1.1.1 Incident Category

Time Critical Removal Action

1.1.2 Site Description

The Valley Post and Sawmill site (Site) is a former sawmill and wood treatment facility located along the south side of Big Goose Road approximately 2 miles south west of Sheridan, Sheridan County, Wyoming.  The Valley Post and Sawmill treated wood using Pentachlorophenol (PCP) mixed with diesel fuel.  It is unknown precisely when the facility commenced its wood treating operation; however, the state of Wyoming believes that it shut down sometime during 1996.

Correction from previous reports: Carl Sayer owned the property subsequent to the time period that it operated.  The facility was operated by Larry, Gary, and Vernon Sayer (WDEQ Report- Feb 2009).  PCP was mixed with diesel fuel in a small tank, after which, it was transferred to the retort tank/pressure vessel where the posts were treated.  In addition to the retort vessel, there were also two smaller tanks that posts were dipped in to be treated.  Treated posts were then stacked on bare soil to dry.  There is no record of any containment features associated with Site operations, and the use of engineered containment features was not a standard practice in the industry prior to the mid to late 1980s.

The Wyoming Department of Environmental Quality (WDEQ) and EPA’s Resource Conservation and Recovery Act (RCRA) programs conducted an inspection of the facility while it was in operation in 1987.  The inspection documented areas of significant soil contamination and dumping of PCP laden solution directly to soil, however, at the time of the inspection, the F032 waste listing had not been promulgated, so no actions were taken.  Results of this inspection are available in the Site file.  There is no evidence that either EPA or DEQ followed up on this inspection. 

In October of 2008, WDEQ responded to an inquiry about the facility from a prospective purchaser and conducted an inspection.  This inspection identified that the tanks and equipment had been removed from the Site and that significant movement of soil had occurred recently.  A cure notice was issued to the current property owner, Mr. Shane Taylor – Carl Sayer’s nephew, to conduct an assessment of the property and to develop a clean up plan.  Taylor was given 60 days to respond.  WDEQ requested EPA’s assistance for the Valley Post and Sawmill Site upon the expiration of the 60 day time period, on approximately May 15, 2009.

The Site is an inactive 25 acre sawmill and wood treating facility consisting of several areas of contaminated soil where wood treatment, dipping, and drying occurred.  The Site as not been used for wood treatment since approximately 1996.  The site also includes a parcel of property located in Guernsey, WY, where Mr. Taylor moved the aforementioned tanks.

1.1.2.1 Location
 

650 West Wheatland Ave, Guernsey, WY; and
446 Big Goose Road, Sheridan, WY

1.1.2.2 Description of Threat

PCP has been documented at the Site in concentrations exceeding 390 mg/kg, indicating that PCP has been released into the environment.  Documents from the joint EPA/WDEQ inspection show very poor housekeeping during facility operations and support the Removal Site Evaluation findings of PCP in the soils on the Site.

PCP has been documented in concentrations exceeding 8,000 mg/kg in the tank at the Guernsey Property.  This tank has also been documented to have existing holes, thus threatening a release of listed hazardous waste to the environment.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
 
See POLREP #1