Burlington Environmental LLC Georgetown

​Last updated 9/2/2022

Burlington Environmental, LLC and PSC (Phillips Services Corporation) Environmental Services, LLC are wholly owned subsidiaries of Clean Earth Environmental Solutions, Inc. (Clean Earth). We refer to Clean Earth/Burlington on this website because the company uses the name Clean Earth in public, but the facility is permitted as Burlington Environmental, LLC.

This page is about two cleanup sites:
     (1) East of 4th
     (2) West of 4th

“East of 4th” refers to the Clean Earth/Burlington-Georgetown site on the east side of Fourth Avenue South. On the east side of Fourth, Clean Earth/Burlington is the only potentially liable party (PLP) for the cleanup.

"West of 4th" refers to the Clean Earth/Burlington-Georgetown site on the west side of Fourth Avenue South. There are four PLPs responsible for the cleanup at the "West of 4th" site. One of those is Clean Earth/Burlington.  

Chemical wastes contaminated soil and groundwater at the Clean Earth/Burlington Georgetown facility at 734 S. Lucile St. Clean Earth/Burlington must clean up this contamination.

In 1991, Ecology and EPA issued a permit to Burlington Environmental-Georgetown for treatment and storage of hazardous wastes. The permit required finding and cleaning up any contamination they caused.

In 2003, Clean Earth/Burlington closed this facility and removed all buildings. EPA gave oversight for this cleanup to Ecology. The next year, Clean Earth/Burlington built an underground barrier wall around highly contaminated groundwater to keep it from moving toward the Duwamish.

In 2010, Ecology issued Agreed Order #DE 7347 to Clean Earth/Burlington, mostly to address contamination east of 4th Ave.

Ecology approved cleanup engineering in 2011 and Clean Earth/Burlington did
most of the cleanup. However, in 2015 new cleanup actions were added to deal with stubbornly high levels of 1,4-dioxane in site groundwater.

In 2016 Clean Earth/Burlington began treating the groundwater within the underground barrier wall every six months for trichloroethylene (TCE) and vinyl chloride. The treatments help bacteria already in the groundwater break down these contaminants. These treatments ended in 2020.

From 2016 to 2018, Clean Earth/Burlington tested how to reduce the 1,4-dioxane in groundwater. The studies showed that modified ‘in situ chemical oxidation’ (ISCO), would work. So, in 2020 Clean Earth/Burlington injected chemical oxidant (sodium persulfate and other chemicals) into the groundwater to breakdown the 1,4-dioxane. Groundwater monitoring is used to make sure the treatments work.

Meanwhile, in 2019, Ecology approved property use restrictions for part of the site. Although a lot of contamination has been cleaned up, some contamination remains and property use restrictions are needed to protect human health and the environment. Restrictions include not allowing homes to be built on the property.

Groundwater outside of the barrier wall is also contaminated with petroleum-related substances, TCE, vinyl chloride, and 1,4-dioxane. Groundwater within the barrier wall contains higher concentrations of these chemicals and other chemicals. For details, see “contamination, E of 4th”.

Soil is contaminated on the Clean Earth/Burlington and Union Pacific Railroad properties. As detailed in the Remedial Investigation (RI), remaining contaminants include:
      
-Gasoline and related petroleum products. 
     
-Chlorinated solvents, trichloroethylene (TCE), and vinyl chloride (VC). *These are chemicals that may cause cancer.
     
-Polycyclic aromatic hydrocarbons (PAHs). *These are cancer-causing chemicals.

-Polychlorinated biphenyls (PCB). *These are man-made, cancer-causing chemicals.

Groundwater outside of the Clean Earth/Burlington barrier wall is currently contaminated with:

-Gasoline and related petroleum products.

-Chlorinated solvents, TCE, and VC. *These chemicals may cause cancer.

-1,4-dioxane. *A chemical that mixes well with water and can harm the eyes, skin, lungs, liver, and kidneys and may cause cancer. It was used in industry to stabilize chlorinated solvents.

Groundwater inside the barrier wall has higher levels of contaminants.

View cleanup documents for East of 4th.

Clean Earth/Burlington must follow Washington’s cleanup process (see Figure). We are in the cleanup phase.

The cleanup actions are described separately for the areas inside the barrier wall and outside the barrier wall. The combined actions address all contamination. Even after cleanup, this area is expected to be in industrial use.

Area inside the barrier wall
     
In 1994, Clean Earth/Burlington removed and treated contaminants that evaporate easily from soils above the water table using water table-lowering and soil vapor extraction (SVE). The water table is the depth where soil is soaked with water. They did a second phase of SVE from 2012–2014.

Between 2003–2004, Clean Earth/Burlington installed the underground barrier wall. It surrounds most of the permitted facility and keeps contaminated groundwater within the wall. They pump and treat this groundwater, and take care to keep it inside the wall.  
       
In 2012, Clean Earth/Burlington dug up and removed 200 cubic yards of PCB-contaminated soils from the property. They paved the area to prevent contact with remaining soil contamination.
       
In 2015, Clean Earth/Burlington began a treatment for groundwater with chlorinated solvent contamination inside the barrier wall: in-situ bioremediation. This treatment helps bacteria already in the groundwater break down the toxic chemicals. This was done twice a year for 5 years.

Area outside the barrier wall
     
In 2003, Clean Earth/Burlington provided 30 homes above contaminated areas with vapor reduction systems to protect indoor air. Where the contamination is still high enough to present a risk of vapor intrusion, the systems are still running. In 2021 they submitted a Tier 5 evaluation to determine when a vapor mitigation system is a candidate for shutdown, testing, and eventually removal.

In 2012, Clean Earth/Burlington removed and disposed of 5,000 tons of PCB-contaminated soil from the Union Pacific Railroad property. They improved biological breakdown of remaining contamination by putting vegetable oil in the bottom of the excavation before it was backfilled. Then they paved the area with concrete to prevent exposure to any remaining soil contamination.
      
Between 2012–2014, Clean Earth/Burlington used soil vapor extraction (SVE) to remove volatile organic contamination from soil on the Union Pacific Railroad property.

Between 2016–2018, Clean Earth/Burlington tested different chemicals to treat 1,4 dioxane. In 2020, Clean Earth/Burlington injected chemical treatments in three locations to decrease levels of 1,4-dioxane in groundwater. They’re currently monitoring results.   

Clean Earth/Burlington will use a combination of administrative controls, institutional controls, and public communications in the area outside the barrier wall to limit exposure to contamination.
       
Clean Earth/Burlington regularly samples their monitoring wells to check groundwater quality inside and outside the barrier wall. Groundwater contamination is tracked over time to see how well the remedies are working.

The Feasibility Study (FS) evaluated many remediation technologies. The alternatives were evaluated separately for inside and outside the barrier wall.

Contaminated groundwater traveled from the Burlington Environmental facility to areas west of 4th Avenue S., and mixed with contamination from three other companies: Art Brass Plating, Blaser Die Casting, and Capital Industries. These three companies AND Burlington Environmental are jointly responsible for cleaning up the West of 4th site. The four companies are the “Potentially Liable Persons,” or “PLPs,” under the state MTCA (Model Toxics Control Act) law.

Ecology has divided the West of 4th cleanup site into two units. We call them Site Unit 1 and Site Unit 2. Site Unit 1 is the more northern unit. Soil and groundwater are contaminated with chlorinated volatile organic compounds at both site units. In Site Unit 1 soil and groundwater are also contaminated with nickel and other toxic metals.

In 2008, Ecology issued Orders to Art Brass Plating, Blaser Die Casting, and Capital Industries. The Orders required the companies to investigate soils and groundwater contaminated with chlorinated volatile organic compounds (mainly, tetrachloroethene, TCE, and TCE’s degradation products). During the Art Brass Plating property investigation, high levels of toxic metals were found. The three companies finished their investigations and submitted Remedial Investigation (RI) Reports in 2012.

In 2014 Ecology issued Agreed Order (#DE 10402) to Art Brass Plating, Blaser Die Casting, Capital Industries, and Burlington Environmental. This Order created the West of 4th site. The Order requires that the four companies perform a joint Feasibility Study (FS) and submit FS Reports for Site Unit 1 and Site Unit 2.

The companies submitted revised FS Reports for the two Site Units in 2016. After Ecology’s review, the parties agreed to do two pilot studies in Site Unit 1 and an interim action in Site Unit 2 before choosing preferred cleanup actions for the site. The Agreed Order was amended in 2017 to include the two studies and the interim action.

In 2018 the companies began studying two potential cleanup methods to see if they would work at this site. Work plans for the two Site Unit 1 studies were approved in January 2018. See: 2017 SU1 Metals Pilot Test Work Plan Final; 2017 SU1 Downgradient DVOC Pilot Test Work Plan FINAL.

Later in 2018 the companies:

1. Installed new wells and collected soil and groundwater samples before the Metals Immobilization pilot study.

2. Completed the "bench-scale" portion of this study.

3. Injected sodium bicarbonate into groundwater to raise its pH.

4. Sampled groundwater to see how high the pH could be raised and for how long.

5. Installed groundwater wells and collected samples before for the CVOC pilot
study.

6. Injected chemicals into groundwater to break down TCE and vinyl chloride.

7. Started groundwater monitoring to see if the treatment was working.

In 2019 the companies continued to monitor groundwater in the Site Unit 1 areas where pilot studies were active. They found that the injections for the Metals Immobilization raised the groundwater pH, but not as high as needed. The companies then tried a lab study to see if different chemicals or different concentrations could more effective. In August, a second injection event was done, this time using a solution of both sodium bicarbonate and sodium hydroxide. This second injection was better at raising the pH in the groundwater.

The two figures below show the site areas where the Site Unit 1 pilot studies were conducted. 

In this site area groundwater is contaminated with TCE and vinyl chloride. The study will determine if in-situ chemical reduction (ISCR) and enhanced in situ bioremediation (ISB)
will be an effective treatment approach.

This is an area where elevated levels of nickel and other metals are present in groundwater. The study will determine the best way to raise groundwater pH, and thereby lower metals concentrations.

In 2018 the companies also submitted work plans for the Site Unit 2 interim action. The first work plan was approved in January 2018. See: 2017 SU2 Interim Action Work Plan Revised. The interim action was designed to use ISCO for the treatment of soil
contamination below Capital Industries’ Plant 4. TCE and tetrachloroethene (PCE) were the target contaminants and the selected oxidant was potassium permanganate.

The figure below shows the site area where the interim action was conducted.

Implementation of the interim action was staged.

The first stage targeted a sub-set of the total locations planned for injection. In August 2018 oxidant injections were conducted at five Plant 4 locations. The injections were followed by soilborings, and samples were collected from boring depths where the oxidant
was observed (potassium permanganate has a purplish color). 

Sampling and monitoring results in August and September after the first stage injections were completed indicated that the oxidant was poorly and unpredictably distributed (See: Draft Capital Industries Plant 4 Interim Action - Stage 1 In-Situ Chemical Oxidation Report.) As a consequence, Ecology and the companies decided not to proceed with the second stage of injections. Instead, in 2019 the companies decided to study the feasibility
of using soil vapor extraction (SVE) to treat Plant 4’s contaminated soils. A work plan for an SVE study was submitted to Ecology for review (See: Draft Capital Industries Plant 4 Interim Action - Soil Vapor Extraction Pilot Study Work Plan), and the study was
completed during the summer.  It concluded that SVE was a feasible treatment technology for contaminated soils at Plant 4.

Currently, soils are contaminated on the Art Brass Plating, Blaser Die Casting, and Capital Industries properties. Contaminants include PCE, TCE, and – at Art Brass Plating –
plating-related metals like nickel. Where soils are contaminated above cleanup levels they are covered with paving or buildings.

Groundwater at the West of 4th site is currently contaminated with PCE, TCE, vinyl chloride, metals, and 1,4-dioxane. Elevated levels of TCE and vinyl chloride have migrated as far west as the Duwamish Waterway and are discharging to the river. 

The 2018/2019 CVOC pilot study targeted contaminated groundwater approaching the Duwamish Waterway. Monitoring results indicate that the chemicals injected into groundwater to chemically reduce and biodegrade contaminants have been effective and have dramatically reduced TCE levels.

The four West of 4th companies are currently completing a joint Feasibility Study (FS). Their amended Agreed Order requires that they submit “Completion Reports” at the conclusion of the two FS pilot studies and interim action. However, since the Site Unit 2 interim action was not completed, Ecology accepted the February 2019 Stage 1 ISCO Report as Site Unit 2’s “completion report.”  We also waived the submittal of Site Unit 1’s “completion reports” for the two pilot studies. Pilot study monitoring data were submitted in quarterly progress reports and Ecology and the companies discussed these data throughout 2019 as they became available.

The next steps at the site are:

1. Preparation of a technical memorandum, discussing the results of two years of site-wide groundwater water-level measurements (including “continuous” results obtained by transducers installed in a number of monitoring wells). The measurements have been taken to help determine groundwater flow directions. The memorandum was submitted in April 2020. 

2. Preparation of FS Report Addenda (one Addendum for each Site Unit’s FS Report). These documents will evaluate specific alternatives for cleaning up the site and conclude with the companies’ preferred cleanup actions. Draft documents have been submitted, and are currently being reviewed and revised.

Following Ecology’s review of the groundwater technical memorandum and the two FS Report Addenda, we will choose our preferred cleanup action for the site. It will be described in a draft Cleanup Action Plan (CAP) and made available for public review. At that time we will also draft a new Agreed Order. After public comment on the CAP
and new Agreed Order, Ecology will finalize the documents and the four companies will
design and implement the selected cleanup action(s).

View comprehensive list cleanup documents for West of 4th.

The Environmental Protection Agency (EPA) added the 5-mile stretch of the Duwamish River that flows north into Elliot Bay to the Superfund National Priorities List in 2001. This part of the river is now referred to as the “Lower Duwamish Waterway (LDW) Superfund Site.” 

Sediments (mud) in the river contain a wide range of contaminants due to decades of industrial activity and runoff from urban areas. EPA is leading efforts to clean up these river sediments. Ecology is leading efforts to control sources of contamination from the surrounding land. Contaminants in the soil and groundwater around the river pose a risk to human health and the environment. These contaminants can find their way into the river through storm runoff and other pathways. 

Ecology’s Lower Duwamish Waterway source control efforts have the long-term goals of avoiding recontamination of the river bottom and restoring acceptable water quality in the river.