BELUNES CONSULTING, INC.

Size: px

Start display at page:

Download "BELUNES CONSULTING, INC."

Jasmine Phillips
6 years ago
Views:

1 BELUNES CONSULTING, INC. Integrating environmental strategies with business solutions. October 3, 2012 Ms. Karen Keeley, Project Manager EPA Region Sixth Avenue, Suite 900 ECL-111 Seattle, WA Mr. Norm Read, RG Department of Environmental Quality Western Region Office 165 East Seventh Avenue, # 100 Eugene, OR RE: Electrical Vault Sample Data and Soil Management Plan (Revised) Dear Ms. Keeley and Mr. Read: Pacific Wood Preserving of Oregon (PWPO) recently disposed of stockpiled soil generated during the installation of an electrical vault at its facility in Sheridan, Oregon. This letter provides information on the disposal of the stockpiled soil, sampling of surface soil beneath the stockpiled soil, and next steps for managing soils remaining on site. Background In September 2011 PWPO installed a new electrical service at its facility in Sheridan, Oregon. Installation included an 8 foot by 13 foot by 5.5 foot excavation north of the Incisor and Staining Building for an underground vault that houses connections to the new electrical transformer (Figure A-1, Attachment A). Originally, excavated soil was placed in two stockpiles to the north and east of the excavation. To manage these soils, the two stockpiles were consolidated into a single stockpile located to the immediate north of the excavation. The stockpiled soil was placed directly on the ground and covered with 6 millimeter polyethylene plastic sheets held in place with lumber. The single stockpile was approximately 25 feet in length, 16 feet wide and 9 feet in height. The approximate location of the stockpile is shown on Figure A-1 (Attachment A). Samples of the stockpiled soil were collected on September 30, Analysis of the samples detected concentrations of arsenic and dioxins (expressed as TEQs) above Oregon Department of Environmental Quality (ODEQ) risk based concentrations (RBCs). The presence of these chemicals ise due to the wood preserving activities of the Taylor Lumber and Treating facility, not PWPO. In April 2012, the Environmental Protection Agency (EPA) and ODEQ approved a Final Soil Management Plan (SMP) (BCI 2012) for the stockpiled soil. The SMP included soil characterization Chinook Plaza, Suite 233, Scappoose, Oregon Belunes-Consulting.com

2 Ms. Karen Keeley Mr. Norm Read October 3, and hazardous waste determination protocols to aid PWPO s decision making process for disposal of the stockpiled soil. Stockpiled Soil Management The stockpiled soil was determined to be a non-hazardous waste containing dioxins and arsenic in concentrations greater than ODEQ RBCs. As a non-hazardous waste, the stockpiled soil could have been disposed of in a Subtitle D landfill. PWPO, however, elected to dispose of the stockpiled soil at Waste Management s Subtitle C facility in Arlington, Oregon. This facility, which is authorized to accept hazardous waste, was selected because it provides a greater degree of environmental protection than that of a Subtitle D landfill. Stockpiled soils were removed from the site and transported to the Waste Management facility on June 7 and 8, A manifest documenting disposal of the stockpiled soil is included in Appendix B. Additional Sampling The April 9, 2012 SMP for the stockpiled soil included a provision to sample the surface soils directly beneath the former large and small stockpiles. The soil samples from these locations were collected from approximately 6 inches to 8 inches below ground surface on June 8, Figure A-1 shows the approximate location of the samples. Samples were analyzed for dioxins and total arsenic by ALS Environmental (formerly Columbia Analysis Services). An equipment blank was also submitted to the laboratory for arsenic analysis. ALS Environmental reports that the samples were received in good condition and consistent with the accompanying chain of custody form. Because the samples had elevated levels of target compounds, dilution was required for analysis. The resulting data is of good quality and acceptable for use in this report. The results of the analysis are presented in Table 1 below. Attachment C presents the ALS Environmental laboratory data report. Table 1: Surface Soil Sample Data Sample Total Arsenic mg/kg Dioxin (TEQ) ng/kg LSP SSP EB nd na RBC LSP = Large Stockpile Composite Sample SSP = Small Stockpile Composite Sample EB = Equipment Blank RBC = Risk Based Concentration nd = Not Detected na = Not Analyzed ng/kg = nanograms per kilogram mg/kg = milligrams per kilogram No analytes were detected in the equipment blank indicating that acceptable decontamination procedures were used during the sampling event Chinook Plaza, Suite 233, Scappoose, Oregon Belunes-Consulting.com

3 Ms. Karen Keeley Mr. Norm Read October 3, Data Review The Risk Based Concentration (RBC) for the Soil Ingestion, Dermal Contact and Inhalation Pathway for an Occupational Worker was selected to screen the newly acquired surface soil data. The samples contain arsenic below or slightly above the RBC, and therefore, do not require additional management. Dioxin, however, was detected in one sample (LSP) in a concentration twice that of the RBC. The ODEQ intended the RBCs to be used as a tool to screen site data. Site data greater than the RBCs suggests that a chemical may be present at a concentration that could potentially present a risk to human health. Exceedance of a RBC, however, is not indicative of an actual risk. However, the data indicate the need to manage a soil in a manner than would mitigate any risk to workers at the PWPO facility. Soil Management The data indicate the need to manage the surface soil in a manner that would mitigate any potential risk to workers at the PWPO facility. As determined in the April 9, 2012 SMP, the stockpiled soils from the electrical vault excavation were not a hazardous waste (i.e., the soils were neither a listed or characteristic waste). This determination can also be applied to the surface soils under the former large and small stockpiles i.e., the same rationale that was used to profile the stockpiled soils as non-hazardous can be applied to profile the surface soils as non-hazardous. Therefore, the soils can be managed on site. To prevent potential worker exposure to dioxin containing surface soils in the vicinity of the electrical vault, PWPO will place 6 to 8 inches of clean crushed rock over the area north of the Incisor and Staining Building. See Figure A-1. To delineate the clean fill from the underlying dioxin containing soil, PWPO will first place geotextile fabric over the surface soils in this area. In the future, if excavations are conducted in this area, the geotextile fabric will alert the workers to potential presence of dioxin containing soils. This area around the electrical vault is approximately 60 feet by 65 feet in size and will require approximately 75 cubic yards of material to cover the area. The crushed rock layer will be graded and compacted to create a stable, interlocking work surface. Compacting the crushed rock will create a cap over the dioxin containing soil that will prevent exposure to the underlying soil or exposure to dust generated by activities conducted on the surface of the crushed rock cap. PWPO will limit future subsurface activities in this area to those activities critical to the operation of the facility and will first attempt to locate these activities in another part of the site. However, if site constraints require subsurface work in this area, the work will be guided by the analytical results contained in the April 9, 2012 SMP and this letter. To prevent possible exposure, subcontractors will be provided with the soil analytical data, be required to develop an appropriate Health and Safety Plan, and require excavation workers (subcontractors) to have 40 HAZWOPER training. Closing PWPO has disposed of the stockpiled soil from the electrical vault excavation consistent with the April 9, 2012 SMP. Analysis of the surface soil underlying the former stockpiles (large and small) was conducted consistent with the SMP, and the large stockpile sample contained dioxin (expressed as TEQs) in a concentration greater than ODOQ s RBC for dioxin. To mitigate potential risk from surface soils in the vicinity of the electrical vault, PWPO will place a cap of compacted crushed rock Chinook Plaza, Suite 233, Scappoose, Oregon Belunes-Consulting.com

4 Ms. Karen Keeley Mr. Norm Read October 3, over the area around the electrical vault. The crushed rock will prevent human exposure to the underlying dioxin containing soil which could pose a potential risk to human health. Future subsurface activities in this area will be limited to those critical to the operation of the PWPO facility. In addition, PWPO will add a new section to the Annual Environmental Report entitled Long-Term Protections to document this area, and other areas identified in the future, that could potentially pose a risk to human health. Please call if you have questions. Sincerely, Terrence E. Belunes President BCI cc: Roland Mueller Dan Winkle Tom Baker Attachments A: Figures B: Soil Profile and Manifests C: Laboratory Data Chinook Plaza, Suite 233, Scappoose, Oregon Belunes-Consulting.com

5 Attachment A: Figures Electrical Vault Sample Data and Soil Management Plan September 18, 2012 Pacific Wood Preserving of Oregon Sheridan, Oregon

Figure A-1 Additional Soil Sampling Locations Electrical Vault Sample Data and Soil Management Plan Pacific Wood Preserving of Oregon Legend Approximate location of stockpiled soil

6 Figure A-1 Additional Soil Sampling Locations Electrical Vault Sample Data and Soil Management Plan Pacific Wood Preserving of Oregon Legend Approximate location of stockpiled soil Approximate location of discrete samples Approximate area to be covered with clean soil Not To Scale Belunes Consulting, Inc Chinook Plaza, Suite 233 Scappoose, OR

7 Attachment B: Soil Manifests Electrical Vault Sample Data and Soil Management Plan September 18, 2012 Pacific Wood Preserving of Oregon Sheridan, Oregon

11 Attachment C: Laboratory Electrical Vault Sample Data and Soil Management Plan September 18, 2012 Pacific Wood Preserving of Oregon Sheridan, Oregon

Rock Fill Layer Management and Maintenance Plan Former BNSF Site 13 Highway 99 Eugene, Oregon

Rock Fill Layer Management and Maintenance Plan 13 Highway 99 Prepared for: Half Moon LLC P.O. Box 25112 97402 PBS Project No. 51833.000 Rock Fill Layer Management and Maintenance Plan TABLE OF CONTENTS