Comments on the P.A. Rayonier Mill Clean Up Plan

DATE: October 21, 2019
Maia Bellon, Director                               Rebecca S. Lawson, P.E.,
LHGWA State Department of Ecology    Southwest Regional Office Section Manager  PO Box 47600                                         Toxics Cleanup Program
Olympia WA 98504

Marian Abbett, P.E.
Unit Supervisor
Toxics Cleanup Program
Southwest Regional Office

RE: Port Angeles Rayonier Mill Cleanup Plan

Dear Director Bellon, Ms. Lawson and Ms. Abbett,

The undersigned organizations and individuals are submitting our comments for the Port Angeles Rayonier Mill Cleanup Plan, which is dated xx, 2019. We actively are working towards the cleanup of the Salish Sea, which includes the Strait of Juan de Fuca and Hood Canal. Some of our organizations were petitioners to USEPA Region 10 for the Superfund listing of the site in 1998. Our comments follow:

• Removal of structures and debris. We support the removal the jetty and the wharf, with its nearly 1000 creosote pilings and newer arsenic-based pilings will be removed. We hope these removals will soon be undertaken.
• Options that leave contaminants in place. We oppose the proposed upland and sediment options which leave the pollutants in place, cover them with soil or sediment, monitor the site over years, and rely on institutional controls (such as signage, fencing, and allowing site access twice a week). This will not protect the public, protect the marine ecosystem, nor the wildlife. It will leave all life vulnerable for years. The proposed option does not meet the intent of the Shoreline Management Act nor, again, the Puget Sound Partnership cleanup mandate, of which Ecology is a major partner.
• Option that removes contaminants. We strongly support an option that will remove contamination. We believe that Rayonier is a wealthy company and can afford the cleanest options of only $55 million. The company should leave the Port Angeles community and Puget Sound healthy. As sea level rises and as storm surges create more destruction along our coastline, it makes no sense – morally or financially – to leave the hazardous waste in place. The waters host endangered and threatened species. Including chinook and Southern Resident Killer Whales. Furthermore, a quality cleanup, as was done by the Port of Port Angeles at the KPly/PenPly site and at Site 4 in the Lower Duwamish Waterway — complete removal – results in the elimination of future costs and maintenance, long term monitoring and liability.

Lastly, Ennis Creek, which runs through the center of the mill in which citizens and the Lower Elwha Klallam Tribe invested many resources towards its renovation, is known for having the greatest potential for salmon habitat recovery among Port Angeles’s streams. We have an obligation to assure that the fish and other wildlife are not endangered by remaining hazardous wastes and not treated with the best available technology. Wastes left at the site will defeat the tremendous investments made to date.

We strongly urge you to hold Rayonier to the best cleanup option. Protect our natural resources, our wildlife, and our public health. Get this done well and soon.

Signed,
Steve Koehler, Protect the Peninsula’s Future President

CLICK HERE FOR THE TECHNICAL REPORT:
Rayonier Mill Site Cleanup Report Vol 3
Comments on behalf of the Olympic Environmental Council