Treoil Industries

Washington State Department of Ecology (Ecology) Toxics Cleanup Program (TCP), Hazardous Waste Program and Water Quality Program, have been working together with Whatcom County Health District in investigating the contaminants, and preventing more waste or junk cars from being brought to Treoil site (Site).

Ecology TCP has finalized a contract with consulting firm Haley & Aldrich (HA) to conduct a remedial investigation (RI) and feasibility study (FS) at the Site.

DRAFT Remedial Investigation Report (April 10, 2024)

Future Ecology TCP Public Participation
In the future, Ecology TCP will hold a public comment period on the Draft Remedial Investigation along with the Draft Feasibility Study and a Draft Public Participation Plan. Ecology TCP will review comments and respond accordingly before finalizing the documents. Ecology TCP will then propose a cleanup action and invite public review and comment on the Draft Cleanup Action Plan and any associated documents. 

EPA Cleanup Actions
One significant cleanup action taken at Treoil site is U.S. Environmental Protection Agency (EPA)’s second removal action, conducted in September and November 2022. 

EPA removed from the Site:

• 4,800 gallons of pumpable oily material
 • 3,316 tons of solidified material
 • 1,890 gallons of corrosive liquids
 • Eight cubic yards (CY) of solidified hazardous materials
 • 97,400 gallons of oily liquid from secondary containment
 • 18,000 gallons of hazardous liquid

In 2017, the U.S. Environmental Protection Agency (EPA) conducted an emergency removal site evaluation at the Treoil facility.  EPA staff then removed thousands of gallons of hazardous waste for safe disposal.  The EPA’s action, carried out in two phases, followed a site visit and administrative order to the site owner by the Washington Department of Ecology that raised concerns about how this material was being stored on the site.

EPA’s Treoil Industries Assessment and Emergency Removal Report (November 2017) reported the removal of:

• 6,750 gallons of crude glycerin
• 93,000 gallons of liquid tall oil and tall oil derivative wastes
• 275 tons of soil, sludge and debris
• 430 containers, 35 drums and 9 cylinders of hazardous chemicals
• 8 cubic yards of asbestos containing material

The Treoil Industries cleanup site is located in Whatcom County, northwest of the city of Ferndale.  The site was used historically for numerous industrial operations, primarily for processing tall oil (a byproduct of Kraft paper pulping processing), but also for refining biodiesel and other small-scale industrial ventures.  These industrial operations were concentrated on a 3.5-acre section of the total 34-acre site.

History & Environmental Investigations
Since the 1990s, numerous Ecology inspectors have visited the Treoil Industries site investigating environmental concerns.  

• Present:  Ecology programs continue to monitor site progress and compliance.
• 2017:  Ecology monitored site progress and found conditions were not in compliance with the enforcement order.  Due to concerns with imminent threats to human health and the environment, Ecology contacted the EPA for assistance.  See EPA Treoil Industries Webpage for response.
• 2015-2016:  Ecology’s hazardous waste program initiated enforcement action in the form of an Administrative Order and an Amended Administrative Order to the property owners as a result of non-compliance with the Dangerous Waste Regulations, Washington Administrative Code (WAC) Chapter 173-303.  Inspectors visited the site several times to note progress toward compliance.  During one of these visits, conducted jointly with Ecology’s water quality program, it was determined that the site met qualifications for an Industrial Stormwater General Permit: Treoil Industries Permit Number WAR303019.
• 2014:  Ecology received an additional formal complaint regarding the site.  Ecology and Whatcom County conducted an initial investigation and a dangerous waste compliance inspection identifying poor containment practices with waste and oily substances on the ground.
• 2006:  A multi-agency advisory visit provided technical assistance and identified numerous site concerns.
• 2000-2001:  Ecology and Whatcom County conducted a Site Hazard Assessment under the Model Toxics Control Act (MTCA). The site was listed on the Hazardous Sites List for confirmed contamination of soils with metals, petroleum hydrocarbon, and polycyclic aromatic hydrocarbons (PAHs).  The site was ranked through the Washington Ranking Method (WARM) with a score of “2.”  (Sites are ranked between 1 and 5, where “1” represents the highest level of risk to human and environmental health and a “5” the lowest.) 
  - The EPA also conducted a Removal Site Evaluation to determine potential threats of discharge to waters of the United States and did not find a threat at that time but made recommendations for cleanup.
• 1994:  Site placed on Ecology’s Confirmed and Suspected Contaminated Sites List.
• 1991:  Ecology issued a Notice of Violation for the discharge of spilled material to a drainage ditch that eventually leads to the Strait of Georgia.

• EPA removal action report (February 2023)
• Ecology RI work plan (June 2022)
• EPA Assessment and Emergency Removal Final Trip Report (November 2017) 
• Ecology Amended Administrative Order (September 2015) 
• Ecology Administrative Order (July 2015) 
• Ecology Compliance Inspection Report (October 2014)
• Ecology Initial Investigation Report (June 2014) 
• Ecology Compliance Inspection Report (August 2006) 
• Ecology Site Hazard Assessment (February 2001) 
• Ecology Site Inspection Summary (March 2000)