Pollution/Situation Report Profile

Samoa Pulp Mill
Samoa, CA - EPA Region IX
POLREP #5

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Samoa Pulp Mill - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IX

Subject:

POLREP #5
Samoa Pulp Mill

Samoa, CA
Latitude: 40.8049600 Longitude: -124.1933100

To:

Harry Allen, EPA Region 9
Peter Guria, EPA Region 9
Dan Meer, EPA Region 9

From:

Steve Calanog, OSC

Date:

12/7/2013

Reporting Period:

Previious PolRep through 12/07/2013

1. Introduction

1.1 Background

Site Number:	A949	Contract Number:	EP-S9-12-01
D.O. Number:		Action Memo Date:	11/4/2013
Response Authority:	CERCLA	Response Type:	Emergency
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	9/30/2013	Start Date:	10/1/2013
Demob Date:		Completion Date:
CERCLIS ID:		RCRIS ID:
ERNS No.:		State Notification:
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

Emergency Response

1.1.2 Site Description

The Samoa Pulp Mill Site is a 70 acre former industrial pulp manufacturing facility. The pulp mill was constructed in 1963 by Georgia Pacific. In the early 1970's Louisiana Pacific acquired and ran the facility until 1990. From 1990 until 2008 various smaller ownership groups owned and operated the facility. The last operating owner of the facility was the Evergreen Pulp Company which ran the facility until 2008. Evergreen experienced financial difficulties and "walked away" from the mill site without properly closing operations. Sometime in 2009 a venture group called Freshwater Tissue Company purchased the facility site with intent of converting to a tissue mill. This quickly failed to reach fruition and Freshwater began scraping the facility and consolidating hazardous waste. In August of 2013 Freshwater Tissue Company sold the facility to the Humboldt Bay Harbor District (aka - Port Authority). The facility is currently staffed with 2 part-time Humboldt Bay Harbor District employees.

1.1.2.1 Location

The Samoa Pulp Mill Site is located within Humboldt County in Samoa, CA. The Site is approximately 70 acres of industrial pulp processing operations and is situated on the North Spit of Humboldt Bay. The facility is on the shore line of Humboldt Bay and has an industrial wharf on the Bay. The Pacific Ocean is located within 800 yds to the west of the facility.

1.1.2.2 Description of Threat

The facility has approximately 30 tanks which contain 4 million gallons of highly caustic liquids (pH greater than 13), 10k gallons of acids (pH less than 1), 3,000 tons of corrosive sludges in uncontained areas, approximately 3k gallons of turpentine, several laboratories with approximately 1000 containers of a wide range of chemicals in various states of stability, and several thousand containers of various types (i.e., compressed gas cylinders, paints/thinners, mercury containing gauges and equipment).

EPA assessment has determined that almost all tanks are leaking or failing. Several of the tanks pose an immediate risk to overflowing due to rainwater accumulation. Several of the tanks which currently hold pulping liquors are not designed to store caustic liquids. Laboratory chemicals are stored improperly and/or are reacting. Rain is exacerbating runoff on-going discharge risks to Humboldt Bay.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

In August, 2013, the Humboldt Bay Harbor District requested OSC Calanog to conduct a preliminary assessment of the hazardous materials which remained at the facility. What remains at the facility are approximately 30 large aboveground storage tanks which contain approximately 4 million gallons of pulping liquors, a caustic liquid with a pH of 13 or greater, approximately 10,000 gallons of acids (primarily sulphuric), and over 3,000 tons of corrosive sludges. Many of the tanks are leaking material and are in various states of decay. Further many of the tank roofs leak rain water and are at their capacity. Subsequent assessment during the week of September 23rd, 2013, EPA determined that 2 of the large aboveground storage tanks were at capacity and threatened to overflow and/or fail completely. OSC Calanog exercised his emergency response warrant to initiate an action to stabilize the site with the primary objective of removing product from 2 tanks which were threatened to overflow.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

Beginning the week of November 18, 2013, the EPA, USCG PST, START, and ERRS personnel remobilized to the Samoa Pulp Mill Site to begin the design and construction of the pulping liquor pipeline. This pipeline will connect 10 large above ground storage tanks that contain the pulping liquors and through a series of hydraulically driven pumps transport the liquours approximately 3,000 feet to the wharf where it can safely be loaded onto a chemical barge. The pipeline will be constructed of 6-inch HDPE pipe and be valved to load discrete loads of black, white, and green liquors at the times when they will be removed. Pipeline construction at the Samoa Pulp Mill is anticipated to take approximately 3 weeks.

2.1.2 Response Actions to Date

11/21/13 - 12/07/2013 - EPA, START, ERRS, and the USCG PST continued with the construction of the loading pipeline. As currently installed approximately 3,000 feet of pipeline has been welded together which connects 11 above ground storage tanks which store the pulping liquors. Also, during this period ERRS and USCG personnel began removing idle pipelines on the wharf that would impeded anticipated loading operations.

During the week of Dec 2nd and extensive re-sampling and volume calculation was performed on all the liquor tanks. Up until this time tank volumes were estimated based on liquid levels in all tanks. Due to the nature of the caustic solutions and the circumstances of how the liquids were handled during recent years it was uncertain how much actual free liquid was stored in the tanks. Extensive bottom soundings were performed and it was determined that there was in fact considerable crystalization and sediment accumulation in all the tanks. A revised free liquid volume calculated and it is now estimated that pumpable free liquid is 2.7 million gallons which is less that estimated 4 million gallons. However, the previously estimated volume of corrosive sludges is now considerably higher.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

EPA has been in discussions with Humboldt Bay Harbor District with regards to their responsibility as the current owner. Verbal notice has been provided by the OSC to the Humboldt Bay Harbor District. EPA civil investigators have been engaged in an investigation and assessment with regards to the responsibility of previous owners (e.g., Evergreen Pulp Company).

EPA civil and criminal investigators have initiated their investigation.

2.1.4 Progress Metrics

*Waste Stream*	*Medium*	*Quantity*	*Manifest #*	*Treatment*	*Disposal*	*Recycled*
Caustic liquids	liquids	2.7m gallons
Sulfuric Acid - Re-usable	liquids	6k gallons				Purchased by Valley Acid, Stratford, CA (11/13)
Sulfuric Acid - Waste	liquids	4k gallons
Hydrochloric Acid - Waste	liquids	3k gallons
Corrosive sludges	semi-solids	9k tons
Turpentine	liquids	3k gallons
Lab Chemicals	various	~2k containers
"HHW" type	various	~2k containers
Hg	liquids	Unk at this time
Waste oils	liquids	~2k gallons

2.2 Planning Section

2.2.1 Anticipated Activities

During the week of Dec 8, 2013:

- ERRS and USCG PST crew will complete final installation, inspection, and pressure testing of the pipeline.

- ERRS and USCG PST crew will complete all infrastruction preparation work

- EPA, USCG PST, ERRS, START, and Humboldt Harbor District will meet with representatives from Crowley Maritime (Barge vendor) to conduct a site-walk of the Samoa Pulp Mill Wharf to discuss and finalize loading plans.

- ERRS will oversee and conduct the removal of approximately 3k gallons of hydrochloric acid which currently stored in totes

- EPA, USCG PST, ERRS will meet with representatives of the USCG Sector Columbia River, WA Department of Ecology, Port Authority of Longview, and EPA Region 10 in Longview, WA to discuss planned activities to un-load the materials at the Kapstone Paper Mill located in Longview, WA.

2.2.1.1 Planned Response Activities

It is anticipated that all preparations for the loading/unloading of the chemical barge, scheduled for Jan 2014, will be completed the week of Dec 8th. Scheduling and final plannning for the loading/unloading is anticipated to be complete the first week of Jan 2014.

2.2.1.2 Next Steps

Finalize shipping plans and schedule barge arrival and departure dates.

2.2.2 Issues

2.3 Logistics Section