NEWEST: 12/16/2015: Backbone Campaign's official Technical Memorandum by Farallon Consulting reviewing the K2 Sports 2015 characterization is HERE.
12/1/15 Update on Former K2 Factory and What We Are Learning:
In late November the Department of Ecology published their review of the environmental assessment or "characterization" of the former K2 factory property on Vashon. This is the result of your activism and Backbone Campaign's organizing in the winter of 2014. Our petition to King County resulted in their requirement that any site on Vashon listed as "contaminated" or "suspected to be contaminated" with the Washington State Dept. of Ecology (DoE) must receive a No Further Action Letter from DoE before any change of zoning or conditional use permit is issued.
That resulted in K2Sports, under the ownership of Jarden Corporation to enter the DoE's Voluntary Cleanup Program. K2 went back to the drawing board to do a real site characterization to assess presence and levels of contaminants. When they submitted their September 2015 report, it indicated that yes, contaminants exceeding minimum mandatory clean-up levels are present. The Nov. 23, 2015 opinion letter from the Department of Ecology was the next step in the process leading toward cleanup. It accepted much of the work K2Sports/Jarden's contracted engineers at ERM had done, but rightly asked for further definition of the toxic plume under the building.
The official Technical Memorandum by Farallon Consulting reviewing the K2 Sports 2015 characterization is HERE
Our Technical Memorandum expands upon and supplements the analysis by Dept. of Ecology available online HERE.
The characterization of the former K2 Ski factory on Vashon Island that was submitted by K2 Sports in September 2015 is available online HERE.
Here's our initial post:
Backbone took this opportunity to consult with an environmental engineer Cliff Schmitt from Farallon Consulting whom we had commissioned the Technical Memorandum in 2014. That 2014 Technical Memorandum raised serious questions about the previous Phase I and Phase II assessments which had been flouted as adequate by the company and developers alike. Clearly, much more work needed to be done at the site. Now we are beginning to get a picture of the nature of what needs to be addressed.
Bottom line is that serious chemicals were used in the production process. These are chemicals that will stick around and have the potential to do harm in the future. For years, these toxins went into a drain and into a drainfield under the main building. From there, they have migrated into what is referred to as a plume. The spread, depth and nature of that plume are not yet understood. The Water District 19 well nearby is close enough that DoE is mandating that K2/Jarden share all data with the Water District. So far, all reports I've heard say that the water is not showing any signs of these compounds. Let us hope that that is true and remains to be true.
What's next? K2/Jarden's engineering firm is going to have to do additional test wells to define the plume. DoE has permitted them to simultaneously begin a feasibility study of how the contamination, in some cases far above minimum mandated cleanup levels, is best dealt with. The materials that are continuing to feed the plume, a plume that is likely moving in complex ways down and out, must be removed and eliminated. I am speculating, but it seems highly unlikely that that can happen without removing the slab in the main building. There also appears to be another "hot spot" to the West of the main building.
The informal and preliminary assessments are below. We hope that the island will support us to get a formal report if others like Water District 19 do not.
If you appreciate that Backbone Campaign stood up for our community's well being when many wished us to be silent, please be sure to make sure we remain able to do so in the future by joining the Lumbar Club.
with Gratitude to and Love for this Community,
co-founder & E.D. Backbone Campaign
Here's the preliminary and unofficial analysis
- (We hope to get this in a formal form soon)
"The investigation documented in the report is a start towards characterizing the contamination at the former K2 facility. I only spent a brief amount of time reviewing the report but two substantive points stood out and must be addressed by a more thorough investigation of the facility before beginning consideration of potential cleanup actions."
"The points of release of trichloroethene (TCE) to soil at the facility were not identified. In order for any future cleanup action of TCE and its degradation products (cis-1,2-dichloroethene and vinyl chloride) to be successful, all sources (areas where soil contamination is present) must be identified and addressed during the cleanup. Based on my very cursory review of the report, the consultant seems to discount that soil contamination exists and does not even include TCE in soil as a concern. Obviously there are multiple sources present at the facility based on the configuration of contamination in groundwater and known size of the TCE plume in groundwater of about 4 acres.
- "Similarly, it is fairly obvious that the size and configuration of the plume of TCE in groundwater is not fully characterized. This statement is based on my experience of working on or reviewing the work by others at many (100s) of chlorinated solvent sites. While the consultant has correctly depicted the extent of groundwater contamination based on the available data shown on Figure 13, that data set is insufficient and I am quite confident that if a more thorough characterization of groundwater conditions is performed that the lateral and vertical extent of the plume will be much larger than this limited data set suggests. The basis for my opinion is as follows:
"The location of the sources of TCE in soil that are contaminating groundwater have not been identified. Therefore, it is highly likely that the current monitoring well network is not positioned to monitor areas where groundwater contamination is highest, i.e. at each source area. There is a moderate gradient of the shallow groundwater table of about 1.5 percent. This means that groundwater is flowing at a fair rate generally towards the south.
"There is no information in the report on the vertical gradient. To assess the vertical gradient would require installation of monitoring wells screened at successively deeper intervals. At a minimum, monitoring wells screened at deeper intervals should be installed adjacent to existing monitoring wells MW 4-5, MW 5-1, and MW-7-1. The intervals screened at these locations would be dependent on the soil types and water saturated intervals encountered during drilling. Also, monitoring well(s) should be installed west of monitoring well MW 5-1 and between monitoring wells MW 5-1 and MW 7-1 and screened at shallow and deep intervals.
"The TCE plume extending down-gradient (south) of monitoring well MW 4-5 is shown as being limited to a distance of about 100 feet. Based on the low concentrations of TCE degradation products in the plume and probable long timeframe that TCE was released at the facility, the plume should be much longer than depicted. Please note that TCE plumes won't grow to a large size unless there has been a very substantial release and a long migration period with little degradation of TCE.
I expect that upon further investigation, the plume of TCE will be found to be migrating vertically downward as it travels south. Therefore the position of the plume will be deeper than the screened interval of monitoring wells MW 5-1 and MW 7-1.
"These data gaps are substantive and must be addressed prior to this project progressing towards the evaluation of potential feasible remediation technologies for cleanup. The community should be pressuring K2 to complete the Site characterization."
The links to all the related documents are HERE