United States Environmental Protection Agency
Region X
POLLUTION REPORT

Subject: 

The Foss Moon and Associates site, formerly known as Airo Services and Crown Tank Cleaning, is an inactive oil recycling facility. The site is owned by Foss Moon and Associates, whose principal is Jim Foss, who was identified as the responsible party (RP).

The RP entered into an Administrative Order on Consent with the United States Environmental Protection Agency (EPA), under which the RP agreed to perform a removal action (RA) at the site under EPA oversight. The purpose of the RA conducted at the FMA site was to remove gross contamination from the site and to mitigate the potential for releases of hazardous substances. Potential hazards included industrial chemicals and petroleum products stored in 55-gallon drums; approximately 80,000 gallons of oily water and petroleum products stored in above-ground storage tanks (ASTs); a concrete mixing pit containing sludge, sawdust, and oil containing polychlorinated biphenyls (PCBs); and various sludge/solids containers scattered across the site containing PCBs and metals including barium, beryllium, cadmium, chromium, copper, iron, lead, mercury, nickel, selenium, silver, and zinc.

The RA was organized and executed by the RP, FMA, with oversight by EPA. EPA tasked START to provide photographic and logbook documentation of the RA and to communicate site activities to the EPA On-Scene Coordinator (OSC) coordinating the RA.

The site was divided into four operable units (OUs) based on the types of contamination found at the site, common disposal methods, and disposal sequencing. In general, work was conducted on only one operable unit at a time; however, work on some of the OUs overlapped. Due to the nature of contaminant distribution at the site, geographic areas are not necessarily associated with the operable units.

OU 1 was defined as the 55-gallon drums stored in the warehouse and found throughout the yard, and the laboratory and industrial chemicals recovered from the laboratory and warehouse building. Contaminants associated with OU 1 included abandoned laboratory chemicals, caustic compounds, paint-related materials, adhesives, oily water, and various petroleum products ranging from oils to heavy tars and asphalt.

OU 2 was defined as the containment pit and the surrounding concrete pads. At the beginning of the RA the containment pit was filled with a mixture of sawdust, rainwater, soil, and oil. During Ecology’s field sampling event in February 2008, the oil in the containment pit and dirt from the concrete pads were sampled. The results indicated that both samples were contaminated with PCBs, heavy metals, and VOCs (Ecology 2008).

OU 3 was defined as the soil, petroleum products, and other materials that were found at the site in a variety of containers including three dumpster-like containers, two steel half-round containers, a circular metal basin, a shipping container, a fifth-wheel tanker trailer, and a large rectangular custom fabricated metal containment area. In general, the soil containers and half rounds had a volume of 5–10 cubic yards (CY) each; however, one container exceeded 50 CY. Contaminants in OU 3 included oily soils, rags, and debris; PCBs; heavy metals; tar; and what appeared to be heavy motor or hydraulic oil.

OU 4 was defined as the oily water, free petroleum product, and sludge stored in nine of the 11 ASTs and in the associated secondary containment areas at the site.
The goal of the RA was to stabilize the site by removing source materials such that future releases would not occur. This was accomplished by taking an inventory of site wastes, collecting analytical information to determine appropriate disposal methods, and transporting the wastes from the site to disposal facilities.

Work at the site progressed in a discontinous fashion from July 10 2008 through December 11 2008. The work schedule was determined by FMA throughout the RA.  

In total, approximately 114 drums, 10 soil containers, 30 totes, 7,000 gallons of free product and 70,000 gallons of oily water were removed from the site.

The RP’s RA activities were completed on December 11, 2008. Based on a visual inspection of the site performed by START and a subsequent interview with FMA, EPA concluded that the risk of a spill to the environment had been mitigated. Site contaminants of concern, including petroleum products, PCBs, and/or heavy metals may exist in the site’s soil and groundwater; however, the drums, soil containers, vehicles, and ASTs known by START to contain potentially harmful materials were removed from the site and disposed of by FMA.

A final report for the site was completed on April 30, 2009.

None.

The removal actions as required in the AOC have been completed.

At the time of the signing of the Action Memo, the Washington Department of Ecology was prepared to oversee the cleanup of any soil or groundwater contamination at the site.  Ecology had identified this site as a high-priority site for rememdiation because of its long-standing inactivitiy, high potential for releases from poor waste management practices, and its proximity to Puget Sound/Commencement Bay.  

Ecology is negotiating a Prospective Purchaser Consent Decree with a private entity that would include a cleanup action plan, with the cleanup actions to be overseen by Ecology.  If the PPCD negotiations stall or if the prospective purchaser decides to not purchase the property, Ecology had intended to pursue cleanup under MTCA, either cooperatively with FM&A, through an enforcement action, or by utilizing state funds to conduct the cleanup.  As of April 3, 2009, the property has not been sold, Ecology has not received an acceptable remediation plan from the prospective purchaser, and funding to conduct a state-led cleanup is no longer available.