United States Environmental Protection Agency
Region X
POLLUTION REPORT

Subject: 

On 20 Sep 06, an Associated Petroleum Products (APP) fuel truck slid off the road and over an embankment at Howard Hanson Dam.  Incident resulted in the release of approximately 600 gallons of #2 diesel fuel into the soil.  The tanker truck has been removed from site.

Initial soil analysis predicted that the fuel would quickly move vertically through the soil until it reached the water table.  

This fuel has traveled from the spill site to the reservoir shore. Temporary measures have been put in place to minimize the fuel impact to the water. This has been accomplished with a series of trenches dug with absorbent materials placed in them and also a combination of oil only absorbents and rigid containment boom.

• Lower slope was covered with jute mat and hydroseeded last Friday. Jute mat was stapled to ground to help in remain in place during inundation. (October 13, 2006)
• A draft report on the lower slope excavation was received and reviewed last week. Based on data in this memo, calculations of petroleum volume recovered 200-400 gallons.
• Groundwater samples were collected from the extraction wells following the rain events this weekend. Results indicate no product in the wells at this time.

• USACE held a meeting with representatives from APP, Whatcom Environmental, Shannon & Wilson, Ecology, EPA, and TPU today (October 17) to discuss path forward. Resolution was reached in this meeting to the satisfaction of the regulatory agencies and TPU as summarized below:
– Excavation of the upper slope or drilling to determine locations of free product were deemed infeasible from a slope stability perspective and were not required by the regulatory agencies or TPU.
– Rather, Whatcom will implement a pilot test of water infiltration on the upper slope to facilitate movement of remaining product. Pilot test will include applying water from the reservoir on the slope at a rate that will not impact slope stability. Changes in concentrations and water levels in the extraction wells will be monitored during this study. Only indicator compounds (TPHG and BTEX) will be monitored during this test. In addition, if product is detected in the extraction wells, the product will be removed. The test is expected to run for 2-3 weeks. Decisions on additional treatment needs and methods will be based on the results of this test. During the pilot test, Whatcom will monitor the reservoir to confirm sheen is not released.
– Details on implementation were discussed. Based on this, no formal plan for these activities is required by regulatory agencies. Results of pilot test will be communicated to team in real time and modified as needed.
– Pending results of this test and other treatment applications, if performed, a long term plan will be established to monitor sheen releases to the reservoir. Monitoring plans will include activities during high water elevation periods. Monitoring for visual presence of sheen will be conducted by TPU in conjunction with APP’s contractors.

• Whatcom Environmental will begin planning the upper slope treatment this week. Initiation of treatment activities will commence NLT October 23, 2006.
• Pending results from the recent extraction well sampling and the amount of rainfall, additional sampling/observations at the extraction well will occur this week (October 20, 2006).

None.