United States
                   Environmental Protection
                   Agency
                   Enforcement and
                   Compliance Assurance
                   (2201)
EPA 520-F-95-003
    Spring 1995
& EPA       Su perf u nd At Work
                   Hazardous Waste Cleanup Efforts Nationwide
   Western Processing
      Company, Inc.
        Site Profile
  Site Description: Former waste
  processing facility

  Site Size: 13 acres

  Primary Contaminants: Volatile
  organic compounds {VOCs}, poly-
  chlorinated biphenyls (RGBs), and
  heavy rnetals including lead,
  cadmium, and zinc

  Potential Range of Health Risks:
  Central nervous system disorders
  and a variety of cancers

  Nearby Population: 10,000 people
  within 3 miles

  Ecological Concerns: Surface
  water and sediments in MHI Creek

  Year Listed on NPL: 1983

  EPA Region: 10

  State: Washington

  Congressional District: 8
 Worker sprays gravel to cover a "hot spot" in Mill Creek.
Success in Brief

Private  Parties Use Innovation In

Cleaning Up Reclaimer's Wastes

   The Western Processing plant in Kent, Washington once served an
industrial purpose reclaiming and disposing of hazardous wastes. The
company recycled hazardous substances such as spent solvents, pesti-
cides, and paints to produce reprocessed products such as fire retar-
dants, fertilizers, and pigments. But careless storage and handling
practices took an enormous toll on the environment: acids, heavy
metals, and other toxic substances seeped into the soil and polluted
ground and surface water.
  Using Superfund authority, the U.S. Environmental Protection
Agency (EPA) reduced immediate risks by stabilizing the site and re-
moving almost a million gallons of hazardous liquid wastes. Based on a
series of negotiations, cooperative cleanup efforts are now estimated to
cost over $100 million when complete. Projects were undertaken by the
parties responsible for the hazardous waste, led by The Boeing Com-
pany, and included some notable features:
   • Use of a new technology to treat dioxin-tainted waste; and
   • Design of a state-of-the-art ground water extraction system to
     remove a complex mix of subsurface contaminants.
  Last spring, scientists began piloting two innovative technology
studies, bioremediation and metals-fixation, to reduce chlorinated
solvent and heavy metal concentrations in ground water.

                              The Site Today
                                Cleanup crews have taken
                              most of the steps necessary to
                              achieve cleanup standards at the
                              Western Processing site. A
                              pump-and-treat system for
                              contaminated ground water is
                              operational and includes 10 new
                              wells installed last summer to
                              speed extraction of VOCs. Recla-
                              mation of heavily contaminated
                              surface water and soil enables the
                              site to support plants, birds,
                              animals, and aquatic life in the
                              Mill Creek ecosystem.

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                   Superfund At Work  •  Western Processing Company, Inc., Kent, WA
                                   Spring 1995
                               A Site Snapshot
  The Western Processing
Company, Inc. site is located
in King County, about 20
miles south of Seattle. The
company originally repro-
cessed animal byproducts
and brewer's yeast.
  In the 1960s, the company
expanded into reclaiming,
recycling, and disposing of
hazardous materials, includ-
ing electroplating solutions,
flue dust from steel mills,
waste oils, paints, spent sol-
vents, pesticides, zinc dross,
and battery acids. As one of
few such approved facilities in
the region, Western Processing
did a brisk business until
pollution problems closed the
doors in 1983.
               Western
               Processing Co.,
               Inc. Site
               Kent, WA
   Over a 20-year period, the
company operated as a permitted
hazardous waste facility receiving
industrial wastes from several
hundred businesses. The opera-
tors accepted almost 6,000 drums,
72 bulk tanks, and numerous
transformers and other contain-
ers; untrained workers mixed
chemicals in open waste piles and
lagoons. Spills and accidents
contaminated a shallow under-
ground aquifer and Mill Creek,
one of a series of tributaries that
empty into Puget Sound.
  Although contaminated
ground water from the site is
not being used by area resi-
dents, approximately 10,000
people live within three miles
of the site; 2,000 depend on
ground water for household
use. More than 90 of EPA's
126 priority pollutants were
found in the ground water, soil,
and surface water, including
volatile organic compounds
(VOCs), polychlorinated
biphenyls (PCBs), and heavy
metals such as lead, cadmium,
and zinc.

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                    Superfund At Work  •  Western Processing Company, Inc., Kent, WA  •  Spring 1995
  E^c lEMrecte Pioneering Cleanup Effort
Poor Waste Handling Practices
  Over the years, the Kent Fire
Department had noted conditions
at the site because of the fire and
explosion potential. In addition,
the Washington State Depart-
ment of Ecology (Ecology) had
attempted to control wastewater
discharges from the site, with
little success. In March 1981, EPA
inspected the site to determine
compliance with the Resource
Conservation and Recovery Act
(RCRA). This law enables EPA
and state authorities to track
hazardous wastes from "cradle"
(point of production) to "grave"
(final disposal).
  EPA found numerous RCRA
violations at the site, including
evidence of frequent spills, large
uncontained piles of waste, and
storage of hazardous by-products
in unlined impoundments. Sur-
face water, soil, and ground water
were polluted to various degrees.

Superfund Takes the Lead
  Western Processing was one of
thousands of problem industrial
sites that brought about passage
of the Comprehensive Environ-
mental Response, Compensation,
and Liability Act of 1980 (CER-
CLA). This law established a
federal program to clean up the
myriad problems associated with
improper hazardous waste dis-
posal. Instead of using taxpayer
dollars, EPA uses a "Superfund"
derived from environmental taxes
on crude oil and chemical feed-
stocks.
                      Because of the severity and
                    extent of pollution, EPA proposed
                    to add Western Processing to the
                    National Priorities List (NPL),
                    EPA's roster of serious uncon-
                    trolled or abandoned hazardous
                    waste sites requiring comprehen-
                    sive cleanup.
                     No taxpayer dollars are in
                          the "Superfund"
                      EPA ordered the owners to
                    cease operations and to provide
                    assurances of a timely cleanup.
                    When the owners failed to take
                    action, a court order closed the
                    plant and EPA assumed responsi-
                    bility for directing the cleanup.
    Western Processing
    Company, Inc.
    Timeline
                                           • Subsurface phase begins m
                    • Chemical detoxification developed for dioxin waste
                    • Public meetings on subsurface plan
 Waste contributors agree to conduct surface cleanup
 Surface work completed except for dtoxin

   •Site placed on NPL
   * Western Processing forced to close
   * Emergency actions stabilize site
   • 200 parties identified
                   • EPA conducts routine inspections

              • Congress enacts Superfund
                                         <&
  Western Processing begins
  operation
                                  1
 1961
  1980
1981
1983
1984
1985     1986   198:

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                      Superfund At Work  •  Western Processing Company, Inc., Kent, WA
                                                             Spring 1995
 EPA Stabilizes Site
   In April 1983, EPA conducted
 an emergency removal of 920,000
 gallons of hazardous wastes
 including PCB liquids, solidified
 paint sludges, recycled solvents,
 and mixed contaminated liquids.
   In addition, EPA capped a solid
 waste pile with a flexible, imper-
 meable cover and regraded
 portions of the site to ensure that
 contaminants did not spread
 further.  Ecology also installed
 storm water controls to minimize
 the risk of contaminants entering
 Mill Creek.

 Dioxin Dechlorination Aids
 Surface Cleanup
   Early site investigations re-
 vealed multiple problems above
 and below ground, and so
                          cleanup crews embarked on a
                          two-phase plan. In July 1984,
                          EPA and Ecology supervised a
                          group of responsible parties who
                          transported bulk liquids to a
                          federally approved facility for
                          disposal or incineration. This
                          group also removed and disposed
                          of transformers and substation
                          equipment, demolished on-site
                          buildings, and dismantled and
                          removed bulk storage tanks.
                            More than 2,400 truckloads of
                          chemical wastes, contaminated
                          soil, and debris were removed
                          from the surface, minimizing
                          further contamination of soil,
                          ground water, and surface water.
                          Crews graded the site and in-
                          stalled a storm water collection
                          and treatment system to dis-
                          charge into the local wastewater
                                             treatment plant.
                                                By the end of 1984, only one
                                             tank remained on site containing
                                             7,400 gallons of a dioxin-contami-
                                             nated oily liquid.  A by-product of
                                             the manufacture of pesticides and
                                             herbicides, dioxin is a stable and
                                             highly toxic compound with
                                             limited disposal or treatment
                                             options.
                                                Following a two-year search
                                             aided by EPA Research and
                                             Development laboratories, the
                                             Remedial Project Manager se-
                                             lected chemical dechlorination.
                                             The process featured an on-site
                                             mobile treatment unit that re-
                                             moved the chlorine from the
                                             dioxin with a low-temperature,


                                                            continued on page 5
      Siuny wall constructed
      Wastewater treatment plant begins operating
           r
     Treatment plant edacity doubted

                  Construction completed

                               Mill Creek dredging
              r
                                                 2,000 willow saplings pfertW along MB Creek
1988
1989
1991
1993
1994
1997
Ongoing

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                     Superfund At Work  •  Western Processing Company, Inc., Kent, WA
                                   Spring 1995
continued from page 4

low-pressure reaction that emitted
no pollutants or contaminated air.
The success of this process paved
the way for use at other hazard-
ous waste sites.

Subsurface Cleanup Poses
New Challenges
  While conducting the surface
cleanup, EPA tried to locate waste
generators, but many had moved,
gone out of business, or were
operating under new manage-
ment. The Boeing Company, the
largest single contributor, orga-
nized a coordinating committee
which allocated cleanup costs
based on the amount of hazard-
ous waste each had contributed
(the "volumetric share").
  EPA, Ecology, and the respon-
sible parties then began organiz-
ing a complex subsurface cleanup.
A wide range of "toxic soups"
had accumulated in underground
pockets of the site's irregular
geology. Specialists in
hydrogeology, engineering,
chemistry, and other fields helped
to develop an effective cleanup
plan.
  In March 1985, EPA held the
first of four public meetings at
Kent City Hall. EPA representa-
tives fielded questions from
community groups and city
officials who expressed satisfac-
tion to be involved in the deci-
sion-making process. In addition,
community involvement coordi-
nators issued regular fact sheets
about cleanup progress, set up
convenient information reposito-
ries, and encouraged local resi-
dents to watch the work from a
viewing tower built at the site.

Subsurface Cleanup Begins
  In September, 1985 EPA se-
lected a plan that included exca-
vation of highly contaminated
materials, selective excavation of
off-site soils, and a pump-and-
treat system for polluted ground
water.  Specific water quality
standards were imposed for
surface water in Mill Creek and
for a plume of contaminated
ground water that was migrating
from the site. The plan also
included excavation of contami-
nated sediments from Mill Creek.
  Following a second public
comment period and a series of
negotiations, the waste contribu-
tors signed a settlement agree-
ment that went into effect in
April, 1987. In three short
months, construction crews
excavated and hauled away
approximately 25,000 cubic yards
of contaminated soil to an ap-
proved hazardous waste landfill.
Their elaborate trucking operation
including building temporary
roads and setting up staging,
lining, covering, and vehicle
decontamination areas. EPA
scheduled and coordinated these
operations in consultation with
local officials and residents.

Innovation Marks Ground
Water Cleanup
  The large number of variable
concentrations and distribution
patterns of pollutants in the
irregular geology required a
ground water cleanup strategy
that was both innovative and
flexible. Cleanup engineers
designed a customized pump-
and-treat system that required
installation of more than 200
extraction wells and three
vacuum pumps to withdraw
contaminated water for treat-
ment.
  A slurry wall, a deep, vertical
barrier that surrounds the site to a
depth of 45 feet, confined the
contaminated ground water,
increased pumping efficiency,
and prevented pollutants from
spreading.
  An on-site wastewater treat-
ment plant began operations in
October 1988. Modifications
installed in 1989 increased the
treatment capacity from 100 to
200 million gallons per minute
and reversed the process so that
metals treatment precedes air
stripping. Treated water enters
the city sewer system under a
state permit. The Pacific North-
west International Section of the
Air Pollution Control Association
recognized the air
strippers, the part
of the water treat-
ment system that
removed VOCs,with an
award for the
carbon regeneration unit.

Mill Creek Restored
  Workers completed major
construction activities at Western
Processing in December, 1991.
Final cleanup requirements for
the site included dredging por-
tions of Mill Creek and replanting
the banks. Removal of creek

               continued on page 6

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                    Superfund At Work  •  Western Processing Company, Inc., Kent, WA
                                 Spring 1995
 Cleanup Effort
continues from page 5

bottom sediments started in July,
1993 after installation of fish
barriers in the stream. Rocks and
anchored logs later installed in
the streambed enhanced fish
habitat. Some 2,000 willow
cuttings were planted on the
restored banks in March, 1994.
   Eighty new extraction wells
began operating in November to
intercept a shallow ground water
plume between an east drain and
the slurry cutoff wall. By reduc-
ing the concentration of heavy
metals in ground water, sedi-
ments and water quality will be
minimally affected in Mill Creek.
    Success at Western Processing
    Significant achievements at
  this Superfund site included
  immediate removal of thou-
  sands of gallons of chemical
  wastes and use of a new
  dioxin detoxification process.
  An award-winning ground
  water pump and treat system
  has enabled many species of
  fish and wildlife to return to
  rebuild the surrounding
  ecosystem.
  In addition/ waste contribu-
tors cooperated to complete
major construction activities in
four years and reimbursed
EPA for costs of emergency
activities. Communications
with the public ensured that
citizens were involved in the
remedy selection process.
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