Phase I Environmental Site Assessment

Transcription

1 Phase I Environmental Site Assessment Wallowa Forest Products Lower Diamond Lane Wallowa, Oregon for Oregon Department of Environmental Quality May 17, SW Sequoia Parkway, Suite 140 Portland, Oregon

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3 Table of Contents ACRONYMS AND ABBREVIATIONS... I EXECUTIVE SUMMARY... ES-I 1.0 INTRODUCTION Phase I Scope of Services Special Considerations Qualifications of Environmental Professional PROPERTY DESCRIPTION Involved Parties Location, Legal Description and Setting Site Reconnaissance Summary of Observations Findings Data Gaps Adjacent Property and Vicinity Observations Summary of Observations Findings Data Gaps Previous Reports Summary of Previous Reports Findings Data Gaps ENVIRONMENTAL RECORDS REVIEW Database Search Review of Regulatory Files Review of Area-wide Contamination Reports Findings Data Gaps PROPERTY HISTORY Historical Resources Historical Property Ownership and Use Summary Adjacent Properties Environmental Liens or Property Use Restrictions Information Provided by User/User Obligations Findings Data Gaps CONCLUSIONS LIMITATIONS REFERENCES May 17, 2011 Page i File No

4 LIST OF FIGURES Figure 1. Vicinity Map Figure 2. Site Features Figure 3. Blow-Up of On-Site Structures Figures 4A through 4C. Site Photographs March 2011 APPENDICES Appendix A. Environmental Data Resources (EDR) report Appendix B. Selected Historical Research Documents Appendix C. Report Limitations and Guidelines for Use Page ii

5 ACRONYMS AND ABBREVIATIONS AAI All Appropriate Inquiries AST aboveground storage tank ASTM ASTM International BAP Budget and Assumption Proposal bgs below ground surface CD Compact Disk CERCLA Comprehensive Environmental Response, Compensation and Liability Act DEQ Oregon Department of Environmental Quality ECSI Environmental Cleanup Site Information EDR Environmental Data Resources EPA U.S. Environmental Protection Agency ESA Environmental Site Assessment HSIS - Hazardous Substance Information Survey LBP Lead Based Paint LG licensed geologist MFA Maul Foster & Alongi NPDES National Pollutant Discharge System PCBs polychlorinated biphenyls PCP - Pentachlorophenol PCS Petroleum Contaminated Soil RG Registered Geologist May 17, 2011 Page i File No

6 RCRA Resources Conservation Recovery Act REC recognized environmental condition USGS United States Geological Survey UST underground storage tank Page ii

7 EXECUTIVE SUMMARY This report summarizes the results of our Phase I Environmental Site Assessment (ESA) of the Wallowa Forest Products property located at Lower Diamond Lane in Wallowa, Oregon. The subject property consists of a 77-acre site that was developed as a lumber mill. Based on the results of this Phase I ESA, we have identified the following recognized environmental conditions (RECs) for the subject property: Existing and former above ground storage tanks (ASTs) and other hazardous materials storage at various on-site locations present a REC to the subject property. Leaks and spills from ASTs and hazardous materials storage areas are common sources of contamination to soil and groundwater. The risk of impacts at the subject property is elevated based on observed staining on and around ASTs and chemical storage areas as observed during the site reconnaissance. The practice of wood waste landfilling on the subject property presents a potential REC to the subject property if landfilled materials included treated lumber products and/or improperly disposed hazardous materials. Decomposing landfill material may also generate methane. Possible past use of wood preservatives on-site present a potential REC to the subject property. While use of pentachlorophenol (PCP) and/or other wood preservatives have not been confirmed at the property, they may have been used at the site historically. Pad-mounted electrical transformers located at the site may present a REC to the subject property if these devices have leaked. Arsenic, lead and chromium, three metals that were historically commonly used in wood treatment chemicals, have been detected at concentrations greater than applicable screening levels in groundwater samples from the subject property. The source of these metals in site groundwater has not been determined and their presence represents a REC to the subject property. DEQ solid waste inspections in 2005 identified a landfill fire and unspecified prohibited materials in a site burn pile, along with additional unspecified violations. The unspecified violations and burning of prohibited materials could be indications of poor housekeeping practices at the subject property, which may increase the likelihood of spills and releases at the subject property that could impact site soil, groundwater, and/or surface water. In our opinion, there is a potential for soil, surface water, and/or groundwater contamination at the subject property from the above sources. Further evaluation of this potential for contamination would require explorations and sampling/ testing of soil and groundwater. This Executive Summary should be used only in the context of the full report for which it is intended May 17, 2011 Page ESA-1 File No

8 WALLOWA FOREST PRODUCTS Wallowa, Oregon 1.0 INTRODUCTION This report summarizes the results of our Phase I Environmental Site Assessment (ESA) of the Wallowa Forest Products property located at Lower Diamond Lane in Wallowa, Oregon. The subject property consists of a 77-acre site that was developed as a lumber mill. The property is referred to herein as the subject property. The subject property is shown relative to surrounding physical features in the Vicinity Map, Figure 1. The layout of the subject property and surrounding properties is shown in the Site Plan, Figure 2. Site features are shown in Figure 3. Our study was completed at the request of Oregon Department of Environmental Quality (DEQ). This project is being funded by DEQ s State Response Cooperative Agreement with the Environmental Protection Agency (EPA).The subject property is currently owned by D.R. Johnson. Wallowa County is interested in acquiring the subject property. This report has been prepared for the exclusive use of DEQ and Wallowa County. Because this environmental report is not intended for use by others, no one except the DEQ and Wallowa County should rely on this report without first conferring with GeoEngineers and the DEQ. 1.1 Phase I Scope of Services The purpose of this Phase I ESA is to identify recognized environmental conditions 1 (RECs) in connection with the subject property. Our scope of services is in general accordance with ASTM International (ASTM) Standard E for Phase I ESAs and the EPA s Federal Standard 40 Code of Federal Regulations (CFR) Part 312 Standards and Practices for All Appropriate Inquiries (AAI), which are intended to permit a user to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner or bona fide prospective purchaser limitations on liability under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).The standard outlines the practice that constitutes all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice as defined by 42 U.S.C Our services, described below, were completed in general accordance with our Budget and Assumptions Proposal (BAP) dated April 7, These services were completed by, and under the direction of, an environmental professional as described in 40 CFR Part 312. Our specific scope of services for this Phase I ESA was as follows: 1 Recognized environmental conditions are defined in ASTM E as the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. May 17, 2011 Page 1 File No

9 WALLOWA FOREST PRODUCTS Wallowa, Oregon 1. Reviewed readily available environmental reports and/or other relevant documents pertaining to environmental conditions at the subject property. 2. Reviewed the results of a federal, state, local and tribal environmental database search provided by an outside environmental data service for listings of properties with known or suspected environmental concerns on or near the subject property within the search distances specified by ASTM. Our database and file review search also included a review of EPA and DEQ websites for readily available information (publications and reports) concerning area-wide soil and groundwater contamination on or adjacent to the subject property. 3. Reviewed regulatory agency files regarding listed properties of potential environmental concern relative to the subject property. 4. Identified a key site manager with specific knowledge of past and present property use and requested that the key site manager meet a GeoEngineers representative on-site for an interview during the visual site reconnaissance. 5. We were prepared to interview current owners or occupants of neighboring properties as necessary to gather information or fill property use data gaps regarding the subject property. Due to the remote nature of the site, no adjacent neighbors were identified. 6. We were prepared to interview past owners and occupants of the subject property as necessary to gather information or fill property use data gaps regarding property use history. These interviews were not necessary. 7. Interviewed a representative of the local health department and DEQ to gather information and fill data gaps regarding the history of the subject property and surrounding properties relative to the likely presence of hazardous substances. 8. Reviewed historical aerial photographs and land use and tax assessor records, as available and appropriate, to identify past development history on and adjacent to the subject property relative to the possible use, generation, storage, release or disposal of hazardous substances. We attempted to identify uses of the subject property from the present back to the time that records show no apparent structures on the subject property, back to the time that the property was first used for residential, agricultural, commercial, industrial or governmental purposes, or back to 1940, whichever is earliest. 9. Reviewed the current United States Geological Survey (USGS) topographic map to identify the physiographic setting of the subject property and provide a statement on the local geologic, soil and groundwater conditions based on our general experience. 10. Conducted a visual reconnaissance of the subject property and adjacent properties to identify visible evidence of RECs. 11. Identified the source(s) of potable water for the subject property and former heating and sewage disposal system(s) used at the subject property. 12. Identified data gaps relative to the Phase I ESA study findings. 13. Prepared this report of the Phase I ESA results and identified RECs along with our opinion and recommendations regarding the potential for contamination by hazardous substances at the subject property and the significance of any data gaps identified. Page 2 May 17, 2011 GeoEngineers, Inc. File No

10 WALLOWA FOREST PRODUCTS Wallowa, Oregon 1.2 Special Considerations Our scope of services did not include an environmental compliance audit or an evaluation for the presence of lead-based paint (LBP), toxic mold, polychlorinated biphenyls (PCBs) in light ballasts, radon, lead in drinking water, asbestos-containing building materials, ureaformaldehyde insulation in on-site structures or debris or other potentially hazardous building materials. Soil, groundwater or surface water sampling was not part of our Phase I ESA services. Our scope of services did not include an assessment of vapor intrusion into structures on the property per ASTM Standard E Qualifications of Environmental Professional John Biggane is a Registered Geologist (RG) in Oregon (G2280) and has at least 20 years of experience completing Phase I ESAs. John is an Environmental Professional per 40 CFR Part 312. Joey Hickey is a Senior Environmental Scientist with over 15 years of experience completing Phase I ESAs. Joey is an Environmental Professional per 40 CFR Part 312. Jessica Robertson is a licensed geologist (LG) in Washington (#2570) and has more than 8 years of experience doing Phase I ESAs. Jessica is an Environmental Professional per 40 CFR Part PROPERTY DESCRIPTION 2.1 Involved Parties The subject property is currently owned by D.R. Johnson Lumber Company. Wallowa County are considering the purchasing the subject property. We understand that the DEQ is assisting Wallowa County in completing due diligence actions at the site, including the completion of this Phase I ESA. 2.2 Location, Legal Description and Setting General information, property use(s) and environmental setting of the subject property area are summarized in Table I below. The location is shown relative to surrounding physical features in Figure 1. The current layout of the subject property and surrounding property uses are shown in Figure 2, with subject property buildings identified in Figure 3. Photographs of the subject property are shown in Figures 4a through 4c. May 17, 2011 Page 3 File No

11 WALLOWA FOREST PRODUCTS Wallowa, Oregon TABLE I. SUBJECT PROPERTY INFORMATION Topographic Map Quarter/Quarter, Section, Township and Range Address General Location USGS, 7.5 minute Wallowa, Oregon topographic quadrangle map dated SE quarter of Section 5, Township 1 North, Range 42 East, Willamette Meridian Lower Diamond Prairie Lane, Wallowa, Wallowa County, Oregon The subject property is located west of the City of Wallowa in Wallowa County, at the western extent of Lower Diamond Prairie Lane. The subject property is surrounded by undeveloped land on all sides. Legal Description Not available Tax Parcel Number Wallowa County Tax Parcel Number 2201 Approximate Area Existing Use(s) Geologic Setting Nearest Surface Water Bodies Approximate Surface Elevation Soil and Geologic Conditions Depth to Groundwater Inferred Direction of Shallow Groundwater Flow Approximately acres Former lumber mill facility. Wallowa River floodplain Wallowa River approximately 1/8 mile to the northeast. Approximately 2,840 feet above mean sea level The majority of the site is underlain by interbedded layers of clay, sand, silt, and gravel deposited by the Wallowa River according to previous reports for the subject property. Wood waste fill material is located at some locations on the property. Depth to groundwater varies from approximately 2 to 28 feet below ground surface (bgs) based on previous reports for the subject property. To the northeast, based on surface topography and previous reports. Our knowledge of the general physiographic setting, geology and groundwater occurrence in the vicinity of the subject property is based on our review of the map listed above, previous reports regarding the subject properties and our general experience in the area. 2.3 Site Reconnaissance Summary of Observations A representative of GeoEngineers performed a visual reconnaissance of the subject property on March 30, The GeoEngineers representative was accompanied on-site by Dan Bishop and John Redfield of D.R. Johnson Lumber Products and Dan Crouse of the DEQ. Page 4 May 17, 2011 GeoEngineers, Inc. File No

12 WALLOWA FOREST PRODUCTS Wallowa, Oregon The subject property was accessed from Lower Diamond Lane. The subject property is currently developed as a lumber mill that is no longer operational. Table II below summarizes conditions observed during our site reconnaissance. Section contains additional details regarding RECs observed during our site reconnaissance. The approximate locations of the observed features discussed in this section are shown in Figure 2 and 3. Photographs of the subject property were taken to document observations made during our reconnaissance; selected photographs are presented in Figures 4a through 4c. TABLE II. SUMMARY OF SITE RECONNAISSANCE OBSERVATIONS Features Observed Comment Yes No Structures (existing) X Several now-vacant lumber mill buildings remain on the property, including an office, scale house, maintenance shop, boiler/fuel silo, building, covered storage, and miscellaneous associated outbuildings. The maintenance shop was reportedly built in 2005 and was used for servicing vehicles and equipment. The shop used diesel-fueled forklifts. The boiler/fuel house used wood to fuel steam boilers and heat the dry kiln area. The planer building included a chemical spray area on the west side. PCP was not reportedly used at the site, but if any wood preservatives were historically applied in this building, it appears that the preservatives would have been applied in the northwest corner of the building. A small amount of staining was observed in the northeast corner of a spray booth. A small maintenance area is located in the northeast corner of the planer building. Structures (evidence of former) X The primary mill building has been demolished. Visible evidence of the former mill building includes concrete foundations and demolition rubble The mill reportedly used kerosene heaters and included hydraulic equipment. Heating/Cooling System X Existing buildings were formerly heated by electricity and/or kerosene heaters. Floor Drains, Sumps or Drywells X None observed May 17, 2011 Page 5 File No

13 WALLOWA FOREST PRODUCTS Wallowa, Oregon Aboveground Storage Tanks (ASTs) X Multiple ASTs were observed in the general locations shown in Figure 3, identified as follows: AST Group 1 located in the south chip/log yard, containing the following: One 4,000-gallon diesel AST One 500-gallon kerosene AST One 275-gallong motor oil AST One fueling pump AST Group 2 located to the east of the Planer Building. Containing: One 2,000-gallon unleaded gasoline AST One 1,000-gallon diesel AST One 275-gallon motor oil AST One 275-gallon hydraulic oil AST One fueling pump Additional ASTs have been removed from the west side of the former mill. Concrete containment berms were located in this area, with visible staining of soil. Underground Storage Tanks (USTs) or Evidence of USTs X None observed. Drums or Other Containers X Three drums of used oil and hydraulic oil were observed in the maintenance building. The overall housekeeping of the drum storage area was good. Chemicals or Hazardous Materials (other than de minimis quantities of cleaning products) X None observed Evidence of Leaks, Spills or Releases Surrounding ASTs, USTs and/or Chemical Storage Areas Stained or Corroded Floors, Walls or Drains (other than apparent water stains or minor oil stains on pavement from parked vehicles) X X Stained soil was observed in the vicinity of the ASTs as well as the shop and former pit. The pit was identified as an area south of AST Area 2, where oil changes and other maintenance were performed. None observed Pipes of Unknown Origin or Use X None observed On-site Septic System X Septic drainfield is located to the north of the office building. Page 6 May 17, 2011 GeoEngineers, Inc. File No

14 WALLOWA FOREST PRODUCTS Wallowa, Oregon Sewage Disposal System X Septic drainfield is located to the north of the office building. Potable Water Supply X Water supply is provided at the property via two on-site wells. One well provides water to the office and shop buildings, the other well provides water to other mill improvements. Solid Waste Refuse Dumpsters X None observed Hydraulic Hoists X None observed Oil/Water Separators X None observed Discolored or Stained Soil or Vegetation Potentially from Hazardous Substances X Stained soil was observed in the vicinity of the on-site ASTs. Hazardous Waste Disposal Areas X Used oil disposal area is located in the shop building. Uncontained Debris, Refuse or Unidentified Waste Materials X A portion of the site has been filled by wood waste landfilling. Standing Water or Other Liquids X Standing water was noted throughout the site with petroleum-like sheens noted in puddles along the main roadways. Catch Basins and Stormwater X Stormwater runoff at the property is Drainage conveyed through open ditches and buried pipes to an unknown discharge location. It is assumed that stormwater eventually discharges to the Wallowa River and/or infiltrates into the soil. Pits/Ponds/Lagoons X One small pond located near the office and one 750,000-gallon concrete fire suppression pond is located at the west end of the property. Waste or Wastewater Discharges X None observed. Unusual Odors X Odor was observed near an approximate 100-cubic-yard stockpile of petroleum contaminated soil (PCS) excavated from the former pit near the ASTs. The PCS is stored on plastic sheeting. Stressed Vegetation X None observed. Fill Material X As noted above, a wood waste landfill and an approximate 100-cubic-yard stockpile of petroleum contaminated soil excavated from former AST Area 2 are located on-site. The excavated area was reportedly backfilled with pit run gravel. Water Wells (agricultural, domestic, monitoring) X Three groundwater monitoring wells (Figure 2) and two water supply wells are located on the subject property. May 17, 2011 Page 7 File No

15 WALLOWA FOREST PRODUCTS Wallowa, Oregon Pad-Mounted Transformers X Three pad-mounted electrical transformers are located on the property north of the former mill location. The transformers are owned by Pacific Power. Non-PCB stickers were not observed on the devices. Two additional pad-mounted transformers are located north of the boiler. No PCB stickers observed. During the site visit, one transformer appeared to have a small oil leak. Pole-Mounted Transformers X None observed. Other Conditions of Environmental Concern X None observed Findings The following RECs were identified by this portion of the study: Existing and former site ASTs and other hazardous materials storage at various locations on-site present a REC to the subject property. Leaks and spills from ASTs and hazardous materials storage areas are common sources of contamination to soil and groundwater. The risk of impacts at the subject property is elevated based on observed staining on and around ASTs and chemical storage areas observed during the site reconnaissance. The practice of wood waste landfilling on the subject property presents a potential REC to the subject property if landfilled materials included treated lumber products and/or improperly disposed hazardous materials. Decomposing landfill material may also generate methane. Possible past use of wood preservatives on-site present a REC to the subject property. While use of PCP and/or other wood preservatives has not been confirmed at the property, it may have been used at the site historically. Pad-mounted electrical transformers are located at the site and are a potential REC if these devices have leaked. A septic drainfield appears to be located at the site. The septic drainfield, while not in itself a REC to the subject property, could provide a potential pathway for petroleum products or other hazardous materials to enter the subsurface if these substances were improperly disposed at the facility. Surface drainage pathways are present at the site. Subject property surface drainage is not in itself a REC, but could provide an additional potential pathway for petroleum products or spills or leaks of other hazardous materials to enter the subject property subsurface and/or nearby surface water bodies Data Gaps Data gaps were not identified by this portion of the study. Page 8 May 17, 2011 GeoEngineers, Inc. File No

16 WALLOWA FOREST PRODUCTS Wallowa, Oregon 2.4 Adjacent Property and Vicinity Observations Summary of Observations We viewed properties located adjacent to and surrounding the subject property on March 10, 2011 from accessible public rights-of-way and the subject property. We did not enter adjacent properties. Table III below outlines adjacent land uses and pertinent observations. Figure 2 shows adjacent property uses and locations in relation to the subject property. TABLE III. ADJOINING STREETS AND ADJACENT PROPERTIES OBSERVATIONS Direction Adjoining Street Position Relative to Subject Property 1 Adjacent Property and Use North None Crossgradient Forest None South None Crossgradient Forest None Comments East None Downgradient Wallowa River and Lower Diamond Lane None West None Upgradient Forest None Note: 1 The inferred shallow groundwater flow direction in the vicinity of the subject property is toward the east, as described in Table 1 in Section Findings RECs were not identified by this portion of the study Data Gaps Data gaps were not identified by this portion of the study. 2.5 Previous Reports Summary of Previous Reports Prior reports for the subject property were provided by DEQ and are described in Section Findings RECs identified by this portion of the study are described in Section Data Gaps Data gaps were not identified by this portion of the study. May 17, 2011 Page 9 File No

17 WALLOWA FOREST PRODUCTS Wallowa, Oregon 3.0 ENVIRONMENTAL RECORDS REVIEW 3.1 Database Search GeoEngineers reviewed the results of a search of pertinent environmental regulatory lists and databases for current or previous facilities listed at addresses located within ASTM-specified distances from the subject property. The search was performed on March 29, The information reviewed was provided by a subcontracted regulatory list search service, Environmental Data Resources, Inc. (EDR). A compact disk (CD) of the EDR report is included in Appendix A. The report includes details regarding the listed facilities identified and maps showing the approximate locations of the listed facilities relative to the subject property. GeoEngineers reviewed the search results for listings pertaining to the subject property. Off-site facilities with the potential to impact the subject property were not identified. The subject property was listed in the EDR report. Table IV below summarizes information about the subject property as provided by the EDR report. TABLE IV. SUMMARY OF REGULATORY DATABASE SEARCH LISTINGS OF ENVIRONMENTAL CONCERN Location Listed Business Wallowa Forest Products Listed Address Lower Diamond Road Regulatory Database Environmental Cleanup Site Information (ECSI), National Pollutant Discharge System (NPDES), Solid Waste Facility/Landfill (SWF/LF), Resource Conservation Recovery Act Non Generator (RCRA- NonGen), Hazardous Substance Information Survey (HSIS), Federal Insecticide, Fungicide, & Rodenticide Act Tracking System (FTTS) Description Subject property According to the EDR report, this site was added to ECSI database for tracking as a potential contaminated site. The site is listed on a variety of regulatory databases for use of potential hazardous materials including petroleum and sulfuric acid. DEQ files for the subject property were reviewed as discussed in Section 3.2 below. Page 10 May 17, 2011 GeoEngineers, Inc. File No

18 WALLOWA FOREST PRODUCTS Wallowa, Oregon 3.2 Review of Regulatory Files DEQ files for the subject property were provided by on March 29 and 31, 2011 and were reviewed in March and April Historical aerial photographs and other pertinent historical information obtained from DEQ has been integrated into Section 4.0 of this report. DEQ files for the subject property included the reports and documents summarized below. Maul Foster & Alongi, Preliminary Assessment and July 2010 Groundwater Monitoring Report for Woodwaste Landfill, Wallowa Forest Products, Lower Diamond Lane, Wallowa, Oregon, prepared for Wallowa Forest Products, dated October 12, In July 2010, Maul Foster & Alongi (MFA) completed groundwater assessment activities at the subject property to determine if the site s permitted woodwaste landfill has impacted the beneficial uses of site groundwater. Assessment activities included installation of three monitoring wells using direct-push drilling to depths approximately 20 to 30 feet deep. The wells are located immediately upgradient of the closed woodwaste landfill and downgradient of the landfill near the access road. Following installation and development of the three wells, one round of groundwater sampling and analysis was completed. One water sample was also obtained from a site water production well (located near the office building). Groundwater was found to flow to the north-northeast beneath the subject property. Groundwater samples were analyzed for tannins and lignins, metals including chromium, copper, arsenic and lead, and additional common cations and anions. Concentrations of metals in wells downgradient of the landfill were lower than concentrations at the upgradient location. Therefore, MFA concluded that there is no evidence of landfill-related metals impacts in the groundwater samples, however, because three metals (arsenic, lead and chromium) were detected at concentrations above screening levels in the upgradient well, MFA also concluded that the landfill was not the primary source of these substances. DEQ files also contained solid waste inspection forms and a record for the subject property regarding an April 2006 violation of its Air Contamination Discharge Permit, in which emissions from the mill boiler stack exceeded opacity levels. The facility was fined $4,833, which was paid in January Available solid waste inspection forms were dated 1989 and According to the 1989 complaint form, a log deck was built on a swampy area and discolored (yellowish) odorous water was observed discharging from the log deck to the nearby Wallowa River, but follow up inspection by DEQ could not verify the complaint. DEQ observed that the creek around the plant was flowing clear water and did not observe any discharge of plantrelated water. In November 2005, DEQ staff visited the site for a solid waste compliance inspection. The 2005 inspection form notes that a landfill fire had occurred in 2004 and that it was extinguished using soil and compaction. At the time of the inspection, wood waste was still being added to the landfill and two large burn piles were on the property. Unspecified prohibited materials were observed in the burn pile and the plant owner was reminded to remove those items and obtain a permit before burning. The available 2005 inspection form also notes the numerous permit violations identified during the 4/08/05 inspection had not been addressed and are noted on the back of this inspection form, however, the back of the May 17, 2011 Page 11 File No

19 WALLOWA FOREST PRODUCTS Wallowa, Oregon form was not included in the available photocopy and the specific violations identified could not be identified for this study. 3.3 Review of Area-wide Contamination Reports We conducted a search of readily available DEQ and EPA reports and other documents that may pertain to area-wide soil or groundwater contamination within the greater subject property area. Reports regarding area-wide contamination were not identified. 3.4 Findings RECs identified by this portion of the study and not previously identified in this report include the following: Arsenic, lead and chromium, three metals that were historically used for wood treatment, were identified at concentrations greater than applicable screening levels in groundwater samples from the subject property. The source of these metals in site groundwater has not been determined and their presence represents a REC. DEQ solid waste inspections in 2005 reportedly identified a landfill fire and unspecified prohibited materials in a site burn pile, along with additional unspecified violations. The unspecified violations and potential burning of prohibited materials could be indications of poor housekeeping practices at the subject property, which may increase the likelihood of spills and releases at the subject property that could impact site soil, groundwater, and/or surface water. 3.5 Data Gaps Data gaps were not identified by this portion of the study. 4.0 PROPERTY HISTORY 4.1 Historical Resources Our understanding of the history of the subject property is based on a review of the information from the historical resources listed in Table V and interviews with the individuals listed. Selected historical research documents are included in Appendix B. Page 12 May 17, 2011 GeoEngineers, Inc. File No

20 WALLOWA FOREST PRODUCTS Wallowa, Oregon TABLE V. HISTORICAL RESOURCES REVIEWED Description Historical Aerial Photographs 1 Historical Fire Insurance Maps Tax Assessors Records Historical City Directories Historical Photographs Historical Topographic Maps Historical Local History Resources Fire Marshal Hazardous Materials Records Preliminary Title Report Interview Provider or Interviewee Dates of Coverage or Dates of Knowledge of the Property EDR 1959, 1976, 1981, 1988, 1994 and 2005 EDR search of Sanborn maps Wallowa County Assessor EDR search at public libraries Date Reviewed or Contacted 3/31/2011 No coverage 3/30/2011 Comment (See Section 4.2 for findings) Recent 4/27/2011 Wallowa County Assessor has only minimal information on file regarding the subject property. No coverage 4/1/2011 DEQ October 1999, June 2001, and November /31/2011 EDR search 1964 and /04/2011 Wallowa County Cheiftan archives provided by DEQ Fire Marshal Hazardous Substance Searchable Database 1970s to recent 3/31/2011 Recent 4/28/2011 n/a n/a n/a A preliminary title report was not provided for our review. John Redfield, Current owner, former facility manager 1999 to present 03/30/2011 We interviewed Mr. Redfield regarding his knowledge of past property use. May 17, 2011 Page 13 File No

21 WALLOWA FOREST PRODUCTS Wallowa, Oregon Description Interview Interview Interview Interview Interview Provider or Interviewee Dana, Wallowa County Clerk s Office Wallowa County Health Department Crystal Allen, Wallowa County Building Department Scott, Northeast Oregon Office of State Fire Marshal Tom Baird, Wallowa District Fire Chief Dates of Coverage or Dates of Knowledge of the Property Date Reviewed or Contacted Comment (See Section 4.2 for findings) Recent 4/27/2011 We contacted Wallowa County Clerk regarding the availability of recorded records for the subject property. The Wallowa County Clerk does not maintain a file for the subject property. Recent 04/27/2011 We contacted Wallowa County Health Department regarding the availability of records regarding septic systems, dumping incidents, or other potential hazardous materials at the subject property. According to the department, Wallowa County Health does not maintain files for these types of records to Recent 04/27/2011 We contacted Wallowa County Building Department regarding the availability of building plans and permits for the subject property. Wallowa County Building Department does not have any records for the subject property. Recent 04/28/2011 We contacted the State Fire Marshal office for information regarding hazardous materials at the subject property. The Fire Marshal s office representative stated that available information regarding the subject property is included in the online Right-to-Know database. Approximately 20 years 04/27/2011 We contacted Mr. Baird regarding the availability of records regarding fire incidents at the subject property. Mr. Baird stated that records are not kept, however, he recalled two likely electrical fire incidents at the property more than 15 years ago. Notes: 1 The scale of the photographs reviewed allowed for an interpretation of general property development/configuration, such as identifying most structures, roadways and clearings. However, the scale of the photographs did not allow for identification of specific property features, such as fuel pumps, wells or chemical storage areas on the subject property, if any. Page 14 May 17, 2011 GeoEngineers, Inc. File No

22 WALLOWA FOREST PRODUCTS Wallowa, Oregon 4.2 Historical Property Ownership and Use Summary The available historical sources indicate that the subject property was owned by Rogge from the mid-1970s until D.R. Johnson company purchased the property in Detailed ownership information prior to the mid-1970s was not included in the available historical resources. The subject property appears undeveloped (forest and grassy rangeland) in the aerial photograph dated 1958 and the topographic map dated The subject property mill is first visible as several buildings and possible lumber storage piles in the 1976 aerial photograph. According to local news articles published by the local newspaper (Wallowa County Chieftan) and provided by DEQ, the mill was originally built in 1974 and began operation as the Rogge Lumber Mill in While the resolution of the 1974 aerial photograph does not allow for detailed identification of facility features, the existing planer and recently-demolished mill buildings are visible in the 1974 aerial. The mill facility appears to have been enlarged by 1988 to the more recent configuration as shown in the 1988 through 2005 aerial photographs., The southernmost property lumber storage area is first visible as a cleared area in the 1994 photograph and as lumber storage in the 2005 aerial photograph. In 1995, the mill was sold to D.R. Johnson Lumber Products and continued operation under the name Wallowa Forest Products from that time until mill closure in approximately Minimal information is available regarding the maintenance and operations of the mill in the first decades of operation. Information regarding existing facility improvements is presented in Section 2.0. Most mill equipment was auctioned off in May 2010, followed by demolition of the mill building itself. Dismantling of the mill building was completed in July 2010; most former building materials were removed for the site for off-site recycling. Wallowa County Assessor records for the subject property are limited to information regarding the size of the property and the assessed value. Wallowa County Building, Emergency Services, and Health Departments do not have any records for the subject property. Wallowa Fire District Chief Tom Baird does not have any records regarding fire incidents at the subject property, but recalled that two fire incidents occurred at the property more than 15 years ago including a fire in the building and near an exterior auger; according to Mr. Baird, both were likely caused by electrical problems. State Fire Marshal records for the subject property include a list of hazardous materials at the subject property, as reported by Wallowa Forest Products during their operation at the site. These materials include petroleum products (diesel, gasoline, gear oil, hydraulic oil, lubricating oils, motor oil, and waste oil) as well as other chemicals including sulfuric acid, sodium bisulfate, ethylene glycol (antifreeze) and potassium hydroxide. According to property owner representative John Redfield, no USTs are known to have been used at the property. Mr. Redfield stated that ASTs in use at the property were originally installed on soil, with concrete containment structures added at a later date. Mr. Redfield stated that minor spills or leaks of petroleum products have likely occurred at the property., Petroleum-contaminated soil was excavated and placed in a stockpile; as noted in Section 2.3. Approximately 100 cubic yards of petroleum-contaminated soil was excavated from the May 17, 2011 Page 15 File No

23 WALLOWA FOREST PRODUCTS Wallowa, Oregon wood-floor pit. The excavated soil still remains stockpiled on-site. Additional information from Mr. Redfield regarding facility improvements is included in Section Adjacent Properties The subject property is surrounded by undeveloped land on all sides. Forest is located to the north, west, and south. The Wallowa River and Lower Diamond Road are located to the east and northeast. 4.4 Environmental Liens or Property Use Restrictions During the course of our research, we did not find that environmental liens had been filed against the subject property. 4.5 Information Provided by User/User Obligations Representatives of the DEQ have only limited historical knowledge of the site. As such, a user questionnaire was not completed. 4.6 Findings RECs were not identified by this portion of the study that were not identified previously in this report. 4.7 Data Gaps The data gaps were not identified during this portion of the study. 5.0 CONCLUSIONS GeoEngineers has performed a Phase I ESA in general conformance with the scope and limitations of ASTM Practice E of the Wallowa Forest Products property located at Lower Diamond Lane in Wallowa, Oregon. Any exceptions to, or deletions from, this practice are described in Section 1.2 of this report. Based on the results of this Phase I ESA, we have identified the following RECs for the subject property: Existing and former site ASTs and other hazardous materials storage at various locations on-site present a REC to the subject property. Leaks and spills from ASTs and hazardous materials storage areas are common sources of contamination to soil, surface water and groundwater. The risk of impacts at the subject property is elevated based on observed staining on and around ASTs and chemical storage areas observed during the site reconnaissance. The practice of wood waste landfilling on the subject property presents a potential REC to the subject property if landfilled materials included treated lumber products and/or improperly disposed hazardous materials. Decomposing landfill material may also generate methane. Possible past use of wood preservatives on-site present a REC to the subject property. While use of PCP and/or other wood preservatives has not been confirmed at the property, they may have been used at the site historically. Page 16 May 17, 2011 GeoEngineers, Inc. File No

24 WALLOWA FOREST PRODUCTS Wallowa, Oregon Pad-mounted electrical transformers are located at the site and are a potential REC if these devices have leaked. Arsenic, lead and chromium, three metals that were historically commonly used in wood treatment chemicals, were identified at concentrations greater than applicable screening levels in groundwater samples from the subject property. The source of these metals in site groundwater has not yet been determined and represent a potential REC. DEQ solid waste inspections in 2005 reportedly identified a landfill fire and unspecified prohibited materials in a site burn pile, along with additional unspecified violations. The unspecified violations and potential burning of prohibited materials could be indications of poor housekeeping practices at the subject property, which may increase the likelihood of spills and releases at the subject property that could impact site soil, groundwater, and/or surface water. In our opinion, there is a potential for soil, vapor intrusion, surface water, and/or groundwater contamination at the subject property from the above sources. Potential pathways for the above sources to enter site soil, groundwater, and/or surface water include releases from the ASTs and other hazardous material storage facilities, septic drainfield, stormwater drainage ditches, and poor housekeeping and/or historic site management practices. Further evaluation of this potential for contamination would require explorations and sampling and testing of soil and groundwater. 6.0 LIMITATIONS This Phase I ESA has been prepared for use by the DEQ and Wallowa County. GeoEngineers has performed this Phase I ESA of the Wallowa Forest Products property located at Lower Diamond Lane in Wallowa, Oregon in general accordance with the scope and limitations of our proposal dated April 7, 2011 and ASTM E , Standard Practice for Phase I ESAs and EPA s Federal Standard 40 CFR Part 312 Standards and Practices for AAI. Within the limitations of scope, schedule and budget, our services have been executed in accordance with the generally accepted environmental science practices for Phase I ESAs in this area at the time this report was prepared. No warranty or other conditions, express or implied, should be understood. Any electronic form, facsimile or hard copy of the original document ( , text, table, and/or figure), if provided, and any attachments are only a copy of the original document. The original document is stored by GeoEngineers, Inc. and will serve as the official document of record. Please refer to Appendix C titled Report Limitations and Guidelines for Use for additional information pertaining to use of this report. May 17, 2011 Page 17 File No

25 WALLOWA FOREST PRODUCTS Wallowa, Oregon 7.0 REFERENCES ASTM International (ASTM) Standard E for Phase I ESAs DEQ ECSI website for Wallowa Forest Products, accessed March Environmental Data Resources, Inc (EDR) EDR Radius Map report dated March 29, 2011 (comprehensive environmental database report, including Ecology and EPA databases). EDR aerial photographs dated 1959, 1976, 1981, 1988, 1994 and 2005 Maul Foster & Alongi, Preliminary Assessment and July 2010 Groundwater Monitoring Report for Woodwaste Landfill, Wallowa Forest Products, Lower Diamond Lane, Wallowa, Oregon, prepared for Wallowa Forest Products, dated October 12, Oregon Office of State Fire Marshal Community Right-to-Know (C2K) Hazardous Substance Information Search Menu, accessed April 28, Wallowa County Chieftan (local newspaper) archived articles and advertisements provided by DEQ, dated 1970s to recent United States Geological Survey (USGS) topographic maps for Wallowa, Oregon quadrangle provided by EDR, dated 1964 and U.S. Environmental Protection Agency (EPA) Federal Standard 40 CFR Part 312 Standards and Practices for All Appropriate Inquiries (AAI). Page 18 May 17, 2011 GeoEngineers, Inc. File No

26 82 SITE Wallowa Office: SPO Path: P:\2\ \00\GIS\ _VM_F1.mxd Map Revised: April 19, 2011 UMATILLA 84 UNION WALLOWA Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showing features discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The master file is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Sources: ESRI Data & Maps, Street Maps Projection: NAD 1983, UTM Zone 11 North. Vicinity Map W 5Th St 4, ,000 Feet Wallowa Forest Products Wallowa, Oregon Clancy Ln Figure 1

27 MW-1 Fire Suppression Water Tank MW-2 Office: SPO Path: P:\2\ \00\GIS\ _SiteFeatures_F2.mxd Map Revised: April 22, 2011 MW-1 Monitoring Well Location Property Boundary Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showing features discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The master file is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Sources: Aerial, Bing Maps Hybrid, from ESRI, ArcGIS Online/Bing Maps. Property boundary and monitoring well locations digitized from Maul Foster Alongi, Figure 2. Projection: NAD 1983, UTM Zone 11 North. MW Feet Site Features Wallowa Forest Products Wallowa, Oregon Figure 2

28 Kiln Dryer Scrap Metal (Boneyard) Wallowa River Former AST Planner Building ASTs Covered Storage Pond Office: SPO Path: P:\2\ \00\GIS\ _SiteStructures_F3.mxd Map Revised: April 22, 2011 Terraced Area Used to Dry Wood Building Removed Boiler Former AST Former Mill Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showing features discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The master file is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Sources: Aerial, Bing Maps Hybrid, from ESRI, ArcGIS Online/Bing Maps. Projection: NAD 1983, UTM Zone 11 North. Railcar Load out Office Maintainence Shop Feet Scales Blow-Up of On-Site Structures Wallowa Forest Products Wallowa, Oregon Figure 3

29 LOOKING SOUTHEAST ACROSS SUBJECT PROPERTY AT EXISTING MILL FACILITY BUILDINGS REPRESENTATIVE VIEW OF EXISTING AST AREA 1 Site Photographs March 2011 Wallowa Forest Products Wallowa, Oregon Figure 4A

30 REPRESENTATIVE VIEW OF AST AREA 2 VISIBLE STAINING WITHIN FORMER AST ENCLOSURE Site Photographs March 2011 Wallowa Forest Products Wallowa, Oregon Figure 4B

31 STOCKPILED PETROLEUM-CONTAMINATED SOIL CHEMICAL STORAGE AREA WITH SMALL STAINS VISIBLE ON FLOOR IN SHOP BUILDING Site Photographs March 2011 Wallowa Forest Products Wallowa, Oregon Figure 4C

32 APPENDIX A Environmental Data Resources (EDR) Report

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