Hello Jim,
Sorry this took so long but if it helps, the site conditions are pretty stable and have not changed much, except to gradually improve. Minor amounts of the off-road diesel (ORD) product are still seeping into the upper level excavation area in a few isolated areas. The sorbent pads and booms are being maintained on a regular basis and we are receiving the logs from Lawrence Oil documenting those actions. The four attached photos were taken on January 28th, 2025. The pads with discoloration had been in place for four days at the time of the photo. Fresh pads are visible in several of the photos illustrating the contrast. The red tank seen in one of the photos contained the water that was pumped from the excavation area quite a while ago during a high rainfall event. To my knowledge, no other dewatering actions have occurred. I spoke with Dave Lawrence last Friday and he said all the water in the tank had been transported to the treatment plant that serves St Helens. MSBA previously obtained authorization for that transfer.
The coffee shop has been moved so the underlying soil at that location is now exposed and accessible. The original plan was to remove that soil as it was a source of the OFD entering the excavation. However, now that the seepage has diminished, we are currently assessing whether excavation at that location is necessary.
Lawrence Oil conducted a test of the steel ORD product lines using pressurized air over a period of several days. The test revealed that the lines did not consistently maintain pressure. However, no obvious leaks were observed. The ORD product lines running east-west from the AST area, are contained within a concrete vault that has a steel grate at the surface and are visible. The ORD lines running north from the vault to the dispensers are housed within a conduit for secondary containment, and are not visible from the surface. Based on the pressure test result and previous site observations, MSBA concludes that the former ORD release most likely originated from a leak in the pressurized lines within the secondary containment running north to the dispensers. The secondary containment drains south into the east-west concrete vault and is then conveyed to the oil water separator. Lawrence Oil is actively planning to replace the ORD product lines in the near future. The replaced lines will be decommissioned at that time. Until then, the ORD system will remain offline.
Progress on the permits allowing future investigation and cleanup in the wetland area continues slowly but steadily. Below is a status summary of the ongoing permitting process.
USACE Joint Permit Application:
We anticipate the fieldwork for mapping the boundaries of the wetland (wetland delineation) will be completed in mid-February. The wetland delineation report will be completed about 3 to 4 weeks after the fieldwork.
MSBA will prepare and submit a brief work plan for collecting additional soil and sediment samples to determine what areas will require excavation.
The 401 Water Quality Pre-Filing meeting application will be submitted after the wetland delineation report is completed.
NPDES Permitting:
The NPDES permitting is in progress. We’re currently in the process of evaluating whether a “No Exposure Certification” is applicable to the site.
Sincerely,
Marty Burck
Licensed Geologist OR, CA, WA
Phone: 855 387 4422