Port Angeles Rayonier Mill 2025 Comment Period

Mr. Sixkiller, 

 Thank you for your commitment to protecting our lands, waterways and larger environment.  I recognize you have many claims on your attention and have to balance sometimes competing demands and responsibilities. Yours is a difficult jo...↓b.

The cleanup of the old Rayonier is one of the challenges the Department of Ecology faces. I and my community are very dismayed that the Department of Ecology is not requiring a full clean up pf the old Rayonier Mill in Port Angeles. This negotiation has been going on since 2001. It seems to  be an enormous waste of resources and time given the millions of dollars which have been spent to restore fish passages, improve the economy of our area through tourism, business and locally sourced food--to name a few, because of an incomplete cleanup leaving forever toxins in the ground, rather than removing them.  Yes, we are a smaller city, however, climate maps show that we will be a preferred destination for those relocating because of climate change.  Below is my statement to DOE.  Please protect the interest of our communities, local, tribal, county and visitors, in advocating for the full cleanup of the Rayonier site in Port Angeles.

DOE Submitted Public Comment:

The cleanup of this site has been under negotiation since 2001 by the Department of Ecology and Rayonier. This area has not only grown in population, but has also become a major tourist destination nationally and internationally—resulting in an increased use of the Olympic Discovery Trail which goes through the contaminated Rayonier site.  Major changes have occurred in the understanding of pollution and the impact of chemicals on the environment and our food supply.  Federal, State, County and local governments have invested a great deal of time and money to improve and restore the environment, correcting mistakes (in part due to limited scientific understanding of the impacts) which damaged the environment and harmed human, aquatic and animal health. 

Below are a few examples of recent actions and investments in the local area relating to environmental restoration and protection, as well as increased use by the community and visitors alike—impacting the local economy and quality of life.

• DOE fined two oil companies on August 5th over $1.3 Million each for sludge and dangerous waste on their properties and which is still being investigated for their impact.

• The July 20th  tanker spill into the Elwah shut down drinking water for the City of Port Angeles and has unknown impact to protect newly restored salmon runs.

• Cost of repair to fish culverts on Ennis and Lee’s Creek  $136,000,000

• Olympic Discovery Trail Cost of Spruce Road Trail improvements $4,758,075.

Department of Ecology’s stated requirements-- “The cleanup action objectives include protection of the following: • Humans who could be exposed to contaminated sediment or exposed indirectly through the consumption of seafood. • The benthic invertebrate community and higher-trophic-level organisms that could be exposed to contaminated sediment. • Aquatic life and humans that could potentially be exposed to contaminated groundwater via the discharge of groundwater to fresh and marine surface water and sediment, and direct contact during construction. • Humans and terrestrial wildlife that could potentially come into contact with contaminated soil in the Upland Study Area.”

These requirements clearly state that potential exposure must be considered. Given the Olympic Discovery Trail is used daily and travels through the contaminated area to be addressed, the exposure risk is high.

In the report it states. “Only one of the evaluated alternatives can satisfy the requirement to use permanent solutions to the maximum extent practicable” Requirements for determining the appropriate method are Protectiveness, Permanence, Cost, Effectiveness over the long term, Management of short-term risks, Technical and administrative implementability, and Consideration of public concerns.”

Of the 7 requirements, only “management of short term-risks” can potentially be seen to meet the requirements in the Department of Ecology’s proposed clean up.  

The proposed approach does not “protect, provide permanence or assure effectiveness over the long term” for the area.  Capping provides no guarantee that it will remain safe. Climate change will likely have both short and long-term impacts.  We are already seeing a change in sea and groundwater levels, an increase in the severity of storms, and experienced a recent tsunami risk. There is no guarantee that the capped area will not be impacted. In addition, a fence and occasional monitoring do not ensure access or exposure to animals or humans will not occur—the fence or cap can be damaged and expose the public to toxins.  The only way to provide those assurances is to remove all known contaminants. 

“Cost” must include the impact on the economy and community.  Failing to remove the contamination, completely, places an additional burden on the state, county and local  governments, non-profits, communities and local tribes who have invested in restoring salmon runs and the local ecosystem.  It will have an impact on fishery and aquaculture—the harbor of Port Angeles and Salish Sea will not be safe with capped forever chemicals, given the uncertainty of rapid environmental changes which cannot be controlled or anticipated. 

“Technical and administrative implementability.” The complete removal of toxins is as available as with the current proposal by DOE.  What is not assured with the proposed plan, is future implementability given the environmental changes we cannot necessarily anticipate over the next 30 years. In addition, the possible impact of the toxins involved are not fully understood scientifically. The current proposal is insufficient, given the ability to completely mitigate the toxins by removing them.

“Consideration of Public concerns.” The public does not just include the local community.  It includes the Tribes, the local community, businesses, visitors to the area (including those coming from out of state and internationally) and organizations invested in the health and well-being of the area. In addition, prehistoric indigenous sites, which have yet to be accessed cannot be accessed in such a contaminated environment.  

The quality of life here is impacted by the presence of known toxins, no matter how well fenced and buried.  The site is on the highly used Olympic Discovery Trail, and damage to the minimally fenced area with only 30 years of monitoring is a very real risk. It is the definition of an attractive nuisance. There is no way to assure the community that the toxins won’t impact our economy, our food, our environment or our enjoyment of this area. That is why the overwhelming public response to the DOEs proposal is negative. 

The only legitimate option, based on the Department of Ecology’s own requirements, is the complete removal of toxins from the former Rayonier site. Rayonier is financially capable of correcting its damage. Its current reported value is $3.76 billion and it recently sold a property for $699,000,000. Partial removal is insufficient and unwarranted for the people of this community and this state.

Thank you for taking the time to read and consider my comments.

Diana L. Erickson, MDiv. JD

2227 E Lindberg Road

Port Angeles, WA 98362

Sent from my iPad

Public Comment on Proposed Rayonier Clean Up, August 12, 2025

Dear Department of Ecology Clean Up Staff,

As a City of Port Angeles resident who was here when the Rayonier Mill closed, It is extremely frustrating to know we have waited almost 30 years f...↓or a massive clean up on our waterfront, only to learn that what is being proposing is a non-permanent solution which involves covering up the site and fencing it off, rather than an actual and total clean up. This is unfair to the citizens of Port Angeles and other state residents who think that polluters should be accountable for not only cleaning up their messes, but doing so in a timely manner. That is the message we want to send to those whose work results in polluted lands and waterways. 

What is being proposed in Port Angeles does the exact opposite. It is literally more of a cover up than a clean up, and it has dragged on for decades. What’s worse, the proposed alternative involves covering over 10 acres of toxins with dirt and fill, capping a 7 foot high mound and fencing off that site along the water’s edge. We are not comfortable with the non-permanence and rammifications of toxins leaching out over time or having a toxic eyesore of a mound spoiling the view for residents and tourists alike. With sea level rise and more frequent and intense storms as a result of the climate crisis, that could mean a serious storm washing away the polluted sediments, releasing and spreading toxins in the environment, and then forcing another decades long “clean up“ process. 

That makes no sense. I agree with the City of Port Angeles whose consultant asserts that the analysis provided does not accurately reflect realistic proposed costs for the capping alternative, while overestimating the cost of carting the toxins off site, and not considering the costs of being unable to use that land or the views it blocks or the harm to endangered species like ESA-listed salmon and forage fish impacted as a result.  While it will take many truckloads to haul the contaminated soils offsite, how is that different then the many trucks which used to carry products from the Rayonier Mill or the many dangerous chemicals previously trucked in for the Mill’s paper-making process? Collecting and hauling off the polluted sediments makes much more sense compared to just collecting it and capping it at the water’s edge, resulting in an unstable problem being left for the next generation of Port Angeles residents. Not to be forgotten is how much less expensive this project would have cost had it occurred 30 years ago when the mill closed. The attempt to run out the clock has resulted in significant cost increases. That does not mean the good people of Port Angeles should now be shortchanged in terms of clean up. 

We have but one chance to get this right and that time is now. I support proposal SL-5 which is an actual full site clean up. The City and its residents deserve no less and it’s the company’s responsibility to right this wrong. We expect our state government to advocate for us in terms of protecting our lands, air, waters and viewscapes. We deserve no less. 

Thank you for your consideration of this comment. 

Cheryl Baumann

Resident, City of Port Angeles

baumannnw@yahoo.com

Hi Marian,

Washington Department of Health, Site Assessment and Toxicology section (SATS) reviewed the Interim Action Plan for Port Angeles Rayonier Mill Study Area (Feb 2025), with particular interest in the proposed cleanup levels, conceptual site m...↓odel, and future remedial actions as they pertain to protection of human health. SATS has the following comments/questions:

Pg. 30 – Section 4.2

In Section 4.2, the plan states that soil CULs are set to Unrestricted Land Use but suggests that this will be re-evaluated if the PLP demonstrates that future use of the land will be industrial. SATS recommends that this standard remains the most stringent to protect human health, and as a corollary, it would allow for future unrestricted use of the property. Furthermore, in 6.2.1, the plan states that, “all soil exceeding the unrestricted land use soil CULs…will be excavated” and that soil will be sampled, “during remedial design to refine the remediation footprint both laterally and vertically”. With the soil standard open to being re-evaluated, it raises the possibility that the cleanup footprint will be reduced while this process is underway, should the CULs revert to industrial. It would be most efficient to excavate where applicable to the stricter standard while the process is already underway, rather than have to revisit this process in the future, introducing a new environmental impact. This would also provide a “more permanent cleanup action for all or part of the site”, as stated in section 6.3, Rationale for Selecting the Remedies.

Pg. 69 – Table 4-4

This shows the sediment cleanup levels (CUL) for the COCs. Although the table is titled, “Sediment Cleanup Levels Protective of Human Health”, for most chemicals the CUL is Regional or Natural Background. SATS agrees that these numbers are lower than those derived from human health screening calculations for specific populations interacting with the site, but it is inaccurate to infer that these values were derived from human health-protective exposure estimates. It would be informative to include, in the table, human health-based values (specifically, the most conservative, with the exposure model population identified) to provide this comparison, especially because MTCA permits cleanup screening levels to be set higher than levels based on protection of human health.

The Regional Background for cPAH TEQ is listed as 64 ug/kg, but in the cited Ecology document (North Olympic Peninsula Regional Background Sediment Characterization (2016)), cPAH TEQ is listed as 31 ug/kg (natural background 16 ug/kg). However, in Ecology (2016), there is also a Port Angeles-specific value of 64 ug/kg which used samples from Port Angeles Harbor combined with three other locations. This runs counter to WAC 173-204-560 (5)(d): “Calculation of regional background for a contaminant must exclude samples from areas with an elevated level of contamination due to the direct impact of known or suspected contaminant sources, including areas within a sediment cleanup unit or depositional zone of a discharge.” Although this cleanup plan follows the standard set by Ecology in the 2016 Regional Background document, it is worth stating that the Regional Background here includes Port Angeles-specific data that make the cleanup levels less conservative than if they had been derived from areas not influenced by the PLP.

Thank you for the opportunity to comment on this Interim Action Plan. Please feel free to reach out if you if have questions or would like any further clarifications.

James Watt, PhD

Pronouns: he/him

Toxicologist

Site Assessment and Toxicology Section

Environmental Public Health Sciences

Washington State Department of Health

james.watt@doh.wa.gov

doh.wa.gov  | 564-669-4205

5. Environmental Justice (section of the Ecology’s Interim Action Plan)

WAC 173-340-380 requires that cleanup action plans summarize how impact on likely vulnerable populations and overburdened communities were considered when selecting the cleanup ac...↓tions.

Selection of Level 3 is inadequate in complying with this State law in addition to many other points made in my earlier communications as part of the official public comment period.

Only a complete cleanup can make the kind of restoration possible that is needed to return salmonids to Ennis Creek in any numbers approaching their historic populations.

Otherwise polluted areas and the need to devote many acres to storing contaminants make restoration actions more difficult if not possible. The stream needs an estuarine area, space and water free of toxins.

Ecology seems to have relied on the requirement that the Lower Elwha Klallam Tribe review its plans and many other documents. That is good, but doesn’t meet the requirements regarding likely vulnerable populations and overburdened communities.

Cleanup and restoration is supposed to be permanent. It needs to measure up to the highest standards science and technology determines regardless of what one tribe may agree to at a certain point in time.

Fish and other marine life in Port Angeles Harbor are not safe to eat. Ecology has the responsibility to change that as well as make sure the waters of Port Angeles Harbor are safe for people and others spending time in them.

Thank you for considering these additional thoughts.

Robbie Mantooth, co-founder, Friends of Ennis Creek

Ms. Abbett,

Please accept the reasoning of the Port Angeles City Council and select Option #5 - full clean-up. We live west of the city of Port Angeles and enjoy bike riding on the Olympic Discovery Trail along the coast, traversing the Rayonier toxic...↓ waste site. The site should be returned to the original state it was in before the Rayonier Mill was in operation, for the benefit of fish, wildlife, the ecosystem, and residents. This includes restoring Ennis Creek back to its natural conditions. We cannot allow the pollution to remain and continue to harm the area for generations to come. Rayonier should pay for the full clean-up, as they profited from dumping the pollutants in the ground and air.

Thank you,

Carolita McGee

Port Angeles, WA

As a resident of the Gales Addition I feel that the best option for the former Rayonier Mill site is option 5, the complete removal of all contaminants. I graduated as a Geological Engineer from the University of Arizona and worked around heap leache...↓d mines. As a trained engineer I question the impermanence of the proposal the DOE has put forth - option 3 is impermanent and what this community needs and deserves from Rayonier is a permanent full solution to the pollution of their public space. Port Angeles is in a geologically unstable area. This amplifies and underscores the need to remove the contaminants away from the water's edge and away from the edge of the harbor. The best way to do this is to require Rayonier to clean up to the level described in DOE's option 5. The only way to guarantee the safety of the residents of Port Angeles is to remove the chances of exposure that will happen after a geologically catastrophic event.

Phillip Renault

I support the permanent solution of Alternative SL-5 for contaminated soil and sediment at the former Rayonier Mill site in Port Angeles, WA. Proposed Alternative SL-3, leaving contaminated soil in place forever in a capped mound which will greatly l...↓imit future development, is unacceptable.

Megan C. Merriwether, Ph.D. 

Clinical Psychologist

206-300-5865

Attention: WA Department of Ecology (WA ECY)

            Marian Abbett

I have resided in Clallam County since 1993 and have been following with interest and concern efforts for having an appropriate cleanup of the hazardous/toxic wastes associated with...↓ the Rayonier Mill operations.

For the record, I note that WA ECY needs to pursue SL-5, NOT SL-3 level cleanup to meet its protection responsibilities and provide for permanent removal of these wastes from our County.

Thank you for your consideration.

Judy Larson

1070 W Palo Verde Loop

Sequim,WA 98382

Ms. Abbett: 

  I reside in Port Angeles and I respectfully submit my comment to you regarding the cleanup of the site of the former Rayonier mill in my city.

  I urge that Rayonier be required to abide by Cleanup Alternative Five (SL-5) for the return ...↓of it's former mill site to our community in the condition it was before Rayonier took over.

  The solution proposed by Rayonier, SL-3, will leave contaminated soils and sediments in a large raised mound on a 10 acre area forever. That proposed solution is not a solution at all since it will leave a permanent, massive, unhealed wound in our otherwise beautiful waterfront that will never allow proper and useful development of that area.

  Rayonier took a valuable piece of our community and misused it for years to make profits for its shareholders. Now that the corporation is finished with abusing our community, it should be required to return the land to us in the same condition that it found it. We should not be further abused and left to deal with Rayonier's noxious waste forever. That would be the ultimate cut and run by Rayonier to the eternal detriment of Port Angeles. 

Sincerely, 

Grant S. Meiner

Marian Abbet,

Hello there, I am a resident of Port Angeles and would like to submit a public comment regarding the Rayonier Pulp Mill Cleanup obligation.

I am an advocate for our fish, wildlife, soil, air and waters and insist on a full clean up of the...↓ ecologically significant and valued site, not a partial cover-up. There needs to be a complete removal of toxic sediments and soils for the long term protection of the community.

The plan for pollution clean up has taken far too long and should now be made a priority, especially given all of the data which documents the contamination.

Thank you!

Stephanie Smith

There is no question that a complete clean up should take place at the former Rayonier site. 

Capping materials and leaving in place is more convenient  and less expensive but those considerations should not be the deciding factor.

I support SL-5, a co...↓mplete cleanup.

Janet Rogatz

Sequim

I support the permanent solution of Alternative SL-5 for contaminated soil and sediment at the former Rayonier Mill site in Port Angeles, WA. Proposed Alternative SL-3, leaving contaminated soil in place forever in a capped mound which will greatly l...↓imit future development, is unacceptable.

Kelvin Eder

     215 N. Vine Street

     Port Angeles Wa 98362

     321 239 3414

     kelvineder@mac.com

I support the permanent solution of Alternative SL-5 for contaminated soil and sediment at the former Rayonier Mill site in Port Angeles, WA. Proposed Alternative SL-3, leaving contaminated soil in place forever in a capped mound which will greatly l...↓imit future development, is unacceptable.

Rayonier may have once provided jobs for this community, but the devastation to our waters and forests has been despicably destructive. The Mantooths, Darlene Schanfield and others have provided a mountain of evidence to help DOE make the right decision for this community and its natural resources. Our community has proven to be resourceful if given a fighting chance. 

How in good conscious, can the DOE choose to bow to the avarice of the industry who profited from our community by stripping and contaminating our forests and waters, and due to their careless greed, have the only resources to bankroll a proper clean-up?

The compromise is no compromise. Make them take the fullest responsibility. 

     Susan Chadd (64 year resident) 

     1774 Little River Road

     Port Angeles, WA 98363

Ms. Abbett,

Please accept the reasoning of the Port Angeles City Council and select Option #5 - full clean-up. We live west of the city of Port Angeles and enjoy bike riding on the Olympic Discovery Trail along the coast, traversing the Rayonier toxic...↓ waste site. The site should be returned to the original state it was in before the Rayonier Mill was in operation, for the benefit of fish, wildlife, the ecosystem, and residents. This includes restoring Ennis Creek back to its natural conditions. We cannot allow the pollution to remain and continue to harm the area for generations to come. Rayonier should pay for the full clean-up, as they profited from dumping the pollutants in the ground and air.

Thank you,

Scott McGee

Port Angeles, WA

I support the permanent solution of Alternative SL-5 for contaminated soil and sediment at the former Rayonier Mill site in Port Angeles, WA. Proposed Alternative SL-3, leaving contaminated soil in place forever in a capped mound which will greatly l...↓imit future development, is unacceptable.

Cletus Toschlog 

1012 W 6th St, Port Angeles, WA 98363