INDEPENDENT CLEANUP PATHWAY REPORT FORMER GEORGIA-PACIFIC CHEMULT

ECSI 2877

Prepared for GREEN DIAMOND RESOURCE COMPANY August 4, 2015 Project No. 1012.01.04

Prepared by Maul Foster & Alongi, Inc. 2001 NW 19th Avenue, Suite 200, Portland OR 97209

INDEPENDENT CLEANUP PATHWAY REPORT FORMER GEORGIA-PACIFIC CHEMULT ECSI 2877 The material and data in this report were prepared under the supervision and direction of the undersigned.

MAUL FOSTER & ALONGI, INC.

______Caitlin Borbely Environmental Professional

______Steven P. Taylor, PE Principal Engineer

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE II CONTENTS

ILLUSTRATIONS IV ACRONYMS AND ABBREVIATIONS V SUMMARY VI 1 INTRODUCTION 1 1.1 PROJECT OVERVIEW 1 1.2 PURPOSE AND OBJECTIVES 1 2 SITE BACKGROUND 1 2.1 SITE LOCATION 1 2.2 SITE BACKGROUND, SITE HISTORY, AND FACILITY OPERATIONS 1 2.3 REGULATORY HISTORY 2 2.4 PREVIOUS INVESTIGATIONS 2 3 CONCLUSION 3

LIMITATIONS

REFERENCES

FIGURES APPENDIX A HISTORICAL AERIAL IMAGES APPENDIX B DEQ FILE REVIEW DOCUMENTATION APPENDIX C SITE PHOTOGRAPHS

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE III ILLUSTRATIONS

FOLLOWING REPORT:

FIGURE

1 PROPERTY LOCATION

2 PROPERTY OVERVIEW

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE IV ACRONYMS AND ABBREVIATIONS

DEQ Department of Environmental Quality (Oregon) ECSI Environmental Cleanup Site Information Database ESA Environmental Site Assessment Green Diamond Green Diamond Resource Company ICP Independent Cleanup Pathway MFA Maul Foster & Alongi, Inc. NFA No further action

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE V

SUMMARY

This summary is not intended as a stand-alone document and must be evaluated in context with the entire document.

This Independent Cleanup Pathway (ICP) report was prepared by Maul Foster & Alongi, Inc. (MFA) on behalf of Green Diamond Resource Company (Green Diamond) for the site located at a latitude and longitude of approximately 43.2225°, -121.7769° in township 27 south, range 8 east, section 21 of the Willamette Meridian (the Property). Green Diamond recently purchased this property and would like to address the Oregon Department of Environmental Quality (DEQ) listing in the Environmental Cleanup Site Information database. Green Diamond has entered the ICP program to achieve a No Further Action (NFA) determination for the Property. This report documents that the NFA determination is applicable to the Property.

A Phase I Environmental Site Assessment (ESA) was completed by MFA in September of 2014 prior to purchase of the Property by Green Diamond. The Phase I ESA was conducted as per the American Society for Testing and Materials Standard Practice E2247-08, and the “all appropriate inquiries” standard under Comprehensive Environmental Response, Compensation and Liability Act in 40 CFR Part 312. The Property is managed as timberland and very little remains to identify that the area was potentially a former mill site. The Phase I ESA found no indication of significant data gaps, de minimis or recognized environmental conditions (current, historical, or controlled). No unacceptable risk to human health or the environment was identified at the Property.

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE VI

1 INTRODUCTION

1.1 Project Overview This Independent Cleanup Pathway (ICP) report was prepared by Maul Foster & Alongi, Inc. (MFA) on behalf of Green Diamond Resource Company (Green Diamond). Green Diamond recently purchased this property and would like to address the Oregon Department of Environmental Quality (DEQ) listing in the Environmental Cleanup Site Information (ECSI) database.

1.2 Purpose and Objectives Green Diamond has entered the ICP program to achieve a No Further Action (NFA) determination for the property. This report documents that the NFA determination is applicable to the property as it does not pose a risk to human health or the environment.

2 SITE BACKGROUND

2.1 Site Location The “Georgia Pacific – Chemult” site as it is referred to in the ECSI database is located at a latitude and longitude of approximately 43.2225°, -121.7769° in township 27 south, range 8 east, section 21 of the Willamette Meridian (the Property). The Property is located within Green Diamond’s Chemult block, a tract of timberland which includes approximately 44,140 acres. The Property is surrounded by forestland with the nearest development (the outskirts of Chemult) nearly 2,000 feet to the west. Other than the small community of Chemult the area consists largely of undeveloped forestland.

2.2 Site Background, Site History, and Facility Operations Little is known about the operational history of the reported mill. Weyerhaeuser, a former owner of the Property is not known to have operated a mill site in this location. This property was later sold to JWTR1 who recently sold it to Green Diamond, neither of whom utilized this portion of land as anything but timberland. Through multiple lines of research no information was identified that substantiated this location as a former lumber mill other than notation of the site within the 1986 DEQ Anti-Sapstain report2 (included in Appendix B). The DEQ Anti-Sapstain report appears to be

1 JWTR Oregon, LLC or JWTR Timber Holdings, Inc. formerly Jeld-Wen Timber Holdings, Inc. 2 Oregon Department of Environmental Quality, An Inventory of Wood Anti-Sapstain Treatment and Preservation in Northwester and Central Oregon. September, 1986. R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE 1

the supporting documentation that prompted the listing of the Property in the ECSI database. The notation in the DEQ Anti-Sapstain report indicates that a lumber mill reportedly existed at or near this location but does not identify that wood treating occurred as part of former operations.

Historical aerial photographs of the Property from 1953, 1963, 1967, 1976, 1982, 1994, and 2000 were obtained from U.S. Geological Survey and were reviewed to observe historical changes to the Property and the Property’s historical uses, if any (see Appendix A3). These aerial images depict what appears to be a mostly undeveloped property, other than the road/railroad spur, in 1953. The images from 1963, 1976 and potentially 1982 appear to show the Property as an approximately 19 acre clearing with a large stockpile which is assumed to be wood chips. Buildings or structures are not visible in any of the images. Based on the observations from these aerial photographs the Property may have been used as a wood chipping and loading yard from the early 1960’s through the early 1980’s.

2.3 Regulatory History This Property appears to have been added to the ECSI database for tracking as a former lumber mill based on a notation in the 1986 DEQ Anti-Sapstain report. No other information is available online. Through a public information request, DEQ’s file4 on the Property was requested. A response from DEQ verified that there is no file for the Property. The 1986 DEQ Anti-Sapstain report was obtained from DEQ and reviewed. The name of the site is presented in this report within a list of facilities (current and former), but no other pertinent information was identified (Appendix B).

2.4 Previous Investigations A Phase I Environmental Site Assessment (ESA) was completed by MFA in September of 2014 prior to the purchase of the Property by Green Diamond. The Phase I ESA was conducted as per the American Society for Testing and Materials Standard Practice E2247-08, and the “all appropriate inquiries” standard under Comprehensive Environmental Response, Compensation and Liability Act in 40 CFR Part 312. The Property is managed as timberland and very little remains to identify that the area was potentially a former mill site. The Phase I ESA found no indication of significant data gaps, de minimis or recognized environmental conditions (current, historical, or controlled). Two heavily rusted drums, which appear to have been approximately 55-gallon drums in size, were observed at the Property near a camp fire ring. These drums appear to have been used for target practice and may not have originated on the Property. Some railroad ties and what appears to be a former rail road grade were also observed on the Property. No structures (current or historical) or stained soil were observed on the Property. Photographs from the site reconnaissance visit are included in Appendix C.

3 The ECSI site is depicted in the approximate center of each aerial photograph. 4 The DEQ file was requested on June 18th, 2014. R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE 2

3 CONCLUSION

As noted above, the Property is managed as timberland and very little remains to identify that the area was potentially a former mill site. The Phase I ESA found no indication of significant data gaps, de minimis or recognized environmental conditions (current, historical, or controlled). No unacceptable risk to human health or the environment was identified at the Property and thus a no further action determination is warranted.

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx PAGE 3

LIMITATIONS

The services undertaken in completing this report were performed consistent with generally accepted professional consulting principles and practices. No other warranty, express or implied, is made. These services were performed consistent with our agreement with our client. This report is solely for the use and information of our client unless otherwise noted. Any reliance on this report by a third party is at such party’s sole risk.

Opinions and recommendations contained in this report apply to conditions existing when services were performed and are intended only for the client, purposes, locations, time frames, and project parameters indicated. We are not responsible for the impacts of any changes in environmental standards, practices, or regulations subsequent to performance of services. We do not warrant the accuracy of information supplied by others, or the use of segregated portions of this report.

The purpose of an environmental assessment is to reasonably evaluate the potential for or actual impact of past practices on a given site area. In performing an environmental assessment, it is understood that a balance must be struck between a reasonable inquiry into the environmental issues and an exhaustive analysis of each conceivable issue of potential concern. The following paragraphs discuss the assumptions and parameters under which such an opinion is rendered.

No investigation is thorough enough to exclude the presence of hazardous materials at a given site. If hazardous conditions have not been identified during the assessment, such a finding should not, therefore, be construed as a guarantee of the absence of such materials on the site.

Environmental conditions that cannot be identified by visual observation may exist at the site. Where subsurface work was performed, our professional opinions are based in part on interpretation of data from discrete sampling locations that may not represent actual conditions at unsampled locations.

Except where there is express concern of our client, or where specific environmental contaminants have been previously reported by others, naturally occurring toxic substances, potential environmental contaminants inside buildings, or contaminant concentrations that are not of current environmental concern may not be reflected in this document.

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Rf_ICP Report - Georgia-Pacific Chemult.docx

FIGURES

Figure 1 Property Location

Green Diamond Resource Company Klamath County, Oregon Path: X:\1012.01 Green Diamond\ICP Reports\Fig1_Property Location Georgia Pacific.mxd

Georgia Pacific - Chemult Print Date:6/9/2015

Note: Georgia Pacific - Chemult is located in Township 27 South, Range 8 East, Section 21 of the Wil lamette Meridian.

0 1,500 3,000 Approved By: C. Borbely

Feet

Source: Topographic map obtained from Esri, ArcGIS Online Produced By: cborbely

p. 971 544 2139 | www.maulfoster.com

This product is for informational purposes and may not have been prepared for, or be suitable for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. Project: 1012.01.04 Figure 2 Property Overview

Green Diamond Resource Company Klamath County, Oregon

Georgia Pacific - Chemult Path: X:\1012.01 Green Diamond\ICP Reports\Fig2_Property Overview Georgia Pacific.mxd Print Date:6/9/2015

Note: Georgia Pacific - Chemult is located in Township 27 South, Range 8 East, Section 21 of the Wilamette Meridian.

0 150 300 Approved By: C. Borbely

Feet

Source: Aerial image obtained from Esri, ArcGIS Online Produced By: cborbely

p. 971 544 2139 | www.maulfoster.com

This product is for informational purposes and may not have been prepared for, or be suitable for legal, engineering, or surveying purposes. Users of this information should review or consult the primary data and information sources to ascertain the usability of the information. Project: 1012.01.04 APPENDIX A HISTORICAL AERIAL IMAGES Historical Aerial Photographs Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

7/19/1953

8/1/1963

Historical Aerial Photographs Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

7/22/1967

7/30/1976

Historical Aerial Photographs Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

9/8/1982

8/29/1994

Historical Aerial Photographs Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

7/28/2000

APPENDIX B DEQ FILE REVIEW DOCUMENTATION

Oregon DEQ: Full Details Environmental Cleanup Site Information (ECSI) Database Page 1 of 3

Protecting Oregon's Environment About DEQ | Contact DEQ | Sitemap | Feedback | DEQ Search

Oregon Department of Environmental Quality

Projects and Programs Publications and Forms Laws and Regulations Public Notices Permits and Licenses Databases/GIS DEQ Home | Divisions | Regions | Commission

Land Quality

Environmental Cleanup

DEQ Home > Land Quality > Environmental Cleanup > ECSI > Site Summary Full Report

Environmental Cleanup Site Information (ECSI) Database Site Summary Full Report - Details for Site ID 2877, Georgia-Pacific - Chemult

This report shows data entered as of June 18, 2014 at 2:07:00 PM

This report contains site details, organized into the following sections: 1) Site Photos (appears only if the site has photos); 2) General Site Information; 3) Site Characteristics; 4) Substance Contamination Information; 5) Investigative, Remedial and Administrative Actions; and 6) Site Environmental Controls (i.e., institutional or engineering controls; appears only if DEQ has applied one or more such controls to the site). A key to certain acronyms and terms used in the report appears at the bottom of the page.

Go to DEQ's Facility Profiler to see a site map as well is information on what other DEQ programs may be active at this site.

General Site Information Site ID: 2877 Site Name: Georgia-Pacific - Chemult CERCLIS No: Address: Hwy 97 & Forest Service RD 286 Chemult 97731 County: Klamath Region: Eastern Other location information: Investigation Status: Suspect site requiring further investigation Brownfield Site: No NPL Site: No Orphan Site: Study Area: No No Property: Twnshp/Range/Sect: 27S , 8E , 21 Tax Lots: Latitude: Longitude: Site Size: 62 acres 43.2225 deg. -121.7769 deg. Other Site Names: Site Characteristics General Site Description: Site History: Contamination Information: (1/18/01 DMC/SAS) Site added to database for tracking purposes. Manner and Time of Release: Hazardous Substances/Waste Types:

http://www.deq.state.or.us/lq/ECSI/ecsidetailfull.asp?seqnbr=2877 6/18/2014 Oregon DEQ: Full Details Environmental Cleanup Site Information (ECSI) Database Page 2 of 3

Pathways: Environmental/Health Threats: Status of Investigative or Remedial (1/18/01 DMC/SAS) Site added to database for tracking Action: purposes. Data Sources: 1. Anti-Sapstain Report (9/86). Substance Contamination Information Substance Media Contaminated Concentration Level Date Recorded No information is available Investigative, Remedial and Administrative Actions Action Start Date Compl. Resp. Staff Lead Date Pgm Site added to database 01/18/2001 Daniel SAS Crouse Site Screening recommended (EV) (Primary 01/18/2001 01/18/2001 Daniel SAS Action) Crouse

Key to Certain Acronyms and Terms in this Report:

CERCLIS No.: The U.S. EPA's Hazardous Waste Site identification number, shown only if EPA has been involved at the site.

Region: DEQ divides the state into three regions, Eastern, Northwest, and Western; the regional office shown is responsible for site investigation/cleanup.

NPL Site: Is this site on EPA's National Priority List (i.e., a federal Superfund site)? (Y/N).

Orphan Site: Has DEQ's Orphan Program been active at this site? (Y/N). The Orphan Program uses state funds to clean up high-priority sites where owners and operators responsible for the contamination are absent, or are unable or unwilling to use their own resources for cleanup.

Study Area: Is this site a Study Area? (Y/N). Study Areas are groupings of individual ECSI sites that may be contributing to a larger, area-wide problem. ECSI assigns unique Site ID numbers to both individual sites and to Study Areas.

Pathways: A description of human or environmental resources that site contamination could affect.

Lead Pgm: This column refers to the Cleanup Program affiliation of the DEQ employee responsible for the action shown. SAS or SAP = Site Assessment; VCS or VCP = Voluntary Cleanup; ICP = Independent Cleanup; SRS or SRP = Site Response (enforcement cleanup); ORP = Orphan Program.

For more information on this site contact the Eastern regional office.

[print version]

For more information about ECSI call Gil Wistar at 503-229-5512 or email.

For more information about DEQ's Land Quality programs, visit the DEQ contact page. Oregon Department of Environmental Quality Headquarters: 811 SW Sixth Ave., Portland, OR 97204-1390

http://www.deq.state.or.us/lq/ECSI/ecsidetailfull.asp?seqnbr=2877 6/18/2014 Oregon DEQ: Full Details Environmental Cleanup Site Information (ECSI) Database Page 3 of 3

Phone: 503-229-5696 or toll free in Oregon 1-800-452-4011 Oregon Telecommunications Relay Service: 1-800-735-2900 FAX: 503-229-6124

The Oregon Department of Environmental Quality is a regulatory agency authorized to protect Oregon's environment by the State of Oregon and the Environmental Protection Agency.

DEQ Web site privacy notice Projects and Programs Publications and Forms Laws and Regulations Public Notices Permits and Licenses Databases/GIS About DEQ | Contact DEQ | Sitemap | Feedback | DEQ Search

http://www.deq.state.or.us/lq/ECSI/ecsidetailfull.asp?seqnbr=2877 6/18/2014 OREGON DI:Pi\IHWN! flli ENVIflONMENTi\L Qlli\U I Y i,llill!ii!'(

00001862

AN · INVENTORY\'Qf•,,•\.- __,o_ ..: .... ·,

IN NOR'ffiWEST AND CEN'fllAI. OREGON. · ··

,;

Christopher P. Webber,

., Wood Preservation Teclulie~an:..., .. · \ State of Oregon Department of Environmental Quality

September, 1986

\' I ·-·~:.;,.__ • J ( EXECUTIVE SUM>lARY \

Current and past users of wood sapstain control chemicals and preservatives in northwestern and central Oregon were surveyed by DEQ to inventory the types of chemicals used, the systems that apply them, disposal of waste by-products, and look for signs of possible environmental contamination. Attempts were made to contact a total of 338 sites which were in some sort of wood products manufacturing. Forty currentlyuse wood preservatives and twelve are past users. Fifty six sites have. gone out of business and were impossible to contact. Nine of the sites inspected Nere given ratings 1vhich indi'tate they need corrective action with respect to their anti-stairi"chemical handling practices. Narratives of these sites, and all the sites· inspected\~hich \. do not need corrective action, are in the results section -6£ tM report. l ) TABLE OF CONTENTS DESCRIPTION PAGE

INTRODUCTION AND BACKGROUND .. 1

Purpose ~ . ~ . . . . ~ ...... 1 \'/hat is anti-stain? •••.•.•...••. ·. • . . • . • I Procedure . • . . • . . . 2 Organization of findings 3

STATEWIDE GENERAL COMMENTS 3 Chemicals in use . . . 4 Methods of application 4 \'laste disposal . • . . 5 Priorities for further inspection 6

StJ!,f.IARY OF FINDINGS • • • • • 0 • 8

1'/ILLAMEITE VALLEY REGION FINDINGS 11

Chemicals used • • . . • . . . 11 Application methods • . . . . 11 \'/aste disposal • . . . • . . . Priority for further inspection u Site narratives ..• 12

NORTI!I'/EST REGION FINDINGS • • • • • 20

Chemicals used . . . 20 Application methods 20 \'/aste dispos~l • . . 21 Priority for further inspect ion 21 Site narratives .. 21

CENTRAL REGION FINDINGS 25 Chemicals used . • . . . . • . . 26 Application methods . . • • . . 26 Waste disposal . . . . • . • . • 27 Priority for further inspect ion , 27 Site narratives • . . . . . • . • • . • • . . • . . . . . 27

APPENDICES 1. Glossary ...... A-1 2. Sites contacted . • . . . . . • ...... • A-3 ( 3. Map of DEQ Reg ions ...... • . . . . . • . . . • • A-10 .... 4. Best Management Practices . . • . . . . • . . A-ll 5. 1'/aterways near medium and high priority sites A-16 6. Survey inspect ion forms ...... , . • A-17 INTRODUCTIO!'I AND BACKGROUND

Purpose

The purpose of this project has been to inventory and catalog all users of wood sapstain control chemicals in the northwestern and central parts of the state. of Oregon. · This report addresses such matters as the types of chemicals used, the systems that apply them, disposal of waste by-products, and possible environmental contamination. This study is not intended to be comprehensive in all these aspects. Rather, this has been a survey of many wood products manufacturers to compile data regarding current and past practices of anti-stain chemical handling. The essence of this project has been to get in, rapidly survey thos.e

facilities which have used anti-stain chemicals, and move on to the next sit~. This study has been approached primarily from the standpoint of a water quality project, The matters of hazardous waste disposal and worker safety are secondary considerations. Funding for this project has been provided in part by the EPA, with the remainder coming from Regional Operations of the UEQ.

What is anti-stain?

Non-kiln dried pine, fir, and hemlock are subject to discoloration when exposed to any rlegree of moisture. Dark.streaks which appear are due to staining of the sap in these woods, typically caused by fungus. It is common practice in the wood products industries to treat 1·;ood with various pesticides to inhibit the occurrence of sapstaining. Nearly all export lumber is treated with anti-stain.

l Lumber is most commonly the wood product which is treated, though ( anti-stain use has been seen with window frames, some veneers, and cedar ~ shingles. In these latter cases, the treatment is done more for prese·rvat ion than sapstain control. The Department of Environmental Quality first became aware of the widespread use of anti-stain chemicals as the result of a 1500 gallon spill into Coos Bay, Oregon in 1981 by a major wood products manufacturer. Until recently, the only common chemicals for sapstain control were either penta- or tetracl1lorophenol. These were originally developed as pesticides. Hence, they are quite toxic, particularly to aquatic life. To make matters worse, the industrial grades of penta- or tetrachlorophenol contain up to ten percent impurities. Though most of these impurities are lower chlorinated phenols, the remainder includes phenoxyphenols, various dioxins, and furans.

Procedure

The geographical areas of interest in this survey are the DEQ's Willamette Valley Region (1'/VR), Northwest Region (N\'IR), and Central Region (CR). !he Willamette Valley Region consists of Benton, Lane, Lincoln, Linn,

Marion, Polk and Ya~1ill counties. The Northwest Region consists of

Clackamas, Clatsop, Columbia, ~1ultnomah, Tillamook, and Washington counties. The Central Region consists of Crook, Deschutes, Harney, Hood River, Jefferson, Klamath, Lake, and li<>.sco counties. Wood products manufacturers in these areas were contacted by phone. All kn01.m current or past users of anti -stain chemicals received field surveys. Data was taken on standardized survey forms. Aftemards, all mill ope rat ions ( inspected were mailed copies of the survey form. Those who indicated that ""- they never had used anti-stain were recorded on a list but not inspected.

2 The inspections performed were all visual. No laboratory samples were ( taken. Direct discharges to surface water would have merited water sampling, \ but none were observed. Typically, anti-stain application systems, mixing equipment, storage areas, and the transport routes of treated lumber were observed.

Organization of findings

The first section of the findings presents the statewide general comments. These comments are non-specific in nature with regard to any mill operator or site. They identify general tendencies or problems seen throughout the wood products industries that were inspected. Detailed comments about sites are next. Sections for the different DEQ regions are presented in chronological order of inspection.

The second section of the findings presents those specific to the l'NR, This includes individual narratives of all the 1'/VR sites inspected and makes recommendations 'for particular sites with apparent problems. The third section of the findings presents those from the NWR. Again, individual site narratives are included and corrective actions for particular mills are recommended. The final section of the findings contains comments from the CR. It is arranged in the same manner as the findings for WVR and NWR.

STATEWIDE GENERAL CQ\~ffiNTS

There were 53 sites inspected all together. Forty currently use anti-stain chemicals and 13 are past users. Attempts were made to contact a ( total of 338 sites, however 56 of these sites have gone out of business and were otherwise impossible to contact. The remainder of the sites indicated ( that they had never used anti-stain chemicals, and were not inspected. "'

Chemicals in use

A wide variety of sapstain control chemicals and wood preservatives have been seen in use. The vast majority of users are still applying some sort of chlorinated phenol, either pentachlorophenol (penta or PCP), or tetrachlorophenol (tetra or TCP). Concern over the toxicity of chlorinated phenols has caused several manufacturers to switch to chemicals that use other agents as active ingredients. Alternatives seen so far include Copper-8 quinolinolate, zinc naphthenate, tributyltin oxide, 3-Iodo-2 Propynyl-Butyl- Carbamate, polyphase, and an acrylic latex sealer with a sodium salt of mercaptobenzothiozole or 2-(Thiocyanomethylthio)benzothiazole. It is also important to note that the anti-stain chemical market is changing rapidly, with several new chemicals coming on the market while others are removed from the market. There is currently a study in progress regarding the effectiveness of

various anti-stain chemicals. It is being performed by Donald J. Miller, a professor in Oregon State University's Department of Forestry. Chlorophenols and their alternatives are the subjects of this study, and most mill operators would be very interested in seeing the results.

Methods of application

There have been four methods of anti-stain application seen in the areas inspected so far. 1'he most common is the spraybooth method, folloHed by dip

4 tanks and greenchain dip systems. Simply spraying the solution ~ith garden ( hoses or watering cans was fairly common in the past, but only two of the { sites inspected continue to use this practice. Wood pressure treating operations were not considered in this project. It has been fairly common to find more than one application system at a particular site. For the most part, one system would be used the majority of the time, and the others only occasionally. Up to four different systems have been seen at one location, but most sites 1vith more than one system usually only have two.

·waste disposal

\~ood debris saturated with anti -stain chemicals is a common by-product of any treating operation. This debris typically ranges from the size of sawdust to up to several inches long, and either accumulates as a sludge or is removed from the system by filtration of a recirculation stream. It is critical to note that the waste generation rates reported on the survey questionnaires are generally rough approximations, at best. Common disposal sites or methods include licensed hazardous waste disposal sites (namely Arlington), local garbage landfills, 1voodwaste landfills, burning in hogged fuel boilers, and mixing with uncontaminated chips for sale. It is important to note that not all of these methods are legal if the material can be classified as hazardous waste. This determination is made by performing an LC 50 aquatic toxicity test on the debris. Sludges or filtered debris from dip tanks or filtered debris from spraybooth recirculation systems has so far been shown as hazardous waste ( where chlorophenols are used. However, planer shavings from wood treated with \. chlorophenols has not. Naturally, this is entirely dependent upon the concentration of the chlorophenols in the debris, Hhich is influenced by many

5 factors. The non-chlorophenols must be considered on a case by case basis,

( due to their wide variety. ( Only 17 of the 40 current anti-stain users contacted send their Hastes

to Arlington, and. these tend to be the larger operations. Given the paperwork

involved in registering and shipping, small operations are naturally going to

avoid this procedure as long as possible.

The smaller mills that burn their waste or' send it to sanitary landfills seem to lack complete knowledge of hazardous waste disposal rules. It is

recommended that a simple, easy to read summary be created that explains to

mill operators that they may need to have their waste management practices

reviewed. This could include generation rates, disposal methods, and whether

or not their wastes are hazardous. The need may exist for a mill operator to

hire an expert consultant for this.

More information is needed about burning debris saturated wi.th the

various chemicals or sending it to landfills. Burning debris saturated with

chlorophenols may generate hazardous combustion products. However, not much

is known about the combustion products of wood debris saturated with the

non-chlorophenol control agents. As far as landfilling these types of debris

is concerned, a good lmrd look needs to be taken at the effects of placing

these chemicals (and their impurities) in landfills intended for household

refuse.

A survey dedicated to lvaste disposal, combined with an informational program to get small mills up to standard on this subject, could be a

worthwhile project for the summer of 1987.

Priorities for further inspect ion

Sites tlmt appear to be contaminating the environment lvill be

6 reinspected at a more detailed level than visual. Soil and/or water samples will be taken. All sites inspected received a low, medium, or high priority for a further inspection such as tllis.

These priorities were assigned with respect to either surface Hater impacts or ground1-1ater impacts and are outlined below.

Surface water impacts Low: The facility is geared to the best management practices. (See

appendix.) The facility appears acceptable, with no indication of past

problems. No further work is needed.

!.tedium: Facility needs some upgrading to llMP, but there are no

indications of pesticides entering surface waters.

High: Facility needs upgrading to Bi>IP. Chemicals have been definitely

released to surface waters.

Groundwater impacts

Low: Facility is geared to ll~IP and appears acceptable, with no

indication of past problems. No further work is needed.

Medium: Facility needs some upgrading to llMP, but no obvious indication

of soil or ground~;ater contamination nas taken place.

High: Facility needs upgrading to BMP. There are visual signs of soil

contamination or groundwater samples have confirmed contamination.

7 The matter of waste disposal was not taken into account when assessing these priorities. Hence, there are a few cases where a low priority site is disposing of its waste in a manner wl1ich could be improved upon. For details on how a particular site disposes of waste, see the individual site narratives in the sections on WVR, NWR and CR;

SUMMARY OF FINDINGS

The following charts contain summarized results of the findings for all sites inspected. Indicators are given for chemicals and application systems used, waste dispo.sal methods, and priorities for further inspection. The indicators are explained below.

Chloro - chlorophenol C-8 - copper-8 ( Busan - Busan 1030 ZN - zinc naphthenate Dip - dip tank Spray - spraybooth Green - greenchain dip system LF - permitted landfill HWDS - hazardous waste disposal site Burn - burned in boiler. Other - see individual site narrative for details

8 ( • li'ILLAMETIE VALLEY REGION SU1•MARIZED FINDINGS

i·c~;;;;;-u;;;;::: ______l_~:~--1-===~-1-~:: ___ 1_:~''·:-1

.Swanson Brothers, Noti I Chloro Dip I Other I High I I Clear Lumber, Sweet Home Chloro Other I None I Med I Peak Lumber, Philomath Chloro Spray I Sold I Med 1' I Starfire Lumber, Cottage Grove Chloro Dip I Other I Med 1· I Zip-0-Logs, Eugene Chloro Green Other Med I Bohemia, Inc., Coburg Chloro Dip I HWDS i Low I I Bohemia, Inc., Culp Creek Chloro Dip I HWDS I Low I I Bohemia, Inc., Saginaw Chloro Dip I HWDS I Low I I Cedar Lumber, Lyons Chloro Spray I LF I Low I I Clark & Powell Lbr. , Junct. City Chloro Spray I Burn I Low I i Columbia Millwork, Salem Chloro Dip I LF I Lm; I I Davidson Industries, Tiernan Chloro Spray I Burn I Low I I Fort Hill Lbr. , Grand Ronde Chloro Spray I LF I Low I I Mountain Fir Lbr., Independence Chloro Spray I Sold I Low I I Ostrom Lumber, Pedee I Chloro Spray I Burn I Low I !.Pope &Talbot, Oakridge I Chloro Dip I HWDS I Low I I Seneca Sawmill, Eugene I C-8 Spray I LF I Low I I Smurfi t Corp, Toledo I Chloro Dip I Hl'IDS I Low I I Taylor Lumber, Sheridan I Pro-Tek+ Spray I Burn I Low I I Weyerhaeuser, Cottage Grove I Nuodex 84 Spray I Hl-IDS I Lm< I i Weyerhaeuser, Springfield I Chloro Dip I Hl'IDS I Low I I Willamette Ind., Bauman I ZN Spray I Hl'IDS I Low I I liillamette Ind., Sweet Home I ZN Spray I Hl'IDS I Low I I Willamina Lumber, 1

9 r NORTHWEST REGION SUMMARIZED FINDINGS ' ·------~-~;~;-u;;;;~~------1-~~~--j-=:::"".j-~~~---i-~'~~~:-j

Forest Grove Lumber, Forest Grove C-8 I Spray I Burn I Med I I Alder Creek Lumber, Portland Chloro I Spray I LF I Low I Ayison Lumber, Molalla Chloro I Dip I HWDS I Low I Brazier Lumber, Molalla Chloro Green I HWDS I Low I Smurfit Newsprint Corp., Molalla Chloro Dip I Hl~ns Low I Smurfit, Oregon City Chloro Dip HWDS I Low I Smurfit, Tillamook Chloro Spray I HWDS I Low I I Vanport Manufacturing, Boring Chloro Dip I Other I Low I I Warrenton Lumber, Warrenton Busan Dip · I Hl'IDS I Low I I I I I I Past Users I I I I I I I I American Shake, Garibaldi Chloro Other I Other I Med I I Banks Lumber, Banks I I I Low I I Columbia Harbor Lbr. Co., Col City I I I Low I I Stimson Lumber Co., Gaston I I I Low I I ·1 I I I I I I I I

CEtfl'AAL REGION SUM4ARIZED FINDINGS

I SITE I CHEt•l1CAL I SYSTEM I 1'/ASTE I PRIOR. I l------l------1------l------l------l I I I I I I I Current Users I I I I I I I I I I I I American Forest Prod., Prineville! Pilt 70 I Dip I LF I Med I I Bend Millworks, Bend I Chloro I Dip I Hl'IDS I Med I I Bright Wood Corp., Madras I Other I Dip I Other I Low I I Clear Pine Mouldings, Prineville I Pilt 70 I Dip I HWDS I Low I I Maywood Industries, Klamath Falls! Other I Dip I LF I Low I I I I I I I i Past Users I I I I I I I I I I I I Henderson Millwork, Klamath Falls I I I I Low I I I I I I I I I I I I I I I I I I I

10 WI~llilTE VALLEY REG!~~ FINDINGS ( The 11illamette Valley Region of the DEQ consists of Benton, Lane,

Lincoln, Linn, ~!arion, Polk and Yamhill counties. This was the first region

inspected in tnis project.

There were 34 sites inspected in this region. Of these, 26 are current

users of anti-stain, and eight are past users. Attempts were made to contact

200 sites.

Chemicals used

Twenty of the current users in the \WR were using some sort of

chlorinated phenol, and most of these were a Permatox product. Two of the

mills were using a copper-S quinolinolate compound, two were using zinc

( naphthenate, and tHo were using the acrylic latex sealer 1;ith

mercaptobenzothiozole. In addition, some of the sites Hould put Ambrocide in

the solution, which contains lindane and xylene.

Application methods

Spray booths were the most common application method in the INR. There

were 17 spraybooths seen, nine dip tanks, and one site which still operates a greenchain dip system. There was also one facility which uses garden watering

cans, which is, by nature, a poorly controlled method of applying anti-stain.

It is important to note that some of the sites had more than one

application system in use.

(

i' 11 l i Waste disposal

Nine of the 26 users in the WVR send. their waste to Arlington. This low percentage can be partially explained by the fact that there are so many spraybooths in this region and that they tend to generate less than two or three pounds per month of filtered debris. Four of the sites send waste to sanitary landfills, eight burn their waste in hogged fuel boilers, one mixes the waste in with chips that were sold, and three sites still had waste stored on site. These latter sites were each storing less than one 55 gallon drum of waste on site. These findings, as with those from the other regions, are only representative of the disposal practices occurring at the time of the survey.

Priority for further inspection

Of the 34 sites inspected in the HVR, 29 of them were assigned low priorities. All nine past users 1vere given low priorities. There \oiere four medium priorities given and one high priority. The medium priorities \oiere assigned to Clear.Lumber in Sweet Home, Peak Lumber in Philomath, Starfire Lumber in Cottage Grove, and Zip-0-Logs in Eugene. The high priority was assigned to Swanson Brothers Lumber at Noti.

Site narratives

High priority: Swanson Bros., Noti This site has a dip tank, which Has not in use at the time of the inspection. Observations have been limited to the setup of the tank Hith regards to its surroundings.

12 They have a typical, medium sized dip tank, which lacks a lowering device of its own. Lumber is lowered into the tank using a forklift with a

large hanging weight, with the wood suspended below ti~t. The weight then submerges the wood into the tank. Upon removal, the wood is reportedly allowed 30 minutes drip time over the tank. The tank is located outdoors, on an area of broken pavement. Those are two aspects which are undesirable. There is a cover for the tank made of 2X4's and corrugated sheet steel, and they claim to cover the tank during heavy rains. TI1e tank is 15 to 20 yards from an embankment that drops 20 to 30 feet steeply to a drainage ditch. A drain valve and spigot point straight towards the embankment. Dark stains· are present on the ground all arotmd the tank. Soil contamination is suspected from leakage, drippage, and possible drainage of the tank. Soil and groundwater sampling is recommended for this site. At the time of the inspection, the owners claimed they wish to replace the tank with a "state of the art" dip tank system that would be indoors, have a secondary containment sump, etc. They plan to start installation this fall. Permatox 101 is used at this site, ami the contact at S1vanson Bros. did not know how \Vaste was disposed.

Medium priority: Clear Lumber, SIVeet Home Permatox 101 is applied' at this site with garden watering cans. No application \Vas done during the inspection, so it \vas not directly observed. The application area is roofed and paved, IVhich could be considered impervious if handled correctly. (i.e. never hosing down the floor or allo~Ving rain runoff to move through.) No contamination of soil or water \Vas obvious upon visuai inspection, but the nature of this process is so poorly controlled that this site does

13 merit soil sampling as a minimum measure. Hence, the mediwn rating. No waste ( debris was observed for this process.

Medium priority: Peak Lumber, Philomath

This site has a single spraybooth that seems to 1~ork well. The problem lies with the recirculation pwnp, located just outside the booth. At the time of the inspection, the pump and pipe connections ·around it were leaking at least two to three gallons per hour. The operator claimed that the system had never leaked that way before and he would correct the problem. Soil around and under the booth, and ground water shouid be sampled ·at this site. Permatox 181 is used here and their waste is mixed with their other sawdust, which is sold.

Medium priority: Starfire Lumber, Cottage Grove This is the least urgent of the medium priority sites in the \I'VR. They have a new dip system with modern control devices in place. The problem arises because the tank is concrete and built into the ground, as one would typically expect a secondary containment sump to be. A crack in the concrete could cause chemicals to be released to the environment. Perhaps it would be wise to modify the system so the current tank becomes the sump, and construct a steel primary tank over the top of it. This would require extensive reconfiguration of the dip control portion of the apparatus.

It is imperative to understand that this priority is based on the potential for a problem. Currently, there is no environmental contamination suspected at this site. Tnirty minutes of drip time is reportedly allmved in

14 the drip area which returns drippage to the tank. Permatox 101 is used here, and the system hasn't been in use long enough to need cleaning.

Medium priority: Zip-0-Logs, Eugene This site is the most urgent of the medium priorities in the 1'/VR. This

site requires no permits on file at the \'IVR office. If anything, they only

l~ve an air permit with Lane Regional Air Pollution Authority. This site operates a greenchain dip system with the steel tank in a concrete sump below ground level. This system is spread out over a wide area, and boards enter a second greenchain, while still dripping, to be sorted and stacked by workers. \'lith this system, which has no designated drip area, a large zone is subject to chemical drippage under normal operation. Contaminated wood debris seems to be present in moderate quantities arow1d and under the greenchain. \'/hen demand for dipped lumber exceeds capacity of the tank, some of the wood pulled off the first greenchain (located prior to the tank) is sprayed with anti-stain by a garden hose. This is a very poorly controlled process, by nature. Most of the area is subject to rain and runoff during the wet season. There is a storm drain grate near the first greenchain, so

contaminated runoff escaping to the city sewer is unavoidable when it rains. In addition, this site has a spraybooth. It looks like a reasonably clean system. The plant was on strike during the inspection, so it was not possible to see any of the equipment in operation. Permatox 101 is used at this site and all their contaminated debris is still stored on site. The only reason this site hasn't been given a high priority is that no environmental contamination was directly visible. However, soil and ground ( water contamination is highly suspected at this site and samples of these

15 ~ should be taken. ~ i I Zip-0 represen1 :aimed that they wished to install a modern dip tank system in the fall or winter and would appreciate any available assistance.

Low priority: Bohemia Inc.; Coburg, Culp Creek, and Saginaw All three sites have identical dip tanks with attached roofs. Culp Creek and Saginaw have secondary containment sumps, Coburg does not because its tank has been relocated several times. All three tanks are planned for modernization, and the tanks are cleaned yearly with the debris being sent to Arlington. Permatox 101 was in use at all three sites.

Low priority: Cedar Lumber, Lyons Permatox 101 is applied with a spraybooth. The system is indoors and on a paved floor. One or two pounds per month of filter waste are generated and disposed of in the general refuse.

Low priority: Clark &Powell Lumber, Junction City This site uses Permatox 101 through a spraybooth. All components are indoors, over a paved floor. No drippage was seen. Two to three pounds per month of filter waste are generated, and are burned in the hogged fuel boiler.

Low priority: Columbia Millwork, Salem This company makes doors and Hindow frames. A petroleum-based penta called Handi-gard is used in a small (app. 25 gallon) tank. The tank is indoors, over a paved floor, but no secondary containment is there. Sludge is cleaned from the tank yearly, and sent to Brown's Island Sanitary Landfill.

16 Low priority: Davidson Industries, Tiernan

) Permatox 101 is applied in a spraybooth, which is located in a rc and paved area. No drippage was seen. Less than ten pounds per month' debris is generated, which is burned in the hogged fuel boiler.

Low priority: Fort Hill Lumber, Grand Ronde Permatox 181 is applied with a spraybooth. The system is in a roofed

and paved area, and no drippage was seen. Roughly ten pounds per week of ~ contaminated debris are sent to the Ri verbend Landfill in McMinnvill ~\v\1 may exceed the legal limit for this type of disposal.) ~

Low priority: Mountain Fir Lumber, Independence. Permatox 101 is applied with a spraybooth, but they are planning to dicontinue anti-stain use in the near future. The system is indoors and over a paved floor. Less than one pound per month of and is mixed with other shavings and sold.

Low priority: Ostrom Lumber, Pedee

Permatox 101 is applied with a spraybooth, indoors over a paved t No leakage was seen. Less than one pound per month of filter debris is generated, which is burned in the hogged fuel boiler.

Low priority: Pope and Talbot, Oakridge Permatox 101 is used in a dip tank, which has a secondary containment sump, paved floors, attached drip area, and a roof. This system has automatic cycling. The tank is cleaned once or twice yearly, with wastes going to ( Arlington.

17 Low priority: Seneca Sawmill, Eugene vJ ( Mitral PQ-8 is used in a spraybooth. The system is in a roofed ar -~~ paved area •. Some moisture was seen under the spraybooth, but no drip, ~

seen. Fifteen to 20 pounds per month of debris are generated, which is ~ to the Short Mountain Landfill.

Low priority: Smurfit Newsprint Corp., Toledo

This site uses Permatox 101, and has both a spraybooth and a dip tar~. Both systems are indoors over paved floors. The dip trulk has a secondary containmerlt sump and automatic cycling. Wastes are sent t9 Arlington.

Low priority: Taylor Lumber, Sheridan

This site uses Pro-Tek + through a spraybooth. All components arP indoors, on a paved floor. Minor drippage is absorbed with wood shavinb which are burned along with the filter waste.

Low priority: Weyerhaeuser, Cottage Grove This site has a spraybooth and a closed dip tank. A chlorophenol was used in the past, and now Nuodex 84 is used. Wood shavings are used to absorb drips, which are barreled with filter debris and sent to Arlington. Both systems are indoors on paved floors. The diptank does have a. secondary containment sump.

Low priority: Weyerhaeuser, Springfield Permatox 181 is used in a large, outdoor dip tank. There is a secondary containment sump with an attached drip rack so drippings are directly ( recycled. Loading is done with a large overhead crane, so roofing the area is not practical. The dip tank is cleaned annually and the debris is sent to Arlington. 18 Low priorities: Willamette Ind., Sweet Home and Bauman (Lebanon) ( Both sites apply MGard WSSO with spraybooths, located indoors over paved floors. Sweet Home lms two spraybooths and Bauman has one. About 50 to 60 pounds per month of debris are collected and sent to Arlington.

Low priority: Willamina Lumber, Willamina Nytek GD is applied with two spraybooths at this site Both are in roofed and paved areas. About two pounds per month of filt~r debris 3~ ,;,~~ generated, which gets burned in the hogged fuel boiler. ~~

Low priority: Young and Morgan Lumber, Lyons Permatox 100 is applied with a spraybooth. The system is indoors, on paved floor. About one pound per month of contaminated sawdust is collected in the filter, which is sent to a sanitary landfill. There is also a closed spraybooth here.

Low priority: 3-G Lumber, 1'/ren Permatox 101 is applied with a spraybooth, indoors over a paved floor. About one pound per month of debris is collected in the filter, and has so far been dried and remains on site.

Past users: all low priority

Action Lumber, Salem

Cone Lumber, Goshen

( Diamond B Lumber, Philomath

19 Hull-Oakes Lumber, Monro·e

Philomath Forest Products, Philomath

Silverton Forest Products, Silverton

Willamette Industries, Dallas

Willamette Industries, Lebanon Lumber

NORTHWEST REGION FINDINGS

The Northwest Region of the DEQ consists of Clackamas, Clatsop, Columbia, Multnomah, Tillamook, and Washington counties. This was the second region surveyed for anti-stain use. There are nine current anti-stain users and three past users in the NWR. Attempts were made to contact 82 sites in NWR.

Chemicals used

Seven of·the nine current users use some type of chlorinated phenol. Two use mercaptobenzothiozole, and one uses copper-S quinolinolate. One of the sites uses two types of chemicals (penta in a diptank and 2- ( t hi ocyanomet hylthi o) benzot hiazo le in a sprayboot h) .

Application methods

( Dip tanks were more conunon in Nl\'R than in 1'/VR. Of the nine current

anti-stain users in N\'IR, four of them used dip tanks as their primary method

20 of application. Each site had one dip ' tank. There were nine spraybooths in NWR, being the primary method at four sites. There was also one greenchain dip system, and it was the primary method at its location.

Waste disposal

Six of the nine current anti-stain users in the NIVR send their wastes to Arlington Hazardous Waste Disposal. One site sends waste to a perfnitted landfill, one site burns the waste in a boiler, and one site has a newer dip tank which hasn't been cleaned yet.

Priority for further inspection

There were no high priority sites in NlVR. There were two medium priorities and ten low priorities. The medium priority sites were American Shake at Garibaldi and Forest Grove Lumber, Forest Grove.

Site narratives

Medium priority: American Shake, Garibaldi This site is located at the southwest corner of illVY 101 and 7th in Garibaldi. The company went out of business and their buildings were demolished in late 1983 or early 1984. This site had a problem with rain runoff moving through, collecting in a sump, and being pumped through a pipe into Tillamook Bay. This effluent Has ( sampled at the point of discharge to the bay and found to contain penta and tetra, among other things. There is a possibility that penta, tetra, and its L"w _.,,·c .

21 impurities (nainely dioxins) may still be present in the soil at this location. ( The property is actually owned by the Port of Bay City and is leased out for commercial/recreational use. Regrading of the area is currently being done by Erickson Lumber, an alder mill across the street. The area is being

prepared for some new industrial buildings. '\'.v/

The graders claim to have removed the top three feet of soil from that "} .{( location and replaced it with clean soil. Sampling of the soil below this for y;·t'J ~ ' I ~~·. chlorophenols and their impurities may be desirable. j7J,v> I

Medium priority: Forest Grove Lumber, Forest Grove This site uses Mitral PQ-8 in a spraybooth, and their waste is burned in a hogged fuel boiler. The booth itself works well, it is the setup around it that causes the medium priority. The sawmill is a pretty old building, with wooden plank floors and no paving underneath. Hence, any leaked chemicals have a fairly direct route to the ground. The outfeed conveyor has no drip pans underneath and is the major source

of concern at this site. The PQ-8 seems to really froth up in this system, and this froth gets all over the outfeed conveyor. The froth then returns to fluid and slmvly drips to the floor. The ends of the conveyor are Hhere most of the fluid drips from. While this may or may not pose a severe problem with PQ-8, this is an old system and pent a was used until recently. It is not known whether this frothing and dripping problem existed while penta was in use. Soil sampling under the sawmill and groundwater sampling are recommended for this site.

(

22 Low priority: Alder Creek Lumber, Sauvies Island (Portland)

( This site applies Permatox 181 with a spraybooth. This plant 0· finished 2X4's, and all their production is spr.ayed. The system

roofed and paved area, no drippage, and the boards come out barely u, \ Filter waste goes to St: John's landfill.

Low priority: Avison Lumber, Molalla This site uses Permatox 181 in a diptank. This system is new, indoors, and has a secondary containment sump and automatic cycling. Wastes are shipped to Arlington. This system serves as a model for the other mill operators throughout the state.

Low priority: Brazier Lumber, Molalla This site has the only well managed greenchain dip system this author has seen. It has been modified greatly over recent years. The tank is over a paved area, and there is a two-stage system of dikes with a sump which stores all the rllitoff and recycles it to the system. The area is roofed and no problems are seen with this system. They also have three spraybooths at various locations, but none were in use at the time of the inspectfon. The booths are pre-assembled units from Chapman Chemical Co. and appear to be set up well. Permatox 181 is used here, and wastes go to Arlington.

Low priority: Smnrfi t Newsprint Corp., Molalla This site uses Koppers T-1 and has both a spraybooth and a dip tank. Both systems are set up in roofed and paved areas, and no problems were seen. Wastes are shipped to Arlington. I

23 Low priority: Smurfit, Oregon City ( I This site uses Koppers T-1 in a dip tank. The system is merely a scaled down version of the one at Smurfit, Molalla. It is indoors, with an adjacent drip area and a secondary contaimnent sump. Waste goes to Arlington.

Low priority: Smurfit, Tillamook This site applies Permatox 181 with two spraybooths. Both are in roofed and paved areas. The newer one is in a large enclosure, has drip pans, and works well. lne other is quite old and seldom used. It was not in use during the inspection. It has no outfeed curtain and its abi.lity to contain spray is unknown.

Low priority: Vanport Manufacturing, ·Boring Permatox 181 is used in a dip tank. The tank is in a roofed and paved area and has a contailllDent swnp that extends under the output ch&ins from the tank into the drip area. This is a well confined system. The only cause for concern is that the swnp doesn't appear large enough to hold the entire contents of \:he tank, should a tank failure occur. The tank is 'filled from the top, so a fitting failure would not result in the draining of the entire tank. · An act of vandalism would be required to cause the whole tank to drain. In the past, penta was sprayed on the wood with hoses, after being pulled from the greenchain. This practice was discontinued at least five years ago, but penta or its impurities may still be present in the soil under the stacking rollers. These should be sampled. Most of the debris goes out of the tank attached to the rough timbers, because an. internal stirring stream is used. Consequently, there has not yet

( been a need to clean the tank.

/

24 Low priority: Warrenton Llllllber, Warrenton ( This site has a dip tank and a spraybooth. Busan 1030 and Nuodex 84 are ·' being used. The diptank is indoors, with automatic cycling and a drip rack that returns drips to the secondary containment sump. The only problem is that less than half an hour of drip time on this rack is allowed during a normal production level. Perhaps.a second drip area adjacent to the original could be constructed. They have a spraybootl1 in a roofed and impervious area that seems to work well. It lacks a filter or screen, but that doesn't seem to cause a problem for this system. Wastes are shipped to Arlington. They have a shut down greenchain dip system, which was cleaned out by the former site owners, Crown-Zellerbach.

Past users: all low priority

Banks Lumber, Banks

Columbia Harbor Llllllber Co., Columbia City

Stimson Llllllber Co., Gaston

CENTRAL REGION FINDINGS

The Central Region of the DEQ consists of Crook, Deschutes, Harney, Hood River, Jefferson, Klamath, Lake, and Wasco counties. This was the final region inspected for anti-stain use. There are six current anti-stain or wood ( preservative users in the CR, and five past users. Attempts were made to contact 56 sites in CR.

25 Five of the current and one of the past users were inspected. Two of ( the past users were on strike (DAW Bend and DAI'I Remanufacturing in Redmond)

and two had discontinued use and removed equipment more than three years ago~ (Mountain Fir in Maupin and Tygh Valley) so they were not inspected. Some attention to this should be made at these sites' next regular inspections. The only current user not inspected was Jeld-lqen in Klamath Falls. A major penta leak was recently discovered there from their dip tank, and a monitoring and cleanup program was started. They will be monitered for several years into the future by DEQ as a result of this, so a field survey as normally done in this project was unnecessary.

Chemicals used

Two of the six current preservative users in the CR use TBTO ( (tributyltin oxide). Tv10 use 3-Iodo-2 Propynyl-Butyl-Carbamate, and tHo use penta. All but one use these in petroleum or mineral spirits solvents, because items like door and window frames and mouldings are Hhat gets treated in this area.

Application methods

All five current users inspected in CR have some sort of dip tank. The tanks tend t<;> be small, because small quantities of various mouldings are the only items that go through them. The past use site inspected also had a dip tank.

(

26 l~aste disposal

Two of the five current users send waste to hazardous waste disposal sites. One sends to Arlington and the other to Enviro-Safe in Idaho. Two send waste to permitted local landfills, and one site has a new dip tank which hasn't been cleaned yet.

Priority for further inspection

Four of the sites inspected in the CR were assigned low priorities. The other two were given medium priorities because they were using concrete dip tanks which were built into the ground. Slow leaks due to cracks in tl1is type of tank may be very difficult to detect. This is essentially the type of problem which has taken place at Jeld-Wen in Klamath Falls.

Site narratives

Medium priority: American Forest Products, Prineville This site uses Pilt 70 in a dip tank. The tank is concrete, built into the floor, and hence has no containment sump. This type of tank has the potential to crack, causing a leak which may be difficult to detect. The tank and drip area are indoors. The tank is cleaned yearly, with waste going to Crook County Landfill. Ariother concern is the outdoor storage tank for fresh solution, because it is underground. Plans exist for eventual removal of this underground tank. Medium Priority: Bend Millworks, Bend I This site uses a 5% penta solution in petroleum solvent J The tank is concrete and built into the ground. Again, this type of tank has the potential for difficult to detect leaks. It is indoors. The treated mouldings are then dried at 105 degrees F for 24 hours. Wastes are sent to Arlington.

Low priority: Bright Wood Corp., Madras This site uses Becham Polyphase in a dip tank. The tank is indoors in an impervious area, and has automatic cycling, but no secondary containment sump is present. The tank is new and has not been cleaned yet.

Low priority: Clear Pine Mouldings, Prineville This site has a dipping process, and uses Pilt 70. The entire system is indoors, over pavement, and in an enclosed area with no human contact. Mouldings enter the enclosed area on a conveyor, are dipped, dried, and painted. Everything is automated. Wastes go to Enviro-Safe in Idaho.

Low priority: Henderson Millwork, Klamath Falls This site had an outdoor diptank, and only a small portion of production was ever run through it. The tank has been gone for five years and no cleanup appears necessary.

Low priority: Maywood Industries, Klamath Falls This site uses an aqueous solution of Weldwood Woodlife in a small

(approx. 60 gallon) dip tank. Roughly 100 shutters are dipped per month, which is a very small fraction of production. The tank is indoors in a paved area. 1'/aste goes to Klamath County Landfill. APPENDIX 1 I ' GLOSSARY

APD Accident Prevention Division, lvorkers Compensation Department

BMP Best Management Practices for anti-stain handling

Busan 1030 anti-stain chemical with 2-(Thiocyanomethylthio)benzothiazole

Copper-8 short 'for copper-8 quinolinolate

CR Central Region of DEQ operating area

( DEQ Department of Environmental Quality

Koppers NP-1 wood preservative with 3-Iodo-2 propynyl butyl carbamate and didecyldimethyl ammonium chloride

Koppers T-1 an anti-stain chemical with penta in it

LRAPA Lane Regional Air Pollution Authority, handles all air programs in Lane County

MGard WSSO an anti-stain chemical with zinc naphthenate

Mitrol PQ-8 an anti-stain chemical with copper-8 quinolinolate

A-1 { Nuodex 84, Pro-Tek + latex sealer with mercaptobenzothiozole

NI'IR Northwest Region of DEQ operating area

Nytek GD anti-stain agent with copper-S

PCP pentachlorophenol, -phenate, or penta

Permatox 100, 101, 180, or 181 chlorophenol anti-stain agents

Pilt 70 wood preservative with tributyltin oxide

Polyphase wood preservative with 3-iodo 2-propynyl butyl carbamate

TBTO tributyltin oxide, a wood preservative

TCP tetrachlorophenol, -phenate, or tetra

Woodlife wood preservative with 3-iodo 2-propynyl butyl carbamate

WVR Willamette Valley Region of DEQ operating area

l APPENDIX 2

These are all the sites inspected, contacted, or wllich attempts were made to contact. Some sites have gone out of business and were hence not possible to find. Inspected sites are indicated by *· Willamette Valley Region (200 sites)

Action Lumber, Salem * All-American Stud, Springfield Alsea Veneer, Waldport American Laminators - Tidewater Dry Kilns, Swisshome Arrow K. Inc., Lane County Bald Knob (Mazama) Creswell Big R Shake Co., Eugene Bohemia, Coburg * Bohemia, Culp Creek * Bohemia, Dorena Bohemia, Junction City Bohemia, Saginaw * Bohemia, Vaughn Boise Cascade, Eugene Boise Cascade, Independence Boise Cascade, IH 11 i ama Bullfrog Lumber, Eugene Burkland Lwnber, Turner C &C Lumber, Lacomb C. L. Mullen, Fall Creek Gabinet Craft of Eugene Cascade Handle, Eugene Cascade Lumber, Cottage Grove Cascadian Company, Eugene Cedar Lumber, Lyons * Central Manufacturing, Eugene Champion, ~lapleton Clark and Powell Lumber, Junction City * Clear Lwnber, Sweet Home * Coast Manufacturing, Eugene Coastal Fibre, Willamina Columbia ~lillwork, Salem * Cone Lumber, Goshen * Cuddeback Lumber, Eugene Davidson, Mapleton Davidson, Tide Davidson, Tiernan * Diamond B, Philomath * Diamond Wood Prods, Eugene Emerald Forest Products, Eugene Eugene Planing Mill, Eugene falcon ~lfg., Eugene l

A-3 Fort Hill Lumber, Grand Ronde * Frank Lumber Co., Mill City Freres Lumber Co., Lyons Freres Lumber &Veneer, Idanha G &R Shake, Cottage Grove G. H. Shake, Jasper Galleton Shake, Florence Gem Lumber, Springfield Georgia-Pacific, Irving Rd., Eugene Georgia-Pacific, Prairie Kd., Eugene Georgia-Pacific, Springfield Golden Veneer, Walker Green Veneer, Idanha Guild Manufacturing, Eugene Guistina, Eugene H &H Cedar, Lyons H. Bawnan Lumber, Veneta HR Jones Veneer, Inc. Halsey Veneer, Halsey Hans' Cabinet Shop, Junction City Hardwood Components, Mehama Hearin Forest Ind. , Eugene Hendrix Lumber, Alsea Hills Creek Manufacturing, Jasper Hoskins Lumber, Philomath Hull-Oakes Lumber, Da10son * Humphrey Shake, Lo10ell Huntington \~ood Indust •. , Springfield Imperial Shake, Eugene J. 0, Olsen Mfg. Co., Eugene K-6 l~ood Products, Eugene L. D. McFarland, Eugene Lane Cedar, Springfield Lane Plywood, Eugene Lanz Cabinet Shop, Eugene Lebanon Plywood, Lebanon Lester (3-Pack) Shingle, Foster Lester Shingle, Sweet Home Linn Timber, Lyons Lumber Tech Inc., Lebanon Mary's River Lumber, Philomath McKenzie River Shake, Springfield McKenzie Trading Co., Eugene McMillan Shingle, Grand Ronde Meile Shake, Eugene Mid-Valley \iorkshop, Amity Midgley ~lillwork & Glass, Eugene Mobile Truss of Oregon, Stayton Morton Alder Mill, Iii 11 iams ·Mountain Fir Lumber, Independence *

A-4 Murphy Co. , Florence l

A-5 Stout Creek (Yoimg & Morgan), Mehama Stuckart Lum.ber, Idanha Stui venga Box ~lill, Polk Co. Swanson Bros. Lumber, Noti * Tangfeldt Wood Products, Eugene Taylor Lumber, Sheridan (Rock Cr. Rd) * Temple Counter Tops, Eugene The Murphy Co. , Eugene The Murphy Co. , Springfield The Ridge Company, Eugene Three G. Lumber, Harlan TI1ree G. Lumber, Philomath Three G, Wren * Tree Products Hardwoods, Eugene Triangle Veneer, Eugene Trus Joist, Eugene Trus Joist, Junction City u. s. Forest Products, Springfield U. S. Plywood Corp., Lebanon V &K Cedar Products, Cottage Grove WW Lumber, Lane County Weathershed, Lincoln City \Vest Coast Hardwoods, Florence \Vest Forest Wood Products, Otis Westfir Shake Mill, Westfir liestridge Plywood, l'iestfir Westwood Furnishings, Eugene Westwood Products, Salem Weyerhaeuser, Cottage Grove * Weyerhaeuser, Springfield * Wheeler Forest Products, Albany (Boise·Cascade) Whitsell & Whitsell, Springfield Whittier Wood Products, Eugene Willamette Ind., Philomath Willamette Industries, Albany Custom Willamette Industries, Albany (Duraflake) Willamette Industries, Dallas * Willamette Industries, Foster Willamette Industries, Indianola Willamette Industries, Lebanon (Bauman Lumber) * \Hllamette Industries, Lebanon Lumber * Willamette Industries, Lebanon Plywood Willamette Industries, Springfield Willamette Industries, Sweet Home, Lumber * l'lillamette Industries, Sweet Home, Midway Willamette Industries, Sweet Home, Plywood Willamette Post &Pole, Springfield Willamette Precut, Inc., Scio Willamette Valley Co., Eugene Willamina Lumber, Conifer Willamina Lumber, Willamina * Wills Shingle Co., Florence Wood Components Co., Eugene Yaquina Veneer, Eddyville Young &Morgan Lumber, Lyons * Zip-0-Lumber, Eugene *

A-6 Northwest Region (82 Sites)

ABC Hardwood, Tillamook Alder Creek Lumber, Portland * Allen Forest Products, North Plains American Hardwoods Inc., Tualatin American Shake &Shingle, Garibaldi * Arrowhead Timber Co., Clackamas Astoria Plywood, Astoria Avison Lumber, Molalla * Banks L~nber Co., Banks * Beaver Lumber Co., Clatskanie Boise Cascade Corp., St. Helens Brazier Forest Products, Molalla * Bridal Veil Lumber Co., Bridal Veil Bruce Merritt Wood Products, Bay City Burlington Wood Products, Portland CB Shingle Mill, Nehalem Caffal Bros. Forest Prods, Oregon City Cedarwood Timber Co., Vernonia Chappell Manufacturing Co., Portland Coast Hard1vood Co., TillamooK Cobb Lumber Co., Portland Columbia Harbor Lumber, Columbia City * Col~nbia Hardwood &Moulding, Tigard Centennial Forest Products, Tillamook Cook Creek Shake &Shingle, Nehalem Curtis Fluhrer, Inc., Astoria Ellson Cedar Products, Vernonia Erickson Lumber, Garibaldi foley Creek Shake, Nehalem Forest Fiber Products (Stimson), Cherry Grove Forest Grove Lumber, Forest Grove * Foster Cedar, Vernonia Friesen Lumber Co., St. Helens Georgia Pacific, Portland Gold i>!edal Cedar, Nehalem Goodrich Forest Products Inc., Sherwood Great Northen1 Products, Portland John Malcom, Tillamook Kimber Log &Lumber Kohl, Inc., Seaside Kropf Lumber-Rock Crk. Bldg. Mats., Molalla Lattice Works of Oregon, Portland Linnton Planing Mill, Portland Linnton Plywood, Portland Little D Lumber, Scappoose ~larie Mills Center, Tillamook Mercer Industries, Inc., Beaverton Morgan-Stanley Lumber, Sherwood Multnomah Plywood Corp., St. Helens Murphy Plywood, Milwaukie Natal Shake &Ridge, Veronia (\._

A-7 Nicolai Co., Portland Nicolai Company, Tualatin Niedermeyer-Martin Co •. , War·ren Noble &Bittner Plug Co., Cloverdale Norm Saarheim, Olney North Portland Lumber,. Portland Pacific Coast Hardwoods, Portland RC Long Shakes, Portland RSG Forest Prods, Estacada RSG Forest Prods., i'list Sandlake Cedar Products, Cloverdale Sandy Shake Co., Sandy Smurfit, Molalla * Smurfit, Oregon City * Smurfit, Tillamook * Specialty Woodworking, Port land St. Johns Forest Products, Portland Stimson Lumber, Cherry Grove * Stimson Lumber, Clatskanie Tappan Co., Hillsboro The Dean Company, Gresham Timber Best, Inc., Manning Valley Ridge, Astoria Vanport Manufacturing, Boring * Vermilyea Shingle Co., Nehalem Waggerby Bros (4-N) Shakes, Bay City Warrenton (Cavenham) Lumber, Warrenton * Washoe Booting & Insulation, Tillamook Westen1 Line Corp., Portl~nd 1'/oodfold-Marco Mfg., Inc., Forest Grove

Central Region (56 sites)

Alpine Veneers, Modoc Point American Forest Products, Prineville * Bend Mill Works, Bend * Bend Wood Products, Bend Boyle Manufacturing, Redmond Bright Wood Corp, Madras * C S Andrus Inc, Silver Lake Carl Krieg Millwork, Hood River Cascade Forest Products, Bend Cascade Locks Lumber Co, Cascade Locks Cascade Studs, Chiloquin Cascade \~ood Components, Cascade Locks Champion International, Dee Chiloquin Forest Products; Chiloquin Clear Pine Mouldings, Prineville * Columbia Plywood, Klamath Falls Consolidated Pine, Prineville Custom Remanufacturing, Bend D &E Wood Products, Prineville

A-8 DAW Forest Products, Bend D~ Forest Products, East Antler Ave, Redmond DAW Forest Products, Railroad Ave, Redmond Dame Lumber & Mouldings, Lakeview Frenchglen Millworks, Hines Georgia Pacific Corp, Chemult Gilchrist Timber Co, Gilchrist Gregory Forest Products, Klamath Falls Hanel Lumber Co, HWY 35, Hood River Hanel Lumber Co, Neal Mill Rd, Hood River Henderson Millwork, Klamath Falls * J H Baxter &Co, The Dalles Jeld-Wen Inc, Klamath Falls Lakeview Lumber Products, Lakevie~o~ Louisiana Pacific Corp, Lakeview Louisiana Pacific Corp, Prineville Maywood Industries, Bend ~laywood Industries, Klamath Falls * Modoc Lumber Co, Klamath Falls Morelock Wood Products, Bend Mountain Fir Lumber Co, Maupin . Mountain Fir Lumber Co, Tygh Valley Ochoco Lwnber, Prineville Ostrander Construction Co, Lakeview Ostrander Construction Co, Paisley Pine Products, Prineville. Pioneer Cut Stock, Prineville Ponderosa Mouldings, Redmond Precision Pine Co, Lakeview Russell Industries; La Pine Snow Mountain Pine, Hines · Sturdi-Craft Inc, Klamath Falls Western Cutstock, Bend \'ieyerhaeuser Co, Bly Weyerhaeuser Co, Klamath Falls Willamette Industries, Bend \Voodmark Corp, Hines

( \.

A-9 ( I

.... ~ ...... _ r' I • -...... - ...... I" H .. - .. -··-, ~~ / • i .-... ··-··-•. - ,..-··-··- iI '!~~J ( I I

.~ i '

w C)

4- 0 c: 0"'

QJ "'

"'X

C) -:z: w 0. 0. <>:

A-10 APPENDIX 4 Best Management Practices Anti-Stain Solution Handling

(

A-ll STATE OF OREGON DEPARU.!ENT OF ENVIRONMENTAL QUALITY INfEROFFICE Mb\0

TO: DEQ Regions DATE: August 27, 1986 FR0.\1: Larry Patterson, Nater Quality Fred Bromfeld,.Hazardous Waste SUBJECT: Best Management Practices, Anti-Stain Solutions In March of 1981, a spill of pentachlorophenate anti-stain solution at a lumber mill in Coos Bay caused the Water Quality Program to initiate a general review of the timber products facilities throughout the state. A memo was sent to· the DEQ Regional Offices with an inventory form. The purpose of the inventory was to observe tite majority of the anti-stain operations to assess the potential environmental problems. Of the 41 facilities inspected, 30 were using some form of wood preserving chemical. The majority of the inventory forms which were returned to 1'/ater Quality did not note any environmental problems. One facility where no problem was noted is now known to have contributed to surface and groundwater contamination with anti-stain solution (pentachlorophenate). This situation has caused the \later Quality Program to conclude that more systematic and detailed inspections are necessary. ( Since this subject is relatively new to DEQ, we have little· experience to use in judging what constitutes acceptable control of an anti-stain application operation. Therefore, the Department felt a need to identify some Best Management Practices for anti-stain application facilities to prevent or minimize the potential for release of these toxic chemicals to surface and groundwaters. These practices are intended to be used as guidelines. However, they should be incorporated into all new or modified anti-stain application facilities. In addition, where surface or groundwater monitoring confirms the presence of the chlorinated phenolic solutions, steps must be taken to prevent any further release of material. In some situations, this may include the removal of contaminated soils. The common anti-stain application methods are by dipping lwnber in a large tank (usually steel) and through the use of an enclosed spray booth located on conveyer systems. Hand application by a hand-held hose or sprayer has been witnessed. This is not an acceptable method wtless it is conducted over an impermeable containment device where overspray and drippings can be collected and returned to a secure tank or sump. Spray-booth facilities consist of a chemical storage tank, a pump, plumbing to convey chemical to spray nozzles located iitside an enclosure, a drip and overspray collection pan, and plumbing to return chemical to the storage tank. Some installations have a filter or screen located on the chemical return line to remove any pieces of wood fiber. Normally there is little loss of chemical from this application method. However, because the chemical is quite toxic to aquatic life precautions should be taken to prevent the loss of chemical from spills and equipment breakdowns.

A-12 Best Management Practices, Anti-Stain Solutions July 19, 1983 Page 2 ( ( All the above described equipment should be located over an impermeable containment device adequate to contain the volume of chemical in the storage tank and the plumbing lines. If these facilities are located outside, roofing should be provided to prevent rain from collecting within the contaimnent area. Any debris from a filter or screen should be placed in barrels located within the containment area. Storage and final disposal of this material should be managed in accordance with the Department's Hazardous Waste Rules. Also, connections for transfer (or refilling) of chemicals should be located such that spillage or leakage can be contained. Dip Tank facilities usually consist of a large steel tank which can hold up to 8,000 gallons of anti-stain solution. The actual dipping of lumber can be done by an overhead crane, a forklift truck, or a hydraulic clamping mechanism affixed to the tank. The lumber is submerged for a few minutes and then is removed from the tank. A considerable amount of chemical drips from the lumber upon removal from the tank. Some clamping mechanisms have a timer provided that keeps the clamp activated for a pre-determined period of time after removing the lumber from the tank. In this manner, the initial drippings drain back into the dip tank and the forklift operator is prevented from immediately removing the lumber. Regardless of the method of dipping, adequate drip time is usually not provided. Even after 10 or 15 minutes dipped lumber will continue to drip. Unless the operations are unusually slow, a dip tank cannot be tied up for this length of time. A drip collection device should be provided which will allow freshly dipped lumber to drain for a minimum of 30 minutes. Some drip collection devices consist of a roller conveyor with a continuous sloped pan which drains back to the tank. In areas of heavy rainfall, the roller conveyer should be covered. More elaborate facilities locate the tank and drip area within a bermed concrete 11or~ing area. · These facilities are designed to contain the entire chemical volume in the case of a tank failure. Drippings drain to a sump where they are pumped back to the dip tank. These facilities should be roofed to divert rainfall. Some dip tank facilities also have a pump and screen to remove wood debris from the working solution. The pumps, plumbing, screen, and debris collection container should be located over an impermeable containment device with a roof. If a screening mechanism is not provided, a sludge layer will accumulate in the dip tar~ over a period of time.

A-13 Best ~lanagement Practices, Anti -Stain Solutions July 19, 1983 Page 3 A few operations have a dip tank built into the green chain. These operations should have a drip pan or pad under the dip tank and the outfeed side of the green chain. A minimum of 30 minutes drip coll ction should be provided. The collection device should be designed to contain the entire volume of the dip tank. Drippings should be returned to the dip tank. Again, those facilities should be roofed. Debris that collects in the drip area periodically needs to be removed. The Best Management Practices that need to be stressed are: 1. Inspections - Monitoring for anti-stain solutions (chlorophenols) is not conducted around these facilities on a routine basis so a problem may exist without our knowledge. Therefore, it is of utmost importance that the mill personnel periodically inspect the contairunent systems to insure their integrity. 2. Security - Protection should be provided against vandalism which could result in a chemical release. Drain valves should be avoided. If possible, pumps and plumbing should be protected by locking cages. All chemical concentrates stored on-site should be in a locked facility. 3. Dipped lumber should be allowed to drip over an impermeable containment device for a minimum of 30 minutes. Normally, lumber exiting a spray booth does not have a significant amount of drippage. 4. Concrete pads and swnps should be sealed with a chemically resistant coating such as epoxy. 5. Waste anti-stain solutions, screened or filtered debris, and dip tank sludge should be managed in accordance with the ·Department's Hazardous Waste Rules. 6. Capture and reuse of residual anti-stain solutions is the primary objective. Some facilities using pentachlorophenol based anti•stain solutions have switched to tetrachlorophenol based on the assumption that tetrachlorophenol would be significantly less damaging to the environment. Recent bioassay studies conducted at our laboratory on salmonids did not show any significant difference in the acute toxicity of the two compounds.

A-14 Best Management Practices, Anti-Stain Solutions July 19, 1983 Page 4 Based on an average LC 50 of 0.15 ppm, the Department's Hazardous \'iaste Rules (OAR 340-63-lZS(l)(a)) require that wastes containing 600 mg/L or greater of total chlorophenates be considered hazardous and subject to the Hazardous Waste Management Program. Essentially all waste chlorophenol anti-stain solutions and fiberous debris generated in the application operations are hazardous wastes. Less than 10 pounds per month of such waste may be tak.en to a permitted solid waste landfill with the consent of the landfill operator. Also, a generator may store onsite (1) up to 2,000 pounds, or (2) in excess of 2,000 pounds for a period up to 90 days. · Due to the extreme toxicity pf these compounds on aquatic organisms, wastes containing less than oOO mg/L of total chlorophenates should be managed to protect surface and groundwater quality. Proper disposal of such wastes is in a permitted solid waste landfill or as otherwise approved by the Department.

A-15 APPENDIX 5 f'· WATERWAYS CLOSE TO MEDIUM AND HIGH PRIORITY SITES

SITE Waterway and distance * American Forest Products, Prineville - Crooked River

American Shake, Garibaldi - Tillamook Bay, borde~s property Bend Millworks, Bend - 300 yards to unnamed irrigation canal; Deschutes River

Clear Lumber, Sweet Home - l~iley Creek; South Santiam River Forest Grove Lumber, Forest Grove - Gales Creek; Tualatin River Peak Lumber, Philomath - 400 yards to Mary's River Starfire Lumber, Cottage Grove - Row River; 100ft to drainage ditch Swanson Brothers Lumber, Noti - Long Tom River; Noti Creek; Elk Creek; 20 yards to drainage ditch Zip-0-Logs, Eugene - 200 yards to drainage ditch; 0, 7 inile to Amazon Creek; 1 mile to Willamette River

* - Approximate distances to waterways are given, where available.

(.,

A-16

APPENDIX C SITE PHOTOGRAPHS

PHOTOGRAPHS Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

Photo No.

1

Description

View of rail road ties on the Property, facing north.

Photo No.

2

Description

View of the Property, facing east.

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Appendix C - Georgia-Pacific Chemult Photographs.docx

PHOTOGRAPHS Project Name: Georgia Pacific - Chemult Project Number: 1012.01.04 Location: 43.2225°, -121.7769°

Photo No.

3

Description

View of two heavily rusted drums near a camp fire ring.

R:\1012.01 Green Diamond Resource Co\Report\04_2015.08.04 Georgia Pacific Chemult ICP Report\Appendix C - Georgia-Pacific Chemult Photographs.docx