Recomp of Washington

The Recomp of Washington site (Site) is located at 1524 Slater Road. The April 23, 2003 No Further Action request for the Recomp of Washington site specifically excludes the hazardous waste pit at the north adjoining Wilder Landfill site.

This Site property was undeveloped farmland prior to 1974. In 1974, Wilder Construction Company, Inc. (Wilder) prepared an Environmental Impact Statement to develop a 100-ton per day solid waste incinerator and disposal site. Whatcom County Health Department (then the Bellingham Whatcom District Department of Public Health) granted a Solid Waste Handling Permit for the facility. The 100-ton-per-day incinerator generated about 30 tons per day of combined bottom and fly ash.

Thermal Reduction Company purchased the Site property from Wilder in 1985 and continued to operate the incinerator and ash landfill portion until Recomp Inc. purchased the property in 1989. Recomp of Washington (Recomp) continued to operate the facility with modifications to remain current with the community’s solid waste handling needs and the evolving regulatory requirements.

The Site includes three current parcels at 1524 and 1526 Slater Road, based on a closed ash landfill on one parcel and an upgradient soil-bentonite slurry wall that extends onto all three parcels. Adak Island Adventures, LLC (ADAK) owns Parcel 99458 that contains the landfill, and PES Holdings, LLC owns the east adjacent Parcel 173981 where the slurry wall is constructed. Parberry Environment Solutions operates Scrap-It recycling services and Stow-It storage container rental solutions (i.e., Scrap-It Stow-It) on these two parcels. Regional Disposal Company owns Parcel 173983 and operates a material recovery facility and waste transfer station on the parcel. The slurry wall extends east-to-west south of the waste transfer building.

Municipal solid waste incinerator ash was disposed in a landfill constructed on the lower terrace deposit on the northwest side of the Site. The landfill was constructed by excavating pits in the low permeability Bellingham Drift soil. The excavated material was used to construct lateral berms around the incinerator disposal area. The landfill was closed after implementation of new minimum functional standards for solid waste handling in Chapter 173-304 of the Washington Administrative Code (WAC). The ash landfill was closed by placing a two-foot-thick compacted clay cover over the incinerator ash and constructing a leachate collection drain along the west boundary of the landfill. Whatcom County Health Department approved that the landfill was closing by the November 27, 1989, regulatory deadline (WAC 173-304-400(3)(b)), such that the facility is not subject to landfill post-closure care and financial assurance requirements in the WAC 173-304 regulation. Subsequently, in 1990, Recomp constructed a low-permeability soil-bentonite slurry wall around the north, east, and south Site boundaries to prevent groundwater from migrating to the landfill in the shallow Sumas Outwash Sand formation in the upper terrace deposit. The outwash sand does not extend to the lower terrace deposit on the west side the Site.  

Recomp constructed a temporary ash storage facility during the development of new special incinerator ash management standards in WAC 173-306, which were implemented on May 31, 1990. Phase I and II storage cells were constructed on top of the closed ash landfill. The specified bottom liner for the ash storage facility includes an 80-mil, high density polyethylene (HDPE) geomembrane on top of the two-foot-thick compacted clay layer, overlain by 18 inches of compacted native soil and four inches of asphalt. The ash storage facility was specified to have a two-foot-high by two-foot-wide perimeter berm, constructed of compacted soil with a 2H:1V (horizontal to vertical) slope covered by an 80-mil HDPE geomembrane to prevent fluid movement through the berm.

Recomp staged incinerator ash in the ash storage area from 1989 to May 2, 1994, under permits issued by Whatcom County Health Department and Ecology. The permits required Recomp to perform regular monitoring of groundwater, surface water, and air in the vicinity of the solid waste facilities.

Recomp modified the existing leachate storage lagoon in the northwest corner of the Site in 1989. The new 55,000-gallon lagoon was specified with an 80-mil HDPE geomembrane over a two-foot compacted clay liner, with eight feet of freeboard. The lagoon receives water discharged from the leachate collection pipe installed along the west side of the ash landfill. Although the leachate pipe was originally intended to collect seepage water from the closed ash landfill, the slurry wall and paved surfaces inhibit lateral groundwater migration and surface water infiltration through the closed ash landfill. The slurry wall diverts groundwater within the Sumas Outwash Sand formation around the closed ash landfill, and the shallow groundwater west of the closed ash landfill likely infiltrates into the leachate collection pipe. Thus, the leachate discharge pipe may discharge limited amounts leachate from the landfill. The leachate storage lagoon water is pumped to the City of Ferndale wastewater treatment plant under a state waste discharge permit issued by Ecology.

Recomp entered into Consent Decree No. 96-2-01293-5 with Ecology on July 5, 1996. The Consent Decree required Recomp to dispose of the incinerator ash at the Roosevelt Regional Monofill landfill, permitted under WAC 173-306, in Klickitat County, Washington. The Consent Decree required Recomp to remove the Prior Production (i.e., ash generated between 1989 and May 2, 1994) from the ash storage facility by May 1, 2002. Following Ecology’s Notice of Completion letter, Ecology and Recomp filed a Joint Motion to Dismiss Consent Decree No. 96-2-01293-5 with Whatcom County Superior Court on May 15, 2001.

Recomp applied to Ecology’s Voluntary Cleanup Program on April 29, 2003, and requested a No Further Action (NFA) opinion to allow the site to be removed by Ecology’s Confirmed and Suspected Contaminated Sites List (CSCSL). Ecology provided an NFA opinion and removed the site from the CSCSL. The NFA opinion request included statements that:

• The Site was regulated by multiple authorities, including Whatcom County Health Department with Ecology oversight, the Northwest Air Pollution Authority, and water discharge permits from Ecology.
• The landfill provides long-term containment of the incinerator ash.
• There was no indication of releases from the landfill based on site investigations and 14 years of groundwater and surface water monitoring.
• The landfill leachate is discharged to the City of Ferndale wastewater treatment plant.
• A permitted waste transfer station continues to operate at the Site.
• A public participation grant was awarded to a concerned citizen group to investigate the facility and findings of state and federal investigations, which provided substantial publicity for public participation and involvement.

Ecology issued an NFA opinion on January 5, 2005. Ecology concluded that the release of lead and cadmium into soil no longer poses a threat to human health and the environment. Ecology’s NFA was granted for only the release identified in the April 29, 2003, letter.

Ecology granted the NFA under the State cleanup regulation, the Model Toxics Control Act (MTCA), however:

• Ash was disposed in a landfill permitted under WAC 173-301 (repealed in 1985) and WAC 173-304.
• Site investigations were performed for the landfill permit under WAC 173-304.
• The ash landfill was closed under WAC 173-304 without post-closure care and financial assurance requirements.
• Groundwater and surface water monitoring was performed in accordance with a Plan of Operation (Harper Owes, 1990) that satisfied WAC 173-304 during operation of the ash storage facility.

Under the MTCA framework, Ecology considered the release to be the landfilled ash material that contains lead and cadmium and the Remedial Action to be the landfill closure. The site investigation and monitoring reports do not reference a release of contamination from the landfill. Ecology’s NFA is subject to maintaining the restrictive covenant for the property.

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