3815_PGSF WMVD Pkg 2_Vol 4-2_03.03.2026_BXWA_Certified

ASPECT CONSULTING PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 23 3 Previous Remedial Actions This section summarizes previous remedial actions, including environmental investigations and independent cleanups separate from this RI/FS, conducted at the Upland Area prior to the Agreed Order. The summary is based on reports provided by K-C supplemented by information summarized in the Phase 1 ESA for the property (AECOM, 2011) where the original documents were not available. This Phase 1 ESA can be viewed on Ecology’s website using the link provided in Section 1. The UST investigations described below are associated with Ecology UST ID 5351 and release ID 1624. For reference, Figure 2-2 depicts historical Site features, including labeling of the pulp and paper mill buildings, and locations of hazardous substance use/storage within the mill based on historical maps. 3.1 Independent Remedial Actions During Mill Operations This subsection summarizes the various independent investigations and cleanups conducted between 1989 and 2011, while the pulp and paper mill was operational. 3.1.1 Removal of Gasoline UST No. 69 (1989) UST No. 69, originally installed around 1966, was formerly located between Buildings 29 and 37 (Figure 2-2). This UST is part of Historical Recognized Environmental Condition (HREC) 1 as identified in the Phase 1 ESA (refer to Section 3.1.14). During removal of this 260-gallon leaded-gasoline UST in 1989, six soil samples and one groundwater sample were collected for chemical analysis. Ethylbenzene was detected in one soil sample and xylenes were detected in four soil samples, all at concentrations less than MTCA Method A soil cleanup levels for unrestricted use. Concentrations of benzene, toluene, ethylbenzene, and xylenes (BTEX) were not detected in the groundwater sample (Scott Paper, 1989). Scott Paper Company reported the findings to Ecology (AECOM, 2011). 3.1.2 Heavy Duty Shop Soil Removal (1991) In 1990, oily water from the Heavy Duty Shop sump was reportedly diverted to the hog fuel pile area north of the Shop. The Heavy Duty Shop Sump is identified as Recognized Environmental Condition (REC) 3 in the Phase 1 ESA. A test pit excavated to a 6-foot depth in the release area encountered “oil-saturated wood chips and soil” to a depth of 3 feet. Total petroleum hydrocarbon (TPH) was detected at a concentration of 2,200 milligrams per kilogram (mg/kg) in a sample of the oily soil. TPH was not detected in two soil samples collected below the oily soil layer. In 1991, an estimated 40 to 50 cubic yards of visibly stained soil was removed from the release area. The memorandum describing the soil removal (EcoChem, 1991) was submitted to Ecology. No verifications of groundwater quality data were collected as part of the cleanup.