BURLINGTON NORTHERN (BN) OTHELLO SITE PROPOSED AMENDMENT TO CONSENT DECREE/CLEANUP ACTION PLAN

The State of Washington Department of Ecology is proposing to amend Consent Decree No. 97-2-00237-4 and the Cleanup Action Plan for the BN-Othello Site. Burlington Northern Santa Fe (formerly Burlington Northern Railroad Company) is referred to herein as BN. The Consent Decree is a legal document, prepared under the authority of the Model Toxics Control Act (MTCA), Chapter 70.105D RCW. The Consent Decree formalizes an agreement between Ecology and BN providing the remedial actions described in the Cleanup Action Plan (CAP) for the Othello Site.

The proposed amendment alters the Site boundary by removing the adjacent Les Schwab property from part of the Site. The soil in the Les Schwab property meets residential standards and is protective of human health and the environment.

This was determined by additional data collected for this property and implementation of Ecology’s Interim Total Petroleum Hydrocarbons (TPH) Policy Guidance.

Ecology invites your comments on the proposed Amendment to the Consent Decree/Cleanup Action Plan February 24, through March 25, 2000. The box at the right indicates where these documents may be found, how comments may be submitted and additional information obtained.

SITE HISTORY

The BN Othello Site (Site) is located in an industrial section of western Othello in Adams County, Washington. The Site is bordered by Broadway Avenue to the east, Main Street to the north, and by private properties (see Figure 1).

The railroad yard was built in 1908 by the Chicago, Milwaukee, St. Paul, and Pacific Railroad known collectively as Chicago-Milwaukee. The yard was used as a refueling facility for steam and electric locomotives. During the transition to diesel locomotives, the facility served primarily as a refueling stop. Diesel refueling was conducted by the Chicago-Milwaukee until 1980. In 1980, BN purchased the property and continued operations until 1982, when Site operations were suspended. BN still owns the yard and Washington Central Railroad currently uses it to load grains into railroad cars.

Investigation of Site conditions was initiated by BN in 1986. In 1991, BN entered into Agreed Order No. 91TC-E703 with Ecology. This Agreed Order provided for additional Site investigations, and subsequently implemented an interim action in 1992. The supplemental Site investigations showed that the majority of the Site contamination was related to elevated concentrations of total petroleum hydrocarbons (TPH) in soils, plus local occurrences of viscous Bunker- C type floating free hydrocarbon product. TPH contamination in the ground water was contained within the boundaries and within the perched aquifer only.

During the interim action, a total of 10,370 cubic yards of TPH contaminated soils were excavated from the Site and recycled by mixing it into asphalt. A ground water diversion system was installed to prevent further perching and contamination of the ground water. Ground water diverted upgradient of the Site was rerouted to the city sanitary sewer system under a State Waste Discharge Permit and continued until November 1997. Compliance monitoring performed after the interim action showed that TPH concentrations in the ground water are below the cleanup level of 1 mg/L.

In 1993, the Agreed Order was amended to complete a Remedial Investigation/Feasibility Study (RI/FS). The purpose of the RI/FS was to define the extent of soil and ground water contamination remaining after the interim action and to evaluate cleanup technologies appropriate for the Site.

The Remedial Investigation showed that residual TPH concentrations in soils exceeding the Method A cleanup level of 200 mg/kg were found outside of the excavated area. Contamination was found both on the surface at the western edge of the Site and underneath 7 feet of clean soils at the eastern edge of the Site. A portion of the contaminated soils found under clean soil at the eastern edge of the Site was inside the Les Schwab property (see Figure 1). Continued monitoring of the diverted ground water showed that ground water was no longer contaminated. The remaining risk at the Site was to human health from possible exposure to TPH remaining in the soils.

The Feasibility Study discussed and evaluated alternatives that would eliminate, reduce and/or control potential risks posed by the Site. A preferred cleanup action involving a combination of institutional controls, containment, and continued operation and maintenance of the interim actions was proposed.

CONSENT DECREE/ CLEANUP ACTION PLAN

The Cleanup Action Plan (CAP) specified soil capping, ground water diversion and monitoring, and institutional controls. Deed restrictions were required for the BN property. BN was also required to obtain an agreement with Les Schwab to implement the same deed restrictions for the contaminated area on their property.

In 1997, BN entered into the Consent Decree with Ecology to implement the actions identified in the Cleanup Action Plan. Soil capping, ground water diversion and institutional controls for the BN property were completed in 1998. However, BN was not able to obtain an agreement with Les Schwab to implement a deed restriction for the property. As required by the Consent Decree, BN was to prepare a focused Feasibility Study for the Les Schwab property that would evaluate alternatives to cleanup the property to residential levels. To prepare for the Feasibility Study, BN collected additional soil data for the Les Schwab property and implemented Ecology’s 1997 Interim TPH Policy Guidance.

Five soil samples from different soil borings were collected inside the Les Schwab property. Only one sample exceeded the Method A TPH cleanup level of 200 mg/Kg. The soil sample with TPH concentration greater than 200 mg/Kg was shown to be protective of human contact under a residential scenario and protective of ground water using the Interim TPH Policy Guidance. These results are discussed in the report "Data Collection and Cleanup Level Comparison, Les Schwab Portion of the Former Othello Railyard, Othello, Washington," October 7, 1998. Based on these results, no additional remedial action is necessary for the Les Schwab property.

PROPOSED AMENDMENTS TO THE CONSENT DECREE/CLEAN UP ACTION PLAN

TPH concentrations in the Les Schwab property meet the residential cleanup level under Ecology’s Interim TPH Policy Guidance. The proposed amendment to the Consent Decree and the CAP removes the Les Schwab property as part of the Site.

 WHAT HAPPENS NEXT?

Public comment on the proposed amendment to the Consent Decree/Cleanup Action Plan will be considered and the documents modified, if necessary. The amended Consent Decree will be filed in Superior Court, and Ecology will forward a notice to BN that the remedial activity required in the CAP, as amended, has been completed. Monitoring of ground water and maintenance of the asphalt cap will continue.

ECOLOGY WANTS YOUR COMMENTS!

This public comment period represents an opportunity to have your ideas and comments heard by Ecology. You may review and comment on the proposed Amendment to the Consent Decree/Cleanup Action Plan February 24, through March 25, 2000. The shaded box on page one indicates where these documents may be found, how comments may be submitted and additional information obtained. To review more detailed Site documents than those in the information repositories, contact Johnnie Harris at Ecology (509) 456-2751. Files may be reviewed at Ecology’s Spokane office Monday through Thursday 8-5 p.m. by appointment only.

Please submit written comments by March 25, 2000 to Dr. Teresita Bala, Site Manager, at the Ecology address listed in the box on page one. Ecology will review and respond to all written comments received and will revise the above documents, if necessary. A Responsiveness Summary will be prepared by Ecology and made available for public review at the repository locations. Updates of Site activities will be provided to those who submit comments or request to be placed on the Site mailing list