December 28, 2010

Mr. Trevor Estlow, Senior Planner Humboldt County Planning 3015 H Street Eureka, CA 95501

Mr. Estlow: Subject:


Comments on the Project Referral for a Coastal Development Permit for the Freshwater Tissue Company Project, Samoa, California

Evergreen Pulp Incorporated, 1 TCF Drive, Samoa, California Case No. 1NHU892 - Humboldt County Case No. CDP-10-18 Assessor’s Parcel Number 401-112-014-000

Regional Water Board staff (Staff) reviewed the Project Referral for a Coastal Development Permit for Freshwater Tissue Company in Samoa. Staff has significant concerns with the project description and environmental issues with the proposed activities.

The project description lacks sufficient detail for staff to determine all the issues that relate to the demolition of the facility. For your information, this site has been identified as a contaminated site on the State Water Resource Control Board’s GeoTracker data base since 2003. The complete extent of contamination in soils and groundwater has not been determined. Several issues were identified from the project description and our concerns are detailed below.

Soil and groundwater contamination with elevated levels has been identified outside the majority of the buildings. It is likely that the contamination exists under the buildings. Exposure to the contaminants in vapor, soils, and/or groundwater may present a health risk to construction workers. This exposure risk is not addressed in the project description.

Some of the areas that are proposed for demolition have not been sampled due to access issues within buildings. It is unclear from the project description if demolition to grade includes removal of building foundations and floors. Significant worker safety

California Environmental Protection Agency

Recycled PaperMr. Trevor Estlow -2- December 28, 2010

precautions are needed in order to prevent exposure to contaminants that may exist under building foundations and floors. The precautions are not mentioned in the project description.

The project description indicates that 10,000 tons of concrete will be crushed and stockpiled onsite for future use or sale. There are insufficient details to determine if the concrete has been subjected to discharge of contaminants and therefore subject to hazardous waste requirements. In addition, until the crushed concrete has been tested, precautions for stockpiling will include protection from rainfall events and exposure to surface water runoff to prevent hazardous materials from entering surface waters and Humboldt Bay.

The project description does not contain sufficient details for Regional Water Board staff to determine the adequacy of spill prevention and control measures for the collection and disposal of hazardous materials remaining at the site. Specifically, the types of equipment to be stored on site to prevent discharges to the environment from spills and/or accidents during demolition require further clarification.

The project description does not include the precautions that will be used to prevent damage to environmental sampling locations (monitoring wells). These wells are located in various areas of the site and are critical environmental sampling locations for the continuing cleanup and abatement of discharges at the facility.

You may contact me at (707) 576-2673 if you have any questions. Sincerely,

Kasey Ashley P.G. Senior Engineering Geologist


cc: Mark Verhey, Humboldt County Division of Environmental Health

(Bold print added for easier reading.)

According to the application for a permit from the Coastal Commission for the demolition of the Samoa Pulp Mill, 800 truckloads of toxins will be transported off site.  Each truckload will be about 40,000 pounds.  Some of the materials to be removed include asbestos, lead based paint, mercury, polychlorinatd biphenal ballasts,
freon, and nuclear materials from a gauge.  Some of the materials will be transported to the Eel River Disoposal located in Fortuna. 

Work in the machine room was scheduled to begin December 20.  The remainder of the work is scheduled to begin January 3, 2011.  The pulp mill building will remain intact.

While we are glad that the mill is going to be demolished a  (Merry Christmas to us), we hope that there is will sufficient caution and oversight of the handling of toxins.  
Freshwater Tissue Co. has requested a Coastal Development Permit for the abatement and demolition of the existing bleach plant, oxygen delignification system , continuous digester, multi-effect evaporators and No. 1 and 2 recovery boilers in the Freshwater Pulp Mill complex.  The County of Humboldt Planning Division at 3015 H Street, Eureka, CA 95501 is accepting comments from concerned agencies until December 25, 2010.  Questions can be asked to Trevor Estlow, Senior Planner (