United States Environmental Protection Agency
Region X
POLLUTION REPORT

Subject: 

See initial POLREP.

On December 23, 2002, the EPA, START contractor, the PRP [PSCI Tank Services (PSCI), Terrasolve] and PRP contractor, Protective Environmental Services (PES) met at the PSCI facility.  PES was contracted by the PRP to remove and dispose of the liquid waste stored on-site.  Upon EPA and START's arrival, PES had already pumped a total of 2500 gallons of oil from tanks located in Areas 10 and 11.  Area designations can be found in the PRP contractor's (US Environmental) Remedial Work Plan.  An additional 500 gallons of oil were removed from tanks in Areas 10 and 11.  At this point the PES tank truck reached it's holding capacity of 3000 gallons, and mobilized to the PES disposal facility in Tacoma, Washington to be off-loaded.

Based on an agreement between EPA, the PRP, and PES, oily waste water was pumped out of the secondary containment structure, identified as the UST Cleaning Area (UCA), the UCA was rinsed, and the waste water directed into two poly-tanks located in Area 11.  Following this, the liquids were transferred from the Area 11 poly-tanks into the 1,000 gallon poly-tank in Area 10 to insure secondary containment for potential release.  PES collected samples of the liquid placed into the Area 10 poly-tank and submitted it for analysis to determine proper disposal.

Work completed on 12/23/02 included the removal of 3000 gallons of liquid referenced above, cleaning the UCA and directing UCA waste water into a poly-tank in Area 10, placing oily debris into drums, and relocating all drums and containers to the UCA.  This area was tarped to prevent rain water from entering the secondary containment structure.  Upon the return of the PES tank truck to the site, an additional 1200 gallons of liquid waste were removed from poly-tanks in Area 11 and subsequently transported to the PES disposal site in Tacoma, WA.  Following the departure of PES from the site, PSCI employees pumped approximately 480 gallons of oily water from another poly-tank in Area 11 into the 1,000 gallon tank in Area 10.      
A combined total of approximately 4200 gallons of oil and water were removed from the site on 12/23/02, and taken to a PES facility in Tacoma, WA.        

On December 27, 2002, START met PES at the PSCI facility to finish removing liquid wastes from the site.  A total of 1800 gallons of oily water and 300 gallons of diesel were removed from multiple tanks in Areas 10 and 11, the sump inside of the UCA, and a poly-tank on the back of a flatbed truck.

PES stated that all of the tanks have 2-3 inches of sludge remaining on the bottom, totaling approximately 200-300 gallons.

Utilizing PRP-contractor analytical results, the planned removal actions are as follows:
1. Remove residual waste water and sludge from all tanks and containers at the site, including the Area 10 poly-tank.
2. Pressure-wash all tanks, drums, containers, and secondary containment areas and remove wastewater mid- to late-January 2003.
3. Stockpiled soil/debris removal and disposal to occur on mid- to late-January 2003 after work plan approval.
4. Demolition of secondary containment areas, assessment of soil contamination, confirmation sampling and soil removal to possibly occur in February 2003, after work plan approval.  The demolition and future soil assessment/sampling may possibly be completed by the PRP under the Washington State Department of Ecology (WDOE) voluntary cleanup program.
5. Once EPA off-site sample results as well as a determination application for the WDOE voluntary clean up program is received and reviewed, further assessment of off-site migration may be warranted and conducted by PRP.
6. All activities to be monitored with EPA oversight and documentation.  EPA participation may change with PRP acceptance to the WDOE voluntary clean-up program.

1. EPA will perform oversight of PRP sludge, soil, and debris removal actions, proposed to occur mid- to late-January 2003.
2. PRP to incorporate EPA comments, finalize work plan, and resubmit to EPA for review prior to any further removal/remedial work being conducted by PRP beyond soil, sludge and debris removal actions.
3. Further on-site actions beyond soil/sludge/debris removal and seconday containment cleaning may be deferred to the WDOE pending approval of PRP's voluntary clean-up program application.

1. Need to resolve property boundaries and ownership issue so that on site contamination can be distinquished from potential off site contamination.
2. PRP's eagerness to hire contractors and conduct assessments and sampling without EPA concurrence on activities and quality assurance objectives, and lack of opportunity for EPA oversight of sample collection and obtaining split samples.

A combined total of approximately 4200 gallons of oil and water were removed from the site on 12/23/02, and taken to the PES disposal facility in Tacoma, WA.

On December 27, 2002, a total of approximately 1800 gallons of water and 300 gallons of diesel were removed from the site and taken to the PES disposal facility in Tacoma, WA.