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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