Hazardous to Safe:
A Case Study of Chemical Contamination at the Diamond Match/Louisiana-Pacific Chico Facility

by Katherin Polan

The purpose of the Diamond case study is to

  • Outline social processes, which determine the Diamond site hazardous in 1991 and safe in 2000,and provide a critique of this process;
  • Address risk assessment and examine the role of risk when assessing hazardous and safe levels to chemical exposure;
  • Provide an update on the status of the Diamond site in order to encourage discussion among Chico community members regarding the future use of the Diamond site.

Thesis Defense

Why Diamond Match? I could have chosen any number of contaminated sites across the country. But why go far? This is my back yard and the California Department of Toxic Substances Control declared this site hazardous in 1991 and safe in 2000.

What does this mean when I am gardening in a community garden located on 16th and Normal?

Hazardous to Safe

After learning of possible environmental health effects caused by toxins within the environment I wanted to know why we still allow them to contaminate our environments.

Approximately, 75,000 different synthetic chemicals are out in the global market, and many others are emitted as by-products of their production or incineration. Roughly 1/3 of these chemicals have been tested for acute toxicity, and fewer than that have been tested for their chronic, mutagenetic, teratogenetic, carcinogenetic or synergistic toxic effects (Luoma 1999, 62; Mitchell 1997, 28; Steingraber 1997, 99).

Regulations such as the Federal Emergency Planning and Community Right-to Know Act of 1986, track the release of only 650 toxic chemicals and chemical compounds. Of these 650 substances, 7.3 billion pounds of chemicals were released by industrial sources into our air, land, and water in 1998 (EPA 1998, 1). This acceptance exists regardless of the added health costs such as increased cancer rates. Steingraber (2000, 40) notes that, "all types combined, the incidence of cancer in the United States rose 49.3 percent between 1950 and 1991."

Cancer rates are also increasing among the most vulnerable population, children "At present, eight thousand children are diagnosed with cancer each year; one in every four hundred Americans can expect to develop cancer before age fifteen" (Steingraber 2000, 38). Increasing incidences to chemically induced health hazards such as cancer reflects a general social tolerance to this type of pollution. Uncertainties still exist surrounding the human health effects posed by particular chemical exposure level.

New technologies and ongoing scientific studies continue to advance our knowledge of hazardous and safe chemical exposure levels, and this in turn changes bureaucratic regulations for a hazardous and safe substance. Human exposure to a combination of chemical substances not tested for synergistic, additive, potentiation or promotion toxicity effects, leaves a gap in the vital information needed to determine what levels of chemical contamination in the environment constitute a hazard.

Why do we allow this to continue?

Because there are social forces that impact scientific determination of hazardous and safe. We are all affected by theses decisions for hazardous and safe, even here in Chico.

Why Diamond Match? Or, Why go far?

I could have chosen any number of contaminated sites across the country. Because this is may back yard and DTSC declared this site hazardous in 1991 and safe in 2000. What does this mean when I am gardening in a community garden located on 16th and Normal?

I found the site by researching for Lois Gibbs's Earth Day 1999 visit to CSUC. She requested information on local hazardous waste sites, found DM, one of 64 sites in Chico.

How did this site get on a hazardous site list?

ToxRAP MAP: Toxicology, Risk Assessment and Pollution Map

Source: Environmental and Occupational Health Sciences Institute, University of Medicine and Dentistry of New-Jersey-Robert Wood Johnson Medial School and Rutgers, the State University of New Jersey.

The recognition of hazardous chemical contamination comes only after pathways between the hazards and health concerns become scientifically identified. A pathway, or exposure route, determines how a chemical is affecting human health. Pathways are described as inhalation, ingestion, or dermal contact to a suspected hazard. Social movements against the health hazards to chemical exposure push the scientific, medical, and bureaucratic communities to recognize pathways. With the pathways recognized, a direct link between the hazard and health effect forms, and the suspected hazard becomes a socially recognized hazard.

Exposure to the hazard plays a key role in determining a safe level for chemical contamination of the environment. When the pathway is eliminated then the hazard has been disconnected from the human health concerns. A role of a risk assessment is to point out the pathways in order to determine effective remediation for the chemical hazard. Pathways are eliminated by various means of remediation.

For instance this is a diagram showing the Diamond site as hazardous: COMPLETE TRIANGLE

And this is a "safe" Diamond site: NOT COMPLETE TRIANGLE

How do they complete the map?

Through a process of human health risk assessment.

1. Data collection and evaluation to identify the hazard.
2. Exposure assessment to identify pathways and people.
3. Toxicity assessment to identify a safe dose level.
4. Risk characterization to determine an acceptable level of risk.

I am going to go through the risk assessment of the diamond site to explain how the site was determined hazardous in 1991 and safe in 2000.

1. Data collection and evaluation to identify the hazard.

Data collection started in 1894. The results from a 1984 statewide groundwater-monitoring program revealed 3,000 public wells to be contaminated with VOC's. 18 of Chico's 59 wells were contaminated with Perchloroethylene, tetrachloroethlyene common dry-cleaning solvents. By 1986, four plumes, were identified (One of those areas was under L-P site) and then Soil-gas samplings revealed source areas for the PCE, TCE groundwater contamination.

August 1989, 45 private wells were tested which feed off the plume under L-P site. Three wells on L-P site and two down gradient of site revealed low levels of PCP. This prompted public awareness, newspaper articles, and eventually ex-employees coming for with information relating to site operations, "For two years I watched glue residue pour into the ground from one of the buildings."

Public pressure prompted L-P to voluntarily sample four onsite wells in December of 1989. Trichloroethene was detected in all of the wells with a maximum concentration of 140 ppb and PCP was not detected in any of the water samples, contrary to what DHS found in their August 1989 well sampling.

The site evaluation performed by L-P consisted of three phases. Phase 1, Phase 2, and Phase 3

The source evaluation phase looked at the historical chemical use, handling, and disposal practices at the site. This information was provided by DHS, Metcalf and Eddy, L-P site records, employee interviews, aerial photographs, site maps and historic files maintained by the Regional Board, Special Collections at CSU Chico Meriam library and the Butte County Assessor's office.

DIAMOND LANDS PHOTO: As part of a larger investment, which included the acquisition of timberland and other milling operations throughout Northern California, Diamond purchased approximately 242 acres of land from the City of Chico in January of 1903.

The planned facility named "Barber" in honor of O.C. Barber, then President of the Diamond Match Company, had a company town, a railroad, engineering department, remanufacturing and millworks division, match factory and retail yard. STIRLING MILL (STIRLING MILL photo) The Barber facility, supported by Diamond Lands logging operations in the forests to the east was the largest Diamond facility in California. Logs were transported from the Stirling City mill to the Barber facility via the Butte County Railroad and sold throughout the facility.

By 1906, four separate divisions operated at the site:

  • the engineering department,
  • the remanufacturing or millworks division,
  • the retail yard,
  • and the match factory.

By 1910, these divisions were staffed and operated separately and "in general, raw materials and waste products were not moved between divisions following that year" (SHN March 1995, 2-1).

Engineering Department

The engineering department established to service the Butte County Railroad and logging operations, provided a foundry for the construction of needed equipment. Between 1904 and 1916, solvents, cutting oils, mineral oils, acids, and other petroleum distillates were used during the operations of the engineering department. All records pertaining to this department, after 1916, were destroyed when the millwork's office building transferred to the match factory (SHN March 1995, 1-4).

The engineering department is best known for the design and construction of the popular double-drum "Whistling Barber" steam donkeys used in logging operations.

Remanufacturing or Millworks Division

The largest division on the Diamond site, the remanufacturing or millworks division included the "main Barber powerhouse," box factory, planning mill, two warehouses, dry kilns, dry lumber sheds, sash and door factory (shown here), sorting shed, and an office building. Before 1915, the mill remanufactured an average of fifteen railcars a day of rough-cut green lumber from the Stirling City mill.Operations at the mill remained relatively unchanged during the years of operation.

Major compounds used by Diamond, at the remanufacturing division included mercury-based adhesives and pentachlorophenol (PCP)- based fungicides. PCP, used to treat wood, protects the wood from mechanical, physical, and chemical influences.

Wood at the Diamond facility was preserved by non-pressure measures, specifically dipping. This process involves the repeated use of the PCP preservative in a treatment tank. Fresh preservative solution was added to replace the solution, which had soaked into the wood products. This process often times results in the accumulation of wood chips, sand, stones, and other debris in the bottom of the treating tanks (EPA September 1995, 28). Treated wood was then placed on the concrete impoundment area where it remained until dripping ceased.

Just after purchasing the site, L-P dismantled and removed a PCP dip system, the concrete impoundment, and an underground tank Diamond used for storing PCP. Up to twenty 55-gallon drums of fungicide, waste was removed by L-P at this time.

Both Diamond and L-P used a polyvinyl acetate adhesive to finger joint and glue finished edges. Finger jointing and gluing wastewater discharged into two depressions located between the box factory and millworks. From here, the wastewater was routed via an underground drain to a ditch located near the large-surface reservoir.

Before 1970, scrap wood from the remanufacturing process was chipped and burned in the match factory boilers or in the on site teepee burners. Scrap lumber not chipped and other industrial debris was disposed of at one of two burn dumps.

Ash Sample Results

The Normal Avenue burn dump was located north of the mill site between 18th and 19th Avenues and the South Orchard burn dump was located in the southeast corner of the facility.

In 1971, the teepee burners were removed and open pit burning on the site ceased due to requirements under the Clean Air Act. Most excess sawdust and chips were then sold as fuel. Remaining wood waste and other mill debris was placed in dumpsters and then eventually taken to the county landfill.

Match Factory

The match factory began production in the fall of 1906 and by 1916, the capacity of the match factory more than doubled. A broiler house, shipping shed, composition building, two material storage buildings, fuel storage building, machine shop, an office building, the broiler house, and the block and veneer building composed the Match Factory. A deep well and a concrete reservoir were added to the factory in 1916. This reservoir, served as a swimming pool for employees of the match plant. Men from the mixing room, following their shift, often used a shower room on the side of the reservoir.

A large concrete fuel oil bunker located just north of the reservoir provided fuel for the match factory broilers in case the wood supply ran out. After this bunker was partially demolished in 1977, the L-P millworks division used it for occasional waste disposal.

The main match factory was a two-story brick building with a basement. The basement was primarily used for storage. The first floor also served as a storage area and was where the matchboxes and books were printed. The processing of matches occurred on the second floor.


Match machine

The chemicals used to produce the matches; phosphorus, sulfur, formaldehyde, chlorate of potash, were stored in the "Sesqui Building," the "Chlorate House," and the "Paraffin Building." The chemical mixture for the match heads, produced on the first and second floors of the composition building, was then transported to the match factory for use.


Match processing

Chemical compounds used in the production of the match heads changed over the life of the plant. Prior to 1911, white phosphorus was used until Diamond's general manager, W. A. Fairborn, discovered a formula for the "strike anywhere match" that used potassium chlorate. Both "red wax" and paraffin were used in the production of the Chico matches. According to historical records, a formula using sesquisulphide of phosphorus was never used at the Chico plant. "However, the naming of the match factory building as the "Sesqui Building" on the 1921 Sandborn maps would lead to the opposite conclusion" (SHN March 1995, 1-7).

Solid waste from the match factory was either recycled or sent to the county landfill. As early as the mid-1930's, empty cans and barrels containing the match chemicals were stored outside of the composition building and often times recycled by the company that delivered the chemicals. The remaining cans were either crushed or filled with defective matches and broiler ash before being sent to the landfill.

Wastewater from the match plant went into the ground. At first, the wastewater was routed to several concrete-lined settling basins. Overflow and sediment from these basins went into an unlined pond that was east of the match plant and south of the existing above ground fire reservoir.

Sediment from the unlined pond was buried in a trench located between the pond and a drainage ditch. The drainage ditch was used to transport overflow material from the pond off site.

Farming Operations

Farmed portions of the Barber site were cultivated as early as 1905 and became the responsibility of the match factory. Hay, grain, alfalfa, and prunes were farmed in 90 acres just west of the Southern Pacific railroad tracks.

Three deep wells were drilled in April of 1916 to water the prune orchard and provide water for the enlarged match factory. The 90-acre prune orchard, removed by 1942, was eventually parceled and sold. The land is now used for various agricultural productions and low density residential.

The almond orchards currently on site were planted in 1974 as a mitigation measure for building the Finished Wood Products building. Chemicals necessary for farming, including lime and sprays, were stored at the match factory. According to historical expense sheets, nitrogen and lime compounds were used on the orchard and row crops, but no history of pesticide use is available (SHN 1995, 1-8). (Chemicals Detected in Almonds)

A prune-dipping plant, erected in 1921, most likely used lime to loosen the prune skins. "No information is available regarding the location of the prune dipping facility, historic storage locations, waste disposal or additional chemical use" (SHN March 1995, 1-8).

Railroad Ballast

Beginning in 1906, the primary means of transporting items around the site was by rail spur lines. Actual track location has varied, but approximately 5 miles of track have been located onsite throughout its history.When track was removed, the rock ballast was recycled on site and the soil was graded.

Herbicides were used along the tracks and railroad ballast to control weeds. Sodium arsenic was the primary herbicide used to control weeds along the tracks. In the 1970_s when arsenic became socially recognized as hazardous and a threat to human health, non-arsenical formulations like Roundup and Garlon were used to control weeds along the tracks (SHN March 1995, 1-9).

Finished Wood Products Division

The finished wood products division (FWPD) building, constructed between 1969 and 1970, remains on site. This division processed molding purchased from the Diamond molding plant located in Red Bluff. "Processing consisted of applying one or two base coats of paint to the molding along the paint line, drying the paint in an oven, applying simulated grain at an inking station, and applying a protective coat of lacquer along the paint line" (SHN March 1995, 1-8).

After L-P's purchase of the site, the FWPD building processed hardboard from the L-P Oroville mill by applying a paper veneer, paint and then ink to the hardboard. Major compounds used in the processing operation were paint, lacquer, ink, and lacquer thinner. These compounds are reported to be solvent-based but information on their composition before 1984 is not available.

Between 1987 and 1989, L-P used polyvinyl acetate adhesives and latex ink in its FWPD operations. From 1970 to 1984, an outside contractor delivered paint and ink used at the FWPD. The paint came in 55-gallon drums and was stored in a paint shed near the main building. It was then transferred by hand into smaller 5-gallon cans and hand carried over to the main building.

The ink was also delivered to the site in 1- and 5-gallon cans, stored in the paint shed and then hand carried over to the main building.

The primary solvent used by Diamond, probably acetone, was stored in a 10,000-gallon underground tank, delivered to a spigot inside the building near the paint line and was used to thin the paint and ink (SHN 1995, 1-8).

Solvent used to clean the machinery along the paint and ink stations, was transported via a cutoff 55-gallon drum, and then was reused after the sediment settled out. Other chemicals thought to be used at the FWPD include methyl ethyl ketone (MEK) and trichloroethlylene (TCE) (DHS 1991, 4).

Solid and hazardous wastes from the FWPD either went into the ground on site or were disposed of at the county landfill.

The paint contractor was responsible for removing the empty paint barrels and cans and often times unused paint was left in these barrels and cans. Hardened lacquer and sediments left over from cleaning the machines were disposed of in a pit outside the paint shed, and solvent was discarded between the main building and the paint shed.

During the entire operation of the FWPD, dumpsters were also used for waste disposal. When full, these dumpsters were transported to the county landfill.

This historical research led to 15 areas of potential concern on the site. Further investigation into these 15 sites revealed 7 areas where, again, further testing occurred. Theses 7 areas are considered to be where most of the chemical contamination occurred and became the areas where, if cleaned-up, the entire Diamond site would then be clean.

In the area of the

  • Normal Avenue Burn Dump, elevated levels of barium, chromium (VI), copper, lead, silver, and zinc were found along with one sample indicating 2,3,7,8-tetrachlorodibenzodioxin (TCDD).
  • The South Orchard Burn Dump area showed levels of arsenic, barium, cadmium, copper, lead, nickel, silver and zinc.
  • The Match Factory Detention Pond and Fuel Oil Bunker contained elevated levels of arsenic, barium, cadmium, chromium (III), chromium (VI), copper, lead, mercury, thallium, zinc, and TPH.
  • The Drainage Ditch area of the Match Factory contained an elevated level of TPH at 315 mg/kg. In the
  • Millworks Division, the New Dry Kilns and the Concrete Impoundment areas contained elevated levels of antimony, arsenic, barium, cadmium, copper, lead, silver, zinc, and PCP.
  • The Glue Discharge Area contained elevated levels of formaldehyde (37 mg/kg). At the
  • FWPD Paint Disposal Pit, an estimated 50 cubic yards of soil contained paint lenses and layers. Formaldehyde, at the elevated levels of 39 mg/kg was found at the FWPD Glue Discharge Area.

In response to the additional testing, on June 28, 1991 John J. Kearns, Deputy Director to the Toxic Substances Control Program issued an Imminent and Substantial Endangerment Determination and Order to L-P. This Order is issued when DHS "determines that there may be an imminent or substantial endangerment to the public health or welfare or to the environment, because of a release or a threatened release of a hazardous substance" (DHS 1991, 1).

Human Health Risk Assessment

This order prompted further investigation into the site and required cleanup actions to occur. However, before remedial action could begin, a human health risk assessment had to be completed.


Historic sampling summary

2. Toxicity assessment to identify a safe dose level.

Toxicity Assessment Inorganic Arsenic

Known to cause Lung cancer. OSHA limit in workplace for air: 0.5 m

Known to cause Skin cancer: (Maximum contaminate level) MCL in drinking water: 50 ppb

Toxicity Assessment Pentachlorophenol

PCP is not a carcinogen but does effect liver, kidneys, blood, lungs, nervous system, immune system, and gastrointestinal track. PCP is listed as a possible carcinogen, but this clssification has not been scientifically proven. For precautionary measures EPA set a MCL in drinking water: 1ppb

3. Exposure assessment to identify pathways and people.

Exposure Assessment for inorganic arsenic in soils: Pathways are ingestion and dermal contact. People are future residents and workers

Exposure Assessment PCP in groundwater: Pathways are ingestion, dermal contact, and inhalation. People are current and future water users, future residents


ToxRAP

Map All components complete, Arsenic, pcp as hazard. Exposure pathways determined, and how this hazard can effect the people are dterermied.

4. Risk characterization to determine an acceptable level of risk.

SOILS "Number crunch" L-P conducted this evaluation for the site and assessed the potential public health risks posed by the contaminants. "Risks are evaluated under current and potential future land use conditions" (CH2M Hill 1994, ES-1). Under this risk characterization, this site was assessed for future residential and industrial use, but never for a school or hospital zoning.


Chemicals Detected in Surface Soils #1


Chemicals Detected in SubSurface Soils #2


Risk Estimate Summary for Surface Soils

GROUNDWATER All exposure scenarios are quantitatively evaluated. A 95th upper confidence limit was used to calculate exposure point concentrations. This confidence limit correlates to a risk assessment of 10-6 or one cancer incidence in 1,000,000 people per lifetime. (Chemicals Detected in Groundwater) (Risk Extimate Summary for Groudwater)


Groundwater Remediation


Soil Remediation

Remediation

Now remediation can begin to make the hazards safe so that we can return to the site, use the land, water, etc. That is - by decreasing the risk chance of cancer, other health effects mentioned.

Groundwater Twenty-eight onsite groundwater-monitoring wells were installed and sampled on a quarterly basis between 1991 and 1996 to determine the extent of the groundwater contamination. Based on these results, it was determined that two specific areas on site have affected the groundwater.

PCP entered the groundwater from the concrete impoundment area and ethylbenzene and xylene entered the groundwater from the Finished Wood Products Division.

February 1997 sampling results determined that ethylbenzene and xylene concentrations did not exceed primary maximum contaminate levels (MCL) approved by the EPA and thus posed no health risk. The concentrations do, however, exceed secondary MCL's, which are set for taste and odor nuisances.

Soil Arsenic 5.4 mg/kg in soil of r/r tracks which is equal to the background level. Naturally occurring, background level is considered safe, so to remediate until background level would make the arsenic contaminated soil safe.

How do we remediate for the hazards?

We need to eliminate the connections between the hazards and the people to make the site hazard safe.

There are many different forms of remedial techniques; I will highlight the three techniques that occurred at the Diamond site in order for the site to be declared safe by DTSC in 2000.

1. REMOVE THE HAZARD

By the fall of 1992, more than 10,000 cubic yards of soil were removed by L-P and disposed of at a hazardous waste landfill. The removal of the contaminated soil met interim cleanup levels approved by DTSC. Remedial actions coincided with risk assessments for carcinogenic substances at 10-6, and to reference dose intake levels for noncarcinogens. After L-P removed the contaminated soils, confirmation samples taken by L-P ensured that a sufficient amount of contaminated soil had been removed.

Removing this contaminated soil off-site resulted in the mitigation of the on-site soil contamination. Eight areas Fuel Oil Bunker: approximately 1,400 cubic yards of debris were taken from the bunker. This debris is defined as soil, wood debris, metal strapping, dried paint, glue, asphalt, and other mill-generated wastes.

In addition, L-P removed 3,770 cubic yards of hydrocarbon-contaminated soil because fuel oil leaked from the bunker into the underlying soils.

New Dry Kilns: approximately 1,450 cubic yards of debris were removed which included non-specified drums, 5-gallon paint cans, strapping and wire rope. Concrete Impoundment: approximately 2,100 cubic yards of pentachlorophenol-contaminated soil were removed from this area.

Detention Pond: approximately 2,500 cubic yards of soil were removed from the unlined pond, which accepted wastewater and sediments from the Match Factory and was leveled in 1977 when the Match Factory was demolished.

Glue Discharge Area: approximately 104 cubic yards of soil containing glue residue were removed from this area. Paint Disposal Pit: approximately 95 cubic yards of soil containing paint residues were removed from this area.

South Orchard Burn Dump: approximately 2,800 cubic yards of ash and construction debris were removed from this area.

Normal Avenue Burn Dump: a minor amount of glass, ash, and metal was observed in this area, but no soil was removed. PCP PUMP Sampling for PCP revealed an average concentration in the groundwater near the vicinity of the concrete impoundment area to be 2,000 ppb.

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