United States Environmental Protection Agency
Region X
POLLUTION REPORT

Subject: 

See initial POLREP.

The Responsible Party (RP) undertook activities in December 2002 to remove oil and wastewater liquids from the site.  However, residual sludge and liquids remained in the numerous tanks and containers on the site.  The EPA OSC tasked one START personnel to conduct oversight activites at the PSCI site during RP activities to remove the residual sludge, liquids, contaminated absorbent materials, and aboveground soil and debris during the period of January 28 - 30, 2003.

On January 28, 2003, START conducted oversight of removal activities performed by the RP's contractors.  Utilizing a vacuum truck and 2 dump trucks, the RP's contractors removed sludge material from various USTs and sixteen drums staged in and around the UST Cleaning Area (UCA)(Areas 8 and 9 cited in work plan) and removed contaminated soil/debris from a stockpile identified as Areas 6 and 7. Approximately six yards of sludge and soil debris were transported to Waste Management where it was determined that the load contained elevated levels of hydrocarbon contamination which they were not permitted to accept.  The vacuum truck was redirected by the RP to TPS Technologies, Inc., a hazardous waste disposal facility, to have the waste incinerated.  Fourteen drums of contaminated absorbent materials and an unknown quantity of moderately-contaminated soil/debris was transported to Waste Management for disposal.  The debris (rock, concrete, wood), stockpiled in Areas 6 and 7, was designated as non-hazardous and transported to Monroe Rock, Inc. in Kirkland, Washington.  An estimated total of 17 tons of sludge/contaminated soil, fourteen drums of contaminated absorbent mixed with soil/debris, and an unknown quantity of non-hazardous soil/debris were transported off site on this day.

On January 29, 2003, the START conducted oversight of the RP's contractors during cleaning of the various containers on-site, including: 30 drums, 13 poly tanks, and one 1000-gallon steel tank (located in secondary containment identified as Area 10).  Containers were steam-cleaned in the UCA with secondary containment.  Upon completion of container cleaning operations the UCA was steam-cleaned.  All wastewaters were contained and pumped into the 2500-gallon steel tank located in Area 10.  The poly tanks are to be either cut up and disposed of or re-used.  The steel drums will be transported to Arrow Metal in Woodinville, WA for disposal.  During removal and cleaning activities, a vacuum truck pumped wastewater and residual sludge from the 2500-gallon storage tank.  The vacuum truck reached it's capacity leaving approximately 200-400 gallons of liquid and sludge in the 2500 gallon tank.  Approximately 2500 gallons of liquid and sludge were removed from the site by the end of this day.        

On 1/30/03 the START conducted oversight of the removal of the remaining 300 gallons of waste water and 300 gallons of sludge from the 2500-gallon tank in Area 10.

1. No further removal activities, requiring EPA oversight, are anticipated at this time.
2. Demolition of secondary containment areas, assessment of soil contamination, confirmation sampling and soil removal may possibly be completed by the PRP under the Washington State Department of Ecology (WDOE) voluntary cleanup program.

1. EPA OSC to continue communications with RP and integration with Washington State Department of Ecology personnel in order to ensure continued assessment, necessary cleanup, and monitoring of activities.
2. EPA with START assistance to complete EPA IDW disposition.

1. Once the liquid and solid wastes were removed from the site, under EPA oversight, there appeared to be a lapse in communications and integration with the RP and the Washington State Department of Ecology, even after repeated attempts at contact by EPA.
2. Need to resolve property boundaries and ownership issue so that on site contamination can be distinquished from potential off site contamination.

The hazardous waste manifest from TPS Technologies stated that approximately 17 tons of waste was received from PSCI on 1/28/03. Also for this date, no manifests have been provided yet indicating quantity of contaminated absorbent/soil accepted at Waste Management.  In addition, there are no receipts indicating the amount of non-hazardous material sent to Monroe Rock.

On 1/29/03, a total of approximately 2,500 gallons of liquid and sludge was removed from the site.

On 1/30/03, a total of 300 gallons of waste water and 300 gallons of sludge were removed from the site.