ero eagle songbirds other
Mammals: deer, ear, a k. beaver, other
Fish: bass, s mo trout errin helifis other
B. List any threatened or endangered species known to be on or
near the site. Bald Eagle have been seen on site. No known
nesting areas on site.
C. Is the site part of a migration route? If so, explain.
Not known to be.
D. Proposed measures to preserve or enhance wildlife, if any.
Dismantling will improve habitat.
6. Energy and Natural Resources
A. What kinds of energy (electric, natural gas, oil, wood stove,
solar) will be used to meet the completed project's energy needs?
Describe whether it will be used for heating, manufacturing, etc.
Energy use of all types should be significantly reduced.
B. Would your project affect the potential use of solar energy by
adjacent properties? If so,generally describe. No
Environmental Checklist EVALUATION FOR
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C. What kinds of energy conservation features are included in the
plans of this proposal? List other proposed measures to reduce or
control energy impacts, if any. NA
7. Environmental Health
A. Are there any environmental health hazards, including exposure
to toxic chemicals, risk of fire and explosion, spill, or hazardous waste,
that could occur as a result of this proposal? If so, describe.
All environmental hazards will be reduced by this
project.
1) Describe special emergency services that might be
required. Fire protection
2) Proposed measures to reduce or control environmental
health hazards, if any. NA
B. Noise
1) What types of noise exist in the area which may affect
your project(for example: traffic, equipment, operation, other)?
Site is now heavy industrial . This project when
completed will reduce the noise and traffic.
2) What types and levels of noise would be created by or
associated with the project on a short-term or a long-term basis
(for example: traffic, construction, operation, other)? Indicate
what hours noise would come from the site. Short term heavy
industrial noise for dismantling with associated
equipment. Long term improvement.
3) Proposed measures to reduce or control noise impacts, if
any: Contractors will be held to current noise standards.
8. Land and Shoreline Use
A. What is the current use of the site and adjacent properties?
Heavy industrial .
B. Has the site been used for agriculture? If so, describe.
No
C. Describe any structures on the site.
See facility site map.
D. Will an
y structures be demolished? If so, what? Yes. See
site map and specifications.
Environmental Checklist EVALUA77ON FOR
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E. What is the current zoning classification of the site?
Heavy industrial
F. What is the current Comprehensive Plan designation of the site?
Heavy industrial
G. If applicable, what is the current Shoreline Master Program
designation of the site? Urban harbor.
H. Has any part of the site been classified as an "environmentally
sensitive" area? If so, specify. Shoreline and along Ennis
Creek.
I. Approximately how many people would reside or work in the
completed project? None
J. Approximately how many people would the completed project
displace? NA -- no residences
K. Proposed measures to avoid or reduce displacement impacts,
if any: NA
L Proposed measures to ensure the proposal is compatible with
existing and projected land uses and plans, if any:
No change anticipated.
9. Housing
A. Approximately how many units would be provided, if any?
Indicate whether high, middle, or low-income housing.
NA
B. Approximately how many units, if any, would be eliminated?
Indicate whether high, middle, or low-income housing.
NA
C. Proposed measures to reduce or control housing impacts, if any.
NA
10. Aesthetics
A. What is the tallest height of any proposed structure(s), not
including
antennas;what is the principal exterior building material(s) proposed?
NA--dismantling to ground level .
B. What views in the immediate vicinity would be altered or
obstructed? None--dismantlinu to ground level . Obstruction
of views toward the Strait of Juan de Fuca would be
v Emironmental Checklist EVALUATION FOR
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C. Proposed measures to reduce or control aesthetic impacts, if any.
NA - Aesthetic impacts will be reduced with the
removal of the structures.
11. Light and Glare
A. What type of light or glare will the proposal produce? What time
of day would it mainly occur? Lighting on site will be
reduced over time.
B. Could light or glare from the finished project be a safety hazard
or interfere with views? No.
C. What existing off-site sources of light or glare may affect your
proposal? None noted.
D. Proposed measures to reduce or control light and glare impacts,
if any.
NA
12. Recreation
A. What designated and informal recreational opportunities are in
the immediate vicinity? None
B. Would the proposed project displace any existing recreational
uses? If so, describe. No
C. Proposed measures to reduce or control impacts on recreation,
including recreation opportunities to be provided by the project or
applicant, if any. NA
13. Historic and Cultural Preservation
A. Are there any places or objects listed on, or proposed for,
national, state, or local preservation registers known to be on or
next to the site? If so, generally describe: State registered
Clallam Indian Village site.
B. Generally describe any landmarks or evidence of historic,
archaeological, scientific, or cultural importance known to be on
or next to the site. Known site of early Native American
settlement.
C. Proposed measures to reduce or control impacts, if any:
For Phase I, no soils will be disturbed.
Environmental Checklist EVALUATION FOR j
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14. Transportation
A. Identify public streets and highways serving the site and describe
proposed access to the existing street system. Show on site plans, if
any. No change in access - current access is shown on the
site plan.
B. Is site currently served by public transit? If not, what is the
approximate distance to the nearest transit stop?
Not served - nearest stop 1/2 mile.
C. How many parking spaces would the completed project have?
How many would the project eliminate? NA - Private property
All spaces will- remain.
D. Will the proposal require any new roads or streets, or
improvements to existing roads or streets, not including driveways? If
so, generally describe(indicate whether public or private).
No new roads or street required.
E. Will the project use(or occur in the immediate vicinity of) water,
rail, or air transportation? If so, generally describe.
No change.
F. How many vehicular trips per day would be generated by the
completed project? If known, indicate when peak volumes would
occur. Reduction of approximately 200 trips per day.
G. Proposed measures to reduce or control transportation impacts,
if any. NA
15. Public Services
A Would the project result in an increased need for public services
(for example: fire protection, police protection, health care, schools,
other)? If so, generally describe. No increase in need for
public services.
B. Proposed measures to reduce or control direct impacts on public
services, if any.
NA
Environmental Checklist EVALUATION FOR
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16. Utilities
A. Circle utilitie currently ava
ibbble at the site electricity natural
gas water efuse service, elephone, sanitary sewer, septic system,
other.
B. Describe the utilities that are proposed for the project, the utility
Providing the service, and the general construction activities on the site
or in the immediate vicinity which might be needed.
No new utilities required.
17. Economics
A. If the proposal will result in expansion of an existing business,
please describe the nature of the expansion: (e.g., additional land
and/or buildings, new equipment, new employees).
No expansion.
B. If the proposal is the creation of a new business, please describe
(e.g., re-use of an existing building and site, construction of a new
building). No new buildings or construction.
C. Describe if the proposal is the first of its type in the community,
or what the similar uses are. NA
Enviromnental Checklist EVALUATION FOR
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D. How many people will the proposal provide employment for at
its completion and what types of jobs will be created(e.g., sales clerks,
factory workers, etc.)?(Jobs created by the construction of the proposal
should be reported separately.) NA
E. Where will the materials, goods or services utilized by the
proposal come from? Dismantling will be removing material .
F. Where will the goods or services produced by the proposal be
utilized? NA - salvage material .
G. Who will utilize the goods or services produced by the proposal?
NA - salvage material .
H. Will the proposal alter the tax assessments of the area?
Yes - significant reduction.
D. YON-PROJECT SPECIFIC ACTIONS:
Complete this section only if your proposal involves a non project specific
action such as a Comprehensive Plan Amendment, Zoning Code Amendment, area-
wide rezone(City-wide or large sub-area), specific rezone, or other similar action:
When answering these questions be aware of to what extent the proposal
or the types of activities likely to result from the proposal would affect the item at
a greater intensity or at a faster rate than if the proposal were not implemented
espond briefly and in general terms
A. How would the proposal be iikely to increase discharge to water.
emissions to air; production, storage, or release of toxic or hazardous
substances, or production of noise?
Proposed measures to avoid or reduce such increases:
B. How would the proposal be likely to affect plants, animals, fish,
or marine life?
Proposed measures to protect or conserve plants, animals, fish,
or marine life:
r environmental Checklist EVALUATION FOR
a ,
.a¢e i_ AGENCY USE ONLY
C. How would the proposal be likely to deplete energy or natural
resources?
Proposed measures to protect or conserve energy and natural resources:
D. How would the proposal be likely to use or affect environmentally
sensitive areas or areas designated (or eligible or under study) for
governmental protection; such as parks, wilderness, wild and scenic rivers,
threatened or endangered species habitat, historic or cultural sites, wetlands,
floodplains, or prime farmlands?
Proposed measures to protect such resources or to avoid or reduce
impacts:
E. How would the proposai be likely to affect land and shoreline use,
including whether it would allow or encourage land or shoreline uses
incompatible with existing plans?
Proposed measures to avoid or reduce shoreland and land use impacts:
F. How would the proposal be likely to increase demands on
transportation or public services and utilities?
Proposed measures to reduce or respond to such demand(s):
G. Identify, if possible, whether the proposal may conflict with local, state,
or federal laws or requirements for the protection of the environment.
I. the undersigned. state that to the best of my knowledge, the above information is true and
cottmlete. It is wxk stood that the lead agency may withdraw anv declaration of nonsignificance that it
mtgm issue in reliance upon this checklist should there be any W-10W misrepresentation or willful lack
of full disclosure on my part.
SIGNED:a/Cz-- DATE: / i 7 Utz'
"EXHIBIT 1"
CL- 13179
PARCEL 1
Blocks 8 , 10 , 11 and 12 of Norman R. Smith' s Subdivision of
the Townsite of Port Angeles , also Blocks 8 , 8 1/2 , 10, 10
1/2 , 111) 11 1/21, 12 and 12 1/21, Tidelands of the First
Class (East of Laurel Street) in Front of the City of Port
Angeles , as shown on the official Plat thereof on file in
the office of the Commissioner of Public Lands of the State
of Washington.
PARCEL 2
All Tidelands of the First Class in front of the City of
Port Angeles included in two tracts lying in front of the
"U. S. Hospital Reserve" and bounded on the East by the IVest
line of Blocks 10 and 10 1/2 , Port Angeles Tidelands and on
the West by the East line of Race Street , as shown on the
supplemental map of First Class Tidelands in front of the
City of Port Angeles , on file in the office of the Commissioner
of Public Lands of the State of I':ashington.
PARCEL 3
That portion of Suburban Block 33, (sometimes called Suburban
Lot 33) of the Original Townsite of Port Angeles , State of
Washington, lying North of a line parallel to and 50 feet at
right angles Northerly from the center line of the Chicago,
Milwaukee, St . Paul & Pacific Railroad Company' s existing
main line track (formerly the Seattle, Port Angeles and
Western Railway Track) sometimes referred to as Lot 1 of
Block 33 in the Townsite of Port Angeles , Washington
PARCEL 4
Block "C" of Port Angeles Tidelands being the Ennis Creek
Waterway vacated by order of the Commissioner of Public
Lands of the State of Washington dated August 27 , 1918 , -as
shown on the official Plat of Port Angeles Tidelands on file
in the office of said Commissioner.
PARCEL 5
The following Tidelands of the First Class in front of
Suburban Block 1 1/2 (sometimes called Suburban Lot 1 1/2)
of the Townsite of Port Angeles , as shown on the official
Plat thereof on file in the office of the Commissioner of
Public Lands of the State of Washington;
(continued)
CL- 13179
Page 2
Division A. Beginning at the Northeast corner of said
Suburban Block 1 1/2, thence North 63°23 1/2 ' Nest 305 feet;
thence South 66030' East 308 feet; thence South 31015" ;Vest
25 feet to the place of beginning.
Division B. Beginning at the intersection of the
Easterly line (extended) of said Suburban Block 1 1/2 .with
the Northerly line of Railroad Avenue; thence North 31015'
East 178 feet; thence North 6 922' West 550 feet ; thence
South 31015' West 158 feet; thence South 66°30' East 5S6
feet to the place of beginning.
PARCEL 6
Division "A" and Division "B" in front of Suburban Block 1
(sometimes called Suburban Lot 1) Tidelands of the First
Class in front of the City of Port Angeles , as shown on the
official Plat thereof on file in the office of the Commissioner
of Public Lands of the State of Washington.
PARCEL 7
All of Blocks 1 and 2 in Syndicate Addition to the City of
Port Angeles , together with vacated street lying between
said Blocks 1 and 2, also Blocks 2 and 3 and the Nest 320
feet (being Lots 5 to 12 inclusive) of Block 4 of Port
Angeles Tidelands of the First Class lying in front of
Syndicate Addition to the City of Port Angeles , as shown on
the official plat thereof on file in the office of the
Commissioner of Public Lands of the State of Washington.
PARCEL 8
Those portions of the following described Parcels lying
'northerly of the Northerly right of way line of the Chicago ,
Milwaukee, St. Paul and Pacific Railroad.
Parcel A: Suburban Block (Lots) 1 and 1 1/2 of the Townsite
of Port Angeles,
Parcel B: Blocks 13 , 14 and 15 of Norman R. Smith' s Subdivision
of the Townsite of Port Angeles.
Parcel C: Lots 1 through 6, inclusive, in Block 3 of Puget
Sound Cooperative Colony' s Subdivision of the Townsite of
Port Angeles.
(continued)
CL-13179
Page 3
PARCEL 9
TOGETHER WITH all vacated streets and alleys or portions
thereof lying Northerly of the Northerly line of said
railroad right of way, East of the East line of Francis
Street in the City of Port Angeles ,
AND West of the East line of the Original Townsite of the
Townsite of Port Angeles and the Northerly extension thereof,
which would attach thereto by operation of the law.
i
PARCEL 10
Lots 5 through 11, inclusive, in Block 32 of Norman R.
j Smith' s Subdivision of the Townsite of Port Angeles.
PARCEL 11
Lots 1 through 7 , inclusive, and Lots 10 through 18, inclusive,
in Block 15 of Norman R. Smith' s Subdivision of the Townsite
of Port Angeles,
PARCEL 12
Lots 16 and 17 in Block 8 of Puget Sound Cooperative Colony' s
Subdivision of the Townsite of Port Angeles.
PARCEL 13
That portion of Suburban Block (Lot) 1 1/2 of the Townsite
of Port Angeles, lying Southerly of the Southerly right of
way line of Chicago , Milwaukee, St. Paul and Pacific Railroad.
i
PARCEL 14
Parcel A: That part of of Suburban Block 1 (sometimes
called Suburban Lot 1) , of the Townsite of Port Angeles ,
described as follows:
Beginning at the Southwest corner of said Suburban
Block 1 , thence South 58'45 ' East along the Southerly line
of said Block 1 a distance of 420 feet; thence North 12'15'
East a distance of 407. 18 feet ; thence North 58°45 ' West a
distance of 287. 44 feet to the Westerly line of said Block
1 ; thence South 31°15' West along the Westerly line of said
Block 1 , 385 feet to the place of beginning.
Parcel B: All that part of Suburban Block 1 1/2 (sometimes
called Suburban Lot 1 1/2) of the Townsite of Port Angeles ,
lying Southerly of a straight line, which line intersects
(continued)
1
CL- 13179
Page 4
the Westerly line of said Block at a point which is 446 feet
Northerly of the Southwest corner of said Block and intersects
the Easterly line of said Block at a point which is 552 feet
Northerly of the Southeast corner of said Block.
PARCEL 15
Lots 5, 6 and 7 of Harborcrest, as recorded in Volume 7 of
Plats , page 31 , records of Clallam County, Washington.
PARCEL 16
Lots 7 through 12, inclusive, in Block 165; Lots 1 through
6, inclusive, and Lots 13 through 18 , inclusive, in Block
164 ; Lots 1 through 6, inclusive, and Lots 13 through 18,
inclusive, in Block 154 ; Lots 1 through 18, inclusive, in
Block 153;
AND Lots 1 and 2 in Block 152;
ALL in Frank Chambers Subdivision of Suburban Lots 37 and
part of 38 Port Angeles Townsite.
PARCEL 17
Lots 1 through 10, inclusive, in Block 1 ; Lots 1 through 9,
inclusive, and Lots 23 through 26, inclusive in Block 2;
Lots 1 and 2 in Block 3; Lots 1 through 5, inclusive, and
the North 40 feet of Lot 10 in Block 4;
ALL in Cains Subdivision of Suburban Lot 36 in the City of
Port Angeles.
PARCEL 18
The East 4 . 81 acre's of Suburban Block 38 (sometimes called
Suburban Lot 38) of the Townsite of Port Angeles , being that
portion of said Block 38 lying between the city limits of
the city of Port Angeles on the East and Blocks 152 and 166
of Frank Chambers Subdivision on the Nest ;
EXCEPT that portion conveyed to the City of Port Angeles by
instrument recorded August 18, 1967 , under Auditor' s File
No. 375004.
PARCEL 19
The Northerly 7 acres of Suburban Lot 27 of the Townsite of
Port Angeles;
TOGETHER WITH those portions of vacated streets and alleys
abutting Parcels 13 through 19 above which would attach
thereto by operation of law.
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F pORT,gNC
0, CITY OF PORT ANGELES - PUBLIC WORKS DEPARTMENT
MEMORANDUM
"Maintaining and Building a Better Community"
TO: Brad Collins, Planning Department Director
FROM: Steve Hursh, Electrical Engineering Manager FEB 1 21997
.�e L
PORT ANuELES
DATE: February 11, 1997 PLANNING DEPARTMENT
SUBJECT: Rayonier Demolition Permit
We do not have any objections to the demolition permit for the Rayonier Mill. However, we do
have the following comments:
1. Rayonier owns and maintains the 69,000 volt overhead transmission line that runs from
the Bonneville Power Administration substation near Peninsula College and winds
through the City to the mill. What are they going to do with the transmission line? If a
car runs into one of their transmission poles, who is going to repair/replace the pole?
Rayonier should be required to inspect their transmission line, I recommend at least
every other year, and maintain their facilities as necessary.
2. We have an existing distribution powerline on their property that serves the City of Port
Angeles secondary sewer treatment plant. Our underground powerline runs west from
the secondary treatment plant to their chip pile and an overhead powerline runs from the
chip pile along their access road to Caroline Street. The demolition contractor shall call
for underground locates at 1-800-424-5555 prior to any excavation and they shall
maintain at least ten (10) feet clearance between their equipment and our overhead
powerline.
3. Rayonier has electrical equipment that probably contains polychlorinated biphenyl
(PCB), which is a hazardous material. Their equipment should be tested and disposed
of according to state and federal regulations. The area around the contaminated
equipment should also be tested and any contaminated material should be removed and
disposed of according to state and federal regulations.
The state regulations allow a higher cleanup level (10 ppm) on an industrial site.
However, this would restrict future uses of the site i.e. zoning changes, anything dealing
with food, etc. A cleanup level of 1 ppm would allow unrestricted use of the property.
Jack Piths,Director Bob Titus,Deputy Director Ken Ridout,Deputy Director
Phyllis Resler,Administrative Assistant Cats Rinehart,Administrative Assistant Dale Warner,Street Superintendent
Tim Smith,Contracts Administrator Gary Kenworthy,City Engineer Bob Jones,Solid Waste Superintendent
Steve Hursh,Electrical Engineering Manager Ralph Ellsworth,Water Superintendent
Scott McLain,Power Manager Pete Burrett,Equip.Services Superintendent
Ken Malke,Conservation Manager Mark Shamp,Light Operations Manager
Lou Heehnlen,Sr.Building Inspector
Tom Spedine,Sr.Electrical Inspector
9
interoffice FEBID
27
M E M O R A N D U M
PLANNING DEP RTMENT
to: Brad Collins, Planning Director
from: Scott Brodhun
subject: Comments Regarding Rayonier Demolition Proposal
date: February 12, 1997
Brad,
The Port Angeles Parks & Recreation Department has a vested interest in the
proposal to dismantle the Rayonier Mill. Departmental concerns are relative
to transportation and recreation issues. . In 1980 the City adopted the Port
Angeles Urban Waterfront Trail Plan, and subsequent to that a trail extension
project known as Centennial Trail. The City has pursued development of the
Centennial Trail, involving development of the trail from Francis Street,
through Rayonier, to Morse Creek. In discussions with Rayonier personnel
regarding development of the trail through the mill site, indications were that
a workable solution could. be found. Based largely on that information the City
has procured in excess of $1,500, 000 in grant funding, and has invested in
property acquisition necessary to construct the trail. Thus, in light of the
priority placed on trail development by the City of Port Angeles, it is
important that our concerns for recreation and transportation be noted during
the review of the proposed Rayonier Project.
Toward that end, I offer the following comments:
d The City has purchased property, outside the current city limits,
necessary to extend the Centennial Trail.
d The Port Angeles Urban Waterfront Trail Plan was adopted in 1980.
Subsequently, the Centennial Trail project has been identified in
a variety of documents, including but not limited to the TIP, CFP,
P.A. Comp. Plan, and the Parks and Rec. Five Year Plan.
d The City has procured in excess of 1.5 million dollars in grant
funds for development of the Centennial Trail.
d The City is in current negotiation for acquisition of property
necessary to develop the Centennial Trail.
d Development of the Centennial Trail is a key element in completion
of the Port Angeles Waterfront Trail, as well as the Olympic
Discovery Trail, each repeatedly rated in the top ten trail projects
state wide. Olympic Discovery Trail being a project of regional
significance.
l
d The Centennial Trail has twice been identified as a top priority
transportation project in the region.
r9 The Centennial Trial remains a top five project statewide in the IAC
(trail category) and DNR (ALFA category) , and has been twice rated
the number one project.
01 Development of the Port Angeles Trail continues to be listed as a
top priority project by the citizens of Port Angeles.
c9 Access through the Rayonier site is essential to development of the
Centennial Trail.
In summary, any proposal regarding the Rayonier site has far reaching and
significant recreation and transportation impacts. Additionally, continued
development of the trail will result in another visible and viable amenity
assisting in Port Angeles becoming a tourism destination. Thus, the trail is
also an economic development project for the greater Port Angeles area.
I am available to discuss this as your convenience. Thank you for noting our
concerns.
VORT4
y O OF
MEMORAND
V Ilr'
'n '� ROUTE TO
'9Fa PAFt'TM�� Building Dept ❑
Planning Dept.
PLANNING DEPARTMENT RESPONSE Public works ❑
City Manager ❑
DATE: February 3, 1997
TO: Planning Department t�tee ,�
i.
FROM: Dan McKeen, Fire Marshal t- r� _ y�
PLANNING OEPA�ME
RE: Shoreline Management Permit - SMA 97-02 NT
Rayonier
The Port Angeles Fire Department reviewed the project and has the
following comments.
1. The following permits will be required prior to any related
work during dismantling of the Rayonier site.
a. welding and Cutting Permit
b. Removal/Abandonment of Above and Underground Storage
Tanks containing flammable, combustible liquids, and any
hazardous materials as defined by UFC.
2 . Fire Department requests weekly meetings as to the area
involved in dismantling.
3 . Assure the water supply system which provides fire protection
is operational in each area during the dismantling process.
Each yard hydrant shall be unobstructed, available for use by
the Port Angeles Fire Department if needed.
4 . Provide information to the Port Angeles Fire Department as to `
the removal of combustible debris from the Rayonier site
during demolition.
5. Provide a Hazardous Material Management Plan (HMMP) to the
Port Angeles Fire Department for the handling and removal of
hazardous materials along with a contingency plan for spills
and releases.
DM/cw
FP 26 Page 1 of 1
• OF QORT,gN rY
V� N
MEMORANDV
M
ROUTE TO:
Building Dept. ❑
Planning Dept. ❑
PLANNING DEPARTMENT RESPONSE Public Works ❑
it
DATE: February 3, 1997 ;
TO: Planning Department FEB _ 5 W
FROM: Dan McKeen, Fire MarshalPORT ANGELES
PLANNING DEPARTMENT
RE: Shoreline Management Permit - SMA 97-02
Rayonier
The Port Angeles Fire Department reviewed the project and has the
following comments.
1. The following permits will be required prior to any related
work during dismantling of the Rayonier site.
a. Welding and Cutting Permit
b. Removal/Abandonment of Above and Underground Storage
Tanks containing flammable, combustible liquids, and any
hazardous materials as defined by UFC.
2 . Fire Department requests weekly meetings as to the area
involved in dismantling.
3 . Assure the water supply system which provides fire protection
is operational in each area during the dismantling process.
Each yard hydrant shall be unobstructed, available for use by
the Port Angeles Fire Department if needed.
4 . Provide information to the Port Angeles Fire Department as to
the removal of combustible debris from the Rayonier site
during demolition.
5. Provide a Hazardous Material Management Plan (HMMP) to the
Port Angeles Fire Department for the handling and removal of
hazardous materials along with a contingency plan for spills
and releases.
DM/cw
FP - 26 Page 1 of 1
Rayonier Mill Closure/Hazardous Materials
Quantities and Use of .Hazardous Materials
The Port Angeles Fire Department maintains background information
on chemicals at the Rayonier facility based on the annual SARA
Title III Tier-Two report. These are the chemicals or products that
are required by both Federal and State law to be reported. These
chemicals are used in the pulp bleaching process or in maintaining
the facility and its equipment. Examples are propane, lube oils,
gasoline and diesel. Some of the chemicals are used in the Rayonier
Lab for testing purposes. Below is a list taken from the February
29, 1996 Tier-Two report received by the Port Angeles Fire
Department.
Acetone
Aluminum Sulfate-Alum
Ammonia-Anhydrous
Ammonium Hydroxide
Ammonium Bisulfite
Boiler chemical -opti tyrol 4000 betz
Boiler chemical -betz 50705 polymer
Calcium Hydroxide (lime slurry)
Calcium Oxide (pebble lime)
Chlorine
Chlorine Dioxide
Corrogen - sodium sulfite
Defoamer-Associated
Defoamer-Foamaster (DF-150-L)
DefoamerV- Foamaster (DF-216-M)
Defoamer - secondary treatment (Fleetcol• 9167B)
Defoamer - secondary treatment (Fleetcol 9168)
Defoamer - secondary treatment (Fleetcol 9137)
Diesel Fuel
Deresinator ( Aquaquest 601)
Detac 5000 - Pitch dispersant
.Filter plant polymer (Calgon POL-E-Z 652)
Filter plant chemical (CATFLOC TL Polymer)
Gasoline - regular and unleaded
Grease (various blends)
Hydrogen Peroxide <50%
1
Industrial Fuel Oil
Lube oil
Monamid 150 sheet softener
Oil, Turbine (various blends)
Parts washer solvents
Phosphoric Acid 52t
Polymer - S - 350
Polymer C -309
Polymer C -311
Propane
Reducer #54
Reducer #58
Sheet debonder - berocell 584-D
Sodium Chlorate
Sodium Hydroxide
Sodium Hypochlorite
Strip Treat - Pluronic .
Sulfur
Sulfuric Acid
Sulfurous Acid
Surfactant - Tritonn - 101
Sulfur Dioxide
Clean-up and disposal laws and/or regulations
The following laws and/or regulations could apply to the Rayonier
facility closure.
♦ WAC 173-303 Dangerous Waste Regulations
This regulation has a section on facility closure plans. The
regulation outlines having a dismantling plan in place which
addresses the following areas:
• Safety
• Storage at the facility
• Transport of the dangerous waste (if the material is
classified as such)
• Hours of operation (for the clean-up)
• Anticipated hazards during facility clean-up
• Dismantling procedures of piping, storage tanks
• Control of run-off
• Disposal of hazardous waste
• Asbestos '.s at the site - proper clean-up and disposal
2
1994 Uniform Fire Code Article 80 relationship to facility closure
♦ 1994 Uniform Fire Code
► Article 80 Hazardous Materials
8001.3 .1 Permittee shall apply for approval to close
storage, use or handling facilities at least 30
days prior to the termination of the storage, use
or handling of hazardous materials. Such
application shall include any change or alteration
of the facility closure plan filed pursuant to
Section 8001.11. This 30-day period may be waived
by the chief if there are special circumstances
requiring such waiver. (Page 1-303)
8001. 11 Facility Closure
8001. 11.3 Plan. The permit holder or applicant shall submit a
plan to the department to terminate storage,
dispensing, handling or use of hazardous materials
at least 30 days prior to facility closure. The
plan shall demonstrate that hazardous materials
which were stored, dispensed, handled or used in
the facility have been transported, disposed of or
reused in a manner that eliminates the need for
further maintenance and any threat to public health
and safety. Such plan shall be submitted in
accordance with Section 8001.3 .1.
8001.5.2 .3 Preparation. Provisions shall be made for
controlling and mitigating unauthorized
discharges.
8001 .5 .2 .5 Responsibility for clean up. The person, firm, or
corporation responsible for an unauthorized
discharge shall institute and complete all
actions necessary to remedy the effects of such
unauthorized discharge, whether sudden or
gradual, at no cost to the jurisdiction. When
deemed necessary by the chief, clean up may -be
initiated by the fire department or by an
3
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authorized individual or firm. Costs associated
with such clean up shall be borne by the owner,
operator, or other person responsible for the
unauthorized discharge.
Washington State Department of Ecology
The Washington State Department of Ecology has a person assigned to
the Rayonier facility closure, Marc E. Crooks, P.E. , Pulp & Paper
Mill Specialist. I received this information from Jim Oberlander,
Washington Department of Ecology Spill Response Coordinator and
from Brian Jones, Environmental Superintendent, Rayonier facility.
A copy of his business card is attached.
4
OF pORTAHC
F
MEMORANDUM
�°�ANNING
EpLANPNOIRTA
171 �,January 24, 1997 �N 3 01997 . :'NGELESTO: Public Works Department NG DEPARTMENT
Fir Department
,Light Department
FROM: Planning Department
SUBJ: SHORELINE MANAGEMENT PERMIT-SMA 97-02
RAYONIER
Attached hereto is an application for a shoreline management permit to allow the dismantling of the
Rayonier mill site. Please review the attached information and forward any general comments or
those you would recommend as conditions of approval to the Planning Department no later than
February 6, 1997. If you have any questions or require further information,please don't hesitate to
contact the Planning Department at extension 4750.
Thank you.
Attachments
SNo�,�-trl� MA��Gt✓M.t�T �f�,�T.
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PORT OF PORT ANGELES
338 W. First St. (360)457-8527
P. O. Box 1350 FAX(360)452-3959
Port Angeles, WA 98362-0251
February 12, 1997 D ( (�
FEB 1 21997
Mr. Brad Collins, AICP '
Planning Director PC;F;T ANGELES
City of Port Angeles PLAf�iv:nc c �;;i:Tr: tENT
P.O. Box 1150
Port Angeles, WA 98362
RE: Request for Comments on Rayonier Mill Demolition Permits
Dear Brad:
In your letter dated Feb. 5, 1977 you informed the Port that the City had received
a permit application and environmental checklist submitted by Rayonier for the
mill closure and demolition. You asked for comments from the Port, as an
agency with expertise, on additional information that may be needed and
environmental impacts with which our agency is concerned.
First, I note the cover letter from Rayonier dated Jan. 16, 1997 states that the
permit applications do not include: (1)work below ground level, (2) any work in
the water below the high tide mark, or(3) removal of the dock, except structures
above the level of the decking. The Port's primary expertise and concern would
be with the in-water work and with the pier. Since apparently this work and
structure are to be the subject of future applications by Rayonier, I will reserve
comment on that aspect of the project until the appropriate time.
Secondly, I have a concern with the lack of information provided on page 11
under item 17, Economics. I believe everyone in the community perceives that
the primary impact resulting from the mill closure and dismantling is the
economic impact. There is no information under item 17 on the economic
impacts. I believe there may be several pages that could be written, analyzing
the economic impacts created as a result of mill closure and dismantling.
Additional comments on information appearing in the environmental checklist
prepared by Rayonier include the following:
COMMISSIONERS: • Glenn Beckman ♦ Dick Foster ♦ Jack Waud
EXECUTIVE DIRECTOR: ♦ Christine Anderson
• On page 5 under the question about whether the property is in the 100-year
floodplain, the answer is "Non'. My copy of the FIRM Flood Insurance Rate
Map shows some of the Rayonier property in Flood Zone V6.
• There is no information given about disposal of demolition waste. According
to the county's solid waste experts, suitable sites for disposal of demolition
waste is one of the greatest unmet needs in the county. If this condition still
exists, it would seem that impacts on existing solid waste disposal sites is a
subject that needs additional analysis.
I have one final observation. The environmental checklist format is designed
more for new and expanded development rather than for an action that reduces
improvements at a site. In attempting to answer the checklist questions for the
mill dismantling, the response is accurate in most instances. However, it leaves
me wanting more information. I believe there is considerably more
environmental analysis that could be provided if the applicant were to go beyond
the question and answer format of the environmental checklist.
I hope these comments are useful and will assist the City as you proceed with
processing the Rayonier applications.
Sincerely,
enneth W. Sweeney, AICP
Planning and Environmental Manager
MEMORANDUM
Clallam County Department of Community Development
TO: Brad Collins, Planning Director D U u d
FROM: Tobi Maggi, Senior Planne J
FEB 12 X97
SUBJ: SEPA Comments on Rayonier Mill Demolition Proposal
PORT ANGELES
DATE: February 12, 1997 PLANNING DEPARTMENT
The Clallam County Planning and Environmental Health Divisions have reviewed the SEPA checklist,
shoreline permit application and work plan for the proposed dismantling of the Rayonier pulp mill and
have the following comments.
Rayonier has indicated that dismantling of the mill will occur in two phases; Phase I will consist of the
removal of above ground structures and Phase II apparently will be subgrade removal of facilities and
remediation. However,the current checklist and permit application appear to only discuss Phase I
issues. No mention regarding the timing of Phase 11 is made by Rayonier in the checklist or work plan.
In essence, agencies are being asked to review this proposal in a piecemeal method as opposed to one
overall, cumulative project. It would seem, according to WAC 197-11-060(5)(d)(io,that phased review is
not appropriate when such phasing avoids discussion of cumulative impacts such as quantities of
materials generated by the total protect.
The applicant, in the environmental checklist, repeatedly refers to the NPDES permit presently existing
for the mill. The applicant has not outlined the provisions of that permit nor provided assurance that
stormwater can be accommodated by this existing permit. The applicant should provide verification from
the Department of Ecology that the current NPDES permit can indeed be utilized for the discharge of
stormwater from this site which may contain increased sediments and contaminates associated with
demolishing the pulp mill which are not identified in the current NPDES permit. It should be imperative
that the applicant submit,and have approved, an engineered,drainage and erosion control plan as part
of the permit review process in view of the scope of the project and its proximity to the marine shoreline
and because it impacts shorelines of statewide significance and creates an opportunity for contaminants
associated with milling processes to enter surface water. Drainage facilities on the site presently may be
altered by dismantling work,therefore, existing facilities may be rendered ineffective to protect surface
waters. On page 5, Section C(1)of the checklist,the applicant indicates that stormwater will be treated
on-site but does not describe that treatment. The drainage and erosion control plan should ensure that
all debris, overburden and other waste materials from demolition be stored and disposed of in such a
manner so as to prevent their entry into the Port Angeles Harbor by erosion from drainage, high water or
other vectoring mechanisms.
Throughout the checklist, Rayonier states that milling structures will be dismantled. If these structures,
previously used in milling processes, are crushed and stored on the site, residual chemicals and
contaminants will most assuredly be associated with the surfaces of demolished structures. This raises
two concerns. If Rayonier intends to wash these materials,then monitoring and proper disposal of wash
water is imperative. Secondly, if Rayonier does not wash these materials before crushing and storage,
drainage from unwashed material must not be allowed to enter surface and ground waters. Furthermore,
if these materials are removed from the site without being washed,they present potential hazards off-site
as they are recycled or disposed. The same issue arises when the applicant intends to dismantle
lagoons on the site and berms associated with these lagoons. Years of accumulated wastes,such as
slugdes and like substances, are proposed for disposal, however,the checkiist.does not address
methods ensuring that these residual materials will be disposed of safely.
Regarding impacts to animals, in the checklist, Pages 5 and 6,the applicant has stated that dismantling
of the mill will improve habitat, however,the applicant has failed to identify just how habitat will be
223 East 4th Street, Port Angeles, WA 98362 (360) 417-2000
Memorandum
February 12, 1997
Page 2
restored. As noted in the checklist, bald eagles are known to be near the site. Furthermore, has the
applicant made any marine restoration proposals or mitigation?
On Page 7, Section 7 regarding Environmental Health,the applicant states that all environmental
hazards will be reduced by this project. This assertion can only be supported if the applicant supplies a
complete disclosure of the long term storage monitoring of material generated by the total project. The
applicant will be exposing soils within the shoreline jurisdiction that have been subjected to decades of
heavy industrial mill processing but has not provided any Indication of the contaminate level of those
soils and potential impacts these soils will have on the marine environment if exposed and-if left on-site.
The County believes it imperative that Rayonier establish a thorough, Independent and verifiable
program for testing, evaluating and tracking through ultimate disposal of all wastes generated during mill
demolition and site remediation.
Regarding land use,this site is zoned heavy industrial. It may be appropriate for the City of Port Angeles
to consider a zoning that will have lesser impacts on the marine shoreline. The applicant has not
identified the marine shoreline to be an area classified as environmentally sensitive. Clallam County has
designated all marine shorelines as Class I Aquatic Habitat Conservation Areas which provides buffers
and options for habitat management plans to be developed. This should be considered.
The applicant has also not addressed public access Issues to the shoreline. The applicant is in a position
to address this issue specifically regarding the Waterfmnt/Olympic Discovery Trail. In review of WAC
173-27-160(1)(b), it states that the public use of the shoreline should not be interfered with. The review
criteria for shoreline conditional use permits repeatedly promotes public access and use of the shoreline.
This is backed up by RCW 90.58.020. Rayonier and the City of Port Angeles had a verbal agreement to
allow extension of the Waterfront Trail through Rayonier's property utilizing the old railroad grade.
Clallam County also has made extension of the Waterfront/Olympic Discovery Trail a major
transportation goal within the Clallam County Comprehensive Plan. A formal transfer of the old railroad
grade right-of-way to the City of Port Angeles or other right-of-way acceptable for trail purposes as a
condition of the shoreline permit would benefit all citizens of both the City and the County and meet
public access goals of both jurisdiction's Shoreline Master Programs. Demolition should occur in such a
manner as to not preclude future shoreline access for the general public.
Area 9 of the work plan addresses the dock area. Assuming this shoreline development is considered to
be a legal, non-conforming use, any subsequent use of this dock must be in compliance with WAC 173-
27-080. The applicant should seriously consider removing this facility and restoring the shoreline.
Presently,this site is served by a large, concrete waterline which runs the length of the shoreline through
the City. Has the applicant discussed the maintenance of this structure? And what is the status of the
water right permit for water conveyed by this structure? We would assume that the existing water right
was granted by the State for an industrial use. The relatively large quantity and high quality of water that
this water right represents could potentially be a very attractive asset to a wide variety of new industrial
uses. If the water right is utilized for a non-industrial use,the City and the County, already strapped with
economic hardships,will lose a potential attribute to draw future industrial land uses. On the other hand,
water levels have been low in past years within the lower Elwha River system. In the some years,flows
in the Elwha River have been so low as to Inhibit salmon migration. Has Rayonier considered the
possibility of enhancing fish habitat in the Elwha River by allowing this water to remain in the system?
In Sections II and III and IV of the work plan, asbestos, lead and hazardous materials are identified and
BMPs are loosely listed. It may be helpful for the County,who may be responsible for landfill location of
demolition materials,to have the sources of these materials identified and inventoried. Once a final
disposal site is identified, a grid system should be employed to locate and identify what materials are
stored where. In Section 5(G),the applicant indicates that the owner will be responsible for all below
grade remediation of soils. Remediation of soils should be discussed as part of this application.
Furthermore,the owner will be responsible for the dismantling of underground piping, conduit and piling.
How will these actions be mitigated to prevent these pipes and excavations from conveying untreated
-Page 2-
Memorandum
February 12, 1997
Page 3
stormwater into surface waters? Asbestos removal may also require a permit from Olympic Air Pollution
Control Authority.
It may be appropriate to designate an on-site person to maintain tracking of material as they are
removed to ensure that all materials are removed in accordance with state and local laws and conditions.
In may also be appropriate for an industrial hygienist to be maintained on-site to ensure worker safety
during the removal of asbestos, lead, hazardous material and all inert materials.
The applicant should also be required to provide a cost analysis of,and consideration, of barging
material intended for disposal to an existing facility with long term monitoring programs in place as
opposed to land-filling in Clallam County.Otherwise,the City should consider withholding issuance of a
shoreline permit until Rayonier has an approved landfill location for their demolition waste. Furthermore,
the applicant should indicate if materials for recycling will be barged from the site. If recycled or other
hazardous materials are barged,the applicant needs to address again the potential transport of
contaminated stormwater to surface waters including impacts that may occur from pumping bilge water
from these vessels. The checklist is so general that the County is unable to assess impacts that could
occur as a result of increased truck traffic or even if trucks will be used.
The County suspects, contrary to what is indicated in the checklist,that a substantial number of
additional permits may be required for this project, including a solid waste disposal permit from the
County. The situation should be avoided wherein the applicant demolishes the facility without the ability
to transport that material from the site.
Considering the extent of this project,the City may want to entertain petitioning the Washington
Department of Ecology to assume lead agency status for the entirety of this proposal.
C. correspondence file
parcel file
Bob Martin, Director
-Page 3-
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1 rt. 1 F
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.4 Ffi 2851 LOWER ELWHA ROAD (360)452-8471
PORT ANGELES,WA 98363 =3428
VAI
FEB 1 2 1997
PORT ANGELES
PLANNING DM'IRTMENT
February 11, 1997
Brad Collins, Planning Director
Port Angeles Planning Department
PO 1150
Port Angeles, WA 98362
Subject: Shoreline and Building Permit Application
Rayonier Inc.- Port Angeles Mill
Dear Mr. Collins,
Ennis Creek on the Port Angeles harbor is a historic Klallam village site
and of critical concern to the Elwha Klallam Tribe. We have historic,cultural
and fisheries co-management concerns regarding demolition,site remediation
and future use of the Rayonier-Port Angeles Mill site. Separating the permits for
structure demolition and site remediation seems inappropriate at best. In these
comments we will focus attempt to focus on facility de-construction,but overall
concerns remain.
1. Cultural resources of the site are of primary concern to the Tribe.
Excavation or exposure of native soils requires an archaeologist in
attendance to assess the presence and condition of cultural evidence.
Depending on the type of soil borings used to assess soil contamination
archeological assessment can occur concurrently.
2. The owner provided no timeline in the permit application. We have
requested technical assistance and on-site inspection during dismantling
process by the Environmental Protection Agency (EPA). To coordinate this
review we need to know when each phase of demolition will occur. For
example, all asbestos, PCBs and hazardous materials must be removed prior
to the structure demolition. This phase is not scheduled or distinct.
3. The workplan does not contain enough detail for adequate review of the
dismantling process. It appears that the owner would like to fast tract the
shut down with a general laundry list of what will go and what will stay.
This does not demonstrate the detail necessary to address the corporate
responsibility inherent in mill closure.
4. Separation of the permit application into "above and below grade"/ "above
and below high tide" phases does not mitigate affects of the dismantling
r
process on cultural,soil,groundwater or surface water resources. The Tribe
finds this inappropriate. Thorough sampling and remediation of the land
and water resources site must occur.
5. Surface water resource of Ennis Creek is above the high tide mark,but is not
addressed in this permit. The Tribe recommends contaminant testing for
sediments of Ennis Creek and surrounding soils. Fisheries habitat has been
degraded by construction and operation of the mill facility.This condition in
the lower reach affected by the facility must be mitigated. The Tribe has
extensive expertise in stream restoration and would welcome the
opportunity advise Rayonier Inc. regarding stream remediation.
6. What use will be made of the Shotwell landfill? What testing of that waste
stream is planned?
7. Third party observation of this dismantling process is essential to assure
compliance with existing environmental protection. The Department of
Ecology technical staff should be on site during the project.
The Tribe has requested review of the dismantling permit by Region 10
EPA in the areas of Hazardous Materials,Resource Conservation and Recovery
Act (RCRA),and Air. We ask that you extend the permit period to allow
adequate review,and above all,require that Rayonier provide a detailed plan for
dismantling the mill.
Sincerely,
Frances G. Charles
Tribal Chair
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DARLENE SCHANFALD
3632 O'BRIEN ROAD
PORT ANGELES WA 98632
12 FEBRUARY'1997
FrEFM
121997
PLANNING DEPARTMENT
CITY OF PORT ANGELES
P O BOX 11 SO PORT ANGELES
PORT ANGELES WA 98362 PLANNING DEPARTMENT
FAX: 360-417-4542
Aare Sue
RE: RAYONIER DISMANTLING OF RAYONIER PORT ANGELES MILL
EIS AND SHORELINE. APPLICATION
Following are my continents on these two documents for the public record.
ENVIRONMENTAL CHECKLIST
ENVIRONMENT
Earth_ 1 F b W. Should other factors than storm water be discussed re: sod erosion?
Water. 3A.3: This is an inaccurate response. Dredge material is and will cond"to be
removed from the site. They have been hauling it and will haul more to their Mt Pleasant
landfill, at least.
3A.6: During demolition and cleanup, discharge into surface waters could very well
increase. Mone discussion n of this is necessary.
3.C.1: Is there other water runoff fnxn the site?
2: Can "Wr waste materials actually be collected? If not realisticaliy, more
c.-onsideration of this is necessary.
Animals. S.A. Mammals should inCwde Seal and river
5-C: The entre region is part of a so"cant migration routel
Environ ontal Health.
7A. The question was not answered. The envirorunnentai health hazards have not bean
listed. IS vital they do so.
1.A.2: Measures to reduce/control environmental health hazards should be proposed
and in dot". The plant is surrounded by open waters and residential sites,as well as
recreational use. Protection of these is necessary-
Noise. 7.8.1: Question unanswered. The question asks about area noise during the projea not
after.
Z: "Short term" is approximately 2 years! This is"bng term to neigl&ors1
Note that no hours are listed.so they can operate 24 hpcl This should not be
allowed. Hours of operation for dismantling and cleanup is important to the well-being of the
surrnurn"eorr~lty. Restricted hours are necessary.
7.8.3: This is why remarks under 2 is necessary.
Light&Glare. This may be knportant depending an dem hours because demo equipnnent could
have lighting more of an impact to the surrounding community.
RecreBLion. 12.A: Recreation is constant in the irmudiate areal Hikers. Water craft.
A trail is funded and will be developed daring the site demolition. Why has Rayonier failed to
mention this, to which they agreed?
51*)RELiNE SUBSTANTIAL DEVELOPMENT. ETC.
FACWG PACE: 9.IX. Public.access wig be allowed by a hike/bike trad.
Page 1: para. 2,fine 3: "flushed and cleaned." Fluslied to where,and how cleaned. The
aonvemnity rneeds a better explanation of the process.
Remarks on paragraphs 3 & 4 withheld, assuming this will be covered in future per rgt
appkcatiom which they need to be.
1. Disrmntkng Areas
A. Area 1-secondary treatment: consWeration of the retairanent of the secondary
tmatnrent plant should be considered.
B. Area 2-Primary Treatment_ As above
N. Asbestos
Rayonier in the past has placed asbestos in their landhils. This was not to be allowed. It
exist be made dear to Rayoraer that there is to be proper disposal of asbestos and that it is not
to go to their landfill, which is in a residential area.
MI. Lead. Same as w/Asbestos.
IV. Hazardous Materials. Same as w/11& III. Materials. Igoe dioxins and furans, known to be
the most hazardous an existence,have received variances and exemptions and then desgnsted as
"wood waste" over the years, and continually placed in their landfills which are in residential
antes. This outrageous practice must not be allowed to continue through the period of dmrmktian
and closure.
V. Owner's Responsibility. 0, Ime 1: "or"in this Case needs to mean as well as for above HV
to be satisfied.
�—^'' rkr� ienfald
February 9, 1997
rF
City Planning Department 1997
City of Port Angeles
321 East 5th Street °W
... .......
Port Angeles, WA 98362
RE: Shoreline Management Permit to permit Demolition of Existing Pulp Mill Facility
In granting this permit, I would request that sensitivity be shown to neighboring residents of the
mill facility regarding hours of operation during any demolition process. Surely operation
throughout the night should not be necessary.
Further, when the time is appropriate, consideration should be given to changing the zoning from
Heavy Industrial to something more compatible with existing residential neighborhoods that
surround the current mill area
Sincerely,
Chris Thomas
1836 Harborcrest
Port Angeles, WA 98362
Mrs.R.M.Cockrill
494 Marsden Rd
Port Angeles WA 98362-9327
February 4, 1997
City Of Port Angeles Planning Department FB - 407
SEPA Official
P.O.Box 1150 PORT ANGELES
Port Angeles, Washington 98362 PLANNINGDEPARTMENT
RE: Rayonier Demolition Permit request
SEPA Checklist comments
ENVIRONMENT #3 Water #4 ) & 6)
pages 4 &5 At present, Rayonier collects leacheate from it ' s Mount
Pleasant Shotwell Landfill site and disposes of it at the mill' s
secondary treatment plant. After closure of the mill, will this
continue? If, (once) the secondary is shutdown or demolished,
will the city be expected to run this material through the Port
Angeles sewage treatment plant?
page 8 #8 Land and Shoreline Use item J. Does this question speak
to residences or to employees? 365 workers will be displaced.
page 9 #12 Recreation A. & possibly B. The Waterfront trail
adjoins this site to the west and should be listed. What effect
will this have on the eastward progression of the trail? Seems
there was a picture and article in the Daily News recently with
Senator Patty Murray and Human Resources Manager Madison about
cooperative efforts to extent the trail.
page 9 #13 Historical & etc. Item C. answer- a reference to
"Phase 1" , Under SEPA guidelines it is my understanding that the
project must be considered "IN TOTAL" . If this is accurate,
what assurances does the City of Port Angeles have that this
projecifleft to "Phasing" will not at some future date be a loop-
hole for the Company to exercise and leave the city or federal
EPA to cleanup?
Total review and disclosure at project inception orsome legal
means to bind the owner for future "Phasing' .
Cockrill page 1 0 f'Z
page 2 Cockrill comments
page 10 # 14 TRansportation items F. & G.
Peak hours and loads per day of heavy truck loads should be
listed. Will this material. be on city streets during daylight
or night time hours? What impacts will these heavy hauls have
on the lower portion of Ennis street? How long will materials be
stored on site after demolishion?
page 10- #15 Public Services Item B.
Are there impacts to the Public Works Dept. road budget?
page 11 # 16 Utilities item A.
reference back to comments on environment on pages 4 and 5.
What are the impacts to the city sewer system treatment plant
relative to landfill leacheate disposal?
page 12 #17 Economics item D.
365 people will be without work.
Items E.F. G.
Where will this material be disposed of? How long will it
sit on site after demolision? And again, where will the Shotwell
Landfill leacheate collection be disposed of?
page 12 Non-Specific actions Item D.and E.
This project does have some potential implications for the Water-
front Trail extention to the east and potential of the downtown
waterfront as a whole. The applicant (owner) as a good faith
cou I d
gesture,^assure the extention of the trail to the east through
the site.
Shoreline Application
Owner/ applicant states responsiblilty for removal from site of
properly enclosed hazard waste.. materials. Where and when will
these materials be disposed of? This is a concern to all citizens.
It should be done without requests for variances from local
or state laws and codes.
Respectfully submitted,
Rosemary Cockri
FEB - .7 1991
PORT ANGELES
PLANNING OEP,�WWRIT
February6, 1997
Mr. Bradley J. Collins
Planning Director, City of Port Angeles
P.O. Box 1150 .
Port Angeles, WA 98362
re: public comment on Rayonier's environmental checklist for SERA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demo]ition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
mo
PLANNING OEP TMENT
February:6,1997 .
Mr. Bradley J. Collins
Planning.Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist"for,SEPA_permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies'to require recognition of those trail plans in
any permits issued for proposed demolition/clew up of the mill site property.
Documentation for extension of the_Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund- :
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
FEB
DEPA M
PORT
PLANNING -
February.6, 1997
Mr.Bradley J. Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA-98362
re: public comment on Rayonier's environmental checklist for SEPA permit- .
Mr. Collins:
It has been brought to my attention that in-their application for a.permit to dismantle the Ray
onier Mill,the company totally ignored the existing plans for a recreationalhi*portation.use .
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property:
Documentation for extension of the Waterfront Trail exists in the County.Comprehensive'plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive-Plan. Federal fund- .
mg was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the.mill property-
-Sincerely,
'7kox-
IX,
�
7. 1997
PORT ANGELES
PLANNING D=P,;aTP,-al
February 6' 1997.
Mr. Bradley J. Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA-98362
re: public comment.on Rayonier's environmental checklist for SEPA permit
W. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans fora recreational/transportation use
trail through the property. I encourage all agencies to require.recognition of those.trail plans in
any permits issued for proposed demolitionklean upof the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing
unding was awarded to the City.through ISTEA Enhancements last year for:planning and.construc-'.
tion of the route through the mill property.
Sincerely,
s �s svc/L cL 900d
0/7_�4 rn �/e_ Gd �vf tom T
c, fa � tom. n(, S717,/2
��- 1) / 5
FEB 10 i,99►T
PORT ANuELES
PLANNING DEPARTMENT
February 6, 1997
Mr. Bradley J. Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincere] ,
FEB.d l .1997
Ptd
February 6 199
Mr.Bradley I Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA98362
re: comment.on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company_totally ignored the existing plans for a recreational/transportation use
trail through the property: I encourage all agencies to.require-recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive.Plan and-the Parks and Recreation Comprehensive.Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year.for planning and construc-
tion of the route.through the mill property.
Sincerely,
G�
D ej � Odf
•fill.
FIX A 1 1997 lia
PLANNING
ANG ES TM
.. _ ENT
Tbruary6;1997.
Mr. Bradley'I Collins
Planning Director;City-of-Port Angeles
P.O. Box 1150
Port Angeles,.WA 98362
re: public comment on Rayoniei's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a.permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreatiorial/transportatiori use
trail through the property. I encourage all agencies to.require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site.property.:
Documentation for extension of the Waterfront Trail-exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive"Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning,and construc-
tion of the route through the mill property.
Sincerely,
v �; 7�
G07
FEB 1 01997
PORT ANGELES
PLANNING DEPOTMENT
February 6, 1997
Mr. Bradley J. Collins
Planning Director, City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
:FEB 4-219971
" . 77i!1i
"
February 6,1997 :
Mr. Bradley.J..Collins
Planning Director,.City of Port Angeles
P.O. Box 1150.
Port Angeles,WA-98362 .
re: public comment on Rayonier's.environmental:checklist for..SEPA permit
Mr. Collins:
It has been brought.to my attention that in their application for a.permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for.a-recreationa/ftnsportation use
trail through the property. I encourage all agencies-to require recognition of those trail plans,in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan 'Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
lilt
tion of the route through the mill property.
Sincerely,
4 V7
L; FEB 1 21997 :
February 6, 1997
Mr.Bradley I Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the-existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, �^
I
FEB 1 21997 �.
PORT ANGELES
PLAINNING DEP.-RTMENT
February 611997-
Mr.
997.Mr. Bradley J. Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
r •
FEB 1 21997
PORT ANGELES
PLAN-NINE O;-Pr,3Tt0ENT
February 6, 1997.
Mr.Bradley I Collins
Planning Director,City of Porf Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transpo Cation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan Federal fimd-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
:`� . .
FEB I '2 07. ,
,- cJ
— _ t PLANININ �_e, TTtriE�T s '
" •; ' . . - 6' 1997.
February ,
Mr, Bradley I Collins
Planning Director,.City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray
onier Mill,the company totally ignored therexisting plans for a recreational/transportation 'use .
trail through the property. ..I encourage all agencies to require recognition of those trail plans in
any*permits issued.for proposed demolition/clean up.of the mill site property.
Documentation for extension,of the Waterfront Trail.exists is the:County Comprehensive plan;
the-City Comprehensive Plan and the Parks and Recreation Compehensive.Plan: :,Federal fiord-
ing was awarded-to the City through ISTEA Enhancements last year for planning and construe=
tion of the route.through the mill pioperty.
Sincerely,
� -� � • _ tom. •
•
J FEB -1:.Z 1997
PORT ANGELES
PLANNING
-DEPARTMENT ..
_ February 6, 1997.
Mr.Bradley J: Collins
Planning Director,.City of Port Angeles.
..P.O.Box 1150
Port Angeles,WA 98362 J
re: public comment on Rayoniee r,environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the:existing plans for a trecreationaUtransportation use .
trail through the properly. :I encourage all agencies`to require recognition of those trail.plans in
any permits issued for proposed demolitionfclean up.of the mill site property.
Documentation for extension of the Waterfront Trail exists in the:County Comprehensive plan, -
the City Comprehensive plan and the Parks and Recreation Comprehensive.Plan: ,Federal fund
ing was awarded to the;City through ISTEA Enhancements last year for planning and construe-
tion of the route through the mill property.
Sincerely,
. - 9.• _ - W, - .. .. -
EB 1`2,1997
PORT AN
DT
PiAP,s�'itG O P`-_M-ENT .
February 6; 1997. _
Mr.Bradley I Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayoniees environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray:
onier Mill,the company totally ignored the existing plans for a'recreationaUtransportation use .
trail through the property. .I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean uP of the trill site property
Documentation for extension of the Waterfront Trail.exists:in the.County Comprehensive plan,
the"City Comprehensive Plan and the Parks and Recreation Comprehensive.Plan:-Federal fimd
ing was awarded to the:City through ISTEA Enhancements last year for planning and construc-
tion of the route.through the mill property.
Sincerely, -
1_9
: U ]' FEB' i 2 (997
1
PORI ANGELES
PI ANN1NG'DEPRRTNIENT
February.
Mr.Bradley I Collins
Planning Director;City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98361 .
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the,existing plans for a recreationaJAunsportation use
trail through the property. I encourage all agencies to require recognition,of those trail plans in
any permits issued for proposed demolition/clean.up of the mill site property.
Documentation for extension of the Waterfront Trail.exists in the County Comprehensive plan,
the City Comprehensive Plan and-the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through"ISTEA Enhancements last year for.planning and construe-'
tion of the route through the mill property.
Sincerely,
1-
:
FEB'.-T-2 109TI?,
PFrII# D irrILES
PL��!ti;Pau Gcr:nrtvTNT `
Mr. Bradley I Collins
Planning Director,City of Port Angeles
P.O. Box 1.150
Port Angeles,WA 98362
re: public comment on Rayonier's.environmental checklist for SEPA permit :
Mr. Collins:
It has been brought to my.attention that in their application for a permit to dismantle the.Ray-
onier Mill,the company totally ignored the existing plans for a recreatiom transportation use
trail through the property. .I encourage all agencies to require recognition of those trail plans in. . .
any permits issued for proposed.demolition/clean up of the mill site property: `
-Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for,planning and construc-
tion of the route through the mill:-property
Sincere _.
w- _
l ., FEB I 21997
PORT APc-3�_i tS
PLAi�Ie'W'G.� Pr,4T.h Er,T
February 6, 1997_ `
Mr,Bradley I Collins ..
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit_
Mr: Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the_existing plans for a recreational/transportation use
trail through the property. .I encourage allagencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan: .Federal fund-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, -
F 2,`I9§T
PORT AM,- LE 4 "
PCANN! JfF a r
:February 6,- 1997
Mr.Bradley I Collins
Planning Director,City of Port Angeles. -
P.O. Box 1150
Port Angeles,WA 98362. .
re: public comment on Rayonier's environmental checklist for SEPA permit:.
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company.totally ignored the existing plans for recreational/transportation use.
trail through the property. '.,I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property,
Documentation for extension of the Waterfront Trail.exists in the County Comprehensive plan;
the City Comprehensive Plan and the Parks and Recreation Comprehensive.Plan: ,Federal fimd-
ing was awarded to the-City through ISTEA Enhancements last-year for planning and.construc-
tion of the route.through the mill property•.
Sincerely,
solf0U.
�i
FEB. i 21997:
PORI �;Ia•J!o
February 6, 1997.
Mr. Bradley I Collins
Planning Director,City of Port Angeles. _
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the.County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Si erely, -
FEB- 121997 i' 3
PORT ANGELES .,
PLANNING DEPART.ENT
February 6, 1997
Mr. Bradley I Collins
Planning Director,City of Port Angeles.
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the.existing plans for a recreational/ ansportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fimd-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, -
FEB 1 21997 '
February 69 1997,
Mr. Bradley I Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles;WA 98362
re: public.comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the.existing'plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those.trailplans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan: .Federal fund-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, -
IL
FEB 1 21997
PORT ANGELES ' -
PLANNING DEP;',RTMENT
February 6; 1997:
Mr. Bradley I Collins
Planning Director,City of Port Angeles.
P.O. Box 1150
Port Angeles;WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
Mail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
I
FEB 121997.. . :.
PLANNING D�oEIES
• L4Tf✓;EP;T
February 6; 1997.
Mr.Bradley I Collins
Planning Director,City of Port Angeles.
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for,a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, .
=rr ,B 1 21997
Nolo ANGELES
INN'�NG 0EFARTMENT a
February 601997-
W.Bradley J. Collins
Planning Director,City of Port Angeles.
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist foi SEPA permit
Mr. Collins:
It has been brought to my attention that in their application fora permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fimd-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construe-
tion of the route through the mill property.
Sincerely,
FEB 1 21997 ll
PLANNI G DEPARTMENT
February 6, 1997
Mr. Bradley J. Collins
Planning Director,City of Port Angeles.
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for,a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, _
F� 21997
PLANNING DEPERTrOENT
February 6. 1997
Mr.Bradley I Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit.
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,-
FEB 1 21997 li
PORT ANGELES
PLANNING DEPi;RTMFNT J
February 6; 1997
Mr.Bradley I Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
U
FEB. 1 .21997 _Li
PORT ANGELES F "
PLANNING DEPARTMENT
February 6; 1997.
Mr. Bradley J. Collins
Planning Director,City of Port Angeles.
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sinc rely, ,
E FEB 1 21981
.,^?T„r!uc!ES
p:; ,.. MFNT t
,,,,.... ,u int"r;,R P�„
February 6, 1997
Mr. Bradley J. Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
t
p
FEB 1 21997 I
P;;R T P
PL htir'F; IT
February 6, 1997
Mr.Bradley J. Collins
Planning Director,City of Port Angeles
P.O. Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
FEB 1 2199'T
February 6, 1997.
Mr. Bradley I Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely, Qp6j
D
FEB t 2197
PORT ANGELES
L PLANNING DEMIRTMENT-
February 6; 1997 .
Mr.Bradley J. Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans mi
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the.City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
FEB 121997
PORT ANGELES
PLANNING DEPARTMENT
February 6; 1997.
Mr.Bradley J. Collins
Planning Director,City of Port Angeles
P.O.Box 1150
Port Angeles,WA 98362
re: public comment on Rayonier's environmental checklist for SEPA permit
Mr. Collins:
It has been brought to my attention that in their application for a permit to dismantle the Ray-
onier Mill,the company totally ignored the existing plans for a recreational/transportation use
trail through the property. I encourage all agencies to require recognition of those trail plans in
any permits issued for proposed demolition/clean up of the mill site property.
Documentation for extension of the Waterfront Trail exists in the County Comprehensive plan,
the City Comprehensive Plan and the Parks and Recreation Comprehensive Plan. Federal fund-
ing was awarded to the_City through ISTEA Enhancements last year for planning and construc-
tion of the route through the mill property.
Sincerely,
01.
STATE OF WASHINGTON
l I d
DEPARTMENT OF ECOLOGY
P.D. Jiox 47976 a a►y►,wpJaV Myslifnglpn 90d/-777S a (360)407-6300
February 18, 1997
i
Mr. Brad Collins FEB 1 81997
SEPA Responsible Official
City of Port Angeles PORT MULES
PO Box 11$0 PUNNING DEPARTMENT
Port Angeles,WA 98362-1150
Dear Mr. Collins:
Thank you for the opportunity to comment during the prethreshold consultation to distrnantle all existing structures on
the site to ground level totaling an estimated S26,855 square feet(Rayonior Mill Demolition), located at 700 North
Ennis Street as proposed by Rayonier,Inc. We reviewed the environ=nerntal checklist and have the fol6wing
comments:
Hazardous Waste/HAZ:
Any wastes generated from operations at this.site that will designate as a dangerous waste must be managed and
disposed of according to all applicable regairernents in the state Dangerous Waste Regulations,Chapter 173-303
WAC.
Shareland !SHORE:
We concur with the applicant and City of Port Angeles on the proposed activity meeting the definition for substantial
development within shoreline jurisdiction. The shoreline location,project cost,and proposed alterations to the
exterior of structures all indicate the shoreline permit process as being required.
The shoreline permit process affords a venue for the applicant to work with the City and other interested parties
toa-ard agreement on design objectives for the site. We encourage the county to require the applicant to mako both
specific and general changes to Nie plan as proposed. The plan steads to provide greater detail on short term
operations.as described below. In designing and permitting the project,long term benefits to the urban shoreline
need to W envisioned.
Even if the applicant's future plans are unclear,the state in which tho site will be left is going to influence future
choices. After demolition,the site should be left in a manner that takes into account the policies and other provisions
of the Shoreline Management Act,its rules,and tho local shoreline ester program. Relevant sections of the Port
Angeles Master Program that will be especially helpfal to consult in drawing up the plans ane ENVIRONMENTAL
IMPACTS,INDUSTRIAL,LANDFILL,CLEARING&GRADING,and SHORELINE RESTORATION.
Short term steps should be identified toward a future use that is water-dependent or water oriented in nature. The
workplan included with the checklist includes ieenrs that appear certain to involve grading and clearing,although the
checklist suggests none will take place. Pursuant to policies of RCW 90.58 and the local master program,the
applicant's plan should include some additional information about where grading and/or filling will occur.
The site plan should include utilities such as stormwater drainage lines and whether these will be altered during
demolition. It should specify designated areas where replanting of native species vegeoition for erosion prevention
and habitat restoration is intended after the removal of existing structures. And the eityls goals for shoreline public
access also need to be considered and implemented as appropriate.
J
Mr. Brad Collins
Fabrbruml 18, 1997
hp 2
Solid WastelM.,
There is no discussion of the altimate disposal Me of the materials removed f von the mill site during dismantling.
Rayonicos attached Work Plan for Puler Mill niM nAWN says only;"06-site transport and disposal of am-
hazardous
mhazardous rubbish and non-salvageable material."(page 9,V.,-R) This should be addressed in more detail in the plan.
Toxic CleanunIMP:
Tho work plan for pulp mill disnuuttling provided by Rayonier briefly discusses removal of Asbestos material,lead
material,and hazardous materials. The plans also state that the Contractor is to provide a"detailed work plan".
Ecology should review dais detailed work pian prior to the start of work.
WedandsMT:
Based on the presence of wetlands, Ennis Creek,and the Strait of Juan deFuca,it may be necessary to install an
erosion control system to prevent sedimentation from reaching those water bodies. In addition,the wetlands should
be clearly identified and protected with appropriate fencing to onsure that they aro not degraded through the
inadvertent operation of construction equipment or the temporary storage of materials during tho demolition protons.
If you have any questions regau WS these comments,please call the appropriate program staff'listed below.
Si ly,
rtes(ink
Assistant to the Regional Director
(360)407.6309
CQ:alw(97-0800)
cc: Abbe White,SWRO
Chuck Matthews,SWRO/SWS-(360)407-6383
Jeffm Stewart,SWRO/SHORE-(360)407-6521
Leon Wilhelm,SNX%04 AZ-360)407-6362
Mark Bentley,SWRO/WET-(360)407-7269
Rebecca Lawson,SWROITCP-(360)407-6255
• w� �y
STATE OF WASHINGTON
DEPARTMENT OF FISH AND WILDLIFE
48 Devonshire Road•Montesano, Washington 9856&9618•(360)249-4628
February 7, 1997
1
FEB 1 81997
City of Port Angeles PORT ANGELES�
PLANNING D_.:.RTh EMT
ATTENTION: Sue Roberds
321 East Fifth Street
Port Angeles, Washington 98362
SUBJECT: Shoreline Management Permit Proposal-Demolish Pulp Mill-Rayonier Inc.,
Proponent-Port Angeles,Tributary to Strait of Juan de Fuca,Section 02,
Township 30 North,Range 06 West,Clallam County,WRIA 18.MARI
Dear Ms. Roberds:
The Washington Department of Fish and Wildlife(WDFW)has reviewed the above-referenced
proposal received on January 27, 1997.
It appears from the general description of the project,that a Hydraulic Project Approval (HPA;
RCW 75.20.100, WAC 220-110)to be issued by WDFW,will be required for the project.
There is,however, insufficient project detail to determine specific conditions to be placed on the
project at this stage of the project development. We encourage the applicant to seek involvement
from WDFW on resource needs and typical project requirements to insure proper protection of
fish life as you proceed with project design and development. Early involvement with WDFW
will facilitate later processing the HPA. Once final design plans are available,please have the
applicant submit a completed Joint Aquatic Resource Permits Application(DARPA)for an HPA,
including complete plans and specifications for the proper protection of fish life,to WDFW for
review.
The plans and specifications should be developed relative to Mean Higher High Water(1V HHW),
(Datum,Mean Lower Low Water [MLLW] =0.0 feet). The drawings should accurately depict
existing conditions and should include plan and cross-sectional views of the proposed project,a
vicinity map of the project area,and accurate directions to the project site. The location of all
prominent natural features and manmade improvements on the bank and beach in the immediate
vicinity of the project area should be accurately represented. In addition,to aid us in locating the
project site,a photograph should be supplied.
Sue Roberds
February 7, 1997
Page 2
JARPA forms are available from WDFW or most local government permit desks. You should
allow 45 days from the receipt of a complete application and completion of the SEPA process for
processing of the HPA.
For the protection of food fish and shellfish resources, WDFW does not generally allow work
below the ordinary high water line(OHWL)in Port Angeles to take place from March 15
through June 14 of any year. Project proposals,however,will be evaluated on a case by case
basis.
We are concerned about several aspects of the proposal. First,WAC 220-110-270(5),adopted
in November of 1994,states: "No debris or deleterious material shall be disposed of or
abandoned waterward of the ordinary high water line...". The proposal indicates that work will
not include any removal of structures below the high tide mark,or removal of the dock. We do
not want structures, including sewage outfalls,bulkheads and riprap,pilings that contain creosote
and other toxic wood treatments,decomposing bark and wood debris from log storage,and
overwater structures including docks that may receive no subsequent maintenance,to be
abandoned waterward of OHWL. There are far too many in-water structures and piles of debris
abandoned prior to 1994 in Port Angeles already that cover up and contaminate once productive
fish habitat. This proposal needs to include removal of all unnatural materials from the beach
and bed of waters of the state that do not have an identified use associated with the future of the
site. This specifically includes all debris,such as rotted or useless piling,wood waste, stray
concrete,asphalt,or other rubble from bulkheads,any unnatural materials that have fallen into
the water over the years,or any structures or portions of structures that will likely fall into the
water in the near future.
We also want the City to know that we will require any future developer of the site to remove
structures not incorporated into the development, and to mitigate for any expansion of the facility
beyond the present footprint.
The environmental checklist fails to note that both Ennis Creek,which runs through the site,and
the shoreline and waters of Port Angeles,are migration,rearing,and feeding areas for Pacific
Salmon. Ennis Creek is additionally a salmon spawning stream and home to at least 4 species of
native salmonids. The estuary of this critical habitat was consumed long ago by this
development,to the subsequent detriment of the salmon resource. This proposal should include
removal of unnecessary structures in or near the creek.
There are insufficient details of how debris is to be prevented from entering the water during
demolition in the proposal. Employment of best management practices to prevent debris from
entering the water is essential to preventing impacts to fish life. If in-water measures are
Sue Roberds
February 7, 1997
Page 3
necessary to contain debris,demolition will likely be subject to timing restrictions,from March
15 through June 14 to protect juvenile salmonids.
The City should consider alternate uses of this property,other that heavy industrial. This site is
anomalously located for a heavy industry,all the rest of which is located at the west end of the
bay. It would make a beautiful park or natural area with public access, located at the east end of
the Waterfront Trail,and grants are likely available for purchase with local matching funds.
Removal of all facilities and restoration of the shoreline would qualify the site for mitigation
banking,which is sorely needed by prospective developers. It also has historical significance to
Native Americans,and may attract grants for restoration of the State Registered Klallam Indian
Village Site. Some of it away from the shoreline could be used for expansion of sewage
treatment plant facilities. All of these would seem to be higher and more beneficial uses of the
site than replacing it with another heavy industry,and would significantly benefit fish and
wildlife over the industrial alternative.
We appreciate your cooperation in our efforts to protect,perpetuate,and manage the fish
resources of the State of Washington.
If you have any questions please call me at(360)249-1217.
Sincerely,
Robert Burkle
Area Habitat Biologist
Habitat Program
RB:rb:12
cc: Dave Gufler
Tim Rymer
Brian Jones,Rayonier Inc, 700 N. Ennis,Port Angeles,WA 98362
Mike McHenry,Lower Elwha Klallam Tribe
Feb-14-97 10:22A STRAITS DISTRIS"1 3bu 4b2 49GC r.uc
Aid
WASHINGTON STATE DEPARTMENTOF
Comm
Natural Resources ER M BELCHER
. _.__.._. . ...._._ Commissioner of ArWlc Lands
KALEEN COTnNGHAM
sunpnervisor
Feb. loth, 1997 a V
City of Port Angeles FB 14 W7
321 East 5th
PO Box 1150 PORT ANGELES
Port Angeles WA 98362 PLANNING DEPARTMENT
Attn: Brad Collins, Planning Director
Re: Dismantling of Rayonier-Port Angeles Mill
Dear Mr. Collins,
The DNR manages two aquatic land leases associated directly with the Rayonier mill site.
Rayonier has several other aquatic leases located throughout the Port Angeles harbor area.
DNB's concerns throughout demolition will be to assure Rayonier satisfies all conditions of their
lease agreement with the Dept. Rayonier Will also need to assure environmental protection from
possible contaminants to surrounding DNR managed aquatic lands from demolition operations.
We have an appointment today with Rayonier officials on site to begin discussions on steps they
will need to accomplish to assure satisfactory environmental assessment and cleanup related to
leases and aquatic lands managed by DNR-
Thank
NRThank you for the opportunity to comment on this proposal. We are interested and concerned
regarding the proceedings of this,please keep us informed.
Thank You,
Wayne Fitzwater '4S-j" jV1 3
Aquatic Land Manager
Olympic Region
For. Tom Robinson
Olympic Region Manager
cc: Hurd
Miller
OLYMPIC REGION 1 411 TILUCUM tN 1 FORKS WA 98331.9797 1 FAX.(360)314-5406 1 TEL.•(360)374-6131
0.4w» Equal opportunity/Affirmative Action Employer eeevCLEDPANN
STATE Of WASHINGTON
DEPARTMENT OF ECOLOGY
P.O. Jbx 4M3 • 01rn^ tvarhingtan WOr-m3 • (360)W.6300
Pon " Nodi r
Ms.Sue Roberts '
fJ
City of Port Angeles Planning Department FEB 1 4 1997 U
Dear Ms.Roberts: PLANNING DEPARTMENT
Re: Department of Ecology's SF.PA Comments for Rayonier Mill Demolition
Below are comments obtained from regional staff representing appropriate programs in
Ecology's Southwest Regional Office. Item may be additional eommante B+om the Industrial
Suction at Ecology how4uarturs. Mike:Palko should be contacted for threw. He cern be r,achcd
at telephone(360)407-6906.
Wetlands
Based on the presence of wetlands,Finis Creek,and the Strait of Juan deFuca,it may be
necessary to install an erosion control system to prevent sedimentation from reaching those
water bodies;. In addition,the wetlands should be clearly identified and protected with
appropriate fencing to ensure that they we not degraded througb the inadvertent operation of
construction equipment or the temporary storage of materials during the demolition process.
Hazardous waste and Tacrine Redaction Program.
Any wastou yuncratW from operations at this site that will designate as a dangerous waste must
tx:managod and disposed of according to all applicable requirements in the state Dangerous
Waste Regulations,Chapter 173-303 WAC.
.Snlld nrvrte and Finamcial Aisistarce Programs:
Them is no discussion of the ultimate disposal fate of the materials removed from the mill site
during dismantling. Rayoniee''s attached Work Plan for Pulp Mill Dismantling says only;"Off-
site transport and disposal of nwehsra*)us rubbish and nonsalvageable material."(page 6;
V-X.) This should be addressed in more detail in the plan.
Shorelamdr:
We concur with the applicant and City of fort Angeles on the proposed activity meeting the
definition for substantial development within shoreline jurisdiction. The shoreline location,
project cost, and prrporA alterations to the exterior of structures all indicate the shoreline
permit process as boing mquirod.
The shoreline permit process affords a venue lbr the applicant to work with the City and other
interested parties toward agreement on design objectives for the site.We encourage the county to
`�"" 'k
require the applicant to make both specific and general changes to ffio plan as proposed. The
plan needs w vide ur detail on short term as desorlbcd below. In designing
P P� 13r'� operations,
and permitting the project,long terra benefits to the urban shorclinc need to be envisioned.
Even if the applicant's future pleas at tmcieac,the state in which the site will be left is going tv
influence future choices. Altar demolition,the site should be left in a manner that takes into
account the policies and other provisions of the Shoreline Management Act,its rules,and the
local shoreline master program. Relevant sections of the Port Angeles Master Program that will
be especially helpful to consult m drawing up the plans are ENVIRONMENTAL IMPAMS,
INDUSTRIAL, LANDFILL,CLEARING&GRADING,and SHORELINE RESTORATION.
Short term steps should be ide ntifled toward a firture use that is water-depaidari ar water
uriesctcd in nature. Tice workplan included with the checklist includes item that appear certain
to involve grading and clearing,although the checklist suggests now will take place. Pursuant
to policies of RCW 90.58 and the local master program,the applicant`s plan should include sane
additional information about whom grading and/or filling will occur.
The sito plan should include utilities such as stormwater drainage pines and whether then will be
altered during demolition.It should specify designated areas where replanting of native species
vegetation for erosion prevention and habitat restoration is Intended after the removal of existing
structural. Aeul thus city's goals fur shumlinc public avom also need tv be wmsidurod and
implemented as appropriate.
1 am still working with the Water Quality and Toxics Cleanup programs for their comments,but
have decided to fax these to you now in hopes they will be usdbl in your meeting. I will send
another fax with the additional comments as soon as they ars received.
Sincerely,
e
Chuck Matthews
Solid Waste Specialist
Southwest Regional Office
(360)407-6383
STATE Of WASHINGTON FEB 41M
DEPARTMENT OF ECOLOGY PORT ANGELES
P.O. Bo:4m3 • olrttrpk waddngron!0504-m3 • t�o14o� PLANNING DEPhRTMENT
Ms.Sue Roberts
City ofPort Angeles Planning Department
Below is an additional comment from Ecology's Southwest Regional 0111ec. '111e appropriate staff perstnt
from the Water Quality Program is not available today,an l will give the docurnimt to her mid usk Utas slit
fu;wand comments as soon as possible. (Water quality concerns may be addressed in the lnduxtrial
Section's comments.)
Also,any questions regarding placement mutcrials in the Shotwell Landfill should be directed to Mr.Cris
Matthews. His telephone number is(360)407-6388.
Toxicx Cleanup Program: �
The work plan for pulp mill dismantling provided by Rayonier briefly discusses removal of
Asbestos material, lead material,and hazardous materials. The plan also states that the
Contractor is to provide a"detalled woric plan". Ecology should review this detailed work plan
prior to the start of work.
Please call if 1 can be of further assistance,or contact Ecology's Environmental Review section at(360)
407-7448.
Sincerely,
Chuck Matthews
Solid Waste Specialist
Southwest Rcgionul Office
(360)407-6383
i" ,7.AT T.AM COUNTY
DEPARTMENT OF
CO DEVELOPMENT
DnzacrOR.BOB MARTIN' - --- - ——- - CLALLAMCovNrY COLm HOM
Buuan;oDmwoWFnmMARzffAL _ 223 EAsrFammSUM
ErNnzorMIMALHsALTHEImmoN PowrAmmm,WA 98362 3098
PLANNING Dr 4W0N/WATM QUALITY (360)417-2000,FAX(360)4173443
February 12, 1997
D
Mr. Donald SchwendimanFM1
Regional Counsel 4 W7 Ej
Rayonier
1800 International Blvd. #900 PLANNING DEP RtMEIVT
SeaTac,Washington 98188-4283
Dear Mr. Schwendiman:
Our meeting yesterday was helpful in developing an overall understanding of Ryonier's intentions
regarding the future use of the Shotwell landfill for disposal operations during and after mill closure.
Based on our discussion, it is our understanding that the plant will continue to operate in a normal
manner producing product until approximately March 1, 1997. During this period the plant will generate
waste for disposal at Shotwell that is"typical'in both quantity and composition to that historically
produced. We now further understand that after the mill ceases to produce a product,there will be an
indefinite period of shutdown during which the plant will continue to generate waste that is typical of
historical operation. This period was estimated as perhaps 6-8 weeks, and would allow waste materials
to clear the spent liquor tanks,sludge cells,and other components of the facility. At some point either
during or after shutdown, it is our understanding that you will complete and initiate a plan to dismantle
the facility. It is expected that once dismantling commences demolition debris will be produced which
Rayonier wishes to dispose at the Shotwell landfill. Finally,it is our understanding that once the existing
facility is dismantled to"ground level"(estimated to take 9-18 months)site investigation and remediation
will occur. Whether this remediation phase will generate waste which Rayonier will wish to dispose at the
Shotwell landfill, and if so,what these waste types may be,will not be known until detailed site
investigation is completed.
As we discussed,we will hereby extend our existing operating permit to remain in effect for the
remaining period of time during which the plant continues to produce product, and generates waste that
is typical in volume and compozition.pith that generated in the past and as described in the existing
permit. We are therefore extending the expiration date on this permit to March 1, 1997. We will expect
the reports required by that permit to be submitted by March 15, 1997.
We are willing to consider your request that the existing permit be extended even further to cover some,
as yet, undetermined shutdown period. During this period,the plant would continue to produce waste
that is equivalent in volume and composition to that historically produced. We are unwilling to allow an
open-ended extension. However,as I stated at our meeting,we will consider defining this shutdown
period in terms of plant components(hog fuel boiler,spent liquer tank,sludge cells, etc.) continuing to
generate wastes typical of normal operation, although we will need a*not-to-exceed"date(perhaps eight
weeks, or until May 1, 1997.) We will also require additional monitoring and reporting requirements
during any such extension. We would like it firmly understood that the permit will terminate earlier if, in
our judgment,the wastestream changes significantly. So that there is no misunderstanding about this
point,we will consider significant increases in volume,changes in composition of the waste,or changes
in the sources of the waste within the plant to constitute a significant change in the wastestream. I am
Donald Schwendiman
February 12, 1997
Page 2
perhaps belaboring this point because we heard it suggested that as the plant is being shut down,some.
cleanup will be initiated, and the hog fuel boiler may continue to operate on cleanup material. If or when
this occurs, it is our opinion that this would trigger a new waste-generating operation which must be
covered by a new waste disposal permit. We are wilting to meet with Rayonier to further discuss these
points.
Concerning the possibility of a new permit covering disposal during dismantling and site restoration, our
letters of January 27 and January 29, 1997 outline the information we need to act on such a permit
request. As we stated,once we have this information we can better judge the SEPA review appropriate
for this permit decision. As you know,from my comments at our meeting, I believe there are a number
of environmental issues that have not been addressed by the previous EIS,which was based on the
plant operating for another 75 years. The plant closure,demolition, and site restoration has, in our
judgment, environmental consequences that were simply not discussed in the prior EIS. Once we have
the information requested in our prior letters,we will be in a position to judge the appropriate actions
necessary for SEPA compliance.
Finally,we raised the issue of the status of your conditional use permit and continuing status of the
landfill as a pre-existing use under our zoning ordinance. We would appreciate your response to this
matter. Specifically,does your intended use of the landfill for demolition debris, and possibly disposal of
non-hazardous waste generated during site remediation,constitute an increase in the non-conformity of
the land use? As you know,we think this question may be linked partially to how thoroughly and reliably
the disposal activity is regulated and monitored.
If you have any questions regarding dont hesitate to contact me at 360-417-2323, or Andy Brastad at
360-417-2415.
Sincerely,
Bob Martin
Director
C. Correspondence file
Andy Brastad, Environmental Health Director
Chris Melly, Deputy Prosecutor
Brad Com,tort Angeles Planning Director
Andy Meyer, Clallam County Planning Director
Chris Mathews, Department of Ecology
Brian Jones, Rayonier
Darlene Schanfeld
Rosemary Cockrill
�OF VORTgN
CITY OF PORT ANGELES-PUBLIC WORKS DEPARTMENT
1 ! MEMORANDUM
`Maintaining and Buirdit a Better Community'
TO: Brad Collins, Planning Department Director �
FROM: Steve Hursh, Electrical Engineering Manager
FEB 12 X97
PORT ANGELES
DATE: February 11, 1997 PLANNING DEPARTMENT
SUBJECT: Rayonier Demolition Permit
We do not have any objections to the demolition permit for the Rayonier Mill. However, we do
have the following comments:
1. Rayonier owns and maintains the 69,000 volt overhead transmission line that runs from
the Bonneville Power Administration substation near Peninsula College and winds
through the City to the mill. What are they going to do with the transmission line? If a
car runs into one of their transmission poles, who is going to repair/replace the pole?
Rayonier should be required to inspect their transmission line, I recommend at least
every other year, and maintain their facilities as necessary.
2. We have an existing distribution powerline on their property that serves the City of Port
Angeles secondary sewer treatment plant. Our underground powerline runs west from
the secondary treatment plant to their chip pile and an overhead powedine runs from the
chip pile along their access road to Caroline Street. The demolition contractor shall call
for underground locates at 1-800-4245555 prior to any excavation and they shall
maintain at least ten (10) feet clearance between their equipment and our overhead
powerline.
3. Rayonier has electrical equipment that probably contains polychlorinated biphenyl
(PCB), which is a hazardous material. Their equipment should be tested and disposed
of according to state and federal regulations. The area around the contaminated
equipment should also be tested and any contaminated material should be removed and
disposed of according to state and federal regulations.
The state regulations allow a higher cleanup level (10 ppm) on an industrial site.
However, this would restrict future uses of the site i.e. zoning changes, anything dealing
with food, etc. A cleanup level of 1 ppm would allow unrestricted use of the property.
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interoffice FEB 12
M E M O R A N D U M ^
PLANNING FA91MEW
to: Brad Collins,Planning Director
from: Scott Brodhun
subject: Comments Regarding Rayonier Demolition Proposal
date: February 12, 1997
Brad,
The Port Angeles Parks & Recreation Department has a vested interest in the
proposal to dismantle the Rayonier Mill. Departmental concerns are relative
to transportation and recreation issues. In 1980 the City adopted the Port
Angeles Urban Waterfront Trail Plan, and subsequent to that a trail extension
project known as Centennial Trail. The City has pursued development of the
Centennial Trail, involving development of the trail from Francis Street,
through Rayonier, to Morse Creek. In discussions with. Rayonier personnel
regarding development of the trail through the mill site, indications were that
a workable solution could be found. Based largely on that information the City
has procured in excess of $1,500,000 in grant funding, and has invested in
property acquisition necessary to construct the trail. Thus, in light of the
priority placed on trail development by the City of Port Angeles, it is
important that our concerns for recreation and transportation be noted during
the review of the proposed Rayonier Project.
Toward that end, I offer the following comments:
d The City has purchased property, outside the current city limits,
necessary to extend the Centennial Trail.
d The Port Angeles Urban Waterfront Trail Plan was adopted in 1980.
Subsequently, the Centennial Trail project has been identified in
a variety of documents, including but not limited to the TIP, CFP,
P.A. Comp. Plan, and the Parks and Rec. Five Year Plan.
V The City has procured in excess of 1.5 million dollars in grant
funds for development of the Centennial Trail.
d The City is in current negotiation for acquisition of property
necessary to develop the Centennial Trail.
d Development of the Centennial Trail is a key element in completion
of the Port Angeles Waterfront Trail, as well as the Olympic
Discovery Trail, each repeatedly rated in the top ten trail projects
state wide. Olympic Discovery Trail being a project of regional
significance.
�y
d The Centennial Trail has twice been identified as a top priority
transportation project in the region.
The Centennial Trial
remains a top five project statewide in the IAC
P ro
(trail category) and DNR (ALBA category) , and has been twice rated
the number one project.
d Development of the Port Angeles Trail continues to be listed as a
top priority project by the citizens of Port Angeles.
c! access th_rouah the ffAX=1er site �s essential to develeameat of �e
Centennial Trail.
In summary, any proposal regarding the Rayonier site has far reaching and
significant recreation and transportation impacts. Additionally, continued
development of the trail will result in another visible and viable amenity
assisting in Port Angeles becoming a tourism destination. Thus, the trail is
also an economic development project for the greater Port Angeles area.
I am available to discuss this as your convenience. Thank you for noting our
concerns.
�pF NVQ _
M EM: ORAN D U
M
ROUTS 'spot
9�pEPApT�� Building Dept. ❑
Planning Dept.
PLANNING DEPARTMENT RESPONSE Public Works ❑
City Manager ❑
DATE: February 3, 1997 D O
TO: Planning Department
AS W7
FROM: Dan McKeen, Fire Marshali—
NI G EPARMENr
T
RE: Shoreline Management Permit - SMA 97-02 �N
Rayonier
The Port Angeles Fire Department reviewed the project and has the
following comments.
1. The following permits will be required prior to any related
work during dismantling of the Rayonier site.
a. Welding and Cutting Permit
b. Removal/Abandonment of Above and Underground Storage
Tanks containing flammable, combustible liquids, and any
hazardous materials as defined by UFC.
2 . Fire Department requests weekly meetings as to the area
involved in dismantling.
3 . Assure the water supply system which provides fire protection
is operational in each area during the dismantling process.
Each yard hydrant shall be unobstructed, available for use by
the Port Angeles Fire Department if needed.
4 . Provide information to the Port Angeles Fire Department as to
the removal of combustible debris from the Rayonier site
during demolition.
S. Provide a Hazardous Material Management Plan (HMMP) to the
Port Angeles Fire Department for the handling and removal of
hazardous materials along with a contingency plan for spills
and releases.
DM/cw
OF PORTA*
MEMORANDUM
To:
9F OEPAa�M� Building Dept. ❑
Planning Dept. ❑
PLANNING DEPARTMENT RESPONSE Public works ❑
DATE: February 3, 1997 L�
TO: Planning Department FEB - 5 W7
FROM: Dan McKeen, Fire Marshal PORT ANGELES
PLANNING DEPARTMENT
RE: Shoreline Management Permit - SMA 97-02
Rayonier
The Port Angeles Fire Department reviewed the project and has the
following comments.
1 . The following permits will be required prior to any related
work during dismantling of the Rayonier site.
a. Welding and Cutting Permit
b. Removal/Abandonment of Above and Underground Storage
Tanks containing flammable, combustible liquids, and any
hazardous materials as defined by UFC.
2 . Fire Department requests weekly meetings as to the area
involved in dismantling.
3 . Assure the water supply system which provides fire protection
is operational in each area during the dismantling process.
Each yard hydrant shall be unobstructed, available for use by
the Port Angeles Fire Department if needed.
4 . Provide information to the Port Angeles Fire Department as to
the removal of combustible debris from the Rayonier site
during demolition.
5. Provide a Hazardous Material Management Plan (HMMP) to the
Port Angeles Fire Department for the handling and removal of
hazardous materials along with a contingency plan for spills
and releases.
DM/cw
pp - ?g - - -
Rayonier Mill Closure/Hazardous Materials
Quantities and Use of Hazardous Materials
The Port Angeles Fire Department maintains background information
on chemicals at the Rayonier facility based on the annual SARA
Title III Tier-Two report. These are the chemicals or products that
are required by both Federal and State law to be reported. These
chemicals are used in the pulp bleaching process or in maintaining
the facility and its equipment. Examples are propane, lube oils,
gasoline and diesel. Some of the chemicals are used in the Rayonier
Lab for testing purposes. Below is a list taken from the February
29, 1996 Tier-Two report received by the Port Angeles Fire
Department.
Acetone
Aluminum Sulfate-Alum
Ammonia-Anhydrous
Ammonium Hydroxide
Ammonium Bisulfite
Boiler chemical -opti tyrol 4000 betz
Boiler chemical -betz 50705 polymer
Calcium Hydroxide (lime slurry)
Calcium Oxide (pebble lime)
Chlorine
Chlorine Dioxide
Corrogen - sodium sulfite
Defoamer-Associated
Defoamer-Foamaster (DF-150-L)
DefoamerV- Foamaster (DF-216-M)
Defoamer - secondary treatment (Fleetcol• 9167B)
Defoamer - secondary treatment (Fleetcol 9168)
Defoamer - secondary treatment (Fleetcol 9137)
Diesel Fuel
Deresinator ( Aquaquest 601)
Detac 5000 - Pitch dispersant
.Filter plant polymer (Calgon POL-E-Z 652)
Filter plant chemical (CATFLOC TL Polymer)
Gasoline - regular and unleaded
Greasd (various blends)
Hydrogen Peroxide <50%
1
Industrial Fuel Oil
Lube oil
Monamid 150 sheet softener
Oil, Turbine (various blends)
Parts washer solvents
Phosphoric Acid 52%
Polymer - S - 350
Polymer C -309
Polymer C -311
Propane
Reducer #54
Reducer #58
Sheet debonder - berocell 584-D
Sodium Chlorate
Sodium Hydroxide
Sodium Hypochlorite
Strip Treat - Pluronic
Sulfur
Sulfuric Acid
Sulfurous Acid
Surfactant - Tritonn - 101
Sulfur Dioxide
Clean-up and disposal laws and/or regulations
The following laws and/or regulations could apply to the Rayonier
facility closure.
♦ WAC 173-303 Dangerous Waste Regulations
This regulation has a section on facility closure plans. The
regulation outlines having a dismantling plan in place which
addresses the following areas:
• Safety
• Storage at the facility
• Transport of the dangerous waste (if the material is
classified as such)
• Hours of operation. (for the clean-up)
• Anticipated hazards during facility clean-up
• Dismantling procedures of piping, storage tanks
• Control of run-off
• Disposal of hazardous waste
• Asbestos's at the site - proper clean-up and disposal
2
1994 Uniform Fire Code Article 80 relationship to facility closure
♦ 1994 Uniform Fire Code
► Article 80 Hazardous Materials
8001.3 .1 Permittee shall apply for approval to close
storage, use or handling facilities at least 30
days prior to the termination of the storage, use
. or handling of hazardous materials. Such
application shall include any change or alteration
of the facility closure plan filed pursuant to
Section 8001.11. This 30-day period may be waived
by the chief if there are special circumstances
requiring such waiver. (Page 1-303)
8001.11 Facility Closure
8001.11.3 Plan. The permit holder or applicant shall submit a
plan to the department to terminate storage,
dispensing, handling or use of hazardous materials
at least 30 days prior to facility closure. The
plan shall demonstrate that hazardous materials
which were stored, dispensed, handled or used in
the facility have been transported, disposed of or
reused in a manner that eliminates the need for
further maintenance and any threat to public health
and safety. Such plan shall be submitted in
accordance with Section 8001.3 .1.
8001.5.2.3 Preparation. Provisions shall be made for
controlling and mitigating unauthorized
discharges.
8001.5.2.5 Responsibility for clean up. The person, firm, or
corporation responsible for an unauthorized
discharge shall institute and complete all
actions necessary to remedy the effects of such
unauthorized discharge, whether sudden or
gradual, at no cost to the jurisdiction. When
deemed necessary by the chief, clean up may -be
initiated by the fire department . or by an
3
authorized individual or firm. Costs associated
with such clean up shall be borne by the owner,
operator, or other person responsible for the
unauthorized discharge.
Washington State Department of Ecology
.The Washington State Department of Ecology has a person assigned to
the Rayonier facilitYclosure, Marc E. Crooks P.E. , Pulp & Paper
Mill Specialist. I received this information from Jim Oberlander,
Washington Department of Ecology Spill Response Coordinator and .
from Brian Jones, Environmental Superintendent, Rayonier facility.
A copy of his business card is attached.
4
9:
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o �
MEMORANDUM
ANNINd R � � O
n
January 24, 1997 AN 3 01997
V
TO: Public Works Department PLANNING CEPA
Fire Department
xght Department
FROM: Planning Department
SUBJ: SHORELINE MANAGEMENT PERMIT-SMA 97-02
RAYONIER
Attached hereto is an application for a shoreline management permit to allow the dismantling of the
Rayonier mill site. Please review the attached information and forward any general comments or
those you would recommend as conditions of approval to the Planning Department no later than
F b =a 6,A22. If you have any questions or require finther information,please don't hesitate to
contact the Planning Department at extension 4750.
Thank you.
Attachments
b6,4r E�p,. qhs No ce)oigcnom To TH5
P
�g
A
PORT OF PORT ANGELES
338 W. First St. (360)457-6527
R O. Box 1350 FAX(360)452-3959
Port Angeles,WA 98362-0251
February 12, 1997 D [� Q ED Wu
Mr. Brad Collins AICP FB
' 2
Planning Director PC IRT AM S
City of Port Angeles ParONINZ D!P,+?T1,1ENT ;
P.O. Box 1150
Port Angeles, WA 98362
RE: Request for Comments on Rayonier Mill Demolition Permits
Dear Brad:
In your letter dated Feb. 5, 1977 you informed the Port that the City had received
a permit application and environmental checklist submitted by Rayonier for the
mill closure and demolition. You asked for continents from the Port, as an
agency with expertise, on additional information that may be needed and
environmental impacts with which our agency is concerned.
First, I note the cover letter from Rayonier dated Jan. 16, 1997 states that the
permit applications do not include: (1)work below ground level, (2) any work in
the water below the high tide mark, or(3) removal of the dock, except structures
above the level of the decking. The Port's primary expertise and concern would
be with the in-water work and with the pier. Since apparently this work and
structure are to be the subject of future applications by Rayonier, I will reserve
comment on that aspect of the project until the appropriate time.
Secondly, I have a concern with the lack of information provided on page 11
under item 17, Economics. I believe everyone in the community perceives that
the primary impact resulting from the mill closure and dismantling is the
economic impact. There is no information under item 17 on the economic.
impacts. I believe there may be several pages that could be written, analyzing
the economic impacts created as a result of mill closure and dismantling.
Additional comments on information appearing in the environmental checklist
prepared by Rayonier include the following:
COMMISSIONERS: • Glenn Beckman • Dick Foster • Jack Waud
EXECUTIVE DIRECTOR: • Christine Anderson
• On page 5 under the question about whether the property is in the 100-year
floodplain, the answer is"No . My copy of the FIRM Flood Insurance Rate
Map shows some of the Rayonier property in Flood Zone VS.
• There is no information given about disposal of demolition waste. According
to the county's solid waste experts, suitable sites for disposal of demolition
waste is one of the greatest unmet needs in the county. N this condition still
exists, it would seem that impacts on existing solid waste disposal sites is a
subject that needs additional analysis.
I have one final observation. The environmental checklist format is designed
more for new and expanded development rather than for an action that reduces
improvements at a site. In attempting to answer the checidist questions for the
mill dismantling, the response is accurate in most instances. However, it leaves
me wanting more information. I believe there is considerably more
environmental analysis that could be provided if the applicant were to go beyond
the question and answer format of the environmental cheddist.
I hope these comments are useful and will assist the City as you proceed with
processing the Rayonier applications.
Sincerely,
enneth W. Sweeney, AICP
Planning and Environmental Manager
MEMORANDUM
Clallam County Department of Community Development
TO: Brad Collins,Planning Director D d
FROM: Tobi Maggi,Senior Planne FB ` 2 W7
SUBJ: SEPA Comments on Rayonier Mill Demolition Proposal
PORT ANGELES
DATE: February 12, 1997 PLANNING DEPARTMENT
The Clallam County Planning and Environmental Health Divisions have reviewed the SEPA cheddist,
shoreline permit application and work plan for the proposed dismantling of the Rayonier pulp mill and
have the following comments.
Rayonier has indicated that dismantling of the mill will occur in two phases;Phase I will consist of the
removal of above ground structures and Phase II apparently will be subgrade removal of facilities and
remediation. However,the current checklist and permit application appear to only discuss Phase I
issues. No mention regarding the timing of Phase 11 is made by Rayonier in the checklist or work plan.
In essence, agencies are being asked to review this proposal in a piecemeal method as opposed to one
overall,cumulative project. it would seem,according to WAC 197-11-0 l)(5)(d)(1i),that phased review is
not appropriate when such phasing avoids discission of cumulative impacts such as quantities of
materials generated by the total prated.
The applicant, in the environmental checklist,repeatedly refers to the NPDES permit presently existing
for the mill. The applicant has not outlined the provisions of that permit nor provided assurance that
stormwater can be accommodated by this existing permit. The applicant should provide verification from
the Department of Ecology that the current NPDES permit can indeed be utilized for the discharge of
stormwater from this site which may contain Increased sediments and contaminates associated with
demolishing the pulp mill which are not identified in the current NPDES permit. It should be imperative
that the applicant submit, and have approved,an engineered,drainage and erosion control plan as part
of the permit review process in view of the scope of the project and its proximity to the marine shoreline
and because it impacts shorelines of statewide significance and creates an opportunity for contaminants
associated with milling processes to enter surface water. Drainage facilities on the site presently may be
aftered by dismantling work,therefore,existing facilities may be rendered ineffective to protect surface
waters. On page 5, Section C(1)of the checklist,the applicant indicates that stormwater will be treated
on-site but does not describe that treatment. The drainage and erosion control plan should ensure that
all debris, overburden and other waste materials from demolition be stored and disposed of in such a
manner so as to prevent their entry into the Port Angeles Harbor by erosion from drainage, high water or
other vectoring mechanisms.
Throughout the checklist,Rayonier states that milling structures will be dismantled. If these structures,
previously used in milling processes,are crushed and stored on the site, residual chemicals and
contaminants will most assuredly be associated with the surfaces of demolished structures. This raises
two concerns. If Rayonier intends to wash these materials,then monitoring and proper disposal of wash
water is imperative. Secondly, if Rayonier does not wash these materials before crushing and storage,
drainage from unwashed material must not be allowed to enter surface and ground waters. Furthermore,
If these materials are removed from the site without being washed,they present potential hazards off-site
as they are recycled or disposed. The same issue arises when the applicant intends to dismantle
lagoons on the site and berms associated with these lagoons. Years of accumulated wastes,such as
slugdes and like substances,are proposed for disposal, however,the checklist does not address
methods ensuring that these residual materials will be disposed of safely.
Regarding impacts to animals, in the checklist, Pages 5 and 6,the applicant has stated that dismantling
of the mill will improve habitat, however,the applicant has failed to identify just how habitat will be
223 East 4th Street, Port Angeles, WA 98362 (360)417-2000
memorandum
February 12, 1997
Page 2
restored. As noted in the checidist, bald eagles are known to be near the site. Furthermore.has the
applicant made any marine restoration proposals or mitigation?
On Page 7, Section 7 regarding Environmental Health,the applicant states that all environmental
on supported hazards will be reduced by this project. This assertion can ty be if theapplicant supplies a
complete disclosure of the long term storage monitoring of material generated by the total project. The
applicant will.be exposing soils within the shoreline jurisdiction that have been subjected to decades of
heavy industrial mill processing but has not provided any indication of the contaminate level of those
soils and potential impacts these soils will have on the marine environment if exposed and1f left on-site.
The County believes pe Ra
it imperative that nier establish a thorough,independent and vedflable
Iro
program for testing,evaluating and tracking through ultimate disposal of all wastes generated during mill
demolition and site remediation.
Regarding land use,this site is zoned heavy industrial. it may be appropriate for the City of Port Angeles
to consider a zoning that will have lesser impacts on the marine shoreline. The applicant has not
identified the marine shoreline to be an area classified as environmentally sensitive. Clallam County has
designated all marine shorelines as Class I Aquatic Habitat Conservation Areas which provides buffers
and options for habitat management plans to be developed. This should be considered.
The applicant has also not addressed public access issues to the shoreline. The applicant Is in a position
to address this issue specifically regarding the Waterfront/Olympic Discovery Trail. In review of WAC
173.27-160(1)(b),it states that the public use of the shoreline should not be interfered with. The review
criteria for shoreline conditional use permits repeatedly promotes public access and use of the shoreline.
This is backed up by RCW 90.58.020. Rayonier and the City of Port Angeles had a verbal agreement to
allow extension of the Waterfront Trail through Rayonier's property utilizing the old railroad grade.
Clallam County also has made extension of the Waterfront/Olympic Discovery Trail a major
transportation goal within the Clallam County Comprehensive Plan. A formai transfer of the old railroad
grade right-of-way to the City of Port Angeles or other right-of-way acceptable for trail purposes as a
condition of the shoreline permit would benefit all citizens of both the City and the County and meet
public access goals of both jurisdiction's Shoreline Master Programs. Demolition should occur in such a
manner as to not preclude future shoreline access for the general public.
Area 9 of the work plan addresses the dock area. Assuming this shoreline development is considered to
be a legal, non-conforming use,any subsequent use of this dock must be in compliance with WAC 173-
27-080. The applicant should seriously consider removing this facility and restoring the shoreline.
Presently,this site is served by a large,concrete waterline which runs the length of the shoreline through
the City. Has the applicant discussed the maintenance of this structure? And what is the status of the
water right permit for water conveyed by this structure? We would assume that the existing water right
was granted by the State for an industrial use. The relatively large quantity and high quality of water that
this water right represents could potentially be a very attractive asset to a wide variety of new industrial
uses. If the water right Is utilized for a non-industrial use,the City and the County,already strapped with
economic hardships,will lose a potential attribute to draw future industrial land uses. On the other hand,
water levels have been low in pact years within the lower Elwha River system. In the some years,flows
in the Elwha River have been so low as to inhibit salmon migration. Has Rayonier considered the
possibility of enhancing fish habitat in the Elwha River by allowing this water to remain in the system?
In Sections 11 and III and IV of the work plan,asbestos, lead and hazardous materials are identified and
BMPs are loosely listed. It may be helpful for the County,who may be responsible for landfill location of
demolition materials,to have the sources of these materials identified and inventoried. Once a final
disposal site Is identified,a grid system should be employed to locate and identify what materials are
stored where. In Section 5(G),the applicant indicates that the owner will be responsible for all below
grade remediation of soils. Remediation of soils should be discussed as part of this application.
Furthermore,the owner will be responsible for the dismantling of underground piping, conduit and piling.
How will these actions be mitigated to prevent these pipes and excavations from conveying untreated
-Page 2-
i
memorandum
• February 12, 1997-
Page
2, 1997Page 3
stormwater into surface waters? Asbestos removal may also require a permit from Olympic Air Pollution
Control Authority.
it may be appropriate to designate an on-site person to maintain tracking of material as they are
removed to ensure that all materials are removed in accordance with state and local laws and conditions.
In may also be appropriate for an industrial hygienist to be maintained on-site to ensure worker safety
during the removal of asbestos,lead,hazardous material and all Inert materials.
The applicant should also be required to provide a cost analysis of,and consideration,of barging
material intended for disposal to an existing facility with long tern monitoring programs in place as
opposed to land-filling in Clallam County.Otherwise,the City should consider withholding Issuance of a
shoreline permit until Rayonier has an approved landfill location for their demolition waste. Furthermore,
the applicant should indicate If materials for recycling will be barged from the site. If recycled or other
hazardous materials are barged,the applicant needs to address again the potential transport of
contaminated stormwater to surface waters including impacts that may occur from pumping bilge water
from these vessels. The checklist is so general that the County Is unable to assess impacts that could
occur as a result of increased truck traffic or even If trucks will be used.
The County suspects,contrary to what Is indicated in the checklist,that a substantial number of
additional permits may be required for this project,including a solid waste disposal permit from the
County. The situation should be avoided wherein the applicant demolishes the facility without the ability
to transport that material from the site.
Considering the extent of this project,the City may want to entertain petitioning the Washington
Department of Ecology to assume lead agency status for the entirety of this proposal.
C. correspondence file
parcel file
Bob Martin,Director
-Page 3-
2951 LOWER ELWHA ROAD (360)432-8471
PORT ANGELES.WA 98363 r *428
ID
_ FEB 1 21997
PORT ANGELES
PLANNING DEPARTMENT
February 11, 1997
Brad Collins, Planning Director
Port Angeles Planning Department
PO 1150
Port Angeles, WA 98362
Subject: Shoreline and Building Permit Application
Rayonier Inc.- Port Angeles Mill
Dear Mr. Collins,
Ennis Creek on the Port Angeles harbor is a historic Mallam village site
and of critical concern to the Elwha IQallam Tribe. We have historic,cultural
and fisheries co-management concerns regarding demolition,site remediation
and future use of the Rayonier-Port Angeles Mill site. Separating the permits for
structure demolition and site remediation seems inappropriate at best. In these
comments we will focus attempt to focus on facility de-construction,but overall
concerns remain.
1. Cultural resources of the site are of primary concern to the Tribe.
Excavation or exposure of native soils requires an archaeologist in
attendance to assess the presence and condition of cultural evidence.
Depending on the type of soil borings used to assess soil contamination
archeological assessment can occur concurrently.
2. The owner provided no timeline in the permit application. We have
requested technical assistance and on-site inspection during dismantling
process by the Environmental Protection Agency (EPA). To coordinate this
review we need to know when each phase of demolition will occur. For
example,all asbestos, PCBs and hazardous materials must be removed prior
to the structure demolition. This phase is not scheduled or distinct.
3. The workplan does not contain enough detail for adequate review of the
dismantling process. It appears that the owner would like to fast tract the
shut down with a general laundry list of what will go and what will stay.
This does not demonstrate the detail necessary to address the corporate
responsibility inherent in mill closure.
4. Separation of the permit application into"above and below grade"/ "above
and below high tide" phases does not mitigate affects of the dismantling
process on cultural,soil,groundwater or surface water resources. The Tribe
finds this inappropriate. Thorough sampling and remediation of the land
and water resources site must occur.
5. Surface water resource of Ennis Creek is above the high tide mark,but is not
addressed in this permit. The Tribe recommends contaminant testing for
sediments of Ennis Creek and surrounding soils. Fisheries habitat has been
degraded by construction and operation of the mill facility.This condition in
the lower reach affected by the facility must be mitigated. The Tribe has
extensive expertise in stream restoration and would welcome the.
opportunity advise Rayonier Inc.regarding stream remediation.
6. What use will be made of the Shotwell landfill? What testing of that waste
stream is planned?
7. Third party observation of this dismantling process is essential to assure
compliance with existing environmeittal protection. The Department of
Ecology technical staff should be on site during the project.
The Tribe has requested review of the dismantling permit by Region 10
EPA in the areas of Hazardous Materials,Resource Conservation and Recovery
Act (RCRA),and Air. We ask that you extend the permit period to allow
adequate review,and above all,require that Rayonier provide a detailed plan for
dismantling the mill.
Sincerely,
Frances G.Charles
Tribal Chair
i
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FRFI 11997
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THE
WASHINGTON STATE
ENVIRONMENTAL POLICY ACT
A LEGAL AND POLICY ANALYSIS
-Richard L. Settle ,
Professor of Law
Seattle University
School of Law
Of Counsel
Foster,Pepper&Shelfelman
Seattle
MICME
Parker Publications Division {
CARLSBAD,CALIFORNIA
WASH.SEPA Issue 8(1996)
§ 13 Threshold Determination
Shoreline Management Act substantial development permits for proposals
of any magnitude are almost always conceded or held to be environmentally,,
significant probably because the premise of the Act is the special ecological
sensitivity, societal value, and vulnerability of "shorelines of the state.'183
Thus, permits for wetland fills,84 marine developments,B5 clam-dredging,86
shoreline facilities for a modest recreational subdivision87 and a major com-
mercial campgroundss have been deemed significant. The exception is a San
Juan Island boating destination site consisting of two mooring buoys,five camp-
sites, a group fire ring, four picnic sites, two vault toilets, a well, signing,
fencing, screening, and improvement of an existing access road for which a
declaration of nonsignificance was upheld.8
The most recent threshold determination case is an aberration. In West
514 v. Spokane County,89a the court upheld a marginally mitigated determina-
tion of nonsignificance for a site development plan approval of a regional
shopping center, which would have in excess of one million square feet of
floor area and parking for 4,550 vehicles in a suburb of Spokane. Given the
sheer magnitude of the proposal,its potential for sapping trade and ultimately
causing blight to downtown Spokane and the unknown effects of storm runoff
on hazardous Leachate from a neighboring "superf ind" landfill, it clearly
crossed the threshold of significance according to all prior relevant cases.89b
However, the opinion muddles two different issues and may not really have
meant that the proposal was not significant. An EIS had been prepared eight
years earlier for a quite different proposal on an 800-acre site that included
the 97-acre site of the later-proposed regional shopping center. The county,
in response to the shopping center proposal (1) adopted the earlier EIS and
(2)issued a mitigated determination of nonsignificance.The court apparently
decided two distinct issues: (1)whether the MDNS was clearly erroneous;
•i
i
83. See generally, R.L. SETTLE, WASHINGTON.LAND USE AND ENVIRONMENTAL LAW AND
PRACTICE ch.4(1983).
84. See Hayes v. Yount, 87 Wn.2d 280,552 P.2d 1038(1976),
85. Sisley v. San Juan County, 89 Wn.2d 78, 569 P.2d 712 (1977);.Merkel v.•Port of
BrowmWUe, 8 Wn. App. 844,509 P.2d 390(1973).
86. See Kitsap County v. State Department of Natural Resources,99 Wn.2d 386,662 P.2d
381 (1983).
87. State v. Lake Lawrence Public Lands Protection Ass n,supra note 70.
88. Toandos Peninsula Assn v.Jefferson County,32 Wn.App.473,648 P.2d 448(1982).
89. San Juan County v.Department of Natuna[Resources,28 Wn.App.796,626 P.2d 995
(1981).
89a. Supra note 45a.
89b. See,e.g.,Barrie v. Misap County,93 Wn.2d 843,853,613 P.2d 1148, 1154(1980);
S.A.V.E. v. City of Bothell, 89 Wn.2d 862,576 P.2d 401 (1978). j
105-0 WASH.SEPA l aue 3(1992)
§ 13(a)The Threshold Standard
which largely restate and clarify existing case law, provide a
useful checklist to consider when determining an action's
environmental significance. Thus, there is explicit recognition
that: 'a proposal may be significant on a relative or absolute,
basis;92 several marginal impacts in combination may be
9s ,
significant, it may be impossible to forecast a proposal's
environmental impacts with precision because some variables
cannot be predicted or values cannot be quantified.94 The
administrative criteria also recognize that a determination of
significance is more likely where a proposal would: ;affect
especially sensitive or socially important environmental
resources,96 including endangered or threatened species and their
habitat;96 conflict with local, state,, or federal environmental
but rather, shall consider whether a proposal has any probable
significant adverse environmental impacts under the rules stated
in this section. For example,proposals designed to improve the
environment, such as sewage treatment plants or pollution
control requirements, may also have significant adverse
environmental impacts.
92. WAC 197-I1-330(3xa)and(b); Narrowsview Preservation Assn v.City of
Tacoma,84 Wn.2d 416,526 P.2d 897(1974).
93. WAC 197-11-330(3)(c);see Polygon Corp.v.City of Seattle,supra note 40.
94. WAC 197-11-330(3xd);see,e.g.,ASARCO Inc.v.Air Quality Coalition,92
Wn.2d 685,704,601 P.2d 501,514(1979)("These emissions to the ambient
air pose possible adverse effects of.unknown dimensions over a large
geographic area which affect air, land and water .."); Norway Hill
Preservation&Protection Assn v.King County Council,87 Wn.2d 267,272,
552 P.2d 674, 677 (1976) ("In essence, what SEPA requires, is that the
`presently unquantified environmental amenities and values will be given
appropriate consideration in decision making along with economic and
technical considerations' RCW 43.21C.030(2xb). It is an attempt by the
people to shape their future environment by deliberation,not default. (Italics
ours.) Stempel v.Department of Water Resources,supra,82 Wash.2d at 118,
508 P.2d at 172;see Loveless v.Yantis,82 Wash.2d 754, 765,513 P.2d 1023
(1973).
"Still a precise and workable definition is elusive because judgments in this
area are particularly subjective—what to one person may constitute a
significant or adverse effect on the quality of the environment may be of
little or no consequence to another.").
95. WAC 197-11-330(3xeXi);see,a g.,Swift v.Island County,supra note 71.
96. WAC 197-11-330(3xexii); see, eg., State v.Lake Lawrence Public Lands
Protection Assn,supra note 70.
A07
§ 13 Threshold Determination
protection laws and policies;97 establish a precedent for future,'
actions with significant effects;96 involve unique and unknown
risks to the environment;99 or affect public health or safety.100
Further guidance is found in the Green Book deflnition of
"significant"101 After cautioning that "[s]ignificance involves
context and intensity . ..and does not lend itself to a formula or
quantifiable test,"101s the definition includes some roughly
quantitative criteria. The vague but well-established judicial
test101b is paraphrased: "'[s]ignificant' as used in SEPA means a
I
'reasonable likelihood of more than a moderate adverse impact on
environmental quality."1010 There is recognition that the extent of
an impact is a product,of two variables: the "severity of an
impact"and its"likelihood of occurrence"load
The Rules also address'the matter of how convincing evidence
of significance must be to support a positive determination. The
responsible official of the lead agency, after gathering sufficient
information, is directed to"[d]etermine if the proposal is likely to
have a probable significant adverse environmental impact"los
and to,prepare an EIS if"the lead agency reasonably believes that
a proposal may have a significant adverse impact"les
As directed by a 1983 SEPA amendment,104-the Rules list the
elements of the environmentlo6 primarily for the purpose of/
providing guidance on the scope of impact statements7106
• 97. WAC 197-11-330(3Xe)(iii);'see,e.g.,ASARCO Inc.v.Air Quality Coalition,
supra note 94; Gardner v.Pierce County Board of Commissioners, supra
note 32.
98. WAC 197-11-330(3Xe)(iy);see,e.g.,S.A.Y.B.v.Bothell,89 W11.2d 862,576
P.2d 401(1978);Hayes v.Yount,supra note 84.
99. WAC 197-11=330(3)(e)(iv);see;e.g.;ASARCO Inc.v.Air Quality Coalition,
supra note 94.
100. Id.
101_ WAC 197-11-794.
101a. WAC 197-11-794(2).
101b. Norway Hill Preservation&Protection Assn.y:King Countytoi veil,supra
note 94.
101c. WAC 197-11-794(l).
101d. WAC 197-11-794(2). "...An impact may be significant if its change of
occurrence is not great;but the-tesulting environmental impact would be
severe if it occurred' Id. -
102. WAC 1974-1-330(1)(b).
103. WAC 197-11-330(4).
104. RCW 43.21 C.110(1)(f)• -
105. WAC 197-11-444.
106. RCW 43.21 C.110(1X£);WAC197-11-440(6Xe).
108
§ 13 Threshold Determination
satisfies SEPA's call for according "substantial weight""' to agency
threshold determinations.142
;Short v. Clallam County,143 the only appellate decision actually deciding'
the correctness of a positive threshold determination,144 contains elaborate and
persuasive justification for more deferential review of positive than negative
threshold determinations. SEPA's central policy of environmental full
disclosure and deliberation is faithfully served by close judicial scrutiny of
determinations of nonsignificance and deferential review of determinations of
significance. While incorrect DNSs thwart SEPA's mission, incorrect DYSS
do not. '
However, close scrutiny of the Short decision reveals that, having paid
homage to SEPA's policies and the desireability of deferential DS review,the
court adopted a standard of review for positive determinations which actually
is less deferential than the clearly erroneous standard applicable to negative
determinations. Commendably, the court identified two quite functionally
distinct administrative determinations within the challenged DS:the agency's
finding that Short intended to construct additional warehouses on the site in
the future, a purely factual determination, and the agency's conclusion that
Short's proposal constituted a "major action" under SEPA, "at the least, a
mixed question of law and fact or, at the most, a pure question of law."145
While review of the purely factual determination was governed by the deferen-
tial arbitrary and capricious standard,the court deemed review of the law ap-
plication determination to be essentially de novo. That is, the agency's inter-
pretation of the statutory standard, "major action significantly affecting the
141. RCW 43.21C.090.See West 514 Inc. v.Spokane County,supra note 117,where the court
purports to apply the clearly erroneous standard in reviewing a MDNS while stressing
that the clearly erroneous standard is qualified by the directive of RCW 43.21C.090 to
defer to agency threshold determination.The court took the directive to defer very seriously.
See§ 13(a),supra.
142. Supra note 140,87 Wn.2d at 275,552 P.2d at 679.Compare Leschi Improvement Council
v. Washington State Highway Comm'n, supra note 139,where the court characterized
agency determination of EIS adequacy as a question of law reviewable de novo notwith-
standing RCW 43.21C.090 which directs courts to accord substantial weight to both threshold
a adequacy determinations. Pease Hill v. Spokane County 62 Wn.App. 800,809,816
P.2d 37(1991)("In reviewing the SEPA[negative threshold]decision,the reviewing court
recognizes and defers to the expertise of the administrative agency.").
143. 22 Wn. App. 825,593 P.2d 821 (1979).
144. In D.E.B.T,Ltd v. Board of Clallam County Commissioners,24 Wn.App. 136,600
P.2d 628(1979),the appellate court did not reach the issue of the correctness of the positive
determination because it was not properly challenged at trial. _
145. Short v. Clallam County,supra note 143,22 Wn. App. at 831,593 P.2d at 825.
116 WASH.SEPA Issue 3(1992)
§ 13(b) The Standard of Judicial Review
quality of the environment," to include Short's proposal was reviewable by
a "contrary to law" standard which meant the court would "conduct its own
independent review of the Board's decision."146 The court recognized that
although the law application determinations within an agency's special exper-
tise or competence are entitled to substantial deference,the County Board did
not have any special expertise or competence in the meaning of SEPA,a state
law which constrains the actions of all state and local agencies. As to such
law application determinations, the court "should be the final arbiter."147
Since there was "no sound reason for any reviewing court to defer to the
Board's interpretation of SEPA in this instance,"148[the court went on to con
duct decidedly non-deferential review and overturned the Board's positive'
threshold determination.
Since in threshold determination challenges the dispute is generally over
the agency's interpretation of the meaning of the statutory standard,
"significantly affecting,"as applied to the facts,Short actually seems to have
adopted a standard of de novo review which is less deferential than the clearly
erroneous standard by which negative threshold determinations are reviewed.
However,the court's policy reasoning in Short leads to the contrary conclusion
that the law application component of negative threshold determinations should
be scrutinized more closely. If the rationale of Short is adopted in the context
of negative determinations,their law application component should be subject
to non-deferential de novo review.148a Such an outcome would eliminate an
inconsistency between standards of review applied to threshold and EIS
adequacy determinations. Both involve agency interpretation of statutory
standards and their application to facts. Yet EIS adequacy long has been sub-
ject to non-deferential de novo review149 while negative threshold determina-
tions are governed by the clearly erroneous standard which requires modest
deference.150 Since threshold and EIS adequacy determinations are function-
ally the same and both are subject to the statutory directive that they be ac-
corded "substantial weight,"151 they should be subject to the same standard
of review.
146. Id.
147. Id. 22 Wn. App. at 832, 593 P.2d at 825.
148. Id. 22 Wn. App. at 883,593 P.2d at 826.
148a. But see Pease Hill v.Spokane County,supra note 142;West 514,Inc.v.Spokane County,
supra note 117.
149. Section 14(a)(ii),infra.See,e.g..Barrie v.Kitsap County,93 Wn.2d 843,854,613 P.2d
1148(1980). "BIS adequacy is a question of law subject to de novo review."
150. See,e.g.,Norway HW Preservation do Protection Assn v. King County Council,supra
note 112.
151. RCW 43.21C.090.
WASH.SEPA Issue 3(1992) 117
Pf1
SEPA Threshold Determination Timing
The following SEPA threshold determination is based on the proposed Rayonier Mill demolition and
shoreline permit applications and SEPA environmental checklist submitted on January 17, 1997 and
found to be complete on January 28, 1997, on additional information requested for the threshold
determination on February 14, 1997, and March 31, 1997, and on the applicant's responses to those
requests on March 17, 1997, and April 7, 1997. Information was also provided by the applicant to
agencies with jurisdiction at two meetings held on February 11, 1997, and March 4, 1997.
The SEPA threshold determination should be made within 90 days of January 17, 1997, plus the time
elapsed while the applicant provided additional information as requested. Decisions on the shoreline
permit and the demolition permit should be made within 120 days of January 28, 1997, again plus the
additional time needed for requested information. Accordingly, the City's SEPA threshold
determination and permitting review times have been necessary and appropriate to date.
In both letters from the SEPA Responsible Official (2/14 and 3/31), it was stated that a DS
(Determination of Significance)was likely. The applicant has continuously expressed an argument
that a DS is not warranted and has been given every opportunity to clarify, change, or condition the
application and the SEPA checklist to mitigate the impact concerns identified by various agencies.
A final meeting has been scheduled with the applicant on April 15, 1997, for one last attempt to
clarify,change, or condition the checklist information to adequately mitigate the proposal's impacts.
Probable Significant Adverse Impacts
In making a threshold determination,the responsible official should determine whether: (a) all or part
of the proposal, alternatives, or impacts have been analyzed in a previously prepared environmental
document,which can be adopted or incorporated by reference and (b) environmental analysis would
be more useful or appropriate in the future in which case, the agency shall commit to timely,
subsequent environmental review(WAC 197-11-330(2)). The lead agency shall prepare its threshold
determination and environmental impact statement (EIS), if required, at the earliest possible point in
the planning and decisionmaking process, when the principal features of a proposal and its
environmental impacts can be reasonably identified (WAC 197-11-055(2)).
In assessing the significance of an impact,a lead agency shall not limit its consideration of a proposal's
impacts only to those aspects within its jurisdiction (WAC 197-11-060(4)(b)). Agencies shall
carefully consider the range of probable impacts, including short-term and long-term effects(WAC
197-11-060(4)(c)). The range of impacts to be analyzed in an EIS (direct, indirect, and cumulative
impacts) may be wider than the impacts for which mitigation measures are required of applicants.
This will depend upon the specific impacts, the extent to which the adverse impacts are attributable
to the applicant's proposal, and the capability of applicants or agencies to control the impacts in each
situation (WAC 197-11-060(4)(e).
Phased review is not appropriate when: (i) the sequence is from a narrow project document to a
broad policy document;(ii)it would merely divide a larger system into exempted fragments or avoid
discussion of cumulative impacts or (iii) it would segment and avoid present consideration of
s
proposals and their impacts that are required to be evaluated in a single environmental document;
however, the level of detail and type of environmental review may vary with the nature and timing
of proposals and their component parts (WAC 197-11-060(5)(d)). Proposals should be described
in ways that encourage considering and comparing alternatives (WAC 197-11-060(3)(a)(iii)). If
information on significant adverse impacts essential to a reasoned choice among alternatives is not
known... Then the agency shall weigh the need for the action with the severity of possible adverse
impacts which would occur if the agency were to decide to proceed in the face of uncertainty. If the
agency proceeds,it shall generally indicate in the appropriate environmental documents its worst case
analysis and the likelihood of occurrence,to the extent this information can reasonably be developed
(WAC 197-11-080).
Environmental Health and Land Use
In this case, previous Department of Ecology(DOE) and Environmental Protection Agency(EPA)
environmental documents, including a February 10, 1992, enforcement order from DOE and a July,
1993, multi-media compliance investigation for EPA, have identified contamination present at the
Rayonier Mill site and are incorporated by reference in this SEPA threshold determination. It is
evident under the enforcement order that site remediation is necessary when demolition of the
aboveground structures has been accomplished. If the demolition were not to happen, then timely
enforcement of site clean up could be continued while the mill remained in operation. The extent of
site contamination and necessary remediation is not known at this time, and the worst case analysis
would place this important marine industrial site in remediation for a 5 to 10 year period of time.
Consequently,a probable significant adverse impact of the demolition of the mill is loss of the use of
the site from the City's land use inventory for more than 5 years. In order to deal with this land use
impact,the threshold determination must provide for either environmental analysis of, or meaningful
conditions requiring, site remediation immediately following completion of the demolition, as part of
a phased environmental review.
Earth, Water, Animals, and Environmental Health
A number of other agencies with jurisdiction and/or expertise have commented on the proposal's
environmental checklist and additional information. These other agencies' concerns regarding soil
testing, spill containment, and hazardous materials handling and waste disposal go beyond the
expertise available at the City and remain as identified impacts.
Recreation and Transportation
Similar to the land use impact, delay resulting from the proposal would affect the development of the
Waterfront Trail(Olympic Discovery Trail)through the site. Millions of dollars of recreational and
transportation funds have been committed to the Olympic Discovery Trail, including current funding
of trail improvements through the Rayonier Mill site. While the demolition of the mill might not
require mitigation of any impact it has on the trail development, delay and/or uncertainty about the
routing of this important recreation/transportation facility resulting from the demolition project would
be a probable significant adverse impact to the public's use of the environment for recreation and
transportation improvements.
J
Mitigation Measures Which an Agency or the Applicant Will Implement as Part of the Proposal
Environmental Site Evaluation and Voluntary Remediation
(1) Within two years after completion of dismantling of aboveground structures, Rayonier will
conduct an environmental evaluation of the mill site.
(2) If the environmental evaluation demonstrates no contamination requiring remediation, no further
action will be taken.
(3) If the environmental evaluation demonstrates levels of contamination by hazardous substances
above those allowed by the Washington Model Toxics Control Act(MTCA),Rayonier will remediate
the contamination consistent with the requirements of MTCA.
The City would accept these mitigation measures as adequate if the environmental evaluation of the
mill site was scheduled to begin"As soon as reasonably practicable"after completion of dismantling
of aboveground structures and if Rayonier "will begin to remediate the contamination as soon as
reasonably practicable"consistent with the requirements of MTCA.
Independent Inspections
(1) Department of Ecology(DOE) has authority to inspect at any time to ensure compliance with
Rayonier's spill prevention control and countermeasure plan, as required by its NPDES permit.
(2) With regard to inspections for hazardous materials handling and waste disposal, DOE also has
jurisdiction and authority to inspect at any time to ensure compliance with state and federal
regulations.
(3) In addition, Rayonier has agreed to allow the Clallam County Department of Community
Development,which has jurisdiction over Rayonier's Shotwell landfill, to inspect materials bound for
that landfill at the mill site at all reasonable times and upon reasonable notice.
The City would accept these mitigation measures as adequate if the costs for staffing these on-site
inspections are paid by Rayonier and "at all reasonable times and upon reasonable notice"shall be
determined by Clallam County.
Olympic Discovery Trail Commitment
(1) The dedication of a trail easement or right-of-way to the City of Port Angeles upon completion
of the demolition project.
The City would accept a commitment from Rayonier and/or Washington State Department of
Transportation in a different form that preferably would allow for the use of the present ISTEA grant
for funding trail improvements through the mill site.
® ® ®® ®®
•
Comm................:1::::::::::::iq;�:q;;:;;::..............
0 or
UT::
® ® ® ®
Port Angeles Mill Site Dismantling A Public Service from Rayonier Vol. I No. '
March 1997
KeepingYou Informed _ ;; = ;
Community Update will keep you informed what is being done to
: ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::..::::::::::::::::_:dismantle Rayon&s Port Angeles Pulp Mill in a safe and environmentally .....
'ble manner while minimizing the impact on our communetYThissp s .:.:.:. ..........:.:.:::::::::::::::-:::::::::::::::::....... - is:
.....................
update will be distributede periodically site dismantlinrocess. ...........
:;... ..
What's BeingDone to Site Dismantling m Team :::::::;::::::::::::::;::::;:::; : :::::::: . :::::::::::::::: .......:..................::
.:
=r
Minimize the Impact? has Considerable
Experience
Rayonier is workinghard n-
Ra onier is experienced enced m site des- ::
m¢e the impact of the site di man-
mantlingand clean-up m Washin
P g ::::::::::::::::::::
tlm on our community.We will con-
g tY K ...:......:................... .........::....................
ton state with Ra oniers former
y
tmue to assist mill employees with s ..................................
GraysHarbor u. and paper mil.. ....... ::::...._ ...........................
Y pulp P P ::: :::::::::::::::::::::.:.....:::::.::::::.........
transition needs and ensure the :::::::::::::::::: ...: :::::::::::::::::::: :_::::::::::::::::::::::.:::
Thateffort received the royal of r ::::::::::::.� ::::::::::::::::.:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
PP :::::::::::::::::.::::::
health and safety of those involved _:::::::::::::::::::::::::::::::::::::::::::::::: :.::::,::::-:.:, :..::::::::::::::::::::::::::
Y -
: ::::::: :; :::::::::::::::::::::::
the Washin on State Department
: : ::::
P :: .. .............::
in the site dismantling process.We _: ::..:::_.. _.....
of Ecologyd completed a
will also continue to support the anwas m i
timely manner. _ _ `. T:w ,: t
community's effort to keep the siteW::;!7f y
...
as a local asset. We have also hired a highly One o the wa s
experienced partner, ICONCO, a managed the mill for its entire 67- Rayonier showed its
• Dismantling operations will occur regional firm with more than 30 year life. appreciation to its
employees and the
from 7 a.m.-5 p.m.,Monday through years experience in industrial site Site dismantling in Port Angeles is PortAngeles
Friday,with no activity scheduled for dismantling and salvage operations, being approached in the same community during
weekends. most of them forest products manner as we address safety issues, the mill's final days.
• Vehicle traffic is expected to be far industry facilities.ICONCO will have which recently resulted in the Port
below what occurred during normal safety and environmental specialists Angeles worksite being nationally
mill operations. Much of the larger, and others on site for several recognized as one of the safest in
recyclable material will be barged months.Rayonier employees will also the country.
from the site. be on site to oversee the contractor
and ensure worksite and community Protecting the
• No unusual odors should occur safety. Environment is a
during the site clean-up and The Port Angeles process is Top Priority
dismantling. Dust control measures expected to be straightforward as it . Rayonier is working closely with
will betaken and noise levels will be was in Grays Harbor, with no the appropriate agencies on the site -
within the city regulations, and are significant environmental issues dismantling and clean-up process.
expected to be below the normal anticipated. Rayonier has extensive All chemicals used in pulp
mill operating levels. knowledge of the site,having owned production are being removed prior
the property since 1929 and to dismantling. The wastewater
Community UPDATE
Port Angeles Mill Site Dismantling • A Public Service from Rayonier- March, 1997
Continued...
treatment system will be in operation
throughout dismantling of the site. Time Line
All waste will be dealt with
properly. Non-hazardous waste will March Clean-up for production process equipment and
be taken to Rayonier or general removal of chemicals used in the process.
purpose landfills.Approximately 85 Mid-March Number of employees on site to begin to taper off,
percent of materials to be disposed with salaried employees and a small group of
of is wood debris, 10 percent roofing, contractor employees on site after April 18.
drywall, plastic and fiberglass,and 5
percent brick and tile.Residue from May Dismantling begins and is expected to last
everyday substances such as paint approximately 12-18 months.Several dozen structures,
thinner and cleaning solvents will be totalling more than 500,000 square feet, will be
disposed of at designated disposal dismantled.
sites.Lab testing of materials that may
be considered hazardous will be done to ensure proper disposal.
A site assessment will be done after dismantling is completed,and a site
remediation plan will be developed with the Washington State Department
of Ecology in accordance with the state Model Toxic Control Act.
Part Three-197-11-305 SEPA Rules
from threshold determination requirements (197-11- shall not require an applicant to prepare a checklist un-
720) except as follows: der SEPA, unless a checklist is required by (1)(a) of this,
(a) The proposal is not exempt under 197-11-908, section.
environmentally sensitive areas. (2) The lead agency shall prepare the checklist or re-
(b) The proposal is a segment of a proposal that quire an applicant to prepare the checklist.
includes: (3) The items in the environmental checklist are not
(i) A series of actions, physically or functionally re- weighted. The mention of one or many adverse environ-
lated to each other, some of which are categorically ex- mental impacts does not necessarily mean that the im-
empt and some of which are not; or pacts are significant. Conversely, a probable significant
( tionaii) A series of exempt actions that are physically or adverse impact on the environment may result in the
funclly related to each other, and that together may need for an EIS.
have a probable significant adverse environmental im-
pact in the judgment of an agency with jurisdiction. If WAC 197-11-330 Threshold determination process.
so, that agency shall be the lead agency, unless the An EIS is required for proposals.for legislation and
agencies with jurisdiction agree that another agency other major actions significantly affecting the quality of
should be the lead agency. Agencies may petition the the environment. The lead agency decides whether an
department of ecology to resolve disputes (197-11-946). EIS is required in the threshold determination process,
For such proposals, the agency or applicant may pro- as described below.
ceed with the exempt aspects of the proposals, prior to (1) In making a threshold determination, the respon-
` conducting environmental review, if the requirements of sible official shall:
\ 197-11-070 are met. (a) Review the environmental checklist, if used:
(2) An agency is not required to document that a .(i) Independently evaluating the responses of any ap-
proposal is categorically exempt. Agencies may note on plicant and indicating the result of its evaluation in the
an application that a proposal is categorically exempt or DS, in the DNS, or on the checklist; and
place such'a determination in agency files. . •(ii) Conducting its initial review of the environmental
checklist and any supporting documents without requir-
WAC 197-11-310 Threshold determination re- ing additional information from the applicant.
!% quired. (1) A threshold determination is required for any (b) Determine if the proposal is likely to have a prob-
proposal which meets the definition of action and is not able significant adverse environmental impact, based on
categorically exempt. the proposed'action, .the information 'in the checklist
%(2) The responsible official of the lead agency shall (197-11-960), and any additional information furnished
make the threshold determination, which shall be made under 197-11-335 and 197-11-350; and
as close as possible to the time an agency has developed (c) Consider mitigation measures which an agency or
or is presented with a proposal 197-11-784 the applicant will implement as part of the proposal.,
(3) In most cases, the time to complete a threshold ,(2) In making a threshold determination, the respon-
determination should not exceed fifteen days. Complex sible official should determine whether:
s` proposals, those where additional information is needed; ;.;...,(a) All or part of the proposal, alternatives,or impacts
.::
and/or those accompanied by an inaccurate checklist have been analyzed in a previously prepared environ-
�'
•fix•'•, ::.. .maY require additional time. Upon request by an aPPli- mental document, which can be adopted or incorporated
cant, the responsible official shall select a date for mak- by reference (see Part Six).
�!`,`'; '•• ing the threshold determination and notify the applicant (b) Environmental analysis would be more useful or
of such date in.writing. appropriate in the future in which case, the agency shall
' (4) All threshold determinations shall be documented commit to timely, subsequent environmental review,
in: consistent with 197-11-055 through 197-11-070 and
:•(a) A determination of nonsignificance (DNS) (197- Part Six.
,..,..•
11-340); or (3) In determining an impact's significance (197-11-
- (b) A determination of,significance (DS) (197-11- 794), the responsible official shall take into account the
`''' following, that:
'L'• (a) The same proposal may have a significant adverse
WAC 197-11-315 Environmental checklist. 1 impact in one location but not in another location;
t=A,' Agencies: (b) The absolute quantitative effects of a proposal are
rr (a)'Shall use the environmental checklist substantially also important, and may result in a significant adverse
I' in the form found. in 197-11-960 to assist in making impact regardless of the nature of the existing
. ' threshold determinations for proposals, except for: Pub- environment; "
lie pr osals-'on which', agency has.decided to
.. .P P. g y (c) Several marginal impacts when considered to-
,>�.prepate;its:own.,EIS,,or.proposaI on which the lead gether may result in a significant adverse impact;
+,ya agency and app hcan't agree an EIS will be prepared. '`(d) For some proposals, it may be'impossible to fore-
;use an.envtrotimental checklist whenever it cast the environmental impacts with precision, often be-
�*Yf rti vjould;assist�.Lin their.:,plannting and,,decisionmaking, but. cause'some variables cannot be predicted or values
t � i�+^^'C`�4y'�"yp:t'ti �°h '"�L �wl J y�'•t 3A 1.°f GS -f Y �l. ' ` `h)A(:.. cannovbe quantified.
ik`d �;. a.,..,..; sir : ,�: _•x+ ; e A proposal may to a significant degree:
w ah�t�akJ P � r.i
f SEPA Rules Part Three-197-11-350
(i) Adversely affect environmentally sensitive or spe- ; (a) An agency shall not act upon a proposal for fif-
cial areas, such as loss or destruction of historic, scien- teen days after the date of issuance of a DNS if the
tific, and cultural resources, parks, prime farmlands, proposal involves:
wetlands, wild and scenic rivers, or wilderness; (i) Another agency with jurisdiction;
(ii) Adversely affect endangered or threatened species (ii) Demolition of any structure or facility not. ex-
or their habitat; empted by 197-11-800(2)(f) or 197-11-880;
(iii) Conflict with local, state, or federal laws or re- (iii) Issuance of clearing or grading permits not ex-
quirements for the protection of the environment; and empted in Part Nine of these rules; or
(iv) Establish a precedent for future actions with sig (iv) A DNS under 197-11-350(2), 197-11-350(3) or
nificant effects, involves unique and unknown risks to, 197-11-360(4).
the environment, or may affect public health or safety. (b) The responsible official shall send the DNS and
(4) If after following 197-11-080 and 197-11-335 environmental checklist to agencies with jurisdiction, the
the lead agency reasonably believes that a proposal may department of ecology, and.affected tribes, and each lo-
have a significant adverse impact, an EIS is required. cal agency or political subdivision whose public services
(5) A threshold determination shall not balance would be changed as a.result of implementation of the
whether the beneficial aspects of a proposal outweigh its proposal, and shall give notice.under 197-11-510.
adverse impacts, but rather, shall consider whether a (c) Any person, affected tribe, or agency may submit
proposal has any probable significant adverse environ- comments to the lead agency within fifteen days of the
mental impacts under the rules stated in this section. For date of issuance of the DNS.
example, proposals designed to improve the environment, (d) The date of issue for the DNS is the date the
such as sewage treatment plants or pollution control re- DNS is sent to the department of ecology and agencies
quirements, may also have significant adverse environ- with jurisdiction and is made publicly available.
mental impacts. (e) An agency with jurisdiction may assume lead
agency status only within this fifteen-day period (197-
WAC 197-11-335 Additional information. The lead 11-948).
agency shall make its threshold determination based (f) The responsible official shall reconsider the DNS
upon information reasonably sufficient to evaluate the based on timely comments and may retain or modify the
environmental impact of a proposal (197-11-055(2) and DNS or, if the responsible official determines that sig-
197-11-060(3)). The lead agency may take one or more nificant adverse impacts are likely, withdraw the DNS
of the following actions if, after reviewing the checklist, or supporting documents. When a DNS is modified, the
. ; the agency concludes that there is insufficient informa- lead agency shall send:the.modified DNS to agencies
tion to make its threshold determination: with jurisdiction.
(1) Require an applicant to submit more information, (3)(a) The lead agency shall withdraw a DNS if:
on subjects in the checklist;, (i) There are substantial.changes to a-proposal'so that
(2) Make its-own further study, including physical in- the proposal is likely,.to have significant.adverse:envi-
vestigations on a proposed site; : ronmental impacts;
(3)'Consult with other agencies, requesting informa- (ii) There is significant new,information indicating, or,
tion on the proposal's potential impacts which lie within on, a proposal's probable•significant adverse environ-
.the other agencies' jurisdiction or expertise ,(agencies mental impacts; or
shallrespond in'accordance with 197-11-550);or (iii) The DNS was procured by misrepresentation or
(4) Decide that all or part of the action or its impacts lack of material disclosure; if such DNS resulted.-from
the actions of an applicant, any subsequent environmen-
are not sufficiently definite to allow environmental
analysis and commit to timely, subsequent environmen- tal checklist on the proposal shall be prepared directly
tal analysis, consistent with 197-11-055 through 197- by the lead agency or its consultant at the expense of the
11-070. applicant.
(b) Subsection (3)(a)(ii) shall not apply when a non-
WAC 197-11-340 Determination of nonsignificance exempt license has been issued on a private project.
(DNS). (1) If the responsible official determines there (c) If the lead agency withdraws a DNS, the agency
will be no probable significant adverse environmental shall make a new threshold determination and notify
impacts from a proposal, the lead agency shall prepare other agencies with.jurisdiction of the withdrawal and
and issue a determination of nonsignificance (DNS) new threshold determination. If a DS is issued, each
substantially in the form provided in 197-11-970. If an agency with jurisdiction shall commence action=to sus-
agency adopts another environmental document in sup- pend, modify, or revoke any approvals until the neces-
port of a threshold determination (Part Six), the notice sary environmental review has occurred (see also 197-
of adoption (197-11-965) and the DNS shall be com- 11-070).
bined or attached to each other.
;:.w(2),:When a:DNS is issued for any of the proposals WAC 197-11-350. :Mitigated DNS. The purpose of
t listed.ini.(2)(a),•.the requirements in this subsection.shall this section is to allow:clarifications or changes to a pro-
be.met.:. posal prior to making the threshold determination.
k Y
JCL 197-11 WAC--p 71
y Part Three-197-11-350 SEPA Rules
:;.(1),:In'making threshold determinations, an agency tribes, and to the public. Notice shall be given under �{
may consider mitigation%measures that the:agency or 197-11-510. The lead agency is not required to scope if
.� applicant will implement. : the agency is adopting another environmental document
` '(2) After submission' of,an environmental checklist for the EIS or is preparing a supplemental EIS.
and prior to.the lead agency's threshold determination (4) If at any time after the issuance of a DS a pro
on a proposal, an-applicant may ask the lead agency to posal is changed so, in the judgment of the lead agency,
indicate whether it is considering a DS. If the lead there are no probable significant adverse environmental
agency indicates a DS is likely, the applicant may clarify impacts, the DS shall be withdrawn and a DNS issued
or change features of the proposal to mitigate the im- instead. The DNS shall be sent to all who commented on
pacts which led the agency to consider a DS likely. The the DS. A proposal shall not be considered changed until
applicant shall revise the environmental checklist as may all license applications for the proposal are revised to
be necessary to describe the clarifications or changes. conform to the changes or other binding commitments
The lead agency shall make its threshold determination made by agencies or by applicants.
based upon the changed or clarified proposal. If a pro-
posal continues to have a probable significant adverse WAC 197-11-390 Effect of threshold determina-
environmental impact, even with mitigation measures, an tion. (1) When the responsible official makes a threshold
EIS shall be prepared. determination, it is final and binding on all agencies,
(3) Whether or not an applicant requests early notice subject to the provisions of this section and 197-11-340,
under subsection (2), if the lead agency specifies mitiga- 197-11-360, and Part Six.
tion measures on an applicant's proposal that would al- (2) The responsible official's threshold determination:
low it to issue a DNS, and the proposal is clarified, (a) For proposals listed in 197-11-340(2), shall not
changed, or conditioned to include those measures, the be final until.fifteen days after issuance.
lead agency shall issue a DNS. (b) Shall not apply if another agency with jurisdiction
(4) Environmental documents need not be revised and assumes lead agency status under 197-11-948.
resubmitted if the clarifications or changes are stated in (c) Shall not apply when withdrawn by the responsi-
"` writing in documents that are attachments to, or incor- ble official under 197-11-340 or 197-11-360.
porate by reference, the documents previously submitted. (d) Shall not apply when reversed on appeal.
An addendum may be used, see Part Six. (3) Regardless of any appeals, a DS or DNS issued by
(5) Agencies may clarify or change features of their the responsible official may be considered final for pur-
' own proposal, and may specify mitigation.measures in poses of other agencies' planning and decisionmaking
their DNSs, as a result of comments by other agencies unless subsequently changed, reversed, or withdrawn.
or the public or as a result of additional agency
=planning.
6)..An agency's indication t nder•'this section that a
DS..appears likely shall not be construed as a determina- PART FOUR - ENVIRONMENTAL
'',:tion of significance. Likewise, the preliminary discussion IMPACT STATEMENT (EIS)
of clarifications or changes to a':proposal shall not bind
1the lead agency to a mitigated.DNS. z` WAC.197-11400 Purpose of EIS. (1) The primary
(7) Agencies may specify procedures for enforcement. purpose of an environmental impact statement is to en
of mitigation measures in their agency SEPA proce- sure that SEPA's policies are an integral.part of the on-
dures..:,i,.,,. going programs and actions of state and local
government. : :.
WAC 197-11-360 Determination of significance (2) An EIS shall provide impartial discussion,of sig-
(DS)/initiation of scoping. (1) If the responsible official nificant environmental impacts and shall inform deci-
` determines that a proposal may have a probable signifi- sionmakers and the public of reasonable alternatives,
cant adverse environmental impact, the responsible offi- including mitigation measures, that would avoid or min-
cial shall prepare and issue a determination of imize adverse impacts or enhance environmental quality.
significance (DS) substantially in the form provided in (3) Environmental impact statements shall be concise,
197-11-980. The DS shall describe the main elements of clear, and to the point, and shall be-supported by the
the proposal, the location of the site, if a site-specific necessary environmental analysis. The purpose of an EIS
proposal, and the main areas the lead agency has identi- is best served by short documents containing summaries
fied for discussion in the EIS. A copy of the environ- of, or reference to, technical data and by avoiding ex-
mental checklist may be attached. cessively detailed and overly technical information. The
(2) If an agency adopts another environmental docu- volume of an EIS does not bear on its adequacy. Larger
ment in support of a threshold determination (Part Six), documents may even hinder the decisionmaking process.
the notice of adoption (197-11-965) and the DS shall be (4) The EIS process enables government agencies and
combined or attached to each other.- interested citizens to review and comment on proposed
(3);'The,responsible official shall.put the DS in the government,actions; including government approval of
lead agency's file and"shall commence scoping (197-11- private projects and their environmental effects. This
z , -:,-,408) by.,circulating copies of,the DS to.the applicant, process is intended to assist the agencies and applicants
r;.•agencies;with jurisdiction,and..expertise, if any; affected to improve their plans and decisions, and to encourage
*AC.— BJ 1 t ;�.
t
• SEPA Rules Part Four-197-11-408
the resolution of potential concerns or problems prior to (3) A final EIS (FEIS) shall revise the DEIS as ap-
issuing a final statement. An environmental impact propriate and respond to comments as required in 197-
statement is more than a disclosure document. It shall 11-560. An FEIS shall respond to opposing views on
be used by agency officials in conjunction with other significant adverse environmental impacts and reason-
relevant materials and considerations to plan actions and able alternatives which the lead agency determines were
make decisions. not adequately discussed in the DEIS. The lead agency
shall issue an FEIS as specified by 197-11-460.
WAC 197-11-402 General requirements. Agencies (4) A supplemental EIS (SEIS) shall be prepared as
shall prepare environmental impact statements as an addition to either a draft or final statement if:
follows: (a) There are substantial changes to a proposal so that
(1) EISs need'analyze only the reasonable alternatives the proposal is likely to have significant adverse envi-
and probable adverse environmental impacts that are, ronmental impacts; or
significant., Beneficial environmental impacts or other (b) There is significant new information indicating, or
impacts may be discussed. on, a proposal's probable significant adverse environ-
(2) The ievel of detail shall be commensurate with the' mental impacts.
`importance of the impact; with less important material Preparation of a SEIS shall be carried out as stated in
summarized, consolidated, or referenced. 197-11-020.
(3) Discussion of insignificant impacts is not required,; (5) Agencies may use federal EISs, as stated in Part
if included, such discussion shall be brief and limited to/ Six.
'summarizing impacts or noting why more study is not"
warranted. ; WAC 197-11-406 EIS timing. The lead agency
(4) Description of the existing environment and the shall commence preparation of the environmental impact
nature of environmental impacts shall be limited to the% statement as close as possible to the time the agency is
affected environment and shall be no longer than is nec-1 developing or is presented with a proposal, so that prep-
essary to understand the environmental consequences of aration can be completed in time for the final statement
the alternatives,including the proposal. to be included in appropriate recommendations or re-
(5) EISs shall be no longer than necessary to comply ports on the proposal (197-I1-055). The statement shall
with SEPA and these rules. Length should relate first to be prepared early enough so it can serve practically as
potential environmental problems and then to the size or an important contribution to the decisionmaking process
complexity of the alternatives, including the proposal. and will not be used to rationalize or justify decisions
(6) The basic features and analysis of the proposal, already made. EISs may be "phased"tin appropriate sit-
alternatives, and impacts shall be.discussed in-the EIS uations (197-11-060(5)). ,
and shall be generally understood without.turning to
other documents; however, an EIS is not required to in- WAC 197-11-408 Scoping. (1) The lead agency
clude all information conceivably relevant to a proposal, shall narrow the scope of every EIS to the probable sig-
and may be supplemented by appendices, reports, or nificant adverse impacts and reasonable alternatives, in-
other documents in the agency's record. �cluding mitigation measures. For example, if there are j
(7) Agencies shall reduce paperwork and the accumu- only two or three significant impacts or alternatives, the I!
lation of background data by adopting or incorporating EIS shall be focused on those. 1
by reference, existing, publicly available environmental (2) To ensure that every EIS is concise and addresses
documents, wherever possible. the significant environmental issues, the lead agency
(8) Agencies shall prepare EISs concurrently with and shall:
coordinated with environmental studies and related sur- (a);Invite agency,affected tribes, and public comment
veys that may be required for the proposal under other 'on the DS (197-11-360). If the agency requires written
laws, when feasible. comments, agencies, affected tribes and the public/shall
(9) The range of alternative courses of action dis- be allowed twenty-one days from the date of issuance of
cussed in EISs shall encompass those to be considered by the DS in which to comment,/unless expanded scoping is'
the decisionmaker. used. The date of issuance for a DS is the date it is sent
(10) EISs shall serve as the means of assessing the to the department of ecology and other agencies with
environmental impact of proposed agency action, rather jurisdiction, and is publicly available. .
than justifying decisions already made. - (b) Identify reasonable alternatives and probable sig
nificant adverse environmental impacts. _
WAC 197-I1-405 EIS types. (1) Draft and final (c) Eliminate from detailed study those impacts that
environmental impact statements (EISs) shall be pre- are not significant.
pared; draft and final supplemental EISs may be (d)Work with other agencies to identify and integrate
prepared. environmental studies required for other government ap-
(2) A draft EIS (DEIS) allows the lead agency to provals with the EIS, where feasible.
consult with members of the public, affected tribes, and (3). Agencies, affected tribes, and the public should
agencies with jurisdiction and with expertise. The lead ioomment promptly and as specificallyas permitted by
agency shall issue a DEIS and consider..comments as the details available on the proposal.
stated.in Part Five.
JUL 197-11 WAC--p 91
".Part Four-197-11-408 SEPA Rules
(4) Meetings or scoping documents, including notices matter who participates in the preparation of the EIS, it
that the scope has been revised, may be used but are not is the EIS of the lead agency. The responsible official,
required. The lead agency shall integrate the scoping prior to distributing an EIS, shall be satisfied that it
process with its existing planning and decisionmaking complies with these rules and the procedures of the lead
process in order to avoid duplication and delay. agency.
(5) The lead agency shall revise the scope of an EIS if (2) The lead agency may have an EIS prepared by
substantial changes are made later in the proposal, or if agency staff, an applicant or its agent, or by an outside
significant new circumstances or information arise that consultant retained by either an applicant or the lead
nd its significant impacts. agency. The lead agency shall assure that the EIS is
bear on the proposal a
!
be prepared according to the scope
(6) DEISs shall prepared in a professional manner and with appropriate
decided upon by the lead agency in its scoping process. interdisciplinary methodology. The responsible official
(7) EIS preparation may begin during scoping. shall direct the areas of research and examination to be
t undertaken as a result of the scoping process, as well as
t: WAC 197-11-410 Expanded scoping. (Optional) the organization of the resulting document.
(1) At its option, the lead agency may expand the (3) If a person other than the lead agency is preparing
scoping process to include any or all of the following, the EIS, the lead agency shall:
which may be applied on aproposal—by—proposal basis: (a) Coordinate any scoping procedures so that the in-
(a) Using questionnaires or information packets. dividual preparing the EIS receives all substantive infor-
(b) Using meetings or workshops, which may be com- mation submitted by any agency orperson;
_ bined with any other early planning meetings of the (b) Assist in obtaining any information on file with
agency. another agency that is needed by the person preparing
(c) Using a coordinator or team from inside or outside the EIS;
the agency. (c) Allow any party preparing an EIS access to all
(d) Developing cooperative consultation and exchange public records of the lead agency that relate to the sub-
-of information among agencies before the EIS is pre- ject of the EIS, under chapter 42.17 RCW (Public Dis-
;':;,pared, rather than awaiting submission of comments on closure and Public Records Law).
`,a completed document. (4) Every agency shall specifically provide in its own
(e) Coordinating and integrating other government procedures those situations in which an applicant may be
*l,reviews and approvals with the EIS process through required or authorized to help prepare an EIS. Agency
' _memoranda or other methods. procedures may not require more information of an ap-
`.
(f) Inviting participation of agencies with jurisdiction plicant than allowed by 197-11-100,,but may authorize
,or expertise from various levels of government, such as less participation. An applicant may volunteer to provide
s °.? egional or federal agencies. any information or effort desired, as long as the 'EIS is
(g) Using other methods as the lead agency may find supervised and approved by the responsible official.
" �r'helpful. These rules do not prevent an agency from charging any
~'s•• '(2) Use of expanded scoping is intended to promote fees which the agency is otherwise allowed to charge
'interagency cooperation, public participation, and inno- (197-11-914).
- ,vative ways to streamline the SEPA process. Steps shall
be taken, as the lead agency determines appropriate, to WAC.197-11-425 Style and size. (1) Environmen-
``:encourage and assist public participation. There are no tal impact statements shall. be readable,reports; which
4' r. "specified procedural requirements for the methods, tech- allow the reader to understand the most significant and
niques, or documents which may be used in an expanded vital information,concerning .the,:.proposed.action, alter-
`
.scoping process, to provide maximum flexibility to meet natives„ and impacts, without turning to:other,�docu-
'nS these:purposes. ments, as provided below and in.
(3) The lead agency shall consult with an applicant (2) Environmental impact statements'shall lie concise
prior• to deciding the method and schedule for an ex- and written in plain language EISs;shall'not be exces-
- ` ", panded scoping process. sively detailed or overly technical '•EISs:shall explain
(4)' Under expanded scoping, an applicant may re- plainly the meaning of technical terms not generally un-
' `quest, in which case the lead agency shall set, a date by derstood by the-general public. This may-be. done in a
which the lead agency shall determine the scope of the glossary or footnotes or by some other.means::EISs may },
,:111;'-EIS, including the need for any field investigations (to include an index for ease in-using the statement.
the extent permitted by the details available on the pro- (3) Most of the text of an environmental impact
• ; ',,,; ;,::_posal). The date shall occur thirty days or less after the statement shall discuss and compare-the environmental !!
DS.is issued unless the lead agency and applicant agree impacts and their significance, rather than describe the
' A. -a later date. B', y PP g proposal and the environmental setting. Detailed de-
upon. ,
scriptions may be included in appendices or supporting
Y WAC 197-11-420 ELS preparation. For draft and documents. ,•
final.EISs,and SEISs -_«,` �(4) The text of an EIS (197-11-430(3)) normally
y ', ,,,.(1)•-,Preparation.of the,EIStis the.responsibility of the ranges from thirty to fifty pages and may be shorter.
lead agency, by or under the direction of its.responsible
The text shall not exceed.seventy—five pages;except .
ficial, as;spectfied by•tl a lead},a�ency s procedures. No for'proposals of unusual scope or complexity; where the t F
r� �P�i pre ' ` w� �,�„•��.`�"��e�''"iy�ttii� i •rrr �}�i • , ��•�
���t�. fir'Lh 1 1� � '' . 5 'i � ; �,• �
j(?h. 1 WAC44301 ; f i 3 • , L