Georgia Pacific Corp Clear Lake

The Environmental Covenant has been removed from this Site. A comment period was held between July 17-August 13, 2015.

The property is located at 1283 Highway 9 in the Town of Clear Lake, Washington. The property occupies approximately 6.8 acres near the western side of Clear Lake, approximately 100 feet northwest of the shoreline. The Site lies at an elevation of approximately 50 feet above mean sea level, and is relatively flat, with approximately 12 feet of topographic relief. The property has been used for commercial purposes for approximately 66 years, primarily related to forestry. The northeastern corner of the Site was utilized as a tree nursery in the 1980s with a greenhouse, a pesticide/chemical mixing building, and a helicopter pad and hanger.
 
Since closure of the forestry operation, the property has been leased to a variety of commercial businesses. The property was utilized in the early 2000s as a storage area for Wise Mobile Home Repair and Sales, and as a staging area for I. Davis Construction. Ownership of the property was transferred from Georgia Pacific Corporation to Plum Creek, Inc. in 2002.
 
Chlordane was detected in October 1994 in the uppermost few inches of the soil in the southwestern and southeastern corners of the greenhouse. Georgia Pacific’s operating practices included the mixing and storage of chlordane pesticide in the storage building and application of the chlordane to tree seedlings in the greenhouse. Prior environmental assessments at the Site indicated that the use of chlordane in the greenhouse and mixing building resulted in dilute chlordane overspray and possibly rinse water from sprayers entering the Site drainage system. This discharge of chlordane caused contamination of the soil at locations along the drainage pipelines and at two drywells. Approximately 274 cubic yards of chlordane contaminated soil was excavated in March 1995 from around the drywell east of the mixing building and disposed at the Roosevelt County Landfill. The residual in situ concentrations of chlordane in this area were non-detectable or were less than the MTCA Method B soil cleanup level of 2.86 milligrams per kilogram (mg/kg) (Independent Remedial Action Report, dated June 6, 1996).
 
A subsurface investigation was performed in December 1996 and January 1997 along the drain lines that ran from the southeastern corner of the greenhouse and from the storage building to the former drywell. The drain line from the greenhouse collected runoff from the greenhouse floor and roof drains, while those from the storage building collected water from a sink and floor drain located there. Contaminated soil was removed from the greenhouse and the associated drain line trenches such that the residual in situ concentration of chlordane was non-detectable or less than the MTCA Method B soil cleanup level (Report of Greenhouse Cleanup, dated April 17, 2001).

Since 1995, ground water samples have been periodically collected and analyzed from shallow monitoring wells located on the Site and between it and Clear Lake. Ground water samples from only two of the monitoring wells (MW-1 and MW-3) have regularly contained chlordane, at concentrations ranging from 1.2 to 36 micrograms per liter (ug/L). MW2, MW-4, and MW-6 have also had previous chlordane detections above the ground water cleanup standard. The chlordane concentrations at MW-1 and MW-3 have generally tended to decrease or stabilize over time. The apparent direction of shallow ground water flow at the Site has consistently been to the northwest, away from Clear Lake, since the establishment of the complete monitoring network in 1998.
 
Since 1994, when Georgia Pacific began reviewing past operations at the Clear Lake Yard to identify potential past sources of environmental contamination on Site, it discovered several areas where hazardous constituents were present. Contaminated soil was excavated and removed from the Site so that the soil remaining at the Site did not contain hazardous constituents at concentrations exceeding MTCA Method B cleanup levels. Previous reports, including the original Independent Remedial Action Report and Report of Greenhouse Cleanup, and the FIRAR Addendum, document the cleanup of all known areas with contaminated soil at the Clear Lake Yard. In March 2000, Georgia Pacific conducted an invasive Site-wide search for other contaminated areas that had not been discovered (Report of April 2000 Ground Water Monitoring and Supplemental Geoprobe Investigation, dated December 6, 2000). The results of that exploratory investigation found no indication of undiscovered soil contamination at the Site. The removal of remaining plastic drain pipes and associated contaminated soil was completed in the spring of 2001. Therefore, the consultant concluded that contaminated soil at the Clear Lake Yard has been fully remediated.
 
Surface water and sediment sampling was conducted in Clear Lake, which is located approximately 100 feet southeast of the subject property. The analytical results indicated non-detectable concentrations of chlordane in the surface water and sediments of the lake. Ground water samples from MW-7, which is located between the Clear Lake Yard and the lake, have had non-detectable concentrations of chlordane (< 0.002 ug/L) for the history of the sampling program at that well (October 1998 through 2010). In addition, the measured ground water gradient has been to the northwest, away from the lake, during 12 of the last 17 monitoring events. These data indicate that surface water and sediments in Clear Lake have not been impacted by the historic chlordane contamination documented at the Site.
 
Groundwater samples from two specific locations of the Site (MW-1 and MW-3) have consistently contained concentrations of chlordane which exceed the MTCA Method B cleanup level for ground water. Both of these wells are located adjacent to the former dry wells where chlordane contaminated soil was excavated and removed from the Site. Analytical results for filtered samples obtained in December 2002 indicate that the detected chlordane is likely associated with fine soil particles which remain in suspension in those wells, and is not soluble chlordane. The other monitoring wells at the Site, MW-2, MW-4, MW-6, MW-7 and the former MW-5 are located in upgradient and downgradient positions relative to the affected MW-1 and MW-3. Groundwater samples from these wells have historically had isolated or no detections of chlordane but all have had non-detectable concentrations of chlordane (< 0.06 ug/L) in the quarterly sampling events which occurred until 2003. Based on the documented contamination source removal from the Site and water quality results the consultant concluded that chlordane detections in MW-1 and MW-3 are isolated and relatively immobile. Also, the analytical chromatograms of the contaminated groundwater samples indicate that the detected chlordane has degraded significantly. It was anticipated that the residual chlordane in MW-1 and MW-3 will continue to degrade until it is no longer detectable, or below the cleanup level.

Ecology agreed with the assessment of protectiveness and issued a ‘No Further Action’ letter July 13, 2004 after a restrictive covenant was recorded with the county; however, confirmational groundwater monitoring was required. Sampling events every two years since 2004 have shown only a moderate decline in chlordane levels in MW-1 and MW-3, and the levels still exceed MTCA Method B; furthermore, MW-3 appears to be outside the property limits. This remedy in its present form, with an institutional control (covenant) on the former Georgia Pacific parcel, but none on the parcel between there and the surface water, is incompatible with regulatory requirements for conditional points of compliance of groundwater contamination.