CLOSURE REPORT SOIL REMOVAL AND DISPOSAL FORMER OIL STORAGE AREA

WRIGHT CITY MILL

January 12, 2010

CLOSURE REPORT

SOIL REMOVAL AND DISPOSAL FORMER OIL STORAGE AREA

WRIGHT CITY MILL

Prepared for

Weyerhaeuser Company 810 Whittington Avenue

Hot Springs, AR 71901-1060

Prepared by

FTN Associates, Ltd. 124 West Sunbridge, Suite 3

Fayetteville, AR 72703

FTN Project No. 6540-111

January 12, 2010

January 12, 2010

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TABLE OF CONTENTS 1.0 INTRODUCTION ...............................................................................................................1 

2.0 REMEDIAL ACTION .........................................................................................................2 

2.1  Removal of Site Structures ......................................................................................2 

2.2  Soil Excavation ........................................................................................................2 

2.3  Stockpiled Soil .........................................................................................................3 

2.4  Waste Material Profiling and Disposal ....................................................................3 

2.5  Backfilling Excavation.............................................................................................3 

3.0 CONFIRMATION SAMPLING .........................................................................................6 

4.0 REFERENCES CITED ........................................................................................................8 

LIST OF APPENDICES APPENDIX A: Analytical Data

APPENDIX B: Non-Hazardous Industrial Sold Waste Certification Form

APPENDIX C: Waste Manifest Forms

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LIST OF TABLES Table 2.1  Chemical data summary for waste material profiling and

confirmation samples .............................................................................................. 4 

LIST OF FIGURES Figure 1  Onsite management of demolition material,

November 17-18, 2009 ........................................................................................ F-1 

Figure 2  Wright City Former Oil Storage Area during excavation, November 19, 2009 .............................................................................................. F-2 

Figure 3  Management of soil stockpiles ............................................................................. F-3 

Figure 4  Site upon completion of soil backfilling and grading .......................................... F-4 

Figure 5  Confirmation sampling grid ................................................................................. F-5 

Figure 6  GRO results for the soil excavation area ............................................................. F-6 

Figure 7  ORO results for the soil excavation area ............................................................. F-7 

Figure 8 DRO results for the soil excavation area November 20, 2009 ............................ F-8 

January 12, 2010

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1.0 INTRODUCTION

Weyerhaeuser and the Oklahoma Department of Environmental Quality (DEQ) have

entered into a Memorandum of Agreement and Consent Order (MACO) dated December 4, 2007

for Supplemental Characterization under DEQ’s Voluntary Cleanup Program (VCP).

Weyerhaeuser’s property that is being characterized is located in Wright City, McCurtain

County, Oklahoma. Weyerhaeuser completed the supplemental characterization of the former dip

tank area and the results are presented in the Supplemental Characterization Report dated

January 9, 2009 (FTN 2009a). During the investigation, impacts to soil related to the use of a

former oil storage tank located adjacent to the rail spur on the north side of the dip tank area

were identified. Sampling to further delineate petroleum hydrocarbon impact to soil was

conducted in response to DEQ comments contained in letters dated February 18, 2009 and

April 27, 2009, and the results were presented in a technical memorandum dated June 26, 2009

(FTN 2009b). As agreed in a July 16, 2009 meeting with DEQ, Weyerhaeuser conducted

additional surface soil sampling (0 to 2 ft) along the railroad spur and east of the former oil

storage tank (FTN 2009c). A subsequent risk assessment completed by the Center for

Toxicology and Environmental Health (CTEH, August 2009) indicated that current and/or future

on-site workers may directly contact petroleum hydrocarbon contaminants in shallow soil via

incidental ingestion of soil, skin contact with soil, and inhalation of chemicals in soil particles.

Diesel range organics (DRO) and gasoline range organics (GRO) in surface soil (0 to 2 ft) and

DRO in subsurface soil (2 to 10 ft) were identified as the chemicals of concern in the former oil

storage. Clean up and removal of petroleum hydrocarbon impacts in the former oil storage area

was described in the soil removal and disposal work plan (FTN 2009c), which was approved by

DEQ in a letter dated October 27, 2009.

This closure report is being submitted pursuant to Section 4.0 of the work plan

(FTN 2009c). It contains documentation of remediation activities and presents the results of

confirmation sampling.

January 12, 2010

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2.0 REMEDIAL ACTION

This section describes the remedial actions taken to remove TPH soil contamination

found in the shallow soils near the former oil storage area. Remedial activities included

excavation of soil and concrete, temporary storage of soil piles, and off-site disposal of

excavated soil at an authorized facility.

2.1 Removal of Site Structures Prior to the commencement of remedial activities, Weyerhaeuser removed treated

railroad ties and other wood and metal debris from the excavation area (Figure 1). It was

previously thought that work would proceed with care so as not to disturb the railroad spur;

however, Weyerhaeuser removed 120 ft of the rail spur to facilitate excavation activities. The

contractor, Tri-Lakes Services, Inc. then removed the concrete slabs and containment structures.

These concrete materials were demolished and approximately 75 cubic yards of concrete

material was moved to an existing onsite concrete debris pile.

2.2 Soil Excavation Soil removal began on November 16, 2009 and was completed on November 20, 2009

(Figure 2). Tri-Lakes Services, Inc. used common demolition and earth moving equipment to

excavate the contaminated soils. The area of contamination was initially estimated to be 150 ft

by 50 ft. The plan called for excavating to a depth of 2 ft below ground surface except for the

area near sampling site W509, which would be excavated to 4 ft. Two feet of soil were initially

removed from the entire area. During excavation, a buried swale that was about 20 ft wide and

narrowed with depth was encountered. Soil within the buried swale was visually stained and had

a strong hydrocarbon odor, thus instead of removing 200 cubic yards of impacted soil as

planned, approximately 1,500 cubic yards, and about 80% of the area was excavated to a depth

of 4 ft. Based on the results of confirmation sampling (Section 3.0), an additional eight cubic

yards of soil were removed from an area where TPH contaminated soil exceeded the Tier 2a

DEQ soil cleanup levels for DRO. The final excavation was 160 ft by 50 ft (0.2 acres).

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2.3 Stockpiled Soil An elevated concrete platform located south of the soil excavation area was used for the

temporary stockpiling of excavated soil. The area and was lined with poly-plastic sheeting, and

soil piles were covered to prevent run-on and run-off during precipitation events (Figure 3).

2.4 Waste Material Profiling and Disposal Upon completion of the excavation, stockpiled soil was sampled on November 20, 2009

and analyzed for the presence of TPH constituents by Oklahoma Method 8021B/8015M. One

grab sample was taken for every 20 cubic yards of material removed. A composite sample

representing 10 of these grab samples, was used to characterize up to 200 cubic yards of

contaminated soil. A total of eight composite samples (“COMP 1” through “COMP 8”) were taken

from areas of greatest visual contamination within the stockpiles and submitted to Environmental

Science Corp. (ESC) of Mt. Juliet, Tennessee (Table 1). Appendix A contains analytical results

from the waste profile sampling. These data were then used to complete a Non-Hazardous

Industrial Sold Waste Certification Form which was submitted to DEQ (Appendix B). Wastes

were approved for disposal at McCurtain County Landfill in Idabel, Oklahoma. Stockpiled soil

was hauled to this facility for disposal from December 22, 2009 through January 7, 2010.

Appendix C contains waste manifest forms.

2.5 Backfilling Excavation The excavation was backfilled with clean fill material and compacted from December 17

through December 20, 2009. The fill material consisted of dirt and gravel from a borrow pit

located of Highway 98 near Wright City. A sample of fill material (“Fill”) was collected on

December 11, 2009 for analysis of TPH components to verify the fill was clean. Appendix A

presents these data. Figure 4 shows the site upon completion of backfilling, after which the area

was seeded with a mixture of rye and fescue and covered with hay to prevent erosion.

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Table 2.1. Chemical data summary for waste material profiling and confirmation samples.

Sample ID Date

Collected Units

Benzene (Method

8021/8015)

Toluene (Method

8021/8015)

Ethylbenzene (Method

8021/8015)

Total Xylene

(Method 8021/8015)

TPH GRO (GRO

Method)

TPH DRO (Method

8015)

TPH ORO (Method

8015) A1 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

A1N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 8.9 8.6 A1W 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 5.3 A2 11/20/2009 mg/kg <0.0025 <0.025 0.0053 <0.0075 3.2 1200 48

A2N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 15 21 A3 11/20/2009 mg/kg <0.0025 <0.025 0.0067 <0.0075 1.5 51 <4.0

A3N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A4 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 100 27

A4D 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 200 32 A4N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A5 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 1000 160

A5N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A6 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

A6N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A7 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 0.58 <4.0 <4.0

A7N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A8 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

A8E 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 A8N 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 B1 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

B1S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 B1W 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 20 15 B2 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 20 4.9

B2S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 B3 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 8.7 <4.0

B3S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0 B4 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 1000 34

B4D 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 0.0096 0.92 580 56

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Table 2.1. Chemical data summary for waste material profiling and confirmation samples (continued).

Sample ID Date

Collected Units

Benzene (Method

8021/8015)

Toluene (Method

8021/8015)

Ethylbenzene (Method

8021/8015)

Total Xylene

(Method 8021/8015)

TPH GRO (GRO

Method)

TPH DRO (Method

8015)

TPH ORO (Method

8015) B4S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 0.016 0.94 260 29

B4SD 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 120 36 B5 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 0.52 2200 340

B5S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 1.3 330 130 B6 11/20/2009 mg/kg <0.0025 <0.025 0.0038 0.0083 3 3300 170

B6-5 12/12/2009 mg/kg na na na na na 15 na B6S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 0.02 5.4 940 450 B7 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

B7S 11/20/2009 mg/kg <0.0025 <0.025 0.0044 0.017 12 560 800 B8 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 120 110

B8E 11/20/2009 mg/kg <0.0025 <0.025 0.047 0.19 44 1200 1100 B8ED 11/20/2009 mg/kg <0.0025 <0.025 0.015 0.074 20 500 690 B8S 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 <4.0 <4.0

TRIP BLANK 11/20/2009 mg/L <0.00050 <0.0050 <0.00050 <0.0015 <0.10 na na COMP 1 11/20/2009 mg/kg <0.0025 <0.025 0.019 0.024 4.2 490 86 COMP 2 11/20/2009 mg/kg <0.0025 <0.025 0.0066 0.0096 1.4 630 120 COMP 3 11/20/2009 mg/kg <0.0025 <0.025 0.013 0.026 4.1 770 340 COMP 4 11/20/2009 mg/kg <0.0025 <0.025 0.016 0.019 8.8 230 90 COMP 5 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 940 170 COMP 6 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 <0.50 84 35 COMP 7 11/20/2009 mg/kg <0.0025 <0.025 0.021 0.12 34 370 100 COMP 8 11/20/2009 mg/kg <0.0025 <0.025 <0.0025 <0.0075 0.63 760 160

Notes: na = not applicable.

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3.0 CONFIRMATION SAMPLING

In accordance with the approach approved by DEQ in the Soil Removal and Disposal

Work Plan (FTN, September 11, 2009), the excavated area, which was 160 ft by 50 ft, was

divided into a sampling grid that was used for confirmation sampling. The sampling grid

consisted of two rows (row A and row B) of eight 20’ x 25’ cells (Figure 5).

Discrete soil samples were collected from the bottom center and along the side walls of

each cell. Confirmation sampling was conducted on November 20, 2009 and December 11,

2009. A total of 37 confirmation soil samples, four sample duplicates, and two trip blanks were

submitted to Environmental Science Corp. for laboratory analysis of GRO, DRO, and ORO

using Method 8015M and BTEX using Method 8021B/8015. Samples were received by the

laboratory in good condition, except for one trip blank that was damaged during shipping.

Samples were properly preserved and labeled and chain-of-custody (COC) documentation was

complete. Appendix A contains analytical reports. Table 1 is a chemical data summary for

confirmation samples.

Cleanup levels for the TPH contaminated soil followed the Tier 2a DEQ soil cleanup

levels:

• 500 mg/kg GRO,

• 2500 mg/kg DRO, and

• 5000 mg/kg ORO.

BTEX compounds were compared to the USEPA 2009, Region 6 Human Health Medium

Specific Screening Levels for Industrial soil.

TPH contaminants were not detected in soil samples collected from 10 of the 16 cells.

Only eight cells had low levels of GRO, ranging from 0.52 mg/kg to 5.4 mg/kg, which are well

below the DEQ soil cleanup levels (Figure 6). Eleven of the 16 cells had low levels of ORO

ranging from 5.3 mg/kg to 1100 mg/kg, all of which were below soil cleanup levels (Figure 7).

BTEX compounds were detected in samples from eight cells. Benzene and toluene were not

January 12, 2010

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detected in soil samples. Low levels of ethylbenzene and xylene were detected but their

concentrations were below regional screening levels.

DRO was detected in 13 of the 16 grid cells that were sampled and ranged in

concentration from 8.7 mg/kg to 3,300 mg/kg. The DRO concentration initially exceeded the

DEQ soil cleanup level in one cell (i.e., B-6) (Figure 7). On December 11, 2009, additional

contaminated soil was removed from cell B-6, as previously discussed, and the cell was

resampled (i.e., sample B-6-5) and submitted to the laboratory for analysis of DRO. Results for

the confirmation soil sample showed DRO levels (15 mg/kg) well below the 2,500 mg/kg

cleanup level, thus Weyerhaeuser commenced backfilling the excavation on December 17, 2009.

January 12, 2010

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4.0 REFERENCES CITED CTEH. 2009. Risk-Based Evaluation of Chemicals in Soil and Groundwater, Weyerhaeuser

Wright City Site, Wright City, Oklahoma, August 2009.

FTN. 2009a. Supplemental Characterization Report, Former Dip Tank Area.

FTN. 2009b. Dip Tank Supplemental Site Characterization Addendum, memorandum to Mr. Jon Reid, June 26, 2009.

FTN. 2009c. Soil Removal and Disposal Work Plan, Former Oil Storage Area, Weyerhaeuser’s Wright City Mill. Prepared for Weyerhaeuser Company, Federal Way, WA, September 11, 2009.

Oklahoma Department of Environmental Quality. 2009. Risk-Based Cleanup Levels for Total Petroleum Hydrocarbons (TPH), Land Protection Division, May 2009.

FIGURES

F-1

Figure 1. Onsite management of demolition material, November 17-18, 2009.

F-2

Figure 2. Wright City Former Oil Storage Area during excavation, November 19, 2009.

.

F-3

Figure 3. Management of soil stockpiles.

F-4

Figure 4. Site upon completion of soil backfilling and grading.

.

F-5F-5

Figure 5. Confirmation sampling grid.

F-6F-6

Figure 6. GRO results for the soil excavation area, Wright City Mill.

F-7F-7

Figure 7. ORO results for the soil excavation area, Wright City Mill.

F-8

Figure 8. DRO results for the soil excavation area November 20, 2009, Wright City Mill.