26 August 1999

Executive Summary of Peter de Fur, PhD. Review of Region 10 EPA Addendum Final Combined Preliminary Assessment/Site Inspection Report
Rayonier Mt. Pleasant Landfill
Port Angeles WA
TDD:99-05-003
July 1999


These are the comments of the Olympic Environmental Council summarizing Dr. deFur's publicly funded review for citizens of the EPA Addendum dioxin site inspection of Rayonier's Mt Pleasant landfill and surrounding properties. This site inspection was at the request of Petitioners for the Superfund Assessment and their former TA, Dr. Joel S. Hirschhorn. The TA and EPA preceded the assessment with an agreed upon protocol for sampling and analyses and of specific sites. This request was made because we felt the first assessment was flawed in sampling and data interpretation.

The question is: Are there sufficient amounts of off-site dioxin levels to warrant EPA intervention. The answer is a clear and decisive "Yes."

* All roof drip line samples are elevated above normal levels, except one sample which, although close to normal, is still above normal.

* All sampled residential soils have elevated dioxin or furan levels. This is also true of the sampled sediments.

* Two soil samples from roof drip lines had clear, elevated levels that warrant confirmation and/or correction for the problem

* Dioxin levels in the water exceed water quality standards.

Also, the background levels used were inappropriate because they were elevated numbers and inconsistent background numbers were used.

The dioxin congeners in the landfill ash are consistent with the pattern, and the likely source of the dioxin contamination in residential roof drip line samples and elsewhere in the neighborhood.

Review of a 1993 report by a Rayonier paid for lab test shows there are dioxin/furan levels at near 69,000 ppt in ash hauled from the mill to the dump. This means hazardous waste was illegally dumped in a limited purpose landfill. It has to be surmised that given the open pit in those years, this highly contaminated ash was dispersed off site. There were report inconsistencies and staff vs. homeowner disagreements about where sampling occurred. This difference needs to be clarified.

As well, EPA should publish the sample sites and sample results Rayonier consultant's took from the property on Mt Pleasant bordering the south boundary of the Rayonier driveway into the landfill. The entrance onto this property by Rayonier representatives, supported by EPA, but at the opposition and discouraged approval of the property owners should be investigated. The action was unethical and maybe illegal. There was no notification to the Petitioners or to the property owners that Rayonier representatives would be allowed to attend the sampling, let alone take samples.


Tying together the results from the first and the second assessments, it is clear there are a broad range of dioxins, PCB's and heavy metals at significant levels through the neighborhoods.

Also, given the soil instability on which the dump rests, this hazardous waste site is poised to drop down into the community of 4 Seasons Park and Morse Creek and, by the river currents, be carried out into the Strait of Juan de Fuca. In order to avoid this horrific scenario, the bluff must be stabilized and the materials onsite, as well as offsite, remediated. Petitioners and Mt Pleasant neighbors should develop this plan together. It may necessitate removing the contaminated soils.

Meanwhile, because the dump is an imminent and substantial endangerment to health and natural resources, EPA should list this site on the Superfund National Priority List and oversee the actions with the residents. Short of this, Rayonier should purchase properties in the area and move the residents. Rayonier should post health bonds for present and potential health problems which may be the result of their exposure to the landfill contaminants.

Last, it was agreed that if EPA found significant levels of dioxins on this site, that would trigger an EPA resampling, according to our protocol, at 13th & M St. and Monroe Road landfills. This is the case and EPA should move forward to resample the other two sites. Air monitoring should be included in the assessments.


Darlene Schanfald
Project Director