Laserfiche WebLink
ASPECT CONSULTING <br />PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 33 <br /> <br />K-C discovered the spill when latex was observed seeping out of the ground next to the <br />loading dock during pumping operations. The spill occurred from subsurface piping, <br />which may have been damaged when a tank car derailed at the spur terminus in September <br />2008. Upon discovery of the spill, the subsurface pipeline was immediately taken out of <br />service and replaced with a temporary above-grade pipeline. Based on unloading records, <br />K-C estimated that up to 250,000 pounds (roughly 28,000 gallons) of product were spilled. <br />After learning of the release, K-C notified Ecology regarding the spill and conducted an <br />investigation into the chemical properties of the latex product to determine its hazard <br />potential. Using data supplied by the vendor, and confirmatory laboratory analysis of the <br />as-delivered product for formaldehyde content, K-C determined that the spill did not <br />constitute a reportable quantity under 40 Code of Federal Regulations (CFR) 302 and 40 <br />CFR 355. Between February and April 2009, K-C removed approximately 15,500 gallons <br />of the spilled product from beneath the mill using vacuum extraction (vactor truck). <br />During the final removal effort, the flow of product from beneath the tissue mill building <br />dissipated to a trickle. <br />Based on an evaluation of the collective information, Aspect (2009) concluded that the <br />residual latex product poses negligible environmental concern and no adverse threat to <br />industrial workers at the mill property, and that it would be impracticable to attempt <br />removal actions more aggressive than ongoing vactor truck recovery of visible product. <br />3.1.13 Characterization of Soil Removed from Sand Filter 1 <br />Foundation (Old Boiler House) (2011) <br />In 2011, CRETE Consulting conducted sampling and analysis of stockpiled soil to profile <br />it for off-Site disposal. The soil had been excavated from within the 7, 8, and 9 Old Boiler <br />House Building (Steam Plant), adjacent to Dutch Ovens 1 through 5, to allow construction <br />of the foundation for new Sand Filter 1 (REC 5 in AECOM, 2011). <br />A composite sample of the stockpiled soil was collected for analysis of gasoline-, diesel- <br />and oil-range TPH, Resource Conservation and Recovery Act (RCRA) 8 metals (arsenic, <br />barium, cadmium, chromium, lead, mercury, selenium, silver), and lead (by the toxicity <br />characteristic leaching procedure [TCLP]). In addition, a discrete soil sample was <br />collected for VOC analysis, and a discrete sample of soil suspected of containing spent <br />sulfite liquor (SSL) was analyzed for RCRA 8 metals. <br />Concentrations of arsenic (35.4 mg/kg) and cadmium (5.2 mg/kg) in the composite soil <br />sample exceeded the respective soil screening levels for unrestricted site use. The sample <br />containing suspect SSL had no detected concentrations greater than unrestricted soil <br />screening levels, and VOCs were not detected in the discrete sample. The 57 tons of <br />stockpiled soil was properly disposed of at Roosevelt Regional Landfill (CRETE, 2011). <br />3.1.14 Phase 1 ESA (2011) <br />In April 2011, AECOM conducted a Phase 1 ESA for the mill property, in accordance <br />with American Society for Testing Materials (ASTM) Standard E 1527-05 (AECOM, <br />2011). Based on the results of the Phase 1 ESA, AECOM identified the following seven <br />recognized environmental conditions (RECs) at the mill property: