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
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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
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Polaris Engineering Surveying, Inc.
206 South Lincoln Street, Suite 201
Port Angeles, Washington 98362
(360) 452 -5393 FAX. (360) 457 -9319
Contractor
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Job Site Description &v,,t ,z
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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
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DEED AND EAS3M1ltn'S
'J."'he Grantor, IlAYONIER INCCRPORATED, a Delzl:'wllre cor-
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poration (hereinafter "Rayonier"),~,for one dollar ($1.00)
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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,
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over, a~r038 and through the following-described real
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over, across and through the :.tollawinq-deecr ibed rea 1
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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".
",.
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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
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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.
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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
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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$:-:
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F. The conveyance by Rayonier of the e2l4ermJots
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described in Parcels D, C, D ana B 18 on the follrywlng
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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-
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Bonably interfere with tho USG70f soid property by the
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terms and conditiona,
City for the purposes herein granted.
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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-
:'...'....
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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
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a relocation of a facility~iocated on one of the four
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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.
~;
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(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-
"."
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claim deed sufficient-in form for recording,
relcal"inq all intercst "of
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former edsomont ar"a.i':
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Rayonier'e r!lite
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the City in and to the
to lequire relocation
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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.
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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
.
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because of the existence of tho pipeline, then the City
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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.
,~
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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
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the sewer plpelinea, the water pipeline or other utilities,
l
end the roadway shall fill all excavations 88 Boon DB prac-
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ticable after opening, remove all debri8~~and restore the
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surfaces of Parcels S, C, D and E a8 nea~ly 88 possible
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to the condition in which they existod atjthe time of con-
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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
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c, the water pipeline, electrical transmission line. and
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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-
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tion to exist on or about parcels B, C,~D and B by reason
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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
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necessary for the purpose ot placing excavated materials
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thereon prior to backfilling. or,for the tomporary move-
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mont of machinery and equipment.~rAny such portion of
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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~~;:"
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with re"pect to .aid parcel or parcels shall revert to and
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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~~~;'
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.,. '~'~""')'
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!;~'!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
~-~
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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
.":-,-
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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
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;/::::.~~. . ~',~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,.:~';'\'::
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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.
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RAYONIE 0
,.
By (
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By
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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
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~~ ~\~. '~::. /~~.~~(: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:
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~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\
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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.
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,
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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
..
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~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
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RIGHT OF WAY CONSIDERATION. ENNIS SrREET
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. . ,... 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
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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:
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