Thursday, November 1, 2012

Around the Sound: K Ply cleanup process and schedule

By Rebecca Lawson, Regional Section Manager, Toxics Cleanup Program

Ecology is entering into an agreed order (legal agreement) with the Port of Port Angeles (port) for the K Ply cleanup site (also known as PenPly or Peninsula Plywood). The agreed order requires the port to do an interim action (partial cleanup), investigate the site, and evaluate options for cleanup.

Last week Ecology’s cleanup team held an open house about the site and comment period. The comment period continues through Nov. 19, 2012. Site manager Connie Groven gave this presentation at the open house. Community members have asked a number of questions about what’s involved in cleaning up a contaminated site and how the K Ply cleanup schedule will work.

How a contaminated site gets cleaned up

Cleaning up sites where toxics have polluted land and water is very complex. Cleanup activities at K Ply are governed by the Model Toxics Control Act (MTCA). MTCA, which was created by a citizens’ initiative that voters approved in 1988, has procedures for cleaning up contaminated sites so they are safe for human health and the environment. Sites are cleaned up in stages:
  • The remedial investigation & feasibility study (RI/FS) looks at the type and extent of pollution on the site and evaluates different cleanup options.
  • Ecology sometimes allows interim actions to partly clean up a site before the final cleanup plan is complete. Interim actions are done to correct a problem that may get worse, reduce a threat, or help complete the RI/FS.
  • The cleanup action plan (CAP) describes the cleanup methods and how they meet state standards. Ecology uses information from the RI/FS to select a cleanup action.
  • Cleanup removes contaminants from the site, contains them on the site, or treats them to make them less toxic.

K Ply cleanup timeline

We are using Lean processes in this cleanup. [You can read the MTCA Lean report here.] Lean goals include finishing the RI/FS process in two years and finishing cleanup in five years or less.

The K Ply agreed order does not set calendar due dates up front because all of the tasks build on previous tasks or milestones. For example, the first milestone is the port demolishing old mill structures. The port’s RI/FS work plan is due to Ecology 60 days after this. Based on the port’s current interim action work schedule, this means the port will likely send us their draft RI/FS work plan in August 2013.

After we review and approve the work plan, the port will do their RI/FS. We estimate that the port will collect data from November 2013 – February 2014 and submit their data and a draft RI/FS report in October 2014.

At each stage, the schedule includes time for:
  • Ecology staff to review the draft report and request any needed changes.
  • The port to make changes and submit a revised draft.
  • Ecology to review and approve the revised draft. By using Lean and working closely with the port up front, our goal is that, when we get to this stage, reports will not need more changes.
After we approve the RI/FS report, the port will develop a preliminary cleanup action plan. Ecology will then develop the final draft cleanup action plan and negotiate a new legal agreement for cleanup.

Following this schedule, we estimate that we will hold a public comment period on the RI/FS report, the draft cleanup plan, and new legal agreement in summer 2015. You can read the full schedule here on page 37.

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