Former Georgia-Pacific Chemult
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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 INTRODUCTION 1 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. SITE BACKGROUND 2 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 CONCLUSION 3 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.