Washington State Penitentiary
Walla Walla, WA
Remedial Investigation/
Feasibility Study (RI/FS)
Final Work Plan
Produced for:
Toxics Cleanup Program
Eastern Regional Office
Washington State Department of Ecology
Spokane, Washington
By:
Ecology & Environment, Inc.
720 Third Avenue, Suite 1700
Seattle, WA 98104

June 2009
Updated by Parametrix, Inc.
1231 Fryar Avenue
Sumner, WA 98390

February 2010
Under Contract to the Washington State Department of Corrections
Contract No. 10-321A

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T

able of Contents

Section

1

Introduction................................................................................... 1-1
1.1
1.2
1.3
1.4
1.5

2

Objectives and Purpose ........................................................................................ 1-1
Precipitating Events ............................................................................................. 1-2
Definition of the Site ............................................................................................ 1-2
Document Organization ....................................................................................... 1-3
Limitations ........................................................................................................... 1-3

Site Description and History ........................................................ 2-1
2.1
2.2
2.3

2.4
2.5

3

Page

Location ............................................................................................................... 2-1
Historical and Current Facility Use ..................................................................... 2-2
Environmental Setting ......................................................................................... 2-2
2.3.1
Regional and Site Geology ................................................................... 2-2
2.3.2
Regional and Site Hydrology ................................................................ 2-2
2.3.3
Stormwater Drainage ............................................................................ 2-4
2.3.4
Climate .................................................................................................. 2-4
Environmental Site Regulation and Compliance History .................................... 2-5
WSP Landfill History .......................................................................................... 2-6

Evaluation of Existing Data and Identification of Data Gaps ..... 3-1
3.1

3.2
3.3
3.4

Previous Investigations and Existing Data .......................................................... 3-1
3.1.1
1984 PCB Appraisal ............................................................................. 3-1
3.1.2
1992 Initial Investigation ...................................................................... 3-1
3.1.3
1995 Site Hazard Assessment ............................................................... 3-2
3.1.4
1995 Site Assessment ........................................................................... 3-2
3.1.5
1996 UST Removal .............................................................................. 3-3
3.1.6
1998 Preliminary Hydrogeologic Evaluation for WSP Landfill .......... 3-4
3.1.7
1999 Sudbury Landfill Site Contaminant Source
Identification/Assessment Report ......................................................... 3-5
3.1.8
2000 Preliminary Assessment Washington State Penitentiary
Narrative Report ................................................................................... 3-6
Contaminants of Concern .................................................................................... 3-6
Areas of Concern & Summary of Findings ......................................................... 3-7
Data Gaps ........................................................................................................... 3-10
3.4.1
Extent of Landfill ................................................................................ 3-10
3.4.2
Landfill Content .................................................................................. 3-10
3.4.3
Soil Contamination ............................................................................. 3-10

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Table of Contents (Cont.)
Section

3.5

4

Page
3.4.4
Groundwater Characteristics & Contamination .................................. 3-11
3.4.5
Stormwater Drainage .......................................................................... 3-11
Preliminary Conceptual Site Model ................................................................... 3-11

Statement of Work ........................................................................ 4-1
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9

4.10
4.11
4.12
4.13

Introduction .......................................................................................................... 4-1
Develop Conceptual Site Model .......................................................................... 4-1
Identify Applicable Cleanup Levels .................................................................... 4-1
Conduct Further Research to Resolve Known Data Gaps ................................... 4-1
Ecological Evaluation .......................................................................................... 4-2
Identify ARARs ................................................................................................... 4-2
Identify Present and Proposed Land Uses ........................................................... 4-2
Identify and Confirm Suspected Sources and Contaminants of Concern ............ 4-3
Execute SAP ........................................................................................................ 4-3
4.9.1
Groundwater Investigation ................................................................... 4-3
4.9.2
AOC Investigation ................................................................................ 4-3
4.9.3
Additional Investigation Measures ....................................................... 4-4
4.9.3.1 Buried Drum Interim Action ................................................. 4-4
4.9.3.2 Landfill Soil and Waste Characterization ............................. 4-4
Fulfill QAPP ........................................................................................................ 4-4
Complete a Site-Specific Risk Assessment ......................................................... 4-4
Conduct a Feasibility Study ................................................................................. 4-4
RI/FS Report ........................................................................................................ 4-5

5

Submittal Requirements............................................................... 5-1

6

Project Schedule........................................................................... 6-1

7

References .................................................................................... 7-1

Figures
Appendices
A

Sampling & Analysis Plan

B

Quality Assurance Project Plan

C

Health and Safety Plan

D

Washington State Penitentiary Security & Tool Policies

E

Project Schedule

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ist of Figures

Figures
1. Site Location Map
2. Facility Site Plan
3. Area Topography Map
4. Area Topography and Surface Water Features
5. Site Drainage
6. Stormwater Drainage (North)
7. Preliminary Site Conceptual Model Map
8. Preliminary Site Conceptual Model Diagram

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ist of Tables

Table

Page

Table 2-1 Summary of Detections in Groundwater & Surface Water ....................................... 2-8
Table 3-1 TPH-D Detections in Soil from WSP UST Excavations ........................................... 3-4
Table 3-2 Depth to Groundwater and Groundwater Elevation for WSP Landfill
Monitoring Wells ....................................................................................................... 3-5
Table 3-3 Washington State Penitentiary Areas of Concern and Contaminants of
Concern ...................................................................................................................... 3-8

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ist of Abbreviations and Acronyms

AOCs

areas of concern

ARARs

applicable or relevant and appropriate requirements

COC

Chain of Custody

CSI/A

Contaminant Source Identification/Assessment

CSM

conceptual site model

DCI

Washington State Department of Corrections, Correctional Industries

DOC

Washington State Department of Corrections

E&E

Ecology and Environment, Inc.

Ecology

Washington State Department of Ecology

FS

Feasibility Study

GE

General Electric Apparatus and Engineering Services

HWA

HWA Geosciences, Inc.

LUST

leaking underground storage tank

MTCA

Model Toxics Control Act

O&M

Operations and Maintenance

PA

Preliminary Assessment

PCB

Polychlorinated biphenyls

PCE

tetrachloroethene

PCS

petroleum contaminated soil

PLP

Potentially Liable Party

QA/QC

quality assurance and quality control

RI

Remedial Investigation

RI/FS

Remedial Investigation/Feasibility Study

SAP

Sampling and Analysis Plan

SVOCs

Semi-volatile organic compounds

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List of Abbreviations and Acronyms (Cont.)

TCE

trichloroethylene

TDS

Total Dissolved Solids

TEE

Terrestrial Ecological Evaluation

TPH

Total Petroleum Hydrocarbons

TPH-D

Total Petroleum Hydrocarbons-Diesel

UST

Underground Storage Tank

VOCs

volatile organic compounds

WSP

Washington State Penitentiary

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1

Introduction
On behalf of the Washington State Department of Ecology (Ecology), Ecology and
Environment, Inc., (E & E) prepared a Remedial Investigation/Feasibility Study (RI/FS)
Work Plan for the Washington State Penitentiary (WSP), located in southeastern
Washington on the northwestern boundary of the town of Walla Walla (Figure 1). This
Work Plan (E&E 2009) presents the approach to complete a Remedial Investigation (RI)
that will provide the data necessary to conduct a Feasibility Study (FS). The FS will
evaluate remedial options for suspected contaminated soil and groundwater on the
grounds of the WSP and within the WSP Landfill.1
The Washington State Department of Corrections (DOC) is the Potential Liable Party
(PLP) responsible for completing the RI/FS at WSP. DOC retained Parametrix, Inc. to
implement the RI/FS, including updating this RI/FS Work Plan with specific information
regarding Areas of Concern, supporting historical information, investigation rationale,
media to be sampled, sampling methods, sample types, sampling locations, chemicals to
be analyzed, and the phasing and scheduling of the RI/FS. This Final RI/FS Work Plan
retains the structure and much of the content of the Work Plan prepared by E & E),
incorporates updates and revisions from a supplemental data search completed by
Parametrix, and has been approved by Ecology subsequent to detailed discussions
between Ecology and DOC.

1.1 Objectives and Purpose
The objectives of the RI/FS are as follows:




1

To determine the source of the chlorinated solvents observed in downgradient
groundwater monitoring wells.
To determine whether any other historical activities at the WSP have caused
on-site contamination that could affect off-site groundwater or surface water.

The WSP Landfill has also been referred to as the “Construction Demolition Landfill” (CDL),
“Construction Debris Landfill,” and “Construction Rubble Landfill.”

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1. Introduction




To characterize the nature and extent of any contamination that can be reasonably
identified in areas of concern (AOCs) at the WSP site.
To determine if any known contaminants are migrating onto WSP property from
upgradient suspect locations.

1.2 Precipitating Events
The RI/FS described in this Work Plan is stipulated under a 2008 Agreed Order
(No. 6200) between Ecology and the Washington Department of Corrections. Two
independent events precipitated the concerns and investigations that led to the Agreed
Order. In 1991 an anonymous complainant alleged that hazardous waste was improperly
disposed of in the WSP Landfill and the former power plant storm drain. In response to
this allegation, Ecology conducted an Initial Investigation in 1992. This investigation was
followed by an early notice letter informing WSP that it is a potentially liable party (PLP)
under the state Model Toxics Control Act (MTCA). The WSP Landfill was added to
Ecology’s Confirmed and Suspected Contamination Sites List on June 8, 1992 (Ecology
1992).
The second event involved an assessment of results from groundwater sampling
conducted in 1993 at locations west of WSP. Chlorinated solvents were detected in
groundwater samples collected from wells located upgradient of the Sudbury Road
Municipal Landfill (Sudbury Landfill) and downgradient of WSP Landfill (Figure 1)
(Ecology 1993). The wells are owned and operated by the Sudbury Landfill. This landfill
is approximately 2 miles to the west of the WSP.
From April 3, 1995, until June 29, 1995, Ecology conducted a Site Hazard Assessment at
the WSP Landfill. Based on the data collected during this assessment, the WSP was given
a ranking of “3” on August 22, 1995 (A “1” represents the highest relative risk, and a “5”
is the lowest). The “3” ranking is based on the potential for human exposure through the
groundwater pathway. Due to this ranking, the WSP was placed on the Hazardous Sites
List.

1.3 Definition of the Site
For the purpose of this work plan, the “site” is defined by the property boundaries of the
WSP, including the WSP facilities and the WSP Landfill. The site definition may be
updated by new information as it becomes available. A site area map can be seen in
Figure 1.

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1. Introduction

1.4 Document Organization
This work plan contains the following sections:







Section 1: Introduction – summary of the scope and organization
Section 2: Site Description and History – Description of current and historical
activities at the WSP as well as the background and setting of the
WSP
Section 3: Evaluation of Existing Data and Identification of Data Gaps –
Review of past investigations and current data gaps at the WSP
Section 4: Statement of Work – Description of sampling objectives and data
collection process
Section 5: Submittal Requirements – Description of the initial submittal
requirements of the RI/FS

The following RI documents are attached to this Work Plan:





Appendix A: Sampling and Analysis Plan (SAP)
Appendix B: Quality Assurance Project Plan (QAPP)
Appendix C: Health and Safety Plan (HASP)

1.5 Limitations
It is possible that the findings produced by executing this Work Plan may not be
sufficient to complete the FS. If this occurs, an additional phase of the RI will be defined
to fill in any remaining data gaps that may impede completion of the FS.
Due to the size of the WSP facility and budgetary limitations, the RI does not examine all
areas of the site equally. Instead, it focuses on AOCs identified by a review of available
information about past investigations and activities that were known to have involved
hazardous materials. It is assumed that current operations are in compliance with
applicable regulations. If new information becomes available about past activities or
current operations that suggest additional sources of contamination may exist, then
further investigation may be necessary.
One of the AOCs is located on a privately owned parcel, and many of the areas within the
penitentiary have strict access limitations. In addition, the WSP has a strict policy for the
types of tools and equipment that can be brought into the confined areas of the
penitentiary (see Appendix D). Therefore, accessibility to sampling locations and the
types of equipment permitted in some areas may be limited.

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2

Site Description and History

2.1 Location
The WSP is an active state corrections facility located in the south-eastern corner of the
state of Washington in the town of Walla Walla (Figure 1). The current address is
1313 N. 13th Avenue. The site consists of the WSP facility, the closed WSP Landfill, and
the surrounding undeveloped and agricultural land. The WSP property, including all
parcels, structures, and improvements both inside and outside the confined areas, has
been expanded numerous times over the years and currently occupies 560 acres. The
WSP Landfill is northwest of the facility and occupies 7.7 acres. The site is situated on
the northern slope of the east-west-trending Walla Walla Valley. The valley is gently
undulating and of low local relief. The site elevation generally ranges from 850 to
950 feet above mean sea level with general sloping toward the west (HWA 1998).
The facility is located within the SE ¼ section 13 and the NE ¼ Section 24, Township 7
North, Range 35 East, and the SW ¼ Section 18, and the NW ¼ Section 19, Township 7
North, Range 36 east, Willamette Meridian in Walla Walla County, Washington.
The site is bounded on the east by privately owned land and on the west by the
wastewater application section of the Sudbury Landfill and several upgradient
groundwater monitoring wells owned by Sudbury Landfill. State Highway 125 and more
privately owned land bounds the site on the north. The site is bounded on the south by
Mill Creek and a drainage pond located on a privately owned parcel that receives
stormwater from the WSP and other properties in its vicinity. Properties to the east and
south of the WSP include junkyards, industrial, fuel and agricultural-chemical facilities.
A Burlington Northern Santa Fe Railroad line that serves local industries is located along
the southern edge of the property. The city of Walla Walla also bounds the site on the
south. The WSP is topographically and hydraulically upgradient of the Sudbury Landfill
and downgradient of properties to the east and south (Figure 1).
The city of Walla Walla also bounds the site on the south. The WSP is topographically
and hydraulically upgradient of the Sudbury Landfill (Figure 1).

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2. Site Description and History

2.2 Historical and Current Facility Use
In 1883, the Territorial Governor authorized the selection of a suitable site for a
penitentiary. In 1885, Walla Walla was chosen. Construction began in 1886 using bricks
manufactured in nearby Dixie from the fine clay beds there. The WSP opened for
operation on May 10, 1887, as the historical starting point for Washington State
Corrections. To provide needed jobs for the prisoners, a one-story jute mill for the
manufacture of sacks was built in 1892. In 1921, the jute mill was transformed into a
license-plate factory, which continues to operate today, producing approximately
3,000,000 sets of plates each year. Today, the property consists of multiple parcels that
total 560 acres (DOC 2009a).
The WSP currently consists of approximately 90 buildings on site, and active expansion
projects are under way (Figure 2). WSP employs approximately 1,289 staff members.
Four different institutions house offenders at different custody levels: Maximum, Close,
Medium, and Minimum security (DOC 2009a).
The Washington State Department of Corrections, Correctional Industries (DCI) provides
jobs for offenders in a metal fabrication shop, a license plate factory, a welding shop, and
a garment factory, where offender clothing, staff uniforms, and other similar items are
made. There is also a sign shop that makes road signs for the state and counties, and a
furniture refurbishing shop that does wood and upholstery restoration (DOC 2009a).
Other site activities that provide jobs for the offenders include food service, janitorial,
and various prison operation and maintenance (O & M) functions including a photo
processing shop; X-ray, dental and medical laboratories; laundry and dry cleaning
operations; motor pool; fix-it shop; and grounds maintenance facility (Ecology 2000).

2.3 Environmental Setting
2.3.1 Regional and Site Geology
The stratigraphy of the WSP area consists of a basement rock composed of Columbia
River Basalt Group superimposed by a poorly defined sequence of weakly consolidated
sediments. The sequence is comprised of 250 to 300 feet of older basal clay overlain by
200 feet of lacustrine deposits comprised of gravels and sand interbedded with silts and
clay. This unit is overlain by approximately 30 to 60 feet of Touchet Beds consisting of
semi-consolidated lacustrine silt and alluvial sand and gravel deposits. Surficial deposits
in the area of the WSP are mapped as the Palouse silt formation, typically consisting of
loess (windblown non-stratified glacial silt) approximately 25 to 47 feet thick (Ecology
2000).
2.3.2 Regional and Site Hydrology
Two main aquifers occur in the Walla Walla region and are referenced as the gravel
aquifer and the deeper basalt aquifer. The deeper basalt aquifer is located within the
Columbia River basalt group. The shallow aquifer is located on top of the clay unit within
the lacustrine unit of gravels and sands interbedded with silts and clays (Ecology 2000).
The gravel aquifer is approximately 200 feet thick in the WSP area and is overlain by the
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2. Site Description and History

Palouse Formation loess (HWA 1998). Depth to groundwater in the shallow aquifer is
typically 30 to 65 feet below ground surface (bgs). Depth to groundwater in the deep
basalt aquifer is approximately 500 feet bgs (Ecology 2000).
The two aquifers are separated by 250 to 300 feet of clay. The basal clay unit serves as an
effective confining unit between the deep basalt aquifer system and the groundwater in
the upper-most sedimentary sequence. The shallow ground water aquifer is a source of
surface water recharge and irrigation supply wells. The deep basalt aquifer is the source
for public groundwater supply wells in the area (Ecology 1999).
A number of VOCs have been detected in the shallow sedimentary aquifer, including
trichlorofluoromethane, tetrachloroethene (PCE), trichloroethylene (TCE), and
chloroform. These contaminants were detected in the upgradient Sudbury Landfill
groundwater monitoring wells and the WSP Landfill groundwater monitoring wells. The
contaminants have fluctuated below and above the MTCA Method A cleanup standards
from 1991 until 1998, the only period of groundwater monitoring data available for
review. According to sample results they have been persistent during the time period
when samples were collected. Such characteristics suggest a continuous source may be
present in the vicinity or upgradient. Because of the historical operations at the WSP as
well as the allegations made in 1991, the WSP is a potential source of the contamination
(Ecology 2000).
The closest perennial surface water feature to the WSP property is Mile 6 of Mill Creek
(Figure 3). Mile 6 is located ¾ miles south of the prison complex. According to USGS
topographic maps, the main branch of this drainage network flows southwest across the
upland terrace and disappears approximately ½ mile north of Mile 4¾ of Mill Creek.
According to past investigations conducted in this area, this point, where the drainage
network disappears, is the area where the majority of the run-off from the WSP
discharges into shallow groundwater (Figure 3) (Ecology 2000). However, except in
cases of very high precipitation, stormwater runoff from the WSP property is believed to
infiltrate into the ground before reaching this point.
It is estimated that the probable point where groundwater, that may include stormwater
from WSP, discharges to Mill Creek is between Mile 3 and Mile 4 (Figure 3). This
location is about 2 miles southwest of the WSP property boundary and nearly three miles
from the WSP facility and the WSP Landfill (Ecology 2000).
Mill Creek joins the Walla Walla River at about River Mile 3½ (Figure 4). This location
is the apparent area of discharge for the shallow groundwater that could include
groundwater flow from WSP. A major tributary, the Touchet River, joins the Walla
Walla River at about Mile 21½. Wetland and riparian zones are abundant along Mill
Creek and the Walla Walla River for 15 miles downstream (Ecology 2000).
WSP records indicate that one of the irrigation wells (No. 4) is located near the WSP
Landfill. As of the time of the initial investigation conducted by Ecology this well was
left open and not abandoned properly (Ecology 1992b). The log of this well shows an
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2. Site Description and History

upper well casing 24 inches in diameter to a depth of 525 feet and completion as an open
hole from 525 feet to the depth of the basalt aquifer at approximately 1,004 feet bgs. An
open well casing observed at the WSP Landfill site by Ecology in 1992 was believed to
have been well No. 4. The Ecology data sheet described the well as open and not properly
abandoned, and it noted that a copy of the Ecology water well closure regulations would
be sent to the WSP officials. That well was subsequently closed and abandoned by
sealing and capping; however, it is unknown if during the time that the well was open
contamination was able to migrate to the deeper basalt aquifer (Parametrix 1995).
2.3.3 Stormwater Drainage
Stormwater at the WSP flows into one of two drainage basins, one to the north and one to
the south (Figure 5). These basins drain to respective natural drainage channels to the
north and south of the facility. Engineering controls on the WSP site, such as drains,
corrugated metal pipes, man-made ponds, and culverts, direct stormwater into either the
north or south drainage channel (HWA 1998). According to Figure 5, the majority of the
stormwater is diverted into the south drainage channel (Parametrix 1995).
The northern drainage basin, shown as basin No. 4 in Figure 5, collects agricultural
runoff from the fields to the north and east, as well as runoff from a small area of the
prison complex, including the Intensive Management Unit. This basin is approximately
120 acres and directs stormwater to the east-west-trending channel that runs through the
culvert underneath the WSP Landfill. This channel is dry most of the year.
Two ponds were constructed in the drainage channel northwest of the WSP Landfill in
the 1940s and still exist on site. They were designed to supply water for irrigation, but are
no longer used for that. Four catch basins that were installed for construction of the
parking lot seen in Figure 2 are also present in the drainage channel, east of the WSP
Landfill. These catch basins reportedly collect stormwater from surrounding areas and
discharge it to the culvert that runs beneath the eastern portion of the WSP Landfill,
eventually draining to one of the constructed ponds (HWA 1999). Further details about
the flow of the drainage channel can be seen in Figures 3 and 6.
During a recent site visit on April 8, 2009 the outlet of the culvert was not visible on the
west side of the landfill. It is possible that the original culvert outlet was buried as the
landfill expanded or from erosion of the fill material. The condition of the culvert under
the WSP Landfill could not be determined from a visual inspection of the area
(Ecology 2009a).
2.3.4 Climate
With an average precipitation of up to 18 inches, the Walla Walla area is considered arid.
August through November are the driest months (Ecology 1999).

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2. Site Description and History

2.4 Environmental Site Regulation and Compliance History
The WSP has a long-standing compliance history with the Department of Ecology.
According to Ecology records, compliance problems at the facility were first reported in
March 1990 immediately after the WSP was declared a large quantity generator. At this
time, WSP was penalized for improper waste management, shipping, labeling, and
handling. In November 1994, WSP was again cited for numerous large quantity generator
violations. During a 2001 hazardous waste inspection, several more hazardous waste
violations were found.
The most recent hazardous waste administrative order was issued in 2002 by Ecology to
WSP. In this order, WSP was penalized $54,000, which was reduced to $43,200 because
of implementation of an employee hazardous waste training program and creation of an
on-site environmental compliance position. WSP completed a contingency plan in 2004
and a facility inspection plan in 2005 to further facilitate regulatory compliance.
The waste generator status of WSP, which is based on the amount of dangerous waste
generated each month, has gone from large to medium to small quantity generator basis
in the last 10 years. From 2000 to 2004, WSP was a large quantity generator. WSP was a
medium quantity generator from 2004 until 2005, and since then has been a small
quantity generator. Several hazardous waste inspections have been conducted over the
last 20 years to confirm that WSP was filing the correct generator status and complying
with hazardous waste regulations. Summaries of these inspections are given below
(Ecology 2009b).
On August 1, 1990, a hazardous waste inspection was conducted at WSP. During this
inspection, several compliance problems were observed, including improper waste
discharges; accumulation past time limit; and failure to designate wastes, label hazardous
waste containers, file a manifest exception report, conduct facility inspections, have a
contingency report, or have a training plan (Ecology 1994).
Another hazardous waste inspection was conducted on November 8, 1994, when further
violations were observed, including failure to designate waste according to required
procedures, send dangerous waste to a permitted facility, provide required notice of a
spill or discharge to Ecology, adequately label containers, provide a personnel training
program, develop a schedule for maintenance and inspection of all monitoring
equipment, prepare a contingency plan, or conduct weekly inspections of dangerous
waste accumulation areas and containers. Documented waste materials included
antifreeze, perchlorethylene sludge, lacquer thinner, still bottoms, spent methylene
chloride, photochemicals, and petroleum naphtha solvent (Ecology 1999).
Additional environmental incidents were a report of a leaky underground storage tank
(LUST) and alleged dumping of chemicals into the powerhouse stormwater drain and
into the WSP Landfill. The LUST, reported to Ecology in April 1996, was a 500-gallon
diesel tank with a hole in the end. DOC reported to Ecology that the UST had been
removed and 30 to 35 tons of petroleum-contaminated soil excavated for disposal at the
Sudbury Landfill.

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2. Site Description and History

2.5 WSP Landfill History
The WSP Landfill served as the principal disposal site for DOC construction and
demolition debris, ash from the penitentiary boiler, and yard and farm waste from the
former state farm from the early 1970s until 1987 (HWA 1998). According to DOC the
facility was constructed in conformance to the regulations in effect at the time (WAC
173-301). When it was created in the early 1970s a culvert was installed in the natural
swale of an east-west-trending intermittent drainage channel to allow drainage to
continue to flow under the landfill. The construction details and materials used for the
culvert are unknown. Portions of the drainage channel were filled with construction/
demolition debris, yard and farm waste, and boiler ash. The fill covers approximately
7 acres. Portions of the fill on either side of an unpaved road are referred to as the east
cell and the west cell (HWA 1998).
The west cell is 4.3 acres and is bordered on the south by a gravel road and a corn field,
on the west by an alfalfa field, on the north by the two manufactured ponds, and on the
east by the north-south access road and the east cell. At closure both cells were reportedly
capped with a one-foot thick cover of native soils (probably silts of the Palouse
formation). Subsequently, the West cell was used as a pasture and manure composting
area. Construction debris was reportedly exposed at ground surface, apparently as a result
of agricultural tilling (Ecology 2000).
The east cell is 3.4 acres, and is bordered on the north by an alfalfa field, on the east by
the drainage channel that receives stormwater from the north parking lot and IMU, and
on the south and on the west by a gravel road. For some time after the landfill closure, the
east cell served as a fenced pasture for cattle. Structures formerly on this cell include a
large feeding trough on the southwest side of the cell, a watering trough in the southeast
corner, and two open sheds on the north-central portion. Brick, concrete, rebar debris,
cow manure, and hay were scattered across the cell at the ground surface. It is unknown
whether the east cell is still used as a pasture or whether any of the structures mentioned
remain in place (HWA 1998). The East cell soil cap, though apparently undisturbed, was
subsequently covered with nine to twelve inches of boiler ash (Figure 2) (Ecology 2000).
No landfill controls such as liners, leachate collection systems, or stormwater
management equipment exist at the landfill because at the time the landfill was closed in
1987, these prevention measures were not required. However, the WSP Landfill was
closed in accordance with regulations applicable at that time (HWA 1998).
In December 1991, Ecology received an anonymous complaint alleging that hazardous
substances had been disposed of in the closed WSP Landfill. Materials allegedly dumped
were hazardous chemicals, solvents, paints, thinners, and medical wastes. Ecology placed
the WSP Landfill on the Confirmed and Suspected Contaminated Sites List in May 1992
after conducting an initial site investigation of the WSP Landfill on March 11, 1992
(Parametrix 1995).

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2. Site Description and History

From 1991 through 1998 groundwater monitoring data from samples collected
downgradient of the WSP and at the WSP Landfill have indicated that concentration
levels for VOCs in the shallow alluvial aquifer sometimes exceeded MTCA Method A
standards and more often exceeded the more stringent Washington State Maximum
Contaminant Levels (MCLs) for drinking water. Levels of nitrate-nitrogen and Total
Dissolved Solids (TDSs) sometimes exceeded MCLs for drinking water. VOCs detected
within the groundwater include trichlorofluoromethane, PCE, TCE, and chloroform.
Toluene has been confirmed as a contaminant in surface water at the WSP Landfill
(HWA 1998). Groundwater and surface water sampling results are summarized in the
following table:

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Table 2-1 Summary of Detections in Groundwater & Surface Water
Well

Sampling
Date

Location

TCE
(µg/L)

PCE
(µg/L)

Toluene
(µg/L)

Chloroform
(µg/L)

Sudbury Road Landfill Monitoring Wells
MW-2

Between cells of SRL

MW-3

West side of SRL

MW-5

NE of SRL and
west of WSP Landfill

MW-7
MW-8

W of WSP on Property Line
Between SRL and WSP

MW-9

MW-10
MW-11

West of WSP Landfill on
WSP Property Line

SW of WSP on WSP
Property Line
South Side of SRL

6/15/1993
8/31/1993
12/30/1998
3/30/1993
4/13/1993
6/14/1993
8/31/1993
3/25/1998
9/21/1998
12/30/1998
7/14/1998
8/31/1993
3/30/1993
4/13/1993
6/14/1993
6/14/1993
8/31/1993
12/7/1993
8/30/1994
9/28/1994
11/8/1994
12/16/1994
2/18/1998
7/14/1998
2/18/1998
7/14/1998
12/30/1998

0.6
0.7
0.5
2.6
4
3.7
2
3
2.7
ND
ND
2.6
1.7
1.7
2.3
2.3
1.9
1.8
1.8
1.77
2.48
3.23
ND
ND
0.7

5.3
7.1
6.5
5.5
3
3
2.3
1.26
0.6
3.6
4.1
2.3
2.3
3.1
3.4
2.7
2.7
2.6
2.42
1.84
1.61
ND
ND

ND

0.7
ND

ND
ND
ND
ND

1.05
ND
2.04
1.49
1.2

ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
1.0 (dup)
1.07
ND
2.87
1.67

WSP Monitoring Wells
MW-1

North side of WSP Landfill

MW-2

900 ft west of WSP Landfill

MW-3

SW corner of WSP Landfill

MW-4

Between WSP Landfill &
IMU

2/18/1998
7/14/1998
2/18/1998
7/14/1998
2/18/1998
7/14/1998
2/18/1998
7/14/1998

1.73 (dup)
1.92
5.72
6.45
5.06
6.06
6.14
6.56

ND
ND
ND
ND
ND
ND
ND
ND

WSP Surface Water Samples
S-1
East side of east cell
2/18/1998
ND
ND
2.36
ND
S-2
NE side of west cell
2/18/1998
ND
ND
5.31
1.86
S-3
NW side of west cell
2/18/1998
ND
ND
23
ND
MTCA Method A Standard for groundwater
5
5
1,000
WA State Maximum Contaminant Levels (MCLs)
3
0.8
1,000
7
Blank = The sample was not analyzed for the contaminant, or the contaminant was not detected (unclear from source).
dup = The concentration was detected only in a duplicate of the same sample location.
ND = The contaminant was not detected at the detection limit for the analysis.
Bold = Exceeds current MTCA Method A Cleanup Level. Shaded = Exceeds more stringent MCL for water quality.

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3

Evaluation of Existing Data and
Identification of Data Gaps
3.1 Previous Investigations and Existing Data
3.1.1 1984 PCB Appraisal
In August 1984, the General Electric Company (GE) Apparatus and Engineering Services
conducted a site-wide polychlorinated biphenyl (PCB) transformer inspection and
prepared a PCB Regulatory Compliance Report for the WSP (GE 1984). Of the 92
existing oil-filled transformers, 90 were inspected, as well as oil circuit breakers and
oil-filled disconnects. The results of this inspection indicated that two transformers had
“running leaks,” and action was taken to provide containment. No confirmation exists on
how much oil actually leaked, what the leak effected, or if the oil was actually PCB oil.
The data plates on the transformers only listed insulating oil. As a precaution WSP
decided to label the contents as PCB oil without testing (EH 2009). The locations of these
two transformers, while in operation or while stored for disposal, are unknown. Some
equipment known to contain PCBs was temporarily stored in a building east of the Big
Yard between Buildings E50 and G50 (Figure 7) (DOC 2009b). Apparently this building
no longer exists and its exact former location is unknown.
3.1.2 1992 Initial Investigation
In March 1992, Ecology conducted an Initial Investigation at the Washington State
Penitentiary due to anonymous complaints of chemical dumping in the WSP landfill.
During the investigation, no contamination was visibly apparent. The migration pathway
of concern noted was groundwater. The investigation noted that a 10” well in the east part
of the landfill was not abandoned properly. The investigation also noted that livestock
carcasses had been disposed of near the northeast edge of the pond with numerous animal
bones littered around the site (Ecology 1992).
As part of the Initial Investigation, multiple letters were sent to former employees of
WSP, the County Health department, and the contractor used during the closure of the
WSP Landfill in order to gather further information. All respondents of this letter claimed
to have no knowledge of any inappropriate dumping at the WSP Landfill (Ecology 1992).
Because no evidence was found to support these claims, the Initial Investigation
determined that the site needed to be carried forward in the MTCA process.

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3. Evaluation of Existing Data and Identification of Data Gaps

3.1.3 1995 Site Hazard Assessment
Based upon the findings of the Initial Investigation, a Site Hazard Assessment was
conducted by SAIC in April 1995 in order to gather information on past and present
waste management activities and other site specific environmental data. This assessment
was conducted in order to score the site following the Washington Ranking Method
(WARM) Scoring Manual guidelines. Sites are ranked on a scale of one to five, with one
representing the highest level of concern, and five the lowest, relative to all other
assessed/ranked sites in the state. The overall ranking given to the WSP Landfill after the
field site hazard assessment was “3” (Ecology 1995).
No field measurements were collected at this time. Suspected hazardous substances listed
at this time were PCE and TCE. The quantities of these hazardous substances were listed
as unknown. The routes in which these hazardous substances were available were listed
as air and groundwater. No details about the source of these hazardous substances were
discussed; however, it was noted that TCE and PCE were found in the two wells
downgradient of the WSP Landfill and upgradient of the Sudbury Landfill. The site
hazard checklist noted that the WSP Landfill cover was not maintained and did not have
run-on/runoff control or cover. The checklist also noted that the landfill was unlined and
that liquid wastes may have been disposed of at the WSP Landfill (Ecology 1995).
3.1.4 1995 Site Assessment
Parametrix, Inc. performed a Site Assessment evaluation of the closed WSP Landfill in
June 1995. The purpose of the evaluation was to compile data on the landfill history and
site conditions and evaluate the types of disposed materials, the contaminant migration
potential, and the landfill condition (Parametrix 1995). The assessment concluded that the
WSP Landfill did not present an imminent threat to human health or the environment that
required immediate remedial actions. However, the assessment also concluded that there
was insufficient information to confirm or to rule out the possibility that contaminants
might be buried in the WSP Landfill (Parametrix 1995).
During the record search performed for the 1995 Site Assessment, it was discovered that
in 1956 an irrigation well (No. 4; no longer used) had been drilled near the current
location of the WSP Landfill. The well log for this well shows an upper well casing
24inches in diameter extending from the surface to a depth of 525 feet, at which point no
further casing was used and the well was finished as an open hole in basalt to a depth of
1,004 feet. An inspection report by Ecology from 1992 noted that the well was not
properly abandoned, and that a copy of the Ecology water well closure regulations would
be sent to the WSP officials. The well was eventually closed, sealed, and capped by
WSP. Although it cannot be confirmed, it is assumed that well No. 4 was properly
constructed and maintained while in use. However due to the fact that it was not properly
decommissioned as reported in the Initial Investigation, it is possible that the alleged
contamination may have reached the lower aquifer through the preferential pathway of
the open well. According to DOC the available records for drinking water wells in the
vicinity of the WSP landfill are unreliable. Therefore, it is difficult to assess the risk of
potential contaminant migration to the lower aquifer.
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3. Evaluation of Existing Data and Identification of Data Gaps

3.1.5 1996 UST Removal
Beginning in August 1995, DOC performed Underground Storage Tank (UST) removal
activities at the WSP. Over a period of 8 months six 500-gallon USTs and one
1,000-gallon UST containing diesel were decommissioned. All seven USTs were used to
supply diesel for several emergency generators on site. Tank removal operations were
followed by post-excavation soil sampling to evaluate whether any soil contamination
existed. Soil samples were typically collected from the walls and bottom of each
excavation pit. In all but one location the four wall samples were composited at the lab
into two samples for analysis (either north and east, or south and west). Typically, three
stockpile samples from the soil removed at each pit location were collected and
composited as one sample for analysis. Samples were analyzed for Total Petroleum
Hydrocarbons (TPH) as Diesel (TPH-D) by WTPH-D (DOC 1996).
Upon removal, all seven tanks and associated piping were described as having no visible
holes, abrasions or corrosion. No visible signs of contamination nor any odors were
observed at any of the seven tank pit locations. The report states that a field instrument
was not used at any of the excavations to determine whether hydrocarbon contamination
was present or further excavation and sampling were necessary (DOC 1996). Contrary to
the report, there is anecdotal evidence that a field device may have been used (DOC
2009c).
The laboratory results from collected soil samples indicated there were many cases where
confirmation samples had non-detect results, but there were multiple detections of
TPH-D in the sidewalls, bottoms, and stockpiles (see Table 3-1). At tank #11 (T11 in
Figure 7) a south sidewall sample could not be collected due to interference with a
building foundation. Although the two sidewall samples analyzed had non-detect results,
the bottom and stockpile samples had TPH-D detections of 640 ppm and 280 ppm
respectively, which exceeded MTCA Method A cleanup level in effect at the time. The
report states that an additional vertical excavation was conducted to a depth of 9.5 feet,
and that a soil sample was drawn with non-detect results. This sample was analyzed with
a different method-WTPH-418.1 for Heavy Oils (DOC 1996). However, it is unclear if
any contaminated soil remains under the adjacent building foundation. There is also an
additional UST location near the former motor pool (T* in Figure 7). The report did not
address this location.

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3. Evaluation of Existing Data and Identification of Data Gaps

Table 3-1 TPH-D Detections in Soil from WSP UST Excavations
Tank
Number

Sample
Number

1

MSC-1 SP

4

MSC-2 SP

8

Sample Location
and Type
3 stockpile samples
composited*

Depth Below
Grade (ft)

WTPH-D
Diesel (ppm)

Tank
Location**

n/a

210

Staff Parking

3 stockpile samples
composited*

n/a

96

Behind MSC Industrial
Building

WSP-4 NE

N & E sidewalls
composited*

5.5

32

Unit 1

8

WSP-4 SW

S & W sidewalls
composited*

5.5

28

Unit 1

8

WSP-4 SP

3 stockpile samples
composited*

n/a

47

Unit 1

9

WSP-2 SP

3 stockpile samples
composited*

n/a

59

Unit 5

11

IMU-1 B

discrete grab – bottom
of excavation

8.0

640

IMU-inside fence

11

IMU-1 SP

3 stockpile samples
composited*

n/a

280

IMU-inside fence

Former MTCA Method A Cleanup Levels for Soil

200

Current MTCA Method A Cleanup Levels for Soil
2,000
Source: DOC 1996
Notes: Bolded entries include exceedances of the MTCA Method A Cleanup Level Standards in effect in 1996.
* Samples were composited by the laboratory.
** Locations are listed as found in the reference.

3.1.6 1998 Preliminary Hydrogeologic Evaluation for WSP Landfill
In 1998, HWA Geosciences Inc. (HWA) was contracted by DOC to perform a
preliminary hydrogeologic evaluation of the closed landfill at the WSP. This evaluation
was designed to provide a preliminary understanding of the hydrogeologic characteristics
of the area and to evaluate surface water and groundwater quality in the area of the WSP
Landfill. In addition, the investigation was designed to evaluate the presence of landfill
soil gas at the WSP Landfill. The HWA investigation consisted of two phases. The first
phase was conducted during February 1998, and the second was completed in July 1998.
During the first phase, HWA installed four monitoring wells at the WSP Landfill, and
subsequently collected groundwater samples for laboratory analysis. HWA also sampled
two existing Sudbury Landfill monitoring wells (MW-9 and MW-10, Figure 1), and
collected stormwater samples from an intermittent drainage near the WSP Landfill.
During the second phase, HWA collected additional groundwater samples from the four
WSP Landfill monitoring wells and three Sudbury Landfill monitoring wells (MW-7,
MW-9 and MW-10). No stormwater samples were collected during the second phase
because none was observed in the intermittent drainage. A soil gas survey was completed
in the area of the WSP Landfill.
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3. Evaluation of Existing Data and Identification of Data Gaps

Groundwater elevations were also determined during the wet and dry seasons. Depth to
groundwater and groundwater elevations are given in Table 3-2.
Table 3-2 Depth to Groundwater and Groundwater Elevation for WSP Landfill
Monitoring Wells
Monitoring
Well

Top of Casing
Elevation

MW-1

February 1998

July 1998

Depth to
Groundwater

Groundwater
Elevation

Depth to
Groundwater

Groundwater
Elevation

898.90

57.97

840.93

61.79

837.11

MW-2

878.72

40.84

837.88

43.85

834.87

MW-3

909.61

69.10

840.51

73

836.61

MW-4

915.43

72.81

842.62

77.36

838.07

MW-7

No data

No data

No data

42.28

No data

MW-9

873.78

59.97

813.81

No data

No data

MW-10

858.66

22.73

835.93

25.3

833.36

Water quality Standards for Ground Waters of the State of Washington (WAC 173-200)
and MTCA Method A Cleanup Standards were used for evaluation of the analytical
results of all groundwater samples where applicable. Exceedances based on these criteria
observed during both phases included Total Dissolved Solids, iron, manganese, nitratenitrogen, TCE, and PCE. Toluene was detected in the three stormwater samples collected
but at concentration levels below the MCL (see Table 2-1).
Results of the soil gas survey indicated combustible gas in the east and west WSP
Landfill cells. The combustible gas might originate from hay and cow manure near the
surface.
The data collected during this investigation did not identify the source of the groundwater
VOC contamination at the WSP Landfill or at the Sudbury Landfill monitoring wells.
The report recommended quarterly groundwater monitoring of existing wells and
installing three new wells to further determine the source of the contamination. There was
no documentation available for review that stated any follow up investigation has
occurred.
3.1.7 1999 Sudbury Landfill Site Contaminant Source
Identification/Assessment Report
In 1999, Ecology completed a Contaminant Source Identification/Assessment (CSI/A)
study for potential sources of VOCs detected in the upgradient groundwater monitoring
wells at Sudbury Landfill. The Sudbury Landfill is immediately west of the WSP. The
CSI/A was conducted under a Site Assessment Cooperative Agreement between Ecology
and the Environmental Protection Agency (EPA).

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3. Evaluation of Existing Data and Identification of Data Gaps

The CSI/A study included a review of public and governmental documents, research on
the contaminant’s use and properties, interviews of officials and residents, and a field
reconnaissance (Ecology 1999).
Sudbury Landfill groundwater monitoring data for 1991 through 1998 indicated that
groundwater quality in the shallow aquifer was being impacted by upgradient sources. In
some samples Nitrate, TDS, and VOCs exceeded Washington State Water Quality
Standards. VOCs detected in the Sudbury Landfill’s upgradient monitoring wells include
PCE, TCE, trichlorofluoromethane, and chloroform (Ecology 1999). Because
contaminant concentrations are generally higher in the upgradient wells and lower in the
downgradient wells, the Sudbury Landfill is not the suspected source of the VOC
contamination (Ecology 2000).
Recommendations made at the conclusion of this study included the execution of a
Preliminary Assessment (PA) that focused on the WSP Landfill while also evaluating
past and present prison institutional operations.
3.1.8 2000 Preliminary Assessment Washington State Penitentiary
Narrative Report
In 2000, Ecology released a PA report. The purpose of the PA was to assess the
immediate or potential threat to human health and the environment in the area of WSP
and to collect information to support a decision on further action under CERCLA. PA
activities consisted of research and file review. Conclusions based on the PA included the
following:






The shallow sedimentary aquifer has been impacted by VOCs and the WSP
Landfill has been assessed as a high potential source of the contamination.
There is no information that indicates that Mill Creek or the Walla Walla River
has been impacted by either runoff or shallow groundwater from the WSP
property. However, because the streams ultimately receive water from the
penitentiary site, there is a possible threat to human health and the environment.
Because of the nature of the suspected contamination, there are opportunities for
soil exposure and air hazards; however, the threat is judged to be low.

3.2 Contaminants of Concern
In the past investigations noted above various contaminants and water quality parameters
have been investigated. Due to exceedances of regulatory limits (either MTCA Method A
or more stringent MCLs) and persistent detections chlorinated solvents and related
degradation products are the primary contaminants of concern (COCs) for this
investigation. Other VOCs are considered to be COCs because of multiple detections at
some period in time, including trichlorofluoromethane, chloroform, and toluene.
Although sampling activity may not be planned solely to identify these additional VOCs,
the VOC analysis of samples will include them.

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3. Evaluation of Existing Data and Identification of Data Gaps

Several Metals are a COC due to detections and some exceedances in past groundwater
samples, as well as information about past operations that pose a risk of releasing heavy
metal contaminants into the environment.
In certain AOCs semi-volatile organic compounds (SVOCs) are COCs based on the past
usage, storage and disposal of solvents, de-greasers and other potential source materials.
These AOCs include the former motor pool, former auto body shop and furniture
refinishing facility, the former hazardous waste accumulation area, and the sign shop.
Due to operational history and available information petroleum hydrocarbons (primarily
TPH-D) are a COC for specific AOCs. These areas involve the locations of two former
USTs, the auto body shop and the former Motor Pool. Further information is discussed
below.
Due to the limited areas of coal storage PAHs are a COC specifically related to the past
storage and burning of coal as fuel. Further field inspection will help to determine the
possibility of this contaminant reaching soil and eventually groundwater.
The location(s) of potential sources of PCBs are unknown at this time; however, due to
reported leaks from equipment potentially containing PCB oil, PCBs are a COC. Analysis
of PCBs will be limited to the identification of potential source locations.
Some investigations identified exceedances of water quality parameters such as TDS and
nitrates. However, because they will not be the target of any proposed cleanup action,
water quality parameters are not considered COCs, but are of interest to expand the
understanding of groundwater dynamics.
Section 1.4 of the Sampling and Analysis Plan (SAP, Appendix A) provides more detail
in defining COCs, including which are confirmed and which are suspected.

3.3 Areas of Concern & Summary of Findings
Based on the preliminary site conceptual model and evaluation of existing data, AOCs
and potential AOCs for the site have been chosen and are described below. An AOC is
defined as having the following characteristics:




Containing one or more contaminants, confirmed by either laboratory analysis OR
documented observations of a release; AND
Presenting a reasonable concern that contaminants have affected soil or
groundwater and may present a risk of contaminant migration or exposure to
human health or the environment.

These classifications may change based on the results of the RI/FS.

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3. Evaluation of Existing Data and Identification of Data Gaps

A potential AOC is defined as an area with the following characteristics:
 Information from the site history indicates that a hazardous material was used or
stored in the area; AND
 There is a reasonable concern that a spill or release may have occurred.
Table 3-3 Washington State Penitentiary Areas of Concern and Contaminants of
Concern
Area of Concern /
Potential Area of Concern

Contaminant of Concern

Reason for Concern

TCE and chloroform in
groundwater. Toluene, arsenic,
copper, lead, and manganese in
surface water.

Contaminants have been detected in
proximate groundwater and surface
water. Hazardous materials have
allegedly been dumped here.

2. Former dry cleaning services
(AOC)

No sampling has been conducted in
this area. Suspected VOCs include
TCE and its degradation products

The first laundry/dry cleaning
facility was built in 1930. Dry
cleaning activities continued until
1974 when they were moved to C30.
Dry cleaning continued until the
early 1990s (Ecology 2009a). PCE
sludge was stored on site at both
locations in 15-gallon drums just
outside the laundry buildings
(Ecology 1994). No sampling has
been conducted at either location,
but during demolition of the initial
laundry location, the DOC crew
noticed strong chemical odors, and
hazardous materials may have been
disposed of down the storm drain
(Ecology 2009a).

3. Former motor pool (potential
AOC)

No sampling has been conducted
here. Suspected COCs include
VOCs, SVOCs, metals, and TPH.

This area is a potential AOC
because it used many solvents,
degreasers, and petroleum products.
The possibility that spills and leaks
occurred in this area is high.

1. WSP Landfill (AOC)

4. Former UST areas (potential
AOC)

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Sampling has been conducted in the
former UST areas. All results were
under current MTCA Method A
cleanup levels. All tanks reportedly
contained diesel fuel.

3-8

Additional information obtained by
DOC in September 2009, and
further data evaluation by Ecology,
resulted in the conclusion that
sufficient soil sampling was done
during removal of the former USTs
and that additional soil sampling
will not be required. However,
testing of groundwater in future
monitoring wells drilled at WSP will
include petroleum hydrocarbons.

Washington State Penitentiary RI/FS
Final Work Plan

3. Evaluation of Existing Data and Identification of Data Gaps

Table 3-3 Washington State Penitentiary Areas of Concern and Contaminants of
Concern
Area of Concern /
Potential Area of Concern

Contaminant of Concern

Reason for Concern

5. Former auto body shop and
furniture refurbishing facility
(potential AOC)

No sampling has been conducted
here. Suspected COCs include
VOCs, SVOCs, metals, and TPH.

This area has been used for both
autobody work and furniture
refurbishing. There has been
extensive solvent use in the furniture
refurbishing shop as well as the use
of multiple petroleum products,
degreasers, and other materials in
the autobody shop. There is a high
possibility of spills and leaks.

6. Former hazardous waste
accumulation area (potential AOC)

No sampling has been conducted
here. Suspected COCs include
VOCs, SVOCs, metals, and TPH.

Because there were multiple WAC
violations, and because this storage
area dates back to pre-RCRA, this is
a potential AOC.
On the basis of additional
clarification provided by DOC in
September 2009 regarding historical
power use, steam generation, and
associated electrical components at
the site, Ecology eliminated PCBs as
SCOCs for AOC No. 7. Regarding
the boiler ash issue, the greatest
potential for exposure to ash is in
unpaved areas of WSP where ash
may have been used as fill (such as
the “yards” associated with the BAR
units and the western edge of the
WSP facility).

7. Steam plant boiler ash (potential
AOC)

No sampling has been conducted in
this area. PAHs and PCBs are
suspected.

8. Sign shop (potential AOC)

No sampling has been conducted
here. Suspected COCs include
VOCs and SVOCs.

This area has a long history of
solvent use during sign
manufacturing. There is a risk that
spills and leaks of solvents occurred.

9. Metal Plant #1 (potential AOC)

No sampling has been conducted in
this area. Suspected COCs include
VOCs

This area is used for manufacturing
license plates and also has a long
history of solvent use. Because of
the threat of spills and leaks over the
years, this area is a potential AOC.

Washington State Penitentiary RI/FS
Final Work Plan

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3. Evaluation of Existing Data and Identification of Data Gaps

Table 3-3 Washington State Penitentiary Areas of Concern and Contaminants of
Concern
Area of Concern /
Potential Area of Concern

10. PCB storage area (location of
two leaking transformers unknown)
(potential AOC)

Contaminant of Concern

Reason for Concern

No sampling has been conducted in
this area. PCBs are suspected.

Additional information obtained by
DOC in September 2009
documented the location of the
former cement block building where
transformers were stored, which had
a concrete floor and was demolished
in the mid 1990s. The area of this
former building was subsequently
graded and is now an open
grass-covered area. A facility wide
changeout and cleanup of
PCB-containing transformers was
completed at WSP in 1986. Any
potential leakage of older
transformers in the former storage
building would have been contained
within the building. After
considering this information,
Ecology concluded that AOC 10
would be eliminated from further
investigation.

3.4 Data Gaps
3.4.1 Extent of Landfill
A review of historical aerial photographs shows the lateral extent of the landfill
expanding throughout landfill operations from the start of the 1970s until its formal
closing in 1987. However, it is unclear whether wastes were disposed of throughout the
entire capped area. The construction details and vertical extents of the landfill are also
unknown. Although the culvert pipe material is unknown, its deterioration over time may
have created a pathway for precipitation that infiltrates the landfill.
3.4.2 Landfill Content
The contents of the WSP Landfill are unknown except for descriptions provided of the
construction debris deposited from the 1970s until 1987. It is not known whether there
are any drums or hazardous materials present in the landfill.
3.4.3 Soil Contamination
There is a lack of soil data to fully characterize confirmed COCs and to confirm or rule
out suspected COCs. The extent of any soil contamination at the former dry cleaning
facility is unknown. Other AOCs where no sampling has been conducted and suspected
contaminants may have reached soil need to be further investigated. Therefore, soil
sampling and/or a soil gas survey will be needed in various AOCs. Depending on initial
findings, this may require further investigation work beyond the initial scope.
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3. Evaluation of Existing Data and Identification of Data Gaps

3.4.4 Groundwater Characteristics & Contamination
Some hydrogeological data has been collected in the vicinity; however, the data is
insufficient to fully understand the characteristics of the shallow aquifer. A better
understanding of the dynamics of the aquifer will help guide decisions for any future
investigations as well as remedial options.
It is clear that the shallow gravel aquifer has had levels of VOCs. However, neither the
extents nor the source(s) of contamination have been identified, and the most recent data
is more than 10 years old. Some areas of concern may be sources of VOCs as well as
other suspected COCs (e.g., TPH and metals). Other upgradient facilities may also be
potential sources (Ecology 1999). There has been mention of contamination of
trichlorofluoromethane, but no data was available to assess the extent of contamination or
the potential source or sources.
It is also unknown whether the deeper basalt aquifer has been affected. It is not known
whether any contamination infiltrated the basalt aquifer through any water wells that
were improperly constructed, maintained, or closed. Such wells may present potential
pathways for the migration of contaminated groundwater from the shallow aquifer into
the deeper aquifer.
3.4.5 Stormwater Drainage
An updated stormwater drainage map is needed to determine current on-site storm water
drainage. According to figure 3, provided from the 1995 Site Assessment, it appears that
the majority of storm water on-site is diverted south into the southern discharge pond/
wetland area. Current storm water flow may have changed since 1995. It is likely that
much of the stormwater now goes to a combined sewer system. However, a more
complete and accurate understanding of the site’s stormwater pathways will provide a
better indication of potential contaminant pathways.

3.5 Preliminary Conceptual Site Model
The preliminary Conceptual Site Model (CSM) gives a general picture of the site
contamination based on current knowledge. According to WAC 173-340, the preliminary
CSM "identifies potential or suspected sources of hazardous substances, types and
concentrations of hazardous substances, potentially contaminated media, and actual and
potential exposure pathways and receptors" and assists in decision-making.
For the WSP, the preliminary CSM is based on the flow of precipitation, stormwater,
groundwater and surface water (Figure 8) along with identification of AOCs and potential
AOCs as described above and as shown in Figure 7. The AOCs and potential AOCs are
identified as independent areas, but each has the potential to contribute contamination
that may migrate off site via groundwater and/or stormwater pathways. The preliminary
CSM is illustrated in Figures 7 and 8.

Washington State Penitentiary RI/FS
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4

Statement of Work
4.1 Introduction
The purpose of the RI/FS is to evaluate whether any hazardous materials have been
disposed of in the closed WSP Landfill or whether any historical operations or disposal
practices have contributed to known or unknown off-site contamination. VOC
concentrations have been discovered in downgradient groundwater monitoring wells. It is
also necessary to determine the hydrogeologic characteristics of the study area.

4.2 Develop Conceptual Site Model
A preliminary CSM was developed for the site based on the results of historical research
(Section 3.4). The CSM portrays contaminant sources and possible transport pathways.
All information portrayed in the CSM is speculative and will be evaluated during
completion of the RI/FS.
The CSM will be further developed based on the results of this RI/FS, conceptually
portraying new contaminant sources and possible transport pathways.

4.3 Identify Applicable Cleanup Levels
In Washington, relevant and appropriate requirements for site remediation are set forth in
the MTCA Cleanup Regulation, WAC 173-340. Criteria for selection of cleanup
alternatives, including the preference for cleanup technologies, are presented in WAC
173-340-360. Since the soil contamination at this site is limited to VOCs, TPH, SVOCs,
PAHs, and metals, the following cleanup standards will be applied in WAC 173-340-720
for unrestricted land use: Table 1, Method A cleanup levels – Ground Water, and
173-340-740; and Table 2, Method A cleanup levels – Soil. If evidence suggests that
additional or different cleanup standards should be applied, this new information will be
compiled to support the revised cleanup levels.

4.4 Conduct Further Research to Resolve Known Data Gaps
For some of the data gaps noted in Section 3.3 additional information may exist that was
not available at the time of this report. Ecology and DOC will be consulted to identify
further sources of information that may help make investigation activities more cost
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4. Statement of Work

efficient and effective in collecting data. Such research can include, but is not limited to,
follow-up interviews, additional reports, facility information, site walks, and contacts
with local agencies and private parties.

4.5 Ecological Evaluation
The actual Terrestrial Ecological Evaluation (TEE) under MTCA will not be performed
until a later stage of the project. The information gathered under this Ecological
Evaluation will be used to determine whether there are potential impacts to ecological
receptors, and will provide the necessary information needed to complete the TEE.
Data will be collected on the types of vegetation present on the property, both proximal to
the secure perimeter and in areas that are less impacted by human activity. In addition, an
analysis of the presence or absence of threatened and/or endangered species will be
completed. Concentrations of contaminants in soil in and around the WSP Landfill will
also be used to complete the TEE.

4.6 Identify ARARs
Site-specific applicable or relevant and appropriate requirements (ARARs) that are
related to the remediation of the WSP site will be identified as part of the RI. The intent
is to identify potential ARARs to be used to evaluate remedial alternatives. Applicable
laws are defined as those requirements that are legally applicable as well as those that
Ecology determines to be both relevant and appropriate.
To be defined as “legally applicable,” a requirement must be propagated under state or
federal law and specifically address a hazardous substance, cleanup action location, or
other circumstance at the site. “Relevant and Appropriate” requirements are limited to
those requirements propagated under state and federal laws that while not legally
applicable, are determined by Ecology to address circumstances sufficiently similar to
those encountered at the site.

4.7 Identify Present and Proposed Land Uses
Land use to the north of the prison complex is dry land wheat farming. Activities in the
commercial/industrial area to the south and southeast of the WSP include food and
agricultural product processing; automotive and truck repair and service; metal working,
including fabrication, casting, and chrome plating; and petroleum product storage and
sales (Ecology 2000).
Most industrial and residential buildings in the area are connected to the municipal
sanitary sewer system and water services. Land use in the area will be confirmed during
WSP site visits, and an inventory of drinking water wells, irrigation wells, and resource
protection wells recorded with Ecology within a 0.5-mile radius of the property will be
compiled.

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4. Statement of Work

4.8 Identify and Confirm Suspected Sources and Contaminants
of Concern
The potential AOCs and suspected contaminants of concern identified in this Work Plan
and described in the attached Sampling and Analysis Plan (SAP) will be either confirmed
or ruled out during the RI. A phased sampling approach and procedures designed to
provide high quality data in an efficient manner will be applied during the RI. Sampling
locations will be based on a combination of current site conditions and historical
information. Field screening and visual and olfactory observations will also be used to
assist in choosing sampling locations.

4.9 Execute SAP
This section describes the general technical approach for the RI. The details of the
technical approach, including sampling methods and procedures, are described in the
Sampling and Analysis Plan (Appendix A). The RI fieldwork will consist of the
groundwater investigation and the AOC investigation.
4.9.1 Groundwater Investigation
The purpose of the Groundwater Investigation is to further develop the conceptual model
of the site and of sub-surface conditions of the WSP Landfill and other AOCs. The
Groundwater Investigation is described in detail in the SAP and QAPP (Appendices A
and B to this Work Plan, respectively) and will consist of the following activities:

ƒ
ƒ
ƒ
ƒ
ƒ

Drilling boreholes for installation of new monitoring wells.
Collecting soil samplings from the borings for chemical analysis.
Constructing and developing the monitoring wells.
Assessment of local water wells as potential sampling locations.
Completing the first quarterly RI groundwater monitoring event by sampling new
monitoring wells, selected pre-existing monitoring wells, and local water wells (if
sufficiently documented).

4.9.2 AOC Investigation
The preliminary scope of the AOC Investigation was developed from the AOC
delineation process and will include a geophysical investigation (WSP Landfill),
installation and sampling of gas probes (WSP Landfill), surficial and shallow subsurface
soil sampling, test pits, and soil gas surveys. Sampling details of the AOC Investigation
may change if site conditions (including direct-push soil probes) warrant a different
approach. Depending on access and availability, there may also be sediment sampling of
the suspected bodies of water. Additional information on the AOC Investigation,
including sampling techniques and analytical methods, is presented in the SAP and the
QAPP (Appendices A and B, respectively).

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4. Statement of Work

4.9.3 Additional Investigation Measures
Some additional investigations may be necessary that go beyond the scope outlined in
this Work Plan. These interim action activities will be implemented under an additional
scope of work at a later time decided by DOC and Ecology.
4.9.3.1 Buried Drum Interim Action
If buried drums (or other suspect containers) are identified during the AOC Investigation
work, an interim buried container investigation work plan will be developed. The purpose
of the buried container investigation is to determine the type and contents of the buried
container(s) identified through geophysical means. Such an investigation requires higher
levels of Health & Safety protection than what is necessary for this Work Plan. Removal
of the buried containers may be considered part of the investigation depending on the
data collected.
4.9.3.2 Landfill Soil and Waste Characterization
Further characterization of the WSP Landfill will be conducted via the excavation and
sampling of test pits in potential hot spots within the landfill.

4.10 Fulfill QAPP
All planning, implementation, and assessment procedures for quality assurance and
quality control (QA/QC) presented in the Quality Assurance Project Plan (Appendix B)
will be followed and implemented during the RI.

4.11 Complete a Site-Specific Risk Assessment
The results of the Groundwater and AOC Investigations will support preparation of a risk
assessment that identifies contaminant migration pathways and potential exposure
scenarios to plants, animals, and humans. This risk assessment will be based upon the
toxicological and fate/transport properties of the CCOCs revealed from the RI field
investigation, soil and groundwater conditions beneath the WSP site, and types and
locations of potential receptors. The TEE will be a component of the risk assessment.
Findings of the risk assessment will determine which CCOCs and their respective
exposure pathways will be addressed in the FS.

4.12 Conduct a Feasibility Study
The objective of the FS will be to evaluate appropriate remediation alternatives and select
the preferred remedial alternative. The FS will be performed in accordance with the
requirements of the Agreed Order and MTCA regulations, specifically WAC 173-340350 (8).

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4. Statement of Work

4.13 RI/FS Report
The documentation, results, and findings of the RI and FS will be presented in a Draft
RI/FS Report to Ecology. Pursuant to discussion of comments between Ecology and
DOC, a Final Draft RI/FS Report will be prepared for public review during the public
comment period. After Ecology has prepared a responsiveness summary to public
comments, Ecology and DOC will discuss revisions to the Final Draft RI/FS Report, after
which the report will be completed.

Washington State Penitentiary RI/FS
Final Work Plan

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5

Submittal Requirements
As part of the execution of this Work Plan the following documentation will be
submitted. However, additional documentation may be necessary if further investigation
is conducted to close the existing data gaps:







Health & Safety Plan – A site-specific health and safety plan that will address all
of the activity hazards likely to be encountered while executing the SOW.
Mobilization Plan – A site-specific mobilization plan that will address logistics,
required utilities, security, and interface issues with other involved parties.
Worker Identification & Background – As directed by DOC, security information
for all personnel who plan to conduct work at the WSP facility will be submitted.
The DOC will perform the background checks necessary to give clearance for
each individual.
Remedial Investigation/Feasibility Study Draft & Final – A draft and final RI/FS
report will be submitted to the extent supported by the investigative activities
outlined herein. A Feasibility Study may not be practical for this submission if
further data is necessary. If this is the case, the RI report will identify further data
gaps and recommendations for closing them.

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6

Project Schedule
The preliminary schedule for the RI/FS at WSP is provided in Appendix E to this Work
Plan. This schedule will be updated as the project progresses and will be included in the
required progress reports to Ecology.

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7

References
Ecology & Environment (E&E). 2009. Remedial Investigation/Feasibility Study Work
Plan (RI/FS), Washington State Penitentiary, Walla Walla, Washington. Prepared
for the Washington State Department of Ecology, Toxics Cleanup Program,
Eastern Regional Office, Spokane, Washington. June 2009.
General Electric (GE). 1984. PCB Appraisal. Conducted by GE for DOC. April 2-5, 1984.
HWA Geosciences Inc. (HWA). 1998. Preliminary Hydrogeologic EvaluationConstruction Demolition Landfill Washington State Penitentiary Walla Walla, WA.
Prepared for the Washington State Department of Corrections. September 3, 1998.
Parametrix. 1995. Closed Construction/Demolition Landfill Washington State
Penitentiary Walla Walla, WA. Prepared for the Washington State Department of
Corrections. June 23, 1995.
Washington State Department of Corrections (DOC). 2009a. Website.
http://www.doc.wa.gov/facilities/washingtonsp.asp. Washington State
Department of Corrections, Walla Walla, WA. Accessed May 2009.
_________. 2009b. Letter to Ms. Sandra Treccani of Ecology. Questions – Washington
State Penitentiary Site Clean up Investigation. Washington State Penitentiary Site
Clean-Up Investigation. May 22, 2009.
_________. 2009c. Comments on the Draft RI/FS Work Plan from Eric Heinitz (DOC) to
Ecology and Environment. June 2009.
_________. 1996. Division of Correctional Industries. Underground Storage Tank
Removal and Health and Safety Plan. June 1996.
Washington State Department of Ecology (Ecology). 2009a. Electronic Communication
from Sandra Treccani, Ecology, to Steve Siefert, Ecology and Environment, Inc.,
on site visit observations. April 9, 2009.
_________. 2009b. Electronic Communication from Sandra Treccani, Ecology, to Steve
Siefert, Ecology and Environment, Inc., on regulatory and compliance history at
WSP. May 12, 2009.

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7. References

_________. 2000. Preliminary Assessment Washington State Penitentiary Narrative
Report. Prepared by Phil Leinart, Hydrologist Toxics Cleanup Program, Ecology.
October 2000.
_________. 1999. Sudbury Road Landfill Site Contaminant Source
Identification/Assessment Report. Prepared under an Agreement between Ecology
and the U.S. Environmental Protection Agency. June, 1999.
_________. 1995. Site Hazard Assessment Data Collection Summary Sheets for the
Washington Ranking Method –Surface Water, Air, and Groundwater routes only.
Prepared for the Washington State Penitentiary. April 25 1995.
_________. 1994. Ecology Hazardous Waste and Toxics Reduction Program Inspection
Report. Prepared for the Washington State Penitentiary. November 1994.
_________. 1993. Memorandum: Sudbury Road Landfill- VOC Detection in Monitoring
Wells. From Bud Musgrove. October 12, 1993.
_________. 1992a. Early Notice Letter, from D. George, Ecology, to B. Johnson, WSP.
May 29, 1992.
_________. 1992b. Initial Investigation Data Sheets. Prepared by the Washington State
Penitentiary.

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Figures

Washington State Penitentiary RI/FS
Figures

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WASHINGTON
Groundwater Flow

Source: Google Earth Pro, 2008.

Washington State Penitentiary
Property Boundary

See Figure 2

Walla Walla

Washington State Penitentiary Landfill
MW-5
MW-2
MW-9
MW-4

Sudbury Landfill

MW-3

Burlington Northern Pacific Rail Road

MW-7

MW-10

MW-1
MW-8
MW-8A
MW-11
MW-6

CITY OF WALLA WALLA

Southern Drainage Pond

Key:
Sudbury Road Landfill Groundwater
Monitoring Well

Mill Creek

Washington State Penitentiary Groundwater
Monitoring Well
Washington State Penitentiary Property Boundary
Washington State Penitentiary Landfill
Sudbury Landfill
Note: Monitoring well locations are approximate.

ecology and environment, inc.
&

International Specialists in the Environment
Seattle, Washington

0

N

1072
Approximate Scale in Feet

2144

WASHINGTON STATE PENITENTIARY
Walla, Walla, Washington

Figure 1
SITE LOCATION MAP
Date:
6/9/09

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10:002330WD2703\fig 1

Key:
Washington State Penitentiary
Groundwater Monitoring Well

N

Washington State Penitentiary
Surface Water Sample Location

Not to Scale

Washington State Penitentiary
Property Boundary
Washington State Penitentiary Landfill

Washington State Penitentiary Landfill
Note:

Monitoring well and sampling
locations are approximate.

MW-1

Ponds
S-3

S-2
West
Cell

East
Cell

S-1

Washington State Penitentiary
Property Boundary
MW-4

MW-3

ecology and environment, inc.
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Figure 2
FACILITY SITE PLAN

WASHINGTON STATE PENITENTIARY
Walla, Walla, Washington

International Specialists in the Environment
Seattle, Washington

Source: Professional Ag Services, 2008.

Date:
6/11/09

Drawn by:
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10:002330WD2703\fig 2