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American Crossarm and Conduit (ACC), was until 1983 an active wood treatment plant on sixteen acres of land in the city of Chehalis, Lewis County, Washington. Chehalis has a population of 6,527. In 1986, ACC was inundated by flood waters which carried contaminants off-site. At least 10,000 gallons of wood treatment product, pentachlorophenol (PCP) in diesel solution, was lost during that flood. Today, ACC remains a public health hazard because of physical hazards and pentachlorophenol (PCP), polycyclic aromatic hydrocarbons (PAHs), and polychlorinated dioxins/furans (dioxin) contamination.

People who enter the site, which is not secure, are exposed to severe physical hazards among the abandoned and dilapidated structures. The plant structures are massive timbers set on pilings in marshy ground. Fires have weakened the wood structures and made them extremely hazardous. A major portion of the contaminants related to this site are in soils on-site. Also, soils around homes adjacent to the site are contaminated to a lesser degree. Other off-site contamination occurs in the adjacent industrial area, wetlands, and a nearby stormwater lagoon.

People in the community have health concerns which they relate to ACC. During December 1992, four residents who live near ACC told the Washington State Department of Health (WDOH) about their health concerns. They felt their family's health problems were related to the site floods of 1986, 1989, and/or 1990. Health effects reported to WDOH included: irregular vaginal bleeding, heavy menstrual bleeding and longer than normal menstrual periods, skin lumps in breasts or ears, swollen lymph nodes, flulike symptoms, colds, headaches and a miscarriage. The local newspaper, The Daily Chronicle, printed an article in late 1992 about these health concerns. No health outcome databases are available which contain information about the expected rates of symptoms/conditions reported by residents.

Flood waters have been the primary force to move hazardous substances off-site. On-site contaminated soil and groundwater remain a public health threat, now and in the future. PCP and PAHs are the primary contaminants identified in groundwater. To date, no off-site contaminated groundwater associated with ACC has been found.

The "Superfund" Record of Decision was completed in May 1993. Site remediation should begin. People should be kept from going onto the site which contains physical and chemical hazards. The off-site stormwater discharge lagoon should be posted to warn people of the contaminant hazard that exists there. Site remediation should insure that ACC will not be a future source of contamination in the area. When remediation is undertaken, safeguards should be put in place to avoid human exposure to contaminants.


A. Site Description and History

From the 1930s until 1983, American Crossarm and Conduit (ACC) operated a wood treatment plant on sixteen acres in the city of Chehalis (1, 2). During 1988, the United States Environmental Protection Agency (EPA) included ACC on the "Superfund" National Priorities List (NPL). ACC generated hazardous wastes which included diesel, machine oils, boiler blow-down, asbestos, pentachlorophenol (PCP), and assorted laboratory chemicals. Some of these wastes were spilled in operations or dumped onto a wetland landfill on site. This landfill may have received wastes from other generators. The landfill was not designed, constructed, or operated in accordance with current landfill practices (1).

ACC is within the 100-year floodplain of the Chehalis and Newaukum rivers (Figure 1). The facility is constructed on pilings and fill in a low lying marsh (Figure 2). Elevated Burlington Northern-Union Pacific railroad tracks run along the west side of the site. ACC contains four areas: a wood treatment works, kilns, the mill, and the landfill (Figure 3 & 4). The wood treatment area is partially fenced and has underground tanks, sumps, a former surface impoundment, and a control room. Wood was treated in this area with a mixture of diesel containing five percent PCP (1).

The area designated the Adjacent Area of Contamination (AOC) is the zone around ACC which includes: the Chehalis Avenue area, a commercial and residential section of the city, a play field, wetlands south and west of the site, a section of Dillenbaugh Creek, and a stormwater discharge lagoon (Figure 4 & 5). The wetland covers about 37 acres and drains into Dillenbaugh Creek. The Chehalis Avenue area consists of several city blocks of which about 20 percent is commercial, and over one-half of the balance is open space (5).

In 1985, soil contaminated with PCP was removed from the facility and used as fill in residential yards located east of the facility. The Washington State Department of Ecology (Ecology) ordered ACC to remove the contaminated soil and clean up the affected areas to a level in soil of 100 parts per million (ppm) PCP. The company complied with the order and removed the contaminated soil (5).

During 1986, ACC was inundated by flood waters of the Chehalis River. Hazardous substances were carried off-site into the AOC. Since 1986, ACC has been flooded five more times. An estimated 10,000 gallons of PCP-diesel solution washed off-site during the 1986 flood. In 1986, EPA did an emergency response action in the Chehalis Avenue area. In 1988 and 1989, EPA incinerated on-site some of the contaminated soil, sludge, and debris (1). Incineration generated about 207 tons of ash which is presently stored on-site (5).

The Agency for Toxic Substances and Disease Registry (ATSDR) released a Preliminary Health Assessment (PHA) for this site on April 4, 1990. The PHA concluded that this site is a public health hazard because humans are probably being exposed to physical hazards and to toxic contaminants. Based on data available at that time, the PHA identified PCP, PAHs, and the dioxin 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) as the contaminants of concern. Potential human exposure pathways noted in the PHA were consumption of contaminated fish or other biota, incidental ingestion, inhalation, and dermal absorption of contaminants from soil, surface water, and groundwater (4).

During 1991, EPA spread gravel over the treatment area to keep fugitive contaminated dust from becoming airborne. In 1992, aboveground tanks and piping were decontaminated and the steel was taken to a recycler. Laboratory chemicals and PCB electrical equipment were collected from various buildings and secured by placing them in an overpack. EPA also removed asbestos from exposed pipe and placed it in sealed drums. Today, drums of hazardous materials remain on-site (5).

In September 1992, EPA completed a Remedial Investigation (RI) and Feasibility Study (FS) for this site. Field work for the RI was done during 1990 and 1991. That work concluded that there was a potential threat to human health. The contaminants of concern identified in the RI were pentachlorophenol (PCP), polycyclic aromatic hydrocarbons (PAHs), and polychlorinated dioxins/furans (dioxin) (1).

EPA issued a Record of Decision (ROD) for the ACC during May 1993. The major components of the selected remedy include:

  • Excavation of contaminated soil from the Chehalis Avenue commercial/residential AOC and consolidation of this material on the ACC facility. Excavated areas would undergo confirmatory sampling and be back filled with clean soil and revegetated or covered as appropriate.
  • Demolition of the ACC facility (e.g., treatment works, mill, kilns, above and underground storage tanks, and all other structures).
  • Excavation of the ACC facility surface and subsurface soil from the most highly contaminated areas.
  • Removal of contaminated sediment from the stormwater lagoon and stormwater sewer for off-site disposal.
  • Removal of floating oil from groundwater under the facility (treatment works) as a short-term source control activity.
  • Disposal of the most highly contaminated excavated material at an approved off-site hazardous waste landfill.
  • Covering the ACC facility with clean soil, sloping and contouring land, and planting grass.
  • Implementing fencing and deed restrictions at the ACC facility.
  • Maintenance of soil cover and other institutional controls.
  • Performance monitoring and a five-year review (5).

B. Site Visit

On January 19, 1993, members of the Washington State Department of Health (WDOH) made a site visit with staff of the Washington State Department of Ecology (Ecology). On January 26, 1994, a second site visit was done with the Environmental Health Director for Lewis County Health District. The site was viewed from the fence line along Chehalis Avenue to the east and an adjacent play field to the south. The site was entered from the west side, which is open.

Large dilapidated buildings, demolition debris, tarp covered piles, barrels, and open space depict the site. A home across Chehalis Avenue from the site is abandoned. Nearby on the same street is an apartment complex. Along Chehalis Avenue ACC is enclosed with a seven- foot cyclone fence with three strands of barbed wire at the top. Several of EPA's signs were posted on the fence line. Each sign stated, "WARNING CONTAMINATED AREA POTENTIAL HEALTH RISK KEEP OUT".

A seven-foot-high wood fence line is along the south side of ACC next to a play field. This fence is intact, but could be opened easily. Several wood slats in the fence had been renailed recently. ACC's structures are of massive timbers on pilings. Repeated fires have weakened the wood supports and increased the hazard condition. The west side of ACC is open. Because of the adjacent play field, wood slat fence, and attraction of abandoned buildings on-site a physical hazard exists.

The site visit of January 26, 1994 with the Environmental Health Director for Lewis County found conditions unchanged from those observed in the earlier site visit. Between site visits EPA removed some underground tanks and piping from ACC. EPA stated recently that all free product on-site was now contained. This would reduce the further spread of contaminants if another flood should occur before remediation.

The Lewis County Environmental Health Director was concerned about continued public exposure to the stormwater discharge lagoon (Figure 3). The lagoon is off-site about 380 feet west of ACC between the BN-UP Railroad and Interstate 5. The inspection party got to the lagoon from the north. The lagoon is about 1,500 feet south of a surfaced road. The area between the lagoon and the surfaced road might be classified as wetland. Demolition debris is being dumped in this area. People have access to the lagoon from the north by foot or in an all-terrain vehicle. The lagoon may be accessible from the south along Dillenbaugh Creek.

The lagoon collects area surface water and discharge from a storm drain that runs west from Chehalis Avenue beneath ACC. A light sheen was visible on the surface of the lagoon. Warning signs posted at the lagoon by the Lewis County Health District had been taken down.

C. Demographics, Land Use, and Natural Resources Use


The city of Chehalis has a population of 6,527 people. The population age structure is divided into the following percentages: 27 percent are below the age of 18, 73 percent are at or above the age of 18, and 18 percent are 65 or older (1990 Census, U.S. Dept. of Commerce, Bureau of Census, July 1991).

Land Use

Adjacent lands are used for commercial, residential, light industrial, and play fields. The Chehalis Avenue area is used for commercial and residential purposes. A dairy products packaging plant is immediately north of the facility.

Natural Resources Use

The primary Chehalis municipal drinking water supply is drawn from the Newaukum River about 17 miles upstream from ACC. Their secondary drinking water supply is taken from the Chehalis River upstream from its confluence with Dillenbaugh Creek. The secondary water supply line passes beneath the southern portion of ACC. There are three private irrigation water supply wells up gradient from ACC (5).

Surface Water

Dillenbaugh Creek and its associated wetlands support significant fish populations of cutthroat trout, coho salmon, sculpins, three-spined stickleback, squawfish, shiners, and others. Dillenbaugh Creek is closed-water to salmon fishing, but recreational trout fishing is possible although not probable because of the small size of the creek (1).


Groundwater flow beneath ACC occurs primarily in a thin coarse-grained unit sandwiched between an overlying silt and clay deposit and the underlying bedrock. Recharge occurs where the coarse-grained unit outcrops at the surface and groundwater is discharged to the Newaukum River southwest of the site. Groundwater flow rates at the site are estimated to range from 10 to 100 feet per year (1).

Thirty-three domestic, irrigation, and municipal wells are located within a two-mile radius of ACC. The majority of these wells are in the outlying areas of Chehalis to the south and southwest, and are separated from the facility by the Chehalis and Newaukum Rivers and Dillenbaugh Creek. Area well water levels range from 30 to 110 feet below ground surface, with about 75 percent of the wells used for domestic purposes. The wells closest to ACC (within a 1/4 mile radius) are used for irrigation (1).

D. Health Outcome Data

Health outcome databases include the Washington State Cancer Registry, the Washington State Birth Defect Registry and Vital Statistics databases (live births, fetal deaths, deaths).

The Washington State Cancer Registry began operations in July 1991 and contracts with two regional tumor registries [Cancer Surveillance System (CSS) and the Blue Mountain Oncology Program (BMOP)] that together cover the entire state. The CSS of the Fred Hutchinson Cancer Research Center provides data on incident cancer cases in Western Washington, covering the majority of the state's population including the largest urban center. This population based cancer surveillance system includes the incidence and mortality of specific cancers since 1974 for 13 counties. CSS works under contract to the Surveillance, epidemiology and End Results (SEER) program of the National Cancer Institute. The BMOP covers the remainder of the state. BMOP regularly contacts hospitals in Idaho and Oregon to gather data on Washington residents who seek health care in those states. Cancer data for the area of the state covered by BMOP, including Lewis County, is available from July 1991 through 1992.

The Washington Birth Defects Registry is a registry of children with serious birth defects diagnosed before their first birthdays. The database contains information by major birth defect classifications and by demographic factors: county of residence, sex, race, address, and mother's occupation, smoking history, and age. As of August 1991, information was available for the entire state for 1986-1989. Health outcome data will be evaluated in the Public Health Implications section.

Vital Statistics databases are maintained by the WDOH Center for Health Statistics and include information on live births, fetal deaths, deaths, marriages and divorces for the entire state.

Variables included are geographic location (city, county, town), age, sex, race, address, cause of death, birth weight, gestational age, and birth defects.

The only specific health data available for the population living near ACC is that which was obtained in a 1993 one-page "fact-finding survey" prepared and administered by a concerned resident living near the site. The survey was administered to residents in 19 households in the area. The survey requested demographic information, provided a list of "chronic health problems" to indicate if present, asked about cancer in household members and pets, and the water source. The results of the resident survey will be discussed in the Health Outcome Data Evaluation section.


WDOH initially determined community health concerns in December 1992 by interviewing four residents who lived near the site. Concerns of the residents were reported in a newspaper article in The Daily Chronicle the same month. They felt their health problems and those experienced by their families were related to exposure to site contaminants during off-site flooding in 1986, 1989 and/or 1990. Reported health effects experienced by the residents or their family members included various combinations of the following: irregular vaginal bleeding (metrorrhagia), heavy menstrual bleeding and longer than normal menstrual periods, skin lumps in breasts or ears, swollen lymph nodes, flulike symptoms, colds, headaches and a miscarriage.

The local health district submitted concerns about the health of anyone trespassing on the property near the drainage lagoons.

These community health concerns will be addressed in the Community Health Concerns Evaluation section of this report.

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