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HomeMy WebLinkAbout700 N Ennis St (Rayonier Mill Property) - Building ELECTRICAL PERMIT CITY OF PORT ANGELES N 360- 417 -4735 Application Number 12- 00000292 Date 3/15/12 N Application pin number 325884 Property Address 700 N ENNIS ST ELEC REPORT SALES TAX ASSESSOR PARCEL NUMBER: 06- 30- 00 -5 -0- 1000 -0000 on your excise tax form Application type description ELECTRICAL ONLY Subdivision Name to the City of Port Angeles Property Use (Location Code 0502) Property Zoning INDUSTRIAL HEAVY Application valuation 0 Application desc security system 2 storage sheds Owner Contractor ITT'RAYONIER INC -PAD HI TECH SECURITY INC 700 N ENNIS ST 723 E FRONT ST PORT ANGELES WA 983624504 PORT ANGELES WA 98362 (360) 452 -2727 y L e,g(oD Permit ELECTRICAL ALTER COMMERCIAL Additional desc Permit Fee 192.00 Plan Check Fee .00 Issue Date 3/15/12 Valuation 0 Expiration Date 9/11/12 C (E5 Qty Unit Charge Per Extension 2.00 96.0000 ECH EL- LIMITED 1ST 1500 SQ FT 192.00 Fee summary Charged Paid Credited Due Permit Fee Total 192.00 192.00 .00 .00 Plan Check Total .00 .00 .00 .00 Grand Total 192.00 192.00 .00 .00 V INSPECTION TYPE DATE: RESULTS: INSPECTOR: DITCH SERVICE ROUGH -IN 3l Z6 ply Z 7< FINAL 212C, l 7! COMMENTS: PERMIT WILL EXPIRE SIX (6) MONTHS FROM LAST INSPECTION Signature of owner or Electrical Contractor X Date: G:\EXCHANGE\BUILDING 13',, r=(; `•I r i ;ri I ll L,. 'uL U 1,- cat rtIff 1, ;L CITY OF PORT ANGELES PERMIT APPLICATION' f •t`°•< 1 4 Zu i I ,•,`LV a Building Division/Electrical Inspections 1 321 East Fifth Street P.O. Box 1150 Port Angeles Washington, 98362 ELECTRICAL Ph: (360) 417 -4735 Fax: (360) 417-4711 INSPECTIONS Date: 3-1312 ✓Q Multi Family or Commercial* f Plan Review May Be Required, Please Complete Electrical Plan Review Inforrnalion Sheet Job Address: 700 North Building Square Footage: Description of above Irma ssemty m b store7I shaft 12) Owner Information Contractor Information Name: naw.i.mistbs Name: Ti san,tar• ►tc Mailing Address: 570 "w" I Mailing Address: 723 East Front St City. J»Gum.nta State: wA Zip: 32202 City: PonM State: WA Zp: 66362 Phone: 39047 Fax Phone: 360-4524727 Fax 3 License Exp. License 1 Exp. 1ITECT695665 Item Unit Charge gty Total (Qtv Multiplied by Unit Charge) Service /Feeder 200 Amp. 132.00 Service/Feeder 201-400 Amp. 160.00 Service/Feeder 401-600 Amp 225.00 Service/Feeder 601 -1000 Amp. 288.00 Service/Feeder over 1000 Amp. 410.00 Brands Ora it W Service Feeder 5.00 Branch Omit WO Service Feeder 74.00 Each Additional Branch Circuit 5.00 Brandi Omits 14 86.00 Temp. Service/ Feeder 200 Amp. 102.00 Temp. Service/Feeder 201 -400 Amp. 121.00 Temp. Service/Feeder 401-600 Amp. 164.00 Temp. ServicelFeeder 601 -1000 Amp 185.00 Portal to Portal Hourly 96.00 Sign/Outline Lighting 88.00 Signal Circuit/ Limited Energy Multi-Family 64.00 Signal Circuit/ Limited Energy First 1500 sf Commercial 96.00 2 'um Note: $5.00 for each additional 1500 sf Renewable Electrical Energy 5KVA System or Less 113.00 Thermostat 56.00 Note: $5.00 for each additional T-Stat 162.07 Total otal Owner as defined by RCW.19.28.261: (1) Owner will occupy the structure for two years after this electrical permit is finalized. (2) Owner is required to hire an electrical contractor if above said property is for sale, rent or lease, Permit expires after six months of last inspection. After reading the above statement, I hereby certify that I am the owner of the above named property or a licensed electrical contractor. l am making the electrical installation or alteration in compliance with the electrical laws, N.E.C., RCW. Chapter 19.28, WAC. Chapter 296 -46B, The City of Port Angeles Municipal Code, and Utility Specifications and PAMC 14.05.050 regarding Electrical Permit Applications. Signature of owner, electrical contractor or electrical administrator: Cash Check Credt Card on Ftle Mike Shirley Gary Politika o 14312 0110 112012 Application Number Application pin number Property Address ASSESSOR PARCEL NUMBER Application type description Subdivision Name Property Use Property Zoning Application valuation Owner ITT RAYONIER INC PAD 700 N ENNIS ST PORT ANGELES WA 983624504 Structure Information 000 000 #06 13 Qty Unit Charge Per Fee summary Charged Permit Fee Total 75 00 Plan Check Total 00 Grand Total 75 00 T•\Paleie \l102.15R{1 /O5] BASE FEE CITY OF PORT ANGELES PUBLIC WORKS UTILITIES DIVISION 321 EASTSTH'STREET PORT ANGELES, WA 98362 06 00000767 377042 700 N ENNIS ST 06 30 00 5 0 1000 0000 CLEARING GRADING UNKNOWN 0 Contractor OWNER Permit CLEAR GRADE Additional desc #06 13 Permit pin number 82636 Permit Fee 75 00 Plan Check Fee 00 Issue Date 7/31/06 Valuation 0 Expiration Date 1/27/07 Paid Credited 75 00 00 00 00 75 00 00 Date 7/31/06 Due Extension 75 00 00 00 00 Separate Permits are required for electrical work, SEPA, Shoreline, ESA, utilities, private and public improvements. This permit becomes null and void if work or construction authorized is not commenced within 180 days, if construction or work is suspended or abandoned for a period of 180 days after the work as commenced, or if required inspections have not been requested within 180 days from the last inspection. I hereby certify that I have read and examined this application and know the same to be true and correct. All provisions of laws and ordinances governing this type of work will be complied with whether specified herein or not. The granting of a permit does not presume to give authority to violate or cancel the provisions of any state or local law regulating construction or the performance of cons 72 f re of Contractor or Authorized Agent Date Signature of Owner (if owner is- builder) Date CALL 417 -4807 FOR UTILITY INSPECTIONS. PLEASE PROVIDE A MINIMUM 24 HOUR NOTICE. IT IS UNLAWFUL TO COVER, INSULATE OR CONCEAL ANY WORK BEFORE INSPECTED AND ACCEPTED. POST PERMIT IN A CONSPICUOUS LOCATION. PW UTILITIES (Engineering Division) WATERLINE METER SEWER CONNECTION SANITARY STORM SITE DRAINAGE SITE EROSION CONTROL PARKING SIDEWALK CURB GUTTER DRIVEWAY APPROACH BACK -FLOW DEVICE T•\Policies \I 102.15R 1/05] RESIDENTIAL CONSTRUCTION R.W PW/ 417 4807 ENGINEERING FIRE 417 -4653 I PLANNING DEPT 417 -4750 I BUILDING 417 -4815 PERMIT INSPECTION RECORD KEEP PERMIT CARD AND APPROVED PLANS AT JOB SITE INSPECTION TYPE DATE ACCEPTED YES I NO 1 I I I I I I I I I .1 1 I I I I I 1 I I I I I I I 1 I I I I I I I I I I I I I 1 I I I I I I I I I 1 I I I 1 I 1 I 1 I I I I I I I 1 I I I 1 I I I I FINAL INSPECTIONS REQUIRED PRIOR TO OCCUPANCY/USE DATE YES NO COMMERCIAL DATE ACCEPTED YES I NO I I I I I I I I CONSTRUCTION R.W PW ENGINEERING I FIRE DEPT. I PLANNING DEPT BUILDING COMMENTS I I 1 I I I I I I 1 Mb N Application Number Property Address ASSESSOR PARCEL NUMBER Application description Subdivision Name Property Zoning Application valuation Owner ITT RAYONIER INC PAD 700 N ENNIS ST PORT ANGELES Permit Additional desc Sub Contractor Permit Fee Issue Date Expiration Date Fee summary Permit Fee Total Plan Check Total Grand Total T- \PLANMNG\FORMS \1102.15 [4/2002] CITY OF PORT ANGELES DEPARTMENT OF COMMUNITY DEVELOPMENT BUILDING DIVISION 321 EAST 5TH STREET PORT ANGELES, WA 98362 WA 983624504 03 00001020 700 N ENNIS ST ELEC 06 30 00 5 0 1000 0000 ELECTRICAL ONLY 0 Contractor ANGELES ELECTRIC 524 E 1ST ST PORT ANGELES (360) 452 9264 ELECTRICAL NEW COMMERICAL RELOCATE SERVICE EQUIPMENT ANGELES ELECTRIC 76 30 Plan Check 10/21/03 Valuation 4/19/04 Qty Unit Charge Per 1 00 76 3000 ECH EL -COM 0 100 NEW SRV FEEDER Charged Paid Credited 76 30 76 30 00 00 00 00 76 30 76 30 00 Date 10/21/03 WA 98362 Fee 00 0 Extension 76 30 Due 00 00 00 Separate Permits are required for electrical work, SEPA, Shoreline ESA, utilities, private and public improvements. This permit becomes null and void if work or construction authorized is not commenced within 180 days if construction or work is suspended or abandoned for a period of 180 days after the work as commenced or if required inspections have not been requested within 180 days from the last inspection I hereby certify that I have read and examined this application and know the same to be true and correct. All provisions of laws and ordinances governing this type of work will be complied with whether specified herein or not. The granting of a permit does not presume to give authority to violate or cancel the provisions of any state or local law regulating construction or the performance of construction. Signature of Contractor or Authorized Agent Date Signature of Owner (if owner is builder) Date 0 \P\ (A 1 ELECTRICAL LIGHT DEPT 417 -4735 CONSTRUCTION R.W PW/ ENGINEERING 417 -4807 FIRE 417 -4653 PLANNING DEPT 417 -4750 BUILDING 417 -4815 T \PLANNING \FORMS \1102.15 [4/2002] BUILDING PERMIT INSPECTION RECORD CALL 417 -4815 FOR BUILDING INSPECTIONS. PLEASE PROVIDE A MINIMUM 24 HOUR NOTICE. IT IS UNLAWFUL TO COVER, INSULATE OR CONCEAL ANY WORK BEFORE INSPECTED AND ACCEPTED. POST PERMIT IN A CONSPICUOUS LOCATION KEEP PERMIT CARD AND APPROVED PLANS AT JOB SITE INSPECTION TYPE DATE ACCEPTED YES I NO FOUNDATION: FOOTINGS WALLS FOUNDATION DRAINAGE ELECTRICAL (LIGHT DEPT) SEPARATE PERMIT ROUGH -IN PLUMBING UNDER FLOOR SLAB ROUGH -IN WATER LINE GAS LINE BACK FLOW WATER AIR SEAL WALLS CEILING FRAMING JOISTS GIRDERS SHEAR WALL WALLS ROOF CEILING DRYWALL T -BAR INSULATION SLAB WALL FLOOR CEILING MECHANICAL HEAT PUMP WOOD STOVE PELLET CHIMNEY HOOD/ DUCTS PW UTILITIES SITE WORK (Engineering Division) SEPARATE PERMIT #'s: WATERLINE METER SEWER CONNECTION SANITARY STORM PLANNING DEPT SEPARATE PERMIT #'s SEPA. PARKING /LIGHTING ESA. LANDSCAPING SHORELINE. FINAL INSPECTIONS REQUIRED PRIOR TO OCCUPANCY /USE RESIDENTIAL DATE YES NO COMMERCIAL ELECTRICAL LIGHT DEPT CONSTRUCTION R.W PW ENGINEERING I FIRE DEPT I PLANNING DEPT I BUILDING COMMENTS DATE ACCEPTED YES I NO From Jack.Anderson @rayonier Qom <Jack.Anderson @rayonier com> To permits @ci port- angeles wa.us <permits @ci port- angeles.wa us> Date Thursday, November 19, 1998 5 00 PM Subject: Soil /Uncovered Pile If there are any additional questions or comments please call me always have my cell phone with me (360 -460 -1037) I will be out of the office from Saturday, Nou 21 until late afternoon of Nov 30 but will have the cell phone and encourage you to call me if a need arises. Jack 11/23/98 Lou, just to summarize my comment on the recent sampling of the large pile of stockpiled soil 1 The pile was uncovered °i Monday Nov 16 and Landau Associates proceeded to "grid" the pile 2 On Tuesday, the pile was sampled by EPA and Landau The City's representative examined the pile to ensure that there were not undesirably large pieces of concrete or other debris in the pile The sampling continued until dark. 3 On Wednesday, the pile Was recovered The pile that was being worked on last Saturday was the material that had been removed from the earthen lagoon Work was not started until -9 AM and consisted of mixing sawdust with a very small part of the pile to thicken material that vras "slumping" Only about a quarter of the pile was uncovered during the procedure Page 1 of 1 Lou .1 October 14, 1998 P ORTANGLELES W A S H I N G T O N U S A PLANNING DEPARTMENT Darlene Schanfald Olympic Environmental Council 3632 O'Brien Road Port Angeles, WA 98362 Re Response to Concerns with Rayonier Demolition Conditions Dear Ms Schanfald: This letter is to follow up on our telephone conversation today After communicating with several other City officials, I have found the situations about your specific concerns with the Rayonier demolition conditions and City Treatment Plant operation to be apparently what can be expected for these particular activities in the Industrial Heavy Zone Your first concern about the loud noises coming from the mill demolition is a result of the demolition activities which for the most part are intermittent. If the noises are ongoing and not intermittent, then City noise regulations could under some circumstances be applicable to curtailing the continuous nature of the operation. When the Rayonier Mill was operating, several noise situations were addressed. The demolition permit and environmental review anticipated that loud noises would occasionally result from the demolition activities, and I have not found that the demolition circumstances are creating a loud noise situation that was not expected. Regarding the horrific odor, field investigation has not identified a specific source for the sewage type odor about which you told me Public Works Director Jack Pittis has determined that the City Treatment Plant is operating correctly The types of odors associated with such a plant may have more to do with prevailing weather conditions if the equipment is not malfunctioning. No specific odor was attributed to the Rayonier demolition activity; however, there are monitoring stations that are measuring for certain types of contaminants. Whether any of these contaminants can be associated with odors is unknown to me The demolition work hours vvere identified by the contractor during the environmental review process as 7 00 am to 5 00 pm, five days a week. We will remind the contractor of this commitment. The City's noise ordinance allows for construction activities between 321 EAST FIFTH STREET P 0 BOX 1 150 PORT ANGELES WA 98362-0217 PHONE 360 -417 4750 FAX 360 -417 4609 TTY 360 -417 4645 E MAIL PLANNING @CI PORT ANGELES WA US Schanfald Rayonier Complaint Letter October 14 1998 Page 2 the hours of 7 00 am and 10'09 pm. City Building Official Lou Haehnlen, who is inspecting the demolition activity, indicates that the activities are generally following the 7 00 am to 5 00 pm operation hours. As with loud noises, the demolition permit and environmental review anticipated that construction work hours would be consistent with normal construction requirements, mild I have not found that the demolition circumstances are creating a pattern of work hours that was not expected. Nonetheless, when you or Chris Thomas become aware of loud noises odors and late work hours, bring each instance to the attention of the City's Public Works and Planning staff As in this case, the City staff will investigate your complaints, will notify the contractor as may be necessary, and will take further action If a pattern of violations can be established Sincerely, Brad Collins, Planning Director cc: Jack Anderson, Rayon er Patrick Ibarra, City Manager Craig Knutson, City Att prney Jack Pittis, Public Works Director Haehnlen, Building Official Chris Thomas, Resides it •a Rayonier Mr Garin Schrieve, PE Washington State Department of Ecology Southwest Regional Office PO Box 47775 Olympia, WA 98504 -7706 Mr Carl Kitz US EPA, Region X 1200 Sixth Avenue (HW -114) Seattle, WA 98101 Re: Monthly Ambient Air Monitc ring Report Rayonier Site Dismantling Pioject Please find enclosed the Ambient Air Monitoring Report for the Rayonier Site Dismantling Project for the month of July 1998. These results are being provided to you as described in our Ambient Air Monitoring Plan for the project. We are also makii g these reports available to the public through the Port Angeles Library and Peninsula College Library. The results from the air monitoring show that the air emission control methods used during the dismantling work have been effective. The air samples collected around the perimeter of the work site were well below the air quality action levels that are use i as indicators of effective emission controls. We are continuing our air monitoring a id emission control programs at the site. As additional results are available, they will be compiled by our consultant, Foster Wheeler Environmental Corp. and will be forwarded to you and made available tc the public. Enclosure r i t1 1-( OHO_ Sincerely ack A. Anderson 0(1 \c li I )11 iit eI 1 0;;362 l k 1 11 1 Ili I :Ss Pulp Products Port 4rigJeles hill October 13 1998 Environmental Manager cc Laurie Davies, Department of Ecology, SW Regional Office Joanne LaBaw US EPA, Region X Richard Robinson, ATSDR, Seattle, W A Chris Hartnett, ATSDR, Austin, TX Richard Foster, Port Angeles Economic Response Task Force Darlene Shanfald, Olympic Environmental Council Lou Haehnlen, City of Port Angeles Port Angeles Public Library Peninsula College Library Rayonier September 4, 1998 Jack N Pittis, Director of Publ c Works City of Port Angeles PO Box 1150 321 East Fifth Street Port Angeles, WA 98362 RE. Water Filter Plant Dear Mr Pittis. Rayonier is in the last quarter c f the dismantling project for the former mill site. As agreed we delayed the dismant ing of the water filter plant located on the bluff above the mill to the end of the project so that the City could consider potential integration of the facility into the City's supply system. In our discussions so far it appears there is little potential for this to occur So that our Contractor may meet their obligations I will be releasing the water filter plant facility to them on September 21 to begin their salvage work. Dismantling of the concrete structures and filter plant buildings will commence shortly after the salvage is completed and will be finished by the end of the year If you have any questions please call me at 360 457 -2442. Sincerely, 2,6 Paul F Perlwitz Environmental Site Manager cc Chris Anderson, Port of Port Angeles Lou Haehnlen, City Buildr ig Official 00 Nor h Ennis Port Angeles WA 98362 Telephone (360) Ltzr 3391 Fax (360) 457 -24138 Special Pulp Products Port Angeles Mill Polaris Engineering Surveying, Inc. 206 South Lincoln Street, Suite 201 Port Angeles, Washington 98362 (360) 452 -5393 FAX. (360) 457 -9319 Daily Inspection Report 27 Contractor -1i. GO Page 1 of Job Q17 Week Day /,,m:A.1 r 64'1 Date )2 .4ua,5 y /99)R Job Site Description 1 hil c. 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Chapter 173 -303 WAC DANGEROUS WASTE REGULATIONS WAC 173- 303 -010 Purpose. 173- 303 -016 Identifying solid waste. 173 -303 -017 Recycling processes involving solid waste. 173 -303 -020 Applicability 173- 303 -030 Abbreviations. 173- 303 -040 Definitions. 173- 303 -045 References to EPA s hazardous waste and permit regu- lations. 173- 303 -050 173- 303 -060 173 -303 -070 173- 303 -071 I73- 303 -072 173- 303 -073 173- 303 -075 173- 303 -080 I73- 303 -081 173- 303 -082 173- 303 -083 173- 303 -084 173- 303 -090 173- 303 -100 173- 303 -101 173- 303 -102 173- 303 -103 173- 303 -104 173- 303 -110 173-303-120 173- 303 -121 173- 303 -130 173- 303 -140 173- 303 -141 173- 303 -145 173- 303 -150 173- 303 -160 173- 303 -161 173- 303 -170 173- 303 -180 173- 303 -190 173- 303 -200 173- 303 -20I 173- 303 -202 173- 303 -210 173- 303 -220 173- 303 -230 173- 303 -240 173- 303 -250 173- 303 -260 173- 303 -270 173- 303 -280 173- 303 -281 173- 303 -282 173- 303 -283 173- 303 -290 173 303 -300 173- 303 -310 173- 303 -320 173- 303 -330 173- 303 -11S (10/19/95) Department of ecology cleanup authority Notification and iientification numbers. Designation of dangerous waste Excluded categories of waste. Procedures and b; ises for exempting and excluding wastes. Conditional exclu ;ion of special wastes. Certification of di.signation. Dangerous waste lists. Discarded chemic al products. Dangerous waste >ources. Deletion of certai i dangerous waste codes following equipment clt aning and replacement. Reserved. Dangerous waste iiharacteristics. Dangerous waste :riteria. Reserved. Reserved. Reserved. Generic dangerous waste numbers. Sampling and testing methods. Recycled, reclaimed, and recovered wastes. Reserved. Containment and control of infectious wastes. Land disposal restrictions. Treatment, storage, or disposal of dangerous waste. Spills and discharges into the environment. Division, dilution, and accumulation. Containers. Overpacked containers (labpacks). Requirements for generators of dangerous waste. Manifest. Preparing dangerous waste for transport. Accumulating dangerous waste on -site. Special accumulation standards. Special requirements for generators of between two hundred twenty and two thou: and two hundred pounds per month that accum [late dangerous waste in tanks. Generator recordkeeping. Generator reporting. Special conditions. Requirements for transporters of angerous waste. Dangerous waste acceptance, tran ;port, and delivery Transporter recordkeeping. Discharges during transport. General requirements for dangero is waste management facilities. Notice of intent. Siting criteria. Performance standards. Required notices. General waste analysis. Security General inspection. Personnel training. Construction quality assurance prigram. 173 -303 -340 173- 303 -350 173 -303 -355 173 -303 -360 173 -303 -370 173- 303 -380 173- 303 -390 173- 303 -395 173- 303 -400 173- 303 -430 173- 303 -440 173- 303 -500 173- 303 -505 173- 303 -506 173- 303 -510 173- 303 -515 173- 303 -520 173- 303 -525 173- 303 -550 173- 303 -560 173- 303 -575 173 303 -600 173- 303 -610 173- 303 -620 173 303 -630 173- 303 -640 173 303 -645 173- 303 -646 173- 303 -650 173- 303 -655 173- 303 -660 173- 303 -665 173 303 -670 173- 303 -675 173- 303 -680 173- 303 -690 173- 303 -691 173- 303 -695 173- 303 -700 173- 303 -800 173- 303 -801 173- 303 -802 173- 303 -804 173- 303 -805 173 303 -806 173 303 -807 173- 303 -808 173- 303 -809 173- 303 -810 173 303 -815 173 303 -820 173 -303 -825 173- 303 -830 173- 303 -840 Preparedness and prevention. Contingency plan and emergency procedures. Superfund Amendments and Reauthorization Act Title 111 coordination. Emergencies. Manifest system. Facility recordkeeping. Facility reporting. Other general requirements. Interim status facility standards. Reserved. Reserved. Recycling requirements for state -only dangerous waste. Special requirements for recyclable materials used in a manner constituting disposal. Special requirements for the recycling of spent CFC or HCFC refrigerants. Special requirements for dangerous wastes burned for energy recovery Special requirements for used oil burned for energy recovery Special requirements for reclaiming spent lead acid battery wastes. Special requirements for recyclable material utilized for precious metal recovery Reserved. Reserved. Reserved. Final facility standards. Closure and postclosure. Financial requirements. Use and management of containers. Tank systems. Releases from regulated units. Corrective action. Surface impoundments. Land treatment. Waste piles. Landfills. Incinerators. Drip pads. Miscellaneous units. Air emission standards for process vents. Air emission standards for equipment leaks. Containment buildings. Requirements for the Washington state extremely hazardous waste management facility at Hanford. Permit requirements for dangerous waste management facilities. Types of dangerous waste management facility per mits. Permits by rule. Emergency permits, interim status permits. Final facility permits. Trial burns for dangerous waste incinerator final facili- ty permits. Demonstrations for dangerous waste land treatment final facility permits. Research, development and demonstration permits. General permit conditions. Reserved. Reserved. Reserved. Permit changes. Procedures for decision making [Ch. 173 -303 WAC —p. 1) (iii) Dangerous waste that is removed from on site storage (8) Small ouantitv generators. (a) A person is a small quantity generator and subject to the requirements of this subsection if (i) Their waste is dangerous waste under subsection (3) of this section and the quantity of waste generated per month (or the aggregated quantity if morel than one kind of waste is generated) does not equal or exceed the quantity exclusion limit (QEL) for such waste (or wastes) as de scribed in WAC 173- 303 070(7) and (ii) The quantity accumulated or stored does not exceed 2200 pounds for wastes with a 220 pound QEL and 2 2 pounds for waste with a 2.2 pound QEL. (Exception The accumulation limit for the acute hazardous wastes described in WAC 173 303 -081 (2)(iv) is 220 lbs) and (iii) The total quantity of dangerous waste generated in one month, all DW and EHW regardless oft their QELs, does not equal or exceed 220 pounds. If a person generates any dangerous wastes that exceed the QEL or accumulates or stores waste that exceeds the accumulation limits, then all dangerous waste generated, accumulated, or stored by that person is subject to the requirements of this chapter A small quantity generator who generates in excess of the quantity exclusion limits or accumulates, or stores waste in excess of the accumulation limits becomes subject to the full requirements of this chapter and cannot again be a small quantity generator until after all dangerous waste on -site at the time he or she became fully regulated have been re moved, treated, or disposed. Example. If a person generates four pounds of an acute hazardous waste discarded chemical product (QEL is 2.2 pounds) and 200 pounds of an ignitable w (QEL is 220 pounds), then both wastes are fully regulated, and the person is not a small quantity generator for either waste. (Comment: If a generator generates acute hazardous waste in a calendar month in quantities greater than the QELs all quantities of that acute hazardous waste are subject to full regulation under this chapter 'Full regula- tion means the regulations applicable to generators of greater than 2200 pounds of dangerous wastes in a calendar month.) (b) Small quantity generators will not be subject to the requirements of this chapter if they (i) Designate their waste in accordance with WAC 173 303 -070 and (ii) Manage their waste in a way that does not pose a potential threat to human health or the environment, and (iii) Either treat or dispose of their dangerous waste in an on -site facility or ensure delivery to an off -site facility either of which is. (A) Permitted (including permit -by -rule, interim status, or final status) under WAC 173 303 -800 through 173-303 840 (B) Authorized to manage dangerous waste by another state with a hazardous waste program approved under 40 CFR Part 271 or by EPA under 40 CFR Part 270 (C) Permitted to manage moderate risk waste under chapter 173 -304 WAC (Minimum functional standards for solid waste handling), operated in accordance with state and local regulations, and consistent with the applicable local (10/19/95) Dangerous Waste Regulations 173 303 -070 hazardous waste plan that has been approved by the depart ment; (D) A facility that beneficially uses or reuses or legitimately recycles or reclaims the dangerous waste, or that treats the waste prior to such recycling activities (E) Permitted to manage municipal or industrial solid waste in accordance with state or local regulations or in accordance with another state s solid waste laws if the waste is sent out -of- state, or (F) A publicly owned treatment works (POTW) provid ed that small quantity generator(s) comply with the prove sions of the domestic sewage exclusion found in WAC 173 303 -071 (3)(a) and (iv) Submit an annual report in accordance with WAC 173- 303 -220 if they have obtained an EPA/state identifica- tion number pursuant to WAC 173- 303 -060 (c) If a small quantity generator s wastes are mixed with used oil the mixture is subject to WAC 173- 303 -510 if it is destined to be burned for energy recovery Any material produced from such a mixture by processing blending or other treatment is also regulated if it is destined to be burned for energy recovery [Statutory Authority Chapters 70 105 and 70.105D RCW 95 -22 -008 (Order 94 -30), 173- 303 -070, filed 10/19/95. effective 11/19/95 94 -01 -060 (Order 92 33), 173- 303 -070, filed 12/8/93, effective 1/8/94 Statutory Authority Chapter 70.105 RCW 93 -02 -050 (Order 92 32), 173 -303 -070, filed 1/5/93, effective 2/5/93 Statutory Authority Chapters 70 105 and 70 105D RCW 40 CFR Part 271.3 and RCRA 3006 (42 U.S.C. 3251). 91 -07 -005 (Order 90 -42), 173- 303 -070. filed 3/7/91 effective 4/7/91 Statutory Authority Chapter 70.105 RCW 89 -02 -059 (Order 88 -24), 173- 303 -070, filed 1/4/89 87 14 -029 (Order DE- 87-4), 173- 303 -070, filed 6/26/87 86 -12 -057 (Order DE- 85 -10), 173- 303 -070, filed 6/3/86. 84 -14- 031 (Order DE 84 -22), 173- 303 -070, filed 6/27/84 Statutory Authority Chapter 70.105 RCW and RCW 70.95.260. 82 -05 -023 (Order DE 81 33). 173- 303 -070, filed 2/10/82.] WAC 173- 303 -071 Excluded categories of waste. (1) Purpose. Certain categories of waste have been excluded from the requirements of chapter 173 -303 WAC, except for WAC 173- 303 -050, because they generally are not dangerous waste, are regulated under other state and federal programs, or are recycled in ways which do not threaten public health or the environment. WAC 173 303 -071 describes these excluded categories of waste. (2) Excluding wastes Any persons who generate a common class of wastes and who seek to categorically exclude such class of wastes from the requirements of this chapter must comply with the applicable requirements of WAC 173 303 -072. No waste class will be excluded if any of the wastes in the class are regulated as hazardous waste under 40 CFR Part 261 (3) Exclusions. The following categones of waste are excluded from the requirements of chapter 173 -303 WAC, except for WAC 173 303 -050, 173 303 -145 and 173 -303- 960, and as otherwise specified (a)(i) Domestic sewage and (it) Any mixture of domestic sewage and other wastes that passes through a sewer system to a publicly owned treatment works (POTW) for treatment provided. (A) The generator or owner /operator has obtained a state waste discharge permit issued by the department, a tempo- rary permit obtained pursuant to RCW 90 48 200 or pre treatment permit (or written discharge authorization) from a [Ch. 173 -303 WAC —p. 17] 173 303 -071 Dangerous Waste Regulations local sewage utility delegated pretreatment pro dram responsi- bilities pursuant to RCW 90 48 165 (B) The waste discharge is specifically authorized in a state waste discharge permit, pretreatment permit or written discharge authorization, or in the case of a temporary permit the waste is accurately described in the permit application (C) The waste discharge is not prohibited under 40 CFR Part 403.5 and (D) The waste prior to mixing with domestic sewage must not exhibit dangerous waste characteristics for igmtability corrosivity reactivity or toxicity, as defined in WAC 173 303 -090 and must not meet the dangerous waste criteria for toxic dangerous waste or persistent dangerous waste under WAC 173 303 -100 unless the waste is treatable in the publicly owned treatment works (POTA) where it will be received This exclusion does not apply to the genera- tion, treatment, storage, recycling, or other management of dangerous wastes prior to discharge into the sanitary sewage system (b) Industrial wastewater discharges that are point source discharges subject to regulation under Section 402 of the Clean Water Act. This exclusion does not apply to the collection, storage, or treatment of industrial waste waters prior to discharge, nor to sludges that are generated during industrial wastewater treatment Owners or operators of certain wastewater treatment facilities managing dangerous wastes may qualify for a permit -by -rule pursuant to WAC 173- 303 802(5) (c) Household wastes including household waste that has been collected, transported, stored, or disposed. Wastes which are residues from or are generated by the management of household wastes (e g leachate, ash from burning of refuse derived fuel) are not excluded by this provision 'Household wastes means any waste matei1ial (including, but not limited to garbage, trash, and sanitary wastes in septic tanks) derived from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day -use recreation areas) (d) Agricultural crops and animal manures which are returned to the soil as fertilizers (e) Asphaltic materials designated only for the presence of PAHs by WAC 173- 303 100(6) For the purposes of this exclusion, asphaltic materials means materials intended and used for structural and construction purposes (e.g roads, dikes, paving) which are produced from mixtures of oil and sand gravel, ash or similar substances, (f) Roofing tars and shingles, except that these wastes are not excluded if mixed with wastes listed in WAC 173- 303 081 or 173 303 -082 or if they exhibit any of the characteristics specified in WAC 173 303 -090• (g) Treated wood waste and wood products including: (i) Arsenical treated wood that fails the test for the toxicity characteristic of WAC 173- 303 090(8) (dangerous waste numbers D004 through D017 only), or which fails any state criteria, if the waste is generated by persons who utilize the arsenical treated wood for the materials' intended end use. (ii) Wood treated with other preservatives provided such treated wood is within one hundred eighty days after becoming waste. [Ch. 173 -303 WAC -p. 18] (A) Disposed of at a landfill that is permitted in accordance with WAC 173 304 -460 minimum functional standards for solid waste handling, or chapter 173 -351 WAC, criteria for municipal solid waste landfills, and provided that such wood is neither a listed waste under WAC 173 303- 9903 and 173- 303 -9904 nor a TCLP waste under WAC 173- 303- 090(8) or (B) Sent to a facility that will legitimately treat or recycle the treated wood waste, and manage any residue in accordance with that state s dangerous waste regulations, or (C) Sent off -site to a permitted TSD facility or placed in an on -site facility which is permitted by the department under WAC 173- 303 -800 through WAC 173- 303 -845 In addition, creosote treated wood is excluded when burned for enerev recovery in an industrial furnace or boiler that has an order of approval issued pursuant to RCW 70.94.152 by ecology or a local air pollution control authority to burn creosote treated wood. (h) Irrigation return flows, (i) Materials subjected to in situ mining techniques which are not removed from the ground during extraction (j) Mining overburden returned to the mining site (k) Polychlorinated biphenyl (PCB) wastes (i) PCB wastes whose ai_sposal is regulated by EPA under 40 CFR 761 60 (Toxic Substances Control Act) and that are dangerous either because (A) They fail the test for toxicity characteristic (WAC 173- 303 090(8), Dangerous waste codes D018 through D043 only) or (B) Because they are designated only by this chapter and not designated by 40 CFR Part 261 are exempt from regulation under this chapter except for WAC 173- 303 -505 through 173- 303 -525 173 303 -960, those sections specified in subsection (3) of this section, and 40 CFR Part 266 (ii) Wastes that would be designated as dangerous waste under this chapter solely because they are listed as W001 under WAC 173- 303 -9904 when such wastes are stored and disposed in a manner equivalent to the requirements of 40 CFR Part 761 Subpart D for PCB concentrations of 50 ppm or greater (1) Samples (1) Except as provided in (I)(ii) of this subsection a sample of solid waste or a sample of water soil or air which is collected for the sole purpose of testing to deter mine its characteristics or composition, is not subject to any requirements of this chapter when (A) The sample is being transported to a lab for testing or being transported to the sample collector after testing, or (B) The sample is being stored by the sample collector before transport, by the laboratory before testing, or by the laboratory after testing prior to return to the sample collec tor or (C) The sample is being stored temporarily in the laboratory after testing for a specific purpose (for example, until conclusion of a court case or enforcement action) (ii) In order to qualify for the exemptions in (1)(i) of this subsection, a sample collector shipping samples to a labora- tory and a laboratory returning samples to a sample collector must. (A) Comply with United States Department of Transpor tation (DOT), United States Postal Service (USPS), or any other applicable shipping requirements, or (10/19/95) (B) Comply with the following requirements if the sample collector determines that DOT or USPS or other shipping requirements do not apply (I) Assure that the following information accompanies the sample (AA) The sample collector s name, mailing address. and telephone number (BB) The laboratory s name mailing address and telephone number (CC) The quantity of the sample (DD) The date of shipment; (EE) A description of the sample. and (II) Package the sample so that it does no leak, spill or vaporize from its packaging. (iii) This exemption does not apply if the laboratory determines that the waste is dangerous but the is no longer meeting any of the conditions stated in (1)(i) of this subsection (m) Asbestos wastes or asbestos containing wastes which would be designated only as respiratory carcinogens by WAC 173 303 -100, and any other inorganic wastes which are designated only under WAC 173- 303 -100 because they are respiratory carcinogens, if these wastes are managed in compliance with or in a manner equivalent to the asbestos management procedures of 40 CFR Part 61 (n) Dangerous waste generated in a product or raw material storage tank, a product or raw material transport vehicle or vessel a product or rhw material pipeline, or in a manufacturing process unit or an associated nonwaste treatment manufacturing unit until it exits the unit in which it was generated. This exclusion does not apply to surface impoundments, nor does it apply if the dangerous waste remains in the unit more than ninety days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials, (o) Waste pickle liquor sludge generated by lime stabilization of spent pickle liquor from the iron and steel industry (SIC codes 331 and 332), except that these wastes are not excluded if they exhibit one or more of the danger ous waste criteria (WAC 173 303 -100) or characteristics (WAC 173 303 -090) (p) Wastes from burning any of the mate>ials exempted from regulation by WAC 173 303 -120 (2)(a)(v) (vi), (vii) (viii), or (ix). These wastes are not excluded if they exhibit one or more of the dangerous waste characteristics or criteria, (q) As of January 1 1987 secondary materials that are reclaimed and returned to the original process or processes in which they were generated where they are reused in the production process provided. (i) Only tank storage is involved, and the entire process through completion of reclamation is closed by being entirely connected with pipes or other comparable enclosed means of conveyance; (ii) Reclamation does not involve controlled flame combustion (such as occurs in boilers, industrial furnaces, or incinerators); (iii) The secondary materials are never accumulated in such tanks for over twelve months without being reclaimed, (iv) The reclaimed material is not used to produce a fuel, or used to produce products that are used in a manner constituting disposal and (10/19/95) Dangerous Waste Regulations 173 303 -071 (v) A generator complies with the requirements of chapter 173 -303 WAC for any residues (e.g. sludges, filters, etc.) produced from the collection, reclamation, and reuse of the secondary materials. (r) Treatability study samples. (i) Except as provided in (r)(li) of this subsection persons who generate or collect samples for the purpose of conducting treatability studies as defined in WAC 173 -303- 040 are not subject to the requirements of WAC 173 301 180 173 303 -190 and 173 303 200 (1)(a) nor are such samples included in the quantity determinations of WAC 173 -303 -070 (7) and (8) and 173- 303 -201 when (A) The sample is being collected and prepared tor transportation by the generator or sample collector or (B) The sample is being accumulated or stored by the generator or sample collector prior to transportation to a laboratory or testing facility or (C) The sample is being transported to the laboratory or testing facility for the purpose of conducting a treatability study or (D) The sample or waste residue is being transported back to the original generator from the laboratory or testing facility (ii) The exemption in (r)(i) of this subsection is applica- ble to samples of dangerous waste being collected and shipped for the purpose of conducting treatability studies provided that: (A) The generator or sample collector uses (in 'treatabil- ity studies no more than 10,000 kg of media contaminated with nonacute dangerous waste 1000 kg of nonacute dangerous waste other than contaminated media, 1 kg of acutely hazardous waste, 2500 kg of media contaminated with acutely hazardous waste for each process being evaluat ed for each generated waste stream and (B) The mass of each sample shipment does not exceed 10,000 kg; the 10,000 kg quantity may be all media contami- nated with nonacute dangerous waste or may include 2500 kg of media contaminated with acute hazardous waste, 1000 kg of dangerous waste, and 1 kg of acutely hazardous waste, and (C) The sample must be packaged so that it will not leak, spill, or vaporize from its packaging during shipment and the requirements of (r)(ii)(C)(I) or (II) of this subsection are met. (1) The transportation of each sample shipment complies with United States Department of Transportation (DOT) United States Postal Service (USPS), or any other applicable shipping requirements, or (II) If the DOT USPS or other shipping requirements do not apply to the shipment of the sample, the following information must accompany the sample: (AA) The name, mailing address, and telephone number of the originator of the sample, (BB) The name, address, and telephone number of the laboratory or testing facility that will perform the treatability study (CC) The quantity of the sample; (DD) The date of shipment; and (EE) A description of the sample, including its danger ous waste number (D) The sample is shipped, within ninety days of being generated or of being taken from a stream of previously [Ch. 173 -303 WAC —p. 19 AUG 12 98 10 08 FR ECOLOGY ENUIRONMENT206 621 9832 TO 1360457243E P 01/12 ?fsF DATE 4,4 -f‹ 4�F 8 /2/98 JOB CHARGE. /D_ ,6 932 T4. �-Xf TO /ate/ -Zr CONIP.-t: \Y FAX NUMBER. 3 Q L) 7 L/3 IESSAGE. ecology and environment, inc. International Specialists in the Environment 1500 First Interstate Center 999 Third Avenue Seattle, Washington 95104 Telephone: 206 624-9537 Fax: 206=621 -9832 FAX FORM TIME. M0.0 TOTAL NUMBER OF PAGES. J� (iactnda Cava Pa FROM. //e)Cc s f 4 kt-if Zdkg f( a f 1 742 X 705 RUG 12 98 10 08 FR ECOLOGY ENU I RONMENT206 621 9832 TO 1360457243E ecology and environment, inc. Iriu,rn:,tiOn:,l Spr;rialists in the Environment 1500 First Interstate Center 999 Third Avenue Seattle. Washington 98104 T4.71: (206) 624 -9537 Fax: (206) 621 -9832 DATE. January 21, 1998 TO Alexis Naikntmb i lkar, Project Manager, E E, Seattle, WA FROM. Mark Woodke, Chemist, E E, Seattle, WA 07 r( THRU Chris Slansky Chemist, E E, Seattle, WA 6,10A0 SUBJ Organic Data Quality Assurance Review, Rayonier Pulp Mill Site, Port Angeles, Washington REF TDD 97 -04 -0003 PAN BD030ITGDM The data quality assurance review of two tile/mortar samples, four wood samples, and seventeen concrete samples, collected from the Rayonier Pulp Mill site in Port Angeles, Washington, has been completed. Toxicity Characteristic Leaching Procedure (TCLP EPA Method 1311) extractions and Volatile Organic C (VOC) analyses (EPA Method 8260B) were performed by Sound Analytical Services, Inc., Tacoma, Washington. The samples were numbered: VOCs (Modified EPA Method 8260B1 Concrete 97120726 MEMORANDUM Halogenated VOCs (Modified FPA_Vetltod 8260B1 Wood- 97120705 97120706 97I20707 97120708 Concrete- 97120709 97120718 97120719 97120720 97120722 Tile/Mortar 97120701 TCLP (EPA Method 11W VOC(Mndified EPA Method 8260B1 Tile/Mortar- 97120701 97120702 Wood- 97120705 97120706 97120707 97120708 Concrete- 97120709 97120710 97120711 97120712 97I20713 97120714 97120715 97120716 97120717 97120718 97120719 97120720 97120721 97120722 97120723 97120724 97120725 P 02/12 RUG 12 98 10 88 FR ECOLOGY ENUIRONMENT206 621 9832 TO 1360457243E SOUND ANALYTICAL SERVICES, INC Client Name Client 10 Lab ID Date Received: Date Prepared: Date Analyzed: Solids Ecology Environment 97120705 69487 -05 12/17/97 12/23/97 12/24/97 TCLP Volatile Organics List by USEPA Method 5030/8260B Modified Surrogate Recovery Dibromofluoromethane 93 08- Toluene 104 Bromofluorobenzene 106 Result Analyte (mg/L) PQL Vinyl Chloride ND 0.2 U 1 1- Dichloroethene ND 0.2 2- Butanone NO 0.2 Chloroform ND 0.2 Carbon Tetrachloride ND 0.2 Benzene ND 0.2 1,2- Dichloroethane ND 0.2 Trichtoroethene ND 0.2 Tetrachloroethene ND 0.2 Chlorobenzene ND 0 2 V (if V P 03/12 Recovery Limits Flags Low High 80 131 65 117 65 130 Flags RUG 12 98 10 09 FR ECOLOGY ENUIRONMENT206 621 9832 TO 1360457243E P 04/12 SOUND ANALYTICAL SERVICES, INC Client Name Ecology Environment Client ID: 97120705 Lab ID: 69487 -05 Date Received: 12/17/97 Date Prepared: 12/22/97 Date Analyzed: 12/22/97 Solids 49.8 Halogenated Volatile Organics by. USEPA Method 82608 Modified Recovery Limits Surrogate Recovery Flags Low High Dibromofluoromethane 148 75 154 Toluene -d8 118 65 141 4- Bromofluorobenzene 146 82 157 Sample results are on a dry weight b psis. Result Analyte (ug/kg) PQL 1 Chloromethane ND 180 1. Bromomethane ND 180 Vinyl Chloride ND 180 Chloroethane ND 180 Trichlorofluoromethane ND 180 1 1- Dichloroethene ND 180 Methylene Chloride ND 180 trans -1.2- Dichloroethene ND 180 1 1- Dichloroethane ND 180 cis -1,2- Dichloroethene ND 180 Chloroform ND 180 1 1 1- Trichloroethane ND 180 Carbon Tetrachlonde ND 180 1.2- Dichloroethane ND 180 Trichloroethene ND 180 1 ,2 Dichloropropane ND 180 8romodichloromethane ND 180 J 2- Chloroethyl Vinyl Ether ND 8801( k cis- 1.3- Dichloropropene ND 180 T trans -1,3- Dichloropropene ND 180 1 1,2- Trichioroethane ND 180 Tetrachloroethene ND 180 Dibromochioromethane ND 180 Chlorobenzene ND 180 Bromoform ND 180 t r d/ 1 1,2,2 Tetrachloroethane NO 180 7 1(rAi Flags RUG 12 98 10 09 FR ECOLOGY ENUIRONMENT206 621 9632 TO 1360457243E P 05/12 SOUND ANALYTICAL SERVICES, INC Halogenated Volatile Organics by USEPA Method 82608 Modified data for 69487 -05 continued. Result Analyte (ug /kg) 1,3- Dichtorobenzene ND 1 4- Dichlorobenzene ND 1,2- Dichlorobenzene ND PQL r 180 VO 180 180+J Flags AUG 12 98 10 09 FR ECOLOGY ENUIRONMENT206 621 9832 TO 13604572438 P 06/12 ecology and environment, inc. International Specialists in the Environment 1500 First Interstate Center 999 Third Avenue Seattle Washington 98104 Tel: (206) 624-9537 Fax: (206) 62 -9832 MEMORANDUM DATE. February 18, 1998 TO- Alexis Naikntmbal i ar, Project Manager E E, Seattle, WA FROM. Christine Slansky, START Chemist, E E, Seattle, WA CAP" .....5 THRU Mark Woodke, START Chemist, E E, Seattle, WA VI 9V SUB! Organic Data Quality Assurance Review, Rayonier Pulp Mill Site, Port Angeles, WA REF TDD 97 -04 -0003 PAN BD0301TGDM The data quality assurance review of 17 concrete, 4 wood, and 2 tile/mortar samples collected from the Rayonier Pulp Mill site in Port Angeles, Washington, has been completed. Toxicity Characteris- tic Leaching Procedure (TCLP EPA Method 1311) extraction and Semivolatile Organic Compounds (SVOC, EPA Method 8270) analyser were performed by Sound Analytical Services, Inc., Tacoma, WA. The samples were numbered. TCLP /SVOC. 9712070I 97120702 97120705 97120706 97120707 97120708 97120709 97120710 971207I1 97120712 97120713 97120714 97120715 97120716 97120717 97120718 97120719 97120720 97120721 97120722 97120723 97120724 97120725 SVOC only- 97120701 97120705 97120706 97120707 97120708 97120709 97120718 97120719 97120720 97120722 Data Oualifications: 1 Sample -Holding Times: Acc^ptable. The samples were maintained at 4 °C 2 °C). The samples for TCLP /SVOC were collected between December 10 and 16, 1997 yere extracted for TCLP December 19, 1997, were extracted for analysis between December 22 and 23, I997, and were analyzed by December 24 1997 Therefore, the QC cntena were met of less than 14 days between collection and TCLP extraction, less than 7 days between TCLP and Preparative extractions, and less than 40 days between final extraction and analysis. The samples for SVOCs only were collected between December 10 and I6, 1997, were extracted December 19 1997 and were analyzed December 20, 1997 therefore meeting the QC cnteria of less than 14 days between collection and extrac and less than 40 days between extraction and analysis. Soil criteria were applied to these matrtctes in the absence of specific criteria for concrete, wood, and tile/mortar AUG 12 98 10 10 FR ECOLOGY ENUIRONMENT206 621 9E32 TO 1360457243E P 07/12 SOUND ANALYTICAL SERVICES, INC Client Name Ecology Environment Client ID 97120705 Lab ID 69487 -05 Date Received: 12/17/97 Date Prepared: 12/19/97 Date Analyzed: 12/20/97 Solids 49.8 Semivolatile Organics by USEPA Method 8270 Surrogate Recovery Nitrobenzene d5 62 2 Fluorobiphenyt 74 p Terphenyl d14 145 Sample results are on a dry weight bi sis. Recovery Limits Flags Low High 23 120 30 115 X9 18 137 Result Anatyte (ug /kg) PQL Flags Naphthalene 210000 4200 2- Methytnaphthalene 1100000 4200 2- Chloronaphthalene ND U 420 Acenaphthylene ND CA 420 Acenaphthene 91000 4200 Fluorene 180000 4200 Phenanthrene 570000 4200 Anthracene 51000 420 Gar' Fluoranthene 16000 420 Pyrene 55000 420 Benzo(a)anth:acene 2000 420 Chrysene 2300 420 Benzo(b)fluoranthene 920 420 Benzo(Ic)fluoranthene 460 420 Benzo(a)pyrene ND L( 420 Indeno(1,2.3- cd)pyrene ND 420 Dibenz(a,h)anthracene ND 420 Benzo(g.h,i)perylene ND \J 420 AUG 12 98 10 10 FR ECOLOGY a ENUIRONMENT206 621 9932 TO 13604572438 P 08/12 Surrogate Nitrobenzene d5 2 Fluorobiphenyl p Terphenyl d14 Phenol d5 2 Ftuorophenol 2,4,6 Tribromophenol SOUND ANALYTICAL SERVICES, INC Client Name Client ID Lab ID Date Received: Date Prepared: Date Analyzed: Solids Recovery 51 49 53 72 86 44 Result Analyte (m9 /L) 1 4-Dichlorobenzene ND 2- Methylphenol ND 3- 4- Methylphenot ND Hexachloroethane ND Nitrobenzene ND Hexachlorobutadiene ND 2.4,6- Trichlorophenol ND 2.4.5- Trichlorophenol ND 2.4- Dinitrotoluene ND Hexachlorobenzene ND Pentachlorophenol 12 Pyridine ND Ecology Environment 97120705 69487 -05 12117/97 12123197 12/23/97 TCLP Sem volatile Organics by USEPA Method 8270 Recovery Limits Flags Low High 19 131 14 139 51 121 11 123 22 137 13 150 PQL 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.5 0 005 Flags AUG 12 98 10 10 FR ECOLOGY g ENUIRONMENT206 621 9832 TO 13604572438 P 09/12 ecology and environment, inc. International Specialists in the Environment 1 500 First interstate Center 994, Third Avenue Seattle. Washington 98104 Tel: (206) 624 -9537 Fax: (206) 621 -9832 MEMORANDUM DATE. January 21, 1998 TO Alexis Naiknimbalkar Project Manager, E E, Seattle, WA FROM. Mark Woodke, Chemist, E E, Seattle, WAI V THRU- Chris Slansky, Chemist, E E, Seattle, WA S SUBJ Inorganic Data Quality Assurance Review, Rayonier Pulp Mill Site, Port Angeles, Washington REF TDD 97 -04 -0003 PAN BD0301TGDM The data quality assurance review of two tile/mortar samples, six wood samples, eighteen concrete samples, and one water sample, collected from the Rayonier Pulp Mill site in Port Angeles, Washington, has been completed. TCLP Inorganic analyses (EPA Method 6010) were performed by Sound Analytical Services, Inc., Tacoma, Washington. Not all samples were analyzed for all elements. The samples were numbered. Tile/Mortar 97120701 9712(1702 Wood 97120703 97120704 97120705 97120706 97120707 97120708 Concrete 97120709 97120710 97120711 97120712 97120713 97120714 97120715 9712016 97120717 97120718 97120719 97120720 97120721 97120722 97120723 97120724 97120725 97120726 Water 97120727 Iota Qualifications:, I Sample Holding Time: Acceptable. The samples were collected be I tween December 10, 1997, and December 16, 1997, and were analyzed by December 23, 1997, therefore meeting QC criteria of less than 28 days between collection and mercury analysis and less than 6 months between collection and analysis for all other analytes. II Initial and Continuing Calibration Acceptable. A calibration standard and blank were analyzed at the beginning of the analysis and after every 10 samples AI11CP initial and continuing I caiibration results were within QC limits of 90 to 110 4 RUG 12 98 10 10 FR ECOLOGY 1=NUIRONMENT2 621 9832 TO 13604572438 P 10/12 Lab Name SOUND ANALYTICAL SE.VICES Lab Code SAS Matrix (soil /water) Level (low /med) s Solids Color Before Color After Comments Concentration Units (ug/L or mg /kg dry weight) UG /L CAS No 0 0 7429 -90 -5 7440 -36 -0 7440 -38 -2 7440 -39 -3 7440 -41 -7 7440 -43 -9 7440 -70 -2 7440 -47 -3 7440 -48 -4 7440 -50 -8 7439 -89 -6 7439 -92 -1 7439 -95 -4 7439 -96 -5 7439 -97 -6 7440 -02 -0 7440 -09 -7 7782 -49 -2 7440 -22 -4 7440 -23 -5 7440 -28 -0 7440 -62 -2 7440 -66 -6 0000 -00 -0 1 INORGANIC ANALYSES DATA SHEET Case N.') N/A WATER LOW Anllyte Aiurriinum Antimony_ Arsenic Barium Beryllium Cadm "um Calcum Chro ium_ Coba t Copp .r Iron Lead Magn sium Mang nese Merc ry Nick 1 Pota sium Sele ium Silt' r Sodi m Thal ium Vanadium Zinc Mo lyt: denu U S EPA CLP Concentration C Q Clarity Before Clarity After Contract E&E SAS No 69487 SDG No 120701 Lab Sample ID 69487 -5 Date Received 12/17/97 FORM I IN 134 U 33 6 24 3 U 91 0 48 8 0r/ 1 7 U 378 U 7 4 U EPA SAMPLE NO 102705 Texture Artifacts ILMO2 1 AUG 12 98 10 11 FR ECOLOGY ENUIRONMENT206 621 9632 TO 13604572438 P 11/12 ecology and environment, inc. International Specialists in the Environment 1500 First Interstate Center 999 third Avenue Seattle, Washington 98104 Tel: (206) 624 -9537 Fax: (206) 621-9832 MEMORANDUM DATE. January 21, 1998 TO Alexis Naiknimbalkar, Project Manager, E E, Seattle, WA FROM. Mark Woodke, Chemist, E E, Seattle, WA Ph( THRU Chris Slansky, Chemi st, E E, Seattle, WA e SUBJ Data Quality Assurance Review, Rayonier Pulp Mill Site, Port Angeles, Washington REF TDD• 97 -04 -0003 PAN BD0301TGDM The data quality assurance rev of two tile /mortar samples, four wood samples, and seventeen concrete samples, collected from the Rayonier Pulp Mill site in Port Angeles, Washington, has been completed. Analyses for pH (EPA Method 9045) were performed by Sound Analytical Services, Inc., Tacoma, Washington. The samples were numbered. Tile/Mortar 97I20701 97120.T02 Wood 97120705 97120706 97120707 97120708 Concrete 97120709 97120710 97120711 97120712 97120713 97I20714 97120715 97120716 97120717 97120718 97120719 97120720 97120721 97120722 97120723 97120724 97120725 Dana Qualificatioiis; The samples were collected botween December 10 and 16, 1997, and were analyzed on December 23, 1997 The calibration itandard results were within 1 of the true values and the check standard results were within 10 of the true values. All pH results are acceptable in the reviewers' professional judgment. "e RUG 12 9E 10 11 FR ECOLOGY 8 ENUIRONMENT206 621 9632 TO 1360457243E SOUND ANALYTICAL SERVICES, INC ANALYSIS. ANATICAL de ENVIRONMENTAL CHEMISTS 4813 PACIFIC HIGHWAY EAST ACOMA. WASHINGTON 98624 TELEPHONE (233)922 -2310 FAX (253)922 -5047 Report To Ecology Environment Date December 23, 1997 Report On Analysis of Solid Report No 69487 IDENTIFICATION. Samples received on 12 -1" -97 Project KJ0102BD0301TG Lab Sample No. Client ID Result 69487 97120701 12 36 69487 -2 97120702 11 89 69487 -5 97120 "05 2 82 69487 -6 97120''06 2 47 69487 -7 9712007 6 44 65487-8 97120708 2 42 69487 -9 97120721 11 67 69487 -10 97120722 11 86 69487 -11 97120723 9 04 69=57 -12 97120724 8 75 69487 -13 97120725 12 02 69487 -16 97120709 12 32 69467 -17 97120710 12 07 ry 59487 -18 971207L1 12 01 69487-19 971207L2 11 61 --7_,Mg 69=87 20 97120763 11 87 --a•r, is udtpl s..!elr for the use if thr v.., pH Per EPA Method 9045 Date Analyzed 12 -23 -97 P 12/12 8 Polaris Engineering rnd Surveying, Inc 206 South Lincoln Street, Suit 201 Port Angeles Washington 98352 (360) 452 -5393 FAX. (360) 457 -9319 DATE July 20 1998 TO City of Port Angele:; ATTN Lou H FROM Tracy Gudgel We are transmitting the following item nAttached [Hand- carried EFAX. PROJECT Ravonier Mill Demolition COPIES PAGES DESCRIPTION 1 1 TCLP Lead Results for sample #25 from Water Treatment Plant COMMENTS fc: 97106 JOB NO 97106 ❑Under Separate Cover JUL 17 98 15 50 FR PTL/PS 206 282 0710 TO 13604579319 -6378 P 02/02 July 17, 1998 PSI Project No. 578 -7P099 PTL Project No. 9709 -7085 8 POLARIS ENGINEERING AND SURVEYING, INC. Subject: Results of TC LP Lead Content in Wood Chips From Rayonier Mill To Whom it May Concern. On July 15, 1998, the Chemist ry Department of PTL/PSI received one sample of wood chips for testing. The sample was labeled #25 and was from your Rayonier Mill demolition project. As you requested, the sample was tested to determine it's TCLP lead content. Results are provided in the following table No additional testing or consulting was requested. Lead was tested for in accords -ice with modified EPA methods 1311 and 6010 using a Thermo Jarrell Ash Atomscan 16 induc tively coupled plasma spectrometer (ICP). Sample Disclaimer Y Sample Received: 07/15198 Sample Extracted. 07/161 98 Sample Analyzed: 07/17198 RESULTS F OM THE ANALYSIS OF WOOD CHIP FOR TCLP LEAD MO IFIED EPA METHODS 1311 6010 Results Reported as mg(L (ppm) Sample ID Result 125 1 0.49 Quality Control Data Sample 1 Result Method Blank 1 <0 05 1 25 Duplicate 0.42 1 Spike Level 1.00 25 Matrix Spike Percent Recovery 96 25 Matrix Spike Duplicate Percent Recovery 86 li Relative Percent Difference 11 4. TOTAL PAGE 02 08/05/98 WED 10 34 FAX Reply To Attn Of: ECL -116 Dear Mr Perlwitz: UNITED STA TES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, Washington 98101 Certified Mail Return ReceizAgauested Paul F Perlwitz, Environmental Manager Rayonier Port Angeles Mill 700 North Ennis Port Angeles, WA 98362 July 20, 1998 As discussed last week, I am requesting wntten plans for the demolition of the Recovery Boiler building and the Main fa( ;fifty stack. It is requested that these plans include the various alternatives evaluated and the masons for selecting the preferred method of demolition. It is also requested that the written plans include methods of dust control, safety issues, and scheduling of the demoliti work. Please provide me the requested plans as soon as possible to allow for adequate time to r ew the proposed work prior to that work actually taking place. If you have any questioi s concerning my request, please feel free to call me directly at 206 553 -1671 cc: Dana B. Dolloff, Rayonter Garin Schrieve, WA State I ept. Of Ecology Sincerely, ai,./ /et Carl Kitz On -Scene Coordinator Polaris Engineering and Surveying, Inc. 206 South Lincoln Street, Suite ;?01 Port Angeles, Washington 9836 (360) 452 -5393 FAX. (360) 457 -9319 DATE June 30, 1998 TO City of Port Angeles Building Department ATTN Lou H FROM. Tracy Gudgel We are transmitting the following item. [Attached 25 Hand-carried ❑FAQ PROJECT Ravonier Mill Demolition COPIES PAGES DESCRIPTION 1 2 Inspection Reports 18 #19 1 1 Lab Transmittal for Wood Sample #25 COMMENTS JOB NO 97106 [Under Separate Cover Polaris Engineering Surveying, Inc. 206 South Lincoln Street, Suite 201 Port Angeles, Washington 98362 (360) 452 -5393 FAX. (360) 457 -9319 Contractor j Job `h 0 6n Week Day _/4„,3 Date t r Tuois .qg Job Site Description DIARY Weeedy Summary Report e9 iD r).19 -Si 1!z AV.19 i. /L !/t/ U- Yo.O �✓1 '1,,.,ad./I (PAUL t..�r �tw r f fu Z, e dM 41 r k &.4i li t r' 29 -?e L.) SIGNED° L Page 1 of LJ.a* I AA f4 S.,,. rf fat 4)4.2 e new 7a5.✓S f �C.�►4,... 1 L2.- 5,r,!\ r INSPECTOR %I,2ou�H 96,„r¢..r4 y9 bL1/ 1-✓) t4ik 7 AuI IA,A) 6 dt 1,.n ,4 c -44( A.66 •13 S t/i ai .P *t7■t QU/J2. S��' (4►aR i.�.1/S •�f f v[ "t 42t 5 1=,¢o vV1 74/ 4, 646, a_ e,vitL 64_ IyooQ, 4.sg Polaris Engineering Surveying, Inc. 206 South Lincoln Street, Suite 201 Port Angeles, Washington 98362 (360) 452 -5393 FAX. (360) 457 -9319 Contractor Job '7irD( Job Site Description &v,,t ,z DIARY er -5e 74 la7 l i!oD v. -ifs I v c� 7;ew t#.4 /1 ,ti, e /94Dei 114YSrLi 72,4G'Y fCA..44e 1 S4a4.P S ct/sA. ya Daily Inspection Report VVeek Day l %tY 1/- 664 Py )7/ Si J 02 r4 U 'v P..r f lz.tm s GEC' ,j 36 r. .6 SIGNED c redit". Page of Date 5 ry )99 n t) /»oon SAS fps s ,,2 N4(k nJ,.t PAckfwe (PAQ 1 J44i,r's t e c r 7'.�/ f(J 6.4 OPle 7;:.14,0 0,7.0 �k 411.-1 J.4c.. /7'/ C /i/I '✓1 /,,t) tJ.�i �'•i r�Jx �LCa J 1 l k S/f /A esP Sfej„ ✓K �.15�Zrc r9z�,f'!�4 S 72r A-5 ,A 4-r A S o6 LP/7' 0'U �K�% q 1 t (k l) r S k f !sQ/'vfrce,- 644-! 5)/ v Ellie LtJPt'•2 60/,, A__P 4. ,4 9 1 i5 Tavt) Ei cf^}✓2* 4 614 7 k iceiR 7 �f 7� ✓�j A t fK t 4 7, P-4x I 7 %a.. S Lao ic Co�sA nF NR42ln •4 1 5 ;14 L(.441) INSPECTOR Polaris Engineering and Stu veying, Inc. 206 South Lincoln Street, Suite 201 Port Angeles, W 98362 (360) 452 -5393 FAX. (360) 457 -9319 LAB SAMPLE TRANSMITTALS To 1,Dt Date: 6-30-78 Attention: :i i t...-iU Comments: From: Y iiJ4'ec Project: &Yi >i /iie /acc. SAMPLES SAMPLE SAMPLE TYPE, TEST TYPE OTHER JOB COMMENTS June 4, 1998 Dear Interest Citizen. Attached is the Department's; Public Participation Plan for a proposed Interim Action at Rayomer's Port Angeles mill site. According to the proposal, Rayomer would clean soils from the area contaminated 1►y leaks from the mill s "finishing room" machinery The purpose of this Plan is to ide atify points where your involvement can influence the cleanup project. Ecology welcomes your con ments and involvement. Our goal for this Plan is to provide timely project information, r icludmg opportunities for meaningful participation in the cleanup planning process. If you have suggestions for the Public Participation Plan, or questions about this Intenm Action project, please contact me m wasting or by phoning (360) 407 -6253 Ecology will consider all suggestions and respond to all contacts. Sincerely, arm Schneve, P.E. Site Manager STATE OF WASHINGTON DEPARTMENT OF ECOLOGY P.O. Boir 47600 Olympia, Washington 98504 -7600 (360) 407 -6060 TDD Only (Hearing Impaired) (360) 407 -6006 R ECEIVED JUN 09 1998 City of Port Angeles WASHINGTOT' STATE DEPARTMENT OF ECOLOGY PUBLIC PARTICIPATION PLAN RAYONIER MILL SITE FINISHING ROOM AREA INTERIM ACTION PORT ANGELES, WASHINGTON Introduction The Model Toxics Corftrol Act (MTCA) specifically authorizes the Department of Ecology to assure the dleanup of contaminated sites in Washington State. Under the MTCA, any current or past property owner or facility operator can be held legally and financially respons ible for cleanup of contamination discovered on their property The Potenti, illy Liable Person is obhgated to clean the site to a standard that is protective of human health and the environment. At the former Rayorue r Mill site m Port Angeles, two areas of contamination have been identified to date (1) One area, referred to as the "bunker oil contamination site Rayomer cleaned as far as was practicable m 1990. The cleanup involved removal of a 2.3 millli° a gallon tank and piping, and removal of contaminated soil from around the tank. Although Rayomer removed 1,500 cubic yards of soil from that area, some contan ated soil had to be left in place around utilities located there. (2) The other ea, referred to as the mill's "finishing room area requires cleanup of soils cons ated with hydraulic oil and polychlorinated biphenyl (PCB) This finishing room ar a contamination is the subject of a lmuted cleanup, called an Intenm Action. The Department of Ecology and Rayomer, Inc. are proposing to enter into an agreement— an "Agrekd Order providing for cleanup of the finishing room area. This Public Participation Plan describes the steps that Ecology and Rayomer will take to mvolve the community m decisions about the methods and processes for addressing that contan unanon. Mill Facility Backgrolund Port Angeles is located on the northeast portion of the Olympic Peninsula, along the southern shoreline of Fort Angeles Harbor The former Rayoruer mill site covers approxunately 70 acres all within the city hnuts, straddling the mouth of Ennis Creek. Entry to the site is from Front Street (Highway 101) at 400 North Ennis Street. The site is currently zoned 1 or mdustnal uses and is bordered on the south by residential and commercial properties. The mill facility was originally constructed in the late 1920's. Rayomer operated the pulp mill from the ear y 1930's until its closure in February 1997 The mill used an ammonia -based acid s ilfite process to produce dissolving -grade pulps for the specialty pulp market. With additional processing, the buyers incorporated the pulp into items such as phc tographic film and paper; high impact plastics for tool handles or dishes; fabnc, yam, and synthetic leather; and absorbent products such as filters and disposable diaper: Rayonier Mill Site at Port Angel( s Interim Acton 1 The Finishing Roon i Area The finishmg room c ntained large hydraulic presses used for preparing product for shipment. Dunng pul mill operations these presses leaked hydraulic oil (some in contamated with PC onto the soil underneath the building, which eventually seeped mto Eruus Cre The release of hydraulic oil was discovered by Ecology in May 1989 In 1990 Rayoruer completed a site study and installed a system consisting of three wells and a pump with which it recovered oil om the ground. This recovery system was only partially successful m control/3 the seepage of oil into the creek. In 1991 Ecology and R.ayonier began negotiations on an Agreed Order designed to more fully address the slung room contamination. After Ecology and Rayomer were unable to reach agre ent on the terms of an Agreed Order, Ecology issued an Enforcement Order E 92TCIO29) directing Rayomer to address the contamination. In response to the ord r Rayonier mstalled a new system consisting of a steel "sheet pile" wall and a trench quipped with sumps to collect oil and contaminated groundwater and to pr ent seepage into the creek. This system has been successful m controlling the oil seep ige. While the direct flow o f oil into the creek has been stopped, contaminated soils and groundwater remain under the fuushmg room. Studies conducted by Rayomer in 1997 indicate that the area iripacted by PCBs and hydraulic oil is approximately 100 feet by 200 feet. With the mill structures removed, the remaining contaminanon will be accessible for cleanup. Ecology wants to see the contamination cleaned up, to prevent additional migration of contaminants to the creek— especially now that the finishing room area will be expo sed to the weather Rayomer Mill at Port Angeles Proposed Interim Action The MTCA rule authcnzes Ecology to require cleanup of a portion of a site whenever the protection of human and environmental health demands. In order to require a cleanup under WAC 173 340 -430, Ecology and the property owner/ operator must enter into a legally enforceable agreement for conducting the cleanup. An Agreed Order is th e admuustrative agreement typically used to implement interim actions; it specifies the standard for the cleanup. The proposal for the Layomer finishing room interim action will consist of several parts. The first part is the Agreed Order itself. The second part of the proposal is a work plan describmg in detail the specific activities that will accomplish the cleanup. Finally, the proposal n Lust also mclude a Determination under the State Environmental Policy Act (SEPA) regarding the environmental impact of the proposed cleanup actic al, and a copy of the SEPA Checklist for the project. I,dx,,,,ACnat 2 Ecology is reviewing Zayonier's proposal for cleanup of the finishing room area to determine whether it meets the requirements of the MTCA. If there are deficiencies m the proposal, Ecology will provide specific wntten comments from which the two parties can work tow rd an agreement. Public Involvement Once completed to E cology's and Rayoruer's satisfaction, the cleanup proposal and related documents will be available for viewing at the Infannatzon Reposztones in reference centers of ti ie Port Angeles branch of the North Olympic Library System (see reference librana L Peggy Noms) and the Peninsula College Library (see Nancy McDonald) Advertis ements announcing the proposal s availability will be published m the Peninsula Daily i VIews and m the Sequzm Gazette A Fact Sheet summarizing the proposal and mvrung public comment will be sent to the persons and organizations on our mailing hst. A notice of the proposal's availabihty will also be published in Ecology s Sue Register, a bi- weekly listing of site status reports and MTCA activities. Upon publication of t Interim Action proposal, Ecology will observe a 30 -day public comment period during which mterested persons may formally submit wntten comments about the proposal's efficacy The beginning and ending dates of the formal comment penod will be stated m the Fact Sheet and the SiteRegzster notices. The formal comment period for the SEPA Determination will run concurrently During the 30 -day coz nment period, Ecology will host a public meeting in Port Angeles at which Ecology staf will describe the full proposal and record public comments, and at which Rayoruei and E.P.A. staff will also answer questions. After closure of the formal comment penod, Ecology will review those comments while considering win they the proposal should be approved, revised, or rejected. Ecology will prepare Responsiveness Summary that describes the conclusions drawn from those comments The Responsiveness Summary will be mcorporated as part of the final Agreed Order; copies of the Summary will be filed m both Information Repositories and a copy will be mailed to each person who submitted a comment and to those people who attended the pubhc meeting. When Ecology issues :he Agreed Order, the actual fieldwork may begin. Ecology will mail a notice of availability of the Agreed Order to those on our mailmg hst; a notice will also be put hshed m the Szte Register A copy of the Agreed Order will be filed m each of the tw 3 local Information Repositories. Rayonier Mill at Port Angeles Interim Action 3 Concurrent Actions Occurring at Rayonier Properties In May, 1997, the Olympic Environmental Council filed a citizen petition with the Environmental Protec tion Agency (EPA) asking that the agency consider adding the Rayomer mill site, Rai -omer's two landfills and a third landfill— owned by Diashowa of Amenca, to the Na tional Pnonties List (NPL) of contaminated sites eligible for the Superfund prograi n. The EPA responded by collecting soil, sediment, water and fish tissue samples on and near the mill site, and collecting soil and water samples from around the three landfills. The EPA is currently evaluating the results of this sampling effort to det .rmine whether the sites should be included on the National Pnonties List (NPL) as sites to be cleaned up under the Superfund program. Mill Site If the Rayonier mill si :e is listed as a national pnonty under the federal program, the E.P.A. may assume re sponsibihty for cleanup activities and developing a pubhc involvement plan for :heir anticipated activities under Superfund. If the site is not included in the Superfund program, Ecology will be the agency responsible for cleanup activities and x the Washington State law, the Model Toxics Control Act. A decision by E.P.A. is expected late this summer Ecology's decision to move forward with this interim actio n will not affect the EPA's decision on the Superfund status of the mill site, nor will r: preclude any future actions that may be taken at the site under Superfund or the MT( :A. Landfills Each of the landfills named m the petition will be evaluated separately by the E.P.A. to determine whether it is eligible for the Superfund program. A decision on each of the landfills is also exi rected late this summer Non municipal landfills are regulated under Washington's Minimum Functional Standards for Sohd Waste Handling, Chapter 173 -304 WA C. If the E.P.A. does not designate the landfills as national pnonty sites, Ecology does not anticipate taking MTCA actions at any of them. Rather, the landfills w' 11 be regulated in accordance with the Minimum Functional Standards rule. Clallam County Envir )nmental Health is the agency responsible for admuustermg the landfill regulations. Rayonier and Clallam County Environmental Health are currently negotiating closure plan for the Mt. Pleasant Road, Landfill. The closure plan will include steps to inform the pubhc about the details of this landfill's closure. The closure plan will be available for public viewing as soon as the parties reach a tentative agreement. Rayonier at Port Angeles Carcovizt Ac 4 To Find Out More If you have questions tbout the fimshuig room mterim action, mill operations, or site assessment m general, please contact one of the individuals hsted below. Garin Schneve, Mill Site Project Manager Washington State Department of Ecology Southwest Regional Office P O Box 47775 Olympia, WA 98504-7775 (360) 407 -6253 easc461c ecv.wa.eov Paul Perlwitz, Envirormental Site Manager Rayomer, Inc. 700 North Ennis Port Angeles, WA 98362 (360) 457 2442 naul.nerlwitz(Wravoru r.com Joanne LaBaw, Site A: sessment Manager Environmental Protec Lion Agency Region 10 1200 Sixth Avenue Seattle, Washington %101 (206) 553 -2594 labaw.toanneC enamai l.ena.eov If you have questions tbout your role m this Intenm Action, or if you would like your name to be addea to or deleted from our mailing hst, please contact: Dolores Mitchell, Pub is Involvement Coordinator Department of Ecolo Industnal Section P 0 Box 47600 Olympia, WA 98504 600 (360) 407 -6057 dnut461@ ecv.wa.s?ov For a site map showing the locations of mill facility structures and processes, contact: Lola Anderson, Corpc rate Relations Assistant Rayomer 18000 International Blvd., Suite 900 SeaTac, WA 98188 -483 (206) 248 -4135 Iola.andersonCa ravomer.com Rayomer Mill Site at Port Angeles Intenm Ac&on 5 APPENDIX A GLOSSARY OF M.T.C.A. SITE CLEANUP TERMS Agreed Order The Depart it of Ecology issues a legal document which formalizes an agreement between Ecology and e property owner or facility operator (Potentially Liable Person) that describes the remedial ions needed at a defined site. Issuance of the order means that the PLP has agreed to pert rm those remedial actions, m exchange for Ecology s refraining from taking additional nforcement action against the PLP Background: In reference to h azardous substances at or in the vicuuty of a defined site, it is the measure (concentration of any naturally occurring or consistently present hazardous substance m soil, water, air, or sediment, the presence of which is unrelated to releases from a former facility or its ooeratnons on the site. Chronic Toxicity. A substance that causes irreversible injury or death to an organism as a result of repeated or constant exhosure during an extended penod of time. Cleanup Action: Any action except Interim Action— that eliminates or destroys, or removes a hazardous substance frc m a site; or that contains and isolates, or immobilizes /stabilizes the substance, thereby mirnizing exposure nsks; or that treats contaminants, rendering them less toxic, so that the si6 complies with cleanup levels. To the maximum extent practicable, the deanup action must effect a permanent solution to nsks posed at the site; and the action must include a method or measuring and monntonng its effectiveness. Cleanup Action Plan: This do :ument Identifies the method(s) and cleanup levels for different hazardous substances ou site, and It describes scheduling pnonties of the cleanup work The plan specifies the cleanup standard for the overall site; it may include additional requirements appropnate to the partic ular site. Cleanup Level. The measure (c:oncentration) of a hazardous substance in soil, water, air, or sediment, which Is dete ed to be protective of human and environmental health— under specified exposure con bons. A higher concentration or higher incidence of exposure demands remedial actioi L. Cleanup Process: This process includes specific, established steps /methods for identifying, investigating, and remed ymg hazardous substance releases. Cleanup Standard: The cleanup standard for the site is estabhshed by considering the cleanup level for each of the hazardots substances Identified on site, the locauon(s) on the site where those cleanup levels mu: t be attamed points of compliance and applicable state and federal laws pertaining to the use and control of the property after cleanup is completed. Consent Decree: A legal docur lent approved and issued by a court, which formalizes an agreement reached between Ecology and the Potentially Liable Person (PLP), that describes the remedial actions the P will undertake at the site. The agreement relieves the PLP of all legal and financial respoi isibility for hazardous substances discovered subsequent to the completed and venfied c leanup. Rayomer Mill at Port Angeles Appendix A 1 Containment: A container, sty ucture, vessel, or natural or constructed barrier that confines a hazardous substance wi dun a defined boundary and prevents or minimizes its release into the environment. Contaminant: Any hazardous substance that does not occur naturally m soil, water, air, or sediment, or that is pret ent m the environment at greater- than- background levels. Enforcement Order A legal d ocument, issued by Ecology, requiring the Potennally Liable Person to take remedial action at site. Failure to comply subjects the PLP to financial responsibility for remedial action perf Dnmance costs and legal penalties. Environment: In this context, we mean any plant, animal, or natural resource; surface water and underlying sediments, g round water, drinking water supply (aquifer), land surface (including tidelands and shoreland 5) or subsurface strata; or ambient air under the jurisdiction of the State of Washington. Exposure: Subjection to the ac Lion, influence, or effect of a hazardous substance (chemical agent) or physical agent, through absorption of the agent. Exposure is quantified as the amount of the agent available at th:: exchange boundanes (e.g., skin, lungs, gut) of an orgamsm, during a penod of tinie. Exposure Pathway The mechanism by which a hazardous substance could reach an individual or population. Each expo lure path includes (i) an actual or potential source, or release from a source, (ii) an exposure )omt, and (iii) an exposure route. If the source exposure point differs from the source )f the hazardous substance, the exposure pathway also includes a transport medium (such as a solid, liquid, or gas) Facility. Any building or stm e, mstallation of equipment, pipe or pipeline (including pipe into a sewer or publicly -owne treatment works), or a well; any pit, pond, or lagoon, or any ditch, impoundment, landfill, r storage container; any motor vehicle (rolling stock), vessel, or aircraft; or any site or d fined area where a hazardous substance— other than a consumer product m consumer use has come to be located. Feasibility Study Identifies an i evaluates potential cleanup actions (alternative combmations of accepted methods and technologies) for the site. Ground Water Water found b neath the earth s surface, that fills pores between matenals such as sand, soil, or gravel. In cinders, it occurs m sufficient quantities to supply drinking water, crop ungation, and othe r purposes. Hazardous Sites List: Ecology maintains a list of sites around this State, sites identified as posmg varying degrees of nsk to human and /or environmental health, that require remedial action. Each site s Hazard Rariiking (from 1 to 5) indicates the level of urgency m performing cleanup action, relative t D other sites on the list; a "1" ranking is the highest pnonty Hazardous Substance: Any chemical, combination of chemicals, category of substances, or compound which has be en determined to pose a danger to human or environmental health, if released mto the envir )nment. Rayomer Mill at Port Angeles Appendix A 2 Independent Cleanup Action; Any remedial action conducted without the oversight or approval of a regulatory agency, nd such action was not defined under an Order or Decree. The action does not relieve Potentially Liable Persons from legal and financial responsibility Information Repository With m the affected community, Ecology and the Potentially Liable Person(s) will mamtam 4 file of reports, sampling data, maps, legal documents, and any other record pertauung to site investigations or to any remedial actions at the site. This file will be accessible by residents a t a public place, but cannot be removed from the premises. Initial Investigation: A review of the site use history and facility operations data to determine whether a hazardous substance release or threatened release warrants remedial action. Institutional Control: Measures to limit or prohibit activities that may interfere with the integnty of a cleanup action in progress; or, measures hmrtmg or prohibiting site uses that might allow inadvertent exposures at a site where further remedial action is not practicable. Interim Action: Any remedial iction that addresses cleanup of a portion of the site. The action is (i) technically necessary to reduce a threat to human or environmental health by eliminating or substantially reducir% one or more exposure pathways; (ii) correcting a problem that may become substanually w rse, or more costly to address, if the action is delayed; (iii) necessary to properly complete a Fite hazard assessment, a state remedial investigation /feasibility study, or the design of a clean Lp action. Maximum Contaminant Level Goal: The Washington State Board of Health or the United States Environmental Protection Agency (EPA) has established and published the maximum concentration of a contPmmant for which no known or anticipated adverse human health effects occur. Model Toxics Control Act: Washington State s laws governing the identification, mvestigauon and assessment, and the clea 'up and monitoring of hazardous substance release sites. Ecology s authonty to take action is defined by Chapter 70.105D RCW, and the rules describing when and how Ecology exercr ses that authority are published under Chapter 173 -340 WAC. Monitoring Wells: Special well 3, drilled at locations on or off a contaminated site, from which samples are taken at selected depths; the samples indicate the drrecuon of ground water flow or the rate of contamma ton plume migration. National Priorities List: The �'snvironmental Protection Agency s list of contaminated sites that may be eligible for a lon ;;term remedial response, funded by federal tax dollars from the "Superfund' trust accou it. Currently, 41 sites m Washington State are officially designated as NPL sites, and 4 sites are pending. Person: Refers to a legally defin :d enuty— an individual being; a firm or corporation, an association or consortium, a partner ship or joint venture, or commercial entity; a state government agency, federal governn:nt agency, or Indian tribe. Potentially Liable Person: A p erson exercising control over a property or facility, by authonty of an ownership interest or of an operations /management duty— or who had owned, operated, or exercised control over the property any time before its abandonment— who is therefore legally responsible for th costs of remedying a hazardous substance release at the site. Rayonrer Mill at Port Angeles Appendix A 3 Practicable: Capable of being designed, constructed, and implemented m a reliable and effective manner A cleanup ake mauve is not considered practicable if the incremental cost of that alternative is substantial and disproportionate to the incremental degree of protection provided by other lower -cost alternatives. Public Participation Plan: An outline prepared according the design of WAC 173- 340 -600, to encourage and facilitate effective public involvement m remedial action planning at the site, that is tailored to the co:nmun ty's needs. Release: Intentional or uninten clonal entry into the environment of any hazardous substance, including but not hmtteA to abandoned or disposed containers. Remedial Action: Any action t o identify and assess, or to eliminate or minimiz any threat to human or environments 1 health posed by a known or threatened hazardous substance release. Remedial action may also include investigating a threatened release of a hazardous substance (and related health assessments), and human health effects monitonng. Remedial Investigation: Any tction /study to define the nature and extent of contamination problems at a site. In c mbination with a Feasibility Study, the (RI/FS) collects and develops sufficient info Lion about the site to enable the Potentially Liable Person(s) and Ecology to design a clea up action plan that will be protective of both human health and the environment. Responsiveness Summary A compilation of questions and comments submitted by the public, about a draft or final pl g /decision document, is published along with Ecology's respective answers and eplies. A copy is filed m each Information Repository, and a copy is mailed to each individua who submitted comments; and nonce of the responsiveness summary's availability is published m the Site Register Risk: The statistical probability that a hazardous substance, when released into the environment, will cause an adverse eff ,ct m exposed humans or other living organisms. Sediment: Particulate matter.th it has settled in the biologically active aquatic zone, or the water column; sediment also u4cludes particulate matter exposed by human activity (e.g., dredgmg) m the aquatic zone or w..ter column. Sensitive environment: An are t where the release of a hazardous substance poses a greater threat than in other areas, mclu ding wetlands or cntical habitat for breeding or feeding fish or shellfish. Site: Has the same meanmg a "facility" See Appendix A 2. Site Hazard Assessment: Coll. !cting sampling data and other mformation, sufficient to (i) confirm or rule out a hazardous s ubstance release or threat, (ii) identify the nature and concentration of the substance, (iii) ide itify the extent and mobility of the contamination plume, and (iv) valuate the potential thrc at to human and environmental health. A site hazard assessment may be used to determine the site's hazard ranking, if appropnate. Site Register Every two weeks. Ecology publishes a list of major activities at sites around the state Rayonier Mill at Pon Angeles Appendix A 4 that are undergoing study or cleanup, as directed by the Model Toxics Control Act. If you want to receive issues o this publication, telephone Sherne Minnick at (360) 407 7200 State Environmental Policy A :t (SEPA) Checklist: After the Remedial Investigation and Feasibility Study (RI/FS) phase of the site cleanup process has been completed to Ecology's satisfaction, any technol ogees and work methods proposed for inclusion in the final Cleanup Action Plan must be evs luated for their impacts upon the built and natural environments on and near the site. Surface Water Refers to any e: [posed lakes or ponds, rivers or streams, salt water, inland waters, and all other water bodi :s or courses under the jurisdiction of the State of Washmgton. SWRO: Ecology's Southwest R ?gional Office, serving the Olympic Peninsula. Unrestricted Site Use Conditions: No restrictions upon the use of the site (or its natural resources) are necessary to ensure continued protection of human and environmental health. Washington Ranking Method: The procedure described in the Washington Ranking Method Scoring Manual was developed v 1 conjunction with, and is penodically reviewed and revised by, the science advisory board (stablished under Chapter 70.105D RCW A report describing the method is available froni Ecology Wastewater Treatment Plant: Includes all structures and equipment used to collect, transport, and to treat and to reclaim, c nr to dispose of domestic, industnal, or combined wastewaters. Wetlands: Transitional lands -s tuated between terrestnal and aquatic systems- -have a water table usually at or near the surface, or the land surface is covered by shallow water Zoned For (A Specified) Use: The type of use that an owner can make of property, is formally permitted or allowed co idiuonally, under the local junsdiction s land use zoning ordinances. A land use that is moon: istent with current zoning, but which is allowed to continue— as a nonconforming use" 0 7 through a comparable designauon— is not considered to be zoned for that (nonconforming) use. Rayonier Mill at Port Angeles Appendix A 5 Rayonier June 2, 1998 Mr Gann Schneve, PE Washington State Department of ecology Southwest Regional Office PO Box 47775 Olympia WA 98504 -7706 Subject: Monthly Ambient Air Monitoring Reports Rayonier Site Dis;nantling Project Enclosed are the Ambient Air Mc mtormg Reports for the Rayonier Site Dismantling Project for the months of February and March i 1998 These results are being provided to you as described in our Ambient Air Momtormg Plan for the project. We are also making this report available to the public through the Port Angeles Library and the Peninsula College Library The results from the air momtorung show that the air emission control methods used dung the dismantling work have been effe.tive. The air samples collected around the perimeter of the work site were well below the air quality action levels that are used as indicators of effective emission controls. We are continuing our air monitoring and emission control programs at the site. As additional results are available, they will be: compiled by our consultant, Foster Wheeler Environmental Corp., and will be forwarded to you and made available to the public. Paul F Perlwitz Environmental Site Manager Enclosure cc: Laurie Davies, Department of E :ology SW Regional Office Joanne LaBaw US EPA, Region t X Richard Robinson, ATSDR, Sea Ile, WA Chris Hartnett, ATSDR, Austin, TX Richard Foster, Port Angeles Ec rnomic Response Task Force Darlene Shanfald, Olympic Env ronmental Council Lou Haehnlen, City of Port Ang :les Port Angeles Public Library Peninsula College Library R� •rtrred to 1 :;O Certft %felt 42114 00 Nord' E:nniti Port 08ih' Tclephone (360) 1-5^ i i9 1 1 t\ 1 =(ii i i H 2 t i Specialty Pulp Products Port Angeles Mill Mr Carl Kitz US EPA, Region X 1200 Sixth Avenue (KW-114) Seattle WA 98101 321 East Fifth Street, Port Angeles Washington 98362 (360) 417 -4500 DATE June 2, 1998 TO Economic Response Task Force Members FROM Dick Foster Char SUBJECT JUNE MEETINGS ECONOMIC RESPONSE TASK FORCE We hay e scheduled a Task Force meeting June 22n in the City Hall Public Works Conference room from 5 30pm till 700pni. 1 Review opinion survey (Mill site) 2 Discuss clean -up issue for the June 23 forum (6 00 9 00 p m.) City Council Chamber 3 Discuss the demolition sc hedule, including dock building 4 Discuss Superfund paper 5 Discuss Ral, onier planning consultant 6 Discuss worker benefits fleeting We will conduct the clean -up foi on June 23 in the City Hall Council Chamber We ha \-e now scheduled a meetirg with Rayonier official from headquarters (Dennis Snyder Dana Dollof) at 10 00 a.m. 12 00 noon on June 25 in the Public Works conference room to discuss its position on uses and o wnership and the extent of it willingness to `work with the community Please let Sam Martin know whe her you can make the meetings on the 22 and 25 Thank You. Dick ECONOMIC RESPONSE TASK FORCE 321 East Fifth Stre: °t, Port Angeles Washington 98362 (360) 417 -4500 DATE May 22 1998 TO Economic Response Task Force Members FROM Dick Foster C hair SUBJECT MISC INFO 1 Attachments for you information 2 Remember Meeting on June 23 1998 City Council Chamber (Co g,orn) 3 Ravonier has agreed not to take rest of warehouse down 4 Rayonier has agreed :o a meeting with us probably July We'll to o ver the opinion survey's then TIE SHAPE OF THINGS TO COME Port Angeles In The 21st Century The year is 2010 All evide rice of the former Rayomer mill is gone from the site, except for a small, pleasant park overlooking the scene from the wooded hillside. Several benches and a wall: surround a tasteful bronze plaque which honors the Rayoruer Corporation for its years of service to the Port Angeles community Reaching out in several dir ctions from the shoreline is the trident- shaped dock, specifically redesigned to a commodate small to medium size cruise ships and larger pleasure craft. A growing umber of cruises have made Port Angeles a key overnight stop on their itineranes. Tl.e reason for this popularity is simple; Port Angeles is the only city on the West Coas t of North Amenca that can offer an unusually wide vanety of shoreside attractions for cruise tourists, and, a deep harbor and new facilities to serve the ships i hat bring them. Most passengers have been given two full days to explore the many area attractions. A range of choices tempts 1 hem, overnight in Neah Bay, to study Makah culture or lure the giant halibut, overnight to shop in Seattle or Victoria, day trips to all the Olympics sites, and local sightseeing. Many debarking passengers are taken by shuttle bus to the new Port Angeles Downtown Transportation Center, while others look forward to walking th.: Shoreline Trail. Once downtown, they are free to explore local shops and restaurants, board their tour buses, or stroll over to the new North Coast Convention Center to check out current activities. As the shuttle buses leave the dock area they pass the new Port Angeles Child Care Center, a spacious and full( equipped facility Staffed by trained and expenenced caregivers, the center is open every day and offers a small library, a game room, and food service provided by a .ocal fast food franchisee. All services except food are provided to both tounsts ar Ld area residents at no charge. Also at the dock, at her ow ri special berth, sits the now famous "Juan de Fuca" Originally a mid -size ferry, she had been refitted at Admiral Manne, and is now widely advertised as, the only international dinner cruise casino in the Western Hemisphere." Each evening, passengers (with advance reservations) board at 5 PM, and enjoy cocktails in the lounge as they cross the Strait to Victoria. There, a similar group joins them, and guests with reservations for the first dinner seating stroll leisurely toward the dining room. All evening, diners are treated to magnificent views of the Olympic Mountains and Vancouver Island through panoramic windows, as the "Juan de Fuca" steams seaward along the Strait. Once past Neah Bay, she will turn a large ci role at sea and return. While the diners enjoy their meals, the others join the excited crowd in the full service casino, which is complete with video poker and slot machines of all types As the evening progresses, all mill have had their turns at both an excellent dinner and all the excitement and fun of Nevada -style gaming. The "Juan de Fuca" eventually returns to Victoria, and those who boarded here return their passes as they depart. Finally, she slips into her berth in Port Angeles some time after midnight. With the sunnse will come the workers who prepare her for another night's entertainment. The unique appeal of the "Juan de Fuca" dinner cruise casino lies in its perfect fit with the outdoor attractions surrounding Port Angeles The opportunity to blend the natural beauty of the Olympics and the quaintness of Victoria with a taste of Nevada has made Port Angeles one of the most compelling family vacation destinations in the West. The "Juan de Fuca" is jointly owned by the cities of Port Angeles and Victona through a nonprofit foundation. With not for -profit ownership taxes are minimal, and both cities apply this new revenue to public benefit purposes. Among activities funded with these dollars are the new community child care facility, the shuttle bus system. and the new North Coast Convention and Visitors' Center Also sharing in these funds are a wide variety of public services, ranging from law enforcement to social services and nonprofit community based organizations. Memo To the Reader The scenario described above is logical, feasible, possible. and achievable. It raises several obvious questions, which are answered below 1) Has anything like this been successful elsewhere? A There are a number of communities in the midwest and south with nothing to attract visitors but their new riverboats. Nevertheless, they generate substantial profits Most of these nverboats" never leave the dock some have never seen a river, but sit in a small manmade pond. They all attract visitors who bnng money 2) Aren't slot machines illegal in Washington State? A. Not entirely Even years ago one could take the "Victona Express" a ferry from Seattle to Victoria and play slot machines during the tnp The "Juan de Fuca" operates in essentially the same manner, and thus we have a powerful precedent. 3) Won't Seven Cedars oppose this proposal? A. Initially, they might. However, with effective joint marketing, Seven Cedars and the Juan de Fuca could actually each benefit from the other's traffic. 4) Rayonier still owns the site. How will they react to this proposal? A. They would probably be very supportive (following several reasonable operating assumptions) a. Assumption. Rayonier would like to get a fair price for the property, and also wants to help the community, but fears a mill or other competing facility i b Assumption. Thc community wants the site to create a strong revenue stream. There are environn rental concerns that mitigate against another factory or other industrial use. There is also a growing recognition that tounsm, which is clean and a service industry, regt.ires little investment in equipment. In addition, although salanes are lower, tourism °mploys many more people than a factory, and is very lucrative for local businesses. c. Assumption. Everyone wins. Rayonier leases the property to the City of Port Angeles for $1 per year for the first ten years, to get the plan up and running. Then, Rayonier and the Ci y negotiate the sale of the property, with Rayonier paid from annual revenues. 5) Where will we get start-up funding for this? A. The nature of this prod ram and the outcome are unique, and therefore could be attractive to certain func ers. As a career professional fund raiser (retired), I believe start-up funding we uld not be a problem. Robert E. Harrison 2125 West 15th Street Port Angeles, WA 98363 Tel. (360) 457 -4943 P \RT( cl 1. T 1 P It l l ")I \C_It. H11 Lip, R q May 5, 1998 REPORT TO THE BOARD OF PORT COMMISSIONERS SUBJECT RAYONIER DEMOLITION When Rayonier announced th ri closure of the mill and plans to demolish the improvements, Dave and I had a number of conversations with Dennis Snyder and Wendy Pugnetti regarding improvements that should remain on the property Of particular importance was the pier and warehouse We also followed up those conversations with a letter to Mr Snyder in March of 1997 We have also had similar conversations with Dana Dolloff Mr Snyder's successor on this project. Dave was walking the waterfron: trail the other day and noticed that the siding of the warehouse on the pier had been removed. I called Paul Perlwitz to find out what was going on Paul was not aware of the conversations with Dennis, Dana or the letter I faxed him a copy of the prior letter I also suggested that a meeting might be in order We were promised by Rayonier (Mr Snyder) that the warehouses would be the last phase of the demolition project and tha: they would work with the Port to ensure that useable improvements remained on the p 'emises. We have been patiently waiting for Rayonier to come to the table to talk about sale of the property, however it appears we are running out of time if we sincerely hope to have any useable improvements remaining on the property It is extremely frustrating that Rayonier has mumbled platitudes over the past year or so but has been unwilling to engage in serious conversation about the property They are always a study away from being in a position start discussions We advised them over a year ago to conduct a study similar to the one they indicate they are now pursuing. They delayed and ultimately hired an appraiser last fall. They abandoned the appraisal (for unknown reasons) and are now peen looking for a consultant to do a highest and best use analysis As far as I know tey haven't even selected the consultant, yet they are promising results by June I have had reservations for some time about Rayonier's sincerity in working with the Port on the redevelopment of this pror erty I hope that this recent problem is not a confirmation that these sentiments are justifiec M Christine Anderson Executive Director RAYNR598.DOC 338 W First St. P 0 Box 1350 Port Angeles, WA 98362 -0251 Mr Dennis Snyder Vice President Pulp Services and Planning Rayonier 1177 Summer Street Stamford, CT 06905 -5529 Dear Mr Snyder A PORT OF PORT ANGELES March 11 1997 (360) 457 -8527 FAX (360) 452 -3959 On behalf of the citizens of Clallam County and the Port District, the Port of Port Angeles would like to take this opportunity to thank Rayonier for it's many decades of activities in Port Angeles and the positive impact you have made in our community Many a family has been supported through employment at the mill and your ongoing effort to minimize impacts to the communities and current employees is to be commended. We appreciate the company's willingness to be open and candid with the Port and the community regarding the future plans for the mill and hope we can move forward together to find positive solutions and altematives that meet the need for industrial employment in Port Angeles. On several occasions we have been able to meet with key people in your organization such as Mark Johnson and Wendy Pugnetti, and have explored on an informal basis, possible future scenarios for the mill site. We have not wanted to circumvent the ongoing efforts of the Economic Response Task Force and the Mill Altemative Committee however, as the Mill Alternatives Committee's findings are not consistent with Rayonier's stated plan or parameters for consideration, we feel the time has come to move forward to find alternative uses outside of the production of pulp Our mandate at the Port is to create long term family wage jobs for the community and we believe the mill property presents an important opportunity to create that type of employment. To move quickly towards an appropriate reuse of the property, the Port would like to work with Rayonier on several key issues that we feel may lead to mutually successful opportunities. First, we would/like to explore the possibility of use of several key assets at the mill site. COMMISSIONERS. Glenn Beckman Dick Foster Jack Waud EXECUTIVE DIRECTOR: Christine Anderson The primary assets are 1) Dock and associated warehouse 2) Assorted warehouses and structures that could house manufacturing activities 3) Various infrastructthre including on site utilities and roads While we do not want to speak for the City of Port Angeles we believe they have an interest in various infrastru ure such as the secondary treatment facilities, waterline, power substation and trail ri ht of way Secondly, and related to the assets listed above, we would like to explore the possibility of utilizing certain assets during the demolition and clean up phases of the mill as we believe there ar4 some activities on the horizon that could be attracted to Port Angeles. How these assets could be utilized and managed also needs to be addressed, i e. rent amounts, lease /sublease, etc. The Port could act as a rental /lease agent or take over the management of the assets or assist Rayonier staff in this effort. Third, the options for the i anticipated time frame for there may be some interi the site will be dependent of the property The Port i Continued use of the site f ng term dispensation of the assets and property, and the vailability should be explored. As stated above, we believe uses, however the long term marketability and viability of n Rayonier's needs and views regarding ownership vs. sale supportive of reuse of the property for industrial purposes. r industry provides the opportunity for Rayonier to approach clean -up of the site as "brownfield as opposed to the more vigorous cleanup requirements for commercial or residential reuse We are willing to explore all of these alternatives with Rayonier and provide our professional expertise either in a public/private partnership with Rayonier or through a contractual relationship for management or purchase 'lease of the site. As you probably know from your local sources, we have little mo,ley to effect a purchase, but we are creative and innovative and if Rayonier is willing, we will work to find the solutions to put this site back into productivity as quickly as possible We are interested in disc ssing your views on this subject and hope there may be a solution that meets every ne's needs. We hope that this letter can represent a staring point for future discussion and look forward to working with you over the next several months to bring needed a onomic development to our community Thank you for your consideration of our requ st and hope to hear from you soon cc: City of Port Angeles Economic Response Task Force Sincerely M. Christine Anderson Executive Director Dick Foster ERTF 73 Island View Road Port Angeles WA 98362 Roger Reidel 350 Longfellow Road Port Angeles, WA 98363 Gary Colley 103 South Peabody Port Angeles, WA 98362 On Campbell 820 Milwaukee Drive Port Angeles, WA 98362 Glenda Burch- Governors office P O Box 43113 Olympia. WA 98504 -3113 Kurt Beckett Dick s Office 1717 Pacific Avenue, Suite 2244 Tacoma, WA 98402 Lou Haehnlen City of P.A. 321 East Fifth Street Port Angeles, WA 98362 O ville Campbell 8: 0 Milwaukee Drive Port Angeles, WA 98363 13 Zindel 5(18 South H Port Angeles, WA 98363 Mac Ruddell 1: 0 South Golf Course Road Port Angeles, WA 98362 JLn Rumpeltes County 2:3 East Fourth Street Port Angeles, WA 98362 L: inn Kessler Legislative Office Building V'ashington, D C 20510 Se ratan Jim Hargrove r: a Patsy Feeley L ;gislative Office Building Olympia, WA 98504 R wised 5/5/98 List A. ECONOMIC RESPONSE TASK FORCE MEMBER LIST A. Carole Boardman C Comm. 223 East Fourth St. Port Angeles, WA 98362 Patty Hannah United Way Dir P O Box 937 Port Angeles, WA 98362 Bart Phillips EDC 102 E Front Street Port Angeles, WA 98362 Chris Anderson Port Exec Dir P O Box 1350 Port Angeles, WA 98362 Jim Buck Legislative Office Building Olympia, WA 98504 Wally Sigmar Pen College 1502 East Laundsen Blvd. Port Angeles, WA 98362 Rayonier May 15, 1998 Mr Garin Schneve, PE Washington State Department of Ecc Ilogy Southwest Regional Office PO Box 47775 Olympia WA 98504 -7706 Subject: Monthly Ambient /Lir Monitoring Report Rayoruer Site Dismantling Project Specialty Pulp Products Port Angeles Mill Mr Carl Kitz US EPA, Region X 1200 Sixth Avenue (HW -114) Seattle WA 98101 Enclosed is the Ambient Air Momtoiling Report for the Rayomer Site Dismantling Project for the month of January 1998 These results are be ng provided to you as described m our Ambient Air Monitonng Plan for the project. We are also making his report available to the public through the Port Angeles Library The results from the air momtonng show that the air emission control methods used dunng the dismantling work have been effective. The air samples collected around the penmeter of the work site were well below the air quality action levels that are u sed as indicators of effective emission controls We are continuing our air momtonng and emission control programs at the site. As additional results are available, they will be compiled by our consultant, Foster Wheeler Environmental Corp and will be forwarded to you and made available to the public. Smcerely Paul F Perlwitz Environmental Site Manager Enclosure cc: Laurie Davies, Department c f Ecology SW Regional Office Joanne LaBaw, US EPA, Re ;ion X Richard Robinson, ATSDR, Seattle, WA Chns Hartnett, ATSDR, Au: tin, TX Richard Foster, Port Angeles Economic Response Task Force Darlene Shanfald, Olympic Environmental Council Lou Haehnlen, City of Port /.ngeles Port Angeles Public Library Re ilsteri'il to ti0 'NIO_ Certificate No A2114 00 \ort;l E:cult:, Port Antit.lc', t)' TL IL p11ot1t_ il)O) -;391 E',(\ 4)0) 2 l i- The following outlines our activities ECONOMIC RESPONSE TASK FORCE 321 East Fifth Street: Port Angeles Washington 98362 (360) 417 -4500 DATE May 1 1998 TO Economic Response Task Force Members FROM Dick Foster Chair I really appreciate your commitment tc staying the course to support appropriate training and benefits to mill workers, prompt but thorough site n -up andiob- creating economic development of the site I ve received man supporting and encouraging comments! 1 ADMINISTRATION Both frank Ducceschi and Gail Frick asked to be replaced for work/personal reasons The knowledge, exp :rience and strong contributions will be missed Two questions Should they be replaced If so who would you sugg itst? While we don t have a lot to d) right now our presence and later activities will be very important dust as they have been! The EDC has replaced Dick Mott with Wally Sigmar as it s representative Dick did an outstanding service to our Task Force and to the community He and his team, did a task that had to be done before we move on. We are all a bit wiser (but I hope not bent) from that experience Wally is an excellent replacement, although it seems he was really a member all the time His presence, and the role of the College, is very important 2 CLEAN -UP MEETINGS I "e met with Rayomer officials (Paul Perlwitz and Dana Dollop to discuss the next Task Force sponsore A public meeting. We are looking at June 23r I ve asked that the Task Force have a greater role in tl ie agenda/arrangements. For example, the purpose of the meetings is to have the principal parties (Rayomer and the regulatory agencies EPA, Ecology and the City) give status reports to the commune tv on site clean -up Interest groups, citizens, and anyone else is welcome to comment after presentatio Zs. Task Force members should try to attend. The focus will be on the mill site, since we really don t have a role in the landfills The first data will probably be air samples 3 SITE REDEVELOPMENT Rayomer is hiring a firm to do a six -week redevelopment assessment of the site, as part of it's evaluation of site value We expect to meet with them in July to discuss the report and related issues of future ownership and uses At some point, we should hold a public meeting for input on these issues The big uncertainties will be the extent of any clean -up activities Some of this could be affected by future uses, keeping the site industrial or considering other zoning uses. We were organized to seek replacement job creation to replace those lost, so that Clallam County can still be a home base for citizens and families I m attaching some information for your creative consideration. V Aquaculture NOAA ship base /labs 4 OTHER. I m attaching Representative Lynn Kessler's letter of support. She has taken a new leadership role in Rural Economic Development and her participation in the Task Force is cntical. I've been in touch with Senator Hargrove's staff. He remains supportive and ready to help His activities already have been cntical, and we expect to utilize some of the legislation he sponsored Similarly Representative Jim Buck was there for us and Rayonier employees We are very fortunate to have three such capable legislators In addition, Congressman Dicks and staff have done the impossible in supporting all of our community's efforts. I want to congratulate Patty Hannah for the United Way Award "Hononng Our Best' for Task Force activities 5 RAYONIER WORKER TRAINING AND BENEFITS Patty and I attended a meeting held by the Rayonier Transition Center staff It seems funds are a bit short to see those now in the program fully completed. They are preparing a detailed and quantitive presentation of benefits needed (by type training, job searching, counseling, etc) to complete those resources and programs available, and shortfalls We will be asked to support this need. 6 MEETINGS I know you are all busy particularly m the summer and we shouldn't meet dust to meet. But, as you have ideas, proposals, or want to meet, please pass that on to Sam Martin, our able and dedicated nerve center so she can distribute it. I hope you all talk around the community about vision for the mill site 7 OPINION SURVEY In preparation for our next meeting, it would be helpful if each of us did some outreach on future Task Force activities. I would ask each of you get your Club members, associates, friends, neighbors to complete the enclosed survey and get them back to Sam by the end of May Please complete one yourself, as well This will give us a idea of what the broader community feels about the Rayonier site a. ertf980623.mtg 321 East Fifth Street, Port Angeles Washington 98362 (360) 417 -4500 1 Are you aware that the Rayonier Economic Response Task Force I facilitating public meetings where Rayonier and regulatory agencies (EPA, Department of Ecology and the City of Port Angeles) present clean -up information and status on the mill site? Yes No 2 Do you feel that these factivities of the regulatory agencies will produce an appropriately clean site for future uses? Yes No ECONOMIC RESPONSE TASK FORCE (ONLY SIGNED FORMS WILL BE SUMMARIZED) 3 If not, do you have serious concerns about potential health risks related to the site? Yes No Comments RAYONIER MILL SITE OPINION SURVEY 4 Do you feel that the community is environmentally better off with the mill closure? Yes No 5 If yes is the possible impacts from the mill removal activities worth it when compared to the results? Yes No ERTF Opinion Survey 2 6 Do you feel that the mill workers were unreasonably exposed to environmental hazzards when the mill was in operation? Yes No 7 What uses do you favor for the cleaned -up site? (Circle one) A. Heavy industrial B Light industrial C Commercial D Park/Recreation 8 Do you think it is important to seek replacement family wage jobs on the site to replace those lost in the mill closure? Yes No 9 Do you have any specific proposals for uses of the mill site? 10 Do you have any comments or suggestions to the Rayonier Economic Response Task Force regarding its activities? A. Supporting Rayonier worker benefits training re- employment B Facilitating clean -up meetings for the public C Seeking new uses of the mill site Please fill out. Name Address City State Zip Phone Please return this questionnaire to Sam Martin, Rayonier Economic Response Task Force, 321 East 5 Street, Port Angeles, WA 98362 by May 29, 1998 10 April 1998 STATE REPRESENTATIVE 4th DISTRICT LYNN KESSLER ‘11',O UT'y WHIP Dick Foster Chairman Economic Response Task Force 321 East Fifth Street Port Angeles WA 98362 Lynn Kessler State Representative 24th District Washington House of Representatives Thank you for doing such a great job You are all to be commended Best, 1i TI DO Fori r n1 P PIONS ENERGY UTILITIES RECEIVED APR 13 '1998 City of ru, c Angeles Dear Dick and Economic ;,Response Task Force Members Thank you for keeping me informed regarding the activities and decisions of the Economic Response Task Force It was indicated in your r iemo of April 1 that you would like me to continue to serve as an ex- officio member I would be more than pleased to continue in that capacity and would ike to be informed about any meetings I will do my best to attend if my schedule permits LEGISLATIVE OFFICE: 412 LEGISLATIVE BOLDING PO BOX 40300. OLYMPIA. WA 98504 -0600 3tifil 7845-' 7l o4 TOLL -FREE LE 315LATIVE HOTLINE_ I-800-562-6000 TDD• 14!00G33.9993 RESIDENCE. 62 KESSLER LANE. HOQLLA.M. WA 98550 3601533 -1944 E hessier IvVp►cg.wa.g0V PRINTED ON REGYCl E0 PAPER Tn �i DATE. April 10 199 TO: Chris Anders n FROM David Hagiw ra RE. Project Inqui Attached you will find location to site a fish r potential of 120 -140 j have discussed the p Rayonier to get permi basis, they have agre sake. While there ar these types of project important to get a "pia go with our strategic M E M O R A N D U M n inquiry from the State of Washington for a waterfront aring and processing facility The project has the bs with a respectable average wage Bart Phillips and I tential site locations and have made a phone call to sion to propose their site at this time On a tentative d to have the mill site put on the table for discussions numerous issues yet to be resolved with Rayonier, typically take some time to put together and it is e holder" as a first response. Depending on where we lanning, the Daishowa property may also be a candidate. However with Daishowa's expressed interest in retaining at least a portion of the 35 acres, that site may not be big enough for Project Aqua NW In looking at the criteria, there are not a lot of places in the State that can accommodate this prcject. As the project moves forward, we will keep you updated. (A/08/98 WEL 08 59 FAX 360 152 9618 CLALL CO EDC 13 30 f,PR 01, 1998 PORT OF PA 4100z TEL NO 260- 664 -2013 vereb rme STATE OF WASHINGTON DEPARTMENT OF COMMUNM, TRADE AND ECONOMIC DEVELOPMENT BUSINESS DEVELOPMENT PROGRAM Date: 4/1/98 From: Ray Isaacson To: EDC OFFICES Subject Project AQUA NW Attached is information and specifications for a fish rearing and processing facility that is being considered for location in Washington State. If you are interested and can meet the required cntena and specifications, please respond with information to me by Friday, 04- 17 -98. Please let me know as soon as possible at 360- 753 -5634 if you do not plan to respond. Please include all pertinent information regarding local incentives, financial assistance, tratrung and etc. I will cover the state information. u4108 98 WED 08 59 FAX 380 152 9811 CLALL 1 CO EDC 13 32 RPR 01, 1998 TEL NO 360- 664 -2013 Send the information to me at the following address. Ray Isaacson, Case Manager CTED, Business Development Program P O Box 42500 Olympia, WA 98504 -x.500 The project is currently to be ;onsidered highly confidennal. The ideal candidate locations For this operation must be able to meet the following requirements: Site Requirements: Utilities' Employment: Build -to -suit prop ..sty located adjacent to or very close to the availability of salt water Ideal acreage is b Zoning needs to b feed mill, proces Building specifications: Process Water Potable water Sewer Natural as Associates Average wage: Discharges from facility Total Sq. Ft. Type of building: Height of building: HVAC. Electrical deman4 1 1 5 MW None, all are rec: rcled into the process. PORT OF PA igJ ou3 #2069 PAGE c'2 w een 45 85 with a 30 acre minimum light industrial, industnal, agricultural with allowances for a high land -use percentage 280,000 320,000 Steel span construction 14 ft. low 23 ft. high Heated with oil -fired burners Geothermal with air handling units (ideal) 300,000 GPD of salt water Domestic only Domestic only 100 —120 MCF/ day 120 140 $30,000/ Yr Mr Dick Foster Secretary, Port Commission Port of Port Angeles 338 West First Port Angeles, Washingtor. 98362 -0251 Dear Mr Foster UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration Rockville, MD 20852-3019 OFFICE OF NOAA CORPS OPERATIONS FEB 2 4 1994 Port of fort Angel Thank you for your letter to Dr Baker regarding preliminary plans to develop a Marine Safety and Resource Center for the Port of Port Angeles and the availability of current port facilities I am impressed by your development plans for Port of Port Angeles Your geograph:.c location, facilities, and close proximity to area reseaych facilities could possibly be beneficial to the effective utilization of NOAA's ships The Pacific Marine Center's Lake Union facilities are adequate for our current: needs However, it is a leased facility, and the lease is scheduled to expire in 2003 With the expansion of NOAA's Fleet, the adequacy of the current Lake Union facilities to support the Pacific Fleet will need to be evaluated NOAA plans t:o complete a study and make a decision prior to the expiration of the Lake Union lease Your continued interest in NOAA and its Pacific Fleet is appreciated /1( -i 6v& 5 vi_D TI f S Afv Std cps etsoo P4— G 7 y 1gcr 17i6 ti0 AA- 61-0 S L a--v gerv114 picr Sincerely, Sigmund R Petersen Rear Admiral, NOAA Director, NOAA Corps Operations 338 West First D. G. HENDRICKS Executive Director Dear Dr Baker PORT OF PORT ANGELES Post Office Box 1350 Port Angeles WA 98362 -0251 January 11, 1994 Dr D James Baker The Under Secretary for Oceans and Atmosphere U S Department of Commerce Washington, D C 20230 We notice that NOAA is planning an expansion of its ship operations and an increase in its fleet. As a former senior NOAA Budget Official and Deputy Assistant Administrator, I well recall the difficulties and cost of operating NOAA ships from the Lake Union facility The narrow channel required installation of bow thrusters The projected growth in ship operations in Puget Sound raises many safety concerns. As your ship operation officials well know, the Port Angeles harbor offers 1) a deep protected harbor; 2) a location much nearer the ocean and NOAA program locations, 3) a location with minimum navigation and congestion problems; 4) close access to an excellent airport; 5) presence of a Coast Guard helicopter and ship base; 6) the closest harbor to the new Marine Sanctuary and potential research activities, 7) close access to the Battelle Northwest Research facility; and 8) presence of a 2 year college with a fisheries program capability The Port �f Port Angeles is in the early planning stages of the development of a $5 2M Marine Safety and Resource Center This would include berthing capacity for about 1250 feet of vessel space for fishing, oil response, tugs, barges and other marine related vessels. It is expected that some office and warehouse space will be developed along with some ship repair facilities. The State of Washington has already funded $1 5M for the project and we have requested the rest as part of the Northwest Economic Adjustment Initiative. We would be very pleased to work with NOAA on possible use of our harbor for basing NOAA ships. It looks to us like a study of comparable cost, program, and safety considerations would lean toward an interest by NOAA in our location. Sincerely, PORT OF PORT ANGELES Dick Foster, Secretary DF sb Port Commission Area code 206 457 -8527 FAX 206 -452 3959 COMMISSIONERS President ROBERT M. McCRORIE, Port Angeles Vice President ANDREW NISBET Sequim Secretary GLENN BECKMAN, Forks •AIRPORTS •MARINE TERMINALS INDUSTRIAL SITES BOAT HAVENS GAO For Release on Delivery Expected at 2.00 p.m EDT Thursday October 21 1993 GAO /T- RCED -94 -52 United States General Accounting Office T stimony B fore the Subcommittee on Oceanography, G if of Mexico and the Outer Continental Shelf, C mmittee on Merchant Marine and Fishenes H use of Representatives OCEAN RESEARCH VESSELS NOAA Fleet Modernization Plan Statement of John H Anderson, Jr Associate Director Natural Resources Management Issues, Resources, Community, and Economic Development Division APRIL 20 1998 FOR RELEASE NO LATER THAN APRIL 29 1998 Contact Patty Hannah 457 3011 days 452 -86513 evenings week -ends The United Way of Clallam Co inty has recently received regional and national recognition for two of its effort!: Nola Gner United Way Administrative Assistant received one of three honorable mentions from the Idea Art paper company for her campaign materials using Idea Art paper Certificates of appreciation for United Way campaign volunteers and Restaurant Day participants were designe on their paper There were 8 prizes awarded out of 325 entrants. United Way will receive a $50 merchandise credit. United Way also received the Best Practices award in the state of Washington for its participation on the Economic Recovery Taskforce and its work with the Rayonier Transition Center The award was presented at the Northwest Volunteer Leaders Conference held in Portland, CSR. with volunteers and staff from United Ways in Washington, Oregon, Idaho, Montana, Alaska and British Columbia. Attending the conference from Clallam County were volunteers Jim Rumpeltes, Phil Volk, Mary Wilgocki, Judith Moms, Chri: Anderson and Executive Director Patty Hannah. Hannah was elected president of the State Association of United Ways for 1998/99 Unlbed Way of Clallam County PO Box 937 Port Angeles WA 98362 -0161 Voice (360) 457 3011 Fax (360) 457 0529 „vvil .N.56 ON. Te `is7:rte ..-i e ,..i, ?AV N4i k ''./..rreAA -4.1 I V. (i'l 1 4 0 ow,. 07 4- ia A14 w,,., .11., ph.- N Pow ig.g. 1 ?.i.kp '944. p i r is tovoy t 0 r. 1 I +1' 4: Z te K .:44, Ler J tea A I al/ "HONORING OIJR. BES7" Certificate of Award t o Azure% ?ea eediet0 e for caang ctoi1tt t /Lev co viavviAnau ti,rotA,g t /Le Cowt,manttu Response Task Force April 16, 1998 Northwest Leacters Conference The Resort at the Mottntatn" ,■Yr' M>C<Sl Pt' A '4 •10; ELM 4" *0 rr' Rayonier Apn129 1998 Mr Gann Schneve, PE Washington State Department of Ecology Southwest Regional Office PO Box 47775 Olympia. WA 98504 -7706 Re Enclosed is the Ambient Air Monitonng Report for the Rayonier Site Dismantling Project for the month of December 1997 Thl .se results are being provided to you as described in our Ambient Air Monitonng Plan for the rroject. We are also making this report available to the public through the Port Angeles Library The results from the air monitonng show that the air emission control methods used dunng the dismantling work have been e ;fective The air samples collected around the penmeter of the work site were well below the air quality action levels that are used as indicators of effective emission controls. We are continuing our air monitonng and emission control programs at the site. As additional results are available, they will be compiled by our consultant, Foster Wheeler Environmental Corp and will be forwarded to you and made available to the public. S incerely, Enclosure Monthly Ambient All Momtonng Report Ravomer Site Dismantling Project Paul F Perlwitz Environmental Site Manager 1 I it 1 CI )fr!l 1 i ILILphl)!le l ;i Mr Carl Kitz US EPA, Region X 1200 Sixth Avenue (HW -114) Seattle, WA 98101 it Il i L` 1 ∎I1I )ti i()_' Spec /aft] Pul p Products Po) t IltgUles 11 r 11111 "ECEIVED ?kY X 4 1998 .1 rort Angeles 1 c c Laune Davies, Department of Ecology SW Regional Office Joanne LaBaw, US EPA, Region X Richard Robinson, ATSDR, Seattle, WA Chris Hartnett, ATSDR, Austin, TX Richard Foster Port Angeles Economic Response Task Force Darlene Shanfald, Olvmpic Environmental Council Lou Haehnlen, City of Port Angeles Port Angeles Public Library C.1gencarRayortier042998.doc 4!30198 bcc Dennis Snyder w/o e iclosure Dana Dolloff Lisa Palumbo w/o enclosure Don Schwendiman Wendy Pugnetti Bill Cassinelli w/o enclosure C:\1gencorlRayonier042998.doc 4!30/98 MH r -08-13% 12 14 Rayonier April 28, 1998 Al_7DRESSEE RE. Rayonier Dismantling Schedule Rayonier Pulp Mill Site Port Angeles, Washington Questions regarding the schedule may be directed to ire at 360-457-2442. Sincerely, Enclosure C1T1 NPNAGEP 360 417 45 09 P 01 Hht..m1v ^oy of the present schedule for dismantling structi r ontractor performing the work for Rayonier .t plans and a; with any project is subject. to Paul F Perlwi tz Environmental Site Manag �r MAY 0 8 1998 City of Port Angeies Special Pulp Products Port Angeles MW 1 Port Afgelt's WA_ (,8302 1LI< 111()11(. (B 4-71 '1 Fax t3c,O) 177- 2+i�i Act ID 0es(nptian C,C.T 4.q'•i J.II FE.; iv -R :.FP I :1 -r' IJ,'; DE.0 J -iI FEB :OAR n °R f Y JUI'; JUL i 3 OVERALL PROJECT 41 MOBILIZE 4 WOOD MILL 4.1B10 PULP STORAGE WAREHOUSE(comp) 4.15 CHIP STORAGE 15 CHIP SCREEN ROOM (Complete) 6 EAST ROLL STORAGE 7 WEST ROLL STORAGE 8 FINISH ROOM 19 ADMIN BLDG COMPLEX (Coroplete) 11 STORESISHOPSENG 13 TANKAGE 14 DIGESTER BLDG. 16 MACHINE ROOM (INCL. MACHINE) 17 BLOWPITS 19 AUTOIPAINTSHOPSICOMP BLDG. 20 SLUDGE BLDG 25 RECOVERY 21 POWER BOILERS 23 SECONDARY TREATMENT 24 PRIMARY CLARIFIER 28 SCREEN RMtBLEACH PLANT I X 27 LEVIER PLANT �c3 4 PULP WAREHOUSEIDOCKT 29 I RECYCLE •�r1 3C i I 32 ISHIP SCRAP 33 (LEAD ABATEMENT 4* (FINAL WOODMILL CLEANUP 25-A 'RECOVERY BOILER STACK 1CONCO,INC. 5409 OM A VE S. SEATTLE, WA 98134 206 -763- 1900 -PHONE 206 -763 7422 -FAX ACTIVITY SCHEDULE* RAYONIER PULP MILL DISMANTLING PROJECT (*THIS SCHEDULE WILL BE UPDATED REGULARLY AS WORK PROGRESSES) ¢7 PULP STORAGE WAREHOUSE(oomp) 4 CHIP SCREEN ROOM (Corn eta) Aat'ADMIN 3LOGCOMPLEXSComplete) WOOD MILL CHIP STORAGE EAST ROLL STORAGE I v SERVING THE WEST WEST ROLL STORAGE FINISH ROOM L w POWER BOILERS mai SCREEN RMSBLEACN PLANT MACHINE ROOM (INCL. MACHIN l L -1- t I AUTOPAINT- SHOPS'COMP BLDG SLUDGE BLDG. RECOVERY PULP WAREHOUSEID I K ASBESTOS ABATEMENT 1 tymorms M TANKAGE DIGESTER BLDG. BLOW( ITS SECONDARY TREATMENT PRIMARY CLARIFIER !FILTER PLANT OVERAL_PROJECT 11RECYC I ib SHIP SCRAP LEAD ABATEMENT j 67 FINAL WOODMILL CLEA IUP RECOVERY BOILER STACK I t I r N T Date I r Revision Checked 1 Approved 0 130CT97 UPDATE DAL MDC 26NOV97 UPDATE DAL MDC 03FEB98 filf DAL MDC 17APR98 UP ATE UAL MDC 1 1 PURPOSE AND OBJECTIVES 1 INTRODUCTION AND SUMMARY Ravomer is implementor an ambient air quality monitonng program during dismantling and cleanup activities at he former Ravomer Port Angeles pulp mill site The momtonng program was conducted set forth in the Draft Ambient Air Work Plan and Procedures (Ravomer 1997) and the Final Ambient Air Momtonng Plan (Foster Wheeler Environmental 1998) This report presents the results of the air momtonng activities for December 1997 The objectives of the Ambient Air Momtonng Plan are 1 Monitor ambient air quality for potential air pollutants related to onsite activities. G: \WA1834 \11968 DOC 4/29/98 Quantify potent ial offsite transport of project- related emissions, and 3 Assess the effectiveness of onsite emission control methods used dunng dismantling an cleanup activities The site is a former pulp mll facility located at 700 North Ennis Street, Port Angeles, WA. Ravomer received approval from the City of Port Angeles in July 1997 to dismantle its former pulp mill facili Following this approval. Rayonier voluntanly committed to develop and implement a i air monitonng program. Air monttonng commenced in October 1997 and is currently ongoing The air monitoring network consists of four sampling stations located as shown on Figure 1 Air momtonng is conducted for potential air pollutants that may be generated by site activities. The spccific pollutants to be monitored and the sampling methods to be used are based on the site activities conducted during the momtonng penod. Air quality action levels Ere established in the Ambient Air Momtonng Plan to use as an indicator of the effectiver ess of onsite emission control methods used dunng dismantling and cleanup activities. In the event that single data point concentrations exceed the action limit cntena. the contmgt ncv plan descnbed in the momtonng plan will be implemented. 1 -1 1.2 SUMMARY OF RESULTS The results of the December 1997 air monitonng show that the air emission control methods used during the dismantling work have been effective The air samples collecteL around the perimeter of the work site were well below the air quality action levels that art used as indicators of effectiveness of emission controls Total suspended particulate matter (TSP) monitors were operated at four sampling stations during ten monitonng events, and dioxin/furan monitors were operated at three sampling stations during six monitoring events. The monitonng activities followed the procedures presented in the Ambient Air Monitoring Plan. with minor deviations as noted in this report. A summary of the monitoring results follows TSP measurements for the ten monitoring events during December 1997 ranged from 4 5 ug/m to 13 0 ug/m the site action level is 150 ug/m Dioxinifuran measurements for the six monitonng events during December 1997 ranged from 0 0002 to 0 0108 pg /m the site action level is 17 6 pg /m dioxinifuran concentrations are reported as 2.3 7 8- tetrachlorodibenzo p- dioxin (TCDD) equivalents (TEQs)], No visible emissions of asbestos from dismantling activities were observed durrr routine inspections, and Onsite winds were generally light and pnmanly from the south through the west northwest. Site activities during this period included general dismantling. matenal handling, and asbestos removal. The Washington State Department of Ecology U S Environmental Protection Agency (EPA) and City of Port Angeles conducted several site visits and inspections dunng this reporting period. No major structure dismantling activities (e.g. recovery boiler stack dismantling, digester dismantling, hog fuel boiler dismantling) or site cleanup excavation activities occurred during December 1997 1.3 PLAN MODIFICATIONS The December 1997 monitonng period marks the third consecutive month of weekly TT and dioxin/furan monitonng results that have not exceeded site action levels identified i the Ambient Air Monitoring Plan. Consequently starting in April 1998 the monitonnt frequency for TSP and dioxin /furan will be reduced to once every two weeks during G. \WP\1834 \11 %S.DOC 4/29/98 1 -2 routine dismantling activities. as established in the plan. TSP and dioxinifuran monitoring will, however be conducted on a weekly basis during future major structure dismantling activities. G. \WP\1834 \11968.DDC 4!2998 1 -5 Hirschhom Associates 2401 Blueridge Avenue Suit a 411 Wheaton, MD 20902 February 4 1998 Dear Dr Hirschhorn DEPARTMENT OF ECOLOGY PO Bor 47600 Olympia, Washington 98504 600 (360) 407-60(0 TDD Only (Hearing Impaired) (360) 407 -6006 This letter provides notice of our intent to terminate our agreement, contract number C9800103 effective Februarl 10 1998 While your report was delivered within the performance time period the focus of the work product did not meet our expectations. The Department will not be requesting additional services from you. We cannot use the work proc uct you delivered to expedite effective remediation of the site —which was the goal of our technical assistance contract. The product's lack of scientific evaluation and its inclusion of editorial opinions unsupported by analyses, render it of extremely limited value to the Department of Ecology For contract performance put poses, we consider the existing report to be your 'final' product, which our contract o Agates you to deliver to the Olympic Environmental Council membership Before releasing this material, however we require that you add to each and every page an easily identifiable statement sidebar or footer These contents reflec: the author's views only They do not represent the Department of Ecology's findings opinions or recommendations Please make simultaneous d stribution of the marked copy to the Olympic Environmental Council through Darlene Sch nfald and to the Elwa Klallam Tribe through Carol Brown to Brad Collins at the City of ort Angeles and to Andy Brastad at Clallum County to the Environmental Protection Agency through Joanne LaBaw and to us by the February 10` contract termination date. We will process your contract payment request upon confirmation of the distribution. Sincerely e James J Pendowski Progra Manager Solid Waste and Financial As istance Dolores D Mitchell J D Contract Officer STATE OF WASHINGTON JL FEB PORT ANGELEr PLANNING DEPT; February' 1998 Greetings Sincere Greg 0 Connor Air Quality Specialist II, Ext. 104 O L Y M P I C Alf-. POLLUTION CONTROL AUTHORITY 909 Sleat.m•- Kinney Rd S E Suite 1 Lacey WA 98503 The purpose of this letter is to i zform you about several legal requirements of the Asbestos Abatement Program enforced b y Olympic Air Pollution Control Authonty (OAPCA) The agency reminds any cities, counties and/or businesses doing projects which may or do involve asbestos to remember the following points OAPCA s Regulation 1 Article 14 specifies regulations related to the removal and encapsulation of asbestos mateiial It is unlawful for any person to cause or allow work on an asbestos project or demolition ;including renovation) unless the owner or operator has obtained an asbestos survey This also includes training fires of structures which may or may not contain asbestos. Permits must he ohm led. All suspect, untested tm .tenals need to be treated as asbestos Surveys must be conduc ted on such projects. The person or company conducting such surveys must be AHERA certif ed. All commercial, business, and government properties require a certified abatement company :o abate such properties Federal and state regulations also dictate specific actions on asbestos containing projects. A `Notice of Intent' must also be filed with OAPCA for such projects. The state Department of Labor and Industnes (L &I) must also be contacted about such projects Generally, specific forms must also be submitted to L &I. When it is determined that asbestos exists on such projects, a `Notice of Intent needs to be filed with OAPCA 10 worki:ig days pnor to any removal. Emergency waivers can be obtained from OAPCA for the 10 days, I rovided certain cntena are met. For more information on asbest Js removal, proper handling, and disposal, call OAPCA at Ext. 104 7 Asbestos is a dangerous mineral which still exists in such places as buildings and structures, decorative ceilings, floor tiles, cement pipes, cement sheets, sealants, insulation and textile products. In addition, asbestos may be found in insulation on heating systems and is used in more than 3,000 other products. When asbestos fibers get into the air and are inhaled they can lead to asbestos related disease and other health problems. (360) 438 -8768 1-800-422 5623 E -Mail OAPCA wln.com I -tome Page http: /wwwwln.com -oapca FAX (360) 491 -6308 imoitpaparmatrik REVIEW OF DOCUMENTSI A/MONISM PULP MILL and LANDFILLS PORT WASHINGTON 4bout the Author- Joel S. Hirschhorn, Ph.D Hirschhorn Associates, Inc 1401 Bluendge Ave., Suite 411 Wheaton, MD 20902 (301) 949 -1235 FAX (301) 949 -1237 January 16 1998 Under contract C9800103 from the Washington Department of Ecology These contents reflect the author s views only They do not represent the Department of Ecology s find:.ngs opinions or recommendations 1 0 )E@ROW7Y _IL FEB I 0 1998 s I' L, PORT ANGELES PLANNING DEPARTMENT He has served as an independent techni :al advisor for many community groups having EPA Technical Assistance Grants for Superfund sites, and groups funded by state agencies, companies, or private sources Formerly, he was a full professor of engineering at the Ui 'iversity of Wisconsin, Madison and a Senior Associate at the Congressional Office of Technology As. ressment With over 30 years of engineering experience and nearly 20 in the environmental area, he is a nationally recognized environmental expert He is currently the Editor of Remediation. The Journal of Environmental Cleanup Costs, Technologies Techniques, and has authored hundreds of papers and presentations is a consultant for nearly eight years he has worked for many government agencies (e.g., U.S. Agency for Internat onal Development, U.S. Information Agency, North Carolina Department of Environment and Natural Resources,, leading corporations (e.g., IBM, Polaroid, Warner Lambert, Chevron, 3M), international groups (eg., United Nations Environment Programme, OECD), law firms, and increasingly, grassroots citizens groups addressing difficult environmental situations Executive Summary The Port Angeles commui ity has every nght to be highly skeptical and concemed about the prospects for obtammg comprehensive and effective government actions to address the health nsks and environmental damages related to the Rayomer pulp mill's operations over nearly 70 years. Those members of the community that sought intervention by the U S. EPA were correct in believing that to be an appropnate action. EPA has made a major funding commitment to conductmg Superfund site inspections at the Rayomer mill site and two landfills it used. But there is no assurance that EPA will list any of the sites on the National Pnorities List (NPL) of the federal Superfund program. Of the three sites, it is clear that the closed mill site is the most important because of its past impacts, current levels of contamination, and potential for causmg continued harm to people and the environment. The mill site has the greatest chance of bemg listed on the NPL by EPA, which would quahfy it for a full remedial action after extensive site studies. But the community need: to understand that Rayomer would undoubtedly conduct all the key activities, with oversight provided by EPA. This report identifies a number of deficiencies with the site mspection for the mill site which may ultimately explain why EPA does not list the site. Even without NPL listing, h wever, mstead of extensive remedial cleanups EPA could require lesser removal actions at y of the sites. Also, under the CERCLA statute, vanous government agencies, mcludmg the local Lower Elwha Klallam Tribe, could seek compensation for natural resource damages caused by any of the sites, particularly damages to the harbor waters, marme life, and fishenes. Concemed citizens were also correct in opposmg the effort by Rayonier to obtam City approval to conduct mill demohtic n. The appropnate perspective of government officials and citizens was to see the closed mill as analogous to a "crime scene." Demolishing a cnme scene pnor to complete forensic mvestigation is fundamentally wrong. A contaminated industrial site is like a cnme scene, because consid.rable mvestigation is necessary to determine the exact scope and origins of contamination and t le need for cleanup Therefore, the current demolition activity could compromise thorough site u vestigation and eventual site cleanup Until EPA makes a decision about listing the mill site bn the NPL, demolition should cease. If the mill site is listed, the extensive site Remedial Investigation would benefit from havmg above ground structures present and available for testing. Anyone seekmg objective information about the Rayomer mill should examine two EPA reports. In 1989 EPA conducted A Chemical Safety Audit and m 1993 EPA conducted a Multi- These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 2 Media Compliance Investigation. EPA s activities pamted a picture of a pulp mill with a broad range of environmental deficiencies, pollution problems, and regulatory violations. While the EPA found considerable cause for concern about ongoing environmental releases, from today's perspective the pnor EPA work also provided a sound basis for believing that the Rayomer mill site was probably contaminated and a strong candidate for the NPL. The pnor EPA activities are also consistent with the estimated high cost of $40 million necessary for capital mvestments m environmental control equipment that Rayomer faced. Coupled with the acknowledged unprofitable status of the Rayomer mill in recent years, the closmg of the mill was a certainty, especially after ITT Corp spun off Rayomer, Inc. as a separate company in early 1994 Rayomer has also anticipated spending a large sum of money to demolish the mill and conduct cleanup activities, even before EPA made plans for the site inspections of the mill and two landfills. The following conclusions and recommendations have been presented for the five categones of documents specified for review and analysis m this study EPA Sampling and Ouality Assurance Plans for Site Inspections of the Ravonier mill site and two landfills EPA Plan for the Ravonier mill site The major deficiencies m the plan are summanzed below These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 3 ISSUE MAJOR PROBLEM OR IMPACT Marne sediment sampling Air data Conclusions. use of surface sediment samples only, but not subsurface or core samples, could mean little or no evidence of releases to harbor and food chain impacts madequate use of past sediment test data could mean EPA looked m wrong places, meaning less evidence of releases Bioassay sampling EPA may not conduct extensive sampling offish, shellfish and other species, which could prevent high score for food cham impacts Offsite surface soil samples EPA may not use data showmg contammation m residential areas for NPL hstmg purposes EPA should have used more shallow samples to maximize probability of finding highest levels of contammation resultmg from deposition of contaminated particulates Dioxin test method EPA will be usmg a novel method for obtammg most dioxin data, but this could mean more nondetects than obtained from the standard, more sensitive test method. and less evidence of releases from site if EPA proposes site listing Rayonier may protest use of data from novel method, if EPA does not propose listing, commumty residents can protest use of data no new data obtained and EPA may ignore extensive past evidence of air releases The mill site has been a major cause of environmental pollution and impacts m the Port Angeles community and ments NPL hstmg. A very large number of people have surely been impacted by decades of mill opera:ion. Because of senous deficiencies m the sampling plan there These contents reflect the author s views only They do not represent the Department of Ecology s find .ngs opinions or recommendations 4 is a high probability that EPA will not score the mill site high enough for NPL hstmg. Not listmg the mill site may sound ludicrous to citizens since there is a clear presumption that the site meets the standard for NPL listmg as shown by the costly Expanded Site Inspection (ESI) EPA has conducted. Nevertheless, there is considerable cause for concern. The mam problems are seriously deficient marine sediment sampling and a likelihood that EPA will ignore previously obtamed data showmg substantial air pollution from the site. EPA may also discount the full impact on fishenes in the harbor There is, however, a good chance that EPA might compromise by calling for one or more removal actions, especially since the Washington Department of Ecology (DOE) has already established two specific hot spots and remediation areas. EPA could then claim credit for establishing removals, but in fact doing so would probably have little impact on what is already gomg on and planned for those two small cleanup locations. Recommendations. Some useful activities for citizens prior to EPA issuing its ESI report include- making the case on the basis of pnor information on air emissions for a high air pathway score, obtammg mformation verifying past human consumption offish and shellfish from the harbor; and making a public pomt about the deficiencies of the marine sediment sampling. The commumty should appreciate the fact that it is far better to attempt to influence EPA's actions before it issues its SI report than wait for the report and then try to change EPA's conclusions. Community groups should formally petition EPA Region 10 for the right to review a draft ESI report. The community should also show support for the local Tribe nommating the mill site for the NPL, because it has the legal right to do so Future independent technical analysis for the community should, of course, focus on the ESI report eventually issued by EPA. If EPA Region 10 does not hst the mill site, concerned citizens should senously consider petitioning EPA's National Ombudsman for assistance and to provide an mdependent agency technical review of the ESI and HRS scoring done by Region 10 Groups such as the Olympic Environmental Council should senously examine how the Agency for Toxic Substances and Disease Registry (ATSDR) can be used effectively, especially by petitioning this federal agency to provide consults on very specific activities and documents, especially those by EPA Region 10 EPA Plans for the two Ravonier landfills The main deficiencies m the plans are summarized below These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 5 1LSSUE MAJOR PROBLEM OR IMPACT Number of landfill samples Air pathway Dioxin testmg Offsite soil testing Sediment sampling Conclusions. Recommendations. too few samples could cause EPA do not link contamination offsite with landfill contents no data obtamed and EPA may ignore air releases same problems as for mill site plan few samples for background and residential area will likely prevent NPL listing too few samples will likely prevent hstmg 6 Because of the intrinsic linuted scope of a normal SI, some deficiencies m the sampling plans, and the low probability of closed exposure pathways, it is unlikely that either landfill will be scored high enough by EPA for NIPL listmg. The reahty that many citizens will not find comfort m is that even with some releases )f hazardous substances from the landfills mto the environment, it is very difficult to estabhsh actu 1 threats to public health, especially if there are no contaminated private dnmking wa er wells. Because buned wastes are covered up and there is no pubhc contact with them, offsite r leases have to reach human receptors m some plausible way if a high HRS score is to be obtame Landfills m relatively rural areas have particularly httle chance of NPL listmg unless local drinking water wells are contaminated sigmficantly And even m those cases, one frequent action is simply to provide those residents with connections to city water supphes. In other words, aril/ thoughts that EPA intervention will make the landfills go away is unfounded and unrealistic. Once landfills are legally sited, permitted, and constructed it is unrealistic to think that some gov rnment action will remove the landfills. Extremely few landfills are excavated and, m fact. EPA's jresumptive remedy m its Superfund program for non- hazardous waste landfills is vanou; forms of containment, such as caps and subsurface barrier walls, and this containment approa ch is also used for most hazardous waste landfills on the NPL, except for proven hot spots of contammation within landfills. Citizens concerned about t fie landfills are advised to focus their efforts on obtammg hard evidence of observed releases from the landfill and, if obtamed, submit such mformation. m terms These contents reflect the author s views only They do not represent the Department of Ecology s findhngs opinions or recommendations of affidavits and photographs, to EPA Region 10 Venfymg whether or not private wells are bemg used for drmking water could also be useful. Commumty groups should formally petition EPA Region 10 for the right to review draft SI reports. They should also focus more on possible removal actions by EPA and improvements in the landfills themselves and in momtoring at them that government agencies could compel Rayomer to make. The mam government agencies that will retain jurisdiction over the landfills, if EPA takes no actions, is the County and DOE, therefore, concerned citizens may have to shift their attention to landfill closure and momtormg requirements and comphance for the long term. Current Situation /Site Concentual Model Report Conclusions. The Rayomer report is more important for its patches of interesting but mcomplete information than for its analyses, interpretations, and conclusions, which are biased and technically deficient. Rayomer's reahty is literally pulp fiction. It defimtely shows the need for regulatory agencies to thoroughly examine the enormous amount of historical information that exists for the mill. But government agencies should not use the document to limit the scope of site investigations and studies, nor allow it to affect decisions about necessary cleanups. City government has already shown itself to be a willing partner with Rayomer, as evidenced by its grantmg a very favorable permit for demolition, allowing use of its landfill for demolition waste, and considering treating landfill leachate m the City wastewater treatment plant. Conflicts between local residents and local government often exist, because residents place the highest pnonty on protection of health and environment, while local government officials often place more importance on economic redevelopment. Recommendations. Concemed members of the Port Angeles community should not allow themselves or their City government officials to be overly influenced by the transparent attempt by Rayomer to paint an overly positive picture of the mill's history and health and environmental impacts. City _permit documents Conclusions. The City permittmg process for demolition was fundamentally flawed because of two These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations incorrect presumptions: (1) that there was no significant threat to health and environment that warranted an environmental impact statement, and (2) that demohtion of mill site structures was a necessary precondition to conducting a comprehensive environmental site investigation. Both findings are not technically correct. Demohshing the mill's structures is like destroying a crone scene before thorough forensic inN estigation. Public officials should have senously questioned why Rayonier had such an mtense interest in nmtiatmg demolition as soon as possible and before extensive site investigation. Certa nly, the possibility of the guilty party wanting to get rid of the evidence should have been an ob ous issue. Without any doubt, it would have been m the public mterest to first conduct a thorou site investigation before implementmg demolition activities. There has been unreasonable acce tance of information from Rayomer by government officials on all technical and environmental matters. Recommendations. Those parties who attempt -d to stop the City from issuing the necessary permits for demolition should consider petitio g the state Attorney General or the U S Attorney to mvestigate the processes and actin s taken by the City for possible improper conduct by local government officials. City gove ent had a responsibility to not rely on the information received from Rayomer and to recognise th., mtrmsic conflicts of interest Rayomer has m such matters, m terms of its own financial benefits versus public health and environmental interests. Some attempt to have a federal court stop the current demolition until EPA makes its decision about listmg the site on the NPL merits consideration. City contract for inspection and observation services during the Ravomer mill side demolition Conclusions. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 8 The scientific and regulatory guidance created by the City to provide the operational framework for the demolition activities and disposal of demolition wastes is not comprehensive or sufficiently deta led to assure the absence of toxic materials bemg disposed m the City landfill. The basic rationale of matenals sampling seems to be accepting the validity of information from Rayomer about 1 nor site activities, but what is really needed is a more objective systematic sampling approach to independently ascertain the real presence of toxic contaminants m buildmgs and other structures tc be demolished. Recommendations. Future independent technical examination of the demolition project should obtam all available records, reports, and laboratory data to thoroughly investigate whether the demolition process and waste disposal in the City landfill has caused potentially adverse impacts. DOE should closely examine sampling and testmg procedures being used for building surfaces relative to standard procedures for identifying hazardous wastes. Letter of September 8. 1997 to Jack Piths. City Director of Public Works. from Brown Caldwell Conclusions. Recommendations. Concerned citizens should take appropnate actions to oppose havmg the landfill leachate treated at the City plant, unless considerably greater technical information is obtained that supports this activity and assures public safety These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 9 There was msufficient data acquisition and engineering analysis to fully justify any agreement by the City to accept leachate from the Mt. Pleasant Landfill in its wastewater treatment plant. In this author's expenence, most municipal authonties that have thoroughly considered acceptmg landfill leachate have not found the benefits (presumably increased revenues) sufficient to offset the potential disadvantages, which mclude a failure of the City plant to function properly and, therefore, to become a pollutant source contrary to its regulatory permits and/or to suffer equipment failures that impede providing proper City services and raise City operation costs. EPA samphng plans for site in ection studies at Rayomer mill and two lam s Rayonier company Current Situktion/Site Conceptual Model Report The central task of this work was to review specified documents, given m the accompanvmg table, that pertain to the mactive Rayomer pulp mill and two landfills used by the company for mill solid waste dig osal. Both the ongomg demolition of the mill's structures and its potential cleanup, particularly under the federal Superfund program, and the potential cleanup of the two landfills under the Sur erfimd program are of mayor concem. If EPA takes no action for the mill site, the Department of Ecology (DOE) has mdicated that, after demolition activities, it will conduct a site hazard assessment, then rank the site and potentially place it on the Hazardous Sites List. Thereafter, DOE could oversee- Rayomer's conduct of site studies and site cleanup DOCUMENT City of Port Angeles pernuts City contractor agreement Letter to City official Introduction MAJOR PURPOSE OR TOPICS potential hstmg of sites on Superfund's National Priorities List the company's perspective on contammation and health and environmental threats, designed to influence government decisions about cleanup and pubhc perceptions city actions regardmg demohtion of the mill site covers functions of contractor for demohtion activities pertams to one of the landfills and the treatment of its leachate at the City wastewater treatment plant 10 It should be understood tl at this document review precludes many other activitiess. Also none of the documents from government agencies present much actual data for review and analysis. Only the report prepared by a contractor workmg for Rayonier contains substantial data. But many other documents were .,xammed to support the review of the pnmary documents. The Rayomer sites have a long history and there are many diverse issues that local citizens have found important, some of which may no: be relevant to this activity Accordmg to the contract with DOE, this limited activity was de: signed to provide the following general contributions: These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 11 provide independent review, translation, and evaluation of the specified documents facilitate informed community participation enable effective stakeholder involvement through mdependent techmcal assistance give explanations of the divisions of hierarchy of several government agencies' authonty over and responsibility for specific activities at each of the related sites It should be noted that this author visited Port Angeles over several days in early December 1997 and exammed the three sites, mcludmg a detailed tour of the mill facility and ongomg demolition activities, and even a visit to the city landfill receiving demolition wastes, at which time it was possible to watch a Rayomer shipment unload at the landfill Another landfill was also observed, called the Daishowa Amenca landfill, at which EPA is also to conduct a site mspection. Also the author met with a broad diversity of parties, mcludmg: Rayomer company and contractor staff; EPA Region 10 officials, City officials and their contractor County officials, hospital officials, hospital nurses, leaders and staff of the Lower Elwha Klallam Tribe, Department of Ecology officials, a representative of a state environmental group, and a number of local residents associated with the Olympic Environmental Council and other groups. A regular quarterly meetmg of the local Economic Response Task Force was also attended, at which very tittle of substance was presented and no significant scientific content ments attention for this activity All of these meetmgs supplied valuable information and insights into citizen concerns and needs and diverse economic and environmental interests, as well as the histoncal context of the sites and techmcal information pertment to the document review task. The Rayomer situation is especially difficult for concemed citizens because of multiple sites posmg different problems. With a demohtion activity and several potential site cleanups people may find it difficult to set pnormes for what they want from government agencies, particularly EPA. Contrary to what people may perceive as ngid legal requirements and absolute needs, these matters are, to a large degree, negotiations, even if not fully recognized by all parties. Facing both government agencies and a strong company with very large amounts of money at stake, concerned citizens are best guided by good information on the best opportumties to gam the most nsk reduction for the most certain threats. `The EPA sampling plan for the PA/SI activity was received after this report had been nearly completed and will not be discussed m this report. The EPA plan made no reference to any waste disposal from Rayomer (although this may not be accurate), and the DOE contract exphcitly refers to Rayomer sites. However, for the most part, the deficiencies identified for the EPA plans for the two Rayomer landfills also apply to the Daishowa Amenca landfill. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations For example, some people may focus on demolition of the mill site. Surely some demolition activities can pose umniediate short-term threats. Yet compared to the exposures large numbers of people have already faced from the mill's operations and possible future exposures resulting from a poor cleanup oft ie mill site and surroundmg waters, the demolition threats are much less severe. Similarly, the li ndfills probably pose less threat and less opportunity for gam above what would likely happen without EPA action. It is hoped that this report will assist citizens m settmg pnonties for their own efforts so that a focused effort can succeed obtaining the best protection of public health and environment that night not otherwise be obta ed. But settmg pnonties for the broad community can be difficult when many parties have vested their time and energy on different issues. This report can assist community dialogue to shape community priorities. This report is presented in sections that correspond to the documents specified in the contract and are given m the order shown m the above table describing the documents. Per the contract requirement to present rotten recommendations, regarding immediate and long -term pubhc activities, as are reasonable and appropnate to expedite effective remediation of the former mill site," recommendations are al >o provided in this report. EPA Sampling and Ouality Assurance Plans for Site Inspections of the Ravonier mill site aid two landfills The contract required the consultant to address the degree to which the plans provide "scientific mquny sufficient to re and to residents' concerns." This report presents findmgs regarding the degree to which the ssessment plans provide sufficient basis for EPA's determination whether to place th sites on the National Priorities List (NPL). For community residents the key issue is whether 1 hey should have confidence in the EPA process, which they wanted, and whether they can expo pct one or more of the sites to be fisted on the NPL by EPA. )ocument Reviews This review has made use of only of the plans themselves but also of EPA s "Guidance for Performing Site Inspections Urder CERCLA," (September 1992) because this is the key document that details exactly what EPA regional offices (and its contractors) are supposed to do m site mspections. Also, copies of comments submitted by other parties to EPA about the plans and responses from EPA have alsc been examined. Some mformation obtamed verbally from EPA staff at a meetmg m Port Angeles has also been used, and a request was made to EPA for These contents reflect the atthor s views only They do not represent the Department of Ecology s findings opinions or recommendations 12 changes m the plans, which are typically made because of field conditions or onsite information. It must also be noted that only when EPA issues its SI reports will the public have an opportumty to see the full extent of information and analyses used by EPA to support its conclusions and hstmg decision for each site. Getting EPA to provide drafts for review is crucial for optimal public participation, especially if there is mdependent technical expertise available to concerned citizens. First, it should be understood that the NPL is a regulatory instrument of the federal Superfimd program authorized by the CERCLA statute. Only sites that get placed on the NPL qualify for remedial actions, which are normally extensive cleanups. Listing on the NPL is a very significant action which then triggers many requirements specified in the statute and the National Contingency Plan, which is the main regulatory regime for the Superfund program. However, EPA can take a vanety of removal actions for sites not placed on the NPL, removal actions are less intensive and costly actions that do not have to comply with the more stringent requirements applicable to remedial actions. Nor do removal actions allow for funding from EPA to community groups for Technical Assistance Grants. The mam purpose of the three plans reviewed for this work and the site mspections based on them is to provide EPA sufficient information to decide whether or not the sites qualify for placement on the NPL, which means providing data by which EPA's Hazard Ranking System (HRS) model can be used to determme a site score, which according to EPA practice must be at least 28 5 to qualify for the NPL listing. It should also be noted that EPA first proposes sites for the NPL, following regulatory rule- making procedures, and allowmg for challenges to the proposal, before a final listing of the site on the NPL. Also, based on the data it obtains, EPA could decide to both list a site and, because of immediate threats to public health or the environment, also take (or cause Rayomer to take) a removal action. It must also be noted that there is a subtle distinction among the three plans. The plan for the mill site is for an Expanded Site Inspection (ESI), while the plans for the two landfills are for a Preliminary Assessment and Site Inspection (PA/SI). An ESI is a larger effort than an PA/SI, particularly m terms of the amount of environmental sampling and testmg that EPA conducts. A PA/SI, however, could be followed up by more SI work, if the data suggest the potential for NPL hstmg. According to the guidance, "Durmg the PA, EPA collects background information to determine whether the SI is warranted." For the SI, the key part, according to EPA, is sampling to "determine whether hazardous substances are present at the site and are migratmg to the surrounding environment." No information about PA activity at the Rayonier mill site has been obtained. It is particularly important for the community to understand that in the case of the mill site, where an ESI has been conducted, EPA guidance acknowledges that "an expanded SI should be reserved for sites that annear to aualifv for the NPL." (emphasis added) In other words, the large expenditure of funds for the ESI has been justified mtemally by EPA recogmmmg the high These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 13 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 14 probabihty for listmg the mill site on the NPL. This seems quite reasonable, because of the long histonc record of documented rel vases and discharges of pollutants mto surroundmg air, water and land by the Rayonier mill over many decades.' This author has examined portions of two key histonc documents that clearly pr wide evidence of the pollutmg nature of the Rayomer mill site, both by government agencies.' Nevertheless, whether or not EPA Region 10 m fact hsts the site depends on the data it obtains anc how it interprets the data within the SI and HRS system it employs. There is no assurance a t this time that the Rayomer mill site will become an NPL site, despite EPA's presumptions and ;activities. Probably the most important scientific concept for people to understand is that the ESI and PA/SI studies are very limitec in scope and are not the full fledged site mvestigations that take place for NPL sites as part of the Zemedial Investigation and Feasibility Study process that is tnggered by NPL listmg. The ce tral objective of the earher SI studies is to deliberately seek mformation on whether there hav been uncontrolled releases of hazardous substances from the sites mto the environment and wh ther there is a real likelihood of actual exposures and impacts from those releases. The HRS re ers to "targets" and to obtam NPL hstmg the SI needs to show significant contamination at target s that relate to either people or sensitive ecological assets potentially impacted by contaminants. No actual health nsk assessment is performed as part of an SI and the HRS only attempts to i 3entify relative nsks among the universe of potential cleanup sites. As EPA's guidance said. Is formally, SI sampling strategies require biased sampling, also known as non random or judgmer tal sampling. Biased sampling uses knowledge of the site and visual observations to propose sar iple types and locations." In other words, EPA is supposed to preferentially look m locations dui ing the SI where any information mdicates contammation is 'It should be noted that, ac cordmg to the EPA guidance, the desired goal for NPL hsting is to have EPA acknowledge an "c bserved release" can be satisfied by either direct observation, which includes havmg information verifying that a hazardous substance has directly entered the medium, which should be possible for the mill site by using various government records and information, or by chemical analys s which the SI performs. It should also be noted that only "some portion of the release must )e attributable to one or more sources at the site," which means that havmg other sources of some releases does not automatically rule out making the case for hstmg the Rayomer mill site. On this same point, the guidance noted the need for sampling to "be designed to determme whether the site is at least partially responsible for the contammation." 3 "An Investigation of Pollu ;ion m the Vicinity of Port Angeles," Washmgton Pollution Control Commission, Technical Biilletm No.23, Summer 1957 "Pollutional Effects of Pulp and Paper Mill Wastes m Puget Sound." U S. Dept. of the Intenor, Federal Water Pollution Control Admm. And Washmgton State Pol [ution Control Commission, March, 1967 15 likely to be found. Although it seems to have done this to some extent for the offsite residential samphng, this study has found that EPA does not seem to have this for marine sediment sampling. The SI studies are closely keyed to the detailed data requirements of the HRS The main legitimate citizen concern for these studies is whether they are designed well enough to find the hard evidence of releases into the environment, because poorly designed plans can produce false negative conclusions. This means that EPA decides that the data do not provide sufficient evidence for NPL listing when, m fact, such conditions really exist. In other words, the early SI studies and the HRS act as gateways into the federal Superfimd remedial program. Because of the uncertainty of EPA action, the community should be aware of the legal opportunity for the local Tribe to invoke its nghts under the CERCLA statute and to nominate the mill site and surrounding land and waters for the NPL. Additionally, the commumty needs to pay close attention to the authonty under the federal CERCLA statute to have federal trustee agencies take legal attention to obtam compensation from responsible parties, such as Rayomer, for natural resource damages, including the cost of assessing the damages and restormg or replacmg key natural resources. It is not necessary to be an NPL site for this action, but if one, then filing of a damage claim must await remedy selection. CERCLA authonzes certain federal, state, and tribal authorities to seek monetary damages for mjuries to natural resources, mcluding wetlands, fish, and wildlife habitat, resulting from releases of hazardous substances.' NOAA is the key federal trustee agency for coastal and marine environment locations. It also appears that the state of Washington is a natural resource trustee because of its ownership of waters leased to Rayomer And the local Tribe is probably a trustee because of its rights for some local waters and fisheries Under CERCLA section 126, that provides rights to Indian Tribes, and section 105(8)(A)(B), the Tribe, like states, could submit to the EPA Admimstrator its pnonty for remedial action and EPA must consider such a pnonty; the statute does not specify a numerical HRS score required for the NPL. Also, part 300 6 15(e)(2) of the National Contmgency Plan specifies that any trustee can request EPA to take a removal or remedial action. 'For some background information on natural resource damage actions a 1995 report from the General Accounting Office is useful. "Status of Natural Resource Damage Claims T -RCED- 95-239 and "Outlook for and Experience With Natural Resource Damage Settlements," RCED- 96-71 April 1996 Among cases reviewed were two m Washington. the City of Seattle case for Elliott Bay with a settlement value of over $24 million, and the Simpson Tacoma Kraft Co./Port of Tacoma case m Commencement Bay with a settlement value of about $13 million In both cases a combination of federal, state and tribal trustees successfully obtained settlements with responsible parties. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations impacted by the Rayomer mill EPA Plan for the R mill site table. The more important technical issues for this ESI plan are summarized m the accompanying ISSUE MAJOR PROBLEM OR IMPACT Marine sediment sampling Bioassay sampling Offsite surface soil samples Dioxin test method Air data use of surface sediment samples only, but not subsurface or core samples, could mean little or no evidence of releases to harbor and food chain impacts madequate use of past sediment test data could mean EPA looked in wrong places, meanmg less evidence of releases EPA may not conduct extensive sampling offish, shellfish and other species, which could prevent high score for food cham impacts EPA may not use data showmg contamination m residential areas for NPL listmg purposes EPA should have used more shallow samples to maximize probabihty of findmg highest levels of contamination resultmg from deposition of contaminated particulates EPA will be usmg a novel method for obtammg most dioxin data, but this could mean more nondetects than obtamed from the standard, more sensitive test method, and less evidence of releases from site if EPA proposes site listmg Rayomer may protest use of data from novel method, if EPA does not propose listing, community residents can protest use of data no new data obtamed and EPA may ignore extensive past evidence of air releases These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 16 17 -Marine sediment samnlina:, EPA said that it would take samples from the top two centimeters usmg a grab sampler Taking such a very shallow sample (less than one mch) of harbor sediment is unacceptable. However m a response to a comment to Washington Department of Natural Resources (DNR), EPA indicated that sediment samples would be collected to a depth of 10 centimeters (or about four mches), which is much better than the ongmal depth, but may still be inadequate. The significant penod smce the plant has closed and new discharges released has been long enough to allow vanous sediment transport mechanisms to literally cover up sediments contaminated by vanous types of discharges from the Rayomer mill Over time, contaminated sediments can become more or less available to aquatic species, dependmg on local conditions that affect sediment movement, such as strong currents. The local Tribe correctly mformed EPA Region 10 before the ESI began about the "risk that contaminants in sub- surface deposits could be missed.i Also, "The Tribe believes the prudent course of action would be to mclude at least one subsurface sediment sample at every transect." The more correct approach would have been to obtam cores of sediments that allow testmg of specific samples correspondmg to different depths. This provides data that more closely resembles the histoncal nature of the discharges and the sediment transport actions m the location, and reveals subsurface contamination. This kmd of sampling is particularly important in refutmg the almost mevitable assertions by responsible parties, such as Rayomer, that there has been effective natural attenuation or destruction of hazardous substances m the environment. because of biological processes or dilution, for example. As Dr Kailin correctly noted in her comments to EPA, taking some core samples prior to full sediment sampling would have enabled EPA to discover the most appropnate depth of grab samples.' A key 1967 study of the harbor collected 22 core samples and 50 grab surface sediment samples.' In other words, either limited use of core samples or full use of them is necessary if the intent of the ESI is truly to obtam the best evidence of the maximum level of marine sediment contamination caused by the Rayonier mill Another subtle technical issue is that EPA has not mdicated any mtent to extract and 'Letter to Joanne LaBaw at EPA Region 10 from Loma Mike, Tribal Chair, October 7, 'Letter to Joanne LaBaw from Eloise Kailin, M.D President, Protect the Peninsula's Future, October 14 1997 8 "Pollutional Effects of Pulp and Paper Mill Wastes m Puget Sound," U S Dept. Of Intenor Washington Pollution Control Commission, March 1967 1997 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations chemically test pore water from s ;dement samples, which is necessary to obtam data on chemicals dissolved within the water, and w'uch could play a major role m causmg contaminated fish and shellfish. Nor was there any mdication that EPA had senously examined all previous sediment test data to optimize its samphng strategy for its ESI. A host of pnor data apparently exist, but it is beyond the scope of this study to examine them. Note that the state of Washington has apparently recognized significant ;ediment contamination by dioxins and PCBs m the Harbor waters.' The DNR commenters correctly noted the absence of adequate discussion of several past reports. It is also pertinent for E A Region 10 to appreciate the history of the Rayomer mill with respect to past EPA actions, incl g the request in 1972 of then EPA Administrator Ruckelshaus to the Attorney Gen ra1 to take legal action agamst ITT Rayomer's sulphite pulp mill m Port Angeles because of the di charge of enormous quantities of wastes in the harbor on a daily basis. mcluding: 10,450 tons of 1phite waste hquors, 881 tons of solid materials, 255 tons of biochemical oxygen consuming w istes, and 51 tons of sulphur 10 Such discharges would be expected to Impact sediments and marine life. Surely the dioxin levels m wastes were remarkably higher than m recent years." There is a strong possibility that by usmg shallow sediment samples EPA will find insufficient evidence of mill -cause 1 sediment contammation. This in turn would probably rule out scormg high enough on the surfac water -human mgestion route for the HRS. This issue also raises a core dilemma m this type f situation, when new discharges may have already halted, and the evidence necessary for listing ust come from sampling to identify past uncontrolled releases. Yet another associated issue is w ether EPA will correctly assess the real level of exposure resulting from human consumptio offish or other species from the harbor waters, even if the exposure is no longer prevalent. ,PA informed this author that it was unable to retrieve any 9 1996 Washington State NA ater Quality Assessment, Section 305(b) Report, Wash. DOE, June 1996 'Port Angeles News, Jan. 1 1971 Ruckelshaus was quoted. "Sulphite waste liquor has been shown to be toxic to valuabl species of marine life m small concentrations, yet ITT Rayomer plant officials have refus d since 1961 to even consider that treatment or removal of the contaminants is necessary "EPA found a 70% reduct: on m dioxin discharges from 1988 to 1993 as a result of technology changes m mills. It is i easonable to beheve that m earlier decades dtoxm levels were substantially higher EPA, "Development Document for Proposed Effluent Limitations, Guidelines and Standards for the Pulp Paper and Paperboard Point Source Category," 1993 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 18 significant number of living fish or other species durmg its conduct of the ESI. This may of course be indirect evidence of substantial sediment contamination that has already caused a severe ecological impact. Another pertinent techmcal issue is that sediments polluted by discharges from the Rayomer mill can move considerable distances and affect fish and shellfish outside the nearest areas to the mill For example, a recent study found long range transport of dioxms/furans in sediments and fish caused by a pulp mill. Bioassay samnhngi The only commitment that EPA made in its plan was for samplmg clams and mussels during it sediment sample collection activity But, as stated above, EPA indicated that only one clam had been found. EPA did not make an adequate commitment for a large enough effort, nor was there sufficient details m the plan, although it was mdncated that 12 samples of clams and mussels each would be taken from areas established as fishery resources. But the exact type of samples and analytical methods were not indicated. While sediment testmg can often be viewed as providing essential information relating to ecological impacts from a source of hazardous substances discharge, various other types of testing can also be essential, mcludmg testmg of living species (either whole or key organs), which may mclude smaller species lower on the food cham (not eaten directly by humans), and also aquatic toxicity testmg to see if water itself is toxic to living aquatic organisms. EPA, in its response to DNR, also indicated that it would analyze some geoduck samples per the recommendation of the Lower Elwah Klallam Tribe, but it is not clear that EPA has done or will do this. The Tribe informed EPA of the locations of four fisheries m the harbor that certainly could have been influenced by releases from the Rayomer mill, including a crab pot fishery, a public pier and recreational fishery site, a commercial/sport shrimp fishery, and an urchm /sea cucumber fishery' The Tribe correctly informed EPA that "Because both tribal members and the general public harvest fish and shellfish resources in the vicimty of the site, they are potentially at nsk from contaminants that may have ongmated from the mill site and accumulated in the food cham." The Tribe recommended "tissue 'Spatial Trends m TCDD /TCDF Concentrations m Sediment and Bottom Fish Collected in Lake Roosevelt (Columbia River), Wash. DOE, June 1991 This author found the analysis somewhat faulty because only the data on TCDD and TCDF were used, even though the 2,3 7 8- TCDD TEQ data were also presented m the report. TEQ means toxicity equivalent, it sums the contributions of various dioxins and furans m terms of the toxicity of the most toxic 2,3,7,8 TCDD congener 1997 13 Letter to Joanne LaBaw at EPA Region 10 from Lorna Mike, Tribal Chair, October 7, These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 19 analysis from bottom-dwelling fis.h, Dungeness crab, and hardshell clams." It appears that EPA has not focused enough attention on this important area. It should be noted that a 1988 EPA study offish from Port Angeles harbor found evidence of dioxms/furans, but that a later Rayomer study found only low levels of furans. Offsite surface soil samples: Perhaps the most remarkable statement heard from an EPA official was that even though EPA has conducted extensive offsite soil sampling, it does not beheve it would use the test data to support NPL listing, because of its concerns about its legal strength. In other words, EPA is concerned that Rayonier could argue agamst hstmg by assertmg that the soil contamination could have come from other sites. Although there is some truth to this, it is also correct that EPA has a long standing recogmtion that all it must show is that a particular facihty has made some contribution to offsite releases and contammation. Matching chemicals found offsite with those found offsite or known to be released from mill operations should, m fact, not be difficult. It is understood from the meeting with EPA staff and letters sent to several citizens that for the site surface samples were taken to a depth of 3 inches. This was apparently done at the reque of ATSDR (the federal agency with responsibility m the Superfund program for public he 1th), which recommended this over the originally planned depth of 6 inches. In fact, if the mtenti is to find contamination data showing offsite contamination that could lead to human exposur through inhalation of dust particles, ingestion or direct contact, then an even more shallow surfac soil sample may have been appropriate. In this author's opinion a depth of one inch is the ost appropriate protocol m such mvestigations. Indeed, a key EPA document supports this view: "When measuring soil contamination levels at the surface for the ingestion and inhalation pathways, the top 2 centimeters is usually considered surface soil. "l5 This more shallow sampling (less han one inch) is particularly appropnate for existing residential areas. It is somewhat ironic tha EPA has taken marine sediments at too shallow a depth and residential soil samples at t o much depth to reveal the worst contamination. Moreover each location, uch as a residential yard, must also be assessed with respect to the history of that location m orde to discover whether there may have been actions taken that would mvandate the sampling. Fo example, any relatively recent covering of old soil (which could have been impacted by deca es of air deposition of contaminated dust particles from the 14 The information about tho. EPA and Rayonier studies is m the Rayomer Conceptual Model report, p.2 -53, but the onginal reports have not been obtamed and examined, therefore, details about sampling and testing ire not known and may be important m understanding the hints to the data reported by Rayomer "Soil Screening Guidance Technical Background Document," EPA, May 1996, p 84 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 20 mill stacks and fugitive emissions) with new soil would mvandate the sampling location. In this author's opinion it is also deficient to test only outdoors soil and not seek places where dust may have accumulated over years of discharges from the mill site, including, for example, dust m attics in homes close to the mill. It is understood that EPA based its final sampling locations on mformation from citizens, but the exact details have not been received. Lastly, it should also be noted that it is not clear to this author whether EPA used discrete grab soil samples or composite samples. If composite samples were used for specific locations (meaning that soils are blended together from several places at the location) there is a high probability that contaminant levels observed could be lower than those obtamed for grab samples, depending on how the exact samphng sites were chosen. Also, choosmg a sample from behind a house or under a tree that would be less impacted from wmd blown particles could bias test data to the low side. -Dioxm test method. It is understood that EPA changed its protocol from the ongmal plan to use standard method 8290 for testmg of dioxins and fivans to a protocol that had been chosen for the two landfill sites. In the latter, EPA has decided to base its dtoxm testing pnmarily on the use of a relatively new laboratory method which only one company has commercial nghts to The method is referred to as a P450 Reporter Gene System Assay offered by Columbia Analytical Services and is based on usmg a genetically engineered human cell that responds m a measurable way to certain toxic chemicals. Considerable mformation about this method was obtamed by the author directly from the company in writmg and m an extensive phone conversation." EPA said that it was using this method to save money, and this is definitely the case, because the overall costs may amount to only about 15% of the costs for using 8290 The assay method is described as a "screening method" which generally means that it is less accurate and has a higher detection limit, and is much lower cost, than the full standardized laboratory method, which m this case is 8290 The assay method has had only limited use, but has apparently been especially used by EPA's SI contractor It is doubtful that the method has the full blessmg of EPA (and not Just EPA Region 10) and there are a host of technical issues that can and should be raised about its use, especially if the data obtained by EPA does not show high dioxin levels. 16 This company has also provided services to Rayonier, accordmg to citations m Rayomer's "Current Situation/Site Conceptual Model Report." "There are many highly technical factors about this testmg that can be considered when test results are obtained and when and if they are revealed in EPA documents that can be mdependently examined. This is a sophisticated and complex test procedure that, like conventional ones, requires certam procedures to be employed. It should be understood that the assay method is NOT chemical analysis, but a measure of a gene response to chemicals. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 21 There is no doubt that thf assay method has higher detection limits, which means that it is possible that some samples might yield a nondetect findmg, whereas the same samples tested by 8290 might show a positive dioxim/furan finding Moreover, a major complication is that chemicals other than dioxins and furans can produce positive findings with the assay test, particularly certam chemicals refE;rred to as PAHs (polycychc aromatic hydrocarbons) and some PCBs, which are also likely conn minants m some mill site samples. In other words, the assay test gives an mtegrated (or total) rest onse to any mixture of planar orgamc compounds in a sample. The extent to which the test data will be carefully analyzed to differentiate among these chemicals is now uncertam, but it is a crud ;1 necessity Importantly, m its plans for the landfills, EPA has told this author that 30% to 40% of samples would be sent for confirmation analysis using EPA method 8290 Although EPA has not made it clear, the normal approach would be to select such confirmatory samples on the basis of high contaminant levels found in the assay test. Nevertheless, whether or not the confirmation samples provide sufficient data to demonstrate a very good statistical correlation between assay data and 8290 data remams to be seen. For example, one problem could emerge if the 8290 samples do not cover the full range of dioxin levels m the actual sample; and if they do not have the full array of other contaminants present. On the other hand, EPA. could base its conclusions only on the 8290 data and ignore the assay test data. If the 8290 data or even some assay data which show high dioxm levels, then there will be no issue. But the potential problem is that EPA may be using data that show relatively low levels or nondetects from either or both of the tests. Legally, EPA may assert that it is free to use the new method, ;specially because it is being used for SI work and not for obtaining data for a full health risk assessment, but there is no doubt that it is unconventional. Onlv a careful review of the actu 11 data obtamed from both the assay and 8290 methods (as well as other data for PAH and PCB testing) will allow a more complete independent analysis of this issue. A subtle disadvantage oft smg the assay method is not obtaining the full range of specific data on mdividual dioxin and fun n congeners, without which it is difficult to use some "fingerprinting" approach to relating findmgs of dioxins offsite with findings of dioxms onsite. Unlike method 8290, the assay r ethod only gives results m terms of 2,3,7,8 -TCDD TEQ values, rather than data for specific dioxin and furan congeners. It is important to note that the mventors of this assay method appropnately discussed the tradeoff between having higher d Aection limits than standard chemical analysis methods versus lower costs.' Their pomt was that there was an advantage to usmg more numerous assay samples, possible because of much lower costs, over using a small number of samples tested by W Anderson et al, "A Biomarker, P450 RGS, For Assessmg the Induction Potential of Environmental Samples," Env T micology and Chemistry, vol.14, no 7, pp 1159 -1169, 1995 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 22 expensive chemical analysis. In other words, false negative results (i.e., missing real contamination) could be reduced by havmg more samples, even though the detection limits were higher for the assay method. The scientists noted a detection limit of 50 parts per trillion (ppt) for dioxin, but method 8290 usually has a detection limit for TEQ values of only 1 ppt. The issue for the site inspections is that there is no real evidence that EPA greatly increased the magnitude of sampling because they were relymg on the low cost assay method. On the positive side, it should be noted that when the assay method reveals positive levels of contaminants the actual numencal values reported tend to be higher than the values obtained from chemical analyses of the same samples, by a factor of 2 or even much greater for dioxin TEQ values. However, this situation could become a negative factor, because Rayomer could challenge assay data, compelling EPA to only use chemical analysis 8290 data for HRS scoring and NPL purposes, which means relying on very few samples from the site inspections. Scientifically, it seems clear that the assay method is producing higher concentrations because the chemicals are actually more toxic than that presumed in the traditional methods used to convert specific dioxins and furans into a toxicity equivalent value or TEQ But in a legalistic or regulatory sense, the overall impact of using the assay method for obtaining most of the site inspection data is probably negative, meaning that if EPA decides NOT to hst a Rayonier site on the NPL, that concerned citizens can mount a strong objection based on the extensive use of the assay method to obtain contaminant data. But much depends on examining the considerable details of testing revealed in SI reports. -Air data. The ESI did not attempt to obtain new air data, nor is it clear that EPA will use previously obtamed data, even from its own comphance activities or from data obtained over many years from company testmg. Even though EPA, in its guidance, has said "air sampling is an expanded SI activity," in this case EPA will surely argue that the lack of any operations at the mill removes its obligation for testing, although it could use data from its air momtonng related to the site demolition activities. The direct inhalation of contaminated dust particles from both the stacks as well as fugitive emissions from vanous onsite mill sources may be not be considered by EPA m its ESI and HRS scoring activities. This of course would be a most serious deficiency There is such a massive amount of historical data on air releases from this mill that no rational person could believe that human exposures have not occurred. Current air momtoring related to site demolition activities, of course, do not at all pertam 19 For discussion purposes, for example, consider an initial plan based on testing 20 samples with expensive method 8290 It could be replaced by first testmg 50 samples with the assay method, followed by about 15 selected samples using 8290 at about the same cost. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 23 to the much more intensive level (If air pollution that existed for many decades from the mill operations. Citizens should also recognize that results from the soil testmg are not likely to be presumed by EPA to be evidence of air deposition of discharges from the mill. As the EPA guidance said. "Soil samples may of qualify to document an observed air release by chemical analysis smce substances may hav migrated via non atmosphenc transport mechanisms." But in this case transport from some oth r site by any other means is implausible, but transport by air from some other site could be ar ed. Again, EPA must be willing to match up contaminants offsite with those on the Rayome mill site. It is particularly striking that over three weeks in 1989 EPA acted under its legal Superfimd authority to conduct a comprehensive site audit of the mill "because of its history of sulfur dioxide releases.i EPA f and "severe deficiencies m the maintenance and operation of mill processes which greatly mere se the potential for hazardous substance release inherent m the mill." Although a safety audit, th effort has considerable relevance for understanding both air releases and site contamination. particularly important observation by EPA was. "The audit team noted that the outlet of the ower boiler stacks were slightly above the elevation of the surrounding residences (which ar located on a hill above the mill), and that durmg certam weather conditions, stack emissio s would travel horizontally, or at a slight downward grade, through the neighborhoods to the south and east of the mill. These emissions were detected by odor and observation. (They appwared as an aerosol.)" Conclusions. The mill site has been a m;gor cause of environmental pollution and impacts in the Port Angeles community and ments N'L hstmg. A very large number of people have surely been impacted by decades of mill oper Lion. Because of serious deficiencies in the sampling plan there is a high probability that EPA will not score the mill site high enough for NPL listing. This may sound ludicrous to citizens since there is a clear presumption that the site meets the standard for NPL listing as shown by the costl;✓ ESI EPA has conducted. Nevertheless, there is considerable cause for concem. The mam problems are senously deficient marine sediment sampling and a likelihood that EPA will ignore previously obtained data showing substantial air pollution from the site. EPA may also discount the full impact on fisheries in the harbor There is, however a good chance that EPA aught compromise by calling for one or more removal actions, especially 20 "Technical Assistance T( am Chemical Safety Audit, Report for ITT Rayomer, Inc., Port Angeles, Washington, December 1990, Ecology and Environment contractor report for EPA Region 10 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 24 smce the state of Washington DOE has already estabhshed two specific hot spots and remediation areas. EPA could then claim credit for establishing removals, but in fact doing so would probably have tittle impact on what is already going on and planned for those two small cleanup locations. Recommendations. Some useful activities for citizens pnor to EPA issuing its ESI report include making the case on the basis of pnor mformation on air emissions for a high air pathway score, obtammg mformation venfying past human consumption of fish and shellfish from the harbor• and making a public point about the deficiencies of the marine sediment sampling. The community should appreciate the fact that it is far better to attempt to influence EPA's actions before it issues its SI report than wait for the report and then try to change EPA's conclusions. Commumty groups should formally petition EPA Region 10 for the nght to review a draft ESI report. The community should also support the local Tribe nommatmg the mill site for the NPL and remedial cleanup, because it has the legal right to do so Future independent technical analysis for the community should, of course, focus on the ESI report eventually issued by EPA. If EPA Region 10 does not hst the mill site, concerned citizens should senously consider petitioning EPA's National Ombudsman for assistance and to provide an mdependent agency techmcal review of the ESI and FIRS scoring done by Region 10 Groups such as the Olympic Environmental Council should senously examine how the ATSDR can be used effectively, especially by petitioning this federal agency to provide consults on very specific activities and documents, especially those by EPA Region 10 EPA Plans for the two Rayomer landfills The fundamental issue for the community is whether the very limited scope of the SI These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 25 Both plans will be considered because they are essentially the same plans. It should be noted that the documents are designated as Preliminary Assessment /Site Inspection plans, indicating that no prior PA activity had occurred for the sites. Although the history of the 13th and M Street Landfill and the Mt. Pleasant Landfill are different, and different Rayomer wastes were disposed m them, from the perspective of an SI, both sites can be treated m similar ways. As already indicated, the SIs for the landfills are not as extensive as the ESI for the mill site. The basic structure of the sampling is the same for both landfills, but the Mt. Pleasant landfill is larger and more complex (with two distinct cells) and probably received the more toxic Rayomer waste, explaining the larger number of planned samples for it. Thus, there were 27 planned samples for the 13th M landfill which is 8.5 acres m size, and 65 for the Mt. Pleasant landfill, which is 64 7 acres m size. These are consistent with the limited scope of an SI. sampling is sufficient to detect thf, maximum levels of offsite contamination to make the case for NPL listing. One difference between the landfills and the mill site is that groundwater contammation caused by the land exposure, if there are local reside this author got the impression fro may make it very unlikely to obtain NPL listmg for the groundwater pathway (the most frequent basis for NPL hstmg). In fact, without this pathway being prominent m HRS scoring, there is very tittle reason to believe that ti landfills would be fisted. Air and surface water pathways are not likely to result in high HRS s ores. Although some citizens may have strong views about the landfills, finding them repugnant d dangerous, from an SI, HRS, and NPL perspective such landfills m such locations are e1y to be listed by EPA. However, EPA might find enough evidence of offsite contammation to cause some removal action to be conducted by Rayomer ISSUE Number of landfill samples Air pathway Dioxin testmg Offsite soil testmg Sediment sampling ills, if present, would have some potential to result m human teal wells downgradient of the sites used by citizens. However, n EPA sources that no such wells are now being used, which The mam technical issues for the landfill SIs are summanzed m the followmg table. MAJOR PROBLEM OR IMPACT too few samples could cause EPA do not link contammation offsite with landfill contents no data obtamed and EPA may ignore air releases same problems as for mill site plan few samples for background and residential areas will likely prevent NPL listing too few samples will likely prevent listing These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 26 Number of landfill samples: The mam importance for NPL listmg from testmg the contents of the landfills is to establish exactly what chemicals are present m the landfill so that offsite contamination can be logic illy linked to releases from the landfills. The mam problem is that very limited testmg m any suc h solid waste landfill can produce data that do not reveal all the chemicals actually present. For the 13th M landfill only 8 landfill waste samples were indicated in the plan, and for the Mt. Pleasa it landfill only 16 samples. According to the plans, two bormgs would be obtamed at the 13 M landfill, with four samples from each, and similarly two borings m the two main parts of the Mt. Pleasant landfill (the mactive sludge cell and the woodwaste and hogged fuel boiler ash cell). In actual fact, from each bonng location one sample will be from the soil cover above buried waste, which certainly is not likely to reveal chemical wastes. Such a limited number of bormgs has a low probability of revealing the full extent of waste composition. In other words, citizens have every right to be concerned about the possible scenano wherein some chemicals might be found outside the landfills but not mside them, causing EPA to avoid making a conclusion that the landfills have leaked. It should also be noted that in Rayomer's Current Situation/Site Conceptual Model Report there were two references to ash type matenals being tested and found to be "defined as dangerous wastes," because of bioassay testing m September 1983 21 This suggests the possibility that state defined dangerous wastes may have been disposed in the landfills. -Air nathwav: EPA is not obtaining any data about air releases, which is consistent with the limited scope of a SI. As for HRS sconng, no score is likely for the air pathway It should also be noted that methane does not qualify as a hazardous substance for Superfund purposes. According to the EPA guidance. "Although methane may support a release of other hazardous substances from a source, methane cannot be used as the observed release substance because it is not a designated hazardous substance under CERCLA Section 101(14)." It is worth noting that the Mt. Pleasant plan made the following observation. "During the initial site visit on August 7, 1997, START [EPA's contractor] observed openings in the geomembrane cover which left areas of the inactive sludge cell exposed." This kind of landfill condition is senous and provides support for EPA finding that particulate releases from the landfill contents have occurred. -Dioxin testma: The comments made for the Rayomer mill site ESI apply to both landfill plans. There is little doubt that dioxin waste was disposed in the Mt. Pleasant landfill, but whether dioxins have migrated from the landfill is problematic. The limited use of 8290 testing reduces the probability of finding dioxins inside and outside the landfills. -Offsite soil testma: The plans indicated that surface soil samples from 4 residential yards near the 13 M landfill would be collected, and from 10 residential yards near the Mt. Pleasant landfill. It is understood from EPA officials that surface soil samples were collected from a depth of six mches, which is believed by this author to be unacceptable to establish maximum contammant levels posing a health threat due to inhalation, ingestion, or direct contact. Only one sample for each landfill was used for establishing background levels, which may be quite inadequate. A potential problem is that major air pollution from the Rayomer mill over many decades may have caused widespread surface soil contamination within several miles of the mill. The problem is that a smgle background sample may actually show contaminant levels that invalidate (from EPA's perspective) contaminant levels found m residential soil samples. That is, 21 The two statements are m section 6 p 6 -19, entries for September 2, 1983 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 27 EPA could conclude that the con aminants were not caused by the landfill if they were also found m a background sample. But a background sample affected by the Rayonier mill is not a valid background sample. Contamination of residential surface soils by surface water runoff from the landfill sites seems unlikely, unless local residents had witnessed such runoff and caused EPA to sample from appropnate location; on their property Sediment samnlinn: Thi is important for finding evidence of contaminated surface water runoff from the landfills. Howev r, unless a closed exposure pathway can be confirmed by EPA, the mere findmg of offsite conta ation m stream sediments would not likely result in high enough scormg for NPL listing. PA needs to consider impacts on fish that may be impacted by stream pollution from the landfill Data for the Mt. Pleasant landfill reported by Rayomer showed regulatory violations ove the 1994 -1996 penod for dissolved oxygen, turbidity pH, and fecal coliform, which certamly su, gests impacts from stormwater runoff or leachate from the landfill. It is necessary to sample both upgradient and downgradient locations to establish a causal link between the landfill and any contaminants found downgradient. With only 4 sediment samples for each of the landfills, it is possible that no contamination will be found, especially if the worst pollutant releases from the landfill sites have occurred m the past and there has been heavy rainfall smce that tune. Here too, unless EPA can make a good case for human exposure to contaminated sediments, no high `.SRS score is likely Groundwater testinn: A small number of groundwater momtonng wells were sampled. Although some groundwater cons amination may be verified, the absence of contamination of drinking water supplies would probably rule out a significant HRS score for NPL hstmg. The broad array of chemicals tested for will provide better information than the data bemg obtaining from routme testmg of momtonn€; wells. Citizens should be aware that, according to EPA. "In 1991, EPA concluded that dioxm contamed in pulp and paper mill sludges does not pose an unreasonable nsks (sic) when disposed m landfills and surface impoundm ,nts and that further regulation of these facilities under Subtitle D of RCRA was not warranted. i 'Letter from Puget Sounc keeper Alliance to DOE, April 17, 1997 ""Formation and Sources of Dioxm -Like Compounds, A Background Issue Paper," by EPA contractor Versar, Inc. Nov ember 7, 1996, p 57 These contents reflect the aathor s views only They do not represent the Department of Ecology s findings opinions or recommendations 28 Conclusions. 29 Because of the mtrmsic limited scope of a normal SL some deficiencies in the sampling plans, and the low probability of closed exposure pathways, it is unlikely that either landfill will be scored high enough by EPA for NPL listmg. The reality that many citizens will not find comfort m is that even with some releases of hazardous substances from the landfills into the environment, it is very difficult to establish actual threats to pubhc health. especially if there are no contaminated private drmkmg water wells. Because buried wastes are covered up and there is no public contact with them, offsite releases have to reach human receptors m some plausible way if a high FIRS score is to be obtamed. Landfills in relatively rural areas have particularly little chance of NPL listmg unless local drmking water wells are contaminated significantly And even in those cases, one frequent action is simply to provide those residents with connections to city water supplies. In other words, any thoughts that EPA intervention will make the landfills go away is unfounded and unreahstic Once landfills are legally sited, permitted, and constructed it is unreahstic to think that some government action will remove the landfills. Extremely few landfills are excavated and, in fact, EPA's presumptive remedy in its Superfund program for non- hazardous waste landfills is various forms of containment, such as caps and subsurface bamer walls, and this containment approach is also used for most hazardous waste landfills on the NPL, except for proven hot spots of contamination within landfills. Recommendations. Citizens very concerned about the landfills are advised to focus their efforts on obtaining hard evidence of observed releases from the landfill and, if obtained, submit such information, in terms of affidavits and photographs, to EPA Region 10 Verifying whether or not private well are bemg used for drinking water could also be useful. Community groups should formally petition EPA Region 10 for the right to review draft SI reports. They should also focus more on possible removal actions by EPA and improvements m the landfills themselves and m momtonng at them that government agencies (particularly the County) could compel Rayomer to make. The main government agencies that will retain junsdiction over the landfills, if EPA takes no actions, is the County and DOE therefore, concerned citizens may have to shift their attention to landfill closure and monitormg requirements and compliance for the long term. Current Situation /Site Conceptual Model Report (October 1997) The DOE contract specified the goal of examining this report and evaluating the matenals' pertmence in developmg the Rayomer properties's site investigation plan. It is not possible to determine exactly how this report has or has not been used by any government agency But it is These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations possible to identify problems with the report and to explam why members of the Port Angeles community should be extremely cautious m relymg on it's analyses, interpretations, and conclusions. But some factual miormation that it presents is very useful. It is also important to understand that Rayomer is wor g within a framework where it has acknowledged two specific, relatively small contamination are s that require remediation that Rayonier has accepted responsibility for One is the des ribed as the Pulp Mill Fimshmg Room area where hydraulic fluid releases, including some ve high levels of PCBs, are bemg addressed, including Ennis Creek groundwater and soil reme anon, under a state enforcement order The other is the Pulp Mill Oil Storage Tank Site with p troleum releases under a road and buildings there. Also, another contammation area was t e hog fuel pile, caused by petroleum releases, but Rayonier apparently was successful in ha g the state accept natural in situ bioremedation as the remedy All of these areas probably have been sources of hazardous releases into Port Angeles Harbor It seems clear that the goal of Rayoi ter is, if at all possible, to avoid having the larger mill site and the Harbor declared a cleanup site, by either the federal or state government. This report was prepared or Rayomer by its contractor, Foster Wheeler Environmental Corp It actually covers both the site and the two landfills that EPA has performed SIs for The report noted that. "A site co ceptual model is a model of the potential sources of contamination and potential pathways based on currently available site information." This statement has been carefully constructed to emphasize the word "potential' because Rayomer is not admittmg that contamination is present or if it is present that it presents nsks to human health and the environment. Here is an EPA defimtion of a conceptual site model. "a three dimensional `picture' of site conditions that illustrates contaminant distributions, release mechanisms, exposure pathways and migration routes, arLd potential receptors." In another EPA descnption m plainer language the site model was said 1 o address "how the pollution is distributed over the site and how it might impact the environment or the pubhc." The model presented by Riyomer is incomplete. It has been constructed, as the whole report has been, to intentionally attempt to limit the scope of government activities and the thinking of members of the Port Angeles community As the report itself said. "It is mtended to focus the attention of decisionmal ers on those areas and operations that may warrant further consideration." No sensible member of the community or any government agency, however, should accept at face value the I ontents of this report. As one important example of the considerable limits of this work, n ite that the prelimmary site conceptual model presented m section 2.5 3 did not acknowledge any contribution, m terms of an onginal source, from decades of air pollution m causmg longer t ;rm contamination and exposure through air deposition of pollutant particles onto soil surfac 3s. which then have served as fugitive air emission sources for human mhalation and ingestion, a' well as exposures through direct contact. As another example, the Rayomer model did not ackno Arledge contaminated groundwater at the site affectmg These contents reflect the a'zthor s views only They do not represent the Department of Ecology s find.ngs opinions or recommendations 30 ecological targets, such as aquatic species m the harbor The conceptual models presented for the two landfills do not pose similar problems, except that releases of particulates and consequent exposures pnor to complete landfill closure have been largely ignored. The approach here is to present what are believed to be some of the more important techmcal issues for this document to both illustrate its limitations and, more importantly, to provide information of potential use to the community -Wind direction data. There is an interesting collection of data presented section 2.2.5 However, what is not revealed through a fair analysis of the data is that about 35% of words would be an effective transport mechamsm for airbome particulates from the mill site over the commumty For the strongest wmds, the fraction nses to about 50 It is crucially important to understand the enormous probable impact from decades of heavy air pollution from both stationary sources, such as stacks, as well as fugitive emissions from equipment and open materials. There has undoubtedly been a major deposition of heavily contaminated particulates onto surrounding community components, including people, buildings, cars, gardens, and soil. While some current governmental activities cannot directly address past human exposure and health effects, there defimtely is a need to recognize contamination still existmg, but originally caused by mill air pollutants, particularly soil contammation that can remain stable for long penods. Direct discharges into Port Aneeles Harbor: While there is some information about such discharges, it is clear that considerable available data have not been presented, especially data that would clearly show the full enormity of the discharges m terms of volumes and chemical constituents. It certamly is very important that the report noted that "In 1963 pnor to the installation of the current outfall, the total discharge effluent volume from the Rayonier mill was 35 million gallons per day According to EPA, in 1992 39 million gallons were discharged daily But exactly what chemical constituents were released was not carefully delineated. The report talked superficially about dilution to give an impression that all of this discharge volume was inconsequential relative to the total volume of the harbor waters. But this is a ludicrous type of argument. It is important to understand that in the first several decades of the plant's operation there were essentially no environmental laws and regulations m the nation, and mdustnal discharges were far more lethal than they later became, especially after the 1970s. The report was also deficient by not addressmg discharges and releases from the three known cleanup areas on the site. For example, although it was acknowledged that there had been oil seeps from the finishing room cleanup area directly into Ennis Creek, potential impacts on the harbor were not presented. Although the leakage was discovered in May 1989, during the EPA chemical safety audit, no information on how long the releases occurred was presented. Nor was there any information on impacts from the fuel tank no 2 and hog fuel pile cleanup areas. However a most These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 31 32 interestmg piece of evidence obtained by EPA in 1979 was that the Rayomer mill "was dischargmg an oily substance" from its underwater waste water discharge pipe extending into the harbor 24 An oily substance was not consistent with normal waste water effluent and suggests the possibility ofvanous types of sediment contamination, perhaps extending several miles from the discharge pomt. -Air releases. There was no serious effort to present data from considerable stack testmg over many years. There is a major omission of data on particulate discharges and the full range of chemical air pollutants. This is clear from a careful reading of what may be some 1,000 entnes m the detailed bibliography at the ex of the report. Despite a lot of testing by the company and regulatory agencies, very tittle da .a appear in the report. Also, section 2.3 3 2 on the air pollution control facilities is ridiculously brief. The statement that "Fine particulate material was removed by glass fiber filters before emission to the atmosphere." is the kind of obscene, scientifically maccurate statement that companies disrespectfully give to communities. Are people really to believe that air pollution control cevices are 100% effective and efficient? Fugitive releases ment more attention. The EPA audit report noted important sources of releases, mcludmg: "the hds of the blowpits leaked during digester blow events. an estimated 1,000 pounds of SO are released from the blowpns on a daily basis EPA also noted releases caused by process piping failures due to corrosion. A later EPA nir'estigation noted. "No emission controls are mstalled on the bleach plant vents or stacks." Also, for six years the waste lagoon was used without any cover -Dioxin releases: There i€ significant information m the report that clearly documents very substantial releases of d.ioxms and furans into the environment. It seems certain that very large amounts of dioxins and fiirans haN e been released into the air, the water, and the land. It is beyond the scope of this effort to fully analyze all the data m the Rayonier report. However, it should be noted that much of the dioxin data reveals a major pollutant source. For example, m Table 2 -3 there is data on dioxm lwels m air emissions from the hog fuel boiler measured in 1995 presumably a lot lower dioxin lev 1 than m previous years when equipment had poorer environmental performance. The ,3,7,8 -TCDD TEQ value reported was some 1 500 tunes greater than the level m EPA's da abase for an ambient level corresponding to an excess cancer nsk of 10 (one m a million), me g that pnor to dilution the release corresponded to a cancer risk that would be considered very unacceptable. This kind of information is compelling evidence that the Rayomer mill was a potent source of dangerous dioxin emissions over many decades. Many factors, of course, determm actual exposures and doses for specific individuals m the Port Angeles commumty But there should be little doubt about the likely significant exposures among 24 EPA Environmental Monitoring Systems Lab Las Vegas, "Aenal Survey of Region X Pulp Mills, Puget Sound, Washmg:on, March April, 1979," October 1979 These contents reflect the at.thor s views only They do not represent the Department of Ecology s findings opinions or recommendations 33 many workers, hospital patients, and residents m the large area likely impacted by airborne releases from the mill In addition to the uutial exposures from real time air emissions, the commumty undoubtedly has also expenenced a complex set of secondary exposures caused by the long lastmg dioxin contammation m soils and other media m the community It is also important to note that most of the tables with dioxin data in the Rayomer report do not present 2,3,7,8 -TCDD TEQ data which are really necessary for easy and complete analysis of the significance of the data. With TEQ one essential number, the toxicity equivalent value, can be compared to others, rather than trying to compare some 20 numbers for different tests or samples. Nevertheless, some of the data clearly verify the powerful source of dioxins from the Rayomer mill. For example, Table 2 -6 presented data on final water effluent and extended outfall levels, and even looking only at the levels for 2,3,7,8 -TCDD and none of the other congeners that contribute to TEQ levels, it is abundantly clear how strong the dioxm contammation was. For example, m June 1991 the level found at the extended outfall was 69 pg/1 for 2,3,7,8 -TCDD alone, which is a very high level. The TEQ level is probably over 100 pg/1, which, for comparison purposes is about 200 times greater than EPA's value for 2,3,7,8 -TCDD m dnnkmg water for, the 10 cancer risk leveL Certainly there is cause for concern regarding impacts on aquatic life and potential food -chain impacts. Similarly, some data reported for dioxm levels m ash showed very high levels, including some considerably higher than the nominal level of 1 parts per billion (ppb) used frequently by EPA to determine the need for soil cleanup and some higher than the level that ATSDR deems important for health effects (about 50 ppt). For example, data on bag house ash m Table 2 -20 showed a 1 8 ppb level for 2,3,7,8 -TCDD alone from 1991 testmg, and it is reasonable to believe that levels m ash produced in earher decades were probably much higher Histoncal information. Section 6 Bibliography presents a very large number of bnef entnes, probably about 1,000, from the 1960s through mid -1997, mostly for the Rayomer mill site. If the mill site is like a came scene, then this section is like exammmg a huge number of snapshots of the history of the site, showing how the crimes against the environment occurred' over nearly 40 years. Concerned citizens are encouraged to carefully read these 50 pages. The entries communicate a picture of a complex industrial facility that is a classic illustration of the worst types of polluting mdustnal facilities and most disturbingly how government regulatory agencies are largely unable (or unwilling) to shut them down, regardless of environmental laws and regulations and noncompliance with them. These entnes also give some sense of the enormity of technical data generated over many years and also of the very large number of compliance problems that the mill had and which the Rayomer report largely ignored. It is beyond the scope of this effort to attempt to summarize of even hiuhlight the large number of entnes that Rayomer's contractor apparently examined and These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations cited. But it is important to noto that there is a large historical record of regulatory violations and documented releases of hazardous substances mto the environment, not only from permitted stacks and outfalls, but also fugr.ive emissions from faulty equipment. It is also clear that the company spent enormous sums of money obtammg data on dioxin generation and releases, but there is no assurance that all oft ie data was given m the report. Section 2.1 2 called Regulatory History did not present any mformation on noncompliance and regulatory violations, which can only be seen by examining the detailed entnes m the longer, less accessible section. On this 1 ;sue it is important to note that EPA's National Enforcement Investigations Center with DOE conducted a Multi -Media Compliance Investigation of the mill facility m July 1993 which even ally produced a Notice of Violation and Warning issued by EPA Region 10 m January 1994 25 E A notified the company of 13 violations of the RCRA regulations associated with the 1 d disposal restnctions for hazardous wastes, which clearly establish that Rayonier was a ha ardous waste generator Such a fact has considerable importance, because mdustnal f cihties that are hazardous waste generators have a higher probability of causmg site conta ation by the mdiscrimmate dumpmg of hazardous wastes on the site, which could have been 1 gal before federal and state hazardous waste regulatory programs became effective m th late 1970s. As a result of state iunsd .ction over some regulatory enforcement, DOE sent a letter in November 1993 to Rayomer that identified other types of regulatory compliance problems. Some of them have significance with regard to site contamination and cleanup, mcludmg notice to Rayomer that DOE had become iware of dumpmg small amounts of acetone on the hog fuel pile." A response from Rayonier to DOE did not dispute this practice and actually said that the mamtenance shops had been told "to stop this practice.i In other words. this is proof of Rayomer dumping chemical wa es m very recent times, which certamly suggests the plausibility of chemical waste dumpmg onsit m earlier times. DOE also identified problems with msufficient testmg of wastestreams to dete a whether they were dangerous wastes under regulatory control. Another problem DOE dentified was the remtroduction of solids mto the wastewater discharge stream, contrary to the facility's federal NPDES permit under the Clean Water Act. Rayomer did not dispute this pra Mice, which also constitutes a form of illegal waste disposal, that could have ramifications for releE ses into the harbor 'Executive Summary Multi -Media Compliance Investigation, July 1993, Letter to Bnan Jones from Randall F Smith, Jan nary 12, 1994 'Letter to Bnan Jones from Don Nelson, November 16, 1993 27 Letter to Don Nelson from Bnan Jones, December 27, 1993 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 34 This author has examined three important EPA reports, only one of which was referenced m the Rayonier report m a mmor way It is a severe deficiency of the Rayomer report that it did not fully and fairly present the many important findings of EPA's chemical safety audit report, the mutimedia compliance report, or the aenal survey report. Perversely, the Rayomer report said that one of its goals was to "support the U S Environmental Protection Agency (EPA) site assessment process." The ultimate challenge for EPA Region 10 is whether their decisions about the NPL listing of the mill and landfill sites are consistent with previous EPA studies and findings. If the NPL listing decisions are not consistent with the very negative picture of the Rayomer facility given in earlier EPA studies, then concerned citizens will have a strong basis for formal actions seeking governmental or judicial assistance m reversing Region 10's hstmg decisions. Conclusions. The Rayonier report is more important for its patches of mterestmg but mcomplete information than for its analyses, interpretations, and conclusions, which are biased and technically deficient. Rayonier's reality is literally pulp fiction. It definitely shows the need for regulatory agencies to thoroughly examine the enormous amount of historical information that exists for the mill. But government agencies should not use the document to limit the scope of site mvestigations and studies, nor allow it to affect decisions about necessary cleanups. City government has already shown itself to be a willing partner with Rayomer, as evidenced by its grantmg a very favorable permit for demolition, allowing use of its landfill for demolition waste, and considering treatmg landfill leachate m the City wastewater treatment plant. Conflicts between local residents and local government often exist, because residents place the highest priority on protection of health and environment, while local government officials often place more importance 011 economic redevelopment. Recommendations. Concerned members of the Port Angeles community should not allow themselves or their City government officials to be overly mfluenced by the transparent attempt by Rayomer to pamt an overly positive picture of the mill's history and health and environmental impacts. City permit documents The DOE contract required review of certam City of Port Angeles documents addressing the demolition project and preparation of a summary of the terms/limitations and scope of activities permitted, mcludng specified oversight and enforcement mechanisms. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 35 These contents reflect the author s views only They do not represent the Department of Ecology s find:.ngs opinions or recommendations 36 The May 14 1997 Shoreline Substantial Development permit and the Addendum to the Mitigated SEPA (State Envirom rental Policy Act) Determination, and the July 11, 1997 City building division permit, essentially provided City approval for Rayomer to demolish aboveground structures at the mill site, essenti illy all existing buildmgs and structures with the exception of the dock. It also provided for donation of a public trail easement connecting the City's Waterfront Trail through the mill property [t should also be noted that the City's position was that the demolition phase would be followed as soon as reasonably practicable by a complete environmental site assessment and, if necessary, remediation of the hazardous materials contamination at the mill site. Moreover, the City found that the demolition activity did not pose a probable significant adverse impact on the environment and, therefore, that no environmental impact statement was required under state law (SEPA). The City was incorrect in this conclusion. In fact, the valid pre ;umption for any such large, old industnal facility known to have used hazardous chemicals and to be a major polluter should have been to recognize significant threats to health and environment from demolition activities. This view is supported by subsequent actions, including the mstallation of ambient air monitonng by Rayomer and extensive official oversight activities by EPA of the demolition activities. Clearly the basis for these actions was a realistic threat from demolition activities and, therefore, an environmental impact analysis was appropriate. The City did require some appropriate actions to protect public health and environment including: a spill contamment plan addressing accidental spills and stormwater runoff; dust control actions, proper disposal of demolition waste with independent inspections, activities to ensure 28 It must be noted that Ra ✓omer instituted its ambient air monitoring effort on its own and without adequate peer review Ts author found their program quite deficient and apparently Rayomer was to make some chan es in its effort. 'In some sense the Rayon ier mill site has already become a federal Superfimd site, because EPA has made a sigiuficaM official commitment to conduct oversight of the demolition activities and to conduct air momiormg. The only apparent legal basis or authority for tlus activity is that EPA Region 10 ha defined the Rayomer demolition as a private "removal action" under CERCLA/Superfund. Inde d, EPA has said that "EPA's purpose in this [oversight] activity is to ensure that activities dunng a demolition do not create eminent (sic) and substantial nsks to the public or the environment om contaminants. EPA has the authority to require remedies, mcludmg stoppmg demohtion] w rk, if demolition activities create these kinds of nsks." The same presumption of threat justify ng EPA's intervention should also have logically supported an affirmative finding by the City that an EIS was necessary EPA Region 10 "Update Mill and Landfill Momtormg and Assessments, Port Angeles, Washington," Sept. 17, 1997 historical and cultural preservation to meet the concerns and interests of the Lower Elwha Klallam Tribe, comphance with a number of pertment federal, state and local regulations. 37 Importantly, the City found that: "A comprehensive environmental site assessment, specifically mcludmg soil analysis for potential contammation, cannot be adequately completed until the removal of the existing structures on the site." This finding by the City is not correct. Clearly, Rayonier wanted to conduct the demolition as soon as possible and before either it (probably under state authority but perhaps under EPA authority) conducted a comprehensive site mvestigation. The City's position is both inconsistent with techmcal expenence with mdustnal cleanup sites nationwide and with the recent conduct of the Expanded Site Inspection by EPA. The truth is that demolition of site structures is NOT a normal or mtrmsically required first step pnor to site mvestigation. A paper describmg work developmg EPA guidelines for addressmg contaminated buildings identified a three step process, where the first step is thoroughly studying the nature and extent of site contamination (includmg building surfaces), followmg by actions such as demolition, and lastly by venfymg the extent of site cleanup 30 There probably have been many hundreds of site mvestigations of mdustnal properties roughly similar to the situation at the Ravomer mill site pnor to initiation of demolition activities. Moreover, when EPA conducted its ESI, which was quite thorough and mcluded many actions associated with a comprehensive environmental site assessment, mcludmg sampling of subsurface soils, most of the mill site's structures had not been demolished. There are a multitude of site investigation technologies and methods that permit extensive site mvestigation pnor to demolition of above ground structures. Moreover, any governmental agency addressmg the desire for quick demolition of such a large complex mdustnal facility for which there surely is a reasonable presumption of potentially extensive site contamination should logically consider the disadvantages of early demolition. There are two primary serious disadvantages: (1) The demohtion activities themselves may cause some harm, because of transport or releases of hazardous substances, especially because there is incomplete information on the fiill extent of the presence of hazardous substances at the site, mcludmg within, on, and below structures. (2) The demolition activities may make subsequent complete site mvestigation less reliable because, for example, site mvestigators do not have the advantage of seeing first hand the 30 M.P Esposito et al, Guidelines for Decontammatmg Buildings, Structures and Equipment at Superfund Sites, Proceedings of the 5th National Conference on Management of Uncontrolled Hazardous Waste Sites, 1984, pp 486 -488 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations kinds of structures and tieir past operations that provide important mformation about possible contamination a d how it should be explored. If the limited ESI mvesti7ation leads to hstmg of the mill site on the NPL, then the much more comprehensive Remedial Investigation would be helped by stopping the current demohtion activity Indeed, EPA's guidance for conducting Superfund Remedial Investigations explicitly noted the need to address surface features, including buildings, tanks, pipmg, and roadways in terms of determining areas of contaminant migration and the locations impacted by contammants. Another relevant EPA report concerned with brownfields sites also does not support the City and Rayonier ac.tions. The mill site definitely fits the category of brownfields, especially because in all likelihoc d the site will be redeveloped. EPA identified and discussed several logical steps for such sit s, beguming with site assessment, which is like an environmental audit that examines all available ormation. In this initial phase EPA noted the appropnateness of the "examination of existing ructures for structural integrity and asbestos containing matenal," as well as testing "for the presence of vanous contaminants, for example, lead paint, polychlorinated biphenyls (PCB), and radon." In the followmg phase of site mvestigation EPA noted the appropriateness of det 9rmining "whether and how (if applicable) the infrastructure systems (including existing struc es) are affected by contammation." Only m the actual cleanup design and implementation phas did EPA again address the infrastructure issue, where demolition could be an appropn a alternative to renovation and would precede construction of new buildings. One of the largest demob ion projects at a Superfund site was recently conducted at the Bunker Hill site in Idaho, a form r mining and smelting plant with nearly 200 structures with most being multilevel wood and steel uildmgs, and a major smokestack. The plant had operated from 1917 through 1981 Demo 'tion m 1996 and 1997 occurred after site remedial mvestigations. The major demolition activities and their costs were buildmg characterization $0 4 million, asbestos abatement $3 3 million, decontamination of buildings $1 6 million, 31 EPA, "Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA," October 1988, p 3 -5 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 38 32 EPA, "Road Map to Unaerstandmg Innovative Technology Options for Brownfields Investigation and Cleanup, 1997 33 M.A. Ohlstrom, "Innovation and Savings Conquer Bunker Hill Lessons Learned at an EPA Superfund Demolition Probe -t," presented at X- Changes `97 The Global D &D Marketplace conference, December 1997, Miauu, Flonda. The author is with the Army Corps of Engmeers m Seattle. 39 demolition $6 4 million, hauling debns $2.1 million. Nearly 15% of the total, or some $2 million, were spent by the demolition contractor on building characterization and decontamination to address contamination by hazardous substances, which may suggest what a reasonable effort would be for the Rayonier demolition project. It is particularly interesting to note that apparently no City or County agency raised concerns about the potential for the demolition activities to spread contamination mto the surrounding commumty For example, if the site had been made a federal Superfund NPL site no trucks could leave the site without extensive decontamination procedures bemg employed. There simply is no doubt that heavy truck and demolition activity at such a site can cause fugitive air emissions of contaminated matenals. It is not clear whether EPA's oversight activities have thoroughily addressed these types of issues. Interestmgly, a 1975 document by Rayomer acknowledged that power boiler ash was bemg used for road and storage area fill matenal on the mill site, and such matenal could be severely contammated. As personally witnessed, there is a considerable amount of truck traffic from the facility that could cause fugitive emissions and disperse solids offsite. The lack of a site mvestigation m conjunction with the deficiencies of the protocol for addressmg the generation and disposal of demolition wastes m the City landfill, as presented below, combme to increase the chances for hazardous matenals associated with site structures being disposed in the City landfill. Comments by ATSDR support the views presented here 36 It said that the structures to be demolished "may have been contammated durmg the operation of the plant. Soil samphng on many potentially hazardous waste sites are conducted before demolition of any above ground structures. This is an important process to ensure contaminated soils are remediated before traffic is allowed to potentially carry the contamination off the site." (emphasis added) ATSDR also made special reference to asbestos and lead contamination and noted a deficiency m the Rayomer work plans: "A more detailed procedure for lead removal should be provided for 'Unclear is whether EPA comprehensively examined the pros and cons of allowmg Rayomer to conduct site demohtion. EPA's oversight of the demolition sidesteps the broader issue of whether demolition affects the quality of a possible Remedial Investigation. 35 Engineermg Report Sohd Waste Handling and Disposal Plan, ITT Rayonier Inc. Port Angeles Division, February 25, 1975 'Letter from Richard Robmson to Darlene Schanfald, June 17, 1997 ATSDR had examined Rayomer work plans for demohtion and Rayomer responses to pubhc comments. These contents reflect the author s views only They do not .represent the Department of Ecology s findings opinions or recommendations 37 April 7, 1997 letter by Donald L. Schwnediman to Brad Collins. 38 Dana Dolloff statements given m news article Rayomer says demolition safe," m the Sequum Gazette, August 13, 1991. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations review ATSDR also supported air momtormg during demolition and that it "would be especially important dunng stack removal." Clearly, ATSDR's views also support the view that the City was mcorrect m concluding that no environmental impact statement was necessary for the demohtion project. Some citizens attempted t 3 stop the City from issuing the necessary permits for demohtion, but failed. It seems no this author that this worthy attempt failed either because msufficient professional environmental expertise was brought into the process to show that the two key conclusions by the City %Iere incorrect (i.e., that no environmental impact statement was necessary and that demohtion ha to precede site investigation), or that the City acted improperly m reaching its decisions. This au or has examined a key letter by a Rayomer attorney to the City where the company made its ar ents that apparently supported the City's decisions." In that letter which addressed pertinent t chnical issues regarding the SEPA checklist, used by the City to determine the need for an enviro ental impact statement, Rayonier made its case for why demolition had to happen before ite investigation. The arguments are without technical ment. Rayomer argued that the c lemolition activity itself would "would not create additional contamination of soil or sedumentk." But this ignores transport of contaminants offsite that are possible through a number of acti')ns, including trucks carrying contammants offsite, air releases moving offsite, and matenals fallutg m the harbor Rayonier said that their demolition contractor "can keep dust from stack removl from leavmg the property Therefore, there is no probable significant adverse environmental impact from dust generated by stack removal." The implication was that NO dust would leave th property This is sheer technical nonsense. There can be no such absolute assurance for such extensive demohtion activity Rayomer asserted that "we cannot assess the need for remedi Lion until we dismantle the buildmgs," and "It is not physically possible to do an adequate enviro ental evaluation of the site until the structures are removed to provide access to the ground and .rneath." These views are patently false and misleading. Also, m addressmg citizen concems about the demohtion of the tall mam boiler smokestack, Rayonier's top environmental executive said that "there is no reason to have dioxins m concrete.i He also said that "There's no way for those matenals [dioxins, mercury or arsenic] to be m that stack, because there'.; no source of them." The only scientifically credible way to test this assertion is to examine detail( d data from chemical testing of stack air emissions, mcludmg 40 41 particulates. However, the Rayomer Current Situation/Site Conceptual Model Report presented very little data from such testmg, mcludmg only one test for dioxins m 1995, which admittedly did not show high levels of dioxins and furans, but which is also madequate to fully support Rayomer's assertion. Rayomer surely had much more extensive test data than it reported. In trymg to understand why the City made the decisions it did which certamly were extremely favorable to Rayomer, this author finds the following mformation relevant. In October 1997 Rayonier made a $300,000 grant to the City for startmg a jobs creation program. This was either a very altruistic action or a thank -you for what the City did on the demohtion permit issue. What must be recognized is that Rayomer's decision to close the mill was no hasty action, but a planned decision that was known for some time. Clear facts show that the Rayomer Port Angeles mill was in extremely poor financial condition for some time. For example, for the five year penod from 1992 through 1996, Rayomer acknowledged that the mill had lost money for four of the five years. Moreover, m the same news story that pomted that fact out, it was also noted that "The Rayomer mill has long suffered financially because of the high costs of anti pollution upgrades and competition from lower -cost foreign competitors.i Another news story had noted that "the mill faced some $40 million in capital improvements to meet air and water quality regulations."' In April 1997 the U S Labor Department ruled that the workers laid off at the mill did not qualify for certain benefits, because the mill's customers had not changed suppliers because of low cost imports, and also noted that the majonty of the mill's pulp products was for the export market. A highly valued dollar, high raw material costs, and global competition had simply caused a pnce squeeze that caused Rayomer to lose money on its sales. In fact, only about 20% of Rayomer specialty pulps were made m its Port Angeles mill, while the remainder came from two other U S Rayomer mills which have been profitable. The pomt is that no rational 39 "Facmg the mevitable," Seattle Times, November 5 1996 40 Puget Sound Business Jounial, editonal, "Clallam County's pulp reahty adjusting to hfe after Rayomer," May 19, 1997 'Considerable financial data available from the Rayonier site on the mtemet was reviewed. The company had revealed a pretax charge of $125 million m 1996 "primarily for the planned closure of the Port Angeles pulp mill." In fact, in 1996 net mcome dived by some 33 presumably in large measure due to the poor performance of the Port Angeles mill The company also said that since 1990 it had invested more than $100 million on environmental spending for the whole company, which shows how significant the $40 million need for the Port Angeles mill was. Also, financial data indicate that the Port Angeles mill was probably grossmg between $100 and $120 million annually m recent years, agam showmg how significant the $40 million environmental investment was. Such a figure also shows a substantial need to improve pollution These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations busmess would keep making large capital investments, especially for environmental pollution control, for such a money losing a id very old plant. By 1993 or 1994 Rayomer probably knew that the Port Angeles mill was not economically viable. Because Rayomer was a very important part of the City and County economy, it certainly could have acted altruistically long before October 1997, after it had already closed the mill and started demolition. Conclusions. The City permitting procec;s was fundamentally flawed because of two incorrect presumptions: (1) that there was r o significant threat to health and environment that warranted an environmental impact statement, d (2) that demolition of mill site structures was a necessary precondition to conducting a co rehensive environmental site mvestigation. Both findings are not technically correct. Demoli g the mill's structures is like destroymg a crime scene before thorough forensic mvestigation. blic officials should have senously questioned why Rayomer had such an mtense interest m initiating demolition as soon as possible and before extensive site investigation. Certainly, the possibility of the guilty party wanting to get nd of the evidence should have been an obvious issuel. Without any doubt, it would have been m the public mterest to first conduct a thorough site mvestigation before implementmg demolition activities. There has been unreasonable acceptance of information from Rayomer by government officials on all technical and environmental matters. Recommendations. Those parties who attemp :ed to stop the City from issumg the necessary permits for demolition should consider petiticnmg the state Attorney General or the U S Attorney to mvestrgate the processes and actions taken by the City for possible improper conduct by local government officials. City goven ment had a responsibility to not rely on the information received from Rayomer and to recognize tile mtrinsic conflicts of interest Rayomer has m such matters, m terms ()fits own financial benefits versus public health and environmental mterests. Some attempt to have a federal court stop the ci Trent demohtion until EPA makes its decision about listmg the site on the NPL merits consideration in order to ensure the integrity of the possible Remedial Investigation. control equipment at the plant. These contents reflect the zuthor s views only They do not represent the Department of Ecology s fincings opinions or recommendations 42 City contract for inspection and observation services during the Ravonier mill site demolition The contract was between the City and Polans Engmeering and Surveying, Inc. and was entered into on September 18, 1997 It should be noted that some demolition apparently took place pnor to this contract. The DOE contract required a summary of its terms, including a cntique of the agreement's scientific and regulatory guidance to the City's contractor The key aspect of the contract for this study was the scope of services in Exhibit A which provided four specific services related to "the disposal of demolition material and debns from the Rayonier Pulp Mill." 1 Observation and documentation of demolition matenal and debns to be hauled to and disposed of in the City of Port Angeles landfill. (Two documents presented m exhibits further defined this service.) 2. On -site mspection of material and debns pnor to removal as directed by City personnel, photo documentation, and weekly reports summarizing sources at the site for matenals and the types of those matenals generated. 3 Coordination of specialized mspections and tests, if materials and debns to be removed is inconsistent with mformation provided by the demolition contractor workmg for Rayomer 4 Providmg copies to the City of all inspection reports. A key exhibit was the contract between the City and Rayomer which covered the disposal 'According to a letter of October 8, 1997 from Polaris to Jack Pittis, a City official, the admuustration building at the mill site was demolished on September 2, 1997 and "At the time the admuustration building was demolished, no written protocol regarding mspection and testmg of the debns had been prepared." Subsequently some samples were retneved from waste disposed at the City landfill Test results for lead indicated illegal levels but that the Rayonier contractor made an argument about dilution to negate the findings that would have made the waste "unacceptable" under the contract between the City and Rayomer This provides httle basis for citizens to have comfort in the entire waste sampling protocol for demolition. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 43 of demohtion debns at the City lay dfill. The estimated mmimum amount of matenal for disposal was given as 5,000 tons. Acceptable waste for disposal was essentially any non putrescible waste that was legally considered authorized for disposal at the landfill but not matenals prohibited under City law, particularly hazarc'ous waste. There was a clear provision for the City's mspector to have access to the mill site in wider to review and inspect materials pnor to disposal and to determine whether any of them wre not "acceptable waste." The other key exhibit was ;,alled the "Demolition Material Disposal Protocol." This protocol covered the removal of aceptable waste from the mill site and dehvery to and disposal of the waste at the City landfill. F ve steps are provided. 44 1 Initial review At least one we k prior to demohtion the City had to receive a demolition schedule for that portion, includm the portion of the facility to be demolished, the proposed demolition dates, the amount and e of material, and the anticipated schedule for delivery to the landfill. This was to provide an opportunity for the City and its contractor to determine if any unacceptable wastes were includes l in the prescribed portion of the mill. The review was to mclude a site mspection. Any Cite designated unacceptable materials were to be removed from the demolition area. 2. Inspection and release: A final Inspection was to be made after unacceptable matenais were removed. The City was to verify t he absence of unacceptable waste, allowing Rayomer and its contractor to begin demolition anc stockpiling of matenal. 3 Demohtion and stockpiling: A thorized materials were to be stockpiled m a separate area on a hard surface and the City and its c ntractor could make penodic mspections of the work area and the stockpile areas to ensure the p esence of acceptable waste. Transport to the City landfill was not to occur until "the compositio of the waste is ascertamed and found to be acceptable waste." Unacceptable wastes would be re owed. If unacceptable wastes were suspected "both Rayomer and the City shall take samples of he waste and have it analyzed for composition." 4 Removal and disposal. After in,>pection and approval matenal could be transported to the City landfill, after the landfill was notifi xd of the shipment. The City was to "maintain a map showing where the demolition debns is to be deposited." This was to allow future excavation. The City had to mamtam a log at the landfill that documented delivery rates, weights, and disposal location for each demolition area. 5 Final documentation. The City iad to mamtam a log that verified each of the steps taken for each of the demolition areas. These contents reflect the atthor s views only They do not represent the Department of Ecology s findings opinions or recommendations All of these documents do not adequately describe and prescribe the exact analytical methods to be used by any of the parties to obtain the best scientific mformation on the exact chemical compounds that might be present in demolition materials, especially beyond lead and asbestos. As an industrial facility that operated for so many decades and clearly involved the use of toxic chemicals and the generation of hazardous wastes and pollutants it is inconceivable that site structures would not, to some degree, be contaminated. In fact, EPA was notified m 1980 that the mill was generating more than 1,000 kilograms per month of regulated hazardous wastes. What is so troubling about the demolition activity is that there really is no clearly detailed mvestigation and analytical procedure to completely assure that "unacceptable wastes" are not disposed in the City landfill. Apparently it is acceptable to dispose of specially bagged asbestos waste, lead contaminated materials, and chemically treated wood in the City landfill. The documents did not reveal specific sampling and testmg methods, except the use of cored samples from buildmgs, for example, for lead testing. Such samples constitute a type of composite sample that automatically dilutes the presence of surface contaminants, such as lead pamt. This seems to be a procedure designed to avoid positive findings of unacceptable hazardous wastes, such as for lead based paint materials, and ments detailed examination by DOE as to its consistency with, standard state accepted methods. In fact, a letter from Polans mdicated that even though a lead leachate level high enough for hazardous waste designation were obtained, a lower calculated level based on total sample thickness (other than lead pamt) was used to reach a conclusion that the waste was not hazardous. Polans maintamed that its sampling and testmg procedure had the endorsement of the County and DOE, but formal government approval is appropnate. It must also be acknowledged that this author is aware that Rayomer has made some commitment to conduct ambient air momtormg for the demolition activities and comments on Rayomer's uutial program have previously been provided to the Olympic Environmental Council. It is also recognized that EPA has made a commitment to conduct some hmited air momtormg at the nearby hospital and to provide oversight of the demolition activities. Certamly the potential for air pollution from demolition is real and had to be addressed. At this time, however, this author has no basis for making a positive conclusion about the effectiveness of these air momtoring and oversight activities. No EPA document has been received that details exactly what EPA is doing or planning to do Although a letter from EPA Region 10 to the Olympic Environmental Council said that EPA together with the City and Rayonier had agreed "to routmely sample every buildmg. and have developed a sample collection protocol to use during 'Letter to Jack Pittis from Stephen M. Zenovic, October 8, 1997 The County official mentioned was Andy Brastad and the DOE official was Cris Mathews. These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 45 These contents reflect the author s views only They do not represent the Department of Ecology s find._ngs opinions or recommendations Mill demohtion. The letter did indicate that "Samples of buildings will be taken with bormgs." and that 'EPA will test samples fc r contaminants of concern based on the place in the mill that the sample was taken from. The contaminants tested for will be determined on a sample -by- sample basis." But this still leaves open important questions, including whether there would be comprehensive testing for dioxins and furans. The author has been told that there will be some sampling and testmg of the inside materials of the main stack at the site pnor to demolition, which is cntically needed. The exact methods used for stack demolition ment considerable attention by government agencies, because a one -time major source of dangerous air releases is possible. This author also examined two documents produced by Rayomer related to this demolition subject. One was called a "Work Plan for Pulp Mill Dismantling" revised January 14, 1997 and the other titled "Rayonier Matena is Handling Plan Port Angeles Mill Dismantling," dated March 17, 1997 Both plans seem to be lesigned to define the activities of both Rayomer and its pnmary demolition contractor The plans provide considerable more detailed information than the documents covered by the DOE c Dntract for this study For the most part these documents provide more cause for concern om a public interest perspective. For example, the second document noted that "Creosote tr ated wood does have the potential to cause environmental harm because of the toxicity of th preservatives. At this Mill the preferred manner of disposal for creosote timbers is by recyclin No preservative creosote timbers will be allowed m the Mt. Pleasant Road landfill Clearly this was written before Rayonier was forced to stop using its Mt. Pleasant Road landfill Most disturbing, however, is that creosote treated wood definitely is being disposed in the City landfill, in fact this author viewed extensive treated wood waste being disposed at the City landfill. Similarly, asbestos waste was not to go to the Mt. Pleasant landfill. The section on lead removal provided no details about testing, but acknowledged extensive lead contamination at the site and referred to the need to ship such hazardous waste to a permitted hazardous waste facility 46 "October 21, 1997 letter by Michelle Pirzadeh to Darlene Schanfald. The letter was accompamed by four pages of re onses to specific questions and issues raised by the Council. This author's review of EPA's re onses finds many of them unsatisfactory, mamly because EPA seems to make assertions without any factual basis to support them. For example, on the issue that the Administration building m*ght have been impregnated with hazardous waste from general emissions from the site, which this author finds quite plausible, EPA asserted. "Although the building could retain trace amounts of some substances they do not pose an imminent and substantial threat to human health and the environment." This presupposes facts not apparently obtained by EPA about contamination and assumptions about waste disposal and future exposure possibilities. In general, the respo ises provide little comfort to citizens that EPA's oversight activities are effective. Conclusions. The scientific and regulatory guidance created by the City to provide the operational framework for the demolition activities and disposal of demolition wastes is not comprehensive or sufficiently detailed to assure the absence of toxic matenals bemg disposed in the City landfill. The basic rationale of matenals sampling seems to be acceptmg the validity of information from Rayomer about pnor site activities, but what is really needed is a more objective systematic sampling approach to independently ascertain the real presence of toxic contammants m buildings and other structures to be demolished. Recommendations. Future mdependent techmcal examination of the demolition project should obtam all available records, reports, and laboratory data to thoroughly investigate whether the demolition process and waste disposal in the City landfill have caused potentially adverse environmental impacts. DOE should closely examine sampling and testing procedures bemg used for building surfaces relative to standard procedures for identifying hazardous wastes. Letter of September 8. 1997 to Jack Pittis. City Director of Public Works. from Brown Caldwell These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 47 Although not explicitly stated, it is reasonable to presume that Brown Caldwell is a contractor working for Rayomer The subject of the letter is: "Impact of Shotwell Leachate on the Port Angeles Wastewater Treatment Plant Biomass and Treated Effluent." The DOE contract asked for a summary explanation of the letter's content and its significance to the City's treatment plant capacity (pollutant load). It should be noted that the Shotwell Landfill is another name for the Mt. Pleasant Landfill, used solely by Rayomer for sohd waste disposal. The letter provides some background information about the landfill and a site visit on July 28, 1997 by a City representative and Rayomer personnel. It is noted that pumped leachate is first stored in an onsite pond and then trucked to the Rayomer wastewater treatment plant. Two technical reports, apparently done by another Rayonier contractor are also discussed. The first report focused on measuring the chemistry of the leachate. The general impression given in the letter discussion is that pnor analytical work found no detectable senous pollutants, and that BOD (biological oxygen demand) was relatively low and similar to that found m treated sewage. Also although some toxic impact of raw leachate had been previously measured, dilution would prevent an adverse impact from treated effluent. The concern seemed to be a possible toxic compact of the leachate on the biological processi ig existmg in the City treatment plant, but that if the leachate was "added slowly" to influent, the 're would be no problem. 48 The second document disc fission focused on some other data collected for landfill leachate and, here too, the purpose was to nake the case that if the leachate was added slowly to the City treatment plant influent the levels of contaminants would "be diluted sufficiently not to cause a toxic impact on the plant biomass. The overall summary in this section of the letter concluded that the low concentrations of pollutants were "unlikely to have any impact on the Port Angeles wastewater treatment plant proved :d the leachate is metered mto the plant influent at a slow rate such that a minimum 100 -fold dilution will occur The next section of the letter focused on "Supplemental Data" and other, related issues, mcluding measurements of the oxygen uptake rate of the plant biomass upon exposure to leachate. Apparently durmg July nd August 1997 City staff made vanous measurements, mchidmg on matenals with leachate. The summary data are given and an interpretation made that the lower oxygen uptake rate meaured with leachate was a result of a lower BOD and not any toxic inhibitory effect from the leachate. But this seems more assertion that scientific proof because no actual BOD was measr The letter then discussed alsorbable organic halides (AOX), a standard type of measurement, especially for pulp and paper mills which produce chlorophenohc pollutants m wastes. One measured value for OX is presented from an August 1997 test on leachate. Interestmgly, the level found in th leachate was acknowledged to be similar to concentrations found m effluent from plants treat' g bleached kraft mill wastewater It was then asserted that the AOX levels "are not considered t ribe at a level sufficient to induce effluent toxicity The last techmcal factor discussed was the fact that the project flows of leachate were on the order of one hundredth of the aw sewage flow to the plant on an average monthly basis. But the letter also noted that "The pl t has limited spare tankage where trucked leachate could be accommodated to allow a steady ..00 -fold dilution to be implemented." The conclusions presented were "that the leachate will not have a toxic impact on the plant biomass nor convey a toxic property to the plant effluent at the project average monthly flows smce this would result in 10D-fold dilution of the leachate m the raw sewage feed to the Port Angeles wastewater treatment plant." It was then recommended that the leachate flow be mamtained at this rate by "meterm a smgle truck into the mfluent. or preferably, by pumpmg the contents of all tanker trucks into tie Filtrate Storage Tank and using the existing flow equalization metering system to disperse the flow over the full day These contents reflect the aithor s views only They do not represent the Department of Ecology s findings opinions or recommendations The letter presentation has failed to consider the following real -world possibilities that would negate the positive findmgs and recommendation, and that would place the City's treatment plant in jeopardy landfill leachate chemistry can vary significantly over time and different leachate characteristics could produce highly negative impacts on the functionmg of the treatment plant the chemical nature of the mfluent to the City plant can also change substantially over time, depending on vanations in the multiple inputs to the sewer system, and could produce conditions which make the leachate contribution harmful and cause untreated or unremoved pollutants to exit the plant there was no work to reveal how some senous toxic constituents of the landfill leachate, such as dioxins and furans, might become contained m the final solid waste residues from the treatment plant and ultimately result in environmental harm Conclusions. 'Letter to Keven S. Curtis from Norman K. Schenck, September 9 1997 These contents reflect the author s views only They do not represent the Department of Ecology s findings opinions or recommendations 49 the analysis did not realistically consider worse case scenanos where upset conditions could be produced in whole or in part because of introducing landfill leachate mto the City treatment plant, such conditions could cause a breakdown of the plant's functioning Lastly, it should be noted that DOE's Water Quality Program made a determination the day after the Rayomer contractor letter to the City that greatly facilitates the City treatmg the landfill leachate. DOE ruled that no state waste discharge permit application was necessary for the proposed discharge to the City system. However, DOE told the City that if the "discharge does cause `pass through' of pollutants or `interference' with the treatment process as defined by federal regulations," than a permit would be necessary to "prevent these effects." There was insufficient data acquisition and engineering analysis to fully justify any agreement by the City to accept leachate from the Mt. Pleasant Landfill in its wastewater treatment plant. In this author's expenence, most municipal authonties that have thoroughly considered accepting landfill leachate have not found the benefits (presumably mcreased revenues) sufficient to offset the potential disadvantages, which include a failure of the City plant to function properly and, therefore, to become a pollutant source contrary to its regulatory permits and/or to f suffer equipment failures that impede providing proper City services and raise City operation costs. Recommendations. Concerned citizens sho d take appropnate actions to oppose having the landfill leachate treated at the City plant, unless onsiderably greater technical information is obtamed that supports this activity and assure, public safety These contents reflect the ,uthor s views only They do not represent the Department of Ecology s fincings opinions or recommendations 50 BUILDING PERMIT PREAPPLICATION The Building Permit Preapp (/cation must be filled out completely Please type or print In Ink. If you have any questions, please call 417 -4815 Applicant and/or Agent Rayonier Inc Port Angeles Mi 11 owner Rayonier Inc Address 700 North Ennis Street Architect/Engineer Contractor Address. PROJECT ADDRESS t'YPE O F WORK: 3 Residential Nnv Constr 3 Multi- family u Addition Commercial -Rramodta u:C 1 DATA 1 WnKEFPERVILDArf.FI M Bil Jensen 700 North .LEGAL DESCRIPTION: Lot.' SP(? attached Exhibit i 'LANNING USE ONL'1 'crnuts Required: vim Height: )ttc Plan and Use Approved by .SA/Wetland(s): o Ycs 0 No SEPA Checklist required': 0 Ycs 0 No Block: Phone City Port Angeles, Washinntnn Phone License City' Ennis .Street, ,P=urt Angeles. WA `a,' Subdivision. r a.Rale. v Applicant: 1. a Exp APPROVALS. PLAN BLDG DPW ,r sin„ FIRE OTHER D.t. R.c 14 rraAp Complete? Date A+q,oved' Dale,. /4 i9 7 't1.t Phone 360- 457 -3391 360- 457 -3391 Zip 98362 360- 457 -3391 Phone Zip ZONING SIZFJVALUAT ION Rcroof Woodstovc 526,855* SF t S 2 28 /SF S 1 200.000 o Move Garage $F (i W iSF S o Lkrnolition Deck P 5 /SF 5 0 Repair a Sign N 'i'C FAL VALUATION S BRIEF DESCREPTTONOFTIfPROJECT Dis i antlino of all st.ri''kt nn t he c't .pocifications for rli cman i.l 1 nc! are o,tto,,'c —ed `"•9 0' Sq ft i s estimated bui l dAvsc-kizaudi ng, nUl ti pl e floors) cOMMERCIAL/RES ENTIAL: Occupancy Group: C)octrpant Load: fastntcti i Type: '4o. of Stones: lot Size: t, L of Coverage: •A xistutg Lot Coverage: /sq. ft Proposed Lo Coverage: /sq. R TO TAL LOT CO V r IZAGF. /sq.ft v Notes: Setbacks: Zoning: Date: Othc� REAPPLICATION S UBMTITAI<.r, Your °pp6aad tr aad lice plan must beRiled out eontploldy to be accepted for review. The Building Nvtsion can provide you with more dctailod information s the application and plan submittal requirements. 3 UILDING PERMIT APPLICATION SUBMITTAL: Your completed application, site p!lut (for additions) and kuilding constriction Mans are to be submitted to the Building Divisia:. Any addition largo tha; 500 aq. ft. will need a Preapplication Review /ALUATION OF- CONSTRUCTION: In all caves, a volt anon am$ m` st be entered by th! applicant This figtwc will be reviewed and nay be revised by the E-uilding Div to comply with currcn: fee schodulw: Contact the Permit Z.;oordinat:x at 417-4815 for assistance. 'LAN CIIFCK FEE. Yocrplan c t= ,ode foe is duc at the tun: the building permit application and construction plans are submitted All other crrrut fom are due at the Lfnc of print u�•, ?oc. .XP!RAT1UN OF PLAN REVIEW: no prrr e issued within 180 days of the date of applicanca, this applt ;itTn will expire by rrutetioru Th ng Off +l art r,,1 t1r time for sJu l by the applicerAt p to vain= 180 days, on w request by die, :applicant (see Section 04(d) of the Uniform Building; Cod, arrant edition) No application e,41 be cxtsrndcd more than once. 1:- a herrby cc,* that l,jave had and examinr d /lilt applicaa,n and blow the same to be true and correct, and an authorized to apply for ',is permit. 1' undei: ►and °!t is not the 0011 kgal resp+•ns/bllity to determine who: permits are required. It re rains the applicant's 'spontlblllty io determine whir' permIU are requlr3us.gnc/ Yo obtain sue. rw.t 1■2.03lhw.2/961 it Rayonier rl 11 IJ 1 )'11/1 January 16, 1997 Port Angeles Planning Department PO Box 1150 Port Angeles, WA 98362 Re Shoreline and Building Permit application Enclosed are a Building P %rmit Preapplication and an Application for Shoreline Substantial Dev lopment for the proposed dismantling of the Rayonier Port Angeles Pulp Mill ncluded with the applications are the work plan specifications, two gener 1 site drawings, and the site drawing showing the individual work areas as esignated in the specifications In order to provide comprehensive inf rmation for the permit review, the application assumes the eventual remo al of all existing buildings and structures For clarity, these permit applications do not include 1) work below ground level, 2) any work in the wat 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 gelerated during the work will be disposed of in accordance with federal ani state regulations Rayonier's current plans are for total dismantling of the facility, however, we have not ruled out othe^ possibilities In the event that these plans change, we will immediately notify you Since total mill dismantling is the most likely course of acti)n, we are asking that you process the attached applications expeditiously, In the event you need any 7 urther information in order to proceed with the permitting process, please do not hesitate to call me Sincerely, /I1 7 914- 43 Brian D Jones Environmental Superintendert (360) 457 -2352 Fax (3(0) 457 -2493 Enclosures BDJ /sh ht■ :tC,e1 to 1 O "We Calif wale No A2!14 700 North Innis Port Angdes WA 98362 I (kphc>n( (360) 45' 3391 lax (360) 457 2437 1 /JC'( 1(111) rill /1 /'rO(I11( 1' 1' 1 I u'c /c Mil/ specs \wjc \0043 I. DISMANTLING AREAS RAYONIER INC Port Angeles Mill January 10, 1997 WOR K PLAN FOR PI JLP MILL DISMANTLING Revised 1/14/97 The intent of this work plan El to describe the dismantling project at the Rayonier Mill in Port Angeles, Washington. The Mill will go through the normal sequence of shutting down, with an emphasis on cleanup of all systems. As a part of this cleanup, all tanks, including the SSL storage lagoon, will be thoroughly flushed 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, 111 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 Imes for future identification where they emerge from or enter the ground, slabs, or foundations. In general, all dismantling wo,'k will be done during daylight hours, Monday through Friday, with weekend work subject to appr oval of the Owner The site has been divided into smaller areas for coordination reasons as outlined on the attached drawing D -92137 "Dismantler. g Areas/Plot Plan." The numerical sequence of these areas has nothing to do witlLthe dtsman ling sequence. It is the Owner's intent to remove as much of the hazardous material initially as is feasibly possible. Emphasis will be placed on removing major wood buildings first to reduce fire dangers 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 areas 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. A. Area 1— Secondary Treatment 1 Remove all buildings, structures, equipment, tanks, and systems in this area including the 69 kv substation and all miscellaneous equipment stored in this area. 2. Remove cl ip truck dump. 3 Remove pulpmill pump station in Area 5 and associated above ground sewer lines. 4 Underground vaults to remain. 5 Remove 59 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—Puma ry Treatment 1 Remove All buildings, structures, tanks, equipment, and systems including the CLO generator area, warehouses, chlorine, and SO storage tanks, lime slaker equipmet it, primary clarifier to grade, and all associated above ground piping. 2. Outfall, foam tank, and influent wet well are to remain. 3 Remove all miscellaneous material stored on ground to east end of property 4 Do not remove the two budges across Ennis Creek. 5 Remove 3SL lagoon dike matenal. C Aga 3 —Pulp Finishing and Roll Storage 1 Remove T11 buildings, structures, equipment, tanks, and systems in this area except main sewer line to treatment facilities which will be removed with Area 1 2. Do not remove bndge at mouth of Ennis Creek until released by the Engineer 3 Remove all wood floonng in these buildings along with associated pile cap and floorJoist Piling to remain as well as any supports for main sewer lines under these buildings. 4 Remove clevated roadway along east wall of fimshing room. Rayomer will relocate a recovery system equipment. D Area 4— Office; -Shops 1 Remove a 11 buildings, equipment, structures, tanks, and systems in the area including the Beanery, Credit Union, and truck scales. 2. Yard ligh :ing to remain. E. Area 5 —Scree i- Bleach Machine 1 Remove ill equipment, structures, tanks, and systems in this area except the pulpmill pump station which will be removed with Area 1 2 Protect e :posed sewer lines near pulpmill pump station north of machine room. 3 Remove all wood flooring and supports, 1 e pile caps. Leave piling as is. 4 Concrete floors in the screen, bleach, machine, and pulp warehouse are to remain. 5 Any resic ual pulp stock will be transported to a mill site designated by the Engineer. F Area 6— Filter Plant Area 1 Remove 11 buildings, structures, equipment, tanks, and systems in this area except overhead 69 kv power lines. 2. Timing fcr 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 1 lant-Digesters-Blowpits 1 Remove all equipment, tanks, structures, and systems in this area north of Mainte riance 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 a 11 pile caps and supports under blowpits, leave piling under blowpits. H. Area 8 —Chip :.reenmg and Storagg 1 Remove E. equipment, structures, tanks and systems in this area including the chip truck dump equipment. 2. Remove c verhead conveyors and associated structures to logical cutoff point between c ismantlmg areas, i.e., transfer tower or building walls. 3 Remove 11 wood flooring and supports, i.e. pile caps. Leave piling as is. Concrete floor areas on grade to remain. 4 Do not remove main overhead pipe trestle that runs from power /recovery east to south s ide of chip storage The solid sewer on this trestle must be maintained until the woodmill pump station is removed. 5 Any residual chips will be removed by the Contractor to a mill -site designated by the Engineer I Area 9 —Dock 1 Remove 11 buildings, structures, tanks, equipment, and slabs. 2 Remove timber support structures, fire lines, conduits, and miscellaneous piping. J Area 10 —Reco ✓erg 1 Remove all equipment, structures, buildings, tanks, stack, and systems in this area inclui ling the absorber cooler and associated systems, Brinks filters, and ductwork to stack. 2. Do not rer Hove 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 oP the Mill. 3 Do not reinove 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 11— Powerhouse Sludge Utility Tie Substation 1 Remove a [1 buildings, structures, tanks, equipment and systems in this area 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 c nd of this area. 3 Remove fi iel oil storage tank, Rayonier will provide for cleaning of tank interior 4 Do not rer dove used oil storage shed. 5 Remove 69 kv overhead line and structures up to pole at filter plant. Rayonier will provic'e for isolation at pole. 6 Remove rc maining utility systems as dock removal progresses to point that fire systems ar; no longer required. 7 Remove riw water pump house, woodmill pump station, and main east -west pipe trestle 8 Remove 11 above ground piping from pump house to filter plant. 9 Remove l' og 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 A ea 12— Woodmill 1 Remove all equipment, structures, and systems in this area at the extreme west end of th site except the raw water pump house, waterline and the woodmill pump station, which will be removed with Area 11 work. 2. Remove r ,twining wall in south end of log yard. 3 Remove f ipe piles in log storage area south of Auto Shop 4 Remove r og fuel conveyor to powerhouse to support at west side of roadway between c roodmill and powerhouse. 15 kv power conduits to recovery substation must remain until the woodmill pump station is out of service. 5 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. 11. ASBESTOS MATERIAL REMOVAL The Contractor will re nove all asbestos and asbestos containing materials (ACM) from the work areas identified t trough site survey information as provided by Owner ACM is known to exist in mug 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 provid. 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 of intent to remove and encapsulate asbestos be filed with the Washington State Department of Labor and Industnes In addition, a 10 -day prior notification of dismantling and renovation is required to be filed with the Si ate Department of Ecology A sample of these forms is attached. Contractor is respons'[ble for submitting and obtaining all asbestos removal permits with a copy sent to Rayonier Engineering Department. It is expected that Co itractor'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 ix moval and handling safety procedures dated August 12, 1996 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. 2ontractor will deposit ACM, properly sealed, into asbestos 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. 6 III. LEAD MATERIAL L R EMOV Ai The Contractor will rein ove all lead and lead containing materials from the work areas identified through site survey information as provided by Owner Lead and lead containing materia is known to 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 ue certified as required by the State of Washington for the removal, handlmg, z nd transport of lead containing materials. A copy of work certifications to be submitted to Rayomer Engineenng Department prior to start of work. C It will be the respon:;ibility of the Contractor to obtain any and all required permits for this wor] D Contractor to provide Rayonier with a detailed work plan including containment and air monitoring procedures pnor to start of work. The work plan is to include a description of the i equired special collection/filtration of waste streams generated by this we rk. Rayonier will provic e for disposal of all lead and lead containing material. E. Contractor will provide for all air monitoring throughout the abatement period. F Contractor will mai stain on -site documentation of airborne lead levels and employee exposures for the duration of the abatement period. G Copies of all tests r°quired including air monitoring, personnel exposure levels, etc will be submmed 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 dumpsters. Rayonic r will be responsible for off -site transportation and disposal of all lead- contamuig materials. IV. HAZARDOIJM IERIALS. Owner has inspected ens isting 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 environn rental concern. A. Asbestos matenal oxists 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 tl ese locations will be provided to the Contractor Rayomer will test samples of concret floonng in the areas of transformers and provide results to the Contractor Concre a floonng m 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, COCA, etc. E. Paints used may have contained lead and pnmers may have contained zinc. Respiratory protection should bye considered dunng any operations involving flame cutting. A detailed survey wil be provided to the Contractor F Greases and oils us for lubncation and hydraulic systems are present. Rayonier will dram gearboxes, primps, 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 matenals are present, the Contractor will stop work in any area where exposure to such hazardous matenal s 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. OWNER S RESPONSIBILITY The following items of work will remain the responsibility of the Owner A. Testing for hazard pus materials prior to start of dismantling work subject to Contractor 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 rer drained transformers (9) from buildings and load on trucks supplied by others for transport to final disposition. D Off -site transport znd 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 matenals. E. Off -site transport and disposal of nonhazardous rubbish and nonsalvageable matenal. Contractor will stockpile segregated matenal at locations on the mill property as designated by the Engineer F All required piping; and electncal alterations to existing mill systems that may be required to keep e equipment operating during the early phases of mill dismantling. G All below grade re; nediation of soils, etc., as well as dismantling of underground piping, conduit, ani piling. H. Installation of secunty fencing at mill property boundanes, Contractor will provide for and maintain security fencing around active dismantling work areas. Attachment: Drawing D -92137 L lismantling Areas/Plot Plan 8 CL -13179 PARCEL 1 PARCEL 2 PARCEL 3 PARCEL 4 PARCEL S Blocks 8, 10, 11 avid 12 of Norman R Smith's Subdivision of the Townsite of Po -t Angeles,, also Blocks 8, 8 1/2, 10, 10 1/2, 11, 11 1/2, 1 and 12 1/2, Tidelands of the First Class (East of Lau el Street) in Front of the City of Port Angeles, as shown n the official Plat thereof on file in the office of the Commissioner of Public Lands of the State of Washington All Tidelands of the First Class in front of the City of Port Angeles inclu4ed in two tracts lying in front of the "U S Hospital Re erve" and bounded on the East by the West line of Blocks 10 9.nd 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 Washington 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 SO 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 Block "C" of Port Angeles Tidelands being the Ennis Creek Waterway xacated by order of the Commissioner of Public Lands of the State pf Washington dated August 27, 1918, as shown on the official Plat of Port Angeles Tidelands on file in the office of said Commissioner The following Tidelands of the First Class in front of Suburban Block 1 1/ (sometimes called Suburban Lot 1 1 /2) of the Townsite of ort Angeles, as shown on the official Plat thereof on fil in the office of the Commissioner of Public Lands of the State of Washington, L \111BIT 1" (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' West 305 feet, thence South. 66 3C' East 308 feet, thence South 31 °15" West 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 31 °15' East 178 feet, thence North 69 °22' West 550 feet, thence South 31 °15' West 158 feet, thence South 66 30' East 556 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 :he City of Port Angeles, as shown on the official Plat ther,:of on file in the office of the Commissioner of Public Lands of the State of Washington PARCEL 7 All of Blocks 1 an4 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 West 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 Puthic 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 stay, East of the East line of Francis Street in the City of Port Angeles, AND West of the Eist line of the Original Townsite of the Townsite of Port Algeles and the Northerly extension thereof, which would attach thereto by operation of the law PARCEL 10 Lots 5 through 11, inclusive, in Block 32 of Norman R 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 PARCEL 14 Parcel A That par: 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 d:stance of 420 feet, thence North 12 °15' East a distance of '07 18 feet, thence North 58 °45' West a distance of 287 44 feet to the Westerly line of said Block 1, thence South 31 °]5' West along the Westerly line of said Block 1, 385 feet tc 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) 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 Clailam 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 Biock 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 Biock 1, Lots 1 through 9, inclusive, and Lots 23 through 26, inclusive in Block 2, Lots 1 and 2 in Blo:k 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 acres 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 Ani.eles on the East and Blocks 152 and 166 of Frank Chambers Sibdivision on the West, 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 0, .'.... """j ':t"" ;<V"'H'f}1:'l---"'-','r-f''''W-'>' -'jJ"\,""'''''I::.'' "r .. i "," ',. '.,.-x "., -,' ,,,'~~' _a., ';';'~ ." "~'I ., ,. . '--L$<' ' . . ~I \""'1\ ."-,.,.,,,4;.~-7...~. '-to "Io;'~"itl."''''l'''-''- ,~~,,"-", ,. 'f;~fi':.:/.~4 df~~1:f': 1~*y4~i~~:j.~~~;[1~~$,if,.t;\.~.;~~,i~ ...~;,\~;~,t~~jJ,~ ::~}:~~~~q,~~~l.~~:'~/~'~~Jii:~:~~~'fj;! JV;e~::~(,':,~_i;l~*!t~J{;,rp;~!" ;\1i:.t)} ,:~G;X{!r;~~$>l~i;~Q~ilr~~7(;ff~~~:!#~~~~:ji I'~ ,'"'' 'h,' '" - -", ,.., "-,,, . '. '-- ..., .,..... ". ""."" ,,," '.. -'", ,,,.,.' ~j)~,. 'I~;;~};~, ~'. "~~~~:'~;,: ',0 ,'. ,'~ l~~:t:~ .'t"""I~' "''''';''.,-1' 'iK~"-' .., '!!I'Sti' 'C/, L;!>;;,,\ ~'. Iii (';.rh:','~ :',.+'~h. )'.'~.;~:~) ;,\;;~~;.:-: ,,}. 7,(1~.~;,f.1~~""";':"~:" . ''') .-", ,......"'~.. .....~ '",.,.,,,. . -"J'J- :~\t(}~'4 ;:.rjt~s~~:', 'N,~ ..J"I,~'ntfJ!l." ~~G~i~~;~; ::~j~~i~~' ltil~~).{; "\"'I.'~i:~>~~'}~t~1 . C':4:~,.',.".v~\~ J.i;;i:f~,":1 ~'~'I'~ '.'" ,.~ ,f\., 4., ;V....; :'.> ~~i,~, I ;.,1.1~.< ,~ ;~:"~$.;.{'~:~:" ~#~",n: ...'tt. '''J;_~",,)'>j'~fl\' . ~f,,~'~',~~:~t"~\'<.;i~t*t::;, ",f~'~ 'l,'I)."'"'l.;:.(i'.:.~ ~ "i:;'~').:'1-.11~J '~I':.1Ji.'~~':'jl :~~~Wft~;f,~;{ .l;~:'~:.{.tti.~:~l';u:;t't'~;~ ~$~: ;'~.g~:~~t,~;',~IJt?: "~"';:'1~;:r,\~,,,','t'lit1: '~;,-,i~: ;~~}'~r:;-r~'U't . .:;:~,.U~{.'-;~}',;11\,Zi::lf'kl !~!~~t;i~k1'~" - .".~~. .~..,;" .. .~~I';.:~'~j5j~~. ._,,'1' :-\"1..,;....,~..~...\'~"oj I'~kll ";I~J;.{~':1;~ "l'!-~"l.\!l~'\ Iff,!~~ ~'";',"Ji~', ,:<,!tt;:J#'~' ~,;'\.:;t\\~~. ;i>:.:-i~~:~:P.:~:' 'X'J:!::.,.A"-f ''g''~~lt'fi\: :f"tJ.r~~';{~' .\1.*,'1',,,-1:.,.. ;i[!(~t"WI""";' .. 4'. ;" . ..~:~~I-',~);v.;,\:'t' -:,:iW~~,.~;:.~y->>-.(..~:.'I.~l),.. -'.~ ';>f""~"'" >l " .-" ~.>.il. '~"~.~~"I .., it.\!i,,~1} . '"M'\'li~I':1~tli~!'ffif!:lliw,v.; f ..... Cl ~ ~ A ~ . ..~, ~ 3 ~ . .. "~ , " , U 0 ' o " .. U .~ ~~ ~ ~ ~ g ~. . .. ~ .<: " u . .. . " . . . .;5<1:. :'",,:,: ::.,:. ;'J"7..j-",d. ~i..~/..:J:f~:"~ ::! ;'.; ,:''':::, ('l' .'::-'.: !'of 51 I P' I '-'/1 /..."i ><~ _ e ,t{ ',;~, " .' , ~ I, DEED AND EAS3M1ltn'S 'J."'he Grantor, IlAYONIER INCCRPORATED, a Delzl:'wllre cor- ..~ poration (hereinafter "Rayonier"),~,for one dollar ($1.00) 'rfi and other valuable consideration/':rBceipt of which i8 ";~ hereby acknowledged, convoys and quitclairna to the CITY OF PORT AN:iELES, a municipal corporation of the State of Woshill9ton (hsreinofter "the city~l, the following. . -;~?: A. Royonier conveye and quitclaL.s to the city all ;~. interest in and to the following-deacrlbed real property located in Clallam County, washingtonl .~. Lots 1 to 6, inclusive, and Lots 13 to 18, inclusive, in Block 1651.All of Block 166, all in Fr.nk Chamber. Subaivision of Subur- b.n Lot 37 and Fart of 39 of Port Angeles Townsite, as per plat thereof recorded in Volumo 1 of Plata, page 24,' recorda of Cl.llam County. W.shingtonl and All th.t portion of Suburban Lot 39 East in the Townsite of Port Angeles, lying east of the East boundary lineoof Frank Chambers Subaivision (Vol. 1 of Plats, page 24) ana northerly of the easterly ext4nelon of the center line of columbia Stroet in the City of. Port Angeles. The above~o8cribed real property is hereafter re~erred to aa "Parcel A" B. Rayonier conveys and ,quitclaims to the City, its successor. and aSBiqne, the perpetual non-exclusive right "";'. and easement to construct, reconstruct, mointain, repair, replace, use and operate a sewer.pipelino, together with all connections. manholes and other appurtenances thereto, I' i over, a~r038 and through the following-described real , , ,. ~$f~ ,{ ,'~;;' .~~ ,:l!;:" ',...:.:- ,,~ ~T r-' '""'Ci . .... .D .... " "...., ~a lll~' ..... " U 0 I o . ,., U ..... ....~: G ~ \ e " " " , ... g . . 0- .... .. . U . ..... o ' ~ g.... .... . U . ! ;: o . ... . . e .... . ..... , .... U u ~:::.::.." ., J~ "~~ ~ .,."" '..;. .; :~ >~." ..1 ~;',' - '. ;. J~~:" ~a; ~j :::::t~ ~ '~f,' over, across and through the :.tollawinq-deecr ibed rea 1 i'f;; property loc8ted in clallam County, Wa~hingtonl ^ etrip ot land 35 feet in width over and across Blocks a and 9 of tidelaoos eBst of Laurel Streett Block. 14 aOO 15 of Norman R. Smith'. Subdivision, Blocks 2 and 3 at puqet Sound Cooperative Colony Subdivision: and vacated Race, Chambers and Jonos Streets, all in the Townsite of Port Angelos, Washing- ton. the centerline of Baid strip of land being more particularly described ae follows I ;.' Beginning at a point on the centerline of Francia Street, Townsite of Port A.ngeles, W~8hington. which point is 17~ feet northerly of the northerly right-of-way line of the Chicago, Milwaukee, st. Paul & Pacific Rail- WAY1 thence easterly along a line drawn parallel to the northerly right-of-way line of the Chicago, Milwaukee, St. Paul & Pacific Railway and 171:1 feet northerly ot said right- ot-way line, llJ3..ured perpendicularly to .aid right-of-way line, to a point where the north- erly right-of-way line ot the Chicago, Milwaukee St. Paul & Pacific Railway intersects the north- erly boundary ot Lot,9, Block 15, Norl1llln R. Smith's Suhdivi,ion,'~\r(hich point is the end of this centerline ~e8cription. </A~ The ebove-describad real pr~pcrty 1a hereafter referred to .'1): All 'l'ercel C". ",. "..' D. Rayon1er conveya"and quitclaims to the City. it~ successorr and assignl!l~~{ the perpetual non-excluaive <if. to construct, reconstruct, maintain, right and eallement repair. replace, use and operate a water pipeline. an ,'''~' electrical transmi8sion line, and other utilities. together ,':~ with necessary pipelines, polea, wires and other Appurten- ances over. across and through the follawing-descrihed real property located in Clall~m County, Washingtona ..t '4 i "~"'!! e M A ~"';l ~~ I ... t:ltt ~ 0 I " " . u .-< -<M ! ~I ~.~ p- O . .. .:: 1 ...c:.. . . ~ I :i d.:l. I o '. . u g-< -< .' u e . po o : '" e .:; a . e-< '''c''c uu . , 'i .'r.....~..... ;"S .~: ..~,;. ""'" }~.~11: .""" C~?4~ ]~t;; A strip of land 30 feet in width across Blocka 153, 154 and 165, Frank Chambera Suhdivision of Suburban Lote 31 and part of 38 of the T~'naito of Fort },nqeles, Ba per plat rocorded in Vo lU1\'ll!l , 1 of Plats at page 24, recorda of Clallam County, Washington, and the abutting vacated streets and alleys, the centerline of which strip of land 18 more particularly described as follows I :~~ Beginnil'l9 at a point on the center- line of vaca ted caroline Street' ..hich ia 335 feet south 58-451 east of the inter- sectlon of the centerline. of Bnnls and caroline Streetsl thence 250 feat north 48-19117" eastl thenc6 323.7 feet Bouth 82'40'41" .aat to a point which ie the !ntorsection of the centerline" of vacated Columbia Street and the projected wester- ly line of Lot 13, Block lG5, of ..id Frank Chambers Sllhdivieion, which point ia the e~ of this centerlinedeacription. it4~ , -.~,:~ ~ .' :<:;"1.;:-- The above-de8cribod real property is hereinafter referred tOBS "Parcel 0". E. Rayonier oonveys and quitclaims to :..he City, itt,1 Buccessora and a8.igna, pc:rpotual and non-exclusive right and easement to construct, roconstruct, maintain, :~~i replace and use a rood for acceDa to Parcel A over and ~l?';.. acro.. the following-daacribod reel property located in . i~ A right-of-way 30 feet in width over and acrODI the follOWing-describe~~propertYI Clallam County, washington I That portion of tho easterly 30 feet of Suburban Lot 38 east of the Townsite of Port Angeles, lying Eouthorly of the projected centerline of Columbia Street a~ abutting and parallel to the easterly city limits, Townsite of por~ Angeles. The above-desc~ibed real property is hereinaftor roferred . to 8e "Parcel S". i$:-: -4- r- ~ . .. A ... .\ ..... ,!l! . 0'0:.\ ~ ~ \ . >- ~ .... ...... ! tl ::'2 r:- .0 l:. .... . 'oS: _ -. u . 0 " g oM" U .' g'" ... . ~ . ! = ~ , 0 . ow . . . .. , ;. " r,' .' .~'-{ ~. If' ';.;w;: ., :.'ff F. The conveyance by Rayonier of the e2l4ermJots """". '1~~n, described in Parcels D, C, D ana B 18 on the follrywlng .1...... '-< ... -" ~ 1. Rayonier re8er~ea all rights 1n and to the - property c.1escribed in parcol.":$:~~" C, D and E, oxcept those '.:" ~'.~J., rights expressly c;r3.nted to the:"City herein, including, "~;: without limiting the generality~of the foregoing. the .~, right at all times and for all;purpoees to go upc'ln, under, along and acroas ~;;. propertylprOviced. howevsr. that in the 8Jtcrciso of said right8'~Rayonier shall not unrea- .~ -.~~# Bonably interfere with tho USG70f soid property by the ;";,r .:. -i:.(;' 1 "'.,t terms and conditiona, City for the purposes herein granted. f1:~~. 2. The. Ci ty shall place all sewar facilities ~. on Parcels B and C and all water pipeliMS ond other Under- ~^ ground utilitiss on Porcel D e.t:'. a Rufficient depth beneath . .~. the surface of the ground th~1j;aYOnier 'Will be able to u.. the surfaco of said Parcel's: for walkways, for drivo- :'...'.... y;r way. and parking lIrOA8 capablo..of holding vehicles beil!lring a:~' heavy loads, for planting areas, and f~r related and Dimi- .~ lar purposes. It requosted by~Rayonier in ~itinq, tho iI1 city agrees to relocate the sewer pipeline (Parcel B), the sewer pipeline (Parcel c)~~tha water pipelines, electri- ,. cal transmission lines and othor utilities (Parcel D), or the eCCOS8 road (Parcol E). to such other location or locations 8~ apaclfied by Rayonier, which removal or <C removals shall be at tho 801e expense of the C!.ty. When I -- . c ~ .. ~ . ...... ~ 3 ~ . .. .~ " .. 0 g " u .~ ~~ ~ ~ : ~ ... 8 . . "- ~ .c . .. . ... o . . .. . . . ; ~I'~ '. .;, .... a relocation of a facility~iocated on one of the four :~, parcels haa been rcqucstca,by_Rayonier, tho following ahall occurl~. (4) The City and Rayonier shall execute a new -1 e~semont for the rel?~ated Dewer pipeline, utili- ~':#!,~' ties or roads, whichever the CAse may be, tho t~rms ~:'~ and conditions of which easement ahall be substan- .,.~.' tially equivalent to~the terma and conditions ;r~;j;. herein cont8ir~d, including this removal clause. ~; '?i (b) The fa cili ty.. aha 11 be removed and re loca ted .....~.fi;, by tho City at its sole expense; provided, however, - ~,~;~ that in the event B particular facility has been ;~ previously ramoved and relocated by the City at .~ ita ex~nse, any 8ub~~quent relocation of that ':;~. particular facility ~t~the requcst of Rayonier ahall be Dt tho expanac ot Rajoniora (c) Alter the relocation and rcmovbl of 1II facility has been completed and a new easement ',';,y;: coverinq the relocDtod eDsement "rea has been ~~\ executed, then the easement herein granted with i&!i respect to such facility shall terminate aI~ the ,:1~' City shall execute and 'deliver to Rayonicr .13 quit- "." &.7, claim deed sufficient-in form for recording, relcal"inq all intercst "of I~ ,'~\t former edsomont ar"a.i': ...~; Rayonier'e r!lite :,~ Jl ., the City in and to the to lequire relocation .... I. I I ' ,""'t'\ . . o - . .,... . . , ~.s \ : t' \ .. 0 o . .. .. .... ......' !' J:~ :1' ... ... . u . ...., o '. .. g .... ... . .. . !: o . '" . . . ... '~ .~ ~:t' "/!' ~~~' 'l I '~:1:< -,'.- and removal ehall be independent with respect to Bach of the four perce Is. and the fact that it may at one time have requosted a removal of the ;~."' facilities trom one of tho percel. ahall not in ~.;;'-$ any way affect its right to require removal of :..i~; the facilitie. from one or more of the remaining three parcele. :~:'(; '~, ':,-t "'}~' ,;-lo.. 3. In the ovent that Rayonier should desire to construct improvements upon either Parcels B or C. which improvements would not necessitate the removal of the sewer pipeline but would be more expensive to construct . ..!:3 u.. because of the existence of tho pipeline, then the City '::;:, ~:::: . "fl': -. ~-'" ~ ~., ohall reilnb~"e Rayo"lier for any construction coats, 8fl9ineering costs and other expenses that it reasonably incurs ",8 a result of tho existence in Baid Parcels B or C of tho eewr pipoline and appurtenances. ,~ -,\.'..'~ 4. In the event that in the future access to ,:--. Parcel A becomes reasonably available and feasible from public street" or roads, then the CitY"ahall relocZlte its # access road to the public streets and the easement for right-of-way purposes over and across Parcel E shall ,"". terminate. In such event the City agrees, upon request. to execute and deliver to Rayonier, ita aucce8sore and \ assigns, an instrument in form suitable for rocording quitclaiming to Rayonier, its successors and assigns. all interest in p.aid Parcel E. ( 5. The city, upon completion of conatruction of j , r~ the sewer plpelinea, the water pipeline or other utilities, l end the roadway shall fill all excavations 88 Boon DB prac- ~~~~: ticable after opening, remove all debri8~~and restore the ;;;~~- r , surfaces of Parcels S, C, D and E a8 nea~ly 88 possible \~;~- to the condition in which they existod atjthe time of con- :_~~~: veyence of theBe easements. In locating" and installing the ,t<" sewer pipeline in Parcel C, the city shall use care to BO ,::;;,(i locate the pipeline that it will not interfere with Rayon- ler's existing structures, pipelines, tanks and other ':':'+';~ equipment. fr,'..(' 6. The se~r pipelines placed upon Parcels Band '\;"".. c, the water pipeline, electrical transmission line. and I' ~~1 !,S..... .' ony other utilitiee ploced upon Parcel D~gond the road placod upon P~rcel E, shall be const~ucted, maintained, ( operated., repaired and replaced in accordance with good , i<<".~ practices, and the City shall not pcrmit-"any unsafe concH- .~<~, ~ -. .' ..;~. , tion to exist on or about parcels B, C,~D and B by reason :i;.J,'- -<,': 01 _~~:1~~i.~~,:e,,:~of,8Did, c~,~~~~liti8__,~~;~~~~~~f~Y:,,,y*!>~:-,' act performed by the City. ita officersii.employees, agents , or contractors in the exercise of the rights herein granted. The city, ita agents, employees and contractors, during the course ('If constructing the sewer pipelines on the rights- of -way described in Parcels B and C, or the water pipeline or electrical tra~6miBsion lines on tho right-of-way depcribed in Parcel D, or the roadway on"the rignt-of-way described in Parcel a, may tomporarily 1;180 Buch portions of Rayonier's land outside of the rights-of-way as may be -8- -~-'~ ;\!',~.~~.:~~ '~~E~~:~.)~~~~~:'~~.~'i:~~~~;~~;;\.;':\{:\:,~ ::~~::::(~:~'.j~~/~:~~:.":~'.,< ::~>~-::,:.;:~ ;::";:"~' ,~ ~v~. ~ .~,.-; y: .;': ,'.'<' ~;,,' .......'t.. ,.,' ..;';,/....' .'1. 4.. '-'.-.' '6~~__"'. ". ';~:~~N)~:t'"i1~i;~f~"t~$':.~~~z\;i!~0t!j;ifl~~~tf;i.?,i~)~;;'\.j~\$:?1~;F, th~r,~WJ"~~::.~~}1;f;;;{::iJfN'Wf:~;C;i':J~iff.~Y{<i)1:';}\'j.~~rt}~~fW~i!,~?~#W'i: ;i'~~ \~"i ~g "..ft.;, .~\'\', {{~~, ~i~. ~h..;;,' ::'~fl~~ ~~~:?~ "'_c.. ""k'~r .' I I"",.: .il,'.' \t~,Jl:i . 1't~l." '..iit)~ Is::':~ .~~r1;~~; ~c.;'~~:~\i ;i\fif,b;, rlj: .'~~p~t~' !~~t~ .K~.~~l;'~ ;,';'~~';~~'i ;'.;.o~n7:~' ~1,I:i..."'. (.:~\l,"'~,' '"'I'I'qt.\ f;p:i~ll' '~~f~~~~~. ;~~,~( f'A'."'F' ,t'f""I" ;'~.~, ,::'.Vi~ ,,~!';;"~t.. '1.':, .~:. ~'_' "11'.' :-.1\-'.,., ...~. . ,;~~C.'l''!f!~~'~'" }-,m:.~"'",~~}" (',,'I t J.;.l..\,.....,I,Z,.~:r.~I. ,1 "'''.~..,'."''.,"''I\'f:t.. ;~:~~.~}l1.Ili',~8: .~.: J,. ...:r.~.".,~Ii)1.. ;0.:,''' '" ~!\::'.';f;l:O:.:;.,:l;.fl\'~:~;; ;.,.~:t, ..;....~. ~rl~....l~ W:{;:~:./ft.>:;Jft~'-!;j'; ,".~-:r,"..'~f. ~r>..~.1~~'. :t~. ~ -~~"'.,: :f.. rl'''1;"!'IC:''~ ~"'b~. :.,'l"~".:.~<...'i(. :"t';:;" '~1 '14?)'P'f." ',!:.:;"'J,t.:lt~, iJ<Il!o.V...t,i: (;:~'j~.~..IlW;1~,~,~yv.\}t .;,.-,'-.:-:..ij' rv:~~~..;l,.,\(~' 1tr~fuit:~~~\~'i (~'~"~~6.".11o(' ;,'~~Hb~~" ...;.}~;..;~di~t:.~~''-'' "~\~ '.~*<r:.'" '*~l.~-!~I;,,~ " ~1~~,~~l~~g ~;:.~.:.'f:''''{"':;:t:,\{''~~~}:~ !I;~i~~{f~1n~1~~~ ,:,.t'&1~,"'~~lt,.. ::({.!jW~':.-~f,~' 'rl'~ .~"\' ;.~<?-');<:..,'l'l ~~;.'\'!1#' .,,-~\1,.." I ;~.tf{o~f~."l ~f"t:i"~rf: f~r.~l~ ~l"""d!f.~;:; ;:tt~~a.. .. ,... . :(. tX', ~!;~. I'; .1;;o;'!i'~1<!' Jr.';.:,:. ';'1.\. -v ,~,/\~'" ~,.r.;,.(.0,J~~"':"~J';' ~ii ;','.:~~:,:.;il': ~ "<<1:;i~:';;~~:;;ltj';,;\':-:liJ\;'$Fm.:if;\{ ,. .,~ U . .... A ~~ I .!l a . ~ I .~' ... .g 0 I . ", u, .~, ........ ! t: ~ t r o . .0- ~ ..c tiS . u . .~. o . u g~ ~ . u . ! : o . '" . . a .... "11 -ij necessary for the purpose ot placing excavated materials ':~ thereon prior to backfilling. or,for the tomporary move- -~~.~; mont of machinery and equipment.~rAny such portion of ~,~:~: Rayonier's l~nd outside of the rights-of-way as is used "Pi' shall be restored immedietely after completion of ccnstruc- tion to as nearly 88 possible the condition in which it existed at tho time of tho grant 'of this easement. Said :'''' right of use of adjoining Rayonier property ahall. with respect tc the sewer pipeline easement over and acroas ,,,,; Parcel B, include the temporary use during the period of construction of a strip of land 30 feet in width along the we.t aid. ari! a strip of land 10 feet in width along ':.oi' tho e8st side of that portion o(,parcel B lying south of ;'if the Milwaukee Railroad right-of-way, and a etrip of land 20 feet in width along both sides of Parcel B lying north of the railroad right-of~'ay. said right of UBC of adjoin- i~ Rayoni~~ ~r~?erty shall. with respect to tho sewer pipeline easemont across porcol C, include temporary use curing the perivd of conBtruction of 8 strip of land 25 feet in width along the northerly side of i'arecl C. 7. If at any time in the future oither or both of the tracts of lend described in Parcels nand C shall cease to be used by tho City for the purpose of maintain- ing and operating sewer pipelines, and such cessation 0':' use ahall continue for D period, of five (5) consocutive ~~; years, the eaaement herein granted and all rights hereunder -9~~;:" ";~~t ,.r:I'.i<,>; .",~. ;~"" <.t;~ ~~;:;: .~~i ~l with re"pect to .aid parcel or parcels shall revert to and '"-"t. . ... .D ... . .....\ ~a . ~l C1-;::: ~ 0 I . .. .~l ....... ! tl : i ~ j :2 .. t " . .... .0 . " g'" .. . " . ! : o . .. . ~ . . . .l!~ "" .. . .... . , .....-.1.(:. ~_..Jl become the property of Rayonier, its su.ccessors era assigns, ~;~- free and clear of any right or claim of:the city. \~, any time in tho futuro the right-of.......ay'.'doscribed If at in Parco 1 D above shall cee&e to be us~d by the city for the purpose of maintalni:lg water pipelines, olect:cical transmission linea or other utilities, and such cessation of use con- ~_6tt5. tinuea for a period of five (5) c6nsoc~tive years, the -.,~~- easement herein granted and all ri9ht8~ereunder shall -~~:' revert to and become the property of Rayonier, its Bucces- Bora and assigns, free and clear of any, right or claim of ;,.;'// ~ N~~~;' 'I""""~~,-,,, .,. '~'~""')' '1\ ,\)~\~.i"'!-' .'t<.. "'". '", "~'" 1lf 1"" \~! :~M\,;.t..;:.: w.~. ~~{!~~;~~. ../:'~'1,:~.n.\,t; ,~i:. ~F: ;;; t"i~ \:.'; '{,tl,~,(,~J..,~, ~f~?J~~:~!; ~~.1 i:":!:l~\\h~;X' ~~n~1;.~~~i:/:~ '!-,:if,:;,,~'>,-e:.,J:-'.;'~':) _..;......".....,.t,h ~:(~;hi;~:6\\~ 1~~~~~~ V~;"I~~\J~t1~i~. :~~~~}~~~ ;"""'!(,~r,:m: {l:!~t~~j .m' ).:,. .'.:,.1" f.:t :,~~ :14 ~~i -"'~ X~ ~::'/f. 11;; 'Et'; ':I~) vn. ",,/;,': "~~f~t1tN;:~:~~:~I;~~r;:~f:~fl!.;t-;;;,\';(~';':'1...::1~ !;~'!Yrl~;?;:ri~~~;it~.i,.~~~:~;){~~\f:j,~/~f~f:;~~.: the City. If at any time in the future' the right-of-way ;~J~ doscribed in Parcel & above ahall cease to bo used by the ~ city for the purpose of maintaining and operating a road 1ii>~ for access to Parcel A and such cessation of use continues ''ti' for a period of five (5) consocutive 'Years, the easement herein granted and all rights hereunder shall revert to and become the pro~rty of Rayonier, its succeseors and assigns, free and clear of uny right or claim of the City. In the event that any of the above-deacribed oaeementa >tt.; shall revert to Rayonier. the city agrees upon request to execute and deliver to Rayonier, its successorB and assigna, an instrument in form suitable for recording. quitclaiming .' ',~'i,-" to Rayonicr, its successors and assigna, all interest in .aid propHty. 8. The City .hall have the right, without prior ~*/ inatitution of any suit or proceeding' at law, at such timeB ~-~ $i :J"f .~;#;' 0';'--"-' -10- ~';f I ~.~ . ... A ~ " ...... ,!l! I . .., O~, " , " 0 I 8., , ,,' .~ ...... i ~i ...n . .. ... .co .. . ...., o '. " .... o ... . " . ! : o . ... . . a ... .~tt':.- ;r ::t~t:~ '~1 aa may be necessary, to enter upon ,Parcela S, C, and D for the purpose of constructing, repair~ng, alterlnq, meintain- ~}.:: inq or reconstructing the sewer pipeline upon Parcel B, the 80wer pipeline upon Parcel C, or the water pipeline, elec- tric transmission lin08, and othe~~utilitie8 on Parcel D, or rtaking any connections with aaid facilities. without ',::f, incurr inq any loga 1 obliga ti on or liability thereforl .":-,- ...~.," ,. providing that such constructing,'repairinq, altering, maintaining or reconstructing shall be accomplished in such 8 manner that structures, tanks, pipelines, installed equip- <: ment and any other improvements o(,nny nature located on .-L" parcela B, C or D shall not be destroyed, disturbed, dam- ,~. aged, or in the event ~at they a~e disturbed, damaged or deotroyed, they shall be immediately replaced by the City "cF in aa good a condition as they were prior to the entry upon the property by tho CitYI and provided furthor. that tho "": City ahall fill ell excavations 88 800n as practicable after opening, remove all debris, and rClstoro tho surface of the Parcel as nearly 8S possible to the condition in which it existed at the time of entry by the City. 9. By accepting ana recording this deed apd easements, the city, ita successors and 8ssigns, 8gresa to indemnify and hold harmless Rayonier. its successors and 8ssigns. from and against any and all costs, 10s8 or liability for injury to or death of persons or damage to or 10as of property arising out of the con8truc~ion. ro- ~ii ::~ construction. maintenance. repair, replacement, use and iL fi W ;;~~ -u-I ,. i"'.I' ;/::::.~~. . ~',~fi'i' '; ;~~ ',':,' ~_}~',l::~'~;J:~d: ;ii~~)~~:Hi?(~~~~~3*{P: ~;i}~J~ji,r;!.~~tr~{;t~i~~f~~~~~!:~;Wb:f;i;;~.;;~::~1.;~f2:<\ik;Hi~Z;;C:S:. ,~".,i/,;j;!~;:' Xi,),!;'!'!,!":,,,.. ;..';);71)J~;pt,;if,.:~';'\':: ~:.:!.: ~f' .' "~;:: :::. ';-~ I it ..: II @~,,;.:. ~-., 'k' .~. operation of the s.wer pipeline (Parcel B). the sewer pipe- i:j<' line (Parcel C), the watfr pipelinef'~~electric transmission :\l,!'. ,...~, line and other utilities (Parcel D) ,::;',8ccesB road (Parcel E), fIi or out of any act or omission of thol..~ity, its agents, em- J. r'"'''' ployees, contractors, while on or ab~ut Parcels B, C, D O~ .~r,' E or ~xercising the permissions here~n granted. 'f. DATED this ,;1I!t.bay of ~.-'~.'}e.."'p . 1967. I'.(~~, I W RAYONIE 0 ,. By ( .~t :~~1 r ":~, \ ;.'. " .~ " "/(,, ~~:,~ (. \ :~~\~: .~.::,: .~;~{;{ .~.. .t...,J ~.':>.., ~.2f;s'" ':?\': '.rt:::;;, "" . ;W~( ,d'.y'i ;y~: r;~r~.!,~, V~W~\ :":i?~~~ \r~~'1:~'. ..q~'i: .,J"~""'{- ij:".k': ~~~ffi ;t:'~'?.@ ~~~l i'Jr~r1.I?, "J"f;'l~"';. ~.li;1..t::'~~_ ;(!Jt"';."l''iig~~;t~ ..~.:}.t:i: ',<J,i:.'t.f~"i'f"r' t}li~ ~.;? kl~;'l ~~':_:~1}:'::'l~~'~\iI;'< .;i.~ ;tr:,:;.r."1''\'~.~'J~,J;'\~\ "'''', ;1';;: _~"'-, t,."j" ;';),W"tlJf;-:lJ,:;,..?fI':':'_;:' ~r:;;*~iii..'-~t);~r'~f;' :r.~ 1~~Jf_j'},"',~~;;A~\\ \J*'r_~);'~ '~\'''I;j~:" "~~~;l.-"'';-}I~;,'~''h.1~ . I ~ 'q"',;~';' .'L ~~'$t;. '!,:{J:I.'; l~y,~\'&.:~;t~:?r~\?~ ~"" .J"t'l~..."":\':'ti:. .. '. ~_,:..~~..?~_i""'*' . t-'" ,\,;:-,,"', '.::(:.) 'l~ ~'f:\\:.t:;W';-'!>i\.\':'I'r..,/.: ,,,.,~:.l,o::,-('(:':'~~1.!f.t\ .'.l't.:, ".';<'.~'f --"~. ,i.if ';1.';:~?2J.\~'~~-;?.{tt(.' ';'\';.':.~'~"'l,""-;::~'i~'1~\~ ,~;~-:~gg1.~~;~ i::I~~1 i .~t'~1-: ~,'i:~.::'s':''!r\ r.~, "~~.~v:i."" '~'''''!J.. J~#'W[~M~~~~}~{rl:.:' f..:i1tt:tt-/-I:')Co".:t..,)/,. ,'jl~'/,;'';';"\~':lv~.~{!\r~i'~ 'r ;:).~rl"""N:h}>;-;1i\1,..J:'ir ;:;i}!!~:u.}~&t'l,~:~n~." :1;!~~~t~1;~{~!k~t~ ,~. ! --I '1~(1f::~:r: ~ r-'" ....!C, , '~1,..,.,t?~~'(#f\'/{~ ;l"~~r .or' -'.'\'>ll." .t'~\'~"~' W~]~~~~ ';;,;,1.'.'.:;)1," ':j::"i"l,...~l.'., ':~~\,. "l~:,'N~,.,t~, ,~t~}~t ,~. ylj~-":d~- '~\~~'\':~ir:~ ~;~ ~~~l~J~;~~; g~i.~..\:~.\o-' IL""",,,,,,,,,,, ;,""''''' \i'l~ll.~~:'f;"l~:t"~;~pl""'~"~-';"'~':'<:' ~"';"(IJ,f.~~';'':;''; ~i~~;1~~~L;Z~F1;\~:E:~;l<;, ~t~)}~~~;S~f~~. ..... o U .. A .. '. 00", ~ ~. .. . 00' ..., 4Jtl o s: ,...: u ... .... it ~ ~ r ~ g , .. u. . . .... o . u g" .. . u ! o ~ . .. By .'l~ ~:'!~, :<'-:f~'-- .~ f.~J ~'l ;~ o ffi On this ~'/ it day of ~' ,t;p;. 1967. '.>afore mo, the urdersigned, a Notary Public in and for the state of Now York, duly corranis8.\oned and sworn, personally appe;J~ed _}., . . / I " /,j c" / ," I (/1 .;'-. ".-.;,"1, (<J.).... el'd, ~ .J'" -./1. ..../. " ~"::'-I to me known to bo the f J:"" I .." .R~' .... J' a.nd -~ ._;/." }. r;;-l'l . respectively, of RAYO:UER INCCRP':;R;\TED, the corporatioh that cxecuted the foregoing instru.jt(tnt, end acknowledged the said instrument to be the fr~e and volun- tary act aoo deed of 8a1d corporation, for t1le uses 1\00 purposes therein mentioned, ano oncoath stated ~hat they were authorized to execute the Baid instru.rent and that the seal affi~ed is the corporato senl of said cQrporation. STATE OF NEW YORK I SS COUNTY OF NE'. YORK WITNESS my hand aoo official seal hereto l!Iffi~edthe day and year in this certificate above written. ., ')11 ({ '/~i;- '-/.. ;,'L /:J '" , " Notary Public in and for the S~~~e of New y~~~, rcsiding at )U-, l,. l:"/t '\;; )//J ~ , ><; MARY E, O'BRIEN IftUl"J P'IIblle. Sut..1 thw YO't N4,31.117,ns QlMll1nt4 h MI" Ytl'~ COI.nh Ctlllll,..1..i:llplmMln;h:'0, I", r 1"........- "77..-...1, NMP':_.r a -12- ~~ ~\~. '~::. /~~.~~(:li!~1 ~:~~':" . X~-{~~ '1:n(:-:;i~~'$.l, ~.;,.t:~~ :!,[,:~_.t:.~..~~~:h~~::;~;:;I.){t~-tt~'.iJ~j~';~--~~' ?:\\'l'.~:ll~ }~I,~~,J:f~:iJ .(' ~'\~;~J;){"+-Y~~~:f~fr:;!~:li2.\~~W1.r:~f~W:t:Y0~~f~i\~1 ~~. .,: '_; ..~~. "~". ~: ~':.L_',~S:~~. ~.:; r'2:;~'"::: ,1\Lt:.~~,:!~>~,~~~~.;1'~!'1~~~~: :;\:ry~~:;~I~Y~l: . .' .;;ib: :1'.. 1'",'1 '), -> ;-t:' ~ill/ ~'1r ~~" "{'i>, ~~;; :~~ <,: .4:{f- ~t:: ,''<: .,1<'':;''_" ',~!~f:-- ',~,",'t@,'; :~, ;"'-'.' ~ighr of~a!J r::C%.~,ment of Pressure. Interceptor ."".~: Sanifar!:J,~ewer S~:t.em S~e Original in Blocks 165 $ 166 \?~~:~; Frank Chambers'subd.. Deed Frle:~; . ,:11\ --~~;;r . '"1''' _':."J:-',::',l :~~ 'I~;,:::.k.' v ":;-<- t.';; ~rs~ - .\;;21,. ;~(~',:: ~,. _(':~Jt>: :~;;.. 1~~;:- - ::'~;t I ~} ",". ,.~,>; "'-, for Construction Lines For .....').... .. . 'l I,..",; ;.;'j . _H ---PIi!4TJK.TII,f"':lUm to the City, its Rayonie.: conveys '~;1~, . ~.2_, , .j;;;,i'fIj'!t:.> . ass'i"gns, the :pljrpe' tual non-exclusive rJ.ght successors and -''':~~ re-:c'o'.nstruct, maintain, repair, ana casement to construct, a_A operate a sewer pipeline, together with replace, use IN '.:'y' manholes and' other appurtenances thereto, all connections, over, across and through the ,tollOWing-describod real loc,ted in Clallam County, Washington: ft _'14..t Y ^ .trip of land of varying width over and Dcross Block 165, Frank Chambers Subdivision of Suburban Lots 37 and part of 38, of the ~rt Angeles Towns~te, as per plat recorded -in volume 1 of Plats at page 24; Suburban Blocks 1 ann l~ (sometimes' called Suburban Lots 1 and l~) of the Townsite of Port ' Angelos; and <'': ,-';'~4.-"";'- .. Division "B" (sometimes known as. Blc:::k "B") and Block "c", Port Angeles Tide- lands, as shown on the official plat thereof on file in the office of the Commissioner of Public Lands of the State of Washington; the centerline and width of said strip of land being more particu- larly described as follows: Beginning at a point on the line between Lots. 6 and 7, Block 165 of said Frank Cham- bers Subdivision, which point is north 31. 15' east 230.00 feet from the intersection of the projected lot line of said lots and the center- line of vacated Columbia Street; thence along the c~nterline of an easement 30 feet in width, north 12.39'20" west 170.24 feet; thence north 8019119" cast 430.13 feet; thence north 57040.5511 west 274.05 feeti thence north 2001157 II west 245.60 feet; thence along the centerline of an easement 20 feet in width, north 28014'37" east 319.26 feet; thence north 13.14'37" east to its intersection with the Inner Harbor Line1 which point is the end of this centerline de- scription, e.:cept the right-of......ay of the Chicago, Milwaukee, St. Paul & Pacific Railroad. The above-described real property iR hereafter referred to as "Parcel B II. ;!:%f}f;.::il~~!~i.~~~~'i:W~;t$J.~F~/':;!j:;,::'0:~d,~':;~':ji:;:f;{,;;!~~:r;ii':,;~>'{;\i'",,~:;,!;/;i;;;i.Tj:.:i";;'J';''":';1.;';:fi~:;;,i.r}F:\ :;:Yi~;?;:,' ;/Pi~;"i.'E.1:;:,;\'~ii~::" ')/;\";;U~,~\:;;j?j~,'(;~':;;:i;ii:;:!,~';i~"j'. :','V:>'i".:t;:"')'j',;',: ,i';~;~i~,:';I,,::;~~,: "i'~ ~;-:;;,-:;'f.:-;'~;;, ,-,'''.'''.}h:q-'H'!."\"r,;:"i;,.,);,vl.'''''!I'';\~1f2~k,(;'t)ii,;,;,,,,;>'i""';iJ'I""N:"")iJl;:",.ir\"'''~''';[':'i\i!''';-:<,i;'i';'":';".'i:,~<~:..;,:../L':.<t";''''i'i:''J?'' t';\";;';-''ffl,,ill~' (~f"~rr!JIiJ!,:~~..,,!:,tt14" ~~~~7iff1%~:i~rJ~![~~j~~~I#1;~~~l~jJ~~;~t.J~b,f\~l~~:~I;i~~if~?m~~lji~;Hfg~i~;1.~~~{f~li!~~~ ~~~f~r~~Jl~f1~~ .~~~lg~~ir11f~1!f1~f/0.4~;~~~l~;Viit~I'iJ},\??~;1;t~r\;Kji~,~fiil~f:r:r;ft:J';~i!il'i~tiM1iNt !jIj~~j}il*:1~:itrk~~~[~H:<ir~~ll;~~1i~i~:~R:.;~Q. !~!tlX~;~~~$~f.~i~f:E . . .' j"_; ....,." "'~ j ...". ...--....1' "... "'; ,..:'0 .... : . ._,_ . ".,' ,'<,'I '. ~ '1. .', '.... ',. :;, ~.... ',' ',", - T' '". ." " .' _','''. "': I ..'" ~..,'- .,., ,.... .. -' .J'<< -. .,' .,", ,. " ':. ,. ,', .r ", ;-~;' '\;,'':}'::\'~~~'''~'' :', l~ff ., . C. . . ~" 1:<';: . Rayonier conveys 'and quitc~~:ims to the City, its <1~:€~:: and assigns, the perpetual:non-exclusive right . successors and easement to construct, reconstruct,. maintain, repair, 1:;<jPi' replace, use and operate a sewer pipeline, together with -.--:)' L-.-- al~~_~tions, n:.a~~~l~",:~,~o~her ap:ur~~~...:~.:ret~,_.__ ---- . .. r ovor, across and through the following-.:lescr wed real property located in Clallam County, )'I'ashington: -,-C"~ A strip of land 35 feet in width over and across Blocks 8 and 9 oftTaelands e~...~ 0:1: Laurel Street; Blocks 14 and 15 of Norma~ R. Smith's Subdivision: Blocks 2 and 3 of Puqet Sound Cooperative colony Subdivision; and vacated Race, Chambers and Jones Streets, all in the Townsite of Port Angeles, Washing- ton, the centerlin9 of said strip of land being more particularly described as follows: ':"'~'" ":~l~~:,; Beginning at a point on the centerline of Francis Street, Townsite of Port Angeles, Washington, which point is 17~ feet northerly of the northerly right-of-way; line of the Chicago, Milwaukee, St. Paul -& Pacific Rail- way; thence easterly along a line drawn .~. _Pll~<tl.l_e,1._ t.o the",0J;tr"rsr1y. :r :j,gp.t-:9f-way line . (lfthe 'Chicago, Milwaukee, st:" Paul & Pacific Railw~y and l7~ feet northerly of said right- of -way line, meas~~ed perpendicularly to said right-of-way line, to a point where the north- erly right-of-way line of the Chicago, Milwaukee St. Paul & Pacific Railway intersects the north- erly boundary of Lot 9, Blockl5, Norman R. Smith's Subdivision, which point is the end of this centerline description. The above-described real property is hereafter referred to as 'Parcel C". VOL. 30~ Pg.70 I. t . I I f r .: i I ! ; I , I FAX TRANSMITTAL CITY OF PORT ANGELES ENGINEERING DIVISION 321 E 5th St PORT ANGELES, W A 98362 (360) 457-0411 COMPANY NAME: K~o';'lelr ,Tv-c- FAX: J 'l'T<-t::.. A-nd~V'so h 457:- zCl 37 't" -A w A- CONTACT NAME: CITY /STATE: SENT BY: IVeYl.c&t.... ~L?\I1STbh DESCRIPTION: , , ~TV'eeT Up.,.c:......TlOY\ --peTITIO., :l be. ....d... "l: P..A, - ( a..Y\a eCV~eK Qonstv"c..-U a..",cL I v\{. I v b ,e... 'S l-....ee..-{. o\.le\r a. tl u 0" ~e -Q (lolUl' - - .r h A-tJ-E.V'e..sC'",..c.-he<l-+he... \.'^~ i", %'1.5 d.Oc.u..,..,e~ a..Y\.cl ~+ ;cJes Ue cc wha.{ we I'\ee<l -Cr VV\Al"'-\Q.IAA.."-c...e.... SlO V" e o.-V'e. y\p{. i'" Y\.ee..d.. 0+ a... \ o...~~ "'Me,.I {' 0 .... <!... 'ST/ l..-l.- 1.....{e.V"eS.-\..e4... \ '" --1-hQ. 0Ae...i\-T'IOVl Dr .~e.. o....\.\'Q.,:\ '\. v..:>OUL!> -e>e- A 'S~+<-TE \ss.uE,..:x:h c.EN~IN~ T~ ~~\....\c..A::\lbY"\ NUMBER OF PAGES (INCLUDING COVER SHEET): !15~~ - RETURN FAX NO.: (360)417-4709 . IF THERE ARE ANY PROBLEMS WITH TRANSMISSIO CALL: (360) 417-4807 .. -..-.---.. '. ?1: " "- ~ ".. ;it.'.-) ;~f~ ".... ~:~ tt~:~: ~7' .', ;~< . ,.... I i? I "'~'- I ........ I :... .1 "..-' ,. I II I ,~';: ~ORTANGEL,ES WAS H I N G TON, U. S. A. PUBLIC WORKS DEPARTMENT DATE: June 16, 1999 To: Real Estate Committee FROM: Gary Kenworthy P.E., City Engineer SUBJEcr: Ennis Street Right of Way Acquisition/Trade & Vacate Alley, North of Water Street Last winters heavy rains resulted in a slide which damaged Ennis Street access to Rayonier between Columbia and Water Streets. The slide initially required total closure of Ennis Street. Temporary repairs were made to allow one way use of the street. Permanent repair will require installation of a retaining structure to support the roadway. In preparation of FEMA documents to fund the repairs it was required to show that the City owned or had easements for the street. This presented a problem since the Ennis Street right of way north of Caroline was not complete and portions were established through prescriptive use of the roadway. This was the case in the area of slide and we had to acquire a temporary construction easement from Rayonier for the pending retaining structure construction. In review of the Ennis right of way the enclosed sketch was prepared to show City and Rayonier ownerships in the area. The proposed acquisitions/trade were discussed with Rayonier and received favorably. In review, Rayonier stated that they would like to vacate Jones and the alley north of Water Street as part of the trades. This was reviewed by the Planning Director and he supported the alley vacation which bisects the developable land owned by Rayonier north of Water Street but did not support vacation of Jones Street which is mostly bluff slope property. The proposed acquisition/trade will benefit the City and Rayonier at no direct cost to either party. The City will benefit by have sufficient right of way along Ennis to maintain the slopes beyond the edge of paving. This will eliminate the need to acquire temporary easements in the future for street repairs involving the work in that area. Rayonier will benefit by vacation ofthe alley bisecting their property. Staff recommends proceeding with the acquisition/trade and vacation as proposed without vacation of Jones Street. The City was recently informed that the Federal Government has declined the Governor's request for FEMA assistance. Repairs of this slide are needed and we are continuing with preparation of plans and cost estimates to assist in development of the funding needed for construction. LOC: N:\PROJECTS\99-05\CORRESP\ENNISRW. WPD FILE: 99-05.06 I. ~\ ~ , f .. . --- ~vlfC .r ~ 8~ , "....- ,-It , UI :^ t' G C' 1<J ~0eG8~ :;j ~ r f'l "I rJ!~S>l' ~ rJ .r o c 0 o (I (I "'- .... 1>- :::t)5:::OlllZ 0~~~~ :!i~~Q~ -z O_fTlC) ~ZAl o - ::e--oZ ~();:oO -<~on ....f'Tl""O> O.....Ulrr1-l Al'" O"U~tI) C::u. () Via c ~""O ::0 60 :::0 z~ ,..., . 0 :s ~ l!L[Nr: J'\. ...--- -I fe> ~,@G ~ r -" ( j ) / I - ~ -- '" 1-J ? -<. o T- nt f u' r -': ':. ,', '::- ---- I Ii / } / II , ~ " , ' , ' :/ " :.' :1, ,,' ; I r ' l' '-.- , " " , '/ " .' , ",/ '-~',/,::' '. '-'. "" , " , ' , ' " " " .' .- , ) / ,..ON" eN,lIef'" , " j, n',;, '.. , ,/ \ , \ ",,,p~,,,, '\ \ ) ~ CJ~ ;i;f,o~'!.ELES CALL 48 HOURS ",~., ~ ...........-T ....._..... EFORE YOU O/fJ -. ~'"::.. - f-8DD-I24e8666 RIGHT OF WAY CONSIDERATION. ENNIS SrREET ~ .. ....-- (t........ ~tf . . ,... FISH.. . WILDLlFB DATE OF ISSUE: Seotember 8.1999 HYDRAULIC PROJECT APPROVAL RCW 75.20.100 or RCW 75.20.108 RECEIVED fit'.. ''1 ,~g9 State olWashIncton Dcpa.rtnu:nt orFiah and WUdUfe Re&fon 6 omce 48 Devonshire Road Montaano. Waahlncton 98S63-9618 LOG NUMBER: OO-C9882-02 At the request of Jack Anderson, in plans received on August 30, 1999, this Hydraulic Project Approval (HPA), which now supersedes all previous HPAs for this project, is a change ofihe original HPA issued May 13, 1999. PERMITfEE AUTHORIZED AGENT OR CONTRACTOR Rayonier, Inc. ATrENTION: Jack Anderson 700 Norih Ennis Pon Angeles, Washington 98362 (360) 457-2329 Fax: (360) 457-2437 Not Applicable PROJECT DESCRlPTION: Construct New Rock Bulkhead, Maintain Existing Rock Bulkhead PROJECT LOCATION: Same as address of Permittee. !! WRIA WATER BODY 18.MAR1 Port Angeles Harbor TRIBUTARY TO 1/4 SEC. SEe. TOWNSHIP RANGE COUNTY 12 . 30 North 06 West Clallarn Strait of Juan de Fuca PROVISIONS I. TIMING LIMITATIONS: The project may begin Immediately and shall be completed by March 14, 2001. a. Work below the ordinary high water line shall not occur from March 15 through June 14 of any year for the protection of migrating juvenile salmonids. 2. NOTIFICATION REQUIREMENT: The permittee or contractor shall notify WDFW Enforcement Sergeant Baker, (360) 452-8781, at least three working days prior to the start of construction or any subsequent maintenance activities. Notification shall include the permittee's name, project location, starting date for work, and the control number for this Hydraulic Project Approval. 3. Work shall be accomplished per plans and specifications entitled, Proposed Emergency Shoreline Stabilization Log Pond Erosion Control Cross Sections, dated August 5, 1999, and submitted to the Washington Department of Fish and Wildlife, except as modified by this Hydraulic Project Approval. These plans reflect design criteria per Chapter 220- I 10 WAC. These plans reflect mitigation procedures to significantly reduce or eliminate impacts to fish resources. A copy of these plans shall be available on site during construction. 4. All manmade debris on the beach, including the concrete structures identified in the plans, and any stray concrete, metal, stray angular rock, asphalt, and other unnatural materials, shall be removed to the extent practicable and disposed of upland such that it does not enter waters of ihe state. 5. The existing rock bulkhead protecting the Ennis Creek bridge abutment shall be reconstructed no further waterward than the face of the existing functioning bulkhead. Page 10fS (:'" --I ;( ~~'~" "~' b 17 ~~';,'" Y CLCVrnl\...f-li... fJt:HPIIII AI'Fl/CA IIUN r>,lftllfc ._~...~-= I'.""il' fhl.- '# /1/':>'0 1)'''''rr'''''"J...___..___.__. 1:"'.1\,".<l.____.._------=., ., h(! FlnC1ljC~I! Pl~rrnil ^pplir:nl;Ol) nl!1.~~E.~.~iJ.!S~.OIJI comolC1m: Ple;;tSr> f}'PI? or fp.fJrinl In ink, It you h:we anr qtlf"~SIIOrl~. pl~ase call (360. 417-4735 Fa)' rlIJmhF'r: (360) ,117~711 . .- O"n", I." Eloe. Coni lOCI", A.yonl:,--AJi{;ELEu.;LECTIU.L-ltlC..__, rhone:4 'i 7 _ Q).6L- Fa"A <;) _ q) h 'i rrop~rtfOvmer: R8~[) fer.... . ~i)(..-=--'-__ __ Phon!'!: AtJd,esc,: 700 Eny,;" 5'/ .__C;IYS~~, HY):fieie'S- Zip: C;'f,5G;2 >NGEL~S ~J J'C'l'!'IC INC' l\NC,J'.r"F.l ORS EleClricClICOnltaClnr: 1\ :, 1', J.....~. ",~-.__.!....~___l.iu)n[,(!ti: Exp:__Phone; d.t;7_q7~~ ","d'e's 524 EAST FIllST Clly: l'O.lF ANGELES, WA ZJp:....2.ll.JJi2 REQUEST INSPECTION [I INS1ALLATION WIRED BY: 1..1 OWNER xM'1.r:CTRICAI. CONTRACTOn Credit Card Holder Name:_---.J:.e..d-Sirnpsnn Billing Address:_ City: Zip: Credit Card Number:__ PROJECTADDAESS'_'~ Exp. Da/e: VISA:_MC:_ sr; ;ta>CTJeiC TYPE OF WORK: Check alii hal apply: [] New (:if Allerationi Addition o Residenlal 0 Multi-family o CommerCial . U Mobile Home Sq. Ft. Number or Circuits add@d or altered: o Remote Meier 0 Detached garage n Hol Tub n Swim Pool 0 Seplic Pump 0 Low Vollage o Telecom. 0 Sign We)o{" ;]-1-",. SE:/!/Ic..e e.q,U;DlY\h'-(" !J / DESCRIPTION OF THE ELECTRICAL PROJECT: 1 j Elecirical Heat Load Additions ~ U; &. Service In/ormallon o Baseboard ::J Furnace .J Heal Pump :J Fan.Wall _KW _KW _..KW _KW ~ Overhead Service CI Temp Service ~Underground Service Vollag.: i2i'D v' Phase: [11 \7 3 Service Size: ~co Feeder Size: l-/M c....~.....l :~AMC 14.05.060(8): F~,. induslriar, commercial, & residential projecls larger than a duplex, a one -line drawing of the Electrical Service & =eeders. building size (sq. ft.), load calc'Jrations, and the lype & of conduclors and/or raceway;s required and shall accompany the ::rectrical Permit applicalion, ();Cu-- . hereby certify that I have read and examined /his application and know that same to be true and correct,' and I am lulhor/zed to apply for this permit, I understand it is not Ihe City's legal responsibility to determine what permits ' ;re required; it remains the applicants responsibility to dele/mine what permits are required and to obtain such. Ijifo3 Af - . Credit Card Holder's Signature: ~ ~ r ~),"r~u .~ Dale: Owner or EII'c. Con!. Signature:~, . Dale: Tt tLl- I -;, N () ~..q4 of -'It,(~cr U-h' t.~ <--- f M-- (j I:. A-s IS - ;~/;6ft'3 ((~"'jL ~ 1ro,~o S9c6 cSV 09Z ~NI ~Id~~313 S3138N~ NOd~ NdZZ'c Z0c-SL-01 1/l/;"'/{)2 Iv 'y ,~ / 'W'9019 L'd