North Cascade Ford

Ecology issued a Property No Further Action (NFA) opinion letter on January 4, 2023.

The opinion letter includes an Environmental Covenant (EC) as an attachment, which is required to assure the continued performance and effectiveness of post-cleanup controls.

The Environmental Covenant (EC) is required because soils and groundwater with concentrations of chemicals above Model Toxics Control Act (MTCA) cleanup levels will remain on the Site after the cleanup has been completed.

The cleanup meets Ecology requirements because the residual contamination does not pose a threat to human health or the environment.  The EC documents the locations of the contamination on the multiple parcels that comprise the Site and, as recorded with Skagit County, will run with the titles on the property parcels.

The Environmental Covenant include:

• Containment of coal residue under a cap consisting of asphalt or gravel.
• Prohibition of groundwater extraction for any purpose other than temporary construction dewatering, investigation, monitoring, or remediation.
• Continued sampling of Site monitoring wells to confirm stable or decreasing contaminant concentrations to values below Ecology cleanup levels.
• Prohibition of activities that could compromise the integrity of the completed cleanup, without prior written approval from Ecology.

The Site was developed in the early 1900s with land uses that included a power plant, automobile shop, feed mill, hotel, railroad depot, coal storage, and residences. An auto dealership was built on the Site around 1949 and this land use continued through 2016. Soil and groundwater contamination was discovered.

The following were removed from the Property between 2016 and 2020:

• three 1,000-gallon underground storage tanks
• two hydraulic hoists 
• approximately 4,100 tons of contaminated soil was removed
• approximately 142,000 gallons of contaminated groundwater was removed

Soil excavations were backfilled with clean fill mixed with oxygen-release compound to enhance degradation of petroleum in groundwater.

Confirmation soil and groundwater sampling documented the cleanup of the Property to meet MTCA standards.

• Total petroleum hydrocarbons (gasoline, diesel, oil), polycyclic aromatic hydrocarbons, non-halogenated organics, and halogenated solvents in soil and groundwater.
• Metals and polychlorinated biphenyls in soil.

The Model Toxics Control Act (MTCA) is Washington’s environmental cleanup law. It provides requirements for contaminated site cleanup and sets standards that protect human health and the environment. Ecology enacts the MTCA and oversees cleanups.

​The MTCA site cleanup process is completed in steps over a variable timeline.

This site was under the Voluntary Cleanup Program (VCP) at Washington State Department of Ecology (Ecology) Northwest Regional Office. The VCP enables owners of contaminated sites to meet state cleanup standards independently and to receive technical guidance from Ecology during the process.

The VCP enables owners to work on an independent basis rather than under an Ecology legal order. Participants in the VCP pay fees to Ecology to cover the Department’s costs for guidance and review. VCP sites must meet the same cleanup standards as properties formally managed by Ecology under the state’s cleanup law, the Model Toxics Control Act, created by a 1989 voter initiative.

This type of no further action (NFA) is issued when the Property is cleaned up but further remedial action under MTCA is still necessary elsewhere at the Site. Ecology concluded that no further action is necessary at the Property (Property NFA) based on site characterization, establishment of cleanup standards for the site, points of compliance, and cleanup of the property. While this cleanup constitutes the final action for the Property, it constitutes only an Interim Action for the Site as a whole.

Completion of the Site cleanup and request for a Site NFA opinion can be pursued through re-enrollment in the VCP.