The Site is located at 18 Blackbird Drive, Inchelium, Ferry County, Washington, 99138 on the Colville Reservation. The Site is mostly located in Section 12 (with a small portion in the Section 1) of Township 32 North, Range 36 East, Willamette Meridian (latitude 48° 17' 40" north, longitude 118° 12' 23" west).

The area surrounding the Site is a mixture of rural and residential, with several residences located to the north, south, and northwest of the Site.

Substantial environmental information exists about the Site. Environmental investigations completed at the Site in the 2000s show that soil and groundwater are contaminated with arsenic, chromium, and copper and that the source of these metals is wood treatment operations using chromated copper arsenate (CCA). CCA-contaminated sludge and wastewater are present in containers at the Site, including above-ground storage tanks (ASTs) and sumps. Spent formulations, residuals, drippage, and other wastewaters from wood preserving processes that use arsenic or chromium (i.e., CCA) are RCRA listed hazardous wastes (waste code F035).

In addition to arsenic, chromium, and copper, lead is also a contaminant of concern (COC) at the Site. Although the source of the lead contamination has not been determined, lead has been detected in Site soil at concentrations as high as over 100 times the natural background levels for Washington State and over 10 times the Site cleanup level. The lead contaminated soil known to be at the Site is mostly collocated with contamination from wood treating chemicals.

 
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
2008 - URS Site Investigation
URS conducted a Site investigation at IWTP in July-August 2008. The field investigation concluded that soil and concrete at IWTP is contaminated with metals, including chromium, copper, arsenic, and lead, at concentrations exceeding established Site-specific cleanup levels, which were based on Washington Department of Ecology Model Toxics Control Act (MTCA) cleanup levels. The URS report estimated that approximately 6,000 cubic yards/tons of soil are contaminated with metals.

 
2014 – EPA Removal Assessment
In May 2014, the EPA performed a removal assessment at the Site, which involved the collection of soil, concrete, water (surface water, wastewater, and groundwater) samples. The purpose of the sampling event was to further delineate specific areas of the Site (e.g., the UCV and portions of the Treated Wood Storage Area [TWSA}) and to determine whether Site materials were characteristic hazardous wastes.

EPA confirmed elevated levels of metals including arsenic, chromium, and copper in soil and concrete at the North and South Drip Pads and Treated Wood Storage Area and delineated the extent of metals contamination in soil in specific areas of the Treated Wood Storage Area.  EPA determined that the metals-contaminated soil at the Site did not fail the TCLP analysis for metals and so is not a RCRA characteristic hazardous waste.  However, some of the metals-contaminated concrete is a RCRA characteristic hazardous waste (for chromium), as determined by TCLP metals analyses.  EPA also determined that the wastewater present in the Retort Chamber Sump and the UCV is a RCRA characteristic hazardous waste (for arsenic), as determined by a comparison of total metals results to TCLP limits. 

For additional detail, please refer to POLREP 1.

• Removal disposal of contaminated concrete in the North Drip Pad, South Drip Pad, and Treatment Building.
• Excavation and disposal of contaminated soil in the NDP, SDP, TWSA, and the Treatment Building.
• Decontamination and disposal (by recycling) the retort, 9 ASTs, and piping in the Treatment Building and 2 ASTs in the Tank Enclosure.
• Removal and disposal of liquids and sludge found or generated in ASTs, retort, and/or the UCV.
• Removal and disposal of the UCV.

During this reporting period (10/13/2014-10/18/2014), the following removal activities occurred:.

• Treatment Building:  The surface of the Retort Chamber Sump and the other three walls were decontaminated with a mechanical grinder to reduce surface contamination.  A jackhammer attached to an excavator was used to begin breakup of the TB floor.
• Treated Wood Storage Area:  The Western TWSA has been 100% excavated, confirmed by XRF, and graded.  ETD agreed to use shredded vegetation and wood chips from the site as ground cover.  The Central TWSA has been 60% excavated, confirmed by XRF, backfilled, and compacted.  The Northern TWSA has been 80% excavated, confirmed by XRF, backfilled, and compacted.  The Northeastern TWSA has been 80% excavated, confirmed by XRF, backfilled, and compacted.  
• Underground Containment Vault:  The concrete floor of the UCV was analyzed by XRF, determined to be contaminated, removed and set aside for disposal as hazardous waste.  The walls of the UCV also were analyzed by XRF.  Analysis and visual inspection determined that the lower half (6') that was in contact with the process water was contaminated and will be excavated and disposed as hazardous waste.  The upper half (6') of the UCV walls were never in contact with process water and were not contaminated.  The upper sections will be excavated and recycled. 
• Blackbird Drive:  The surface of Blackbird Drive between the treatment area and the NE Treated Wood Storage Area was excavated, confimed clean by XRF, backfilled, compacted.  All work along Blackbird Drive has now been completed. 
• Off-site Transportation and Disposal:  During this reporting period, a total of 61 trucks were loaded with contaminated material and sent off-site for disposal.  Sixty-one trucks (1,921.20 tons this week/5,299.18 tons to date) of non-hazardous waste soil were sent to an appropriate disposal facility. 
• Tank Enclosure ASTs: All work in this operational unit was completed W/E 10/4/2014.
• North Drip Pad: All work in this operational unit was completed W/E 10/11/2014.
• South Drip Pad: All work in this operational unit was completed W/E 10/11/2014

2.1.2 Response Actions to Date
An Action Memo was prepared and signed by EPA on August 14, 2014. 

Five Underground Storage Tanks, located on the east side of the Maintenance and Treatment Buildings, were removed several years ago (date uncertain).

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
A Settlement Agreement between EPA and Colville Tribal Enterprise Corporation (CTEC) was signed on August 22, 2014.  The settlement agreement provides funds from CTEC to EPA to conduct this removal action.

2.1.4 Progress Metrics
Below is a summary of material transported off site during this reporting period:

• Treatment Building:  Remove the concrete floor.  Excavate and remove contaminated soil.  Backfill the Treatment Building floor.  Cover openings cut into the Treatment Building. 
• Treated Wood Storage Areas:  All excavation in the Treated Wood Storage Areas, except for those soils under stockpile footprints, have now been completed.  As contaminated soil is sent off site for disposal and stockpiles are reduced, excavate and XRF remaining areas.   
• Underground Containment Vault:  Complete removal of the walls of the UCV. Segregate concrete into stockpiles for disposal or recycling.  Backfill the UCV excavation.
• Off-site Transportation and Disposal:  Load trucks for transportation and disposal of contaminated materials. Approximately 350 truckloads of material left to remove from the site.
• Tank Enclosure ASTs: All work completed.
• North Drip Pad: All work completed.
• South Drip Pad: All work completed.
• Blackbird Drive: All work completed.
• Long-term/Demobilization Tasks (10/20/2014-11/8/2014):  Replace fencing around IWTP property; install refectors to delineate roadways; assist with recycling of scrapped steel; general site cleanup; demobilize equipment and personnel.

2.2.2 Issues
None. 

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.