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Permit L02-041 - RHONE-POULENC FACILITY - SHORELINE SUBSTANTIAL DEVELOPMENT
L02 041 FORMER RHONE POULENC 9229 E MARGINAL WY 5 SHORELINE MANAGEMENT Mr. Peter Wold RCI Environmental Inc. PO Box 1668 Sumner, WA 98390 Ms. Minnie Dhaliwal, Planner City of Tukwila Dept. of Community Development 6300 Southcenter Blvd. Suite 100 Tukwila, WA 98188 Dear Mr. Wold and Ms. Dhaliwal: Sincerely, dr a e, ` . e me er Shorelands and Environmental Assistance Program STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Re: City of Tukwila Shoreline Substantial Development Permit # L02 -041 SHORELINE MANAGEMENT RCI ENVIRONMENTAL INC., OWNER Via Peter Wold - Applicant Shoreline Substantial Development Permit # 2002 -NW- 50077 -1 If this permit is NOT appealed, this letter constitutes the Department of Ecology's final notification of action on this permit. • 1 to RECEIVED NOV 2 2 2002 DEVELOPMENT Northwest Regional Office • 3190 160th Avenue SE • Bellevue, Washington 98008 -5452 • (425) 649 -7000 November 20, 2002 The subject Shoreline Management Substantial Development Permit has been filed with this office by the City of Tukwila on November 8, 2002. This permit is for the implementation of interim measures for environmental cleanup at the former Rhone Poulenc Site. The project includes construction of a subsurface wall encircling contaminated groundwater and installation of groundwater recovery system to control migration of contaminants into the Duwamush River. This is a RCRA corrective action under administrative order to consent between container properties LLC, Rhodia Inc and USEPA. The development authorized by the subject permit may NOT begin until the end of the 21 -day appeal period, November 29, 2002. The Shorelines Hearings Board will notify you by letter if this permit is appealed. Other federal, state, and local permits may be required in addition to the subject permit. 0 11/20/02 15:47 FAX 425 649 7098 NORTHWEST REGIONAL OFFICE facsimile Cover Sheet t AS$INGtor slAtt ECOLOGY DATE: TIME: Number of Pages: Plus Cover Sheet TO: FAX # , � — mkt. ,U)wt,/ - d;: DEPT OF ECOLO° RECE RP9kcElvE n 001 NOV 2 1.2002 .2002 R r COMMUNITY DEVELOPM E OMhflUNITY Ulf ac' ---v?(— 3 C FROM: C-0 __/) Se.., Elf --Yro?, PHONE: 1 6 CSEcrioN: /USA- C� Department of Ecology • Northwest Regional Office 3190 - 160th Avenue S.E. Bellevue, WA 98008 -5452 Phone: (425) 649 -7000 Fax: (425) 649 -7098 COMMENTS: .� 1 �:';�:,� ^�:- i::.. ;,,a.; . ww' : }«E:^,ra2Ectix�� •.i���'Fisa:8�_ si$k?�frs.�s"�.,,�f� ; �': *�+ 11/20/02 15:48 FAX 425 649 7098. DEPT OF ECOLOGY STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Northwest Regional Office • 3190 160th Avenue SE • Bellevue, Washington 98008 -5452 • (425) 649 -7000 November 20, 2002 Mr. Peter Wold RCI Environmental Inc. PO Box 1668 Sumner, WA 98390 Ms. Minnie Dhaliwal, Planner City of Tukwila Dept. of Community Development 6300 Southcenter Blvd. Suite 100 Tukwila, WA 98188 Dear Mr. Wold and Ms. Dhaliwal: Re: City of Tukwila Shoreline Substantial Development Permit # L02 -041 RCI ENVIRONMENTAL INC., OWNER Via Peter Wold - Applicant Shoreline Substantial Development Permit # 2002 -NW- 50077 -1 The subject Shoreline Management Substantial Development Permit has been filed with this office by the City of Tukwila on November 8, 2002. This permit is for the implementation of interim measures for environmental cleanup at the former Rhone Poulenc Site. The project includes construction of a subsurface wall encircling contaminated groundwater and installation of groundwater recovery system to control migration of contaminants into the Duwamish River. This is a RCRA corrective action under administrative order to consent between container properties LLC, Rhodia Inc and USEPA. The development authorized by the subject permit may NOT begin until the end of the 21 -day appeal period, November 29, 2002. The Shorelines Hearings Board will notify you by letter if this permit is appealed. Other federal, state, and local permits may be required in addition to the subject permit. If this permit is NOT appealed, this letter constitutes the Department of Ecology's final notification of action on this permit. San d a Lange, Shoreline planner Shorelands and Environmental Assistance Program 4ffilYP le 0 Dept. Of Community Development City of Tukwila AFFIDAVIT OF DISTRIBUTION I , L.6767.--/6 HEREBY DECLARE THAT: Notice of Public Hearing Determination of Non - Significance Project Name: PE7f Wo--t Notice of Public Meeting , i'eC2 1 'vi 2oNN€ENTf7I. T /c _ Mitigated Determination of Non - Significance S Mailer's Signature: L.• Cam. Board of Adjustment Agenda Pkt 114 r,ri I1 E_ Determination of Significance & Scoping Notice Board of Appeals Agenda Pkt Notice of Action Planning Commission Agenda Pkt Official Notice Short Subdivision Agenda Notice of Application Shoreline Mgmt Permit Notice of Application for Shoreline Mgmt Permit _ _ FAX To Seattle Times Classifieds Mail: Gail Muller Classifieds PO Box 70 - Seattle WA 98111 X Other / IO GCF D� 1slD AI (" S � p4— far S I+ • tj rl Was mailed to each of the addresses listed on this 15" day of /VO ✓ in the year 20 02- P:GINAWYNETTA/FORMS /AFFIDAVIT -MAIL 08/29/003:31 PM Project Name: PE7f Wo--t , i'eC2 1 'vi 2oNN€ENTf7I. T /c _ Project Number: a 02 -0 2/ G b 2 - C. V/ S Mailer's Signature: L.• Cam. Person requesting mailing: 114 r,ri I1 E_ I+ • tj rl Was mailed to each of the addresses listed on this 15" day of /VO ✓ in the year 20 02- P:GINAWYNETTA/FORMS /AFFIDAVIT -MAIL 08/29/003:31 PM 1) U.S. ARMY CORPS OF ENGINEERS ( ) FEDERAL HIGHWAY ADMINISTRATION )(DEPT OF FISH & WILDLIFE OFFICE OF ARCHAEOLOGY ( ) TRANSPORTATION DEPARTMENT DEPT NATURAL RESOURCES ( ) OFFICE OF THE GOVERNOR () DEPT OF COMM. TRADE & ECONOMIC DEV. ()DEPT OF FISHERIES & WILDLIFE () BOUNDARY REVIEW BOARD () FIRE DISTRICT #11 ( ) FIRE DISTRICT #2 ( K.C. WASTEWATER TREATMENT DIVISION ( ) K.C. DEPT OF PARKS & REC K.C. ASSESSOR'S OFFICE ( ) TUKWILA SCHOOL DISTRICT ( ) TUKWILA LIBRARY () RENTON LIBRARY () KENT LIBRARY ( ) CITY OF SEATTLE LIBRARY ( ) QWEST () SEATTLE CITY LIGHT ( ) PUGET SOUND ENERGY () HIGHLINE WATER DISTRICT ( ) SEATTLE WATER DEPARTMENT ( ) AT &T CABLE SERVICES ( ) KENT PLANNING DEPT ( ) TUKWILA CITY DEPARTMENTS: ( ) PUBLIC WORKS () POLICE ( ) PLANNING () PARKS & REC. ( ) CITY CLERK () PUGET SOUND REGIONAL COUNCIL SW K C CHAMBER OF COMMERCE MUCKLESHOOT INDIAN TRIBE X CULTURAL RESOURCES PROGRAM FISHERIES PROGRAM WILDLIFE PROGRAM () SEATTLE TIMES ( ) SOUTH COUNTY JOURNAL CHECK. : ENVIRONMENTAL REVIEW /SHORELINE PERM, .. ILINGS ( ) FIRE ( ) FINANCE () BUILDING ()MAYOR WASHINGTON STATE AGENCIES FEDERAL AGENCIES ( ) DEPT OF SOCIAL & HEALTH SERV. () DEPT OF ECOLOGY, SHORELAND DIV J DEPT OF ECOLOGY, SEPA DIVISION* --'r Q(jOFFICE OF ATTORNEY GENERA * SEND CHKLIST W/ DETERMINATIONS * SEND SITE MAPS WITH DECISION KING COUNTY AGENCIES SCHOOLS /LIBRARIES UTILITIES CITY AGENCIES OTHER LOCAL AGENCIES MEDIA () RENTON PLANNING DEPT ( ) CITY OF SEA TAC ( ) CITY OF BURIEN ( ) TUKWILA PLANNING COMMISSION MEMBERS ( ) TUKWILA CITY COUNCIL MEMBERS ( ) CITY OF SEATTLE - SEPA INFO CENTER - DCLU ( ) STRATEGIC PLANNING OFFICE* * NOTICE OF ALL SEATTLE RELATED PLNG PROJ. U.S. ENVIRONMENTAL PROTECTION AGENCY ( ) U.S. DEPT OF H.U.D. NATIONAL MARINE FISHERIES SERVICE () FOSTER LIBRARY ( ) K C PUBLIC LIBRARY ( ) HIGHLINE SCHOOL DISTRICT ( ) SEATTLE SCHOOL DISTRICT ( ) RENTON SCHOOL DISTRICT (C- ( ) HEALTH DEPT ( ) PORT OF SEATTLE pc) K.C. DEV & ENVIR SERVICES -SEPA INFO CNTR ( ) K.C. TRANSIT DIVISION - SEPA OFFICIAL j,) K.C. LAND & WATER RESOURCES ( ) OLYMPIC PIPELINE ( ) VAL -VUE SEWER DISTRICT () WATER DISTRICT #20 () WATER DISTRICT #125 ( ) CITY OF RENTON PUBLIC WORKS () BRYN MAWR- LAKERIDGE SEWER/WATER DISTRICT DUWAMISH INDIAN TRIBE P.S. AIR POLLUTION CONTROL AGENCY ( ) SOUND TRANSIT ( ) HIGHLINE TIMES ( ) CI.TUKWILA.WA.US.VWWV P:\ ADMINISTRATIVE \FORMS \CHKLISTT.D C t 2 , 0 - 0 6 S�s:x{{(e- cr O alp ' Lf lctJ( � G �� ) �Ccl�r✓ '.� -L1 L ��� / _I TL7 6 7 6 U Obi P L LIC NOTICE MAILINGS FOR PtiZNIITS SEPA MAILINGS Mail to: (comment period starts on date of mailing) Dept. of Ecology Environmental Review Section *Applicant *Other agencies as necessary (checked off on attached list) *Any parties of record * send only the staff report, site plan and the SEPA Determination KC Transit Division — SEPA Official would like to receive information about all projects that might affect transit demand Send These Documents to DOE: SEPA Determination (3 -part from Sierra) Findings (staff report, usu. with MDNS) SEPA Checklist (filled out by applicant) Drawings/Plans of project (site plan, elevations, etc. from PMT's) Affidavit of Distribution (notice was mailed or sent to newspaper) SHORELINE MAILINGS: Notice of Application for a Substantial Development Permit must be mailed to owners and to property owners within 500 feet of subject property, comments are due 30 days after the notice of application is mailed/posted. The notice of Application for Shoreline Substantial Development Permit must include a statement that any person desiring to submit written comments on the application or desiring to receive notification of the final decision on the application may do so within 30 days of the notice of application. If a hearing will be held on the application, the hearing notice must include the information that written comments may be submitted, or oral presentation made at the hearing. Shoreline Permit Notice of Decision: Mail to: (within 8 days of decision; 21 -day appeal period begins date received by DOE) Department of Ecology Shorelands Section State Attorney General *Applicant *Indian Tribes *Other agencies as necessary (checked off on attached list). *Any parties of record * send only the staff report, site plan and the SEPA Determination Send These Documents to DOE and Attorney General: Permit Data Sheet Shoreline Substantial Development Permit (3 -part from Sierra) Findings (staff report or memo) Shoreline Permit Application Form (filled out by applicant) Drawings/Plans of project (site plan, elevations, etc. from PMT's) - Site plan, with mean high water mark & improvements — Cross - sections of site with structures & shoreline — Grading Plan — Vicinity map SEPA determination (3 -part from Sierra) Findings (staff report or memo) SEPA Checklist (filled out by applicant) Any background studies related to impacts on shoreline Notice of Application Affidavit of Distribution (notice was mailed) P :\ADMINISTRATIVE \FORMS \CHKLIST.DOC City of Tukwila Department of Community Development November 8, 2002 NOTICE OF DECISION TO: Peter Wold, RCI Environmental Inc, Applicant King County Assessor, Accounting Division Washington State Department of Ecology Agencies with Jurisdiction All Parties of Record This letter serves as a notice of decision and is issued pursuant to TMC 18.104.170 on the following project and permit approval. The project is issued approval with the following condition: If archeological or historic materials are discovered during construction, all activity must be stopped and the following agencies must be notified: City of Tukwila, Muckelshoot Cultural Resources program and the State Archaeologist. Project File Number: L02 -041 Applicant: RCI Environmental Inc. Type of Permit Applied for: Shoreline Substantial Development Permit Project Description: Location: Associated Files: Comprehensive Plan Designation/Zoning MIC/H District: I. PROJECT INFORMATION Steven M. Mullet, Mayor Steve Lancaster, Director The project is to construct a subsurface barrier wall encircling contaminated groundwater to control migration of contaminants into the Duwamish River and Slip 6. The wall will be approximately 2300 linear feet long and 50 to 70 feet deep. The Environmental Protection Agency (EPA) Region 10 is the lead governmental agency for the site. The site facility is regulated under Resource Conservation and Recovery Act (RCRA). The scope of this project at this time is for implementation of interim measures, which include a low permeable barrier wall with groundwater recovery for hydraulic control of the impacted groundwater. 9229 East Marginal Way South E02 -021 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206- 431 -3670 • Fax: 206- 431 -3665 1 z ¢ 1 = z .f- W re 2 J U 0 co o cn J E U a j O gQ = Z I- O Z uj O U � 1— W W O .. W co O 1 ' z H. DECISION SEPA Determination: The City SEPA Responsible Official has previously determined that the project, as proposed, does not require a threshold determination under SEPA because it qualifies as a planned action pursuant to WAC 197 -11 -172, that the probable significant adverse environmental impacts of the project were adequately analyzed in the EIS previously prepared for the planned action and will implement the conditions and mitigation measures imposed by the planned action approval. Decision on Substantive Permit: The City Community Development Director has determined that the application for a Shoreline Substantial Development Permit does comply with applicable City and state code requirements and has approved that application, subject to the condition which are set forth in the Decision based on the findings and conclusions contained in the staff report. The Decision on this Permit Application is a Type 2 decision pursuant to Tukwila Municipal Code §18.104.010. Other land use applications related to this project may still be pending. III. YOUR APPEAL RIGHTS One administrative appeal to the Shorelines Hearings Board of the Decision is permitted. Any person appealing to the Shorelines Hearings Board may raise certain SEPA issues as part of the appeal to the Shorelines Hearings Board. Appellants should consult the rules and procedures of the Shorelines Hearings Board for details. IV. PROCEDURES AND TIME FOR APPEALING The requirements and procedures for appeals to the Shorelines Hearings Board are set forth in RCW 90.58 and WAC 461.08. Project materials including the application, any staff reports, and other studies related to the Shoreline Substantial Development Permit are available for inspection at the Tukwila Department of Community Development, 6300 Southcenter Blvd., Suite 100, Tukwila, Washington 98188 from Monday through Friday between 8:30 a.m. and 5:00 p.m. The project planner is Minnie Dhaliwal, who may be contacted at 206 -431- 3685 for further information. Property owners affected by this decision may request a change in valuation for their property tax purposes. Contact the King County Assessor's Office for further information regarding property tax valuation changes. V. INSPECTION OF INFORMATION ON THE APPLICATION Department of Community Development City of Tukwila File Number: L02 -041 Applied: 08/29/2002 Approved: 11/08/2002 Expiration: 11/08/2004 City of Tukwila Department of Community Development / 6300 Southcenter BL, Suite 100 / Tukwila, WA 98188 / (206) 431 -3670 SHORELINE MANAGEMENT ACT OF 1971 PERMIT FOR SHORELINE MANAGEMENT SUBSTANTIAL DEVELOPMENT A permit is hereby granted to: RHONE - POULENC FACILITY to: IMPLEMENT INTERIM MEASURES FOR ENVIRONMENTAL CLEANUP AT FORMER RHONE POULENC SITE. THE PROJECT INCLUDES CONSTRUCTION OF A SUBSURFACE WALL ENCIRCLING CONTAMINATED GROUNDWATER AND INSTALLATION OF GROUNDWATER RECOVERY SYSTEM TO CONTROL MIGRATION OF CONTAMINANTS INTO THE DUWAMISH RIVER. THIS IS A RCRA CORRECTIVE ACTION UNDER ADMINSTRATIVE ORDER OF CONSENT BETWEEN CONTAINER PROPERTIES LLC, RHODIA INC AND USEPA. Upon the following property: Address: 9229 EAST MARGINAL WY S TUKW Parcel Number: 5422600010 Section/Township /Range: NE 33 -24 -04 The following master program provisions are applicable to this development: KING COUNTY SHORELINE MASTER PROGRAM Development under this permit shall comply with the following conditions. Cond: CON0015622 IF ARCHEOLOGICAL OR HISTORIC MATERIALS ARE DISCOVERED DURING CONSTRUCTION, ALL ACTIVITY MUST BE STOPPED AND THE FOLLOWING AGENCIES MUST BE NOTIFIED: CITY OF TUKWILA, MUCKELSHOOT CULTURAL RESOURCES PROGRAM AND THE STATE ARCHAEOLOGIST. This permit is granted pursuant to the Shoreline Management Act of 1971 and nothing in this permit shall excuse the applicant from compliance with any other Federal, State or local statutes, ordinances or regulations applicable to this project, but not inconsistent with the Shoreline Management Act (Chapter 90.58 RCW). This permit may be rescinded pursuant to RCW 90.58.140(8) in the event the permittee fails to comply with the project as approved and any conditions thereof. CONSTRUCTION PURSUANT TO THIS PERMIT MAY NOT BEGIN AND IS NOT AUTHORIZED UNTIL TWENTY -ONE (21) DAYS THE DATE OF FILING WITH THE DEPARTMENT OF ECOLOGY (D.O.E.) AS DEFINED IN RCW 90.58.140(6) AND WAC 173-14 - OR UNTIL ALL REVIEW PROCEEDINGS INITIATED WITHIN TWENTY -ONE (21) DAYS FROM THE DATE OF SUCH FILING HA TERMINATED; EXCEPT AS PROVIDED IN RCW 90 58.140(5)(a)(b)lc). Steve Lancast:��'! e E�Ini ((/ of epartment of o ity`�jevelopment Construction or substantial progress toward co struction must begin within two (2) years from the effective date of the permit (the date the permit is filed with D.O.E.), per RCW 90.58.143(4). Project: File Number: Applicant: Request: Associated Permits: Comprehensive Plan/ Zoning Designation: Staff: City of Tukwila STAFF REPORT TO THE DIRECTOR DEPARTMENT OF COMMUNITY DEVELOPMENT Manufacturing Industrial Center/Heavy (MIC/H) Minnie Dhaliwal November 8, 2002 The following information was submitted as part of the application. Steven M. Mullet, Mayor Department of Community Development Steve Lancaster, Director Implementation of interim measures for environmental cleanup at the former Rhone Poulenc site. L02 -041 - Shoreline Substantial Development Permit RCI Environmental Inc. Shoreline Substantial Development Permit to construct a subsurface barrier wall encircling contaminated groundwater to control migration of contaminants into the Duwamish River. Planned Action SEPA Miscellaneous Permit 1. SEPA Checklist dated July 24, 2002. 2. Boundary and topography survey drawing. 3. Biological Assessment prepared by URS dated June 2002. 4. Interim Measures Construction Work plan Volume I and II prepared by URS dated July 2002. 5. A copy of the Administrative Order of Consent between Container Properties, L.L.C., Rhodia Inc., and the USEPA Region 10 dated March 1993, as amended in February 1999.. 6. Letter by the applicant analyzing the project's consistency with Comprehensive Plan, Shoreline Management Regulations. 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206 - 431 -3670 • Fax: 206 - 431 -3665 z . z a w J U 00 N 0 u) w J � COW w w ? �' a = 1- w _ z � I- 0 z �— w w 2 • o 0 0 — o W w I- u o . w z U = O~ z I. Project Description The project site is 21.5 acres, 19.5 of which is on -shore and 2 acres of which are offshore intertidal areas in the Duwamish Waterway. The subject site is within 200 feet shoreline of the Duwamish River and is zoned Manufacturing Industrial Center/Heavy (MIC/H). The property is partially paved with a few buildings and surrounded by fencing and secured gates. The property is flat except near the intertidal areas adjacent to Slip 6 and the Duwamish Waterway. The site is a former industrial facility purchased by Container Properties L.L.C. from Rhone Poulenc. The facility produced vanillin and was closed in 1991. Past process activities at the site introduced contaminants to the soils and groundwater. Primary contaminants included toluene and dissolved metals (primarily copper, arsenic and chromium). There are currently no manufacturing activities at the site. A small vapor extraction and emission control system is presently active at the site. At the time the facility was closed, process equipment, most of the tanks and several buildings were dismantled or removed. Northwest Container Services is currently leasing the facility and using it as shipping center for its ocean-going containers. The site facility is regulated under Resource Conservation and Recovery Act (RCRA). This project is a RCRA corrective action under Administrative Order of Consent No. 1091- 11- 20- 3008(h) between Container Properties, L.L.C., Rhodia Inc., and the USEPA Region 10, dated March 1993, as amended in February 1999. The order of consent lists different components of the clean up process that include interim measures (short term actions to control ongoing risks while a final remedy is being selected); RCRA facility investigation to assess the nature and extent of contamination identified during facility assessment; corrective measures study to identify and evaluate different alternative measures to remediate the site; and corrective measures implementation that includes detailed design, construction, operation, maintenance and monitoring of the chosen remedy. At this time the scope of the project is limited to implementation of interim measures, which include a low permeable barrier wall with groundwater recovery for hydraulic control of the impacted groundwater. The barrier wall is proposed to enclose, to the maximum extent practicable, source areas and affected groundwater. An Impermix barrier wall constructed using vibrated beam technology, will be installed along the western and southern portions of the wall, which border the Duwamish Waterway and Slip 6. A soil - bentonite barrier wall will be constructed using slurry wall technology along the northern and western segments, which comprise the inland portions of the barrier. The location of the barrier wall is within 100 feet low impact environment. Also, a groundwater recovery system will be installed within the containment area to maintain an inward hydraulic gradient and a water level monitoring system will be installed to measure the groundwater level inside the contained area and between the barrier wall and the Duwamish Waterway. The recovered groundwater will be discharged to the King County Department of Natural Resources sewer for final treatment and discharge. 2 r, +,„.,:R.IltRa II. Policies of the Shoreline Management Act/Shoreline Master Program The site is located in an area that was annexed by Tukwila from King County in 1989. As no new shoreline master program has been adopted for this area, the project is subject to King County Shoreline Master Program and regulations. Tukwila is the agency responsible for administering King County shoreline regulations as they pertain to this site. III. Shoreline Regulations Following are the relevant review criteria as contained in the King County Shoreline Regulations as applied by the City of Tukwila: King County Code (KCC) Section 25.16.030 General Requirements: A. Non -water related development shall not be permitted waterward of the Ordinary High Water Mark (OHWM). Response: The proposed project is not water ward of the ordinary high water mark. B. ...No structure shall exceed a height of a thirty-five feet ... Response: The proposed barrier wall is proposed to be subsurface. No other structures are proposed. C. All development shall be required to provide adequate surface water retention and sedimentation facilities during the construction period. Response: The proposed project will meet all King County Surface Water Design Manual requirements for retention and sedimentation facilities during the construction period. D. Development shall maintain the first fifty feet of property abutting a natural environment as required open space. Response: This criterion is not applicable, as the King County shoreline environment designation adjacent to this site is "Urban Environment ". E (1) Parking areas must be located beneath or upland of the development... E (2) Any outdoor parking area perimeter...must be maintained as a planting area with a minimum of five feet. E (3) One live tree...shall be required for each thirty linear feet of planting area. E (4) One live shrub...for each 60 inches of planting area shall be required. E (5) Additional perimeter and interior landscaping of parking areas may be required when large parking areas are proposed. Response: No parking is proposed as part of this project. 3 F. Collection facilities to control and separate contaminants shall be required where storm -water runoff from impervious surfaces would degrade or add to the pollution of receipt waters or adjacent properties. Response: The proposed project will meet all King County Surface Water Design Manual requirements. IV. Comprehensive Plan Shoreline Policies The site is located within the Manufacturing/Industrial Center along the Green/Duwamish River. The Tukwila Comprehensive Plan establishes the following priorities in this shoreline environment: • Redevelopment of under - utilized areas and development of intensive commercial and industrial activities; • Enhancement and restoration of access to the river; and • Protection and restoration of natural environment features and riverbank characteristics, where compatible with development. The proposed project is part of the environmental cleanup required at the site by the USEPA. The proposed subsurface barrier wall and groundwater recovery system is to control migration of contaminants to the Duwamish Waterway. This environmental cleanup will help in the redevelopment of the subject site. V. Comments In response to the notice of application, verbal comments were received from Donna Hogerhuis, Muckelshoot Cultural Resources Program. The comments included a request that if archeological or historic materials were discovered during the construction, all activity must be stopped and Muckelshoot Cultural Resources Program and the State Archaeologist must be contacted. VI. • SEPA and other approvals The proposed project was determined to be a Planned Action and a Notice of Decision was issued on November 8, 2002. Based on the determination of the project as a Planned Action, it was concluded that all impacts associated with this project were mitigated as part of 1998 EIS and no further SEPA review or threshold determination was required. The applicant is responsible for meeting all United States Environmental Protection Agency (EPA) regulations related to contamination issues on the site. VII. Recommendations Approval of the application subject to the following condition: If archeological or historic materials are discovered during the construction, all activity must be stopped and the following agencies must be notified: City of Tukwila, Muckelshoot Cultural Resources Program and the State Archaeologist. 4 Shoreline Management Act Permit Data Sheet and Transmittal Letter From: City of Tukwila Department of Community Development 6300 Southcenter Blvd. Suite 100 Tukwila WA 98188 Date of Transmittal: 11 -08 -02 Type of Permit: Substantial Development Local Government Decision: Approval Applicant Information: Name: RCI Environmental Inc. Address:PO Box 1668, Sumner WA 98390 Phone: 253- 863 -5300 To: Ms. Sandra Lange, Environmental Planner Department of Ecology NW Regional Office 3190 160 Ave SE Bellevue WA 98008 Date of Receipt: Applicant's Representative: Name: Peter Wold, RCI Environmental Inc Address: PO Box 1668, Sumner WA 98390 Phone: 253 -863 -5300 Is the applicant the property owner? No Location of the property: 9229 East Marginal Way South, Tukwila Water Body Name: Duwamish River Shoreline of Statewide Significance: Yes Environment Designation: Urban Description of Project: Implementation of interim measures for environmental cleanup at former Rhone Poulenc Site. The project includes construction of a subsurface wall encircling contaminated groundwater and installation of groundwater recovery system to control migration of contaminants into the Duwamish River. This is a RCRA corrective action under administrative order of consent between container properties LLC, Rhodia Inc and USEPA. Notice of Application Date: Sept 30, 2002 Final Decision Date: Nov 8, 2002 By: Minnie Dhaliwal, Senior Planner, City of Tukwila Phone Number: (206) 431 -3670 ' ;; SHORELINE MANAGEMENT ACT OF 1971 PERMIT FOR SHORELINE MANAGEMENT SUBSTANTIAL DEVELOPMENT File Number: L02 -041 Applied: 08/29/2002 Approved: 11/08/2002 Expiration: 11/08/2004 A permit is hereby granted to: RHONE - POULENC FACILITY to: IMPLEMENT INTERIM MEASURES FOR ENVIRONMENTAL CLEANUP AT FORMER RHONE POULENC SITE. THE PROJECT INCLUDES CONSTRUCTION OF A SUBSURFACE WALL ENCIRCLING CONTAMINATED GROUNDWATER AND INSTALLATION OF GROUNDWATER RECOVERY SYSTEM TO CONTROL MIGRATION OF CONTAMINANTS INTO THE DUWAMISH RIVER. THIS IS A RCRA CORRECTIVE ACTION UNDER ADMINSTRATIVE ORDER OF CONSENT BETWEEN CONTAINER PROPERTIES LLC, RHODIA INC AND USEPA. Upon the following property: Address: 9229 EAST MARGINAL WY S TUKW Parcel Number: 5422600010 Section/Township /Range: NE 33 -24 -04 The following master program provisions are applicable to this development: KING COUNTY SHORELINE MASTER PROGRAM Development under this permit shall comply with the following conditions. Cond: CON0015622 IF ARCHEOLOGICAL OR HISTORIC MATERIALS ARE DISCOVERED DURING CONSTRUCTION, ALL ACTIVITY MUST BE STOPPED AND THE FOLLOWING AGENCIES MUST BE NOTIFIED: CITY OF TUKWILA, MUCKELSHOOT CULTURAL RESOURCES PROGRAM AND THE STATE ARCHAEOLOGIST. This permit is granted pursuant to the Shoreline Management Act of 1971 and nothing in this permit shall excuse the applicant from compliance with any other Federal, State or local statutes, ordinances or regulations applicable to this project, but not inconsistent with the Shoreline Management Act (Chapter 90.58 RCW). This permit may be rescinded pursuant to RCW 90.58.140(8) in the event the permittee fails to comply with the project as approved and any conditions thereof. CONSTRUCTION PURSUANT TO THIS PERMIT MAY NOT BEGIN AND IS NOT AUTHORIZED UNTIL TWENTY -ONE (21) DAYS THE DATE OF FILING WITH THE DEPARTMENT OF ECOLOGY (D.O.E.) AS DEFINEDIN RCW 90.58.140(6) AND WAC 173-14 - OR UNTIL ALL REVIEW PROCEEDINGS INITIATED WITHIN TWENTY -ONE (21) DAYS FROM THE DATE OF SUCH FILING HA TERMINATED; EXCEPT AS PROVIDED IN RCW 9058.140(5)(a)(b)(c). City of Tukwila Department of Community Development / 6300 Southcenter BL, Suite 100 / Tukwila, WA 98188 / (206) 431 -3670 T5 P1n Steve Lancast ect of epa ment of o rnty evelopment Construction or substantial progress toward construction must begin within two (2) years from the effective date of the permit (the date the permit is filed with D.O.E.), per RCW 90.58.143(4). October 11, 2002 Donna Hogerhuis Muckleshoot Indian Tribe Cultural Resources Program 39015 172 Ave SE Auburn WA 98092 Re: Shoreline and Planned Action SEPA application for former Rhone Poulenc site. File number L02 -041. Dear Ms. Hogerhuis: As per our phone conversation yesterday, I am enclosing the SEPA checklist submitted with the application. Also, I have included portions of the construction work plan report that pertain to the proposed earthwork. The entire two- volume report is available for your review at our office. If you have any questions or comments please call me at 206 - 431 -3685. Sincerely, Minnie Dhaliwal Senior Planner. City of Tukwila Steven M. Mullet, Mayor Department of Community Development Steve Lancaster, Director 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206 - 431 -3670 • Fax: 206 - 431 -3665 Project: 1 Z P I di.e Lvt,. i--iet.t•4 4 V1 Y 114.+w1- - C Address: /) 2251 E& 1\i. L.t,0Q l.3 c..t.( V Ti, Date transmitted: q J� / ` ( Response requested by: i 0 .V 1--- Staff coordinator: t� ( 1` �v�..Ca �`'`� (1 \� Date response received: City of Tukwila Department of Community Development File Number z - oz/ e� - a 4 l L a LAND USE PERMIT ROU ING FORM TO: ❑ Building ❑ Planning ❑ Public Works ❑ Fire Dept. ❑ Police Dept. ❑ Parks /Rec ❑ DRC review requested COMMENTS 9(S 14J w- tzSyir?1C 40 bula kipat4 Casru_cosw4-44-e-) 44b t YNAA 4 N \--004 0%4 t- ittik t,44.G) 4 4-i tAnkik. tM -t -2261, ( kr TT) ID 1 0 A 'V (-I / 4- 7 2-964.- ! S “" vt , ❑ Plan submittal requested RECEIVED 1 UKV PUBLIC WORKS ❑ Plan approved Plan check date: /6. Comments prepared by: 03/14/94 L"" z W ce 6 J U 00 U J w g Q = a z � w ~ 0 0I- w w I 0 r- " Z w U = O ~ z LtNA CITY OF TUKWILA PUBLIC WORKS PROJECT REVIEW COMMENTS Project Name: Rhone - Poulenc Facility File #: P02 -069 E02 -021 L02 -041 Review #: 1 Date: 10.14.02 Reviewer: L. Jill Mosqueda, P.E. This is a RCRA corrective action under Administrative Order of Consent No. 1091- 11- 20- 3008(h) between Container Properties, LLC, Rhodia, Inc and USEPA dated March 1993 and amended February 1999. RCI Environmental, contracted by Container Properties, current owner, is project coordinator for this RCRA corrective action. EPA is handling the storm drainage for construction. Applicant must apply for a Type E permit if the work involves hauling 6 loaded vehicles /h /8 hr day, for 2 or more consecutive days. Projects /P02 -069 rhone - poulenc facility 1 State of Washington County of King City of Tukwila CITY OF TUKWILA Department of Community Development 6300 Southcenter Boulevard Tukwila, WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E -mail: tukplan(@,,ci.tukwila.waus AFFIDAVIT OF INSTALLATION AND POSTING OF PUBLIC INFORMATION SIGN(S) I Pete Wold (PRINT - NAME) understand: that•Section:18.104.110 of the Tukwila Municipal Code requires me to post• the property no later than fourteen (14) days following. the issuance of the Notice of Completeness. I certify that on 9 / 3 0 / 0 2 the Public Notice Board(s) in accordance with Section 18.104.110 and the other applicable guidelines were posted on the property located at 9229 E. Marginal Way S. so as to be clearly seen from each right -of -way primary vehicular access to the property for application file number L02 -041 . I herewith authorize the City of Tukwila or its representative to remove and immediately dispose of the sign at the property owner's expense, if not removed in a timely manner or within fourteen (14) da . ?" a Notice letter. A'plicant or Projec anager's Signature On this day personally appeared before me Pte— \N O\ to me known to be the individual who executed the foregoing instrument and acknowledged that he /she signed the same as his/her voluntary act and deed for the uses and purposes mentioned therein. SUBSCRIBED AND SWORN to before me this Z rd day of Oc -obey" , 7ADZ NOTARY PUBLIC in d for the State of Washington residing at (43ePt St- ■rre. G ~ Ta.c+tr,a, L,J F 4 :18 44 3 My commission expires on Dept. Of Community Development City of Tukwila AFFIDAVIT OF DISTRIBUTION r, G -,S-/__, / ,E" HEREBY DECLARE THAT: Notice of Public Hearing Project Number: L 0 Z — D 4/ Determination of Non - Significance Person requesting mailing: /- Notice of Public Meeting Mitigated Determination of Non- Si gni fi cance Board of Adjustment Agenda Pkt Determination of Significance & Scoping Notice Board of Appeals Agenda Pkt Notice of Action Planning Commission Agenda Pkt Official Notice Short Subdivision Agenda \ ! Notice of Application Shoreline Mgmt Permit Notice of Application for Shoreline Mgmt Permit _ _ FAX To Seattle Times Cl assifieds Mail: Gail Muller Classifieds PO Box 70 - Seattle WA 98111 Other Was m a i l e d to each of the addresses listed on this 3o rr day of Ye—Pr in the year 20 (2,: P:GENAWYNETTA/FORMS /AFFIDAVIT -MAIL 08/29/003:31 PM z 3 Z cL w J0 O 0 () 0 cn w W I H U) Li. w • ¢ = W _ z�. 1- Z I— 0 5 • I— w W I I - rz w z 2 0 Project Name: 1FCJ- . V/R f\/t P JT L Project Number: L 0 Z — D 4/ Mailer's Signature: Z_ Person requesting mailing: /- Was m a i l e d to each of the addresses listed on this 3o rr day of Ye—Pr in the year 20 (2,: P:GENAWYNETTA/FORMS /AFFIDAVIT -MAIL 08/29/003:31 PM z 3 Z cL w J0 O 0 () 0 cn w W I H U) Li. w • ¢ = W _ z�. 1- Z I— 0 5 • I— w W I I - rz w z 2 0 1c) U.S. ARMY CORPS OF ENGINEERS () FEDERAL HIGHWAY ADMINISTRATION (>4). DEPT OF FISH & WILDLIFE ( ) OFFICE OF ARCHAEOLOGY ( ) TRANSPORTATION DEPARTMENT QQ DEPT NATURAL RESOURCES Pt) OFFICE OF THE GOVERNOR P4 DEPT OF COMM. TRADE & ECONOMIC DEV, Q() DEPT OF FISHERIES & WILDLIFE () BOUNDARY REVIEW BOARD ( ) FIRE DISTRICT #11 () FIRE DISTRICT #2 ( ) K.C. WASTEWATER TREATMENT DIVISION ( ) K.C. DEPT OF PARKS & REC ( ) K.C. ASSESSOR'S OFFICE ( ) TUKWILA SCHOOL DISTRICT ( ) TUKWILA LIBRARY () RENTON LIBRARY ( ) KENT LIBRARY ( ) CITY OF SEATTLE LIBRARY () QWEST () SEATTLE CITY LIGHT () PUGET SOUND ENERGY ()HIGHLINE WATER DISTRICT ( ) SEATTLE WATER DEPARTMENT ( ) AT &T CABLE SERVICES ( ) KENT PLANNING DEPT ( ) TUKWILA CITY DEPARTMENTS: () PUBLIC WORKS ( ) FIRE ( ) POLICE ( ) FINANCE () PLANNING () BUILDING ( ) PARKS & REC. () MAYOR ( ) CITY CLERK ( ) PUGET SOUND REGIONAL COUNCIL ( ) SW K C CHAMBER OF COMMERCE pQ MUCKLESHOOT INDIAN TRIBE 4 CULTURAL RESOURCES PROGRAM FISHERIES PROGRAM (,• WILDLIFE PROGRAM ( ) SEATTLE TIMES ( ) SOUTH COUNTY JOURNAL P:\ADMINISTRATIVEWORMS\CHKLIST.DOC CHECKLIST: ENVIRONMENTAL REVIEW /SHORELINE PERMIT MAIL �S FEDERAL AGENCIES WASHINGTON STATE AGENCIES ( ) DEPT OF SOCIAL & HEALTH SERV. AC) DEPT OF ECOLOGY, SHORELAND DIV ,py DEPT OF ECOLOGY, SEPA DIVISION* t) OFFICE OF ATTORNEY GENERAL * SEND CHKLIST W/ DETERMINATIONS * SEND SITE MAPS WITH DECISION KING COUNTY AGENCIES SCHOOLS /LIBRARIES UTILITIES CITY AGENCIES OTHER LOCAL AGENCIES MEDIA ,p4 U.S. ENVIRONMENTAL PROTECTION AGENCY ( ) U.S. DEPT OF H.U.D. KNATIONAL MARINE FISHERIES SERVICE Q!;) HEALTH DEPT () PORT OF SEATTLE K.C. DEV & ENVIR SERVICES -SEPA INFO CNTR ( ) K.C. TRANSIT DIVISION - SEPA OFFICIAL (k) K.C. LAND & WATER RESOURCES () FOSTER LIBRARY ( ) K C PUBLIC LIBRARY () HIGHLINE SCHOOL DISTRICT ( ) SEATTLE SCHOOL DISTRICT ( ) RENTON SCHOOL DISTRICT () OLYMPIC PIPELINE ( ) VAL -VUE SEWER DISTRICT ( ) WATER DISTRICT #20 () WATER DISTRICT #125 ( ) CITY OF RENTON PUBLIC WORKS () BRYN MAWR- LAKERIDGE SEWER/WATER DISTRICT () RENTON PLANNING DEPT ( ) CITY OF SEA -TAC ( ) CITY OF BURIEN ( ) TUKWILA PLANNING COMMISSION MEMBERS ( ) TUKWILA CITY COUNCIL MEMBERS (`,(J CITY OF SEATTLE - SEPA INFO CENTER - DCLU ( ) STRATEGIC PLANNING OFFICE* " NOTICE OF ALL SEATTLE RELATED PLNG PROJ. ()Q DUWAMISH INDIAN TRIBE () P.S. AIR POLLUTION CONTROL AGENCY ( ) SOUND TRANSIT ( ) HIGHLINE TIMES ( ) CI.TUKWILA.WA.US.WWW ********* * * * * * * * * * * * * * * * * ** * * * * * * * * * * * ** COMMENTS 000160- 0060 -03 MCELROY GEORGE E ASSOC INC 080468 3131 S VAUGHN WAY STE 301 AURORA CO 80014 000160 - 0061 -02 DUWAMISH YACHT CLUB 1801 S 93RD ST SEATTLE WA 282404 - 9007 -00 KING COUNTY 500 KC TLE WA BLDG 332404 - 9019 -09 KING COUNTY MUSEUM 9404 E MARGINAL WAY S SEATTLE WA 542260 - 0015 -09 BURLINGTON NORTHRN SANTA FE090764 ATTN PROP TAX PO BGX 96189 FORT WORTH TX 76161 542260- 0060 -03 KENWORTH MOTOR CORP 8801 E MARGINAL WAY SEATTLE WA 542260- 0124 -07 KING COUNTY ROOM 500 KC AOMIN BLDG 500 4TH AVE 552410 98108 122 98104 699800 98108 98.108 103535 , 90909 1I 00VOIH3 L30 -£0OS 0/W 30IS2i3AI N 001 8S£SSZ 3H1 ANVdWOJ 9NI30q 1O- 2E0T -0Z Z9S 80196 LL €OV VM 3111V3S H196 S 9091 3N11JVW V1130 90-5000-02 4 70186 VM L9£96 :+awmo etlipemu4...13xsan ,m, S WOV O N 005 AUNO07 )N I)4 20- 09TO- 09ZZ VM 31.i1V3S S 3AV NV4llff12131NI 998Z1 SOAS 1WSW SW)I /1NVl1UVflt 4 0/0 598190 011 SMOOV3W 000M '1c..eniwbl/+.ini 'mu4� z = H `~ W J U. U co 0 w= —I 1 _ w gal w ? "f a w F- _ . zF- t - O w ~ • w 0 U O - w • uj Z . (. O ~ z DATE OF APPLICATION: NOTICE OF COMPLETE APPLICATION: NOTICE OF APPLICATION POSTED: Cizy of Tukwila Department of Community Development NOTICE OF APPLICATION DATED SEPTEMBER 30, 2002 The following applications have been submitted to the City of Tukwila Department of Community Development for review and decision. APPLICANT: RCI Environmental Inc. LOCATION: 9229 East Marginal Way South OWNER OF THE PROPERTY: Container Properties LLC. FILE NUMBERS: L02 -041 PROPOSAL: The proposal is to remediate groundwater contamination by construction of a barrier wall that will be approximately 2300 lineal feet long and 50 to 70 feet deep. This action is being taken under the supervision/approval of EPA region 10. The objective of the project is to control migration of site contaminants into the Duwamish River and Slip 6. OTHER REQUIRED PERMITS: Planned Action SEPA Development Permit These files can be reviewed at the Department of Community Development, 6300 Southcenter Blvd., #100, Tukwila, WA. Please call (206) 431 -3670 to ensure that the file(s) will be available. OPPORTUNITY FOR PUBLIC COMMENT You can submit comments on this application. You must submit your comments in writing to the Department of Community Development by 5:00 p.m. on October 30, 2002. If you have questions about this proposal contact Minnie Dhaliwal, Planner -in- charge of this file. Anyone who submits written comments will become parties of record and will be notified of any decision on this project. APPEALS You may request a copy of any decision on this project or obtain information on your appeal rights by contacting the Department of Community Development at 206 -431 -3670. Decision related to the Shoreline is made by the Director of Community Development and may be appealed to the State Shorelines Hearing Board. The Department will provide you with information on appeals if you are interested. August 29, 2002 September 23, 2002 September 30, 2002 Steven M. Mullet, Mayor Steve Lancaster, Director 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206 - 431 -3670 • Fax: 206 - 431 - 3665 RCI ENVIRONMENTAL INC. ENVIRONMENTAL CONTRACTORS & ENGINEERS September 26, 2002 Minnie Dhaliwal Associate Planner City of Tukwila — Department of Community Development 6300 Southcenter Boulevard Tukwila, Washington 98188 -2544 Subject: Former Rhone - Poulenc Site Dear Minnie: If you have any questions please call me at 253 - 863 -5300 Sincerely, RCI Environmental, Inc. Pete Wold President ,-- 2 — 4 - 2_01 RCI Environmental, Inc. ( "RCIE ") is under contract to Container Properties to be the project coordinator for the Administrative Order on Consent for Corrective Action from EPA Region 10 for the former Rhone - Poulenc Site. The owner of RCIE is part owner of Container Properties. I have been given the authority by the owners of Container Properties to administer the RCRA corrective action concerning legal and administrative duties, to be the owners' representative, and to sign documents for Container Properties. P.O. Box 1668 Sumner, WA 98390 Sumner Tel 253.863.5300 Kent Tel 253.852.4254 Fax 253.859.5702 Contractors Uo RCIENI•0959i'JK An Equal Opportunity Employer 1 CITY OF TUKWILA Department of Community Development 6300 Southcenter Boulevard, Tukwila, WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E - mail: tukplan rr,ci.tttkwila.wa.u5 AFFIDAVIT OF OWNERSHIP AND HOLD HARMLESS PERMISSION TO ENTER PROPERTY STATE OF WASHINGTON COUNTY OF KING The undersigned being duly sworn and upon oath states as follows: I. I am the current owner of the property which is the subject of this application. ss 2. All statements contained in the applications have been prepared by me or my agents and are true and correct to the best of my knowledge. 3. The application is being submitted with my knowledge and consent. 4. Owner grants the Ciqt, its employees, agents, engineers, contractors or other representatives the right to enter upon Owner's real property, located at 9229 East Marginal Way South for the purpose of application review, for the limited time necessary to complete that purpose. 5. Owner agrees to hold the City harmless for any loss or damage to persons or property occurring on the private property during the City's entry upon the property, unless the loss or damage is the result of the sole negligence of the City. 6. The City shall, at its discretion , cancel the application without refund of fees, if the applicant does not respond to specific requests for items on the "Complete Application Checklist" within ninety (90) days. 7. Non - responsiveness to a City information request for ninety (90) or more days, shall be cause to cancel the application(s) without refund of fees. EXECUTED at S V 'Mi.) (city), to .- A (state), on (j t) r. '.J el T Z• 9 , P 1 T sL n V (Si On this day personally appeared before me 1-Pke •). Va to me known to be the individual who executed the foregoing instrument and acknowledged that a /she signed the same as his/her voluntary act and deed for the uses and purposes mentioned therein. SUBSCRIBED AND SWORN TO BEFORE ME ON THIS 2 DAY OF ?Iv , ?�oZ ' MoTA S f S My Commission expires on PVB ot, ito '�� I 111 (Print Name) (Address) 12.1 , Ve<S 11■102 co-3 1 7,5,s r .5•J +'1N R wA c' C - z 5'3) E9 - C`J (Phone Number) NOTARY PUBLIC in and for State of Washington residing at ( L C ij r & Salr Poe G- G4r�'12 L,.,3(::) 983910 - 1 -7Z-03 RECEIVED AUG 29 2002 COMMUNITY DEVELOPMENT '• st'« zti:;t:a <._W i1J.,n "'Y,�aY:, x�'s'�„�;p+:Sx..^^ ... .. M;; a ',.•.. i'. :... • , ,, ., �iK ::.,�:;:; u+ar . .^.Yf`.2:�"-:�:4... . ,, .. ....,.�...�'_:.��.{;.:.+.+.:.' September 23, 2002 Peter Wold P.O. Box 1668 Sumner WA 98390 Dear Mr. Wold: Sincerely, Minnie Dhaliwal Senior Planner City of Tukwila Steven M. Mullet, Mayor Department of Community Development Steve Lancaster, Director NOTICE OF COMPLETE APPLICATION Re: Application for former Rhone Poulenc Inc facility at 9229 East Marginal Way South; File Numbers- Shoreline permit (L02 -041), and Planned Action SEPA (E02- 021). The Department of Community Development received your application on August 29, 2002 to remediate groundwater contamination by construction of a barrier wall at the above referenced site. Based on a review of your submittal relative to those requirements as set out in the Complete Application Checklists for Planned Action and Shoreline Permit, your applications are deemed complete. A notice of application for shoreline permit must be distributed within 14 days of this letter. At this time we have started code related review of your application. This determination of complete application does not preclude the City to require that you submit additional plans or information, if such information is necessary to further review the application and ensure that the project meets the substantive requirements of Tukwila Municipal Code. The next step is for you to install the notice board on the site within 14 days of the date of this letter. You received information on how to install the sign with your application packet. As per our conversation today we have prepared a laminated copy of the Notice of Application to post on the board. The notice is dated September 30, 2002 and must be posted on or before that date. After installing the sign with the laminated notice, you need to return the signed Affidavit of Posting to our office. If you have any questions you can reach me at 206 - 431 -3685. 6300 Southcenter Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone: 206 - 431 -3670 • Fax: 206 - 431 -3665 RCI CONSTRUCTION GROUP ENVIRONMENTAL General Contractors & Engineers August 29, 2002 Ms. Nora Gierloff, Senior Planner City of Tukwila Department of Community Development 6300 Southcenter Boulevard Tukwila, Washington 98188 RECEIVED AUG 2 9 20021 COMMUNITY DEVELOPMENT Subject: Shoreline /SEPA Planned Action Permit Application Former Rhone Poulenc, Inc. Facility 9229 East Marginal Way S. Tukwila, Washington Dear Ms. Gierloff: RCI Environmental, Inc. is pleased to present the following information in support of the Shoreline /SEPA Planned Action Permit Application for the above - referenced facility. This application is provided in support of our proposed plan to remediate groundwater contamination by construction of a barrier wall. This action is being taken under the supervision /approval of EPA Region 10. The proposed remediation plan is included in Attachment A. The following addresses the items listed in the " Shoreline /SEPA Planned Action Permit Complete Application Checklist Table ". APPLICATION FORMS 1. Application Checklist One copy of the application checklist is included with this letter (Attachment B), which indicates items submitted with the application. 2. Complete Application Packet Eight copies and one set of high quality photo reductions, reduced to 8 1 /2" to 11" of all plans are included with this letter (Attachment A). 2 3. Application Fee The $550.00 fee is included with this letter. 4. SEPA Planned Action Environmental Checklist Eight copies of the SEPA Environmental Checklist (Attachment C). 5. King County Assessor's Maps King County Assessor's maps, indicating each property within 500 feet of the subject lot are included with this letter (Attachment D). 6. Mailing Labels Two sets of mailing labels for all property owners and tenants within 500 feet of the subject property are included with this letter (Attachment E). 7. Public Notice Board PO Box 1668 Sumner, WA 98390 • Phone (253) 863 -5300 • Fax (253) 859 -5702 webslte -www. rcI- group. com Contractor Lic. RCIENI'099NK An Equal Opportunity Employer SITE PLANS Former Rhone - Poulenc, Inc. Facility page 2 August 29, 2002 A 4'x4' Public Notice board will be installed at the site within 14 days of the Department determining that a complete application has been received. PROPERTY INFORMATION = cd 8. Vicinity Map 6 = A vicinity map with site location is included with this letter (Attachment F). The site is v p located at 9229 East Marginal Way S., in the City of Tukwila, Washington. Cl) W J = 9. Surrounding Land Use u The site is located in an area characterized by industrial development. Major features in w 0 the site vicinity are depicted in Attachment F. 2 10. Title Report d A title report, establishing status as a legal lot of record, ownership, and any easements ▪ w and encumbrances is included with this letter (Attachment G). Z 11. Lot Lines Z O U.1 A map indicating lot lines for 300 feet from the site's property lines is included with this o letter (Attachment D). 0 co O • N PROJECT DESCRIPTION AND ANALYSIS w W • U 12. Response to K.C.C.25.16.030 General Requirements L I O The following are responses to K.C.C.25.16.030 Shoreline Management General W Z Requirements: H O ~ A. The proposed project is not waterward of the ordinary high water mark. B. There are no structures associated with this project that exceed thirty -five feet in height. C. Surface water retention and sedimentation control facilities to be utilized during construction are discussed in the enclosed engineering report (Attachment A). D. The proposed project is not abutting a natural environment. E. The proposed project does not include any parking facilities. F. Stormwater drainage facilities are discussed in the enclosed engineering report (Attachment A). G. The proposed project will comply with all applicable regulations. H. The proposed project is not located in an area proposed for a King County trail system or public access. I. The proposed project is not located on Lake Sammamish. 13. Plan Stamps and Signatures One set of all plans have been stamped and signed by the appropriate individual. 14. Boundary and Topographic Survey A boundary and topographic survey, stamped by the surveyor, are included with this letter (Attachment H). Z Former Rhone - Poulenc, Inc. Facility page 3 August 29, 2002 15. Sensitive Areas A designated sensitive area (Duwamish River) is located adjacent to the west of the site. According to the "Biological Assessment Covering Federally Listed and Candidate Species for the Barrier Wall Installation at the Former Rone - Poulenc Site on the Duwamish River in King County, Washington" (URS, 2002), the effect of the project on bull trout/Dolly Varden, chinook salmon, and coho salmon, is unknown; however, the project is "not likely to adversely affect" these species. The project is not expected to affect bald eagle, steller sea lion, humpback whale, or leatherback sea turtle populations that may be present near the project location. In addition, the project is not expected to affect chinook salmon (Duwamish HUC) or coho salmon (Duwamish HUC) habitats. Please refer to the attached report (Attachment I) for details regarding the impact of the proposed project on the Duwamish River. 16. 100 Year Flood Plain Boundary The 100 year flood plain boundary and elevation map requirement has been waived by the City of Tukwila Planning Department (see Attachment B). 17. Lot Line Plan Neither a short plat nor a subdivision is included in this project. 18. Site Improvement Plan A plan depicting site improvements (Attachment J) is provided with this letter. The project includes the construction of a slurry wall, enclosing approximately 6.9 acres. The slurry wall w ill be located at and beneath the ground surface of the site. The construction of buildings is not included in this project. 19. Fire Access Plan A plan indicating the locations of on -site fire hydrants is included with this letter (Attachment H). Since the project does not include the construction of any buildings, a fire access plan is not included. 20. Sewer and Water Plan A plan depicting water and sewer line locations is provided as Attachment H. 21. Sewer and Water Plan (non -City of Tukwila) According to representatives at the City of Tukwila, Public Works Department, sewer and water service at the site is provided by the City of Tukwila. 22. Storm Drainage A plan depicting storm drainage systems is provided as Attachment H. The project complies with the King County Surface Water Drainage Manual's Core and Special Requirements in the following manner: 1.2.1 All surface and storm water runoff will be discharged at the natural location and will not affect downstream properties. 1.2.2 Offsite analysis is not necessary, as the project will not change the rate, volume, duration, or location of discharges to and from the project site. 1.2.3 No new impervious surface and /or land cover is involved in the project; runoff will not be increased. 1.2.4 No new conveyance systems will be created. Former Rhone - Poulenc, Inc. Facility page 4 August 29, 2002 1.2.5 The project includes demolition of small areas of asphalt. Erosion control measures will be implemented as necessary; due to the relatively flat topography of the site significant erosion resulting from the demolition is not expected. Erosion control elements may include temporary containment berms, silt fences, straw bales, check dams, and stabilized construction entrances. Mulch application and hydroseeding will be used if needed. 1.2.6 Drainage facilities will be maintained and operated in compliance with King County maintenance standards. 1.2.7 No drainage facilities will be constructed or modified. 1.2.8 A groundwater recovery and treatment system, creating an inward hydraulic gradient is i ncluded i n the project. T he recovered water will m eet King C ounty Department of Natural Resources criteria. 1.3.1 The project site is not a critical drainage area and does not necessitate a master drainage plan, basin plan, lake management plan, or shared facility drainage plan. 1.3.2 The site is not adjacent to a stream, lake, wetland, or closed depression. 1.3.3 A levee exists at the site; however, the levee will not be modified or demolished. 1.3.4 A Stormwater Pollution Prevention Plan has been prepared for the project and is included in Appendix F of Attachment A. 1.3.5 A project- specific Spill Prevention and Containment Plan and a Stormwater Pollution Prevention Plan have been prepared and are included in Appendices E and F of Attachment A. 23. Hydrant Plan See number 19. 24. Schematic Road Design The project is located to the west of East Marginal Way South. A schematic plan depicting nearby roadways is provided as Attachment F. 25. Geotechnical Analysis A geotechnical characterization was completed by URS in June. A copy of this report is provided a s Attachment A . T he report indicates t hat the " soil strengths are considered sufficient for slurry trench construction; however, it is planned that the barrier wall be restricted to a key depth of approximately 2 feet into the upper aquitard to avoid problematic construction with soft soils ". 26. Landscape Planting Plan The site consists of an asphalt -paved area. The project will not include the removal or planting of any vegetation at the site. 27. Lighting Plan The project will not include the installation, removal, or alteration of any lights. 28. Signage The project will not include the installation of any signage. Appropriate public information signage will be installed at the site. 29. Stream Frontage Plan No streams or creeks are located within or adjacent to the project area. Former Rhone - Poulenc, Inc. Facility page 5 August 29, 2002 SITE PLANS FOR SHORELINE PROJECTS 30. River Characteristics Plan A plan indicating the top of the riverbank, landward catch point toe of the levee, riverbank toe, mean high water mark and base flood elevation is included with this letter. 31. Riverward Work The project will not extend riverward of the mean high water mark. 32. Limits of River Environment A plan indicating the limits of the 40 -foot river, 100 -foot low impact, and 200 -foot high impact environments is included with this letter (Attachment K). 33. Riverbank Easement The project is located approximately 50 feet from the riverbank, which satisfies the minimum setback distance (30 feet) required. See Attachment J for details. 34. Construction Limit Lines Construction line limits are depicted in Attachment J. The proposed volume and type of extracted material and fill is characterized in URS's in June 2002 report. A copy of this report is provided as Attachment A. ELEVATIONS 35. Building Elevations The project does not include construction of any buildings. 36. Colored Elevations The project does not include construction of any buildings. 37. Models and Photomontage As the project does not include residential development, a model or photomontage is not required (TMC 18.60.040). 38. Rendering An accurate rendering of the site is not included in this permit application. CROSS - SECTIONS FOR SHORELINE PROJECTS 39. Shoreline Cross Sections Plans depicting subsurface profiles are provided in Attachment L. Sincerely, RCI Environmen Pe er B. Wold President Enclosures: Attachment A Attachment B Attachment C Attachment D Attachment E - Attachment F Attachment G Attachment H Attachment I - Attachment J — Attachment K Attachment L — , Inc. Former Rhone - Poulenc, Inc. Facility page 6 August 29, 2002 RCI Environmental, Inc. appreciates the opportunity to present this Shoreline /SEPA Planned Action Permit Application. Please do not hesitate to contact the undersigned with any questions or comments. — Interim Measures Construction Work Plan Volume 1 and 2, URS July 2002 — Shoreline Permit Complete Application Checklist — SEPA Planned Action Initial Qualifications — King County Assessor Maps Two Sets of Mailing Labels — Project Vicinity Map — Site Title Report — Boundary and Topographic Survey /Fire Access Plan Site Biological Assessment Site Barrier Wall Layout — Construction Limits - Limit of River Environment Site Subsurface Profiles CITY OF TUKWILA D E V E LO M EN PMENt Department of Community Development 6300 Southcenter Boulevard, Tukwila, WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E- mail :: tukplan @ci.tukwila.wa.us APPLICATION NAME OF PROJECT /DEVELOPMENT: Former Rhone Poulenc, Inc. Fac 1 i ty LOCATION OF PROJECT /DEVELOPMENT: Give street address or, if vacant, indicate lot(s), block and subdivision, access street, and nearest intersection. LIST ALL 10 DIGIT PARCEL NUMBERS. 9229 East Marginal Way South /5422600010 Quarter: SE /SW Section: 33 Township: 24N Range: 4E (This information may be found on your tax statement.) RECEIVED 'AUG 2 9 7002 SHORELINE PERMIT DEVELOPMENT COORDINATOR : The individual who: • has decision making authority on behalf of the applicant in meetings with City staff, • has full responsibility for identifying and satisfying all relevant and sometimes overlapping development standards, and • is the primary contact with the City, to whom all notices and reports will be sent. Name: Peter Wold, President, RCI Environmental Inc. Address: P.O. Box 1668, Sumner WA 98390 Phone: 253 -8600 FAX: 253- 859 -5702 Signature: Date: August 29 , 2 0 0 2 R•\ hnmr nn v,\tnlwiln\lyd\nnnc \SIIf1RI. nnr OR/I /00 FOR STAFF USE ONLY Sierra Type: P -SHORE Planner: File Number: . (' — 0 ,4 Application Complete (Date: ) Project File Number: 'J7D 9, - 0(79 Application Incomplete (Date: ) Other File Numbers: /- -oil CITY OF TUKWILA D E V E LO M EN PMENt Department of Community Development 6300 Southcenter Boulevard, Tukwila, WA 98188 Telephone: (206) 431 -3670 FAX (206) 431 -3665 E- mail :: tukplan @ci.tukwila.wa.us APPLICATION NAME OF PROJECT /DEVELOPMENT: Former Rhone Poulenc, Inc. Fac 1 i ty LOCATION OF PROJECT /DEVELOPMENT: Give street address or, if vacant, indicate lot(s), block and subdivision, access street, and nearest intersection. LIST ALL 10 DIGIT PARCEL NUMBERS. 9229 East Marginal Way South /5422600010 Quarter: SE /SW Section: 33 Township: 24N Range: 4E (This information may be found on your tax statement.) RECEIVED 'AUG 2 9 7002 SHORELINE PERMIT DEVELOPMENT COORDINATOR : The individual who: • has decision making authority on behalf of the applicant in meetings with City staff, • has full responsibility for identifying and satisfying all relevant and sometimes overlapping development standards, and • is the primary contact with the City, to whom all notices and reports will be sent. Name: Peter Wold, President, RCI Environmental Inc. Address: P.O. Box 1668, Sumner WA 98390 Phone: 253 -8600 FAX: 253- 859 -5702 Signature: Date: August 29 , 2 0 0 2 R•\ hnmr nn v,\tnlwiln\lyd\nnnc \SIIf1RI. nnr OR/I /00 DRAFT REPORT BIOLOGICAL ASSESSMENT COVERING FEDERALLY LISTED AND CANDIDATE SPECIES FOR THE BARRIER WALL INSTALLATION AT THE FORMER RHONE- POULENC SITE ON THE DUWAMISH RIVER IN KING COUNTY, WASHINGTON Prepared for RCI Environmental, Inc. June 2002 1400 Century Square 1501 4th Avenue Seattle, Washington 98101 (206) 438 -2700 RECEIVED AUG 2 9 2nn2 COMMUNi DEVELOPMENT Z =Z W J U U • uJ U 0 J = w • 0 g a I— • d Z � I- 0 Z W U • D :0 - .0 I-' W W I w U N: 0 Z TABLE OF CONTENTS . Page 1.0 INTRODUCTION 1 1.1 DESCRIPTION OF ENDANGERED SPECIES AND CRITICAL HABITAT 1 1.2 DESCRIPTION OF ESSENTIAL FISH HABITAT 2 i 2.0 PROJECT LOCATION 3 3.0 PROJECT DESCRIPTION 3 3.1 BACKGROUND INFORMATION 3 3.2 BARRIER WALL AND VIBRATED BEAM TECHNOLOGY 4 3.3 CONSTRUCTION SCHEDULE AND TECHNIQUES 5 3.3.1 Timing 5 3.3.2 Construction Methods and Implementation 5 3.3.3 Barrier Wall Installation 6 S 3.3.4 Bather Wall Contingencies 7 I 3.3.5 Groundwater Recovery System 8 3.3.6 Maintenance and Monitoring 8 3.3.7 Site Restoration 8 3.3.8 Best Management Practices 9 4.0 ACTION AREA 9 5.0 EXISTING ENVIRONMENTAL CONDITIONS 10 5.1 THE DUWAMISH RIVER ESTUARY 10 5.2 SITE CONTAMINATION 11 6.0 SPECIES AND HABITAT INFORMATION 11 6.1 SITE SPECIFIC INFORMATION 11 . 6.2 SPECIES PRESENT 12 i 6.3 SPECIES UTILIZATION 13 . 6.3.1 Bald Eagle 13 6.3.2 Bull Trout/Dolly Varden 13 6.3.3 Chinook Salmon 16 6.3.4 Coho Salmon 18 6.3.5 Steller Sea Lion 19 6.3.6 Humpback Whale 20 6.3.7 Leatherback Sea Turtle 21 7.0 EFFECTS OF THE ACTION 22 7.1 ESA EFFECTS ANALYSIS 22 7.1.1 Bald Eagle 22 7.1.2 Bull Trout/Dolly Varden, Chinook and Coho Salmon 23 7.1.3 Steller Sea Lion 28 7.1.4 Humpback whale 28 7.1.5 Leatherback Sea Turtle 29 7.2 EFH EFFECTS ANALYSIS 29 7.2.1 Identification of Essential Fish Habitat 29 1:Wrojects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 1 URS CORPORATION 7.2.2 Site Specific Effects to Duwamish River Essential Fish Habitat 29 8.0 TAKE ANALYSIS FOR LISTED SPECIES 31 8.1 BALD EAGLE 31 8.2 BULL TROUT/DOLLY VARDEN, CHINOOK AND COHO SALMON 31 8.3 STELLER SEA LIONS 31 8.4 HUMPBACK WHALE 32 8.5 LEATHERBACK SEA TURTLE 32 9.0 CONSERVATION MEASURES 32 9.1 BALD EAGLE 32 9.2 FISH 32 9.3 MARINE MAMMALS AND SEA TURTLE 33 10.0 DETERMINATION OF EFFECT 33 11.0 COORDINATION /CONSULTATION HISTORY 35 12.0 REFERENCES 36 APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Figures Site Photos Species Request Letters USFWS Matrix NMFS Matrix TABLE OF CONTENTS (Continued) Page I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP■Engineering Report\Draft Engineering Report Wppendix- Biological Assessment.doc fi URS CORPORATION Z ; Ir 2 6� JO. 00 . u) 0 . L11 I J N LL W O. 2 uj L-- _ z �. l=-0 Z W U 0 c I- I . L ! - 0 . z 0 =' O ~ z ' • BIOLOGICAL ASSESSMENT COVERING FEDERALLY LISTED AND CANDIDATE SPECIES FOR THE BARRIER WALL INSTALLATION AT THE FORMER RHONE - POULENC SITE ON THE DUWAMISH RIVER IN KING COUNTY, WASHINGTON 1.0 INTRODUCTION This Biological Assessment (BA) was prepared to examine how the proposed barrier wall installation at the former Rhone- Poulenc site on the Duwamish River in King County, Washington may affect federally listed and proposed threatened and endangered species under the Endangered Species Act (ESA). This BA evaluates potential impacts to these species from project implementation based on existing information on the site's current habitat conditions and a description of the proposed project. Additionally, the assessment considers the site's suitability for providing the life history requirements of these species. A Biological Assessment is required for some federal activities (projects that are authorized, funded or carried out by a federal agency) under Section 7 (c) of the Endangered Species Act of 1973, as amended. State agencies and private parties are not required to consult with the National Marine Fisheries Service (NMFS) or the U. S. Fish and Wildlife Service (USFWS) unless state or private actions require a federal permit or receive federal funding (NMFS 1996). A BA identifies the status of listed and proposed species and/or critical habitats for such species within a project area (candidate species are optional). This report identifies the project impacts on these species and their critical habitats, states the conservation measures taken to mitigate those impacts, and makes a determination of effect. This BA also documents consultations under the Magnuson- Stevens Act of 1996. Public Law 104 -267, the Sustainable Fisheries Act of 1996, amended the Magnuson - Stevens Fishery Conservation and Management Act (MSFCMA) to establish new requirements for Essential Fish Habitat (EFH) descriptions in federal fishery management plans (FMPs) and to require federal agencies to consult with NMFS on activities that may adversely affect EFH. Under Section 305(b)(4) of the Magnuson - Stevens Act, NMFS is required to provide discretionary EFH conservation and enhancement recommendations to federal and state agencies for actions that may adversely affect EFH. However, state agencies and private parties are not required to consult with NMFS unless state or private actions require a federal permit or receive federal funding. 1.1 DESCRIPTION OF ENDANGERED SPECIES AND CRITICAL HABITAT Federally listed threatened and endangered species are those plant and animal species formally listed by the USFWS and the NMFS under authority of the Endangered Species Act. An endangered species is defined as "one in danger of extinction throughout all or a significant portion of its range." A threatened species is defined as `one likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range." Species listed as proposed receive limited federal protection (i.e. Section 7 consultation requirement for federal actions). Candidate species are those that are candidates for listing and I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\Th{WP■Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 1 URS CORPORATION could become listed during the course of the project. Candidate species receive no mandatory federal protection under the ESA, but NMFS and USFWS encourage voluntary protection of the species during project design. The efforts to minimize impacts may avoid a future listing and/or future modification should the species be listed (NMFS 2001). Under the ESA, vertebrate populations are considered a "species" if they are "distinct." The USFWS classifies and lists salmonid species by Distinct Population Segments (DPS). The NMFS classifies and lists salmonid species by Evolutionary Significant Unit (ESU). To be considered an ESU or DPS, a population or group of populations must (1) be substantially reproductively isolated from other populations and (2) contribute substantially to the ecological or genetic diversity of the biological species. Factors used in determining ESUs and DPSs include spatial, temporal, and genetic isolation, maturation rates, and other life history traits. As part of the ESA process, critical habitat for a listed species is identified and designated by the NMFS or USFWS. The term critical habitat is defined in the ESA (16 U.S.C.153) to mean: (i) the specific areas within the geographic area occupied by the species, at the time it is listed in accordance with the provisions of Section 4 of the Act, on which are found those physical or biological features (I) essential to the conservation of the species and (II) which may require special management consideration of protection; and (ii) the specific areas outside of the geographical area occupied by the species at the time it is listed in accordance with the provisions of Section 4 of this Act, upon a determination by the Secretary that such areas are essential to the conservation of the species." 1.2 DESCRIPTION OF ESSENTIAL FISH HABITAT I:Wrojects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering ReporADraft Engineering Report\Appendix- Biological Assessmentdoc 2 URS CORPORATION The ESA also states that "Except in those circumstances as determined by the Secretary, critical habitat shall not include the entire geographical area which can be occupied by the threatened or endangered species." By this definition, critical habitat includes those areas that are essential to the conservation of a threatened or endangered species. The ESA defines the term "conservation" as "...to use and the use of all methods and procedures which are necessary to bring any endangered species or threatened species to the point at which the measures provided pursuant to this Act are no longer necessary." That is, the status of the species would be such that it would be considered "recovered." Therefore, the area designated as critical habitat should contain the physical and biological resources necessary to support and sustain a population of a threatened or endangered species that is sufficiently large and persistent to be considered recovered. The federally listed and proposed species or ESUs, as defined above, referred to in information requested and received from the NMFS, USFWS and the Washington Department of Fish and Wildlife (WDFW) are included in this BA along with candidate species. The Magnuson - Stevens Fishery Conservation and Management Act of 1996 requires consultation with the NMFS on activities that may affect EFH, defined as "those waters and substrates necessary to fish for spawning, breeding, feeding, or growth to maturity." EFH includes marine waters, intertidal habitats, and freshwater streams accessible to anadromous fish. Pacific salmon EFH for the Pacific Coast Salmon Plan z =z CC w 6 00 CO CI UJ J H W O �Q I d Z = I- 0 w ~ U 8 22 0 F- Ww I- H W O Z includes all streams, lakes, ponds, wetlands, and other water bodies currently and historically utilized by Pacific salmon within Washington, Oregon, Idaho, and California within the U.S. Geological Survey (USGS) hydrologic unit code (HUC). The Magnuson - Stevens Act promotes the protection of these habitats through review, assessment, and mitigation of activities that may adversely affect these habitats. This BA satisfies the consultation requirements by providing a description and assessment of EFH in the project area; a description of the project and its potential impacts on these habitats; and a description of the mitigation measures that will be implemented to protect these habitats. The project is located at 9229 East Marginal Way South in Tukwila, King County, Washington. The site is 21.5 acres, 19.5 of which are on -shore and 2 acres of which are offshore intertidal areas in the Duwamish Waterway (Appendix A, Figure 1). The site is north of, but adjacent to Slip 6 at approximately river mile (RM) 5 and between Stations 245+00 and 250+00 in Township 24N, Range 4E, Section 33. The project is located in Watershed Resource Inventory Area 9 (Duwamish- Green) and the USGS HOC 17110013 (Duwamish). 3.1 BACKGROUND INFORMATION The Environmental Protection Agency (EPA) is the lead regulatory agency for this project. The site facility is regulated under Resource Conservation and Recovery Act (RCRA). In 1989 -90, the EPA conducted a RCRA Facility Assessment (RFA) (EPA 1990). RCRA Facility Investigation work plan was subsequently prepared by CH2M Hill in 1993. Th acility Investigation (RFI) was completed and the results presented in a 1995 report (CH2M Hill 1995). An Administrative Order of Consent was executed with EPA, Region 10, in May 1993. In October 1998, Container Properties purchased the property and assumed responsibility of the remediation order. On November 15, 2000, Container Properties submitted to EPA a Hydraulic Control Revised Interim Measures Work Plan (IM Work Plan) for the facility. The IM Work Plan proposed interim remedial action to control migration of contaminants from affected soil and groundwater at the facility and contains summary information of site layout, geotechnical investigations, and contamination. Based upon subsequent negotiations with EPA, significant changes have been made to the scope of the interim action. The key components of the interim measures include a low - permeability subsurface barrier wall to be installed completely around the source areas and a groundwater recovery system to maintain inward flow of groundwater. 1:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 3 URS CORPORATION 2.0 PROJECT LOCATION 3.0 PROJECT DESCRIPTION z = z c w QQ J O 00 co ❑ W I I-- CO Li_ w 0 LQ ❑❑ = d 1— w z H 1— 0 Z 1— • ❑ • S. 12 • — w W 1— H L A:O .. z U= O ~ z 3.2 BARRIER WALL AND VIBRATED BEAM TECHNOLOGY In 1974, Thatcher Engineering brought the vibrated beam technique to the United States (Slurry Systems 2002). The technique originated in Europe in the early 1950's. The vibrated beam installation technique allows very thin walls to be constructed subsurface with minimum disruption of surrounding surfaces and buildings. The construction of a vibrated beam subsurface slurry wall consists of vibrating (using a powerful vibratory hammer) a crane- suspended I -beam (33 -inch wide by 152 -inch long flange steel beam) from the surface to the impervious layer, while a pre -mixed slurry is injected through nozzles affixed to the bottom of the beam (Appendix A, Figure 2). The beam is locked in the guide frame for exact positioning and stabilized by a hydraulic foot that provides guidance and aids in keeping the insertion vertical. The beam is driven to the target depth using the vibratory hammer. After the beam attains the required depth, the beam is extracted at a controlled rate (while injecting slurry) to fill the void left by the beam extraction, creating an in -ground panel of slurry. Slurry is injected under pressure through a set of nozzles located at the base of the vibrated beam. This enables a thin slurry curtain wall of consistent mix to be constructed below ground. This process is repeated along the line of the wall, with each beam insertion overlapping the previously inserted panel. The overlap is achieved by utilizing a fm welded to the flange of the beam. The fm penetrates into the completed section and allows the slurry to key into the previous, adjoining panel. In more definite terms, the continuous barrier wall is created by overlapping each 33 -inch beam panel approximately 17 inches using the 14 -inch fm. The subsequent beam insertions overlap the previous by a total of 17 inches (14 inches of fm, plus 3 inches of wide flange beam). The actual panel installed, exclusive of overlap, is 30 inches using a 33 -inch beam with a 14 -inch fin. The wall is 4 to 6 inches thick and can be installed to depths over 100 feet. The technique has been used to contain the enclosed area or to isolate the enclosed area from its surroundings. Applications include construction or permanent dewatering, prevention of lagoon leakage, containment of toxic wastes or tailings. A benefit to the vibrated beam method, especially for hazardous waste containment, is that minimal excavation is required. Only a 2' x 2' reservoir trench would need to be dug along the barrier wall alignment. This trench remains full of slurry during beam emplacement ensuring a continuous wall. The main reason for the retention of slurry in the trench during installation of the slurry wall is to handle void spaces such that a continuous wall is formed. If a small void is encountered during beam penetration, there may be enough volume of slurry in the trench to fill it. However, with larger voids, backfill, generally sand, may be required to fill the void and then the beam will be redriven through the backfilled material. During backfilling, the vibratory rig will move ahead and redo the slurry wall. If an obstruction is reached that the beam cannot penetrate, there are two possible solutions, which are dependent on field conditions. One solution is to backfill after discovering the void/obstruction and if an obstruction, removal of the obstruction. Another solution would be to simply circumvent the void/obstruction. A slurry wall can consist of any pumpable slurry material that will hold a vertical trench and set into a non- 1 :\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 4 URS CORPORATION erodible solid. It shall be chemically compatible with its environment and be of adequate impermeability. The self - hardening slurry for this project is called IMPERMIX. Impermix is similar to cement bentonite slurry. However, attapulgite or sepiolite clay is used in lieu of bentonite, and selected ground blast furnace slag cement is used in lieu of Portland cement. Impermix offers a hydraulic conductivity of lx 10 -8 cm/sec or less. Mixing of the materials is conducted in a controlled mixing plant on -site. Continuous injection and a unique on -site mixing plant ensures stringent control of slurry mixes. The mixing pump is a high -speed colloidal pump that allows complete blending of the shiny materials and water. After blending, the slurry is transferred to a two -stage Moyno pump which allows for varying discharge pressures. In general, a slurry pressure of 30 to 50 pounds per square inch (psi) is maintained during beam installation. 3.3 CONSTRUCTION SCHEDULE AND TECHNIQUES 3.3.1 Timing Construction will begin when the permitting process is complete. The anticipated start date would be Oct 2002. ction will take approximately 30 days to complete. The in -water work period for this reach of the Duwamish River is October 15 to March 15 (Clark 2002). Adult salmonids are entering the river and migrating upstream between July 15 to October 15 and in -water work is prohibited during this time. Juvenile salmonids rear in the estuary year -round and are likely to be present near the project site at any time of the year. The project does not require any work in the river, however underwater noise from the project may be detectable in Slip 6 and in the immediate vicinity of the project site in the Duwamish River. See Section 7.0 for further discussion. Construction during the fish window (October 15 to March 15) would also be outside the nesting period for bald eagles, which is from January 1 to August 15 (USFWS 2002). However, there are no bald eagle nests within several miles of the project site (WDFW 2002). Wintering activities occur from October 31' through March 31 The project could possibly be constructed during this time frame when wintering eagles would be expected to be present. However, there are no known roost sites in the vicinity of the project area (WDFW 2002). 33.2 Construction Methods and Implementation Personnel, materials, and equipment will be mobilized to the site according to the project schedule and sequence of construction activities. Site:preparation will include the siting of temporary facilities, utilities, access routes, work and decontamination zones, and staging and storage areas. Site security will be established during mobilization and maintained for the duration of the construction activities. This would include installation of temporary fencing, barriers, and signs to mark work areas and prevent access by non- workers. Staging and storage areas for heavy construction and slurry mixing equipment, materials, and supplies will be designated at the site. Local horizontal and vertical controls will be established at the site by a registered land surveyor. Survey control points and station/grade stakes will be established along the alignment of proposed construction and protected through the construction period. At the completion of construction, the location of permanent construction features, including the barrier wall, groundwater recovery and monitoring wells, and new I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP■Engineering Rcport\Draft Engineering Report\Appendix- Biological Assessment.doc 5 URS CORPORATION utilities will be documented. The following earthwork activities are expected during construction of the remedy: Installation of temporary erosion and sediment control (TESC) features and maintenance for the duration of work activities; surface grading for storm water drainage and control, and pad preparation for the installation of the barrier wall and groundwater recovery system; pre - trenching and subsurface exploration for open rock, porous gravel, buried utilities and obstacles along the proposed alignment of the barrier wall; temporary berms and surface barriers to prevent slurry spills to the adjacent waterway or existing storm water controls at the site; slurry wall trenching and installation of the barrier system(s); drill cuttings from groundwater recovery and monitoring well construction; soil relocation, spoils or unsuitable material handling, and imported materials for new construction. Surface grading will be required to prepare a pad for the groundwater treatment system's surface equipment and adjust grades along the barrier wall alignment. Regrading and compaction of the existing ground surface is expected to provide a suitable work pad for the trenching and barrier wall installation. Construction of engineered work pads along the barrier wall is not anticipated. Work along the Duwamish Waterway and Slip No. 6 will include suitable setbacks for TESC installation and protection of the shoreline from equipment weight- or vibration - induced settlement or slope failure. 33.3 Barrier Wall Installation Pre- trenching of the barrier wall alignment will be conducted to a depth of =5 to ?A feet below existing grade. This work will: 1). Identify areas of the barrier wall alignment containing open rock or porous gravel that would pose a problem for slurry loss or control, 2). Locate subsurface utilities or structures that are not identified in historic records and utility locates, and 3). Identify other subsurface obstacles or conditions that could interfere with installation of the barrier wall. Portions of an existing berm along the shoreline of the Duwamish Waterway and Slip 6 will be removed. The barrier wall system is the key component of the proposed remedy's hydraulic control measures. A low - permeability subsurface barrier will surround the contaminated areas of the site. The barrier wall will be installed between 25 and 50 feet from the adjacent water bodies. The wall will not extend to the water's edge. The contaminated sediments outside the perimeter of the barrier wall within the 25 to 50 feet between the water and the wall will not be capped off. The wall is expected to be 70 to 80 feet deep and the depth of Slip 6 and the Duwamish is roughly 15 feet. The barrier wall will be installed in two sections along the site (Appendix A, Figure 3): • A vertical wall constructed using the vibrated beam method will be used along the Duwamish Waterway (the western boundary of the site) and Pier No. 6 (the southern boundary of the site). • A vertical wall constructed using a conventional, trenched soil/bentonite barrier will be used along the east and north boundary of the site. The first section (Section 1) lies along the south and west boundaries of the site and will be constructed using Impermix barrier material. Vibrating -beam technology shall be used to install this section of the wall (see Section 3.2 for additional information). The minimum thickness of the wall in this section is 6- inches. The I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc SitalMWP\Engineering Report \Draft Engineering Report\Appendix- Biological Assessment.doc 6 URS CORPORATION length of the first section is 1460 feet and it shall be keyed a minimum of two feet into the upper aquitard. The barrier wall will be constructed to a maximum depth of 85 feet and an average depth of 75 feet. The installed Impermix barrier wall shall have a hydraulic conductivity of no more than 1x10" cm/sec and a minimum 28-day strength of 200 pounds per square inch (psi). Quality Control for the Impermix barrier wall installation shall be in conformance with the manufacturer's recommendations. The second section of the barrier wall (Section 2) is also shown on Figure 3 and extends along the north and east portions of the site. This section shall be constructed using slurry trench techniques and soil - bentonite backfill. The length of the second section is 1200 feet and it shall be keyed a minimum of two feet into the upper aquitard. The barrier wall will be constructed to a maximum depth of 85 feet and an average depth of 75 feet in this section of the wall. The minimum width of the trench shall be 3 feet. The installed soil - bentonite barrier wall shall have a hydraulic conductivity of no more than 2x10 cm/sec. The completed wall will be continuous, with no gaps. Where the vibrated beam wall intersects the soil/bentonite barrier, the Impermix slurry will extent into, and along the alignment of, the soil/bentonite wall to form a sealed transition between the two barrier systems. A protective cap will be constructed over the barrier wall after curing has occurred. The cap is intended to prevent dehydration of the bather wall's backfill and to handle traffic loads from equipment and vehicles. 3.3.4 Barrier Wall Contingencies A number of factors can impact the barrier wall construction, and have been considered in the design approach. Some specific factors that may require corrective action during wall construction are listed below: • Low Fine Content in Excavated Soil —If actual site conditions differ from design assumptions, the soil available for use in the trench backfill for the soil/bentonite wall may require amendments (addition of fine graded soil from offsite sources), replacement with imported fill, or increased bentonite content in the slurry mix. • Backfill Moisture Content— Excessively moist soil could result in too much slump of the soil/bentonite slurry, requiring addition of dry soil from other portions of the site or use of imported fill. • Heavy Precipitation —Heavy precipitation, as rain or snow, could affect the characteristics of the bentonite or Impermix slurry in the mixing area or the open trench section. Addition of dry bentonite at the mixer or trench may be required to maintain the specified slurry characteristics. • Hydraulically Connected Voids —Open rock or. porous gravel in the subsurface could allow the trench slurry to reach the adjacent shoreline or waterway. Corrective actions may require temporary filling of the trench with sand to plug the void(s); installation of a silt curtain in the waterway; or modification of the slurry to enhance plugging/filling of the hydraulically connected voids. • Trench Collapse— Frequent observations of the trench will be performed to detect any indications of trench instability, i.e., setdowns and tension cracks within 35 feet of the bather wall alignment. Corrective measures may include raising the slurry level in the trench, increasing the slurry density, or both. Should collapse occur, the bather wall will be re- excavated to a stable portion of the barrier I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site \IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 7 URS CORPORATION �ca�M- �m:•rci nw+arr.�xo�.,.c.:�:u ,....Rkm tcre.G:.- :r g): alignment and corrective actions investigated for the failed trench section. 3.3.5 Groundwater Recovery System The groundwater recovery system is intended to maintain an inward (to the site) hydraulic gradient in the shallow groundwater. The proposed system includes groundwater recovery wells, piping, a water storage facility, and batch discharge to either the local sewer system or an approved offsite disposal facility. A brief description of the groundwater recovery system follows. Three 6 -inch diameter, PVC groundwater extraction wells, with low -flow, variable rate extraction pumps, will be constructed on the inside (land -ward) of the barrier wall system. The extraction pumps in each well will be operated using a pump controller that maintains a pre -set pressure differential (an elevation head difference of 1 foot of water). This differential is measured by pressure transducers located within a monitoring well on the inside of the barrier and a single monitoring well located outside (shoreward) of the barrier wall. As tidally driven changes occur in the shoreward well, the interior extraction wells are automatically run to maintain the pre-set pressure differential. Groundwater extracted from the three groundwater recovery wells will be piped to a central storage tank ', al p' cr,), where accumulated water will be periodically tested and characterized for disposal. The tank will be operated in batch mode, allowing manual diversion of its contents to either an on -site discharge point or loading and transportation for offsite treatment and disposal. No active on -site treatment of the containerized water will occur prior to discharge. Discharges from the groundwater recovery system will occur on a batch mode, based on analytical testing and characterization of the storage tank contents. If the tank contents meet the maximum concentration limits for a sewer discharge under a King County Industrial Waste Program discharge permit, the accumulated water will be transferred to an adjacent sewer line. If the tank contents exceed the limits for sewer discharge, the accumulated water will be transferred to a tanker truck for offsite transportation and disposal. 3.3.6 Maintenance and Monitoring New groundwater monitoring wells will be constructed at the site prior to bather wall installation (pre- construction monitoring and long -term performance monitoring) and after barrier wall installation (long -term performance monitoring). A number of existing monitoring wells located in or adjacent to the barrier wall alignment will be abandoned prior to the barrier wall's construction. Additional wells will be abandoned following construction of the barrier wall and groundwater recovery system. 3.3.7 Site Restoration Site restoration will include the following: Repair_ and replacement of concrete and asphalt surfaces disturbed by construction activities; Filling, regrading, or repair of heavily rutted or scarred surface soil to pre - construction conditions or better, Inspection of catchbasins, manholes, and permanent storm water controls at the site, and the removal and disposal of any accumulated solids; Final grading and stabilization of surface areas disturbed by construction, include mulching, hydroseeding, or other protective measures to prevent erosion and sedimentation; (revegetation of the site will not be performed); Temporary protective actions for existing work will be removed and relocated surface equipment, materials, or other features returned to their I:\Projects \WCIA\02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 8 URS CORPORATION f original location. 3.3.8 Best Management Practices The TESC features for this project will be in accordance with Appendix D of King County's Surface Water Design Manual. Potential control elements may include silt fences, straw bales and check dams, stabilized = ~ construction entrances, mulch application, and hydroseeding. Dust control measures will be required during w general site preparation and barrier wall construction. Dust monitoring will be performed during 6 v construction, using portable instrumentation such as a Miniram Model PD -3 aerosol monitor. If dust levels U o exceed action limits specified in the Health and Safety Plan dust controls will implemented. These actions w tu may include termination of dust - generating work during high wind periods; pre- wetting of roadways and —t H work areas before daily work begins; and modifying excavation, demolition/removal, or slurry mixing w O operations to reduce dust levels. Dust suppression techniques, including water application, will be used as necessary to control the spread of dust from active work areas. Water use will be minimized or eliminated if g Q it poses a hazardous or objectionable condition. to d Temporary soil berms will be used at various locations during construction to protect and divert storm water Z or slurry mixes away from existing features such as catchbasins and along the alignment of the barrier wall. F- O Temporary berms will be constructed on each side, and up to 20 feet from the centerline, of the barrier wall w w during active trenching and slurry installation. As the wall installation progresses, new berm sections will be o constructed and unnecessary berms will be removed or graded for subsequent construction of the protective 0 to cap. TESC features will installed and maintained for the duration of work activities. Lt.! i Spill containment structures for bulk fuel or chemical storage will be constructed with nominal 20-mil linters _ - H and perimeter berms. Temporary waste accumulation areas will be constructed as needed. Two types of u' Z storage are anticipated: 1). Interim storage areas will be used for the accumulation of lightly- contaminated U to soil, excavation spoils, or debris. Existing paved surfaces in good condition may be used for direct storage; 1= damaged pavement or non -paved areas will be lined with a minimum of 6 -mil polyethylene sheeting before Z placing wastes on them. 2). Waste storage areas used for containerized hazardous and non - hazardous waste solids and liquids will be constructed with nominal 20 -mil liners and perimeter berms; alternatively, wastes may be accumulated in covered bulk storage containers or connexes. Containerized wastes will not be held on the site for longer than 90 days from the "out of service" date (i.e., when wastes are first placed in the drum or container). Decontamination stations for personnel and equipment will be set up within the contamination reduction zone established for each construction area or activity. An equipment decontamination facility will be constructed at the site. All equipment and vehicles that enter the exclusion zone or come into contact with wastes will be cleaned prior to exiting the work zone. 4.0 ACTION AREA The action area includes the project site, Slip 6, the Duwamish River adjacent to the construction site, and extends for a 0.5 mile radius around the project site. This action area encompasses the areas directly impacted by construction, as well as areas potentially impacted from construction (Appendix A, Figure 4). 1:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site \IMWP\Engineering Report \Draft Engineering Report\Appendix- Biological Assessment.doc 9 URS CORPORATION 3:efr. iLp�S+t V.. lrW. JT a' dv1�YbT .�7xsi iF"\ 5.1 THE DUWAMISH RIVER ESTUARY The lower eleven -mile segment of the Duwamish/Green River system from Tukwila to Elliott Bay is known as the Duwamish River (WDFW et al. 1994). The Duwamish River is that portion of the Green River downstream of the historic confluence with the Black River (RM 0.0 to 11.0) (WCC 2000). Tidal influences are observed upstream to about the mouth of the Black River in the city of Tukwila. These last 11 miles of the system are a brackish estuarine environment also called the Duwamish estuary. The Duwamish is considered "vital to salmon as a transition area for adaption of migrant to salinity changes" (Williams et al. 1975). The last 4.6 miles of the estuary are located within the city of Seattle. The rest of the river, upstream from Tukwila beginning at RM 11.0, is known as the Green River (WDFW et al. 1994). The Green/Duwamish River watershed begins in the Cascade Mountains about 30 miles northeast of Mount Rainier and flows for over 93 miles to Puget Sound at Elliott Bay. Over the past century the river has been drastically altered. Water diversions and channelization have reduced habitat and increased summer temperatures resulting in adverse habitat conditions. One hundred fifty years ago, the White, Green, and Cedar (via the Black) Rivers flowed into the Duwamish River, and the system drained an area of over 1,600 square miles. Approximately 1200 miles of river have been diverted to the north and south. The diversion of the White River in 1911 and the Cedar River in 1916 (which left the Black River essentially dry) reduced the Green/Duwamish drainage area to 483 square miles (Weitkamp et al. 2000). Far upstream, two dams were built on the Duwamish/Green River, both of which are complete passage barriers to upstream and downstream fish migration. Anadromous fish access to the upper reaches of the Green/Duwamish River has been blocked at RM 61 since 1911 with the construction of the Tacoma Diversion Dam and again upstream at the Howard Hanson Dam (RM 64). The Duwamish River delta was historically wide meanders, mud flats, and wetlands that provided nursery habitat for all kinds of wildlife. Tides flooded 5,300 acres of wetlands. Today, it is has been dredged, straightened, shortened, diverted, filled, paved, and heavily urbanized resulting in the elimination of 98 percent of the delta's original estuarine marsh and mudflat habitats. All (100 percent) of the forested riparian tidal swamps bordering the Duwamish were filled by 1940 (WCC 2002). The last 10 miles were straightened, deepened, and shortened to form a 6 -mile long shipping canal. The last 5.3 miles of the Duwamish are dredged for navigation and contain deep water habitats where none previously existed (Warner and Fritz 1995). The lower area has been developed for water dependent commerce and heavy industry. The remaining shortened channel has been simplified and contaminated with polluted sediments from industrial activities on the banks. The Port of Seattle operates a series of terminal facilities at the mouth of the river. Despite these alterations, the Duwamish still supports every species of anadromous salmonid that are native to the west coast of North America (chinook, coho, chum, sockeye, and pink salmon, coastal cutthroat trout, steelhead, bull trout, and dolly varden), including one non - native (Atlantic salmon). Currently, all salmonid species migrate, rear, and acclimate in the lower 6 -mile transitional area between river and marine waters. I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 10 URS CORPORATION 5.0 EXISTING ENVIRONMENTAL CONDITIONS 1 5.2 SITE CONTAMINATION The project site is located in the lower Duwamish River at approximately RM 5.5. This section of the Duwamish River was listed by the EPA as a federal Superfund site on September 16, 2001. More than 100 Z years of dumping industrial toxic chemicals, sewage, and stormwater caused the pollution. In 1998, King = H County found that fish and crab caught in the Duwamish River have up to seven times more cancer causing W chemicals in them than those from clean sites (DRCC 2002). Polychlorinated Biphenyls (PCBs) are found in 6 = nearly all salmon in the river. Within the carcinogens studied, PCB levels were found up to 20 times higher 0 0 in Duwamish River fish than in fish from clean areas in Puget Sound. In 1999, the EPA conducted a site c w investigation to determine the extent of contamination in the Duwamish River. The results showed toxic - 1- pollution levels so high the river was listed as a Superfund site (DRCC 2002). Pollution that has been found w w p in the river includes industrial carcinogens like PCB's, oil and other hydrocarbons, mercury, lead, and other 2 heavy metals, pesticides, arsenic, and even raw sewage. Sediments at the river bottom exceed state standards g Q for heavy metals like mercury by up to 400 percent. One hundred percent of all sediment samples contained to d trace levels of lead. Pockets of arsenic in the sediments exceed state standards by more than 1,000 percent. H w Seven sewer /stormwater outfalls dump over 600 million gallons of untreated sewage and stormwater into the ? I— river each year. The contamination becomes more widespread as the toxins bioaccumulate through the food z O chain. Orcas, eagles, and even humans consume the contaminated fish and shellfish. g 0 The project site is about 21.5 acres, 19.5 of which are on -shore and 2 acres of which are offshore intertidal 0 N areas in the Duwamish Waterway (see Appendix B, Site Photos). The property is partially paved with a few 0 (— buildings and surrounded by fencing and secured gates. The property is flat except near the intertidal areas = U adjacent to Slip 6 and the Duwamish Waterway, where it slopes at moderate grades to the water. The depth LI O of Slip 6 is approximately 16 feet (Port of Seattle 2002) and the shorelines are heavily rip rapped. The depth of the Duwamish Waterway adjacent to Slip 6 is between 13 to 15 feet (USAGE, 2002). P The site is a former industrial facility purchased by Container Properties L.L.0 from Rhone- Poulenc. The Z facility produced vanillin and was closed in 1991. Past process activities at the site introduced contaminants to the soils and groundwater. Primary contaminants included toluene and dissolved metals (primarily copper, arsenic, and chromium). Copper has been identified in the south and west sides of the site at levels exceeding 6800 mg/kg. Toluene has been identified in central portions of the site, but has not been found at high concentrations along the proposed barrier wall alignment. The maximum measured groundwater pH in the area the southwest corner of the barrier wall alignment is near 12. Excavated materials must be managed as hazardous waste. There are currently no manufacturing activities at the site. A small soil vapor extraction and emission control system is presently active at the site. At the time the facility closed, process equipment, most of the tanks, and several buildings were dismantled or removed. Northwest Container Services is currently leasing the facility and using it as a shipping center for its ocean -going containers. 6.0 SPECIES AND HABITAT INFORMATION 6.1 SITE SPECIFIC INFORMATION As part of agency consultation, the NMFS, USFWS, Washington Department of Natural Resources 1:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\IINWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 11 URS CORPORATION ne�u evvro.Y+t r.Ftiarw�:t 'iB'.T �g.:1sYFlX '++ CX W E 4W (WDNR), and WDFW were contacted to obtain records of special status species in the vicinity of the site area. Section 11 of this report documents the consultation history and Appendix C contains the reply letters that accompanied the requested information. The provided information was used to develop the list in Section 6.2 of endangered, threatened, proposed, and candidate species with the potential to occur in the vicinity of the proposed project. 6.2 SPECIES PRESENT Managed fish species that utilize the Duwamish River and Duwamish Waterway for various stages of their life history include: fall chinook salmon (Oncorhynchus tshawytscha), coho salmon (0. kisutch), chum salmon (0. keta), sockeye salmon (0. nerka), winter- and summer -run steelhead (0. mykiss), resident and sea -run coastal cutthroat trout (0. clarki clarki), bull trout (Salmo confluentus), and Dolly Varden (S. malma) (WDFW 2002). Pink salmon (0. gorbuscha) apparently occurred historically in the Green/Duwamish River system (Hard et. al. 1996). The highest annual number of adult pink salmon observed in the Green River over the last several decades is 13 (Hard et. al. 1996). Juvenile chinook, chum, and pink salmon are most dependent on the transitional estuarine habitat (WCC 2002). Other wildlife documented in the lower Duwamish includes osprey, Great blue herons, sandpipers, eagles, peregrine falcons, river otters, and foraging sea lions. There is an osprey nest just south of the project and within 0.5 mile of the project site. The osprey is not federally listed. Bottom - dwellers such as clams, mussels, Dungeness crab, English sole, and rockfish are common, in addition to schools of herring near piers and pilings. California sea lions have swam up the Duwamish and been documented in the project area around Boeing Field ( Garren 2002). California sea lions have been known to forage up rivers and typically stay a few weeks at a time. One California sea lion was documented 125 miles up the Willamette River in Oregon, and another 140 miles upstream in the Columbia River above Bonneville Dam (Garren 2002). California sea lions are not listed under the ESA. A search for rare plants or high quality ecosystems in the vicinity of the project was conducted through the WDNR Natural Heritage Information System. Currently, no records were found in the vicinity of the project. The nearest species of interest is the Oregon floater ( ?;?41), which has no state or federal status. It is at least 0.75 mile outside the project area at the north end of Boeing Field. Requests were sent to both NMFS and USFWS for a list of species likely to occur in the vicinity of the project area. The species list received from the USFWS identified the bald eagle (Haliaeetus leucocephalus) as being near the project area eis bovpelican ?). The species list obtained from the NMFS identified Puget Sound chinook salmon in addition to the Steller sea lion (Eumetopias jubatus) and humpback whale (Megaptera novaeangliae), but acknowledged that the marine mammals were unlikely in the project area. However, they could be present in Elliott Bay. The leatherback sea turtle (Dermochelys coriacea) is the other ESA listed marine species under NMFS jurisdiction with the potential to be in the marine waters of Elliott Bay. Information for this BA was gathered from several sources including recent literature, WDFW priority habitat I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 12 URS CORPORATION 1 z ~ w tr l 00 CO 0 I J = 1 w i cn I" w i ~_ z1._ l-o z I- LL! w U O o22 OH w w F- IL 8 H .. z 1 022 ` O z and species data, NMFS, USFWS, WDNR, and local agency biologists. A URS biologist surveyed the project site on June 16, 2002. ESA LISTED SPECIES THAT MAY OCCUR IN OR NEAR THE VICINITY OF THE PROJECT • ESA Listed: • ESA Proposed: Dolly Varden - Washington State - Threatened • ESA Candidate: Coho Salmon -Puget Sound/Straight of Georgia ESU • Essential Fish Habitat Species: Chinook Salmon- Duwamish River HUC Coho Salmon- Duwamish River HUC 6.3 SPECIES UTILIZATION Bald Eagle- Threatened Bull Trout - Coastal -Puget Sound DPS- Threatened Chinook Salmon -Puget Sound ESU- Threatened Steller sea lion - Threatened Humpback whale- Endangered , Leatherback sea turtle-Endangered 6.3.1 Bald Eagle Status: The bald eagle is listed as threatened by the USFWS and by Washington State (March 26, 1967). The USFWS proposed the removal of the bald eagle in the lower 48 states from the list of Endangered and Threatened Wildlife on July 6, 1999. Background Information: In western Washington, winter migrants and breeding bald eagles are found near seacoasts, rivers, and lakes (Rodrick and Milner 1991) (Smith et al. 1997). Bald eagles are often observed perching on large trees and snags along rivers and streams where they forage on fish, waterfowl, small mammals, and carrion. Threats to bald eagles include the loss of or human disturbance of nesting trees, loss of waterside habitat, shooting, and food contamination, especially by pesticides (USFWS 1986). Populations in the Proposed Project Area: There are no documented bald eagle nests or roost sites in the vicinity of the project (WDFW 2002, USFWS 2002). The nearest nest site is located approximately 3.5 miles to the east at Seward Park. Another nest is located approximately 4 miles downstream near Harbor Island (WDFW 2002). No roost sites were identified by either agency as being present in or near the project site. 6.3.2 Bull Trout/Dolly Varden Status: The Coastal -Puget Sound DPS of bull trout from the coastal drainages and Puget Sound in Western Washington was listed as threatened by the USFWS on November 1, 1999. On January 9, 2001, the USFWS proposed to list Dolly Varden in Washington State as threatened under the "Similarity of Appearance" I:\Projects \WCIA\02\53 -01000496 RCI Former Rhone Poulenc Site \IMWP\Engineering Report\Draft Engineering ReporAAppendix- Biological Assessment.doc 13 URS CORPORATION z _� w 6 0 n WI ° 2 g Q w z I w� ui U 0— co CI H. Ill I - u. O w z U= O ~ . Z _ 011111111: irgOittt 11 Ylatt ea/10: provisions of the ESA (Federal Register 2001). In the November 1, 1999, listing of the Coastal -Puget Sound DPS as threatened, the USFWS found that the designation of critical habitat is not determinable for bull trout in the coterminous United States, based on the best available information. Within 2 years of the publication date of the original proposed rule (June 10, 1998), the USFWS must designate critical habitat, unless the designation is found to be not prudent. The USFWS did not receive any new information during the open comment period regarding specific physical and biological features essential for bull trout. Until the designation of critical habitat is determinable, the USFWS will protect bull trout habitat through the recovery process and through Section 7 consultations ( USFWS 1998a). Appendix E contains a USFWS Matrix for Documentation of Effects on bull trout. Background Information: Anadromous (sea -run), fluvial (living in mainstem streams), lacustrine (lake - dwelling), and stream resident (living in tributary streams) populations of bull trout/Dolly Varden are found in coastal drainages from the Chehalis River to the Canadian border (WDFW 1992b and WDFW 1998). Bull trout and Dolly Varden are difficult to distinguish in the field and are managed as a single species (native char) by the Washington Department of Fish and Wildlife (WDFW 1992b and WDFW 1995). Threats to bull trout include land or water management activities that degrade stream habitat, such as urbanization, industrial development, forest management practices, livestock grazing, agriculture and agriculture diversions, roads, and mining (McIntosh et al. 1994 and Wismar et al. 1994). Migratory corridors used by bull trout are affected or threatened by flood control structures, dams, and water diversions. Eight subpopulations in this DPS are currently known to be isolated or fragmented as a result of man-made barriers. The native char (bull trout/Dolly Varden) in the North Puget Sound Distinct Population Segment spawn in the headwaters of mountain streams. Char spawning occurs upstream of areas used by most other anadromous fishes. For successful spawning and egg incubation the fish require very cold water with spawning occurring in the fall of the year as the water temperature drops below 48° F. The successful incubation of the eggs requires temperatures below 42° F. In this region, the downstream limit of successful char spawning is nearly always upstream of the winter snow line (that elevation at which snow is present on the ground for much of the winter) (Kramer 1999). Spawning generally occurs from late September to early November. The exact timing of the each year's spawning can vary depending on water temperatures. Adults avoid temperatures over 59° F and 64-68° F is lethal. Strict cold water temperature requirements make bull trout vulnerable to activities that warm spawning and rearing waters. Bull trout fry remain in the intragravel environment for an extended time between hatching and emerging from the gravel. Their juvenile life phase is also closely associated with the stream bottom and the intragravel environment. This extended relationship with the intragravel environment may be a major reason why bull trout populations are suppressed in unstable stream channels or substrates with a high percentage of fine sediments. The foraging juvenile and sub adult char may migrate throughout the basin looking for feeding opportunities even following prey species up tributary streams. Because of this behavior, they may be found anywhere in I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 14 URS CORPORATION e ref. r .1 I • the basin downstream of spawning areas (Rieman 1997). The potential distribution of the foraging char can be defined as that portion of the basin that is accessible to anadromous salmonids. If coho salmon juveniles are found in an area then it is likely that foraging char may be present (Kramer 1999). Populations in the Proposed Project Area: The USFWS lists the Green River as one of eight river basins in the Puget Sound that contain a subpopulation of the Coastal -Puget Sound Bull Trout DPS (USFWS 1998b). Mongillo (1993) indicated that native char are "present" in the Green River below Howard Hanson Dam. Native char have been harvested in the Green River as far upstream as RM 64 (Howard Hanson Dam); however, there is insufficient evidence to determine if these fish are fluvial, or anadromous bull trout (Watson and Toth 1995). A historical account reported that native char were abundant in the Duwamish and other rivers emptying into Puget Sound during the fall and early winter (Suckley and Cooper 1860). These were likely either spawning or foraging runs of anadromous bull trout/Dolly Varden. However, no spawning of native char has ever been documented in the Green River basin (Watson and Toth 1995). Since the early 1940s native char in the Green River have been rarely observed (USFWS 1999, WDFW 1998). Creel counts on the Green River indicate native char are extremely rare, with only four char taken by over 35,500 anglers checked between 1940 and 1973 ( USFWS 1998a). A single native char was reported captured at the Soos Creek Hatchery rack above RM 33 (Beak 1996). Another native char was captured at RM 2.1 during a study conducted by the Port of Seattle (Weitkamp and Schadt 1982). An adult bull trout was captured by the Muckleshoot Indian Tribal Fisheries Department Staff at approximately RM 5 . in 1994 and identified by genetic analysis by the University of Washington (Kerwin and Nelson 2000). A native char was caught in May 1994 in the Duwamish River that was positively identified as a bull trout both by meristic characteristics and genetic analysis (USFWS 1998a). Eight native char were caught in the Duwamish turning basin during a recent survey by Taylor and Associates (Mavros 2002). Two of these fish were genetically identified as bull trout (Mavros 2002). Surveys of Puget Sound nearshore areas and estuaries in the last 3-4 years have found anadromous native char to be more common than previously believed in the nearshore marine and estuarine environment of Puget Sound. A survey of inner Shilshole Bay produced 7 native char and 40 sea -run cutthroat trout (Warner 2000). Additional native char were captured near Golden Gardens Park north of Shilshole Bay and Salmon Bay (Mavros 2002). Genetic samples were taken from most of these fish and all of them have been identified as bull trout (Mavros 2002 and Young 2001). Most of the fish captured in the Green Duwamish River have been captured within the range of tidal influence where a wedge of salt water provides cool temperatures for bull trout. It is highly unlikely that any spawning areas below Howard Hanson Dam provide a temperature regime suitable for successful bull trout reproduction. Suitable spawning areas for fluvial and anadromous native char in the Green River below RM 64 may have once existed prior to the construction of the City of Tacoma's municipal water diversion, which has been an anadromous fish barrier since 1911. If a spawning population of native char spawned in headwater tributaries with sufficient snowmelt runoff to allow successful reproduction, this population would have been isolated as a resident population by the Tacoma diversion dam. The lack of a documented spawning population of native char above Howard Hanson Dam 1:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\LMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 15 URS CORPORATION am Weiat oweri3: • .................. .._ ^'^.••∎= " "°.""ma""`m'_.�"rt"...r.�,e ,..,20,VTI«.cm. could be attributed to debris torrents associated with timber harvest and railroad construction activities destroying native char spawning areas and creating barriers to migration, timber harvest related increases in water temperature creating unsuitable rearing habitat, or thermal barriers to migration from Eagle Gorge Reservoir, or incorrect timing of bull trout surveys (Malcom 2000). It is also possible that a spawning population of bull trout/Dolly Varden never existed in the headwaters of the Green River. The large population of Green River native char documented in the 1800s by Suckley and Cooper (1860) may have been composed entirely of char that spawned in the headwaters of the White River. The only other spawning population of char that historically occurred in the Green River basin is the Cedar River population above Cedar Falls, a relict lacustrine population of bull trout isolated above a water fall in the headwaters of the Cedar River, which drained into the Green River by way of the Black River before the it was diverted into the Lake Washington after the opening of the Montlake Ship Canal. All native char from the White, Green, and Cedar River basins that have been genetically analyzed have been identified as bull trout. Both the White and Cedar River populations still exist as spawning populations; however, the White River native char population has probably been significantly impacted by water diversion and flood control dams. The status of the White River population is unknown, but probably consists of anadromous, fluvial, and possibly resident populations of native char that spawn in tributaries of the White River above Mud Mountain dam. The reports of bull trout/Dolly Varden harvested in the Green River after the construction of the City of Tacoma's municipal water diversion may refer to anadromous fish that have strayed into the Green, but were produced in a different river basin (WDFW 1998). It is apparent from recent captures of bull trout during studies of the marine nearshore and estuarine environment of Puget Sound (including the Duwamish River estuary), that anadromous bull trout from relatively healthy populations in the Skagit, Stillaguamish, and Snohomish River basins and other Puget Sound river basins form a metapopulation that rears and forages in Puget Sound's nearshore and estuarine habitat. These fish may utilize stream basins, such as the Green River, which have no known available spawning habitat as foraging habitat. Until enough genetic information is gathered from native char at their spawning grounds, it will not be possible to determine if fish captured in the Duwamish/Green River basin are foraging or stray fish from other stream basins. The USFWS considers the Green River subpopulation of bull trout "depressed" (USFWS 1998b and USFWS 1999). The WDFW regards the stock status for the Green River stocks of native char as "unknown" with insufficient information to assign status with confidence. 6.3.3 Chinook Salmon Status: Under the Magnuson- Stevens Act, the Duwamish River USGS Hydrologic Unit (HUC 17110013) was listed as chinook salmon EFH. The Puget Sound population segment of chinook salmon from the Puget Sound drainages in western Washington were listed as threatened by the NMFS on March 24, 1999. Critical habitat was designated on February 16, 2000 (NMFS 2000a). Background Information: Spawning adults are found in most of the larger streams of the upper and lower Columbia River basin, Washington coastal basins, and Puget Sound basins (Wydoski and Whitney 1979). Threats to chinook salmon include land or water management activities that degrade stream habitat, such as urbanization, industrial development, forest management practices, livestock grazing, agriculture and I:\Projects \WCIA\02\53 -01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 16 URS CORPORATION agriculture diversions, roads, and mining (McIntosh et al. 1994 and Wissmar et al. 1994). Migratory corridors used by chinook salmon are threatened by flood control structures, dams, and water diversions. Outbreaks of diseases affecting salmonids introduced by exotic species and hatchery fish are a threat to chinook salmon stocks. Competition and hybridization with hatchery fish are potential threats to some chinook salmon ESUs. Commercial and sport harvest of large hatchery runs can be a threat to small or depleted natural runs. Adult chinook salmon, especially spring chinook, require deep pools within reasonable proximity to spawning areas where they can hold and mature for several months between migration and spawning. Populations in the proposed project area: Chinook salmon in the Duwamish/Green River basin originated from both native and hatchery fish (WDFW et al. 1994). However, the hatchery stock of chinook salmon is currently believed to have descended from the wild run (Grette and Salo 1986). Green River chinook are a summer /fall stock that migrate upstream through the Duwamish River to spawning grounds in the Green River from late June to October, with large numbers entering the river by July (Williams et al. 1975, Frissell et al. 2000, and Kerwin and Nelson 2000). Adults spawn in the fall, with spawning occurring between mid - September and October (WDFW et al. 1994 and Williams et al. 1975). The Duwamish River in the vicinity of the project area is used primarily as a migration and rearing area. Summer /fall chinook in the Duwamish/Green River basin are ocean type fish that rear in freshwater a few months after emerging from the gravel, before migrating to the ocean in the spring as sub - yearling smolts. Chinook juveniles occur in the Duwamish estuary from early April through late July (Meyers et al. 1980) with a peak in late May. Juveniles are known to use both shallow and deep -water habitat in the Duwamish estuary. Chinook salmon fry prefer protected estuarine habitats with low salinity. In contrast, larger chinook salmon fingerlings and smolts (ocean- or stream -type) immediately take up residence in deeper - water estuarine habitats upon emigrating from freshwater (Everest and Chapman 1972; Healey 1991). Preferred habitat such as emergent marshes and intertidal mudflats have been reduced by 98 percent. As a result, juvenile salmonids have less food available and are more exposed to predators. Juvenile chinook use side channels for feeding and resting, while undergoing physiological changes to salt water. In the Duwamish from Boeing Field to Elliott Bay, the riverbanks have been straightened and simplified. Fish use is higher in areas such as Kellogg Island, where remnant intertidal shallows are available. Kellogg Island was formed by extensive fill placements, but includes remnants of two historical channels and has a densely vegetated riparian zone and intertidal wetlands. These represent a majority of the remaining intertidal wetlands in the Duwamish estuary (Simenstad et al. 1991). It is located about 0.5 mile south of Harbor Island. In the Duwamish River, below RM 11, water quality is the most serious limiting factor, with borderline dissolved oxygen levels during August and September when adult spawners are migrating through the river. Industrial wastes, domestic sewage, and a saltwater wedge contribute to the critical oxygen condition (Williams et al. 1975). Other contributing factors are flood control measures, silt deposits, industrial and urban development, and stormwater runoff from increased impervious surface area. Puget Sound chinook salmon remain relatively abundant because much of the production is from hatcheries. Although natural production of chinook salmon is masked by hatchery returns, the overall trend in I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 17 URS CORPORATION abundance of Puget Sound chinook salmon is predominantly downward. However, the Duwamish/Green River has not experienced the same decline in naturally spawning fish as has occurred in other streams in Puget Sound. The WDFW divides Green River chinook salmon into two stocks, the Duwamish/Green River summer /fall stock and the Duwamish/Green River- Newaukum Creek summer /fall stock. The Newaukum fish spawn in Newaukum Creek, a tributary of the Green River. The Duwamish/Green River stock includes all other chinook salmon in the Green River basin. Both stocks were considered healthy (WDFW et al. 1994). 6.3.4 Coho Salmon Status: Under the Magnuson- Stevens Act, the Duwamish USGS HUC 17110013 was listed as coho salmon EFH. The Puget Sound/Strait of Georgia population segment of coho salmon is a candidate for federal listing. Because the Puget Sound/Strait of Georgia ESU Coho Salmon ESU has not been proposed for listing under the ESA, no critical habitat has been identified. Background Information: Spawning adults are found in streams of the lower Columbia River basin, Washington coastal basins, and the Puget Sound basins (Wydoski and Whitney 1979). Threats to coho salmon include land or water management activities that degrade stream habitat, such as urbanization, industrial development, forest management practices, livestock grazing, agriculture and agriculture diversions, roads, and mining (McIntosh et al. 1994 and Wissmar et al. 1994). Migratory corridors used by (' coho salmon are threatened by flood control structures, dams, and water diversions. Outbreaks of diseases affecting salmonids introduced by exotic species and hatchery fish are a threat to coho salmon stocks as is poaching of spawning fish. Competition and hybridization with hatchery fish are potential threats to some coho salmon ESUs. Commercial and sport harvest of large hatchery runs can be a threat to small or depleted natural runs. Spawning and rearing of coho salmon occurs in small, low gradient (less than 3 percent) tributary streams. Populations in the Proposed Project Area: Coho salmon in the Green River basin migrate back to natal streams to spawn, entering freshwater from . mid- September to mid- November. Spawning occurs in late October to mid -January (WDFW et al. 1994). I Juvenile coho salmon in the Duwamish/Green River remain in fresh water for 1 year, rearing in side - channels and tributary streams. Coho outmigration to the estuary typically occurs between late April and early July. Coho smolts move rapidly through the lower river and estuary (Bostick 1955; Weitkamp and Campbell 1980). The amount of time juvenile coho salmon rear in estuaries appears to be highly variable, with more northern populations generally dwelling longer in estuaries than more southern populations (Simenstad et al. 1982, Tschaplinski 1982). Coho from the Oregon coast, Columbia River, and Puget Sound are thought to remain in estuarine areas for several days to several weeks, while many Britichs Columbia and Alaska populations remain in estuaries for several months (Myers and Horton 1982, �. Simenstad et al. 1982; Tschaplinski 1982; Levings et al. 1985). In estuaries, coho smolts occur in intertidal and pelagic habitats, with deep, marine influenced habitats often preferred (Dawley et al. 1986; MacDonald et al. 1987). Juvenile coho tend to use the shallow nearshore habitats less than other salmon species I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessmentdoc 18 URS CORPORATION i (Simenstad 1983). Coho generally spend two years in the ocean before beginning the spawning migration back to their natal streams. In the Green River, flooding conditions above the capacity of Howard Hanson Dam, low summer flows, and water quality are the principal limiting factors for coho salmon. The removal of stream cover in the lower valley, construction of dikes, and bank stabilization projects have changed the river profile and altered the channels (Williams et al. 1975). Other contributing factors are flood control measures, the diversion of the White River into the Puyallup River basin in 1906, silt deposits (particularly below RM 14), industrial and urban development, and stormwater runoff from increased impervious surface area. Most tributary streams in the project area also exhibit low summer flows, especially during August and September, when some go dry. In the Duwamish River, below RM 11, water quality is the most serious limiting factor with borderline dissolved oxygen levels during August and September when adult spawners are migrating through the river. Industrial wastes, domestic sewage, and a saltwater wedge contribute to the critical oxygen condition (Williams et al. 1975). Puget Sound coho salmon remain relatively abundant, and much of the production is from hatcheries. Natural production of coho salmon is masked by hatchery returns, with the overall trend in abundance in many streams predominantly downward. Virtually all accessible streams and tributaries draining into the Green - Duwamish basin are utilized by coho salmon (Williams et al. 1975). As with the chinook salmon, Green River coho salmon are divided into two stocks with the Newaukum Creek stock displaying a later spawning time than Green River /Soos Creek stock which are found throughout the remainder of the basin. The Newaukum Creek coho salmon stock is classified as "Depressed" because of a short-term severe decline in its escapement and the Green River /Soos Creek stock rated as "healthy" by the WDFW (WDFW et al. 1993). 6.3.5 Steller Sea Lion Status: On November 26, 1990, the Stellar sea lion was listed as threatened under the Endangered Species Act of 1973. In 1997, the species was split into two separate stocks on the basis of demographic and genetic dissimilarities; the status of the western stock (west of 144° longitude) was changed to endangered, and the status of the eastern stock (east of 144° longitude) was left unchanged (Bickam et al. 1996, Loughlin 1997). The proposed rule for establishment of critical habitat for the Steller sea lion was published on April 1, 1993, and the final rule was published on August 27, 1993. Background Information: The Steller sea lion is distributed around the North Pacific rim from the Channel Islands off southern California to northern Hokkaido, Japan. The species distribution extends northward into the Bering Sea and along the eastern shore of the Kamchatka Peninsula. The center of the distribution has been considered to be in the Gulf of Alaska and the Aleutian Islands. Within this distribution, land sites used by Steller sea lions are referred to as rookeries and haulout sites. Rookeries are used during the reproductive season (late May to early July) for mating, pupping, and nursing. Haulouts are generally not areas used for reproduction, but like rookeries they are areas used for protection from marine and terrestrial predators, protection from severe climate or sea surface conditions, and (perhaps most importantly) are near available prey resources. Haulout sites are found on jetties, offshore rocks, and I:\Projects \WCIA\02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessmentdoc 19 URS CORPORATION • coastal islands. Extensive declines of the Steller sea lion population have occurred within the Alaskan and the Russian portions of their range over the last 30 years. Counts in southeast Alaska, British Columbia, and Oregon have remained stable over the same period, and numbers in California have declined. The areas designated as critical habitat for the Steller sea lion were determined on the basis of the available information on life history pattern of the species, with particular attention paid to land sites where animals haul out to rest, pup, nurse their pups, mate, and molt, and to marine sites considered to be essential foraging areas. The foraging areas were determined on the basis of sightings of sea lions at sea, incidental catch data, and foraging studies using satellite - linked tracking systems. Rookeries in California and Oregon are considered critical habitat, but in Washington there are no breeding rookeries or critical habitat area designations. The nearest rookery is in southern Oregon and West Vancouver Island. Haulout sites in Washington, Oregon, or California have not been identified as critical habitat. However, prevention of contamination and conservation of prey resources and foraging areas appears essential to the recovery of the Steller sea lion population. Populations in the Proposed Project Area: The Steller (or Northern) sea lion is the largest of the eared or otariid seals found in Washington waters and uses haulout sites primarily along the outer coast from the Columbia River to Cape Flattery, as well as occasionally on navigation buoys in Puget Sound (Jeffries et al. 2000). This species is also found at numerous haulout sites along the Vancouver Island side of the Strait of Juan de Fuca. Steller sea lion numbers vary seasonally in Washington with peak counts on the outer coast of 1,000 animals present during the fall and winter months (Jeffries et al. 2000). There are around 600 to 700 individuals from Cape Flattery to La Push on the outer coast (Garren 2002). However, there may be 1 to 2 individuals in inland Puget Sound at any time (Garren 2002). There is a haulout site at Race Rocks and Trial Island in the Strait of Juan de Fuca, near Vancouver Island where a few Stellers have been seen with a large number of California sea lions. The other nearest known haulout site is on the Toliva Shoals Buoy at the south of end of Vashon Island. Foraging may occur in Elliott Bay as these and other animals range to find the optimal foraging conditions. In the last 20 years, there have been no sightings or documentations of Steller sea lions in the Duwamish River (Garren 2002). However, the California sea lion has swam up the Duwamish River and been documented in the project area around Boeing Field (Garren 2002). 63.6 Humpback Whale Status: The humpback whale is listed as endangered under the ESA. The International Whaling Commission (IWC) gave them worldwide protection status in 1966. In 1985, the IWC instituted a moratorium on commercial whaling. Background Information: Humpback whales are wide ranging and can be found virtually worldwide. Humpback whales feed on krill, small shrimp -like crustaceans, and various kinds of small fish. Humpbacks are strongly migratory. They summer in temperate and polar waters for feeding, and winter in tropical waters for mating and calving. Due to their tendency to aggregate on the tropical breeding grounds and to come close to the shore on the polar feeding grounds the humpback whales were highly vulnerable to whalers. Humpbacks were hunted for their oil, meat and whalebone. It is likely that whalers throughout the modern whaling era killed more than 100,000 humpbacks and, although some stocks seem to be recovering, today's I:\Projects \WCIA\02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 20 URS CORPORATION k population is still a fraction of its original size. Based on whaling statistics, the pre -1905 population of humpback whales in the North Pacific was estimated to be 15,000 (Rice 1978), but this population was reduced by whaling to approximately 1,200 by 1966 (Johnson and Wolman 1984). The North Pacific total now almost certainly exceeds 6,000 humpback whales (Calambokidis et al. 1997). Populations in the Proposed Project Area: The humpback whale does not frequent the inland waters of Puget Sound, but it has in the past. Historically, humpback whales occurred in inland Puget Sound (Calambokidis 2002), but they were hunted to local extinction. In the early part of this century, there was a productive commercial hunt for humpbacks in Georgia Strait that was probably responsible for their disappearance from local waters (Osborne et al. 1988). Currently, individual humpback whales are occasionally seen south of Admiralty Inlet. There have been about 6 sightings in the last 5 years (Calambokidis 2002, Tallman 2002). There have been no documented sightings of humpback whales in Elliott Bay. The nearest and most recent sightings were: in June 1999, an individual was seen in the Strait of Juan de Fuca; in July 1999 an individual was seen near Alki Beach, West Seattle; in March 2000, another individual was sighted in Sinclair Inlet near Bremerton (Tallman 2002); and in March 2002, one individual was seen in Admiralty Inlet. Humpback whales have strayed up rivers (Humphrey, a juvenile humpback whale swam at least 10 miles up the Sacramento River in 1985). Clearly this is not normal and extremely unlikely in the project area given the rare occurrence of humpbacks in south Puget Sound. 63.7 Leatherback Sea Turtle Status: The Leatherback sea turtle is listed as endangered under the ESA. Background Information: The leatherback is the largest sea turtle. It can grow up to 6.5 feet (2 m) long and weigh 1,400 pounds (636 kg). The leatherback gets its name from its shell, which is like a thick leathery skin, with the texture of hard rubber. Once abundant throughout the world's oceans, all eight species of sea turtles are now threatened or endangered. Leatherback populations have plummeted in recent years. Leatherbacks are unique among sea turtles in that their primary food is jellyfish. They also will eat fish, mollusks, squid, sea urchins, and other marine creatures. Adult leatherbacks ply the seas alone, except on occasion gathering to feed in areas with large numbers of jellyfish. They are also remarkable among reptiles in that they can survive in cold waters; they have been reported as far north as Norway and south off the coasts of Chile and New Zealand. This range is possible because leatherbacks can keep their body temperature warmer than the water surrounding them, due to a thick, oily, fat layer under their skin and their ability to shunt (turn off) bloodflow away from cold flippers. All other sea turtles are confined to the warmer regions of the world's oceans. The leatherback is the most pelagic of the sea turtles; it is often found near the edge of the continental shelf. In northern waters they are reported to sometimes enter shallow estuarine bays. Populations in the Proposed Project Area: NMFS lists the leatherback sea turtle as a species that "may occur in Puget Sound." However, no known documented sightings or strandings of leatherbacks have occurred in Puget Sound ( Norberg 2002). K. McCallister (WDFW) had heard of a sighting "thought to be a leatherback" but was unable to confirm. Leatherbacks do occur on the outer coast of Washington and dead specimens occasionally wash ashore on the outer coast during the summer (Norberg 2002). It is possible that leatherbacks could enter the inland Puget Sound waters if there are large jellyfish aggregations. I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 21 URS CORPORATION 7.0 EFFECTS OF THE ACTION 7.1 ESA EFFECTS ANALYSIS 7.1.1 Bald Eagle No critical habitat designation has been made for the bald eagle. WDFW Management Recommendations (Rodrick et al. 1991) do not require specific buffers for bald eagle nests and roosts, but rather use a site - specific approach to management. In general, nests or roosts within 0.5 mile are managed for disturbance through timing restrictions on construction projects. A 4,000 -foot buffer zone has been suggested to accommodate alert behavior responses of breeding bald eagles to distant disturbances from vehicle, noise, and aircraft disturbance (Grubb and King 1991). This distance from the project site was used to define the action area. Direct Effects: It is unlikely that the project construction would have an effect on the known nest sites located 3.5 miles to 4 miles away because of the distance between the nests and the site. Breeding and nesting activities occur from January 1 through August 15 It is likely that the project would be constructed during the in water work period for salmonids between October 15 and March 15. Therefore, breeding eagles would be present in the vicinity. However, the project site is located in the industrial district of south Seattle and across the street from Boeing Field. Bald eagles using this area are habituated to man made noise and would not likely be disturbed by construction. No habitat features important for bald eagles, such as large trees and snags, will be removed as part of this project. There are no known roost sites in the project vicinity. Interrelated/Interdependent Effects: Interrelated actions are those that are part of a larger action and depend on the larger action for their justification (Federal Register 1986). Interdependent actions are those that have no independent utility apart from the action under consideration (Federal Register 1986). The proposed restoration to the tidal flats adjacent to the site are Klepeude`hl�r`e`Aate to the cleanup of this site. The restoration activities proposed by (Rigel would not be effective if the contaminants are allowed to continue to leach into the river. The staging areas and handling of toxic waste would be an interdependent effect of the project. The possibility exists that during installation some slurry may leak out through surface or subsurface flow and enter the Duwamish River. Berms will be constructed on site to prevent surface discharge. Additional preventative measures are described under construction and conservation measures (Section 3.3 and 9.0 respectively). These additional measures would be considered interdependent effects. The groundwater recovery system would also be considered an interdependent effect. Without the bather wall, the groundwater recovery system would not be built. Indirect Effects: There are no known communal winter roost sites near the project area. Eagles roost in stands of timber adjacent to or relatively near foraging areas (Stinson et al. 2001). Communal roost sites are an important component of wintering habitat (Stinson et al. 2001). Wintering activities occur from October 31 through March 31 The project would likely be constructed during the time when wintering eagles would be expected to be present in the lower Duwamish River. However, if any bald eagles were in the area they may avoid the site during construction and be displaced to adjacent forage areas along the Duwamish River and Lake Washington. Water quality and fish habitat in this reach of the Duwamish would be improved in the long term, thus not permanently removing a prey species for the bald eagle. The restoration I:\Projects \WCIA \02\53 - 01000496 RCI Former Rhone Poulenc Site\IMWP■Engineering Report \Draft Engineering Report\Appendix- Biological Assessment.doc 22 URS CORPORATION • . 1' efforts may provide rearing habitat for juvenile salmonids and other bald eagle prey species. Cumulative Effects: Cumulative effects are those effects of future state or private activities, not involving federal activities, that are reasonably certain to occur within the action area of the federal action subject to ESA consultation (Federal Register 1986). The following activities can reasonably be expected in the action area: a) continued industrial activities, shipping, and port activities and b) continued cleanup and restoration of contaminated sites in the Duwamish river estuary. 7.1.2 Bull Trout/Dolly Varden, Chinook and Coho Salmon Fish Bioacoustics: Sound is defined as a density disturbance that propagates through a medium. The amplitude of a sound wave is proportional to the maximum distance a vibrating particle is displaced from rest. The frequency of a sound wave is the rate of oscillation or vibration of the wave particles and is measured in cycles per second or Hertz (Hz). Sound intensity (loudness) is described in decibels (dB). The velocity of sound propagation in water is approximately 1,500 meters per second (m/s) and is independent of sound frequency. The speed of sound in air is approximately 340 m/s. Noise levels in air do not equal underwater levels. They are referred to in different reference points. Sound pressure is the sound force per unit area and is cited in micropascals (pPa). Transmitted sound pressure levels in water equal received sound pressure level ONLY at a distance of 1 meter from the source, since the reference unit is 1 microPascal at lm. In air, the sound pressure level is referenced to 20jPa, while in water the sound pressure level is referenced to 1 µPa. As sound propagates away from a source, its amplitude decreases in proportion to the distance from the source due to geometric spreading. Additional diminution of sound results from attenuation due to mechanical and chemical factors. Attenuation rate is directly proportional to sound frequency. Ultrasound refers to any sound above 20,000 Hz, low frequency means signals from 35 -300 Hz, and infrasound means any signal below 35 Hz. Underwater Sound: A sound wave is a pressure disturbance that travels through water. The energy in a sound wave is contained in changes in local pressure and concurrent back - and -froth (vebrational) motions of water "particles." Although particles in a wave field show no net motion over time, they have a directional (vectorial) motion at any instant in time. This particle motion or displacement is a major component of a sound field relatively close to a sound source. Further from the source the primary (but not only) component of the field is pressure. Sound sources in the air and water both produce particle motion, but the greater density if water preserves particle motion over a much greater distance. Particle motion is generally not functionally significant for a terrestrial organism, whereas it is very important for aquatic animals. A critical issue is how well a particular species can detect the particle displacement component of a signal with the ear or with the lateral line. If the fish ear is very sensitive to particle displacement, then it may detect the signal over a considerable distance from the source. Equally important is the idea that the lateral line detects particle displacement gradients along the length of the fish (Denton and Gray 1989, 1993). Fish ears may be able to detect particle displacement at a greater distance from the source than their lateral lines can. Another critical aspect of underwater acoustics relevant to work with salmonids and other fishes that live at least part of their lives in shallow water such as rivers and streams, is that low- frequency sound propogates very poorly in shallow water because the wavelength is larger than the water depth (Rogers and Cox 1988). I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 23 UPS CORPORATION j.T _�1 Low frequency sounds (both pressure and particle displacement components) attenuate far more rapidly with distance from the source in shallow than in deep water (Rogers and Cox 1988). Substrate also affects attenuation rates; for a given depth, lower frequencies can be propogated over soft bottoms than over hard bottoms. Because low- frequency propogation is affected strongly by depth, fish in shallow habitats probably detect lower - frequency sounds only from sources that are extremely close to them. Therefore, given that the Duwamish is fairly shallow and likely with mud or silty substrate it was determined that any noise received in the river would not travel very far. This provides ample opportunity for the fish to move out of the area of disturbance. The only problem with this theory is that fish will not necessarily move out of the area (Visconti 2002). Also, the response of fish to water flow overrides or supercedes responses to other stimuli (Carlson 1994). Sound detection thresholds, background noise, and other characteristics of a sound source and the receiving fish's sound sensory system must be specified in terms of the adequate sound field stimulus for that species. Until recently, most data of this type have been universally expressed in acoustic pressure referenced to one standard or another. This is not appropriate under near -field conditions for species lacking pressure -to motion transducers or whose octavolateralis structure, though present, does not function for such purposes. Its is of little value to have data expressed in acoustic pressure and have no direct, unambiguous means of translating these values to the component of the sound field that stimulates the fish's sensory system (Kalmijn 1988, 1989; Rogers and Cox 1988). For example, it is quite clear that the adequate stimulus for the salmonid sound sensory system is particle motion and that a spontaneous avoidance reaction is elicited only if the fish is in the near field of the source (Van Derwalker 1967; Knudsen et al. 1992, 1994). One would need to know the distance from the source at which pressure measurements were made to calculate an estimate of particle acceleration corresponding to the pressure measurement. Fish have evolved sensory systems to detect both the particle motion and pressure components of sound fields to optimize the amount of information about a sound source from its sound field. The capability of detecting and extracting information from both particle motion and pressure provides fish with hearing capabilities that differ in many respects from those of humans. One of the major differences between fish species is their respective abilities to detect the pressure component of sound fields at extended distances from a sound source. Detection of vibrational signals (which include sounds) by fishes involves two sensory systems, the ear and the lateral line. Together the ear and lateral line are often referred to as the octavolateralis system (Popper et al. 1992). The ear and lateral line do have some functional overlap. The ear detects sound frequencies from well below 50 Hz to over 2,000 Hz in some species. It also responds to position and acceleration of the body (Platt 1983; Popper and Platt 1993). The lateral line responds to differences between motion of the fish and motion of the surrounding water (Montgomery et al. 1995). These include stimuli produced by other swimming fish and other organisms and include frequencies from less than 1 Hz to several hundred hertz (Coombs et al. 1989, 1992; Enger et al. 1993; Satou et al. 1994; Montgomery et al. 1995). An important difference between the two systems is the distance from the fish over which they function. The lateral line detects signals that originate close to a fish, within one or two body lengths, whereas the ear detects signals at considerable distances from thefish (Kalmijn 1988, 1989). It is important to note that although the frequency and distance ranges of the two systems differ, many near —field signals can stimulate both the ear and lateral line. I:\Projects \WCIA \02\53 - 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 24 URS CORPORATION The effectiveness of the swim bladder in stimulating the fish ear appears to depend upon its proximity to the ear (Fay and Popper 1980). When the swim bladder is relatively far from the ear (as in salmonids and other hearing generalists), hearing does not appear to be enhanced very much, if at all, by the swim bladder. However, a number of species have specializations that acoustically couple the swim bladder to the ear (Weberian ossicles). Species with acoustic coupling appear to hear better than species without coupling (Fay Z 1988; Popper and Platt 1993). c4 2 Hearing generalists such as Atlantic salmon can detect sounds to well below 50 Hz with good sensitivity U O ( Karlsen et al. 1992; Knudsen et al. 1992, 1994; Enger et al. 1993). The frequency generated by the vibratory co w beam is around 900 revolutions per minute (rpm) or 15 Hz (Slurry Systems 2002) and therefore well within J the range of salmonid hearing. The level at which a fish can detect a sound depends upon the level of � background noise. Tavolga (1967, 1974) and Buerkle (1968) found that sound must be 10 dB more intense Ill than background noise to be detected; otherwise, the noise is "masked." Studies of Atlantic salmon showed that masking occurs in the far field (Hawkins and Johnstone 1978). Masking can occur when noise has I.. different frequencies from the center frequency of the sound source, although some fish can effectively filter = w CI out sound at frequencies that differ from the frequency being listened to (Fay 1974, 1992). Atlantic salmon, Z however, cannot filter out noise that is less than 90 Hz (Hawkins and Johnstone1978). Fish can use their Z 0 ability to locate a sound source to detect a signal in the presence of noise. This is known as the "cocktail party effect" because it is analogous to the ability of humans at a cocktail party to hear a specific person with whom they are speaking despite the masking effects of all other people in a room The background noise of p — the environment is not as important to salmonids as it is to species with better hearing such as Atlantic cod. W H Measurements of background noise in many aquatic environments have shown that the sensitivity of H U salmonids is so poor that (except for extremely noisy environments such as waterfalls and dam tailrace) their u_ ability to detect a sound is not limited by background noise, but by the poor sensitivity of their octavolateralis Iii N system (Hawkins and Johnstone 1978). H O VanDerwalker (1967) described studies of steelhead responses to various sound frequencies. Without . Z providing detailed results, he summarized the data by saying that the fish responded to sound onset when the stimulus was a pure tone from 10 to 280 Hz and that the maximum behavioral response (changes in swimming pattern of large groups of fish) occurred when the sounds were from 35 to 170 Hz. The fish never moved more than 60 cm from the sound source an this maximum distance occurred at frequencies from 40 to 120 Hz. Hearing by Atlantic salmon was investigated by Hawkins and Johnston (1978) using classic conditioning of heart rate. The fish responded to sounds from 32 to 270 Hz, showing greatest sensitivity from 100 to 200 Hz. Knudsen et al. (1992, 1994) measured the behavioral responses of Atlantic salmon to tones from 5 to 150 Hz and found the best responses were from 5 to 10 Hz. Juveniles showed an avoidance response to 10 Hz signals, but not to 150 Hz signals, although avoidance of the 10 Hz signal would only occur if the fish were within 2 m of the sound source. Stober (1969) found that some, but not all, cutthroat trout gave an unconditioned startle response to sound up to 443 Hz, although no response was found to sounds below 50 Hz. Stober also showed rapid habituation by the fish, as did Knudsen et al. 1992). Knudsen et al. (1992, 1994) concluded that Atlantic salmon responded to very low frequency sounds (infrasound). Karlsen (1992) demonstrated that several species of fish are able to detect infrasound and he concluded that the ear was I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site \IMWPPEngineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 25 URS CORPORATION involved in such detection. On this basis, Knudsen proposed that Atlantic salmon use their ears to detect infrasound. Regardless of the receiving end organ involved, the important fording is that juvenile Atlantic salmon respond in a pool to infrasound and that the response only occurs when the signal is presented within 2 m of the fish. Based on the studies of Atlantic salmon, it is assumed that Pacific salmon would hear at similar frequencies and respond in the same manner. The only sound information known about the vibratory beam is that the noise of the generator is greater than the vibratory hammer. The vibratory beam would generate pressure waves within the soil that would transmit quite readily to the Duwamish. The noise statistics received from Slurry Systems indicate that the energy generated by the hammer is 7000 inch -lbs and a 120 ton static force. These measurements are different than measurements needed to determine the sound and intensity of underwater noise that may be present during construction. Water is virtually incompressible and far less forgiving than air for transmitting sounds. The soil is also a dense medium and therefore would transmit sound much more easily than air (Burgess 2002, Carlson 2002). Any groundwater present in the soil will only assist the underwater noise in traveling to the river. The movement of the beam into the ground will send out a pressure wave that propagates outward in all directions. The vibrating beam sends out a succession of waves as it is pushed deeper into the soil. In shallow water, much of the acoustic energy is expected to be absorbed by the bottom and reflected off the surface back down to the bottom. Thus, the rate of attenuation is much higher in shallower water and the expected area of adverse effects is expected to be reduced. Loud sounds can have a detrimental effect on fish by causing stress, and increasing predator avoidance capability, and interfering with communication necessary for navigation and reproduction (Woodbury 2002). Woodbury (2002) determined that 150 dB (frequency unknown) would elicit a startle response, 180 dB would cause physical damage and delayed mortality due to the inability to avoid predators, and 204 dB would instantly kill fish. In pile driving studies, (beyond 60 m and 204 dB re lµPa and up to 440 m and 180 dB relp.Pa) from an active source listed salmonids are likely to experience trauma in many organs including the inner ear, eyes, blood, nervous system, kidney, and liver. These injuries are expected to result in the delayed mortality of many of these fish. As the underwater sound pressure wave generated by a pile strike passes through a fish, the swim bladder will be rapidly squeezed due to the high pressure and then rapidly expand as the underpressure component of the wave passes through the fish. At relatively low sound pressure levels, only a fraction of 1 psi above the ambient sound pressure level in the environment, the swim bladder will rhythmically expand and contract with no adverse effect. The swim bladder routinely expands and contracts as salmonids swim near the surface or swim in deeper water near the bottom. At high sound pressure levels of pile driving, the swim bladder may repeatedly expand and contract, hammering the internal organs that cannot move away since they are bound by the vertebral column above and the abdominal muscles and skin that hold the internal organs in place below the swim bladder (Gaspin 1975). This pneumatic pounding may result in the rupture of capillaries in the internal organs as indicated by observed blood in the abdominal cavity, and maceration of the kidney tissues. The pneumatic duct, which connects the swim bladder with the esophagus, may not make a significant difference in the vulnerability of the salmonids since it is so small I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 26 URS CORPORATION S�:Ll.t�41�V rr.mpt Ste' ' •l • relative to the volume of the swim bladder (Gaspin 1975). It is unlikely that the vibrating beam elicits such loud sounds, however, no measurements have been done so it is unknown. Fish can also experience trauma when exposed to lower pressure levels if exposed for longer periods of time (Woodbury 2002). Since this project would be involve the vibratory beam being "on" for hours at a time, this is another aspect to be considered. However, without hard data of what frequency and pressure level is being received in the river, it is very difficult to predict what will be heard by the salmonids and other fish present. Direct Effects: During the slurry wall installation, vibratory noise would be detectable in the river. The intensity that it would be detected is unknown and also specific to the fish species. The fish may startle at the noise and depending upon its intensity in the water, temporarily move away from the area. If the noise is not of an intensity that causes distress, the fish would likely remain in the area. Juvenile salmonids would be more susceptible to predators if they are forced to move into deeper water to avoid the site. Juvenile salmonids are also more susceptible to noise disturbance than adults (Woodbury 2002). The underwater sound would not likely transmit across the river given the physical characteristics of the Duwamish. This means that the disturbance would be highly localized and fish species could leave the area during construction. Interrelated/Interdependent Effects: Interrelated actions are those that are part of a larger action and depend on the larger action for their justification (Federal Register 1986). Interdependent actions are those that have no independent utility apart from the action under consideration (Federal Register 1986). The proposed restoration to the tidal flats adjacent to the site are depeniiel2heated to the cleanup of this site The restoration activities b osed ro whom ' would not be effective if the contaminants are allowed to P P by (�... .,,. �� continue to leach into the river. The staging areas and handling of toxic waste would be an interdependent effect of the project. The possibility exists that during installation some slurry may leak out through surface or subsurface flow and enter the Duwamish River. Berms will be constructed on site to prevent surface discharge. Additional preventative measures are described under construction and conservation measures (Section 3.3 and 9.0 respectively). These additional measures would be considered interdependent effects. The groundwater recovery system would also be considered an interdependent effect. Without the barrier wall, the groundwater recovery system would not be built. Indirect Effects: The proposed action would not affect salmonid prey species in the river. Juvenile salmonids feed on a variety of bugs and insects. The noise and vibration from the slurry wall installation and associated construction is not likely to disturb the prey resource. Both the insects and juveniles would however be benefited by the reduction in contamination leaching from the site. Further enhancement of the intertidal areas adjacent to the site following construction may provide habitat for prey species and refuge areas for juvenile salmonids. Water quality in the area around the site would immediately be improved following the construction of the barrier wall. Some contaminated sediments on the perimeter of the site will not be capped off because the wall will be installed between 25 to 50 feet from the waters edge, (depending on where you are on the site). These areas outside the barrier wall will continue to leach contaminants into the river. The river in this reach is tidally influenced and considered brackish. The installation of the groundwater recovery system would change the way groundwater flowed near the site. Groundwater would I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 27 URS CORPORATION . rrw.. e.... m.yn,. rnw+ 5+. n+ N. YM.+ Y•'. MeN. ri? �MM41+ aY. f.++` si4 '�1YF'.i'.tw,pRyS(•.by)fijl naturally be diverted around the site due to the presence of the barrier wall. The barrier wall will maintain an inward hydraulic gradient and this will allow groundwater to flow into, but not out of the site. Water accumulated inside the barrier walls will be pumped out and sent to Metro for treatment. This would result in a net loss of approximately 0.011095 cfs (5 gpm). This change is not expected to impact the nearshore habitats because they are already accustomed to the fluctuation of fresh and saltwater from the tides and freshwater discharge. The small net loss of groundwater discharged to the Duwamish river would be not be of significant quantities to alter the nearshore habitat. Freshwater would discharge to the north and south of the site rather than through it. Cumulative Effects: Cumulative effects are those effects of future state or private activities, not involving federal activities, that are reasonably certain to occur within the action area of the federal action subject to ESA consultation (Federal Register 1986). The following activities can reasonably be expected in the action area: a) continued industrial activities, shipping, and port activities and b) continued cleanup and restoration of contaminated sites in the Duwamish river estuary. 7.13 Steller Sea Lion The project would not effect the Steller sea lion for several reasons. In the last 20 years, Steller sea lions have not been documented in the Duwamish River. To the contrary, California sea lions have been seen quite frequently foraging in the Duwamish River near Boeing field (Garren 2002). Steller sea lions are much more common on the outer coast of Washington and in the Strait of Juan de Fuca. Due to their smaller population size in this area, only one or two Steller sea lions would be expected in Puget Sound at any time. If they happened to occur in the project area during construction, they could easily swim outside any area of disturbance. The received source level for temporary hearing threshold shift in marine mammals has been estimated at 185dB re lµPa @ lm. It is unlikely (although unknown) that the project would generate that much noise. The Duwamish River is not conducive to sound transmission and the project is not expected to deliver intensities that would create a disturbance for either the Steller sea lion or the California sea lion. California sea lions in this area are highly habituated to shipping and other ambient noise. Therefore the project would not likely effect the Steller sea lion (nor the California sea lion). 7.1.4 Humpback whale The project would not effect the humpback whale, even if one were present in Elliott Bay during construction. Humpback whales and other baleen whales can hear low frequency sounds. The received source level for temporary hearing threshold shift in marine mammals has been estimated at 185dB re 1pPa @ lm. It is unlikely (although unknown) that the project would generate that much noise. However, even though they hear low frequency sounds, avoidance behaviors would be expected when the noise becomes quite loud. It is extremely remote, if not impossible for this project to generate underwater noise to the level that would cause disturbance for the humpback whale. The physical characteristics of the Duwamish River adjacent to Slip 6 are not conducive to sound transmission (Burgess 2002). Therefore, the noise (regardless of how loud) generated from this project would not travel the 6 miles out of the channel and into Puget Sound. Furthermore, the ambient noise in Puget Sound and the shipping channel would mask any project related noise. In addition, the humpback whale occurs in Puget Sound on average of once per year. Humpbacks have not been documented in Elliott Bay nor straying up the Duwamish River. It is thereby I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\I1vIWP■Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 28 URS CORPORATION concluded that the project would not effect the humpback whale. 7.1.5 Leatherback Sea Turtle The leatherback sea turtle has not been documented in the inland Puget Sound waters. It has the potential to Z occur in inland Puget Sound, as well as in Elliott Bay. The leatherback would be present for foraging on aggregations of jellyfish, its primary food source. It is highly unlikely that the leatherback would stray up the C 2 Duwamish River if it were to make its debut into Elliott Bay. It is thereby concluded that the project would 6 v not effect the leatherback sea turtle. 0 0 CO cn w 7.2 EFH EFFECTS ANALYSIS 7.2.1 Identification of Essential Fish Habitat W O Based on the available life history information, freshwater EFH for Pacific salmon consists of four major g components: (1) spawning and incubation, (2) juvenile rearing, (3) juvenile migration corridors, and (4) adult u2 d migration corridors and adult holding habitat (Roni et al. 1999). Important features of essential habitat for _ spawning, rearing, and migration include adequate (1) substrate composition; (2) water quality (dissolved Z �- oxygen, nutrients, temperature, etc.); (3) water quantity, depth, and velocity; (4) channel gradient and W O uj stability; (5) food availability; (6) cover and habitat complexity (e.g., large woody debris (LWD), pools, 2 channel complexity, aquatic vegetation, etc.); (7) space (habitat area); (8) access and passage; and v (9) floodplain and habitat complexity. p Important elements of salmon marine EFH are (1) estuarine rearing, (2) early ocean rearing, and (3) juvenile U and adult migration and feeding (Roni et al. 1999). Important features of this estuarine and marine habitat are u. (1) adequate water quality, (2) adequate temperature, (3) adequate prey species and forage base (food), and uj N (4) adequate depth, cover, and marine vegetation in estuarine and nearshore habitats (Roni et al. 1999). U = Potential threats to these habitat features and life history components include (1) direct (hydrologic Z modifications); (2) indirect (loss of prey or reduction of species diversity); (3) site - specific; or (4) habitat - wide impacts that are chemical, biological, and physical in nature and may result in individual, cumulative, or synergistic consequences (Wilbur & Pentony 1999). The Duwamish HUC is designated EFH for chinook and coho salmon (PSMFC 2000). 7.2.2 Site Specific Effects to Duwamish River Essential Fish Habitat The lower Duwamish River at the project site is a tidally influenced reach that provides essential fish habitat features and beneficial components to the life history stages of several species of salmonids. The saline wedge water, which has its source in Elliott Bay, oscillates upstream and downstream with the tide. During periods of low fresh -water inflow and high tide stage the saltwater wedge has extended as far upstream as the Foster Bridge, 10.2 miles above the mouth. At freshwater inflow greater than 1,000 cubic feet per second (cfs) the saltwater wedge does not extend upstream beyond the East Marginal Way Bridge (RM 7.8) regardless of tide height (Stoner 1967). The Duwamish River transports fine material in a freshwater plume emptying into Elliott Bay. Sediments return from Elliott Bay to the Duwamish as a near -bottom sediment load contained in the saltwater wedge (GeoSea Consulting 1994). Prior to the diversion of the White and I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc Site'JMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 29 URS CORPORATION Cedar rivers the mean annual flow for the Duwamish was estimated to be between 2,500 to 9,000 cfs (Fuerstenberg et al. 1996). By 1996, the mean annual flow of the Duwamish was estimated to be approximately 1,700 cfs (USACE 1997), a total reduction between 32 to 81 percent. Shoreline armoring has reduced the functionality of the intertidal habitat. Upper and middle intertidal habitat has been eliminated by the construction of bulkheads and piers. Regular dredging operations (every 2 -3 years) in the Duwamish waterway have deepened the main active channel for navigation purposes. A report issued by the Army Corps of Engineers (USACE 1997, p. 36) implied that due to dredging practices, the tide migrates farther upstream than it had prior to channelization and dredging. This assumption appears to be valid when considering the combined effects of deepening the channel, reducing the watershed by 70 percent, and reducing freshwater discharge by 70 percent (USAGE 1997). Sediment sampling performed by GeoSea Consulting (1994) suggests that sand in the Duwamish River is becoming increasingly rare, and its removal (from dredging activities) may result in favoring the deposition of mud (silts and clays). Tidal activity dominates the sediment deposition in the Duwamish and as a result it may also control the kinds of sediment that are deposited. If tidal activity is occurring farther upstream than it previously had, then it could have changed the composition of the streambed (KCDNR 2001). At the project site, the groundwater is contaminated by heavy metals (copper and chromium), arsenic, and toluene. The metals are dissolved in the groundwater and are transported to the Duwamish river. The installation of the barrier wall will contain the contaminants, thereby preventing further leaching into the river. This will have an immediate benefit to the water quality in this area. Another component of the barrier wall involves the installation of a groundwater recovery system. This is intended to maintain an inward (to the site) hydraulic gradient in the shallow groundwater. After the barrier wall is in installed, the wall will affect groundwater (GW) flow in the immediate area. It is expected that the area between the wall and the river may become more saline as the "shadow" of the wall affects GW flow. However; the installation of the wall won't necessarily affect the amount of GW discharging to the Duwamish. It should have no net effect on the amount of water flowing into the Duwamish, but freshwater flow will go around the site and increase (discharge) to the south and north of the wall to compensate. Approximately 2 to 3 months after the wall is installed the groundwater recovery system will begin pumping GW from within the wall at a rate of 5 to 10 gallons per minute (gpm) (projected). This GW will come mainly from within the wall and will be extracted to maintain a net inward -flow of GW towards the inside of the wall. The wall and the low permeability layer that the wall is tying into at depth is anticipated to limit the amount of pumping required to achieve this net - inward gradient. It is possible that the pumping of 5 gpm will be recovering some GW from outside the wall, which would result in a small net loss of fresh GW that will not discharge to the Duwamish. This water will be sent to Metro for treatment and then discharged into Puget Sound at the Metro outfall at West Point. This withdrawal of GW will continue for the foreseeable future and would be a central requirement by the EPA. Despite the small net loss of GW (0.011095 cfs) projected by the implementation of this project, the overall benefit of improved water quality far outweighs the option of not capping off the contaminants. A restoration project is planned dig for the intertidal flats on the west (Duwamish) side of the site. This restoration would be a mute exercise if the contaminants were not sealed off. In addition, the dike along Slip I:\Projects \WCIA \02153- 01000496 RCI Former Rhone Poulenc SiteWvlWP\Engineering Report\Draft Engineering Report\Appendix - Biological Assessment.doc 30 URS CORPORATION 6 will be removed as part of this project. All factors considered, this project would have a net benefit on EFH in this reach of the Duwamish. The ESA defines the term take to mean "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct." The term harm is defined as "an act that actually injures or kills wildlife. Such acts may include significant habitat modification or degradation where it actually injures or kills wildlife by significantly impairing essential behavioral patterns, including breeding, feeding, and sheltering." 8.1 BALD EAGLE 8.0 TAKE ANALYSIS FOR LISTED SPECIES No direct take of the bald eagle would occur during the construction phase of the containment walls. The nearest bald eagle nest is 3.5 to 4 miles away. Fish in the immediate project reach of the Duwamish River may be temporarily impacted, displacing fish both upstream and downstream during the several weeks of construction. If foraging eagles are present during construction, temporary displacement of foraging activities in this reach of the river may occur. However, foraging opportunities exist elsewhere in the Duwamish River both upstream and downstream of the project site, as well as in Longfellow Creek and Lake Washington. Also, the project will likely occur between 15 October and 15 March after the adult salmonids have migrated upstream past the project area. Water quality in this reach of the Duwamish River would be immediately improved after installation of the containment walls. The noise associated with construction would be temporary, and therefore in the long run, the project would not permanently remove a prey species for the bald eagle. No habitat features important for bald eagles, such as large trees and snags, will be removed as part of this project. 8.2 BULL TROUT/DOLLY VARDEN, CHINOOK AND COHO SALMON The degree to which this project may affect listed anadromous fishes and result in a take is unknown. The project may result in the temporary avoidance of the nearshore areas around the site. The distance displaced would be less than the width of the river, because the physical characteristics of the river do not support noise transmission. The extent to which this area of the river is utilized for rearing is unknown. The areas around Kellogg Island provide much more suitable estuarine habitat for feeding and sheltering. Without information on the frequency and intensity of sound received in this reach of the river it cannot be concluded whether or not a take will occur. 8.3 STELLER SEA LIONS This project should not result in the take of a Steller sea lion. It is very unlikely that the Steller sea lion would be in the project vicinity based on their small numbers and limited occurrence in Puget Sound as previously discussed. Because the Duwamish River would not transmit the sound over long distances, and in fact perhaps not even across the distance of the river, any Steller sea lion foraging in the project area could easily I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc SiteelMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 31 URS CORPORATION avoid the disturbance by swimming away. Furthermore, if the project is conducted during the fish construction window, the adult salmonids would have already migrated upstream past the project area. Thus the chance of a foraging Steller sea lion in the Duwamish would not only be extremely remote, but a first in the 20 years of NMFS observations in Puget Sound. 8.4 HUMPBACK WHALE The project would not result in the take of a humpback whale, even if one were present in Elliott Bay during construction. As discussed, humpback whales and other baleen whales can hear low frequency sounds. However, it is basically impossible for the project to generate underwater noise to the level that would cause disturbance for the humpback whale. This is due in part to the physical characteristics of the Duwamish River adjacent to Slip 6, which are not conducive to sound transmission. The noise generated from this project would not travel the 6 miles out of the channel and into Puget Sound. Furthermore, the ambient noise in Puget Sound and the shipping channel would mask any project related noise. In addition, the humpback whale occurs in Puget Sound on average of once per year. Humpbacks have not been documented in Elliott Bay or nor straying up the Duwamish River. It is thereby concluded that the project would not result in a take of the humpback whale. 8.5 LEATHERBACK SEA TURTLE The project would not result in the take of a Leatherback sea turtle. Leatherback turtles have not been documented in Elliott Bay and are not likely to ascend the Duwamish River. In the unlikely scenario that a turtle should stray into the river and swim upstream, the turtle can avoid the area by swimming away. 9.1 BALD EAGLE • There are no bald eagles in the action area or vicinity of the action area. The nearest bald eagle nest is between 3.5 and 4 miles away. Disturbance at the site would not affect their nesting or foraging activities. The site is in a highly industrialized area across the street from Boeing Airport. 9.2 FISH The conservation measures for fish are listed below. 9.0 CONSERVATION MEASURES • Stormwater control berms will be built about 1.5 feet high with a one -foot wide crest around the perimeter of the slurry wall alignment to control run-on and run -off and prevent escape of slurry by surface flow to the environment. The construction subcontractor shall be responsible for maintaining these berms and ensuring that slurry does not escape containment. If additional berms or increased height are needed for containment, the subcontractor shall amend the berms to ensure slurry containment. I:\Projects \WCOA \02\53- 01000496 RCI Former Rhone Poulenc SiteMMWP\Engineering Report\Draft Engineering ReportWppendix- Biological Assessment.doc 32 CORPORATION .g a i z := z ce w 6 00 (O W J H CD LL w 2 §Q • d w z z1- w U • � O • i— w • w 1— H O , Z LIJ O ~ . z pthAvicA The Barrier Wall subcontractor shall perform excavation of a pre -trench to 20 feet depth along the south and west boundaries of the alignment. The purpose is to positively identify any potential conduits or void areas that could present a potential release of slurry or contaminants to the adjacent water bodies. This activity is in response to concerns by the regulating agencies (Washington State Department of Ecology and EPA). This trench shall be a minimum of 6- inches wide to the planned depth and shall be filled with potable water or other inert liquid during the trenching, or immediately following completion of a section of the trench, to positively identify that no conditions are present that would represent a significant slurry loss during full scale bather construction. RCI Environmental (RCI) will remove and seal any conduits identified by the subcontractor. RCI will also perform other utility locating, identifying aboveground and underground utilities, and arrange necessary de- energizing or lock - out/tag -out of known utilities prior to beginning site work. • Based on previous discussions about the sound generated by the vibrating beam, it can be assumed that fish in the immediate vicinity of Slip 6 and the Duwamish Waterway adjacent to the site will hear some noise from the vibratory beam. The amount of pressure (intensity associated with that noise (frequency) is unknown. Therefore, as a conservation measure, it is proposed that acoustic monitoring be conducted by a qualified underwater acoustic sub - contractor. This monitoring may be as short as one day, but after analysis it will provide site - specific answers to the frequency and intensity of underwater noise generated by this project. If it is found that the noise generated from the vibratory beam is above the threshold for disturbance, pain, short- or long -term damage, trauma, or death, then additional conservation measures will be implemented. This may include a bubble screens. Bubble curtains work best in areas not influenced by currents, because moving water will carry the upward - traveling air bubbles away from the site. • 9.3 MARINE MAMMALS AND SEA TURTLE • The Steller sea lion, humpback whale, and Leatherback sea turtle are not likely to occur in the Duwamish River. It is even more remote that they would be present 5.5 miles upstream at the project site. Although the underwater noise generated from the vibrating beam technology used on land adjacent to a waterbody is not known, because the species listed here would not be present in the project area, no additional conservation measures were designed. The acoustic monitoring conducted for the fish species would provide enough information that could be used to determine any potential disturbance should a Steller sea lion be seen in the project area during construction. 10.0 DETERMINATION OF EFFECT Preparation of the USFWS and NMFS matrix (Appendices D and E), site visits, and species information obtained from literature and the state and federal agencies was used to establish the following finding of effects. Bull trout/Dolly Varden/Chinook and Coho salmon: The degree to which this project may affect listed anadromous salmonids is unknown. The project may result in the temporary avoidance of the nearshore I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\JMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 33 URS CORPORATION z I I - =z ~w ce 0 CO W w u- i I .w Z ZI- U.1 w U � O N O I— w W H 1 LL Z r I O ~ z areas around the site. The distance displaced would be less than the width of the river, because the physical characteristics of the river do not support noise transmission. The extent to which this area of the river is utilized for rearing is unknown. The areas around Kellogg Island provide much more suitable estuarine habitat for feeding and sheltering. Without information on the frequency and intensity of sound received in this reach of the river it cannot be concluded whether or not a take will occur. It is likely that the noise generated from the site will be within the hearing range for salmonids. It is also likely that the noise will transmit through the soil and be detectable in the river. The intensity of the frequencies is not known. It is known that because of the physical features of the river the received frequencies will not transmit any great distance and therefore provide ample opportunity for the fish to leave the area. Therefore, it was determined that this project may affect, but is not likely to adversely effect bull trout/Dolly Varden, chinook and coho salmon. Bald eagle: No habitat features important for bald eagles, such as large trees and snags, will be removed as part of this project. No bald eagle nests or roosts are present within 3 miles of the project site. Bald eagles present during construction may or may not be displaced to alternate more likely foraging areas both upstream and downstream. Foraging bald eagles present in this area are acclimated to man made noise and most likely would not be disturbed by construction. The project site is in the industrial district of south Seattle and across the street from Boeing Field, which generates far more noise than the proposed project. There will be a long -term benefit to the water quality in the immediate vicinity of the site. No removal of a prey species for the bald eagle will occur. In fact, restoration activities post- construction near the site may provide additional rearing habitat for prey species of the bald eagle. Therefore, it is determined that this project will have no effect on the bald eagle. Steller sea lion, Humpback whale, Leatherback sea turtle: These species have not been documented in the Duwamish River, are rarely if at all seen Puget Sound, and with the exception of the Steller sea lion, unlikely in Elliot Bay. Therefore, it is determined that the project will have no effect on the Steller sea lion, humpback whale, or leatherback sea turtle. I:\Projects \WCIA \02153 -01000496 RCI Former Rhone Poulenc Site'JMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessmenldoc 34 URS CORPORATION • SUMMARY OF RECOMMENDED FINDINGS OF EFFECTS ESA Species: Bull trout/Dolly Varden Chinook salmon Coho salmon Bald eagle Steller sea lion Humpback whale Leatherback sea turtle EFH Species: Chinook salmon ( Duwamish HUC) Coho salmon (Duwamish HUC) 11.0 COORDINATION /CONSULTATION HISTORY Information concerning endangered, threatened, proposed, and candidate species was requested on May 25, 2002 from the NMFS. A written response was received on May 28, 2002 concurring with our identification of the Puget Sound chinook ESU (threatened) and the Puget Sound/Strait of Georgia coho salmon ESU (candidate) as the listed species in the area. NMFS also listed the Steller sea lion (threatened) and humpback whale (endangered) as species of concern, but noted that they are unlikely to frequent the project area. Chinook and coho salmon were identified as the EFH species. Several phone calls were placed to the Lacey office to determine why the humpback whale was on the species list, but the leatherback sea turtle was not included. Both are marine species under NMFS jurisdiction and equally unlikely to be present at RM 5.5 on the Duwamish. NMFS acknowledged that the humpback whale was unlikely and that the leatherback sea turtle was the only other marine species under NMFS jurisdiction in the area. Based on their judgment at the time of the species letter response, they determined that the sea turtle could have been included on the list since they are as equally unlikely as the humpback, however they did not get put on the response list. Threatened and endangered species likely to be found in the area of the proposed project was requested from the USFWS on May 28, 2002 and was received on ; ,�,_y;r 2002. Species listed by the reply letter as "threatened" in the vicinity of the project area include ulltrouil;Ytlie ti ldeae. eeply lette %list Er pzopo s 'can"clat0 species in the area of the project. Priority Habitats and Species (PHS) maps and data were requested from the WDFW on May 22, 2002 and received on June 12, 2002. Database information and PHS maps were acquired for the Seattle South quadrangle. Information from the WDNR was obtained through a CD provided by WDNR dated January 2002. Our query resulted in the Oregon floater as a ?z;;speci"eg with no state or federal status and located 0.75 mile from the project area. I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP1Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 35 URS CORPORATION May affect, not likely to adversely affect May affect, not likely to adversely affect May affect, not likely to adversely affect No effect No effect No effect No effect No adverse effect to EFH habitat No adverse effect to EFH habitat 12.0 REFERENCES DRCC (Duwamish River Cleanup Coalition). 2002. Fact Sheet reviewed and approved by EPA and King County. Seattle, WA. Federal Register 1986. Volume 51. No 106. Interagency cooperation- Endangered Species Act of 1973, as amended. Final Rule. pp. 19957- 19963. Federal Register 2001. Volume 66. Number 6. USFWS. Endangered and Threatened Wildlife and Plants; Proposed Rule to List the Dolly Varden as Threatened in Washington Due to Similarity of Appearance to Bull Trout. page 1629. Hard, J.J., R.G. Kope, W.S. Grant, F.W. Waknitz, L.T. Parker, and R.S. Waples. 1996. Status Review of Pink Salmon from Washington, Oregon, and California. 131 pp. McIntosh, B.A., J.R. Sedel, J.E. Smith, R.C. Wismar, S.E. Clarke, G.H. Reeves, and L.A. Brown. 1994. Historical changes in fish habitat for select river basins of eastern Oregon and Washington. Northwest Sci., vol. 68, no. special, pp. 36 -53. NMFS (National Marine Fisheries Service). 1996. Making Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Watershed Scale. Environmental and Technical Services Division, Habitat Conservation Branch. 20 pp. NMFS (National Marine Fisheries Service). 2001. Office of Protected Resources website: www.mnfs.noaa.gov/prot_res/PR3/candidates/candidate.html. Port of Seattle. 2002. Chart of Soundings for Slip No. 6 provided by G. Blomberg on June 12, 2002. Sounding were taken on August 16, 1983. PSMFC (Pacific States Marine Fisheries Commission). 2000. Proposed Recommendations for Essential Fish Habitat for the Pacific Coast Salmon Plan. Riemen, B.E., Lee, B.C., and Thurow, R.T. 1997. Distribution, status, and likely future trends of Bull Trout within the Columbia River and Klamath River Basins, North American Journal of Fisheries Management, 17:1111 -1125. Rodrick, E. and it Milner eds. 1991. Management recommendations for Washington's priority habitats and species. Washington Department of Wildlife. Olympic, WA Roni, P., Weitkmap, L.A., and Scording, J. 1999. Identification of Essential Fish Habitat for Salmon in the Pacific Northwest: Initial Efforts, Information Needs, and Future Direction. Pages 98 -107 in L. Benaka, editor. Fish Habitat: Essential Fish Habitat and Rehabilitation. American Fisheries Society, Symposium 22, Bethesda, Maryland. Slurry Systems. 2002. Vibrated Beam Technology and IMPERMIX documentation. Gary, Indi ana. Stinson, D. W., J.W. Watson, and K.R. McAllister. 2001. Washington state status report for the bald eagle. 1:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix - Biological Assessment.doc 36 UPS CORPORATION YINCAIVOM Washington Department of Fish and Wildlife, Olympia. 92 pp. Smith, M.R., P.W. Mattocks, Jr., and K.M Cassidy. 1997. Breeding Birds of Washington State. Volume 4 in Washington State Gap Analysis - Final Report (K.M. Cassidy, C.E. Grue, M.R. Smith, and K.M. Dvornich, eds.). Seattle Audubon Society Publications in Zoology No. 1, Seattle, 538 pp. USACE (U.S. Army Corps of Engineers). 2002. Chart of Soundings in Duwamish Waterway. Soundings accurate as of May and June 1997. Provided by G. Blomberg, Port of Seattle. USFWS (US Fish and Wildlife Service). 1986. Recovery Plan for the Pacific Bald Eagle. Portland, Oregon. 160 pp. USFWS (US Fish and Wildlife Service) 1998a. Bull Trout Interim Conservation Guidance. 32 pp. USFWS (US Fish and Wildlife Service) 1998b. A Framework to Assist in Making Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Bull Trout Subpopulation Watershed Scale. USFWS (US Fish and Wildlife Service). 2002. Threatened and Endangered Species List for the Saar Creek Project. 1- 3 -02 -SP -1028. Lacey, WA. WCC (Washington Conservation Commission). 2000. [Salmon and Steelhead] Habitat Limiting Factors and Reconnaissance Assessment Report: Executive Summary. Green/Duwamish and Central Puget Sound Watersheds. Water Resource Inventory Area 9 and Vashon Island. King County and the Washington State Conservation Commission. Olympia, WA. WDFW (Washington Department of Fish and Wildlife) 1992a. Salmon and Steelhead Stock Inventory, (SASSI) Appendix One Puget Sound Stocks. Olympia, WA. 371 pp. WDFW (Washington Department of Fish and Wildlife) 1992b. Draft bull trout/Dolly Varden management and recovery plan. WDFW. Olympia, WA. 125 pp. WDFW (Washington Department of Fish and Wildlife). 1995. Bull trout/Dolly Varden management plan, draft programmatic environmental impact statement. WDFW. Olympia, WA. 61 pp. WDFW (Washington Department of Fish and Wildlife). 1998. Washington Salmonid Stock Inventory (SSI): Bull trout/Dolly Varden. WDFW. Olympia, WA. 437 pp. WDFW (Washington Department of Fish and Wildlife). 2002. Priority Habitats and Species list dated March 28, 2002. Wilbur, A.R. and Pentony, M.W. 1999. Human - Induced Nonfishing Threats to Essential Fish Habitat in the New England Region. Pages 299 -321 in L. Benaka, editor. Fish Habitat: Essential Fish Habitat and Rehabilitation. American Fisheries Society, Symposium 22, Bethesda, Maryland. Wismar, R.C., J.E. Smith, B.A. McIntosh, H.S. Li, G.H. Reeves, and J.R. Sedell. 1994. A history of resource use and disturbance in riverine basins of eastern Oregon and Washington (early 1800s- 1990s). Northwest Sci., vol. 68, no. special, pp. 1 -35. Wydoski, R.S. and R.R. Whitney, 1979. Inland Fishes of Washington. University of Washington Press. I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc 37 URS CORPORATION Seattle,WA.220 pp. BProjects\WCIA\02\53-01000496 RCI Former Rhone Poulenc Site\IMWMEngineering Report\Draft Engineering Report\Appendix- Biological Assessmenidoc 38 UBS CORPORATION 1 „ •z • Z; • t •_J C-) 00 • .0) : W —I 'W o. Q. • . uj . Z 0: Z 1.11 uj '2 a ;D 0. 0 I-) 1— • 0 • z Cu • c.) ( r ) O. • NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR1 HAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. cA 0 td JD • ■■•••-■-i, NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THIS NOTICE IT IS DUE TO THE QUALITY OF TFIE DOCUMENT. APPENDIX D USFWS Matrix for Documentation of Effects on Bull Trout Indicators for documented environmental baseline and project effects are evaluated using the criteria in "A Framework to Assist in Making Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Bull Trout Subpopulation Watershed Scale" (USFWS 1998b). The Environmental baseline and project conditions are designated as "functioning appropriately ", "functioning at risk ", or "functioning at unacceptable risk" according to the USFWS (1998) criteria. Table D -1 summarizes the diagnostic pathways and indicators listed in the USFWS (1998) matrix method for the Duwamish River Estuary. i Li APPENDIX E NMFS Matrix for Documentation of Effects on Chinook and Coho Salmon Indicators for documented environmental baseline and project effects are evaluated using the criteria in NMFS (1996). The Environmental baseline and project conditions are designated as "properly functioning ", "at risk ", or "not properly functioning" according to the NMFS (1996) criteria. Table E -1 at the end of this appendix summarizes the diagnostic indicators listed in the NMFS (1996) matrix methodology for the Duwamish River Estuary. L eJw lr Uw.. n:+ -r•:ur..arF�u. <rr..wgerlrawinw. caawrNa� >x�w:.w ' p•'..e:r; . r ^,�' ✓ . _ ' S ' f . n '° • `'� }y ..�t�t.: . : f •i K a t .: t q .5, r .5• +'•; _ a a � : �Y,,�•�'Y',} as9 ; " > GT. e { "„`5f 'I S +' { 3 fv :J. �1;1u�iS : ♦• T o f � , • t`y . t , !�� 7 p. r � +. M .•'�-�. >(, ' `x£r;• "2' : .� . . '�$ �5• ., -5�+�y q ' KP'+✓4Y N , ," i : " ~ °r'< Di ti4 ,01,1t h wa . s' Y 'r a� r 4y � <r 3y � 1 r 1 r i�S1 [ f $. ,;, :. 3 11• . C .U, P 4:ik., , , j • {a n 1jj..��,,�����td •� - -�. • n�cafors w,�r „; +'w � o ,,,4 .�+ v! 1 N m , cn•::✓ F,•. ..r -c.,�' csr..: or:. 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M f ' • y" fir' .✓. "' F: , i4 i^ a .f Y'l ! . •�{`,: -..'73 ,w i ♦; .0 '•.t :iS'r,= tt l +` .'3Y'v �j}'�';7.r .'Sub• o atoi`.ChtiracterStics�•�•�irQ �3 "•''S';r•'t.,%i,� %�^�i. ' :z<. ✓t?'r, a 3�y..: : <3s3�_ >.'�;:.a "'�' •4:5 : :` } I :', dh.,;.Y '3f� - j ,,W,; r A:•. •.5. n 1i•.:f5.•Tt: 'PRO .;�.• .: "'B=•': '.r >•: ::.Y• ^n A:: l �'!•:`iFM r. t.ti�Tox';,< •E •.!'. ,:: {i `f r. ' ; rt. fi t:. { :.r ;i : •., vrS.�.:�i. q i sh: » �.. . -Ir„i: ' :. .., i f �9 °::`.00ru' ' x:' .v�r ?.r h '-i. .iN.37. Subpopulation Size Growth and Survival Life History Diversity & Isolation Persistence & Genetic Integrity !� yyr: ✓.y i•. ;•s• Wit:.?. N r Y . : . F cj,n:M..;,l.., ... ,..y ^f + �'?.' ''ci;y • N 'r; ?rte �:t:i sYc•::',:' ''s:�"�`7'.. _ S� .3 { ou �� �.- ..A : r}•'�. NSe .• ! , A !{:'�.i r-,`i tt;,4h '. yt r,.y.. ,, �..._ f. .. .. �J.x. ,c n *.rr+..J $( +'t'1.. : } 3 .'f • I` t vf Y. �"�t •��•r��.J`. :�:' + "[:may �Sfti• -. �y <.:.r- n�, .^.. t ... �- . - . E1rii. -,�i'• �( }p.'fpi,�.T kntir4,, �. Gr" �`. �"' •,:Y- t`�;.��,'-iX:...T�Sv;^.:.. '.... �{- .Yx7' XW't5%. </i3:i).�'�:!rfik• a •. }.,�- etftF•,, j J, > ��. f j �. - .�Itb •t� �C•lt ». ' >alD!�n... � <., •r ;? � " 5• _ ,„,,, u , �S.• .t•, ^Y.. ; ',C2:.ti?ti!,» .�.K1+'.,-....•' : • M ,. t' " y L.y.. . `+ [ 5 /�,�•} - '�✓i':v.M �Sr}(. Temperature Sediment Chemical Contamination/Nutrients , ' . ; •;V:pvxy ,..f .7' r'.'+ }l� X ii[ "n.:+�:yy. ..1;'?' -Kf:• i -; J `'. .. ,•: J,�(� ••i �:P. '.4':,;: =',p'l "•,': '`' ..G S+�' ^:ti.��. ;:., ra n. r�S ".Y• >•°' >:i.+ ':,t??. ?' f 4 t`ie -r: �.:•r.:� .sir lad: , c t '.nF' t i� �.•'" iP r :'• • ' , {,, ':1'` , el... x, . q , ,� '>LZQfC �•*' � r.��•e.! �� � : ih�:�C`� ..Y2 �;�. r',M1 .r �"'3r„°,.f:•a� �•�^••j� .f..Jari3. ,�, �d.', .tV� t:t,`:� 'l ;l, i:oni ,:3, h�.. �.>:�' t,X::`�'•''�t .,!'�f'i>Y, acriu <` �i<,.t. . "�4.:;i•b`. �'' �'•s��. Mali Lilf.. �Z �• �I....S�'Rr..,,Fe�J."d,xrs...in ysk' �' n.. f.-.._..., t�. �i{ E3w�':.,... :r. ...�.,��Lr„•..xA'YS..r•.•:. %�i.'�u�`.. .'k� . [Sr.'tr �: t{rt.. ...... .t:t:' .. ... .... .. ..u..e .Y,.... ter,. r'x,... �. �:�F.. .... t �'� . ' j ," S•4 Physical Barriers 1 !r •»4,t n'+Y:t1fi;JOt:.yy:: ^ Y.'! .. 5 `r : ` 'i """ n u'�y` S ' 2 ,, t ;'.4 rs.Y. : %5q � ' .H;l yi _ ;T_' ( t: "'. :-:T C x S i;' `� f : v ' a,� s;��`.t:: r�'� q , i ; %.E' i;i' '�,4tt?3 "r.' . s au .,�;. � £ �', t4• .Gy'.t•'Ji:.. �tJ.: d:T%.:rY�'•%?, i. `,�it':�: .ci+.� :. .y'- g3.•4:.r;- �..Rar;Y/:i� ?. .� .Yi•.' to .d eta t 1�CX1 n. ��•. �t 'xi::, .'Y%i�,tTJ�fKrrkii!M.�,"�S. `4 �`.�... N 3, 3�. +.r�»� ' iiiiI t Isr u ", �,,� � 5 �a�.. '' 43-4 i3'�'�.- $ 4 '4d [. 0 Via.` :, � ;,.�;• 5. ,,v s -P ,' haft. Substrate Embeddedness Large Woody Debris Pool Frequency & Quality Large Pools Off - Channel Habitat Refugia t „ x z. .r �•' ..d" - . •nrrnt • »av:a'.:w. »ti t,:••:!?c[r ?•.;? :ti '�� , -� v T.-r :,1::;' �:,'FC;: , .. i. ;. ;:r.•r.�.a a ,• i ; _.�:T,r,..• y .$ r. -,2 �, _ ;`r °'' -: +.i i'•'?'' fi ' ".Y,.,ksi> r,,.� Clzanne7 •� �:ccd,•'� �`.�LL ;,,� ;,�' r >.:� r,,. � 1 S4" 'i• '._.�95!5"i'rrt�5'. +.'':' h :4��T, ;';t'::v. }uJ+ {? �+ � ^.Y.S >�: a'.c: - .�t '�,�• ; to y ?.• ^ • w ' ;'i :r>:;,,,.r . f. ;a i{ " "-'.,%* . �F .tom.. <:.- �:� >�4n�' .:Rfx.�� >a %' ".: Y �'.- . T 0. r : ac� °: 4 s ' ..•.��,.:��� .1r� %' Wetted Width/ Max Depth Ratio Streambank Condition Floodplain Connectivity t:� *aTrt!e - vKi'h4::»•": [Yl ".a' 1.•�{�� 7:s�G,•t..'. `� :`th'r'FaI�S >.: :!'{ - r., rf- �.,�a,�v.�.rY.�..4 n�- x�:•S1.i'. t: .� �..� <•• Q: �y/�yy{a'y. 1L.olo igi y�!!{{{yy'jj i••` F•i :,i. 115; P',P•'ri�i,�:> .. i'.' 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(r ':i. . �\ '.f.i..,r2 ; �', ^,2' ja'Yi tc' .,X!_.J: `^:.t . ,3— 10-,:•:.: :.i,a,:.l- h .'i •i r1 .f . j'e- 4S✓J a '-: l Ater .Sl�lS_di+.l`+ondlUOn. . _.. s:..,, t;. �: i'{'2 .�:..,. .et ?St...; �i" }. +;c. .,.. .... _F._...._.... s. <`�t.. z''� ..u.....�... r., .:X;^'.:.... ,..'t,.. r..:•a^'•.:n , ,. .e'�5 .. r c'1� . . , Road Density and Location Disturbance History Riparian Conservation Areas Disturbance Regime ' Lnx "S: i�.:Yr.' � >wv' v;t:s ,4'- r4 SC. »tJ � ___ p45y:43 ^»4.'+ r't. i:1 .'.'r. . °�',�T.' r : xG .� xt;: a - hr:a : [ 1�.. ' .:'t, ++.-. n• rA . -i.>r .ja'`a,'r;'.l•N :i a . " l' ;sc;: vyir•- �'Infegrsiion;of, Speci a nii: �' Iabi�at�eonc��itiionsr := ?���� „�,Y:- ,...,;�. -. < �., �ft,;T �:,.} r.;.. ��,.,::,.,. ...•��.�t�: .�- :,�= 1, :':i >v > - ` ' ✓ 'w % yt�•:�if ° �..:'; t...T...,;�; .t....u� _ : {''° � t�. �;_ •' '4' ,r.�i�git ^/5' ,.,,, ,r 1>?: fi Il i I i( Table D -1. USFWS MATRIX- Checklist of indicators for documenting the Environmental Baseline of the Duwamish River Estuary and the effects of the barrier wall installation. I:\Projects \WCIA \02153 - 01000496 RCI Former Rhone Poulenc Site \IMWP\Engineering Report\Draft Engineering Report\Appendix- Biological URS CORPORATION Assessment.doc Drainage Network Increase �j �� g of "h ty(b�0y�kaiti ift+ T it:".N Sr•ftr } ,.5... aR. �s `4r, il;.. ... .!�?:•C� ?rr, ..�. .i ..wa. e sr?• a•.'��i:, SS , : ;,.. 1 V " 'tte7+riS: 1.;WSta'... ,.fxP+w.MgV._ ° ''. .:.t... I �4• . I a's' : r"'a�3;SA" -w •< ' s S...,: NIV ,..'fit.. �4K. .. . I -.. �L ' >.:�c �s�Ca'z 1.. .�r. I '.z9 --.6 Y 1. ., � a. 0, *.til . ftt,.,l Table E -1. NMFS MATRIX- Checklist of indicators for documenting the Environmental Baseline of the Duwamish River Estuary and the effects of the barrier wall installation. Change in Peak/Base Flows Road Density and Location I:\Projects \WCIA \02\53- 01000496 RCI Former Rhone Poulenc Site\INIWP\Engineering Report\Draft Engineering Report\Appendix- Biological Assessment.doc URS CORPORATION F yn ::. !' .,wcagx4,rtx5 t40,. .;_? ;s , *:14Cl1:14n aL ; �. ?' '� . .�. x Imp�r.,o',�veii it � edr egradec :. 51 mraem s~i t'.Q•FIiL'.��•��dsum.. .. s a�k.� hti :av Temperature Sediment Chemical Contamination/Nutrients Physical Barriers 00r nt's Substrate Large Woody Debris Pool Frequency Pool Quality Off - Channel Habitat Refugia Wetted Width/ Max Depth Ratio Streambank Condition ter: > i< Baseline.* ,y , awe 1J ;E a���le�' �c R Yna O,.F: r t+sa it3 ri.V ;• �µ , .;ate , �nr y ' Floodplain Connectivity i III ryry t� �'k` l�s»:+ MMI x'1,`tV, �. Q8 �f?.�.'.`L,:'K�°;�'�`:s' �i��' •`c`.�''i'= �'E:.''Yi•`r. =�`' ti.•`$i`2 }- 4^`�y��;�(; �= L�� > <• :•..,�;'".� { � 'r €`�"� . +:%•: .y .. - 1n•fi'a.w.: `.. S t i w S+.¢, •ri „!�T!':Ls.ii:ti��'L��..: '� L i q 4 f , p�} ; 5�.„� }w �SJn ��v��ip�'tn '�T 51�'q���,,•�pt" rr. q F PJI aSF/ t''' H` 9¢` s?- SMa.- v;'lYa..•`"'; „(.i14�4.:35; ?9d5' i .- S ,� ..,. q ty � fi ti a%^ "•� 'r..�r�,a,v� 1. .. ;+ ./'I {.�. 1.�'SS'(t t .C� 'r' 6 l L "' Y•'TL34'..� .a•- a ' 3 4'±�}, „ W4y� r t'+ eft S .`> . ra`. � � ;:.'. :?�?,.�', .lS,.;?.,.x�. � s�,r:�.:[r >... #;ar�''� .. {r'.1 nis,2',�°.4. ,...F:a, ;.y, �� ':- ..�.°:. {,�.rli� .. '',�o�) � .��'��� ..�,� %�' , e::. : S ;k3;:.0 ,Y 'GMAIRdw..y VOSAN 1 �� 'skYaRk.'�'^ S5 :cr°,.:X1�2~,Y} ! ^" P'tME"si< .,eSYX .: n.� l • Disturbance History Riparian Reserves DRAFT INTERIM MEASURES CONSTRUCTION WORK PLAN VOLUME H Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site July 2002 URS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 ,(206) 438 -2700 53- 01000496.00 01000 RECEIVED AUG 2 9 2002 COMMUNITY DEVELOPMENT NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. _. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. L' o•i ■:: Ic 1 44 1-1 c) IN) sto 4 04::0 c:::) .i. aro NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. I Major Divisions !!!! Symbols Typical Descriptions , Graph Letter Coarse Grained Soils More than 50% of No. 200 Sieve Size vela I% of Coarse tined in No. 4 the Clean Gravels (less than 5% fines) 64 i • • •• GW Well-Graded Gravels, Gravel -Sand Mixtures, Little or no Fines e i .' / / Gp Poorly-Graded Gravels, Gravel -Sand Mixtures, Little or no Fines Soft 2 - 4 Gravels with Fines (more than 12 % fines) 10 - 30 GM Silty Gravels, GravelSand -Sift Mixtures r� GC Clayey Gravels, Gravel- Sand -Clay Mixtures Sands More than 50% of Coarse Fraction Passing through No. 4 Sieve Clean Sand (less than 5% fines) :::% SW Well- Graded Sands, Gravelly Sands, Little or no Fines SP Poorly Graded Sands, Gravelly Sands, Little or no Fines Sands with Fines (more than 12 %fines) ;•;.: • ' ' SM Silty Sands, Sand -Clay Mixtures SC Clayey Sands, Sand -Clay Mixtures Fine Grained Soils More than 50% of Material Is Smaller than No. 200 Sieve Size Silts Liquid Limit and Less than 50% Clays ■�■ „ ML Inorganic Silts and very Fine Sands, Rock Flour, Silty or Clayey Fine Sands or Clayey Silts with Slight Plasticity CL Inorganic Clays of Low to Medium Plasticity, Gravelly Clays, Sandy Clays, Silty Clays, Lean Clays OL Organic Silts and Organic Silty Clays of Low Plasticity Silts Liquid Limit and Greater than 50% Clays NH Inorganic Silts, Micaceous or Diatomaceous Fine Sand or Silty Soils CH Inorganic Clays of High Plasticity, Fat Clays OH Organic Siftanic of Medium to High Plasticity, ? Highly Organic Soils I " ' is ts es PT Peat, Humus, Swamp Soils with High Organic Contents (see ASTM D4427 -92) Coarse- Grained Soils Fine- Grained Soils Relative Density N, SPT Relative Consistency N, SPT Blows / ft Blows / ft Very loose sand 0 - 4 Very soft < 2 Loose 4 -10 Soft 2 - 4 Medium dense 10 - 30 Medium stiff 4 - 8 Dense 30 - 50 Stiff 8 - 15 Very dense Over 50 Very stiff 15 - 30 Hard Over 30 CI- Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Key to Log of Boring and Descriptive Terms for Soil Unified Soil Classification System (ASTM D2487 & D2488) Relative Density or Consistency Minor Descriptors Trace 0 - 5% Slightly (clayey, silty, sandy, gravelly) 5 - 12% Clayey, silty, sandy, gravelly 12 - 30% Very (clayey, silty, sandy, gravelly) 30 - 50% 2. Dual Symbols are used to indicate borderline soil classifications Moisture Content Dry Moist Wet Absence of moisture, dusty Damp but no visible water Visible free water, from below the water table URS OT SA Sieve Analysis M Moisture DD Dry Density AL Atterberg Limits HA Hydrometer Analysis C Consolidation Pc Constant Head Permeability Pf Falling Head Permeability DS Direct Shear TX Triaxial TV Torvane Shear LV Laboratory Vane Shear PP Pocket Penetrometer OVA Organic Vapor Analyzer OC Organic Content N Number of hammer blows for last 12 inches sampled WOR Weight of Rod Sampler Symbols 3" O.D. Split Spoon Sample with brass rings Core 2" O.D. Split Spoon with 140lb Hammer /30 -inch drop (SPT) Abbreviations ® 3" O.D. Shelby Tube Sample Grab Sample NOTES: 1. Descriptions and stratum lines are interpretive; field descriptions may have been modified to reflect lab test results. Descriptions on these logs apply only at the specific boring locations and at the time the borings were advanced; they are not warranted to be representative of subsurface conditions at other locations or times. S+E�'r�c+"? f�23HaN^N�nr,M..:.,.� . 777., .., " w ...,... t -.' 77 ......-R Z ,• "--..K - ... ,�,,,?, • CJ o � � m m m w N N SAMPLES . . C7 J MATERIAL DESCRIPTION o N o g� � U J 0 C a (Y � n.< Cl) C a° - (� � c .co Cl) C m n.0 REMARKS m ig F— Z . N � I N ... 0 N CO 0 • Note:, All geotechnickll samples collected in 1 - - 1- gallon ziploc bags _ Chemical samples collected in 2-oz ant 2 8 rs. 3 4- • - -10 5--7 0820 N =5 Dark gray, medium to fine SAND (SP -SM) with some brown silt (some petroleum odor) 0.0 0.3 1 -VOC, 1- metals Duplicate sample 6 / .- (Moist)(Loose) - B -1-4 collected of B-1 -1 (0845) 7 8 - - 1 9 10 r 0825 N=4 ° Occasional roots 0.0 0.0 1 -VOC, 1- metals 11 r 12 - 13- 14 s- — 0 15 0830 N =2 <; Dark gray, medium to fine SAND (SP) with some orange, medium grains 0.0 0.8 16 :;. (wet)(Loose to Medium Dense) (no strong odor) - 2 • 17- 18 - ;r 19- -- 5 20 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Date(s) Drilled 6117/02 Drilling Method Hollow Stem Auger and Mud Rotary Drill Rig Type Formost B - 59 Groundwater 14 Ft. Level Diameter of Hole (inches) ' Diameter of 4.25 Well (inches) NA Type of Sand Pack NA Logged By C. Castro Drilling Holt Drilling Contractor Sampler Type Split Spoon, Shelby Tube Drill Bit Size/Type 4.25" HSA (140# Auto Hammer) Type of Well Casing NA Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. J N. Ytp •y%+.+ ' , :qi.;': ;,y tA . • ■ Log of Boring B -1 -02 Sheet 1 of 4 Checked By Total Depth - Drilled (FT BGS) 77. Surface Elevation Top of PVC Elevation Screen Perforation D. Hawk 14.70 MSL NA NA m-c..r +ww.`iaiti{o40.:3M.{C>'iy!Y+' 114 1 i I •■••■••■• • ■ Project: Rhone-Poulenc Project Location: Former Rhone-Poulenc Facility Project Number: 53-01000496 Log of Boring B-1-02 Sheet 2 of 4 --15 --20 --25 --30 SAMPLES .0. ili o.4-• .0 0 0 0 E ›... = I-- Z 20 0 21 22 - 23 - 24 25— 26 - 27 - 28 - 29 - 30-7- 31 32 - 33 - 34 - 35 36 - 37 - 38 - 39 - 41 / 42 - 43 - 44 - 45— 46 - 0835 0855 0925 "6 3 N=10 N=13 N=13 :E 0. 0) MATERIAL DESCRIPTION Occasional silt and gravel layers. Grades to fine SAND URS 0 0. E 0 0.0 0.0 0.0 REMARKS Mud slurry introduced after 20' bgs ..„,I=4.44;;;01'111,11.11:1`''' •-;;;;#7 11"..1,41,C-4134:1641 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53 -01000496 Log of Boring B -1 -02 Sheet 3 of 4 --35 --40 --45 - -50 --55 SAMPLES m 0 . a) 0 w 47 - 48 - 49 50 51 52 - 53 - 54 - 55— 56 - 57 - 58 - 59 - 60� 61 62 - 63 - 64 - 65— 66 - 67 - 68 - 69 - 70 71 1 72 - 73 - a) T F- ar .0 E z CO m 0935 0950 1005 0 3 m N =5 WOR WOR 0 .0 D. 0) (9-i MATERIAL DESCRIPTION Dark gray very silty fine SAND. (Loose). Dark gray SILT with trace sand. (Very Soft) C 0 a) 0. 0 0 O J N cC 0) C cr) N 0) C a) 0 a) Q CCB 0= O.v REMARKS Probable location of upper aquitard (see CPT -03) No recovery l r Project: Rhone-Poulenc Project Location: Former Rhone-Poulenc Facility Project Number: 53-01000496 Log of Boring B-1-02 Sheet 4 of 4 --60 --65 --70 --75 --80 --85 a) a) Ca 74 - 75 76 77 78 - 79 - 80- 81 - 82 - 83 - 84 - 85- 86 - 87 - 88 - 89 - 90- 91 - 92 - 93 - 94 - 95- 96 - 97 - 98 - 99 - 100 SAMPLES CU 0. l .0 E 0 1015 0 NA . 0 .7 0. CUD) " 0 —J MATERIAL DESCRIPTION Boring was completed to 77' bgs. URS a. 0 0 REMARKS Shelby pushed in and allowed to rest for 5 minutes so that full recovery could be achieved . . • Dates) Drilled 6117102 Logged By K. Dressen Checked By D. Hawk Drilling Method Hollow Stem Auger Drilling Holt Drilling Contractor Total Depth Drilled (FT BGS) 72 0 Drill Rig Type Forrnost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 15.10 MSL Groundwater Level 14.5 Ft. Drill Bit 4.25" HSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Diameter of Hole (inches) ' Diameter of 4.25 ; Well (inches) NA Type of Well Casing N ' 4 Screen Perforation NA Type of Sand Pack NA Type and Depth NA of Seal(s) . Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 C —) O U) m 2 may tu -15 -10 -5 - SAMPLES a o,a? 0 6 16 17- 18- 19 - 20 0 .0 � rn C9 J -..2 -3" asphalt MATERIAL DESCRIPTION 2- 3- 4- a) 0. 5-7- 15-7- 1.- 0) E z 0 0 0 0 m s t— N 0845 0853 0857 0 0 0 O N =0 N=4 N =2 Brown, medium SAND (SP) grades to gray to black, medium to fine SAND. (Moist). Gray to black, silty SAND /sandy SILT. Fine to medium sand. (Moist)(Very Soft) Gray to black, medium to fine SAND. (Moist)(Loose to Medium Dense) V 0 0 m 0 d E 0 0 O) C V 03 CC m 0Q 0 0) C •0 -.. as 0 M m� n .v Log of Boring B -2 -02 Sheet 1 of 3 REMARKS I Add Mud to Hole I I Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53 -01000496 Log of Boring B -2 -02 Sheet 2 of 3 - -10 - -15 - -20 - -25 - -30 SAMPLES s m T 20 7 21 22 - 23 - 24 - 25- 26 - 27 - 28 - 29 30-7- 31 32 - 33 - 34 - 35- 36 - 37 - 38 - 39 41 42 - 43 - 44 - 45- 46 - 40-7- 2 I d) .O E z v ID 0902 0920 0930 O 3 0 m N =5 N =8 N =5 C.) N 0) C9.° MATERIAL DESCRIPTION Gray to black, medium to fine SAND Gray to black, medium to fine, sandy SILT (ML). (Very Soft to Medium Stiff). URS U) 0) CD 17 a) CL CI 7 as N 0) m2 cc 3 ii? REMARKS Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 •Vati YO Log of Boring B -2 -02 Sheet 3 of 3 C- 1g > w e) --35 --40 --45 - -50 --55 SAMPLES a) a) I- Z 47 - 48 - 49 - 50-7 ,� 51 1 52 - 53 - 54 - 55- 56 - 57 - 58 - 59 - 607 co 61 1 62 - 63 - 64 - 65- 66 - 67 - 68 - 69 - 70-1 c, 71 72 73 - U O U m i= g; 0945 0959 1015 O 0 Ed Grades to clayey SILT. Boring was completed to 72' bgs. N =4 N =1 NA U L n. 0 _i MATERIAL DESCRIPTION URS REMARKS T Probable location of Upper Aquitard. I Date(s) Drilled 6/14/02 Logged By K. Dressen Checked By D. Hawk Drilling Method Hollow Stem Auger Drilling Holt Drilling Contractor Total Depth _ Drilled (FT BGS) 72 0 Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 15.00 MSL Groundwater Level 13.5 Ft Drill Bit 4.25" NSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Diameter of Hole (inches) 4 ' Diameter of .25 ; Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. robe. u. 13 I? a Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -3 -02 Sheet 1 of 3 —10 n• a) 0. I— Z 0 2- 3 - 4- 5� 6 7- 8 9- 157 16 17- 18- 19- 20 SAMPLES 1100 1110 1116 O 0 0 O m N =2 N =3 N =2 L 0. 0) � Gray to black, fine silty SAND (Moist to Wet)(Loose to Medium Dense). MATERIAL DESCRIPTION Gray to black, gravelly SAND (SP) Grades to SAND. O a m O 0.0 0.0 0.0 REMARKS Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -3 -02 Sheet 2 of 3 - -5 - -10 - -15 - -20 -25 -30 SAMPLES 0 w CD CD 20 21 22 - 23 - 24 - 25- 26 - 27 - 28 - 29 - 30 31 32 - 33 - 34 - 35— 36 - 37 - 38 - 39 - 40-7 41 42 - 43 - 44 - 45— 46 - O 0 3 O in N =8 N =8 N =8 0) .n E z U, CD 1147 U a m (9 J Gray to black, medium to fine silty SAND MATERIAL DESCRIPTION O 0) Q. °)0 O J N 0) cu co— rX Om aco 0.0 URS REMARKS 1 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53 -01000496 Log of Boring B -3 -02 Sheet 3 of 3 - -35 --40 --45 - -50 - -55 SAMPLES 0 mm 0 a? 47 48 49 50 51 52 53 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 a) 0 . a`) .0 E z 0 O 0 O in N=4 N =0 NA 0 m rn MATERIAL DESCRIPTION Gray to black SILT with trace fine sand (ML). (Very Soft to Medium Stiff). Grades to gray to black clayey SILT. Boring was completed to 72' bgs. URS REMARKS Probable location of Upper Aquitard. Dates) 6 6/14/02 L Logged C. Castro C Checked D D. Hawk Meth g H Hollow Stem Auger and Mud Rota D Drilling Holt Drilling T Total Depth 8 82 a. c: L ' 0 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 —15 —10 5-7- 6 7 - 8- 9 - 10- 11 16 17- 18- 19- 20 m iT 15-7 1 m .0 E z SAMPLES 1035 1040 1045 O 0 O 0 m N =3 N =3 N =3 MATERIAL DESCRIPTION Dark gray medium to fine SAND grading to dark gray, sandy SILT (SP). No odor. (moist)(Loose). Dark gray, silty SAND (SM) with some brown sand. No odor. (moist)(Loose) Dark gray slightly silty fine to medium SAND (SP). Slight odor. (Wet)(Loose to Medium Dense). URS s Log of Boring B-4 -02 Sheet 1 of 4 0.0 0.5 0.0 0.0 REMARKS 1-VOC, 1 -metal 1 -VOC, 1 -metal 1 -VOC, 1 -metal Note:,All SP samples collected in ziploc bags I i • a { o 0 0 U .�. 1. E E 1- 0 a M � a 6 m LL ti 5 . a` tx P m cC Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B-4 -02 Sheet 2 of 4 - -10 - -15 - -20 - -25 - -30 SAMPLES N O a) ra H Z 21 22 23 24 25 26 27 28 29 30 31 32 33 35 36 37 38 39 40 41 42 43 44 45 46 1050 1105 1135 O O m N =6 N =21 N =5 t MATERIAL DESCRIPTION m rn C9 J Grades to silty SAND. Dark gray slightly sandy SILT (ML). No odor. (Medium Stiff). 0.0 REMARKS Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B-4 -02 Sheet 3 of 4 --35 --40 --45 - -50 - -55 SAMPLES N m w ❑. T I- Z U 0 U (1 t N 47 - 48 - 49 - 50 51 52 - 53 54 - 55- 56 57 58 - 59 - 60 a) 61 62 63 64 65- 66 - 67 - 68 69 - 70 71 72 73 - 1145 N =2 1200 N =2 O1 1220 NA O 0 3 O Fla U L N CO 0 J MATERIAL DESCRIPTION Grades to dark gray clayey SILT. URS fn C) C - e w U pm N C) C :5— a) 0!g 03 1 REMARKS I Probable location of Upper Aquitard. I 1 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B-4 -02 Sheet 4 of 4 --60 --65 - -70 - -75 --80 as „a) 0 0 74 - 75 76 77 78 - 79 - 80 81 82 83 - 84 85— 86 87 88 89 90— 91 92 - 93 - 94 - 95— 96 - 97 - 98 - 100 SAMPLES m 0)) .n a. E z 99 - 0 U 0 U 0 `c E0 1—N 1228 1250 0 NA NA U 0. rn C9 MATERIAL DESCRIPTION Olive to dark gray, medium to coarse SAND (SP) with some gravel. Boring was completed to 82' bgs. URS C O 0. X U REMARKS Dates) Drilled 6/13/02 6/14/02 Logged K. Dressen By Checked By D. Hawk 1 Drilling Method Hollow Stem Auger Drilling Holt Drilling Contractor Total Depth - Drilled (FT BGS) 72 0 Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 15.70 MSL Groundwater Level 9 F t. Drill Bit Size/Type 4.25" HSA (140# Auto Hammer Top of PVC Elevation NA Diameter of Hole (inches) ' Diameter of 4.25 ; Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) Na . Comments Gravel surface conditions. Soil boring backtilled with bentonite chips. 1 ti Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 -15 -10 W 0 2 3 4 5-7- 6 7 8 9- 10- 157 16 17- 18- 19- 20 N SAMPLES 0 cu 0 0 E � O o 0 0 m N =3 1/18" N =2 m 0) 0 J MATERIAL DESCRIPTION Brown SAND (SP) Gray, medium to fine SAND (SP) (Moist to Wet)(Very loose to loose). Grading to brownish SILT. (Soft). y4 4 [ Si " 1. ;ifrOMIIOIO:740.1 SgAe?C- *%S'�:• Log of Boring B -5 -02 Sheet 1 of 3 C 0 w Tv" E U 0.4 5.2 2.6 y 0) C co o ca N C = a0 REMARKS I r ; Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -5 -02 Sheet 2 of 3 Report: RP: Project File: SAANNC-1112P2.GPJ; Date Template:WC_CORP1.GDT Printed: 7111/02 r a,a) om 20 SAMPLES Graphic Log MATERIAL DESCRIPTION - Well Completion Log PID Readings (Auger) PID Readings (Sample) PID Readings (Cuttings) REMARKS Type Number Time 24 -hr clock Blows /foot / 4 9 9 N =3 ',;: • Gray, medium to fine SAND (SP). 5.9 (Loose to Medium Dense). 21 /_Z .. 22 - 23 - 24 - - 25- - - 26 - - 27- - 28 - 29 - 30 N =11 — 31 - 32 - 33 - 34 - ' : 35- - 36 <: "- - 37 - - 38 - 39 - , 40- N =12 41 42 - 43 - 44 - - - 45- - - 46 - 1 TID ; Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -5 -02 Sheet 2 of 3 Report: RP: Project File: SAANNC-1112P2.GPJ; Date Template:WC_CORP1.GDT Printed: 7111/02 8 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 -•-35 --40 --45 -50 - -55 SAMPLES w a) a) 0 w 47 48 - 49 - 50 51 52 - 53 - 54 - 55- 56 - 57 - 58 - 59 60� 61 62 - 63 - 64 - 65- 66 - 67 - 68 - 69 - 70 71 72 73 - a) a a� E z O w m U L Ea MATERIAL DESCRIPTION Gray clayey SILT (ML). (Very Soft). Gray, fine, sandy SILT. (Very Soft). Boring was completed to 72' bgs. U, m N =1 1/18" NA URS 1 Log of Boring B -5 -02 Sheet 3 of 3 REMARKS Probable location of, Upper Aquitard. I Shelby tube sank 14 I inches under weight rods. - J m m a ww ma 0 0 SAMPLES La CO e t.7 -1 MATERIAL DESCRIPTION o . o o 3 c� rn C m rn 07 aQ en C m E Om E rn C m rn 0 p.° REMARKS a) € T 7 l Z 0 mL E• F N ° 3 o CO Surface Elevation 16.00 MSL Groundwater Level Drill Bit 4.25" HSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Light to dark brown SAND (SP) (no staining) ' Diameter of 4.25 ; Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack -15 1 Comments Gravel surface conditions. Soil boring backfllled with bentonite chips. - 2 - 3 - 4- - 5-- — 1425 N =5 Brown SAND with some gravel (moist) (no odor) 0.0 1.8 0.0 Grading gravelly -10 6 / - 1 7 8 - Boring terminated at 8' bgs due to refusal Redrill 5' NE of this location 9- - - 10- - - -5 11 - - - 12- - - 13- - - 14- - - 15- - - -0 16 - - - 17- - - 18- - - 19- - - 20 TTD Date(s) Drilled 6113/02 Logged C. Castro By Checked By _ D. Hawk Drilling Method Hollow Stem Auger and Mud Rotary Drilling Holt Drilling Contractor Total Depth Drilled (FT BGS) 8 0 Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 16.00 MSL Groundwater Level Drill Bit 4.25" HSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Diameter of Hole (inches) ' Diameter of 4.25 ; Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfllled with bentonite chips. Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -6 -02 Sheet 1 of 1 pi:r`� 33 iYi:t�� f � S ?.9Wll�Cq e .i,'AC1 t rgterrr 474, }n. » :a.,;.`.iLf`V.. ..x+i. , Dates) Drilled 6/13/02 Lo C. Castro By Checked By D. Hawk l Drilling Method Hollow Stem Auger and Mud Rotary Drilling Holt Drilling Contractor Total Depth - Drilled (FT BGS) 4 Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 16.10. MSL Groundwater Level Drill Bit 4.25" HSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Diameter of Hole (inches) 4 25 ; Diameter of NA , Well (inches) Type of NA Well Casing Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) NA - 4 Comments t._ Gravel surface conditions. Soil boring backfilled with bentonite chips. l Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53 -01000496 15 10 5 0 a — 0 a 0 10— 11 - 12- 13- 14- 15— 16- 17- 18- 19- 20 SAMPLES O o 3 O 0. 0 C9 J MATERIAL DESCRIPTION Boring terminated at 3-4' due to refusal. 0 m a 0 E . 330 .. AVMTS#1 ° �':L'G'e .I;! Log of Boring B -6A -02 Sheet 1 of 1 N C) N 3. cCB 7 REMARKS Dates) Drilled 6/13/02 6/14/02 Logged By C. Castro Checked By D. Hawk Drilling Method Hollow Stem Auger and Mud Rotary Drilling Holt Drilling Contractor Total Depth _ Drilled (FT BGS) 82 0 Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 16.20 MSL Groundwater Level 13.5 Ft Drill Bit 4.25" HSA (140# Auto Hammer) Size/Type Top le of PVC Elevation NA Diameter of Hole (inches) ' Diameter of 4.25 ; Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfllied with bentonite chips. • Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -6B -02 Sheet 1 of 4 • C J ow CI) a) in . a) -15 -10 — —0 SAMPLES 0 a a) ) m 0 w 0 2- 3 4- 5- 6 7- 8 9- 10� 11 17- 18- 19- 20 N 1520 1525 O 0 3 0 m N =2 N =1 MATERIAL DESCRIPTION Light to dark brown, medium SAND (SP) with gravel. (Moist)(Loose). s Dark gray, fine, silty SAND (SM) with some black stains (medium plasticity) (slight odor, staining). ;;r (Wet)(Very Loose). N O) 0 f ) ) N 0 3.4 REMARKS First sample at 10 feet. Sample at 5 feet in B -6-02. Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 - -10 - -15 - -20 - -25 - -30 SAMPLES U `. O o.4-. n O s nra) m E t 3 0 . F— Z f— N co O _) MATERIAL DESCRIPTION 20 1530 WOR Dark brown, very sandy SILT (ML) (medium plasticity). (Wet)(Very Soft to Very Stiff). 21 22 23 24 25 26 27 28 29 30 31 32 33 35 36 37 38 39 40 41 42 43 45 46 1545 N =3 1615 N =17 Log of Boring B -6B -02 Sheet 2 of 4 N or or 0) O) 0) C C C _ C_ O O^ �N N� m� or CO CO O CI M REMARKS Mud rotary started at 30 feet. No recovery, catches broken 1 Catcher replaced 1 l I I Project: Rhone-Poulenc Project Location: Former Rhone-Poulenc Facility Project Number: 53-01000496 Log of Boring B-6B-02 Sheet 3 of 4 - -35 - -40 - -50 --55 .111••■■•■ SAMPLES a) ▪ a) 0 47 48 49 50 51 52 53 55 56 57 58 59 60 61 62 63 65 66 67 68 69 70 71 72 73 O. I cS .0 E z 0 0 0 a) 2E E gi 1630 0820 0830 0 0 N=10 N=11 WOR 0 0 m MATERIAL DESCRIPTION Grades to gray to olive gray very sandy, clayey SILT. Grades to clayey SILT. 0 cu 0. E 00 5. C.) in 0) CO CO (1)Z U. 0 a; — co REMARKS 6/14/02 Begin drilling (0810) Probable location of Upper Aquitard. Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 --60 --65 - -70 - -75 --80 0 a l - T 74 - 75 76 77 78 - 79 - 80 81 82 83 - 84 - 85- 86 - 87 - 88 - 89 - 90- 91 - 92 - 93 - 94 - 95- 96 - 97 - 98 - 99 - 100 a`> .O E Z SAMPLES 0845 0905 O O 00 NA NA ` CD J MATERIAL DESCRIPTION Boring was completed to 82' bgs. Log of Boring B -6B -02 Sheet 4 of 4 to rn rn C C C C O "0 'D.-. 'O N CD (6 d f9 arr.: ce �s m E0 0= Ow 0= UJ as a� n REMARKS R +N I '1 1 ro., • byFt4b w. -6i' .. .16.:�`,L OC,„:---1-' MI5 I. a n � Ow 0 SAMPLES s m (7 J MATERIAL DESCRIPTION rn o a, d E o v 9 N c . cc m 0 m o.< to C m a cc O m a� y a c 0. o..° REMARKS T o i- z U E 4 i= N y o m Groundwater Level 17 Ft. Drill Bit Size/Type 4.25" HSA (140# Auto Hammer) Top of PVC Elevation NA Dark brown fine to medium SAND (SP) with trace silt. . Type of Edell Casing NA Screen Perforation NA Type of Sand Pack 1 - Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. - (Moist)(Medium Dense). - 2- - 3 T '- 0915 N =20 t r;: 1.5 1 -VOC, 1 -TCLP —10 4 5— — — 6 - 7- - 7 % N 0920 WOR Dark gray SILT (ML), wood chips, black coloring 2.2 1 -VOC, 1 -TCLP 8 �/ - (some plasticity) (some odor, staining). 9 4 1 (Moist)(Very Soft to Very Stiff) - - —5 0930 WOR - Grades to slightly silty. 2.0 1 -VOC, 1 -TCLP 10 11 - - 12- - - 13- - - —0 14 - - - 15-7 v 0940 N =22 2.0 1 -VOC, 1 -TCLP 16 1 - - 17 - - s- 18- - - - -5 19 - - 20 :•\_ . 1T DC Date(s) Drilled 6113102 Logged C. Castro By Checked D. Hawk By Drilling Method H Stem Auger and Mud Rotary Drilling H Drilling Contractor Total Depth GS) 91.5 Drilled FT Drill Rig Type Formost B -59 Sam Split Spoon, Shelby Tube Type Surface Elevation 14.20 MSL Groundwater Level 17 Ft. Drill Bit Size/Type 4.25" HSA (140# Auto Hammer) Top of PVC Elevation NA Diameter of Hole (inches) ' Di of 4.25 , • Well ( NA Type of Edell Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth of Seal(s) NA Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. • Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility • Project Number: 53 -01000496 Log of Boring B -7 -02 Sheet 1 of 4 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -7 -02 Sheet 2 of 4 REMARKS 1 -VOC, 1 -TCLP 1 - -10 - -15 - -20 - -25 - -30 SAMPLES 0 4 n F- 20 f 21 _L 22 - 23 - 24 - 25— 26 - 27 - 28 - 29 - 30-7- CD 31 1 32 - 33 - 34 - 35- 36 - 37 - 38 - 39 - 40 � r 41 42 - 43 - 44 - 45— MATERIAL DESCRIPTION Dark brown to dark gray very silty fine SAND (SM). (Wet)(Medium Dense). Grades to dark gray in color. 46 - a`) E z U 0 U N 0950 1010 1040 O 0 in N =10 N =19 N =11 UFtS C 0 n O 0 o3 U) 0) C co a) � 0) aQ N 0) C ai CL 0 as a (/) 1.7 N 0) C mu cr) tY 0 E.° I • Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -7 -02 Sheet 3 of 4 iWetiloWAAlgOo Report: RP; Project File: S:IANNC-11RP2.GPJ; Data Template:WC CORP1.GDT Printed: 7/11/02 wa) O a3 SAMPLES MATERIAL DESCRIPTION Z 0 H a E2 0 co W 0 Q E2 W H Q 2 6o- I 601 uonaldwoD II PID Readings I (Auger) PID Readings (Sample) PID Readings (Cuttings) REMARKS Type Number Time 24 -hr clock Blows /foot 47 - r 8 6 oL L - 48 - - 49 - 50 / 1055 N =3 : ' Dark brown, fine SAND to sandy SILT (SM -ML). (Wet)(Soft). 51� - 52 - • - 53- • . ' - 54- • 55— • • — • 56 - - 57 - - 58- - T N 59- . 1005 WOR 0 • • Probable location of 60 / / Dark brown, clayey SILT /silty CLAY (MUCL). ii (Wet)(Very Soft). Upper Aquitard (see 61 / /'1' - CPT -02) 62- O 0 - 63- 110 64 - I 65-1 OS 0 0 NA • 67 01 68 - OS O 69- 'j1' - 1135 WOR ''1 %4 70 Olive gray, silty CLAY (CL) (medium to high 71 (Wet)( Soft). - 72- 73- I Irma • Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -7 -02 Sheet 3 of 4 iWetiloWAAlgOo Report: RP; Project File: S:IANNC-11RP2.GPJ; Data Template:WC CORP1.GDT Printed: 7/11/02 Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 C J oco mm W --60 - -65 - -70 - -75 --80 - -85 SAMPLES 0 0 o 0 iii O U m o 4) m N 0. a) O. E '= 3 co FT o >. Ev -° E o I- Z i- N m 0 J MATERIAL DESCRIPTION 74 - 75- 76 - 77 - 78 - 79 - 80- 81 82 - 83 - 84 85- 86 - 87 - 88 - 94 - 95- 96 - 97 - 98 - 99 - 100 89 - 90--/- 91 92 - 93 - r 1150 1215 N =36 N =26 Gray, fine to coarse silty SAND (SM) with trace gravel. (Wet)(Medium Dense to Dense). Occasional shells. Boring was completed to 91.5' bgs. N C) C @N Wi �m Log of Boring B -7 -02 Sheet 4 of 4 REMARKS 1 Drillers notes gravel .I slurry trough StEritMStsaatt2=4, Dates) Drilled 6113102 Logged By K. Dresses Checked By D. Hawk Drilling Method Hollow Stem Auger Drillin H Drilli Contractor Ct pp Dri lled (l T BGS) 80.0 ) Drill Rig Type Formost B -59 Sampler Split Spoon, Shelby Tube Type Surface Elevation 14.50 MSL Groundwater Level 12 FL Drill Bit 4.25 HSA (140# Auto Hammer) Size/Type Top of PVC Elevation NA Diameter of Hole (inches) ' Diameter of 4.25 is Well (inches) NA Type of Well Casing NA Screen Perforation NA Type of Sand Pack NA Type and Depth NA of Seal(s) Comments Gravel surface conditions. Soil boring backfilled with bentonite chips. u . *e n. cc a Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -8 -02 Sheet 1 of 4 -10 - -5 2 - 3 - 6 - 7 - 8 18- T 5 9 10---- 19 20 m .0 0. - Z SAMPLES 0940 cn N =3 N =2 N =6 N =10 L 0. El-s. 0 C9J MATERIAL DESCRIPTION Dark gray, fine to medium SAND. . (Molst)(Loose). • Gray SILT (ML) (medium plasticity). (Moist)(Soft). Dark gray, fine to medium silty SAND (SM). (Wet)(Medium Dense). 5.0 5.5 REMARKS Mud in auger at 18.5 feet. Z . t Z ce W U0 U 0 U) W J = 1 U) LL 0 g Q N I W Z = I-- 1— O E l- w W U O 1- W W u. O Z W U = • Z Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 - -10 - -15 - -20 - -25 - -30 SAMPLES a) a) G Ow 0 - - Z 20 21 - 22 - 23 - 24 - 25- 26 - 27 - 28 - 29 31 - 32 - 33 - 34 - 35- 36 - 37 - 38 - 39 40� 41 - 42 - 43 - 44 - 45— 46 - v -C / N� 0) V MATERIAL DESCRIPTION O 0 0 O m N =7 N =14 Grades to fine, very sandy SILT. (Very Soft to Very Stiff). y 0) C - C N o to— Ce 0m n-. t/) 0) C co 0 a) °) rYS. EC? 1 F z a •.aw a 5 bi a• Log of Boring B -8 -02 Sheet 2 of 4 It REMARKS F r I 0 7. 7 Project: Rhone-Poulenc Project Location: Former Rhone-Poulenc Facility Project Number: 53-01000496 Log of Boring B-8-02 Sheet 3 of 4 0 ) > 0 0 al - -35 - -40 --45 --50 - -55 SAMPLES _o 0 o I— Z 47 - 48 - 49 - 7- 52 - 53 - 54 - 55— 56 - 57 - 58 - 7; 59 61 62 63 - 64 - 65— 66 - 67 - 68 - 69 70 71 - 72 - 73 - 1- 03 CO 0 0 a) 1 E 0 0 55 N=9 N=1 NA NA 0 0. IP. 0) (.9 MATERIAL DESCRIPTION Grades to olive gray clayey SILT. 0) 0. 9 REMARKS Probable location of Upper Aquitard (see CPT-02) Shelby tube settled 1.5 feet under weight of rods. _ j Project: Rhone - Poulenc Project Location: Former Rhone - Poulenc Facility Project Number: 53- 01000496 Log of Boring B -8 -02 Sheet 4 of 4 --65 - -70 - -75 --80 -45 SAMPLES 75- 76 - 77 78 79 ,/ 80 81 - 82 83 84 - 85- 86 87 - 88 89 90- 91 92 - 93 - 94 - 95- 96 - 97 - 98 - 99 - 100 C ) .a z • O 0 0 0 to N =40 0 -C N O) o3 MATERIAL DESCRIPTION Gray to dark gray, gravelly, coarse SAND (SW). (Dense). Boring was completed to 80' bgs. N 0)_ C 0m N 0) C N a) 0) CLE I REMARKS T Drilling becomes mc'r difficult J tr 5 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN. THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Boring Number Depth (ft) Moisture Content ( %) B -1 -02 20' 27.1 B -1 -02 40' 35.7 B -1 -02 60' 37.8 B -1 -02 75' 31.4 B -2 -02 30' 26.1 B -2 -02 50' 36.3 B -3 -02 15' 28.7 B -3 -02 60' 35.3 B -4 -02 20' 30.2 B -4 -02 30' 25.7 B-4 -02 40' 37.4 B -5 -02 60' 37.8 B -5 -02 70' 40.9 B -6 -02 50' 33.8 B -6 -02 70' 40.8 B -7 -02 20' 26.4 B -7 -02 80' 16.2 B -7 -02 90' 19.5 B -8 -02 38.5' 37.0 B -8 -02 58.5' 37.0 • ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC URS Corporation RCI 1005 -574 Sieve Size (microns) Moisture Content 2 „ 1.5 „ 1 „ 3/4 1/2" 3/8" #4 #10 (2000) #20 (850) #40 (425) #60 (250) #100 (150) #200 (75) B -1 -02 20' 27.1 100.0 100.0 100.0 100.0 100.0 100.0 99.8 99.4 95.3 66.4 26.2 11.0 4.6 B -1 -02 40' 35.7 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.8 98.8 98.2 84.5 50.9 16.8 B -1 -02 60' 37.8 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.8 99.0 97.7 96.1 B -2 -02 30' 26.1 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.5 96.9 80.7 37.3 13.3 7.1 B-3-02 15' 28.7 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.6 99.5 98.5 78.3 41.6 17.7 B -3 -02 60' 35.3 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.6 99.2 97.1 B-4 -02 20' 4.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.7 89.9 39.8 9.0 B-4 -02 30' 25.7 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.1 90.3 53.7 22.1 B-4 -02 40' 37.4 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.5 98.6 97.8 95.0 88.6 B -6 -02 50' 33.8 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.6 99.1 98.2 89.9 57.1 B -6 -02 70' 40.8 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.7 99.5 98.6 B -7 -02 20' 26.4 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.1 87.1 57.4 35.2 B -7 -02 90' 19.5 100.0 100.0 100.0 100.0 100.0 100.0 95.6 85.9 79.1 61.6 47.7 28.1 18.1 B -8 -02 38.5' 37.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.7 98.6 83.1 53.0 Tests conducted according to ASTM D421/D422 URS RCI ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC Percent Finer (Passing) Than Indicated Size 1 1005 -574 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Sieve Size (microns) >2" 2 to 1.5" 1.5 to 1" 1 to 3/4" 3/4 to 1/2" 1/2 to 3/8" 3/8 to #4 4750 -2000 2000 -850 850 -425 425 -250 250 -125 125 -75 <75 B -1 -02 20' 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.4 4.1 28.9 40.2 15.2 6.4 4.6 B -1 -02 40' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 1.0 0.6 13.7 33.6 34.1 16.8 B -1 -02 60' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.8 1.3 1.6 96.1 B -2 -02 30' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 2.6 16.2 43.4 23.9 6.2 7.1 B-3-02 15' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.4 0.1 0.9 20.2 36.8 23.9 17.7 B -3 -02 60' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.3 0.3 2.2 97.1 8-4 -02 20' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 9.8 50.1 30.8 9.0 8-4 -02 30' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.8 8.9 36.5 31.6 22.1 8-4 -02 40' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.9 0.8 2.8 6.5 88.6 B -6 -02 50' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.3 0.4 1.0 8.3 32.8 57.1 B -6 -02 70' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.2 0.2 0.9 98.6 B -7 -02 20' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.8 12.0 29.7 22.2 35.2 B -7 -02 90' 0.0 0.0 0.0 0.0 0.0 0.0 4.4 9.7 6.8 17.6 13.9 19.6 10.0 18.1 B -8 -02 38.5' 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 1.1 15.5 30.1 53.0 Tests conducted according to ASTM D421/D422 t.. _ __ _ URS RCI __ 1 ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC Percent Retained in Each Size Fraction J 1 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEARi HAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1005 -574 1005 -574 N r M cV #20 #40 #60 #100 #200 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -1 -02 20' 1000 100 GRAIN SIZE (MICRONS) 10 1 .100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. . _.._ ._._._ I 1 ...1 _l __1 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -1 -02 40' N :- 4 N I #4 #10 #20 #40 #60 #100 #200 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D -422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -1 -02 60' r N #4 #10 #20 #40 #60 #100 #200 1 • 10000 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. . j .. _1 } _ 1005 -574 #4 #10 #20 #40 #60 #100 #200 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -2 -02 30' 1000 100 GRAIN SIZE (MICRONS) '10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. ree41 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -3 -02 15' N I #4 # 10 #20 #40 #60 #1 #200 a ■ 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1005 -574 s N M #4 #10 • #20 #40 #60 #100 #200 • • 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -3 -02 60' 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR�ThAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -4 -02 20' N c N c co co ( #4 #10 #20 #40 #60 #100 #200 �- J • • 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 PI NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEARIHAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1 _100 50 .I t NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. } 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. j #4 #10 • #20 #40 #60 #100 #200 • • 10000 ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -4 -02 30' 1000 100 GRAIN SIZE (MICRONS) 10 .100 50 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. N to #4 #10 J • #20 #40 #60 #100 #200 10000 ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -4 -02 40' 1000 100 GRAIN SIZE (MICRONS) 10 1 .100 E W z LL C7 z Cl) 50 Q O. H z w U W a. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. _.._y L. __ __ 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -6 -02 50' I #4 #10 • #20 #40 #60 #100 #200 r 1000 100 GRAIN SIZE (MICRONS) 10 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 100 50 1005 -574 100000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. 10000 ASTM D GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -6 -02 70' N c_ J #4 #10 CY) M #20 #40 #60 #100 #200 • • • 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. L__ _ • - 1005 -574 1 000 0 0 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -7 -02 20' i #4 #10 J _ e #20 #40 #60 #100 #200 I • 1 1000 100 GRAIN SIZE (MICRONS) 10 1 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -7 -02 90' N e- M N - C ` 0 • #4 #10 #20 #40 #60 #100 #200 • N 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 1 _100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. L.__.._ L 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY, LLC. ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -8 -02 38.5' kr . I #4 #10 #20 #40 #60 #100 #200 co • • • 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 100 50 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Sieve Size 1" 3/4" 1/2" 3 /S" #4 #10 #20 #40 #60 #100 #200 32 22 13 9 7 3.2 1.3 (microns) (4750) (2000) (850) (425) (250) (125) (75) B -1 -02 @ 75' 100.0 100.0 100.0 100.0 100.0 100.0 99.6 93.7 85.3 75.8 63.9 54.4 47.2 36.8 33.6 27.2 20.0 13.6 B -2 -02 @ 50' 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.8 98.8 82.3 44.6 34.5 20.9 17.3 13.7 10.8 7.9 B -5 -02 @ 60' 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 98.6 88.0 53.0 40.9 30.3 22.7 19.7 14.4 9.1 8-5 -02 @ 70' 100.0 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.8 99.6 98.8 78.4 70.4 57.6 48.8 42.4 30.4 19.2 8-7 -02 @ 80' 100.0 100.0 100.0 98.0 90.8 77.9 58.3 43.1 27.7 19.6 14.4 12.0 10.6 7.8 7.8 6.9 5.5 4.2 B -8 -02 @ 58.5 100.0 100.0 100.0 100.0 100.0 100.0 99.9 99.9 99.7 99.4 87.5 59.2 48.4 33.8 28.4 23.1 14.6 10.0 Testing performed according to ASTM D421/D422 Rosa Environmental Geotechnical Laboratory, LLC URS Corporation RCI Percent Finer (Passing) Than the Indicated Size 1005 -574 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Sample No. % Gravel % Coarse Sand % Medium Sand % Fine Sand % Total Sand % Silt % Clay Size (microns) > 4750 4750 -2000 2000 -425 425 -75 4750 -75 75 -3 <3 B -1 -02 @ 75' 0.0 0.0 6.3 29.8 36.1 43.9 20.0 B -2 -02 @ 50' 0.0 0.0 0.1 17.7 17.7 71.5 10.8 B -5 -02 @ 60' 0.0 0.0 0.0 11.9 12.0 73.7 14.4 B -5 -02 @ 70' 0.0 0.0 0.1 1.1 1.2 68.4 30.4 B -7 -02 @ 80' 9.2 12.9 34.8 28.7 76.4 8.9 5.5 B -8 -02 @ 58.5 0.0 0.0 0.1 12.4 12.5 72.9 14.6 I _ L. _. ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY URS Corporation RCI Percent Retained in Each Size Fraction 1005 -574 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 100000 1005 -574 10000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -1 -02 @ 75' N O o o 0 • • 1000 100 GRAIN SIZE (MICRONS) 10 1 100 80 60 40 20 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. L_ _. r- I 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -2 -02 @ 50' N • • • 0 0 o 0 0 0 • • 4, 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 1 100 80 60 40 0 20 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 100000 1005 -574 10000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -5 -02 @ 60' 0 0 _ 0 CNI 0 0 1000 100 GRAIN SIZE (MICRONS) 10 1 100 80 60 40 20 r � NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • 1005 -574 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -5 -02 @ 70' N t • • o o � 4t 1-- 4t N N. 100000 10000 1000 100 GRAIN SIZE (MICRONS) 10 1 100 80 60 40 0 20 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 100000 1005 -574 10000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -7 -02 @ 80' r N E • • r (7 0 0 0_ 0 a 0 "\\ ti 1000 • 100 GRAIN SIZE (MICRONS) 10 0 1 100 80 60 40 20 EMI NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 100000 1005 -574 10000 ROSA ENVIRONMENTAL & GEOTECHNICAL LABORATORY ASTM D-422 GRAIN SIZE DISTRIBUTION Project: RCI Sample No.: B -8 -02 @ 58.5' 0 • o o o 0 o • 1000 100 GRAIN SIZE (MICRONS) 10 1 0 100 80 60 40 20 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Sample Number Depth Plasticity Index Liqu Limit Plastic Limit Classification B -1 -02 60' NA NA NA Non - Plastic B -2 -02 50' NA NA NA Non - Plastic B -3 -02 60' NA NA NA Non - Plastic B -5 -02 60' NA NA NA Non - Plastic ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC URS Corporation RCI 60 50 G. 20 10 0 Atterberg Limits CL or OL CL -ML ML or OL CH or OH MH or OH 0 10 20 30 40 50 60 70 Liquid Limit 80 90 100 110 T B 1 02 —A— B -2 -02 —*--B 3-02 —f— B -5-02 1005 -574 z W Ce JU 00 cf) W • I H • u-. W 0 ? . co = W z � I-0 Z F— j U O ff' O F— W I 0 I= u'O .. Z W • = O ~ z Sample Number Depth Plasticity Index Liquid Limit Plastic Limit Classification B -6 -02 50' NA NA NA Non - Plastic B -6 -02 70' 13.6 40.8 27.2 ML B -7 -02 80' NA NA NA Non - Plastic B -1 -02 75' 6.0 25.5 19.5 CL X 40 ;+- 30 0. 60 50 20 10 0 ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC URS Corporation RCI Atterberg Limits CL -ML • • ML or OL CH or OH MH or OH r 0 10 20 30 40 50 60 70 80 90 100 1 Liquid Limit —.-- B -6-02 — B 6-02 --•— B -7 -02 — B -1 -02 z il r W J 00 CO W J = • t— � w g a D. z cif t- i z,._ z o. • D ww tL O w z O ~ z Sample Number Depth Plasticity Index Liquid L Plastic Limit Classification B -5 -02 70' 11.8 34.7 22.9 CL ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY, LLC URS Corporation RCI 60 50 d 40 30 t, its Co O. 20 10 0 0 Atterberg Limits CL or OL CL -ML ML or OL CH or OH MH or OH 10 20 30 40 50 60 70 Liquid Limit 80 90 100 110 --.- B 5-02 -A- 1005 -574 Sample ID Depth Confining Wet Density Moisture Content Dry Density (ft) Pressure (psi) (pcf) ( %) (pcf) B -1 -02 @ 75' 75 63.2 121.4 31.4 92.4 7 Rosa Environmental and Geotechnical Laboratory, LLC URS Corporation RCI 2500 2000 1500 1000 500 0 0 0.02 Unconsolidated, Undrained Triaxial Compression 0.04 —♦— B -1 -02 @ 75' 0.06 0.08 Axial Strain 0.1 0.12 0.14 0.16 Notes to the testing: 1. The testing was performed according to ASTM D -2850. 2. The sample had a bulging failure. 1005 -574 Z Z I- W U . 00 co o W = U) u- WD 2 g Q. a I— W 2 Z � I— 0 Z U � 0 N : ❑ F- . W . u" O Z W U 0 f- Z Sample ID Depth (ft) Confining Pressure Wet Density (pcf) Moisture Content ( %) Dry Density (pcf) (psi) B -5 -02 @ 70' 70 54.5 112.1 40.9 79.5 Rosa Environmental and Geotechnical Laboratory, LLC URS Corporation RCI 1600 1400 1200 1000 800 600 400 200 0 0.02 Unconsolidated, Undrained Triaxial Compression 0.04 -- ♦- B502 @70' 0.06 0.08 Axial Strain 0.1 0.12 0.14 0.16 Notes to the testing: 1. The testing was performed according to ASTM D -2850. 1005 -574 i,n•� .w„'MCthv].�sl,.". :r.�r54e�v6L'G��s.��'ne.w ' Sam le P ID De th P (ft) () As Received Sample Parameters After Test Sample Parameters Gradient h/l ( ) Hydraulic Conductivity (cm /s) Wet Density Y Ibs /ft (lbs/ft 3 ) Total Porosity Saturation Moisture Content ( %) Wet Density ty s (Ibs /ft ) Total Porosity Saturation Moisture Content ( %) B -1 -02 75 122 0.436 1.00 30.6 123 0.424 1.00 28.7 27.78 1.10E -07 B -5-02 70 109 0.547 1.00 46.2 112 0.525 1.00 43.1 23.77 1.25E -07 Sample ID Depth (ft) Visual Description Confining Pressure (psi) Initial Average Length (cm) Initial Average Diameter (cm) Final Average Length (cm) Final Average Diameter (cm) B -1-02 75 Clayey Silt 3.0 6.10 7.23 6.02 7.19 B -5-02 70 Clayey Silt 3.0 7.12 7.08 6.95 7.00 ROSA ENVIRONMENTAL AND GEOTECHNICAL LABORATORY URS Corporation RCI Test Results for Flexible Wall Hydraulic Conductivity Testing Notes: 1. The samples were tested in accordance with ASTM D -5084. 2. The tests were performed using tap water for the permeant. 3. The porosity and the saturation were calculated using an assumd specific gravity of 2.65 Sample Description and Dimensions 1005 - ici+e••mxa.:s4xn,wt,. x;9n�w s *s+.:nw..aure+rivS'xWr s::auxwi��e"Jv+� J�*aiaii.:r; NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. The Cone Penetrometer Test (CPT) pplianalidfasumernl Dowmhole Shear wave velocity, Y, URS Speed of push 2 cm/second (=4 ft/minute) A I 1 -meter connecting rod Y If I Sleeve Friction Resistance, f, Cone • Resistance, q, Standard Measurements Friction Ratio =-100 (Electric and Mechanical (Dutch) cones) The basic product of a CPT sounding Cone Resistance, 9c (tsf) Sleeve Friction Resistance, f (tsf) 1000 100 10 Zone q Soil Behaviour Type 1 2 Sensitive Fine Grained Material 2 1 Organic Material 3 1 Clay 4 1.5 Silty Clay to Clay 5 2 Clayey Silt to Silty Clay 6 2.5 Sandy Silt to Clayey Silt 7 3 Silty Sand to Sandy Silt 8 4 Sand to Silty Sand 9 5 Sand 10 6 Gravelly Sand to Sand 11 1 Very Stiff Fine Grained ( *) 12 2 Sand to Clayey Sand ( *) ( *) Overconsolidated or Cemented 1 Bar =1.044 TSF SOURCE: Robertson et al.. 1986 iJR.S 3 5 Friction Ratio ( %), R 6 SIMPLIFIED SOIL CLASSIFICATION CHART FOR STANDARD ELECTRONIC FRICTION CONE ftelf Depth (ft) w ■ Tip Resistance Qt (Ton /ft ^2) 0.0 0.00 1 sensitive fine grained {i 2 organic material 513 clay Predrilled top three feet. r - - Operator: BROWN Sounding: CPT -03 Cone Used: 581 Friction Ratio Fs /Qt ( %) 300.0 0.0 5.0 URS Corporation J J Maximum Depth = 81.04 feet 2214 silty clay to clay El 5 clayey silt to silty clay 6 sandy silt to clayey silt Pore Pressure Pw (psi) 0.0 I I I I — i 1 1 - I - I ( I 1 I 1 1 I I I I I I I I I I I 1 1 I 1 I I I t I 1 I 1 I 1 1 1 f CPT Date/Time: 06 -20 -02 12:23 Location: Former Rhone Poulenc Site Job Number: 53- 01000496.00 Soil Behavior Type* SPT N* Zone: UBC -1983 60% Hammer 30.0 0.0 12.0 0.0 50.0 7 silty sand to sandy silt .Y.t 8 sand to silty sand sand I1I MI^�>•bA� � I I 111 111 III IIII IIII 111 IIII 1111 III 111 :I 1I r;iy rl ■il 1 11 I I I I i I < =r I r/37.71 r 1 11 1 'I ".i I I ): III I 1 III III 11 ill II II II 1' II II II II 11111 IIIII "1 II IIIII IIIII 1 1111 IIIII IIIII 1111 II111 _11111 II Ad'FiA 11 II II 11 II :r' a.l'- '11F15,L1 1111111111 1111111111 III 111111 II III11111 1 III IIIIIII I 1111111111 III i reinmeantom Depth Increment = 0.16 feet I I I 1 I I 1 I 1 I I I I I I 11 I I I I I I I I T 1 1 1 r l 1 1 1 1 1 1 III 1 1 I I I I I 11111 1 I 1 1 1 1 1 1 ; ; I I I I I 1 - 1 II ;III; 11 111 I I I I I I I I I I 11 1 1 1 11111 I I 1_I t 1 1 1 1 1 1 1 1 1 1 1 1 1111111 I 1111 I I I 1 I I 1 11 1 I I 1 I 1 11111 V: 10 gravelly sand to sand 11 very stiff fine grained ( *) 12 sand to clayey sand ( *) 3PPsi LOwL'�L 2 \t� '-rw2G '"`ibepth (ft) . ull uelldvlur Lype aria ar 1 oasea on aata rrom Utyl,..LV .5 { Tip Resistance Qt (Ton /ft ^2) 0.0 0.00 10.00 20.00 30.00 40.00 50.00 60.00 70.00 80.00 90.00 1 sensitive fine grained 2 organic material 3 clay Predrilled top one foot. Operator: BROWN Sounding: CPT -02 Cone Used: 581 Friction Ratio Fs /Qt ( %) 300.0 0.0 5.0 w3 I- I U RS Corporation I I I I I I I 1 1 1 1 I 1 1 1 1 � 6F -I-I P ♦- J I Maximum Depth = 76.94 feet 4 silty clay to clay 5 clayey silt to silty clay ® 6 sandy silt to clayey silt Pore Pressure Pw (psi) 0,0 I I 1 1 I I I I { I I —_I _1_ 1 1 I 1 1 I 1 I I I 1 I I 1 1 I 1 I I I I I I CPT Date/Time: 06 -20 -02 11:01 Location: Former Rhone Poulenc Site Job Number: 53- 01000496.00 30.0 Soil Behavior Type* Zone: UBC -1983 0.0 12.0 I I n -- I I 1 I I 1 I I I I (IIIII "r1.,: ::r 1 4- I-I 1 -1-1 -• '�•� �` -� 1 1 1 1 1 1 � L1 1 I I I I = '•rtjjx / •-r, I I I I I I I III I I I '�.: IIIII I r l I I I 1 1 I 1 I I I 11...1 1 1. i .irlitli,1 I I 141''1 %1`.;1• "� i I Ijcl,rii 1`liI I 1 1 I T r1r l lral;a I I I It f;Q; It1 I I . 1: hI'i1y1) I I I I tY'j1'.;1 yt I I I '4;r.i ?I rIr I I I I 1111 1I I 1111 II I `1 1II 111 1111 1111 1111 II II 11 1 1 1I1 II1 111 111 I I 11I 11 1111 11 1111 1111 111 1 1 I. 1_1 LI_I L I .L 1111 11111 11 111111 1 1II1 11111 11111111 11III11I 11111111 11111111 Depth Increment = 0.16 feet ® 7 silty sand to sandy silt 8 sand to silty sand sand SPT N* 60% Hammer 0.0 50.0 Cmu 111 111 111 I I 1 111 I I I , I ;' 10 gravelly sand to sand 11 very stiff fine grained ( *) ®12 sand to clayey sand (*) UVII uCIIUV VI LJ.I, UI WI - ":depth (ft) 0. Tip Resistance Qt (Ton /ft 1 sensitive fine grained 2 organic material ® 3 clay Predrilled top three feet. Operator: BROWN Sounding: CPT -01 Cone Used: 581 Friction Ratio Fs /Qt ( %) 300.0 0 0 5.0 1 1 1 I- I I 1 I I I I I I I I I I I I 1 I I I URS Corporation Maximum Depth = 84.15 feet 4 silty clay to clay 5 clayey silt to silty clay Ili 6 sandy silt to clayey silt Pore Pressure Pw (psi) 0.0 CPT Date/Time: 06 -20 -02 08:37 Location: Former Rhone Poulenc Site Job Number: 53- 01000496,00 Soil Behavior Type* SPT N* Zone: UBC -1983 60% Hammer 30.0 0.0 12,0 0.0 50.0 .IIIII , t . .�.•.' I I I I I I 1 I I I I I I miaano111. I I I I I ��,� -; �• I I I I I ;•w -h:IIt1l I I I I I 1111 IIIII IIIII IIIII 1 1 J LI.L III 1 ,9,•1.7l I I I t(iLLlh(iL�.Ca I I I II 11111111 11 11111111 1 111111111 IIII I 11111 I l I l i l l l i I l Depth Increment = 0.16 feet ® 7 silty sand to sandy silt 8 sand to silty sand 9 sand I I 1 1 I - I 1 1 1 1 1 1 - 1 1 -1 I -I -I I -1 - 1- 1 1 1 1 r. 1 1 1 1 1 1 1 1 I I 1 1 1 1 1 1 1 1 1 1 I ' 1 1 1 1 1 1 I 1 1 - 1 - I '1 - 1 't I 1 1 1 I I 1 1 1 1 II11 I I 1 1 1 1 I I I I I I 1 1 I I I I I I I I I 1 I 1 I - 1" I - 1 l 1 - 1 7 1 - - 1 1 1 1 1 11 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 11111 III T 1 - 1 - I nr 1 1 1 1 1 11 1 1 1 I 1 1 1 1 1 I 1 1 1 1 1 w 1 I I 1 1I I I I 1 1 1 1 I I ii1i1 1i I I I I I I I I I I I I I I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1_1 1 1 1 1 1 1 1 1 1 I I I I I I I 1 111111 1 1 1 1 1 1 1 IIIIIII 1111111 IIIIIII 1 I I I_I 1 I 1 1 1 1 1 1 1 I I 1 1 1 1 1 1111111 I I I I I I I IIIIIII I I I I I I I 1111111 1_1 _1 L I_I _1 I I I I I I I II 1111 I I 1 I I I 1 1 1 1 1 1 1 1 it 1 I I I I I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 El 10 gravelly sand to sand 11 very stiff fine grained ( *) 12 sand to clayey sand ( *) ■ J , s 1 .' I PLW ' TIC; .0 • CALCULATE THE SLOPE STABILITY FACTOR OF SAFETY FOR THE FORMER RHONE POULENC SITE DATA AVAILABLE: 1. Slope Cross Section A and B from site recon (June, 2002) 2. Soil Properties B -1 -02 to B -8 -02, CPT -1 -02 to CPT -3 -02. ASSUMPTIONS: 1. Assume static conditions only for case 1a and case 2a due to temporary nature. 2. Assume no liquefaction occurs during seismic event in alluvium deposits ANALYSIS : 1. Static Stability Analysis. Case 1a: Cross section A -A' Case 2a: Cross section B -B' 2. Seismic Stability Analysis Case 1 as: Proposed Final Construction for cross section A -A', horiz. Seismic coef. = 0.1 Case 2as: Proposed Final Construction for cross section B -B', Horiz. Seismic Coeff. = 0.1 CONCLUSIONS: 1. Static Stability Analysis. Factor of Safety Case 1: 2.2 Case 2: 1.5 2. Seismic Stability Analysis REFERENCES: ATTACHMENTS: Case 1s: Case 2s: 1.7 1.0 None of the critical failure surfaces occurred within the barrier wall. The conclusion of the analysis is that construction of the barrier wall does not have an effect on the stability of the south or west slopes of the site, although the factor of safety under seismic conditions for the south slope is low under current conditions. 1. SlopeW output figures for each Case. 2. Plan view of locations for section A -A' and B -B'. Job: Former Rhone Poulenc Facility 53- 1000496.00 GAL, 07/09/2002 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. L L 7 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT: RCI Former Rhone Poulenc Facility GW Total Quantity of Water to be Pumped Q (flow) = KiA Where K = Hydraulic Conductivity (cm/sec) i = Hydraulic Gradient ( %) A = Area of Wall, Aquitard (cm2) Calculations: JDL Checked By: n � V .3 gallon /min NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Area Q K i ft2 cm2 cm3 /sec ft3 /min gallon /min Soil Clay Wall 1.00E -05 0.34 61,800 57,414,079 18.95j 0.040 0.30, Impermix Wall 1.00E -08 2 81,000 75,251,462 ' 1.51 0.003/ 0.02, NI J ' Aquitard ''5.00E -06 T) (0.061) 302,000 280,567,18'1..1' 84.17../ 0.178 1.33 �t Total Flow = 1.66v RCI Former Rhone Poulenc Facility GW Total Quantity of Water to be Pumped Q (flow) = KiA Where K = Hydraulic Conductivity (cm/sec) i = Hydraulic Gradient ( %) A = Area of Wall, Aquitard (cm2) Calculations: JDL Checked By: n � V .3 gallon /min NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Job r Description 1 ' � a ( I T t r 1 .! r.k. 1 1 0 c� 0 - g 0 = 3 iv € r- [AJ 5Li ° cb (0 o 1 • dra IA o Page 1 of D-- Project No. Sheet I of Computed by J D L Date 6/ 30 p a- Checked by Date Reference r tvee( p r c '-av r S w, 115 fits7Ler' �y o e5 yea e tl� ( 7 O rc` 0 �� o O ° ,b -C PP/ pa' -rQ � - t 15 • fce. r 5 fer iis /��5 �r�Gf r vt CG. U 1 v4r raL z o r- e v k..r o r- -I e .- o 14" /5 Q ✓J 'a.+ op D7v 0"I 7 re a,Hr r� /mac -�e l/ we 1 .eva r a• - u. 7L • a 010 o*F" 4 e- -1 I f rr ' b-1 // w, // pi r 4 �e--- / (07076) • (3.35 ra,� . f / (36a,t,ao . F�) / ,14'5 ) ay- A-ec•� , H •,a�e S /ate 1ti (f _ /6, '36/. "7 eab/e fee4 oC a✓4,-14 X 7, Sf y c /10, 4 o d 1 /ye/o rL , 475) s (a 5 a ((orb / — /P6., / a 5 r/(0 RV/ 41 1.1 -4 URS it Job _a • Description ►F 3.35 ►Kckes of CtII& e-LA-- 07. ( 4 , , t•P .f • e c- ( 3.3 6 Ifrictre5 0.30'parostt Page of D— Project No. Sheet of Computed by Date Checked by Date Reference 1 k45,Jc- - � t5 . 3a mew. �r 64 ac7 v► ref'. z • L T J ar . 6D ; JU .0 O' .CO J = .U) w. w O: L ¢: LO • =c5 w Z :Z �—: LU o . o N ` ww • u. O • .Z. w Z . L: L L..J L L L.J. I iLJt NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. _ _ 1. Assume static conditions only for case la and case 2a due to temporary nature. 2. Assume no liquefaction occurs during seismic event in alluvium deposits ANALYSIS : CALCULATE THE GLOBAL SLOPE STABILITY FACTOR OF SAFETY FOR THE FORMER RHONE POULENC SITE DATA AVAILABLE: 1. Slope Cross Section A and B from site recon (June, 2002) 2. Soil Properties B -1 -02 to B -8 -02, CPT -1 -02 to CPT -3 -02. ASSUMPTIONS: 1. Static Stability Analysis. Case 1a: Cross section A -A' Case 2a: Cross section B -B' 2. Seismic Stability Analysis Case 1 as: Proposed Final Construction for cross section A -A', horiz. Seismic coef. = 0.1 Case 2as: Proposed Final Construction for cross section B -B', Horiz. Seismic Coeff. = 0.1 CONCLUSIONS: 1. Static Stability Analysis. 2. Seismic Stability Analysis REFERENCES: ATTACHMENTS: Factor of Safety Case 1: 2.2 Case 2: 1.5 Case 1s: Case 2s: 1.7 1.0 None of the critical failure surfaces occurred within the barrier wall. The conclusion of the analysis is that construction of the barrier wall does not have an effect on the global stability of the south or west slopes of the site, although the factor of safety under seismic conditions for the south slope is low under current conditions. 1. SlopeW output figures for each Case. 2. Plan view of locations for section A -A' and B -B'. Job: Tongue Point Landfill Remediation Design 53- F0072199.15 GAL, 07/01/2002 20 10 0 -10 -20 -30 -40 -50 -60 -70 -80 -90 -10 Description: Comments: File Name: Case la.slp Analysis Method: Spencer Seismic Coefficient: (none) ! ICA Dscr ptio 10 n n r r u u u 30 50 70 • • • • • . • • • • • • • • • • • • • • • • • • • • • • • • • • • • . . . . 1 • • • •......•••••••••••••• per 6i{ty €and " 90 . • • • • . . • • . . . • • • • • 2.245 110 130 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 150 Ik 20 10 0 -10 -20 a) -30 O :�_-� -40 a) W -50 -60 -70 -80 -90 -10 Description: Comments: File Name: Case 2a.slp Analysis Method: Spencer Seismic Coefficient: (none) 10 mn u L.J n.0 roe s te 1 30 50 70 (feet) • • • • • . 90 110 • • • • • • • • • • 1.524' • • • . •• •• o .• 1 130 • • • • • • • • . • • • •.. ••. ••• 150 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 170 • C) iii' Y A:`""`'..' T ;:.�i'L'm -r"E :'?i;':;;75'':. �.;MfT „•S, "i:i,zi;4�.:ft`��::r::, ✓."'SC'•i.alt :;.°5.�;::.;e`a`5- i::;lr;; e'.t�:. ;u. I I I O 0 0 O N I 0 O O 0 N C7 'T In (Taa4) uoReneI9 O u) O M O 0 0 0 O O Z to ~ Z • 6 JU U O co p o co W c') U-I I `” J 1 Q LL W Ce O - CO _ W Z F- O Z F- W Lu rn F p p O • 52 0 F- =W i -- o o W Z LLI = O ~ • L z N O_ 0 O Wi n.= N C � � 0 O U a 15 o 0) 0 cEN n Ez ?, U) , CO0 =c a) OO La(r) 7z•V f r , rx?31T1sc 1".';,?,1;`, .,v, :at» w�.,zx.< .rµ.r. ....'" ":�'i`•?" N 0 O O 0 0 0 CD 0 1 r (leej) uogenal3 I I r� oo c 0 O 0 o 0 ` ' Z z CC 2 6 J0 00 0 C W J F O (nu- Cr) w O ua cn F-w Z = F— 0 Z F— LU 0 0 0 u) O F- ILI w 0 0 F— u.~ .. Z 0 OF- 0 CD co 0 r Z NOTICE IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. eti% aZt Cat Og 09 1 1 • 0 8 O *W IC10V -i cJd� 016°) f?eh el ( S) P'Z 9 i Oh CY' (ooi. 0 � —` O 07. =R a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. CD m CD m 0 2 Q : 0 - D 0 0 co c) 0 aa) E m 00. m __J LL) LJ NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. _ a • CALCULATION SHEET PROJECT: RCI PROJECT NO: 53- 01000496.00 TITLE: DESIGN OF BARRIER WALL REINFORCED PROTECTION CAP PERFORMED BY: M. McCabe and V. Schifano CHECKED BY: Ct. ' - �` c OBJECTIVES: 1. Find the number of reinforcement layers needed to limit vertical stress at top of barrier wall to less than 500/3 psf. 2. Compute the length of geogrid embedment required to avoid pullout of geogrid. DATA • Load from H2O trailer truck = 18 kip single axle, which is equivalent to 32 kip dual tandem(Yoder and Witczak, 1975). The 18 kip single axle corresponds to a pressure of 80 psi. • Flexible pavement consisting of : • 4.0 -inch asphalt pavement • 6.0 -inch base (1 -1/4" minus crushed aggregate. WSDOT 9- 03.9(3))) • 29 -inch compacted fill • Allowable vertical pressure on barrier wall = 500/3 = 167 psf ASSUMPTIONS Stated in each of the Computation Methods used COMPUTATIONS 1. As there is no direct analytical method available (except for finite elements) for calculating the vertical stress within a layered soil - geogrid reinforcement system, four different related methods of computations were used to determine the number of reinforcing layers required to limit vertical stress at top of barrier wall to less than 500/3 psf: Method 1: The design method for Tensar - geogrid reinforced subgrade developed by Giroud and Han (as presented in the attached Tensar publication by S. Valero and A. Anderson, dated December 2001) was used to find the thickness of reinforced subbase course material necessary to distribute a wheel load to a pressure equal to the bearing capacity of the subgrade. For the present calculations both the thickness of unreinforced and reinforced compacted fill producing a pressure p = 500/3 167 psf on the barrier wall are computed as: p= q= Ncxmxcu =500/3 where Nc bearing capacity factor = 3.3 for unreinforced fill (Giroud and Han) m =1 (Giroud and Han) The computations of the thickness of unreinforced and reinforced compacted fill (subbase) were performed using the software SpectraPave2 - Subgrade Improvement Design (Tensar Earth Tech, Atlanta) neglecting the reduction of the pressure transferred to the top of the compacted fill K: \163 \53 - 01000436.00 \CALC. SHEET RCI #2.doc ri? DATE: 6/21/02 DATE C= 12.1 102 The following data were input into Spectra Pave 2 software: Axle load = 18 kips Tire pressure = 80 psi Number of axle passes = 1 Rut depth = 1.5 in (minimum value allowed by the software) Field subgrade CBR = 0.4 % (this value is the minimum considered by the software for correlation with cu. For a CBR < 0.4 % SpectraPave2 provides a cu < 250 psf). Field subbase CBR = 20 % (corresponding to E= 15,000 psi). The results of the computations (attached) show that a thickness of unreinforced fill of 49.3 inches is required to transfer a pressure of about 167 psf to the barrier wall. For a single Tensar geogrid (BX1100 or BX 1200) reinforcement layer the thickness of the fill is reduced to 31.3 inches (i.e. slightly more than the 29 inches planned). The ratio of unreinforced to reinforced thickness is: 49.3/31.3 = 1.57. To compute the thickness of the double- reinforced subbase it was assumed that the above ratio applies. Thus the use of two reinforcement layers should result in a required thickness of compacted fill of 31.3/1.57 = 19 inches. Thus a minimum 20 inch thick double reinforced compacted fill is recommended to support the tire load with an acceptable pressure of 167 psf at the top of the barrier wall. Method 2: Similar to method 1 but considering the stress reduction occurring for a rigid layer (asphalt pavement) overlying a less rigid layer (base course) and the consequent reduced pressure at the top of the compacted fill: The vertical stress at the top of the compacted fill layer was computed using the Jones (1962) elastic stress distribution for a three layer system. The elastic moduli of the asphalt pavement, crushed aggregate base, and compacted fill were assumed based on textbook values for a three layered flexible pavement system (Yoder and Witczak, 1975): El = 600,000 psi (asphalt pavement) E2 = 30,000 psi (crushed aggregate) E3 = 15,000 psi (compacted fill) The Jones elastic distribution requires the computation of the following parameters: H = hl/h2 = 4.0/6.0 = 0.6 (thickness of layer 1 / thickness of layer 3) K1 = E1 /E2 = 600,000/30,000 = 20 K2 = E2/E3 = 30,000/15,000 = 2 A = 0.5a/h2 = 4.2/6.0 = 0.7 Where a is the radius of tire contact (a= (Plitp) ^ ° ' S = (18,000/(80 *3.14))^0.5 = 8.46 in ), P = total load on tire (18 kips), p = tire pressure (80 psi) From the chart published by Jones (1962) the vertical stress acting at the top of the compacted fill is equal to 0.3 x 80 = 24 psi = 3456 psf When the software SpectraPave2 is again applied using the new pressure of 24 psi instead of 80 psi, No Reinforcement is required. K: 163153- 01000496.00'CALC. SHEET RCI#2,doc 2 Method 3: The stress at the top of the barrier wall was computed using the elastic stress distribution for two successive 2 -layer systems (Poulos and Davis, 1988, Elastic Solutions For Soil and Rock Mechanics). See attached sheets 3 -1 to 3 -3. Method 4: The stress at the top of the barrier wall was computed considering the effect of the geogrid on the angle of load spreading. See attached sheets 4 -1 . CONCLUSIONS FOR OBJECTIVE #1 The number of geogrid layers required to limit the pressure on the barrier wall to less than 500/3 psf is: Method 1: Two layers of geogrid reinforcement are necessary to limit the pressure to the desired 167 psf. Method 2: No reinforcement is necessary Method 3: More than two layers of reinforcement are necessary to limit the pressure to the desired 167 psf. Method 4: More than two layers of reinforcement are necessary to limit the pressure to the desired 167 psf Two of the methods used indicated that 2 or less layers of reinforcement are needed, while the other two methods indicated that more than 2 layers are needed. Our judgement is that Methods #3 and #4 are overly conservative, and that the objective of limiting the vertical stress to 167 psf can be achieved using two layers of geogrid. The normal procedure for roadway reinforcement is to place the geogrid layer at the top of the soft subgrade layer. However, since the objective is to limit the pressure on the subgrade, we recommend that the procedures for placing reinforcement below footings (i.e. depth of the geogrid layers should be not more than 1.5 times the width of the loaded area, per K. H. Khing et al, "Foundations on Strong Sand Underlain by Weak Clay With Geogrid at the Interface ", Geotextiles and Geomembranes, V.13, 1994) be used to select the location of the geogrid. The first geogrid layer should be placed at the bottom of the base course layer,and the second geogrid layer should be place within the fill at a distance of 12 to 16 inches below the first geogrid layer. Even better rigidity and stress spreading is expected if the two reinforcement layers are installed by wrapping a single geogrid around the 12 to 16 inch fill layer. An overlap of approximately 18 inches should occur near one side of the reinforced fill layer (i.e. preferably not at the center). OBJECTIVE #2 : Computation of length of embedment required to avoid pullout of geogrid. The anchorage capacity of a geogrid, A (Ib /ft), is expressed by the following relationship (Koerner, 1994): A= 2CiLea' tan 4, Where: Ci = interaction coefficient (for Tensar geogrid, manufacturer provided a range of 0.9 — 1.0) Le = length of geogrid embedment a'„ = Effective normal stress on the geogrid (assuming the unit weight of the asphalt, base, and subbase to be 145 pcf, 140 pcf, and 135 pcf, respectively): • at mid depth of compacted fill, a',, = 150 x 4/12 + 140 x 6/12 + 135 x 29/2/12 = 281.45 psf K: \163153 -01000496.00 \CALC. SHEET RCI1/2.doc 3 • at the top of compacted fill a'„ = 150 x 4/12 + 140 x 6/12 = 118.37 psf • at the bottom of the compacted fill 6'„ = 150 x 4/12 + 140 x 6/12 + 135 x 29/12 = 444.6 psf ) = Subbase friction angle (assumed to be 37 degrees) The tensile capacity of the Tensar Bx 1100 and BX 1200 is 1300 lbs/ft and 2000 lbs/ft, respectively. Assuming a factor of safety of 3 (suggested by manufacturer), the design tensile stress for Tensar Bx 1100 and BX 1200 is 433bs /ft and 667 lbs. /ft, respectively. Thus • mid -depth of compacted fill : Le = (433 to 667) /2 x 0.9 x 281.5 x tan 37 = 1.1 to 1.75 ft • top of compacted fill : Le = (433 to 667) /2 x 0.9 x 118.37 x tan 37 = 2.7 to 4.15 ft • bottom of compacted fill : Le = (433 to 667) /2 x 0.9 x 444.6 x tan 37 = 0.7 to 1.1 ft An alternative approach is to use guidance from the study of reinforced footing subgrades where R.J. Fragaszy and E. Lawton (1984, Bearing Capacity of Reinforced Sand Subgrades, ASCE Journal of Geotechnical Engineering, V.110, N.10) have shown that the optimum length of reinforcement layers is approximately 6 times the width of the loaded area. Using this optimum length of reinforcement produces the highest ultimate bearing capacity and the lowest strain at a particular applied pressure. Therefore use a geogrid length of - - 6 x 16 inches = 96 inches (i.e. 8 feet) CONCLUSIONS FOR OBJECTIVE #2 The minimum length of geogrid embedment required to avoid pull -out depends on the depth of embedment of the geogrid. • For a geogrid placed in the middle of the compacted fill layer it is 1.1 to 1.75 ft for Tensar Bx1100 and Bx1200, respectively. • For a geogrid placed at the top of the compacted fill layer it is 2.7 to 4.15 ft for Tensar Bx1100 and Bx1200, respectively. • For a geogrid placed at the bottom of the compacted fill layer it is 0.7 to 1.1 ft for Tensar Bx1100 and Bx1200, respectively. However, since the objective is to limit the stress on the soft subgrade layer, the alternative guidance for length of reinforcement beneath footings should be applied, and a minimum geogrid length of 8 feet should be used. K:\163 \ 53-01000496.00 CALC. SHEET RCI#2. doc 4 If O m s E 0 a .s REFERENCES - TITLE r -= REVISIONS NO. BY. DATE DESCRIPTION . REVISIONS NO. BY. DATE ' DESCRIPTION Dr TYPICAL SECT NTS I V ACP 60 1 -1/4" MINUS CRUSHED AGGREGATE (WSDOT 9- 03.9(3)) COMPACTED FILL (EITHER GRAVEL BORROW, WSDOT 9- 03.14(1) AND MODIFIED FOR GEOSYNTHETICS; OR COMMON BORROW, WSDOT 9- 03.14(2) AND MODIFIED FOR GEOSYNTHETICS.) ::.TRENCH : BACKFILL ., '0 Meld' . i RO.UGHvBARRIER • WALL 9/ TE 0 0.L " ti. N• ti: N:. S.' N:. S' r'!, S. NS. f�. 'ti:?r'tit'. +'.f%sf:ti"f::ti{:'t:N: S' N :.S:N:.ti:. ✓..1:$S:N:.S.{!;tif;tif 'ti.'N:.S:N,1'.::;;�.r;,r v _ - P TOP" OF UPPER. ' AQUrr— .' BARRIER: WALL - ' 5 sop ref -- sac- S � f snC( fa(oWSIOvl =p BARRIER WALL PROTECTION CAP NTS U4 WAMIS6 • WATERWAY MINIMU BELOW'LOW LEVEL PAVED ROADWAY PER SPECIFICATION SECTION 02575 GEOGRID LAYERS' (TYPICAL UNDISTURBED EARTH 4- lam- s Caveat p.ei 20 MIL: PVC .LINER 5 -FOOT (MIN.) WIDTH 51.1 G STILLING WELL NTS NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. DRAWING : DESIGNED DRAWN •B' CHECKED I APPROVED F E. h.i1K 17-4 BRIDGE ENGINEERING 10' CLEARANCE AND WIg,HA@F. be selected to produce muni stress. CONCENTRATED LOAD {18 KIPS FOR MOMENT `26 KIPS FOR SHEAR NIFORM ,LOAD 0.64 NIPS LINEAR FOOT OF LOAD LANE H20-44 LOADING H$20 -44 LOADING CONCENTRATED LOAD { 13 5 KI PS FOR MOMENT 19.5 KIPS FOR SHEAR NIFORM LOAD 0.48 NIPS LINEAR FOOT OF LOAD LANE 1415 -44 LOADINI HS15 -44 LOADING CONCENTRATED LOAD { 9 KIPS FOR MOMENT 13 KIPS FOR SHEAR UNIFORM LOAD 0.32 KIPS PER LINEAR FOOT OF LOAD LANE 1410 -44 LOADING FIg. 17-4. H and HS loadings for simply supported spans. For maximum negative moment in continuous spans, an additional concentrated load of equal weight should be placed in one other span for maximum effect. For maximum positive moment, only one concentrated load should be used per lane, but combined with as many spans loaded uniformly as required for maximum effect. ;wide uniform load in combination with a concentrated load (Fig. 17-4). As indicated 7 -3, there are five classes of loading: H20, H I5, and H I0, which represent a truck with ded axles, and HS20 and HS15, which represent a truck and trailer with three loaded ese loading designations are followed by a 44, which indicates that the loading stan- adopted in 1944. in proportioning any member, all lane loads should be assumed to occupy, within their ye lanes, the positions that produce maximum stress in that member. Table 17 -1 gives um moments, shears, and reactions for one loaded lane. Effects resulting from the simul- oading of more than two lanes may be reduced by a loading factor, which is 0.90 for es and 0.75 for four lanes. gn of steel grid and timber floors for H2O or HS20 loading, one axle load of 24 kips e loads of 16 kips each, spaced 4 ft apart, may be used, whichever produces the greater Read of the 32 -kip axle shown in Fig. 17 -3. For slab design, the center line of the wheel ';assumed to be 1 ft from the face of the curb. elks and their direct supports should be designed for a uniform live load of 85 lb/ft "et Of sidewalk live loading on main bridge members should be computed from P = (30 } 30001 55 b P = (30 60 lb /ft wcow,. u (17-1) 1 sidewalk live load, lb /ft ¢;loaded length of sidewalk, ft .sidewalk width, ft jshould resist a force of 500 lb /lin ft acting 10 in above the floor. For design loads for Fig. 17 -5. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • \ is t24 rS► • FIXED TRAFFIC VERSUS FIXED VEHICLE 129 (Increase)--1- Single wheel load (a) Figure 4.1. Basic pavement design approaches. (Increase) --Y Repetitions to failure (b) diagram. Normally, this procedure uses a relationship established between pave- ment thickness and a single -wheel load for various subgrade support values. Figure 4.1b illustrates design approaches that rely on a. fixed standard vehicle type and normally express pavement thickness as a function of the number of repetitions to failure of the standard vehicle for various subgrade supports. Although both methods consider • the vehicle and traffic repetitions, the philos- ophy used in handling these affects are quite different. For the procedure of Figure 4.1a, a need exists to equate the design multiple -wheel gear into an equivalent single -wheel load (ESWL). Normally, in this design approach, only a "critical" or "design" vehicle is used (e.g., heaviest or most damaging aircraft) and the damage effects of the other vehicle types are ignored. This procedure is largely applicable to airports. The procedure relying on a standard vehicle type normally involves the use of determining the equivalent damage effects of all vehicle types in the mix ex- pressed in terms of the number of repetitions of the standard vehicle. The factors that relate the relative amount of damage of a particular vehicle to that caused by the standard vehicle are called equivalent wheel load factors (EWLF). AIthough each highway and airfield pavement design approach must be viewed specifically with the previous thoughts in mind, the general approach that is now widely adopted in highway design methods is that of the fixed standard vehicle type while for airfields the fixed traffic level approach is more common. Highways. In many parts of the world, a standard legal axle load limit has • generally been imposed for highway travel. Hence maximum gear loads in high - ;. way design have not appreciably increased with time. In. the United States, a widely accepted standard vehicle type is the 18 -kip single axle (generally equiv. talent . to 32 -kip dual tandem). Thus the effects of other vehicles are normally ccounted for in the design phase by the use of equivalent 18,000 -pound single - xle load (EAL). Airports. In contrast to highways, airfield pavements are exposed to a much der potential range in gross aircraft weights. Figure 4.2 illustrates this point bier remarkedly. As many airfield designs may be based upon a 20- to 30 -year ixpectancy, the designer may be faced with the problem of selecting a critical craft that may not even be in the planning phase of the aircraft industry. As qbe seen from Figure 4.2, extrapolation of this curve tends to show that lire aircraft may approach the 1000- to 2000 -kip gross weight variety. In any Z 1— W JU 0 U U W N � WO Q UJ ▪ a I— W Z = F- 1— 0 Z LLI • W • 0 O E ) . • 1-- W I - U �"O Z W U U — 'h O ~ Z t 16 PAVEMENT TYPES AND DESIGN FACTORS L • • L = � 0.5227 Figure 1.8. Tire imprint assuming rectangle and semicircles. 0.6L failure but is such that the pavement will not carry out its intended function without causing discomfort to passengers or without causing high stresses in the plane or vehicle that passes over it, due to its roughness. Obviously the degree of distress for both categories is gradational, and the severity of distress of any pavement is largely a matter of opinion of the person observing the distress. However, the difference between the two types of failures is important, and the engineer must be able to distinguish between them. As an example, consider a rigid highway pavement that has been resurfaced with an asphaltic overlay. The surface may develop rough spots as a result of breakup in the bituminous overlay (functional failure) without structural breakdown of the overall structure. On the other hand, the same pavement may crack and break up as a result of overload (structural failure). Maintenance measures' for the first situation may consist of resurfacing to restore smooth - riding qualities to the pavement. However, the structural type of failure may require complete rebuilding. The cause for either of the aforementioned distress conditions may be three- fold. First, overload including excessive gross loads, high repetition of loads, and high tire pressures can cause either structural or functional failure. Second, climatic conditions as well as environmental conditions may cause surface irregu- larities and structural weaknesses to develop. For example, frost heaving, volume change of soil due to wetting and drying, breakup resulting from freezing and thawing, or improper drainage may be the prime cause of pavement distress. Many of the climatic variables can be estimated, but prediction of climatic con- ditions may, at best, be poor. A third cause may be disintegration of the paving materials, due to freezing and thawing and /or wetting and drying. Scaling of rigid pavements, for example, may result from nondurable aggregates and can be caused by or aggravated by the application of salts for ice removal. Base - course materials may breakdown, thus generating fines which may cause an unstable mix to develop. Subgrades also are susceptible to climatic conditions. Construction practices may have • - 1\r\ Ck1f 03 Al- Introduction and Summary of a New Design Method for Tensar Geogrid- Reinforced Unpaved Roads Developed by Dr. J. P. Giroud and Dr. Jie Han Prepared by Steve Valero and Andy Anderson, December 2001 1 of 10 z I I - Background: re J U U0 U U U) 111 J I H In the past, two design methods have been widely used to determine the required base course thickness for unpaved roads and granular working pads. Giroud and Noiray (1981) developed the first of these classic methods. The Tensar Corporation (1986) developed the other. Both methods employ stress distribution theory to estimate vertical pressure on the subgrade resulting from a wheel load at the road surface. The aggregate base thickness required to reduce the vertical pressure imparted on the subgrade to a value equal to it s estimated bearing capacity is computed. The Giroud and Noiray (G &N) Method assumes that the tire pressure is applied to a rectangular area at the surface and is distributed uniformly over progressively larger rectangular areas with depth. The areas of distribution are defined by lines that slope down and away from the four edges of the surface load. The slope of these lines, from vertical, is termed the stress distribution angle. The Tensar Method uses Boussinesq stress distribution theory to estimate the maximum vertical stress under the center of a circular loaded area. Both methods consider the wheel load, tire pressure, and subgrade shear strength in computations. Both also assume that geosynthetic reinforcement effectively increases the available bearing capacity of the subgrade by changing the failure mode from local to general bearing capacity failure. In addition, the G &N method considers the number of load applications and the acceptable rut depth. G.H_Method.doc w LL? = a . F w Z I— 0 Z I- However, neither method considers other factors of obvious importance, such as reinforcement and base course material properties. In the early to mid 1980 s, very little research and field data was available to facilitate calibration and proof of more complex models incorporating these parameters. While Giroud and Noiray and Tensar realized the importance of reinforcement and base course material properties, neither had sufficient research and field data to allow incorporation into the respective models. Consequently, designers have employed both methods applying a significant degree of conservatism in selection of input parameters. This approach leads to effective performance, but does not yield the most efficient design. Over the last two decades, geogrids have been widely used in subgrade improvement applications and studied in several research programs. Thus, a much broader body of information exists today than did in the 1980 s. This new information allowed Drs. Giroud and Han to develop and verify an improved design method. The Giroud -Han Method incorporates the strength/modulus of the base material, variations of the stress distribution angles through the base course, and the aperture stability modulus (stiffness) property of the geosynthetic reinforcement in addition to all of the parameters considered by the G &N Method. Consequently, this improved method allows designers to use more accurate input parameters to better predict performance. This, in turn, leads to more efficient use of aggregate resources, construction equipment, labor, and time. Basis of the Giroud -Han Method: As with classic reinforced road design methods, The Giroud -Han Method is based on a theoretical model. However, Giroud and Han went on to calibrate the model using the G.H_Method.doc 2 of 10 • C. .. `-, • results of a specially developed research program (Gabr, 2001) conducted at North Carolina State University. This research program incorporated a significant number of large - scale, cyclic plate load tests using Tensar BX1100 and BX1200 geogrid reinforcement. The research provided data regarding pressure induced on the subgrade and surface deformation as a function of the number of load cycles for multiple combinations of reinforcement and base thickness. This data was used to estimate the pressure distribution angle and to quantify the effects of base reinforcement and thickness on both initial stress distribution angle and changes to the angle with continued load applications. Following the method was verified using results of other research and field data. A complete bibliography of references and research used to develop the method is provided at the end of this document. Summary Derivation of the Giroud -Han Method: The Giroud -Han Method assumes a circular equivalent tire contact area and circular pressure area on the subgrade. Thus the stress distribution surface forms a cone rather than the trapezoid assumed by the G &N Method. The pressure, p, at any depth, h, is then P P _ ir(r +htana)2 where P = wheel load, r = radius of equivalent tire print, a = stress distribution angle. The depth required to distribute the wheel load to a pressure equal to the bearing capacity of the subgrade, q = mc„N is G.H_Method.doc 3 of 10 z Q; '~ 0 00 . co cn J U) LL. w 2 J u. = • a F w Z zI- 2 o' 0 O O I— W W F 0 � -- O .. z U =. O ~ . Z h = 1 tan a N7r m c„ Ar where c„ = undrained shear strength of the subgrade, N = bearing capacity factor of the subgrade and m = bearing capacity mobilization coefficient. N is taken as 3.3 for unreinforced base courses, 5.14 for geotextile reinforced and 5.71 for Tensar geogrid reinforced base courses. Selection of N values is based on classic shallow foundation bearing capacity theory that suggests: 1) = 3.14 for a local bearing capacity failure (modified to 3.3 based on field test results on unreinforced base courses); 2) = 5.14 for a general bearing capacity failure where there is a smooth interface (i.e. geotextile) between a footing and soil; 3) • = 5.71 for a general bearing capacity failure where there is a rough interface (i.e. Tensar geogrid) between a footing and soil. The bearing capacity mobilization coefficient (m) accounts for the fact that only part of the full bearing capacity is developed at any specified rut depth. This coefficient is a function of r/h and s , the rut depth. m ranges from nearly 1.0 for relatively thin aggregate bases and a rut depth of 3 inches. It is less than 1.0 for thick aggregate bases and/or less than 3 -inch rut depths. The function is calibrated using test data. The stress distribution angle is greater through a high modulus base course than through a lower modulus material. Giroud and Han empirically related the initial stress distribution angle, a,, through a stiff base over a softer subgrade to the stress distribution angle, ao, through a homogeneous material and to the ratio of the moduli (or CBR) of the base and subgrade as follows. G.}1_Method.doc r ) 4 of 10 c3.7N,(7 f 1 13 1 - 0.9ex - 1.426 { } ]]CBR , 03 tan a = tan a [1+ 0.204 1 = tan a 1 + 0.204 3.48CBR 1 E CBR where Ebc and E = the modulus of the base course and subgrade, respectively and CBRb and CBR = the base course and subgrade CBR, respectively. Data from the North Carolina State University research program was used to correlate the stress distribution angle with the number of load cycles, N, yielding: t tan a an - 1 +k log N where k is an empirically derived constant depending on the base course thickness and geogrid reinforcement property J, the aperture stability modulus. 1.5 1.1954910+0.019J-1.7444 logN h- G.H_Method.doc 3.48 CBR 1 +0.204 CBR5g 5 of 10 The bearing capacity mobilization coefficient was calibrated and the equations combined to arrive at the following design equation for the minimum required thickness of the base course: where s equals rut depth in inches, P is in pounds, h and r are in inches, = 3.3, J = 0 for unreinforced base course; N = 5.14, J = 0 for geotextile reinforced base course; N 5.71, J = 0.32 m -N /deg for Tensar BX1100 reinforced base course; and N 5.71, J = 0.65 m-N/deg for Tensar BX1200 reinforced base course. r 6 of 10 In application of the Giroud -Han method, it is currently suggested, based on a field study of unreinforced bases, that the modulus ratio Ebc/Es be limited to a maximum value of 5.0 to account for the inability to effectively compact base course material over very soft - subgrades. Consequently the term 3.48CBRb °3 /CBR sg <_ 5.0. However, there is evidence (Webster, 1996) to suggest that the introduction of stiff geogrid reinforcement allows for improved compaction of the base course material. The authors are currently evaluating this phenomenon to determine if the limit in modulus ratio may be increased for the geogrid- reinforced case. Applicability of the Giroud -Han Method: In theory, the Giroud -Han Method is applicable to use of all geosynthetics in subgrade improvement applications. Validation against other research and observed field performance indicates that the method accurately predicts the performance of geotextiles and geogrids having property values falling within the range of those used for calibration of the method. However, a degree of conservatism must be applied to results obtained through application of the method to geogrid products with property values outside the limits of calibration. The following paragraphs provide guidance regarding important geogrid properties and the range of values represented by Tensar geogrids used in calibration of the model. The effectiveness of a geogrid in subgrade improvement applications is dependent on several factors. The geogrid must be able to effectively (i.e. broadly and evenly) distribute load over the subgrade. This involves a complex interaction of geogrid, soil, and base. Through extensive experience with this application and review of past research G.H_Method.doc 4 r,."�37:..Sti'A3i . �Eb t�":R. Geogrid Property Observation • Giroud -Han Method Validation Range Geogrid Type Single Layer (extruded and woven) geogrids are easily placed without damage to junctions or layer separation. Single layer products perform better than multi -layer or welded strip products. Multi -layer products tend to separate during placement. Welded strips tend to separate at the junctions during placement. The Giroud -Han Method was validated with single layer products. Aperture Stability Modulus Research strongly indicates that this property effectively captures the complex interaction of initial tensile modulus, stiffness, confinement, and stability. Geogrids with higher aperture stability perform better. The Giroud -Han Method has been validated for values up to 6.5 cm- kg/deg. Rib Shape Square or rectangular ribs provide better interaction with soil and subbase. Square and rectangular rib products perform better than those with rounded ribs. The Giroud Han method was validated with rectangular rib products. Rib Thickness Thicker ribs provide better interaction with soil and base. Products with thicker ribs perform better than those with thinner ribs. The Giroud Han Method was validated with products having rib - thickness greater than or equal to 0.03 inches. Aperture Size Geogrid apertures must be large enough to permit aggregate /soil strike - through, but small enough to provide effective interlock. Research indicates that an aperture size between 0.9 and 1.5 inches performs most effectively with the majority road base aggregate /soil combinations. The Giroud -Han Method was validated with products having aperture dimensions between 0.9 and 1.5 inches in both directions (machine and cross - machine). Junction Efficiency Research indicates that geogrid junctions must be strong enough to effectively confine base particles. Geogrids with higher junction efficiency perform better. The Giroud -Han Method was validated with products having junction efficiency greater than or equal to 90% of ultimate tensile strength. tt .-J 7 of 10 (Webster, 1992), Tensar has concluded that the following properties impact a geogrid s ability to provide subgrade improvement: G.H_Method.doc z . =z 4- w CC 6 U0 • 0 w � U) u_ w 0 g = W 1- z � 1- z i— 0 O N O I— w W O w z O ~ z Summary: z z The Giroud -Han method is theoretically based and empirically calibrated. It may be 6 U O expected to yield accurate predictions of field performance for similar loading conditions, co 0 J base and subgrade properties and for the specific geogrids used in calibration and cn w 0 validation of the model. Giroud and Han are currently finalizing a detailed technical g w Q paper regarding development and calibration of this new method. The paper will be c submitted for publication in a technical journal in the near future. z F- O z F- w Bibliography: v O cn AASHTO (1993). Guide for Design of Pavement Structures (1993), 589p. 01-- w Barber, V.C., Odom, E.C., and Patrick, R.W. (1978). The deterioration and reliability of 0 pavements. Technical Report . S -78 -8, United States Army Engineer Waterways ill z Experiment Station, Vicksburg, Miss., July. w Bauer, G.E. (1994). The control of settlement using geogrids. Proc. of Settlement 94, College Station, Texas, USA, 491 -501. z Burmister, D.M. (1958). Evaluation of pavement systems of the WASHO road test by layered systems method. Bulletin 177, Highway Research Board, 26 -54. Collin, J.G., Kinney, T.C., and Fu, X. (1996). Full scale highway load test of flexible pavement systems with geogrid reinforced base courses. Geosynthetics International, 3(4), 537 -549. De Groot, M., Janse, E., Maagdenberg, T.A.C., Van den Berg, C. (1986). Design method and guidelines for geotextile application in road construction. Proc. 3 Int. Conf. on Geotextiles, Vienna Vol. 3, 741 -746. Fannin, R.J. and Sigurdsson, O. (1996). Field observations on stabilization of unpaved roads with geosynthetics. ASCE, Journal of Geotechnical Engineering, 122(7), 544- 553. Gabr, M. and R.E. Dodson (1998). Stress distribution in geogrid reinforced foundations. Proc. of Geo- Congress 98, Geotechnical Special Publication No. 76, 62 -76. Gabr, M. (2001). Cyclic Plate Loading Tests on Geogrid Reinforced Roads. Research Report to Tensar Earth Technologies, Inc., NC State University, 43p. G.H_Method.doc 8 of 10 1144(i4!i1A# • SO Uci) s 4 • 9 of 10 Geosynthetic Materials Association (2000). Geosynthetic Reinforcement of the Aggregate Base /Subbase Courses of Pavement Structures. GMA White Paper II, prepared for AASHTO Committee 4E, 176p. Giroud, J.P. and Noiray, L. (1981). Geotextiles- reinforced unpaved road design. ASCE,._ Journal of Geotechnical Engineering, 107(9), 1233 -1253. Giroud, J.P., Ah -Line, C., and Bonaparte, R. (1985). Design of unpaved roads and trafficked areas with geogrids. Polymer Grid Reinforcement, Thomas Telford Limited, London, 116 -127. Hammitt, G. M. (1970). Thickness requirement for unsurfaced roads and airfields, bare base support, Project 3782 -65. Technical report S -70 -5, U.S. Army Engineer Waterways Experiment Station, CE, Vicksburg, Miss., 135p. Heukelom, W. and Klomp, A.J.G. (1962). Dynamic testing as a means of controlling pavements during and after construction. Proc. of the First International Conference on Structural Design of Asphalt Pavements, University of Michigan, 667 -679. Huang, Y.H. (1993). Pavement Analysis and Design. Prentice Hall, 805p. Knapton, J. and Austin, R.A. (1996). Laboratory testing of reinforced unpaved roads. Earth Reinforcement, Ochiai, Yasufuku, and Omine (eds), Balkerma, Rotterdam, 615 -618. Kinney, T.C. (2000). Standard test method for determining the Aperture Stability Modulus of a geogrid. Shannon & Wilson, Inc., WA. 9pLawton, E.C. (1996). Section 5A: Nongrouting Techniques. Practical Foundation Engineering Handbook, edited in chief by R.W. Brown, McGraw -Hill, 992p. McGown, A., and Andrawes, K. (1977). The influence of nonwoven fabric inclusions on the stress strain behavior of a soil mass. Proceedings of the International Conference on the Use of Fabrics in Geotechnics, Paris, 161 -166. Milligan, G.W.E., Jewell, R.A., Houlsby, G.T., and Burd, H.J. (1989a). A new approach to the design of unpaved roads -Part I. Ground Engineering, April, 25 -29. Milligan, G.W.E., Jewell, R.A., Houlsby, G.T., and Burd, H.J. (1989b). A new approach to the design of unpaved roads - Part II. Ground Engineering, November, 37 -42. Milligan, G.W.E and Fannin, J. (1986). Model and full -scale tests of granular layers reinforced with a geogrid. Proc. of 3 rd International Conference on Geotextiles, Vienna, Austria, 61 -66. Perkins, S.W. (1999). Geosynthetic Reinforcement of Flexible Pavements: Laboratory Based Pavement Test Sections. Final Report, FHWA/MT -99- 001/8138, 140p. Raymond and Hayden (1983). Effect of Reinforcement on Sand Overlying Bases of Different Compressibilities Subject to Repeated Loading. C.E. Research Report No. 79, Department of Civil Engineering, Queens University, Kingston, Ontario, Nov., 120p. Sigurdsson, O. (1991). Geosynthetic Stabilization of Unpaved Roads on Soft Ground: a Field Evaluation. MS thesis, the University of British Columbia, 149p. G.H_Method.doc G.H_Method.doc 10 of 10 Steward, J.E., Williamson, R., and Mohney, J. (1977). Guidelines for Use of Fabrics in Construction of Low - Volume Roads. Report No. FHWA -TS -78 -205, Pacific Northwest Region Forest Service, U.S. Department of Agriculture, Washington, DC, USA, 172p. The Tensar Corporation (1986). Design Guideline for Subgrade Improvement under Dynamic Loading with Tensar Geogrids. Tensar Technical Note(TTN:BR5), 30p. The Tensar Corporation (1996). Design Guideline for Flexible Pavement with Tensar Geogrid Reinforced Base courses. Tensar Technical Note(TTN:BR96), 77p. The Tensar Corporation (1998). A Review of Geosynthetic Functions and Applications in Paved and Unpaved Roads. Tensar Technical Note(TTN:BR11), 45p. Wayne, M.H., Han, J., Akins, K. (1998). The design of geosynthetic reinforced foundations. Proc. of Geo- Congress 98, Geotechnical Special Publication No. 76, 1 -18. Webster, S.L. and Watkins, J.E.•(1977). Investigation of construction techniques for tactical bridge approach roads across soft ground. Technical Report S -77 -1, U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss., 75p. Webster, S.L. and Alford, S.J. (1978). Investigation of construction concepts for pavements across soft ground. Technical Report S -78 -6, U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss., July, 82p. Webster. S.L. (1992). Geogrid Reinforced Base Courses for Flexible Pavements for Light Aircraft: Test Section Construction, Behavior under Traffic, Laboratory Tests, and Design Criteria, final report, DOT /FAA /RD- 92/25, U.S. Department of Transportation and Federal Aviation Administration, 91p. Webster, S.L. ( 1996). Personal communications with Anderson, R.B. Yoder, E.J. and Witczak, M.W. (1975). Principles of Pavement Design, Second Edition, John Wiley & Sons, Inc., 711p. `111:4`; ; fut.'rT i. .: '-, Y.^ .-.! ;J_ i SpectraPave2 -- Tensar Earth Technologies, Inc. Page 2 of 4 Copyright ©1998, 2001 Printed on 06/21/2002 4:28:16 PM GEOGRID PROPERTIES Aperture Dimensions (Inside to inside) MD (in) XMD (in) ANALYSIS RESULTS Subbase Thickness (in) = Subbase Saving (in) = . SUBGRADE IMPROVEMENT INPUT DATA Axle Load = 18(kip) Tire Pressure = 80( si) Number of Axle Passes = 1 Rut Depth = 1.5(in) Field Subgrade CBR = 0.4 ( %) Field Subbase CBR = 20 ( %) BX1100 BX1200 Geogrid Type Integrally formed Integrally formed single layer single layer Rib Shape Rectangular /Square Rectangular /Square Rib Thickness (in) 0.03 0.05 Aperture Stability Modulus(cm - kg/deg) 3.2 6.5 Junction Efficiency ( %) 90 90 (Percent of Tult) 1.0 1.0 1.3 1.3 Unreinforced 49.3 BX1100 BX1200 31.3 31.3 18.0 18.0 current file name Project Name: Design Case: i # SpectraPave2 -- Tensar Earth Technologies, Inc. Page 2 of 4 Copyright ©1998, 2001 Printed on 06/24/2002 3:26:10 PM GEOGRID PROPERTIES Aperture Dimensions (Inside to inside) MD (in) XMD (in) ANALYSIS RESULTS Subbase Thickness (in) = Subbase Saving (in) = SUBGRADE IMPROVEMENT INPUT DATA Axle Load = 18(kip) Tire Pressure = 24(psi) Number of Axle Passes = 1 Rut Depth = 1.5(in) Field Subgrade CBR = 0.4 ( %) Field Subbase CBR = 20 ( %) BX1100 BX1200 Geogrid Type Integrally formed Integrally formed single layer single layer Rib Shape Rectangular /Square Rectangular /Square Rib Thickness (in) 0.03 0.05 Aperture Stability Modulus(cm - kg/deg) 3.2 6.5 Junction Efficiency ( %) 90 90 (Percent of Tult) 1.0 1.0 1.3 1.3 r einforced BX1100 BX1200 10.4 10.4 15.8 15.8 current file name Project Name: Design Case: F• , fv-N.e*\ nth. +z 44 STRESSES IN FLEXIBLE PAVEMENTS Solution: THREE - LAYER SYSTEM Although Burmister's work provided analytical . expressions for stresses and displacements in two -'and three -layer elastic systems, Fox (17) and Acum and Fox 0 0 1 2 3 d 0 4 5 6 7- Interface deflection factor F 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4 1.5 2 I I I I J I I y 1 �f 2 1, 1\I .25 0.75 0.5 0 ,I 2.5 3 0 For E /E = 5, r/a = 0, and z/a = 12/6 = 2 from Figure 2.8, F = 0.48 0 E2 F _ 80 000 (0.48) = .023 inch. Since AT = [1 + As where L T = .030 inch (Example 2.2) A„ = AT - A = .007 inch. 5 4 E /E2 =1 E1 = E p = 80 psi E2 = 10,000 psi 0 0 1 2 v3 n 4 0 5 6 7 15 a = 6 in. 10 r = 0 z = 12 in. Interface deflection factor F 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4 1.5 1 I �I 1\ I 1 1 l 1 1 0 \ ) 1 0.75 .50 1.5 1.25 1 2 �5 4 3 5 7 E1 /E2 =5 A E E2 (a) Figure 2.8. Vertical deflection at the interface of a two -layer system. Deflection values are obtained from Equation 2.10. Numbers on curves indicate offset distances in radii. Curves are for various modular ratios as follows. (a) E, /E = 1; 5; (b) Et/E2 = 10; 25; (c) E1 /E, = 50; 100. (From Huang.) c A 0. 0 4 e 7 0 1 2 v 3 t 0. 04 5 6 7 Figur EMENTS ses and .nd Fox 3 1.4 1.5 ; alues are urves are 50; 100. Interface deflection factor F 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 2 It; 3 A a 04 E1 /E2 = 100 (b) 1.4 1.5 (c) Interface deflection factor F 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4 1:5 0 E1 /E2 = 25 Interface deflection factor F 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 12 1.3 1.4 15 Interface deflection factor F 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0 1.1 12 1.3 1.4 1.5 Pa . a = E F = j S F E 45 Figure 2.8. Continued ii • 46 STRESSES IN FLEXIBLE PAVEMENTS (1) produced the first extensive tabular summary of normal and radial stresses in three -layer systems at. the intersection of the plate axis with the layer inter- faces. Jones (21) and Peattie (30) subsequently expanded these solutions to a much wider range of solution parameters. The representative three -layer pavement structure along with the stresses that can be solved by stress factor values provided in this textbook is shown in Figure 2.9. Solutions for the five stresses are: o- Vertical stress at Interface 1 cr,2: Vertical stress at Interface 2 Q',. Horizontal stress at the bottom of Layer 1' crrz: Horizontal stress at the bottom of Layer 2 v Horizontal stress at the top of Layer 3 Vertical stress solutions have been obtained by Peattie (30) and are shown in graphical form in Figure 2.10. The horizontal stress solutions have been obtained from Jones (21) and are shown in tabular form in Table 2.3. The stress values are all along the axis of symmetry of a single load. Because of this, a = a't. It should be noted that the figures and tables have been developed for kt, = 0.5 for all layers. The sign convention is positive for compression. While interpola- tion of the stress factors is necessary for many problem solutions, no extrapola- tion is allowed. Both the vertical stress (graphical solutions) and the tabular solutions for the horizontal stresses use the following parameters: k or Kl = - k or K2 = E� E2 a hi a l or A = 7 H = /12 µt= 0.5, hr, E1 ° :t > Qrl I•Z2= 0.5, h2,E2 113 = 0.5, h3 = °°, E3 o a r -- ='"" ar3 Interface 1 Interface 2 Figure 2.9. Three -layer pavement system showing location of stress solutions presented in text. THE Fig for are str, pa toI R1 ter m; ex. Err for at at: by a is • n •d .5 a- a- ie :t. THREE -LAYER SYSTEM 47 The following combinations of values for these parameters are presented: k (K I) = 0.2, 2.0, 20.0, 200.0 k2 (K2) = 0.2, 2.0, 20.0, 200.0 a (A) = 0.1, 0.2, 0.4, 0.8, 1.6, 3.2 H = 0.125, 0.25, 0.5, 1.0, 2.0, 4.0, 8.0 The vertical stresses 0rzi and o-z2 can be obtained by the diagrams shown in Figure 2.10. From these diagrams, a stress factor value (ZZ1 or ZZ2) is obtained for the particular K1, K2, A, and H values of the pavement system. The stresses are then: for Fil = 0.5 and au = Tr/ azi = p(ZZ1) Qz2 = p(ZZ2) Qrl — = p[ZZ1 — RR1 ] Q :2— Qr2 = p[ZZ2 — RR21 0 — 0 r3 = p[ZZ2 — RR3] art v : 1 • :1 Er1 = E1 - E1 - 111 E 1 (2.11) (2.12) The horizontal stresses a rl, 0 r2, and o-, can be obtained by the horizontal stress factors shown in Table 2.8. Three sets of stress factors are shown for a particular combination of the input parameter k k a and H. The stress fac- tors are given in stress difference, that is, (ZZ1 — RRI) (ZZ2 — RR2), and (ZZ2 — RR3). The product of the plate pressure and stress factor is the stress difference. (2.13) (2.14) (2.15) Therefore to obtain the horizontal stress values, Uzi and 0 z2 must be de- termined. Because of the symmetry involved in the stress analysis, several types of strains may be computed from the calculated stresses and the equations of strain. For example, knowing Uzi and °r1 the horizontal strain at the bottom of Layer 1, E may be computed as follows: Erl = 2. lQrl — (TA It should be obvious that the vertical and horizontal strains can be computed at the bottom of Layers 1 and 2 as well as the top of Layer 3. The stress and strain solution techniques discussed for three -layer systems can also be used to compute similar values for two -layer systems.)This is accomplished by letting E = E2 (k or K1 = 1.0) and selecting a convenient H value and a (A) value that can be read directly from the table or figure such that h +h2 is equal to the pavement thickness of the two -layer problem. Z Q� '~ .J U 00 co to W J W • O g co = W Z = 1- O W ~ W U � O N O I- W W L i' O .. Z U = O ~ Z cn ZZ1 0.00001 1.0 0. 0.001 0.0001 1.0 0.1 111•21.11111111 W ANIRIA 11111 1 15 11111■711111111k1111144 • 0 1 2 A WAWA El WAII = iminny .■■■■■■ ■Imiwal■■■■■••■ Tha 0.25 Al I I I I I I I CAIT=7== MINIM 11111111/~111111PANIIIMMIllk vAllIC H = NM I Elk/ I I Aim A= 0.8 H 1.0 v■E■orAL■ 1 11, H = 2.0 r A = 0.4 H = 4 . Ov . A = 0.2 H = 8.0 A = 0.1 K1 200 K2 = 0.2 -41111111111111 411•16,1 ■IMINV.•.■IN1111•■..111M. ( c) 7. " 1 31111. I I I nIfm. Wel I I 11111 11E r il.1 volv■■■• ■■•■■■■■■■■•■■■ ■■■ 1.• lor■■■■■■■■■■■■■■• = 0.25 •■•••wAy■pr■milIAMMININN Mimi= ma I I I I WI I 1 Ir • AC VIIMMINV■■•=va • v 7 11•1111/4 ■ 11 • 1111 MMAINIMMIMMINIMMI V H =10 M .0 7. • • • • H = 0.4 = K1= 20.0 H— 8.0 A = 0.1— K2 = 2.0 • •" • ", • • , • . A NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. ■---.■ !AIM I 1 M I I I MI . atra a EWA►:� r�:� r, M. --- -- -...∎∎ - - WH= alWAIWAIM- v 0.12541V_-Ar- A A H 0. '�►����V A = 0.8 - Vi%ri H = 1.0' - A = 0.4 - H _.2.0 vi air 02 H = 4.0 H = 8.0 A =0.1 K1 - 20.0 K2 - 02 } } (B) ASV AldhAl■ Aik A !O BM II a 1 WA WAWA MI \ Wiry = 0.5 di • =0.8 NENWAIMMEMEMAIIMMEMIVW ���'�A .4 H = 2. - 00• H_4.0 A =02 K1 = 20.0 H= 8.O7A =0.1 K2 - 2 . 0 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • • M ez rx ° a ` °z E. J. YODER Professor of Highway Engineering Purdue University M. W. WITCZAK Associate Professor of Civil Engineering University of Maryland PRINCIPLES OF PAVEMENT DESIGN SECOND EDITION A Wiley- Interscience Publication JOHN WILEY & SONS, INC. New York • Chichester • Brisbane • Toronto Page 3 -1' of Job Project No. 51- olaoo' .4o Sheet .• of Description Computed by Date CQ.( 2t (oZ m ETotjtb 3 - S access cv c 2 -4072..r 4 q.e.s V" 11 'Cte� ; 1ou S 4-1).04-vS dP a Alp es. i3a.s C-00-1C4 . = 000 30 ts ' �; a 15 000 N-51 W+1ce1JC4 Z. = 2.fo,25 vis. IN' loo NZ-Et NVcsiteg, ►� �fa S SPhuk4 --E0 - 5.12. - oo;oc» �Z - . 3b,oOb 21:, a" 0.5 Si) --Fro, Prig �.3 i � 50 ; S?c� . (80. , psi ' ) _ 1 {0 'Fs; (aCJ ' Gf �c�v;•v Pert?-4 �„ t _.' 7 . �.. h � + ,.. �.r.. \u � y . , r •' �W ���1r.f cY'�u. '14 1 fo�b�0 «•S Checked by Date Reference SF C.owrse -`{n - C Z - lcer. 3o,oc°< _ Z C° /i. c 3 - 4.5 3 ICO �- - .$ (Lto r s ) •t4,,coo lbs � S'? •.,z taut C . r S 4 ; e.t k rid. - 2.2:4) �n . • I r »0 ; Page 3 -2 of Job Project No. c3.- 0 tOOO % . Sheet of Description Computed by (...„...,NN. #' ` Date Co Uzi (0 2 Checked by Date Reference Pik\ - 4o - Sc il 'tae - 4th ►, r4e_. 2 x to 0 = $ Ccimely -sk `)c) ceNr,Rcn -c e-'r .... "tQ Qe_A 'oC_QA. ... S c t - tht ‘ 4 0 1? o }Fi„e GcCc1 'P M 2, -- s \c,'tq r ierssz,. `4re& ' voa d!P ..... l68 rsc • (S_00 500 -- t o • 3 �/ l2 Z • z �,2S o rs_O % ;\( G_ - 3© i ' � Z „ _ z S too = 1 4,5 c A- • ' loc. P 8,0% (3S psi Za{ . ,t .. cgo- Ore Last, ex ew. -- R-ssu.e_-4�,� o� `a � 1m -ce6- -Cot' t Ne- c1'4- oi� - 14\ � � ‘o•-/ `f 5 `> (7 S .045 CS S Ts t. es, c 22.% e (C:2 p4 •P •> tea pis C O 'JC. u_s \O t..1 C-0__ re,1"'C. tcnii es+- c. c1c rw o$ shr -esx z a � W 00 W J H CO Li_ W g Q Z O, E..W z Z O Lij O N O F- W W `—`O .z O N H = O z in a two -layer h /a =1, have Ishawn in Fig. th those for the 2 and h/a on obtained by Fox on the nd r /h, is he axis (Fox, t should be for a perfectly (ci r ) for 138 110 100 90 80 70 0 60 50 b Ia 40 30 20 10 •1 1.0 VIM •■•• M I WOO I/ rvv��• 1.1 III h -vq4 M1111111i17411111111 1111111 Mill El I r�N. rap 10 to 100 E FIG.6.3 Vertical interface stress on axis (Fox, 1948a) . 1000 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 6.1 Two -Layer Systems Unless otherwise stated, this chapter are for adhesive layers. 6.1.1 UNIFORM VERTICAL LOADING ON A CIRCULAR AREA (Fig.6.1) ■1.111r1<1.1.1 Layer 1 Et v Layer 2 E2 v2 lZ FIG. 6.1 the results given in interfaces between p /unit area Parfactly odhasiva intarfoca. Contours of vertical stress a in a two -layer system, with E1 /E2 =10, v1= v2 =0.5 and h /a=1, have been obtained by Fox (1948a) and are shown in Fig. 6.2. These contours are compared with those for the Boussinesq case (E1 /E2 =1). The influence of the ratios E1/E and• h/a on the vertical stress on the interface, obtained by Fox (1948a), are shown in Fig.6.3. The variation of vertical stress a on the axis at the interface, with E1 /E and r/h, is shown in Fig.6.4. Values of a and (a -Or) on the axis (Fox,. 1948a) are tabulated in Table 6.1. It should be noted that all the above stresses are for a perfectly rough interface between the layers. Corresponding values of o and (az -a for Chapter 6 SURFACE LOADING OF MULTI-LAYER SYSTEMS 138 a perfectly smooth interface between the layers are tabulated in Table 6.2 (Fox, 1948a). 8 110 100 90 e0 70 60 50 1° 40 b 30 20 10 0 0.1 I radius.a 1 Unlfarm •Intensity of Loadi p A ,/ll��.. ERN 11 40,_. 1111 'Ta rough y 3o intartaca ■, Vertical st i ss 0 ,■ y as parcantago • of p ■■ =1,■■ FIG.6.3 Uniform modlum:- E E2 .1 (Boussinesq 10 (Fox, 1946a). i‘n.e.-kArto, eW 10 E1 Layar 1 Modulus E 20 4a Two -layer sys E .10. v 0 .1 Layer 2 Modulus E2 a l l 1 FIG.6.2 Vertical stress in uniform mass and two - layer system (Fox, 1948a). 1111111111111111111111IMM o •0 2 1 p 11 NIIIIuu1>♦illi111111111 E 11 ��11111 IIIMIIIlIll�$111: E {{ �i.�l11111�•I I ..O 5 1111101111111111111 �u11111ii�•I11111i auIu111I� aI11111 IMMUMNIONMIIIMUMMEIMII ��i�!!III��111i!I a 1N1IIIMI1111i!! m11111II►111ill1 1111110111.1111111 X01111111 •5° i:!111a •2 . O 1 1 J.111111.1 i111III 100 Vertical interface stress on axis 1000 ANL i ELASTIC SOLUTIONS FOR SOIL AND ROCK MECHANICS H. G. Poulos Reader in Civil Engineering, University of Sydney E. H. Davis Professor of Civil Engineering, (Soil Mechanics) University of Sydney JOHN WILEY & SONS, INC. NEW YORK . LONDON SYDNEY . TORONTO •'" iz iothealzhli5f`r'•'�,J.6111P 1nY.:SC71)iSre S41b? \'t :Sin•sY::'1 {' ..C(e, z 6 Di J U 00 N W 2 J H w0 cn = z � 1 0 Z i- O D : o I • V ' • . —o . r: • = :O ~. Z Page "t t of Job eC-S. Sheet of Project No. 5 - ci t =YR 4 , 0 0 Description Computed by Date CD/ZL / 6 2- Checked by CA—) ‘•ff \ :std., Date - 1. 0.24 SIA P j i\ N r - tal , SIS Reference 4 );) 1\e:.. Te al ,--4-- . -ore ? .. `b ■A 0.k Loo.i). —"—"Ts„s_t x , ",.., 4 .z 1 ,ci u,s ce aw-tiiaci- t't k e. L.-012N- 0" \ C° -OrNe. re..N.rAme.:t■rv keaclt 1\ux•sce-r cb-sr-g1e. 'Ar■ kiack.Se__ ° Ck.kx‘reA etelic -Ea IS • • CRO..Q. .= • kN 4"-- 7. f ' • g t St . 5tPtS e.4 k t.ttgAesh . or. irer...0‘).".■mit.t..1Lciletio 'r• •tr Ittcoro 'IN • -rows cs4 . . xa ktr;'2.0 <3 3S" ' = 5093 v.s-c icttut.1 \;::43. Sea- a r, z • S72.. .75773- T-sc t 00th. c-A5KA 62A- " RS Page y - 2 of Job Project No. ^ 0k ooCouccv.s.00 Sheet of Description Computed by L,J I -. -- Date (91 ( pz Checked by Date Reference one- (off ex- c vev ` tc,c ,1 _.. less ' a de s2.t-esk ' u , `ma(-er -Vt '- ` �,.►�h ` wo l ev-s Luau su2 ce- :rite., KZacr :.v ac ast v�wa;rwt : -M Th ELSEVIER cb .1.._ Geotextiles and Geomembranes 13 (1994) 199 -206 Q 1994 Elsevier Science Limited Printed in Ireland. All rights reserved 0266 - 1144/94/$7.00 Foundation on Strong Sand Underlain by Weak Clay with Geogrid at the Interface K. H. Khing, B. M. Das, V. K. Puri, S. C. Yen & E. E. Cook Southern Illinois University, Carbondale, Illinois 62901, USA (Received 21 June 1993; accepted 17 November 1993) ABSTRACT A number of laboratory model test results for the ultimate bearing capacity of a surface strip foundation supported by a strong sand layer of limited thickness underlain by a weak clay with a layer of geogrid at the sand —clay interface has been presented. The tests were conducted at one relative density of compaction of sand and one undrained shear strength of clay. Two types of geogrid were used. Based on the model test results presented, it appears that the optimum height of the strong sand layer should be about two- thirds that of the foundation width for obtaining the maximum benefit from the geogrid reinforcement. 1 INTRODUCTION Ultimate and allowable bearing capacities of shallow foundation on weak clay can be improved to a great extent by placing a compact (or strong) layer of sand of limited thickness over it. Limited theoretical and experi- mental studies are presently available in the literature which relate to the bearing capacity of shallow foundations on layered soil (e.g. Meyerhof, 1974; Meyerhof & Hanna, 1978). Of these studies, the theoretical devel- opment of Meyerhof and Hanna (1978) appears to be the most rational one. More recently a number of papers have been published which show that geogrids can be used for reinforcement of soils supporting shallow foun- 199 8 ies IV). the bearing capacity for all purposes, (b/ LEVELS 1 0 for limited levels of uate bearing capacity the ultimate load. In nited settlement level (2) .dation at a given s/B :rent.. Since, from the mum H/B ratio for forcement is about 2/ B 10% (b /B = 10) e average values are r Tensar SS1. Hence, (3) 1.3 1.2 Foundation on strong sand underlain by weak clay 205 ► ► ► / Series III • • Series II ► ► t • Series III average • • Series II average • H _2 B 3 t ► 2 4 6 ( %) 8 10 12 Fig. 5. Variation of BCR with s/B (test series II and III; for H/B = 2/3). the increase of the allowable bearing capacity is about 20-25% due to the inclusion of the single layer of geogrid. If a further increase in BCR is needed, it will be necessary to put more reinforcement in the sand layer. 5 CONCLUSIONS A number of small -scale laboratory model tests for the ultimate and allowable bearing capacity of a surface strip foundation supported by a layer of strong sand underlain by a saturated weak clay with a layer of geogrid reinforcement at the sand -clay interface have been presented. Based on the model test results, the following conclusions can be drawn. (1) The maximum benefit from geogrid reinforcement in increasing the ultimate bearing capacity occurs when the thickness of the strong la er is about two - thirds the wi +d_.h� the foundation. (2) For H/B about the contribution of the geogrid reinforce- ment to the bearing capacity improvement is practically negli- ibl T e optimum width of the geogrid layer required to mobilize the maximum possible bearing capacity for a given sand - geogrid -clay combination is about six times the width of the foundation. z W re 2 00 U) 0 CO W J = F - • LL W u j • d I- W H = Z � I— 0 Z I — ww U � 0 - o I- wW u. 0 ..z w U = O ~ z Design Equations and Curves," Journal of Soil Mechanics and Foundation Divi- sion, ASCE, July, 1972. 2. Ohta, P., and Koto, N., "Empirical Shear Wave Velocity Equations in Terms of Characteristic Soil Indices," Earthquake Engineering and Structural Dynamics, Vol. 6, 1971. 3. Seed, H. B., and Idriss, I. M., "Soil Moduli and Damping Factors for Dynamic Response Analysis," EERC -70 Report, University of California, Berkeley, Calif., Dec., 1970. BEARING CAPACITY OF REINFORCED SAND SUBGRADES By Richard j. Fragaszy,' M. ASCE and Evert Lawton,' A. M. ASCE INTRODUCTION The beneficial effects of using tensile reinforcement to increase the bearing capacity of sands have been clearly demonstrated by several in- vestigators (1,3,4,5). The optimum number of layers of reinforcement and the optimum depth to the first layer of reinforcement has been stud- ied extensively. This note describes a series of laboratory model tests designed to determine the influence of soil density and reinforcing strip length on the load - settlement behavior of reinforced sand. Also, Binquet and Lee's (4,5) theoretical analysis of bearing capacity of reinforced earth is compared to laboratory test results. MODEL TEST ARRANGEMENT A rectangular steel footing composed of three segments each 7.6 cm wide by 15.2 cm long was used for the laboratory experiments. As in previous work (4), only the center section was instrumented so that the effect of side wall friction was reduced. All tests were conducted on the surface of a 36 cm deep sand layer in a rectangular fiberboard box with inside dimensions of 56 by 122 cm. The footing was centered in the box, with the length of the footing parallel to the width of the box. An electronic load cell and LVDT were used to measure the load and settlement, respectively, of the footing. Spacers the height of the load 'Assoc. Prof., Dept. of Civ. and Environ. Engrg., Washington State Univ., Pullman, Wash. 'Grad. Student, Dept. of Civ. and Environ. Engrg., Washington State Univ., Pullman, Wash. Note.- Discussion open until March 1, 1985. To extend the closing date one month, a written request must be filed with the ASCE Manager of Technical and Professional Publications. The manuscript for this paper was submitted for re- view and possible publication on July 28, 1983. This paper is part of the Journal of Geotechnical Engineering, Vol. 110, No. 10, October, 1984. ©ASCE, ISSN 0733- 9410/84/0010- 1500/$01.00. Paper No. 19182. 1500 rp , . . .,.... ^ l� i t cell were placed on each of the two outside sections of the footing. The footing was loaded by a hand operated hydraulic jack bolted to a loading frame located above the box. The load was transmitted to the footing through a rigid bar centered on top of the load cell and spacers. A ball bearing was positioned between the piston and the bar to ensure that no extraneous moment was applied to the footing. An X - recorder was used to plot a graph of settlement versus bearing pressure for each test. Further details on the equipment are given in Lawton (6). The soil used in the laboratory tests is an angular, uniformly graded sand (SP), with a uniformity coefficient, C , of 1.8, a curvature coeffi- cient, C„ of 0:9, and a mean grain size, D50 , of 0.4 mm. The minimum and maximum dry densities (1.37 and 1.61 Mg /m respectively) were obtained by performing the ASTM Standard Test for Relative Density of Cohesionless Soils (2). The friction angle was determined from the re- sults of triaxial tests conducted at densities of 1.47, 1.54, and 1.59 Mg/ m (D, = 31 %, 70 %, and 90 %, respectively). The corresponding friction angles are 36.5 °, 38 °, and 39 °. The soil was placed in 5.08 cm lifts up to a depth of 25.4 cm and then in 2.54 cm lifts up to the final depth. For each lift, the amount of soil needed to produce the desired dry density was weighed out and placed loosely in the box with a metal scoop. The soil was then gently leveled out and compacted to the proper depth by placing a plywood board on the surface and hitting the board with a hammer, using the depth mark- ings on the sides of the box as a guide. The reinforcing strips were cut from rolls of household aluminum foil. Nine strips of 2.54 - cm wide, 0.0254 min thick foil were placed 5.08 cm center -to- center in each of three layers. This produced a linear density ratio of.47 %, slightly higher than Binquet and Lee's value of 42.5% (4). In all tests, the layers of reinforcing were located at depths of 2.54, 5.08, and 7.62 cm below the footing. TEST RESULTS Effect of Soil Density. -Tests were performed on both unreinforced and reinforced subgrades at soil dry densities of 1.49, 1.51, 1.54, 1.56, and 1.59 Mg /m (Dr = 51 %, 61 %, 70 %, 80 %, and 90 %, respectively). The term Bearing. Capacity Ratio (BCR) is used to assist in expressing and comparing the test data and is defined as follows (4): BCR = (1) qo in which .q and qo = .the bearing pressures for the reinforced and the unreinforced soil, respectively, at the same initial dry density and at a given settlement. For the initial set of reinforced tests, a constant rein- forcing strip length of 61 cm was used. In all cases, the reinforced soil was stiffer than the unreinforced soil at the same density. Load settle- ment curves for unreinforced soil are shown in Fig. 1, for reinforced soil in Fig. 2. Calculations of BCR were made at settlements equal to 4% and 10% of the footing width (0.04B and 0.10B). These comparisons are shown in Table 1. It can be seen that at a settlement of 0.04B, the BCR increases 1501 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. TABLE 2.- Bearing Capacity Rat o Determined at Settlement = 0.10B when 4f = a, Using Binquet and Lee's (7) Theoretical Equations Dry density, in megagrams Theoretical BCR BCR from Breakage Slippage per cubic meter 4)/ model test (1) (2) (3) (4) (5) 1.49 37.0° a0 V. In N oe c•) cn N N H -21.5' 1.6 1.51 37.7° -14.6 1.7 1.54 38.3° -10.6 1.7 1.56 38.8° . -8.7 1.7 1.59 39.2° -7.5 1.6 1.2 / / / / / - / ♦/ / 1.0 0 B 2B 3B 4B 5B 6B 7B 88 Length of Reinforcing Strips (B = Footing Width) 1.1 FIG. 3.- Effect of Strip Length on Bearing Capacity Ratio at Settlement Equal to 10% of Footing Width tests. The BCR at a settlement of 0.10B versus length of reinforcing strips is shown for each t- -ii' - _ p - -- - .: th increasing strip ee gtA up to a length of about 6 -7B, after which it remains - a nstant. Binquet and - Lee's work supports this conclusion. Their test using three layers of reinforcing is quite similar to the tests performed as part of this investigation (D = 75% versus 70 %, 4 = 35° versus 38 °, linear density ratio = 42.5% versus 47 %). The vertical spacing of the strips is identical, as is the strip material itself. The only major difference is the length of the strips, 20B versus a maximum of 8B. Their BCR at a settlement of 0.10B is 1.7, the peak value obtained in the experiments described previously. Analyses Using Binquet and Lee's Theory. - Binquet and Lee's the- oretical analysis of reinforced earth slabs (5) is based on three factors: tie breaking resistance (R tie pullout frictional resistance (T and de- veloped tie force (T Comparison of the allowable resistance forces, T and R , with the driving force, Td, determines whether tie breaking or tie pullout will govern and what the BCR is for a given settlement. In order to determine values of cli to use in these equations, pullout tests were performed at soil densities ranging from 1.41 -1.59 Mg /m using a pullout device developed by Mitchell (8). At a density of 1.41 Mg /m the pullout results were consistent and indicated a 4, = 11.6 °. 1504 Unfortunately, the data from the tests at densities from 1.49 -1.59 Mg/ m (the same range as the model tests) were inconsistent. However, many of the pullout values for cli were approximately equal to the values for 4 at the same density, and since values of 4, as high as 4 were found from laboratory tests by Lee et al. (7) for strips of aluminum foil, the first series of analyses were done using 4 = 4 as an upper limit value of 4f Table 2 lists the values of BCR for a rectangular footing determined at settlement = 0.10B for both tie slippage and tie breakage when 4f = �. The BCRs for tie breakage values vary from 3.8 -1.8, in contrast with the model test results that showed the BCR to be independent of density and equal to about 1.7. The next approach consisted of calculating the f at a density of 1.54 Mg /m necessary to produce a BCR of 1.7. Then, assuming that tan cli is directly proportional to tan 4 (tan ci = K tan 4), where K is a constant), K was determined to be 0.335. The value of f at each density was then calculated. The results of this analysis are tabulated in Table 3, which shows the BCR at each density to be 1.7 with slippage controlling, which concurs with the model test results. This indicates that Binquet and Lee's equations agree with the model tests if tan (1)/ is proportional to tan 4. The values of 4i f from this analysis ranged from 14.3 ° - 15.1 °, which seem reasonable when compared to the value of 4)f = 18° found for aluminum strips by Binquet and Lee (4) and the value of 11.6° at a density of 1.41 Mg /m found from the pullout tests described previously. Also, these values appear realistic when compared to the work on reinforced earth friction done by Mitchell (8). One interesting feature of Binquet and Lee's equations is that they predict the bottom layer of reinforcing will break first (if breakage gov- erns over slippage). This agrees with the model test results presented in this paper, but is in contrast to Binquet and Lee's findings reported in Ref. 4 that breakage of the reinforcing strips occurred in the upper- most layers first. In summary, the equations developed by Binquet and Lee are very sensitive to the value of cji used. Unfortunately, 4 is quite difficult to determine accurately from either laboratory or field tests, and Mitchell 'Negative value indicates strip breakage controls. Note: 1 kPa = 0.145 psi; 1 Mg /m' = 62.4 pcf. 1505 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 SUMMARY OF TECHNICAL MEMORANDUMS Attached are three (3) out of five (5) technical memorandums which are applicable to the Interim Measures Construction Work Plan (IMCWP), and respond to certain aspects of EPA's Draft Letter of Approval with Modifications of Container Properties proposed Hydraulic Control Interim Measure Work Plan dated November 15, 2000. These memos outline the following: 1. Technical memorandum No. 2 - Barrier Wall Alternatives: EPA is proposing that part of the subsurface barrier wall be installed using sheet piles rather than soil bentonite. This Technical Memorandum outlines an alternative to sheet piles that meets EPA's concerns about soil bentonite, is superior to sheet piles at meeting the project objectives of hydraulic containment and is more cost effective than sheet piles. 2. Technical Memorandum No. 3 - Permeability of the Barrier Wall: EPA has proposed a performance standard for permeability of the soil bentonite portion of the wall that is beyond (i.e. a less permeable wall) the permeability needed for meeting the project performance objectives for hydraulic containment. This Technical Memorandum outlines an alternative view on appropriate barrier wall permeability. 3. Technical Memorandum No. 4 - Performance Monitoring: EPA has indicated that "robust" monitoring will be expected to assess performance of the subsurface barrier wall and to monitor contaminants that are left outside the wall. This Technical Memorandum outlines a plan that fully meets EPA's requirement for performance monitoring of the Hydraulic Control Interim Measure. Container Properties believes that the monitoring of contaminants beyond the wall that has also been recommended by EPA, is more appropriately addressed in the Corrective Measures Study. Summary of Technical Memorandums 1 ri Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 TECHNICAL MEMORANDUM NO. 2 BARRIER WALL ALTERNATIVES Purpose of this Memo: The U.S. EPA has given conditional approval of the Hydraulic Control Revised Interim Measures Work Plan (IM Work Plan) submitted by Container Properties on November 15, 2000, for the former Rhone- Poulenc facility located on Marginal Way in Tukwila, Washington. EPA has informed Container Properties that in accordance with paragraph 7.1 of the Administrative Order on Consent for Corrective Action (Order), it intends to conditionally approve the IM Work Plan with modifications. Key components of the hydraulic control interim measures is installation of a low - permeability subsurface barrier around the source area and a groundwater recovery system to maintain an inward flow of groundwater. Container Properties proposed that the barrier wall be composed of soil bentonite installed using slurry trenching techniques. EPA proposed that two segments of the barrier (along the shoreline of the Duwamish Waterway and Slip 6) be constructed of steel sheet piles. This memo outlines practical alternatives to the sheet pile wall along the shoreline where site conditions may not be conducive to installation of a traditional soil/bentonite barrier. The alternative barriers considered for the site include a geomembrane, steel sheet piles, traditional soil bentonite barrier wall, and a barrier wall constructed using Impermix, a commercially available barrier material composed of attapulgite clay and cementitious material. The alternatives are compared below and a preferred alternative recommended. Specifically this memo shows: • A barrier consisting of Impermix installed with vibrating beam technology is the preferred bather option along the shoreline. Technical Memorandum No.2 1 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 • An Impermix barrier would be compatible with site groundwater. z • An Impermix barrier would have lower permeability than sheet piles and w conventional soil/bentonite materials. 6 = - U 0 • An Impermix barrier would provide greater long -term effectiveness than other u) o alternatives. - = �w • An Impermix barrier would be adaptable to potential final remedies at lower costs w 0 than steel sheet piles. § co a . Containment Effectiveness: The effectiveness of each potential barrier wall alternative z for containment at the former Rhone - Poulenc site is compared based on the following w o 2 criteria: v o O CI I-- ww I F- O ..z w U 2 O / • Is it constructable? • Is it compatible with groundwater conditions in the southwest corner of the site? • Will it minimize the potential for adverse impact to critical habitat? • How well does it control pumping rates? • What is the long -term reliability /performance? • Is its cost commensurate with benefits and how do costs compare to other alternatives? • Will waste disposed associated with construction be minimized? • Is it compatible with the final remedy? These issues are discussed in the following paragraphs. Site Specific Issues: The following site - specific issues affect the quality of the bather wall installation and its long -term effectiveness. Technical Memorandum No.2 2 z Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 • Depth to aquitard: The depth to the aquitard is estimated to be up to 60 to 70 feet along the shoreline. Experience in the area indicates that organic material such as seashore remnants and timber can be encountered at depths of 35 to 40 feet. • Proximity to surface water: The site abuts the Duwamish Waterway and Slip 6, a narrow inlet extending to the east along the southern boundary. Tidal influences cause the water table, especially along the south and west edges of the site, to fluctuate. The groundwater in proximity to the river and slip is influenced by the marine waters present in the Duwamish and therefore is expected to have moderate to high salinity. • Groundwater constituents: Groundwater in the southwest corner of the site has a high pH, likely caused by caustic soda used in the Vanillin process. Metals, including copper, have been mobilized and are present in this area. Toluene and other organic chemicals are present in groundwater at the site; however, organic chemicals are not the primary constituents of concern beyond the area to be contained. Toluene is also not present in high concentrations along the alignment for the barrier wall. In addition, toluene is being treated using vapor extraction and is not expected to be a concern for barrier wall compatibility in the longer term. • Future land use issues: The site is to be developed for future commercial and industrial use. As such, the barrier wall design should include cost effective provisions for load bearing capacity or load restrictions to avoid damage from future use. Alternatives Comparison: A discussion of the various alternatives that either have been or are being considered for the barrier wall construction along the shoreline follows. Geomembrane: A geomembrane barrier to the depth of the aquitard would be subject to several constructiblity issues that render this alternative impractical. Because of the depth and soil condition, the geomembrane would have to be installed in a slurry trench. With deep trenches, sloughing of the side walls is more likely. If trench sloughing occurs Technical Memorandum No.2 3 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 during the geomembrane installation phase, there is no feasible way to clean the trench without severely damaging the geomembrane. Due to the substantial depth needed for the geomembrane barrier, it will also be difficult to reliably weld adjacent geomembrane panels together to form a continuous, low permeability barrier. Quality control measures needed to ensure a continuous, undamaged installation would be difficult to implement. Geomembrane liners have not been successfully placed to the depths required by this project. High density polyethylene (HDPE) is not generally compatible with brine and high pH conditions. This is documented in past HDPE pond failures at Chlor- Alkali processing plants, where brine and caustics are constituents of the effluent process water. Although the concentrations of these constituents at the former Rhone - Poulenc site would probably not significantly degrade the HDPE, compatibility testing with site groundwater from the southwest corner of the site would be warranted. Given that the significant difficulties noted above for installation of a geomembrane barrier indicate that it could not be properly constructed for the former Rhone - Poulenc site, a properly installed geomembrane barrier would be acceptable for both short-term and long -term hydraulic control. The primary leakage would be along the base, where sand would settle in the keyed portion and allow a pathway beneath the wall in portions of the wall damaged by trench sloughing or tears created during backfilling operations. The risk of damage to the barrier during construction is moderate to high. Breaches in the barrier would not provide a buffer for contaminant transport, and repair of any breaks would be very difficult. Overall, the cost of installation for a geomembrane barrier would be high, in the range of a sheet pile wall, with a high risk of failure or overruns and minimal opportunity for repair of any breaks or failures. Potential risks associated with slurry discharge to adjacent waterways and the need to transport and dispose of excess excavated soils will Technical Memorandum No.2 4 z _� ;F .z w 6 J U 00 U U cow J = w J LL Q cn _ • w Z zI- W U • � O — wW 1-F � o .. z w co 0 . . z Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 be essentially the same for the geomembrane wall as for a soil bentonite wall, and significantly greater than such risks associated with a steel sheet pile wall. Steel Sheet piles: A continuous steel sheet pile bather would be difficult to install to the depth of the aquitard, but is considered feasible. Additional geotechnical explorations would be needed to confirm that the proposed alignment is free of obstructions. Surface exposure of contaminated materials would be limited and disposal of contaminated materials would be minimal. Pile resistance increases with depth and with it the energy required to continue driving. At the depths required, hammer energy approaching the pile capacity may be reached or exceeded. Obstructions at depth, such as timber, could cause damage to the sheet piles, in particular to the joints. Joint continuity and interlock are critical to obtaining a low permeability for the sheet piles. The nature of the pile installation creates a preferred pathway for groundwater to flow along the pile face to any defects. If damaged or left open, joints permit unrestricted flow of groundwater across the pile boundary with no adsorption of contaminants. Damaged joints are difficult to detect and if detected, are difficult to repair. The effective permeability of a steel sheet pile wall is largely dependent on the size of the joint openings. The permeability of steel in good condition is zero. Assuming minimal alteration of soil conditions due to driving and the creation of minimal vertical preferred seepage paths (as discussed above), the effective permeability of a steel sheet pile wall is a function of the average joint opening in relation to the sheet pile width. For example, 12- inch -wide steel sheeting with an average joint spacing of 0.12 inch would result in an effective permeability of about 1 /100 (0.12/12) that of the soil. Assuming this reduction of 2 orders of magnitude, the effective permeability of the steel sheeting in the upper aquifer will be approximately 2 x 10 cm/sec. Based on this analysis, a steel sheet pile wall is considered marginal for hydraulic containment. Barrier permeability on the order Technical Memorandum No.2 5 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 of 1x10 cm/sec or less is preferable for hydraulic control at reasonable pumping rates (refer to Technical Memorandum No. 3). Lower permeabilities can sometimes be obtained using groutable joints and suitable joint fillers, but these techniques will be difficult to perform effectively at the depths of this project. Barrier wall permeabilities being recommended by EPA will not be met using sheet piles. The steel pile and joint filler would be subject to corrosion attack by the high pH water on one side of the boundary and marine environment on the other side. This could create a concentration cell that may accelerate corrosion, possibly causing the dissolution of metals. Tidal fluctuations of the water table would also create a large aerobic zone, in which the steel sections would be exposed to an oxygen -rich environment conducive to corrosion. Long -term reliability and performance of the steel sheet pile wall is expected to be less than the other alternatives examined. Based on the groundwater conditions and potential corrosion of the steel, a functional life of 20 to 30 years can be expected." Potential risks to adjacent surface water bodies that would result from installation of a steel sheet pile barrier along the shoreline are considered minimal. No affected media will be brought to the surface, creating risks for handling, transportation and disposal. If joints are grouted, slurry materials may be used, leading to a low potential for release, assuming proper management actions are implemented. A small risk also exists for release of hydraulic fluids from the pile driving equipment. The cost of a steel sheet pile barrier with grouted joints is expected to be from 3 to 5 times greater than installation of a traditional soil/bentonite wall or a barrier constructed with Impermix. Other alternatives provide similar or better performance at lower cost. Technical Memorandum No.2 6 • Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 One reason for selecting steel sheet piles that was noted in the proposed EPA conditional approval letter is the potential for supporting excavation of the area outside the barrier. The proposed approval suggested that the sheet pile barrier be designed to provide for excavation. Sheet piles, designed for containment, would support only limited depth excavations while retaining its containment effectiveness. Leakage at joints or holes from using tiebacks that would be required to increase structural integrity are issues to the long term effectiveness of the performance of the barrier wall for hydraulic containment. These issues are discussed in more detail in Technical Memorandum No. 5. The total benefit of the steel sheet pile barrier is expected to be small compared to the costs of the installation, especially considering that the nature of the final remedy is yet undetermined. For long -term source area containment, a sheet pile barrier is considered the least desirable of the alternatives evaluated due to its expected effective life span and the higher permeabilities. Soil - Bentonite Barrier: A soil - bentonite cutoff wall is expected to be readily constructible. The barrier would likely be set back from the slope crest at least 30 feet to allow room for construction equipment and to provide a necessary buffer zone to provide .a high level of safety against potential surface slurry discharge to the adjacent water courses. The potential for surface discharges can be minimized through effective construction management and use of safeguards during construction. Obstructions such as buried logs that may be encountered at depth could be readily handled by conventional trench construction techniques including rock chisels. The soil conditions at the former Rhone- Poulenc site are otherwise considered nearly ideal for slurry trench construction., Based on the subsurface conditions identified in site investigations, the potential for subsurface slurry loss is considered very low. Excess materials on the order of 20% of the trench volume would require suitable disposal and constituents of concern would be brought to the surface during barrier construction. Construction quality control to confirm a continuous installation is straightforward. However, the completed wall has Technical Memorandum No.2 7 to . w r3irmlteP ,,4sTik7..*aafiY+Sai�7antS, ;na:�.+wwr,�,r. Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 low strength and would require installation of a structural platform above the top of the wall to accommodate future land use loading conditions. Sodium bentonite is not likely to be compatible with the high pH and saline conditions along the shoreline. Compatibility tests would be warranted prior to proceeding with construction of this alternative in the areas of high pH and/or salinity. Care would be needed during construction to ensure that the properties of the slurry did not degrade during trench construction, which could lead to trench failure. Other clays could be substituted for sodium bentonite to address compatibility issues, but would likely require further compatibility testing. Soil - bentonite walls provide an added benefit for addressing contaminants such as metals, in that metals migrating through soil - bentonite will tend to adsorb to the clay fraction. The amount of adsorptive capacity is based on the percentage of fine- grained material in the wall and the wall thickness. The cost of soil - bentonite wall construction along the site shoreline is expected to be the lowest of the alternatives being evaluated. Soil - bentonite barrier wall costs are expected to be on the order of one -third to one -fifth the cost of the steel sheet pile alternative. The benefit of long -term containment of constituents of concern for the soil - bentonite wall is considered moderate. It is likely to be less permeable than steel sheet piles, but less effective than a barrier constructed of Impermix due to the potential compatibility issues with high pH and salinity. A soil bentonite wall along the site shoreline is likely to be compatible with the final remedy due to its long -term integrity. Due to its low strength; however, a soil bentonite wall offers little structural benefit for excavation of materials in the immediate vicinity of the wall, should this become necessary. However, excavation of contaminated materials outside the contained area could be accomplished using temporary sheet piling, or other methods, at costs much less than the initial installation of a permanent sheet pile barrier Technical Memorandum No.2 sn�yVCT'fi 8 `Ns t, Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 (see Technical Memorandum No. 5). The compatibility issues related to the high pH and salinity along the shoreline may cause an increase in permeability of the soil - bentonite wall. Impermix Barrier: A barrier constructed with Impermix and using vibrating beam construction technology can be readily implemented at the site. The technique uses a self hardening slag cement and attapulgite clay slurry (similar to a cement bentonite slurry) to construct the barrier. The beam, about 3 feet wide, is hung from a crane and advanced to the confining layer using vibration. Barrier constructed using this technology are typically about 6- inches thick, but have been designed for thickness varying from 5 to 18 inches. Pressure jetting using the circulated slurry mix can be employed for advancing the beam through dense layers of soil. The soil displaced by the beam is compacted to the side of the trench by the beam, hence, no excavation materials are generated and constituents of concern are not brought to the surface. The slurry hardens to a strength of several hundred psi and would be conducive to future land use without additional significant design considerations. Slurry quantities are much less than required with a conventional slurry trench. The slurry is contained in a 2 foot by 2 foot trench excavated along the alignment. This technology has been implemented successfully in many prior applications, and can be done with minimal risk of releasing barrier materials to the adjacent waterway. The barrier wall alignment provides ample buffer space to reduce the potential for surface releases of slurry. Appropriate management safeguards can be employed during construction to minimize the potential for impacting critical habitat areas by slurry releases. Potential risks for affecting critical habitat as a result of installing an Impermix barrier using vibrating beam technology are considered only slightly greater than potential risks associated with sheet pile installation. Conditions at the site are nearly ideal for the installation of the vibrating beam barrier with the exception of potential obstructions at depth. Various alternatives are available to Technical Memorandum No.2 9 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 circumvent any obstructions encountered, including switching to pile driving techniques (i.e. steel can be inserted in the trench and driven to break up the obstruction) or moving the alignment around the obstruction. If the obstruction is chiseled through, the vibrating beam can be returned to the trench without jeopardizing the integrity and continuity of the installed barrier. The liquid nature of the self hardening slurry ensures that the wall will be continuous. Observations of the installation and straightforward construction QA can document proper barrier installation. The Impermix self hardening slurry has been used extensively, and ample data exist to demonstrate compatibility with groundwater conditions in the southwest corner of the former Rhone- Poulenc site and the saline conditions along the shoreline. High pH additives are often used as an enhancement agent to decrease the permeability of the final Impermix barrier. Studies have shown that permeabilities in the range of 1x10 cm/sec to 1x10 cm/sec are achievable in conditions similar to those anticipated for the former Rhone - Poulenc site. Results of compatibility tests performed by Thomas and Tallard are attached to this memo (Attachment 1). Achievable permeabilities in the range of 1x10" cm/sec are more than sufficient to establish hydraulic control at efficient pumping rates, as previously discussed and as presented in Technical Memorandum No. 3. These very low permeabilities more than compensate for the wall being thinner than a traditional soil - bentonite wall. The overall resistance to groundwater flow is greater in a thin Impermix wall than in a thick soil - bentonite wall. The long -term reliability and performance of an Impermix barrier is expected to be the best of the alternatives evaluated. The known material compatibility and affinity to the high pH conditions and nature of the barrier materials would ensure that the wall remains effective as a containment barrier for a period well beyond the life of the project. The extremely low permeability of the barrier materials would reduce contaminant transport to a level several orders of magnitude below that of the other alternatives evaluated. Technical Memorandum No.2 10 • ■•• y Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 The cost of installing the Impermix barrier is on the order one third to one half the cost of a steel sheet pile wall and one and one half to two times the cost of a soil - bentonite wall. There are no costs or risks associated with handling, transportation, and disposal of excess contaminated materials since none are generated. The Impermix barrier provides the highest cost/benefit ratio of the alternatives evaluated for the shoreline of the former Rhone- Poulenc site. The Impermix barrier is expected to be fully compatible with the final remedy with respect to long -term containment and future land use, as discussed above. In the event it becomes necessary to excavate affected soil from the area outside the shoreline barrier wall, cost effective approaches are available to protect the integrity of the Impermix barrier, as discussed in Technical Memorandum No. 5. One alternative is to install temporary sheet piling a few feet on the outbound side of the wall at the time of excavation. The total cost of such temporary actions to support excavation would be much less than the cost for installation of a steel sheet pile wall as a containment barrier. Conclusion: The Impermix barrier wall is a superior alternative to a steel sheet pile barrier and the other alternatives discussed in ALL of the categories evaluated. It's superior long -term effectiveness, known compatibility with site groundwater, compatibility with the final remedy, minimization of construction related waste and low potential to negatively impact critical habitat, are sufficient reasons to select this alternative for the south and west portions of the barrier wall over other alternatives including a steel sheet pile barrier. Potential for impact to critical habitat while constructing the Impermix barrier wall is addressed in a separate technical memorandum. Technical Memorandum No.2 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 ATTACHMENT 1 z Unique Hydraulic Conductivity Test Results from a Self - Hardening Slurry t aa JU U Greg Thomas l and Gilbert Tallard2 w 11.1 1- u_ Abstract: Self- hardening slurries using attapulgite clay and blast furnace slag cement w 0 have often been used as a low permeability alternative to cement - bentonite slurries. g a Recently, there has been a growing use of self - hardening slurries in other barrier forms, i a w such as in deep soil mixing, vibrated beams, slurry trenches and jet grouting, largely due �- 0 . to the recognition of the materials capability of providing a low hydraulic conductivity z UJ w under adverse environments. Recent testing of one of these self - hardening slurries for v ❑ N use in barrier construction has highlighted some of the unique testing problems associated o F w — with these materials, which in turn highlight some of the unique characteristics of the 0 material. �` z w z co 5'- For this study, two specimens were trimmed from a single sample of a self - hardening z slurry. After consolidation and saturation, one specimen was permeated with tap water using an initial gradient of approximately ten while a second specimen was permeated using a gradient of about 100. Initial hydraulic conductivity measurements for both specimens were on the order of 1x10" cm/sec. Subsequently, both specimens showed a trend of decreasing hydraulic conductivity to approximately 5x10 " cm/sec, as shown in Figure 1. At this point of permeation, the flow rate measured using a gradient of ten dropped rapidly to below the sensitivity of the equipment. , 1 Laboratory Director, URS Corporation, Totowa, NJ 07512 Ph 973.812.1818, Fx 973.812.8640, reg thomas @urscorp.com (corresponding author) President, Liquid Earth Support, Inc., Pelham, N.Y. 10803 Technical Memorandum No.2 12 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Figure 1— Hydraulic Conductivity variations as a function of duration of permeation. The applied gradient for this test was then increased in stages. No measurable flow "-` occurred until a gradient of approximately 40 was applied, at which point a hydraulic conductivity of about 4x10 cm/sec was again determined. The test on the second specimen was continued by dropping the gradient in stages, as shown in Figure 2. This resulted in generally increasing values of hydraulic conductivity until a gradient of about 40, at which point measurable flow abruptly ceased. These results indicate that a gradient of about forty may exist as the long -term threshold gradient for this material, below which no measurable flow occurs. Technical Memorandum No.2 13 wZ. &AlohaC:4 Z :.:w:0erc w.rva ea+++a+tr. Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Figure 2 — Example results of hydraulic conductivity vs. gradient These results are for one specific slurry mix. Results for other self- hardening slurry mixes will depend on the age and amount of solids present in that self - hardening slurry mix, but hydraulic conductivities better than 1x10 cm/sec are typically achievable with these materials. At these low hydraulic conductivities, the use of field level gradients in the laboratory is impractical, and even with an applied gradient of approximately thirty (the recommended maximum hydraulic gradient in ASTM Method D 5084), flow may be minimal to nonexistent. Under most test programs, the hydraulic conductivities for this material would have been measured using a gradient of approximately thirty and with all readings made within a few days of consolidation of the specimen. Under these conditions, the value would probably have been reported as approximately lx10 cm/sec. As these tests indicate, the long -term behavior of this material would more likely be on the order of 5x10 cm/sec, if a sufficiently high gradient existed to cause flow at all. However, under most field Technical Memorandum No.2 14 .(a!iu..� �i:�.�Df�✓`.+�jv"J.w;.r, .Uyx_.A_, �i�t .. _ _. "�. .1 JIM • Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 conditions, gradients would not be above the threshold gradient, and the self - hardening slurry would create a practically impermeable barrier. Figure 3 shows the results of a series of stages made on a third specimen made from a similar self - hardening slurry as in the previously reported tests. The structural integrity of this specimen was intentionally damaged by hydraulic fracturing by rapid release of the confining stress and by statically shearing the specimen to evaluate the healing characteristic of this material. After each of these stages, measured hydraulic conductivities showed significant increases compared to prior to stressing the specimen, indicating that the specimen was damaged, but in each case the slurry showed that it has some capacity to reheal itself after it is allowed to reconsolidate. Technical Memorandum No.2 15 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 1.00E-6 1.00E-7 1.00E -8 1.00E -9 1.00E -10 0 hydraulically fractured Static Shea Stress Release, new stones w ith NaOH 20 40 60 Elapsed Time (days) '\ .,,,,x.7\K Below system — useable range _ 80 100 120 Figure 3 — Example of self - hardening slurry response to stressing and permeant pH Finally, the permeant was switched from tap water to a caustic NaOH solution with a pH of approximately 13. With this permeant, the hydraulic conductivity dropped rapidly to below the equipment's capacity to measure. Similar trends have also been noted for permeants with low pH values. Recognition of the unique behavior of this construction material, such as the practical existence of a threshold gradient, its' capacity to decrease hydraulic conductivity with Technical Memorandum No.2 16 7 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 time and to self -heal, and its' response to environments of extreme pH values, may provide benefits if its' particularities are exploited wisely. References Annual Book of ASTM Standards, 2001, Volume 04.08. D 5084 -90, Standard Test Method for Measurement of Hydraulic Conductivity of Saturated Porous Materials Using a Flexible Wall Permeameter. Technical Memorandum No.2 17 <riSSUie'AV+.aA'..�fsri`+'HT 3.: .4 !/++ iV•"-`+ ��: Y' i' WI: i '�'L4LZ+k:e'+'�i�'Sh`i;"':� : 1= 5." �Lki'+ bti. dtrw'!✓ liYYetiti�Y.51':+ "L4Rth'h"1}i'� Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Technical Memorandum No.3 TECHNICAL MEMORANDUM NO.3 SUBSURFACE BARRIER WALL PERMEABILITY REQUIREMENT Purpose of this Memo: The U.S. EPA has completed its review of the Hydraulic Control Revised Interim Measures Work Plan (IM Work Plan) submitted by Container Properties on November 15, 2000, for the former Rhone - Poulenc facility (the site) located on Marginal Way in Tukwila, Washington. EPA has informed Container Properties that in accordance with paragraph 7.1 of the Administrative Order on Consent for Corrective Action (Order), it intends to conditionally approve the IM Work Plan with modifications. This IM Work Plan covers planned remedial activities to control potential migration of constituents of concern (COCs) from affected soil and groundwater on the site. The key components of the hydraulic control interim measures are a low - permeability subsurface barrier wall to be installed around the source areas and a groundwater withdrawal system to maintain an inward hydraulic gradient into the containment area. As part of the conditional approval of the IM Work Plan, EPA is proposing the subsurface barrier wall attain a hydraulic conductivity (commonly referred to as permeability) of 1 x 10 -7 centimeters per second (cm/s). To meet this field permeability, EPA proposes that slurry mix designs completed prior to installation of the wall must meet a laboratory permeability of 5 x 10 cm/s. This memorandum outlines the rationale for hydraulic containment using a subsurface barrier wall and provides technical justification for a design permeability of 10-6 cm/s. 1 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 level measurement, field measurements, and chemical monitoring for COCs. The proposed program includes the following: • Installation of 12 performance monitoring wells outside the barrier wall area and 3 wells within the containment area • Pre - construction baseline monitoring of groundwater conditions • Performance monitoring for water level elevations on a continuous basis for 1 month following completion of the interim action • Monthly monitoring of field parameters (Specific conductance, pH, dissolved oxygen, and temperature). • Quarterly chemical monitoring for key indicator constituents of concern (toluene and copper). Technical Memorandum No.4 7 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Control of the Zone of Influence: Aquifer systems are, by nature, highly variable. Without introducing a high degree of conservatism, it is difficult to place wells such that their zones of influence overlap. Similarly, it is difficult to ensure that contaminants at the margins of a pumping system will be captured by the well(s). Complicating the situation for this site is the presence of the Duwamish Waterway and Slip 6 on two sides of the area of contamination. These two sources of water could overwhelm a pumping system that does not include a barrier wall. This is especially true at high pumping rates. In other words, as the rate of pumping increases to ensure control of contaminated water, even more clean water from the Duwamish and Slip 6 is captured by pumping. Of course, the removal of clean water from the Duwamish is not beneficial to the environment and increases the cost of pumping and treatment. At present, four barrier wall systems are under consideration: a geomembrane wall, a steel sheet pile wall, a soil -clay wall, and a wall composed of Impermix and installed using vibrating beam technology. Each of these wall systems is sufficient to control the zone of influence of the pumping well(s). These alternatives are discussed in Technical Memorandum No. 2. Hydraulic Performance of System During Pumping: The hydraulic performance of the system during pumping is a function of (1) the flow through the wall, (2) the flow through the aquitard, and (3) the infiltration of precipitation. For purposes of this analysis, the site will be assumed to be paved with concrete for industrial use, such that infiltration is negligible. Flow through the aquitard is influenced by the natural (upward) gradient through the aquitard, the enhanced upward gradient caused by pumping, the permeability (vertical) of the aquitard, the thickness of the aquitard, and the size of the area within the bather wall. The vertical hydraulic conductivity of the aquitard is not known, but based on the description of the soil is believed to be no lower than 5 x 10 " cm/s. The natural gradient and the thickness of the aquitard are estimated to be 0.003 ft/ft (RCl/RPI Groundwater Monitoring Plan) and 20 feet (Hydraulic Technical Memorandum No.3 3 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Control Revised Interim Measures Work Plan, Nov. 15, 2000), respectively. Assuming that pumping will lower the water level within the barrier wall by 1 foot, the resulting enhanced vertical gradient is 0.060 ft/ft. Using the 5 x 10 cm/sec value for the vertical permeability and an area within the barrier wall of 420,000 square feet, the flow through the aquitard can be calculated to be approximately 1.9 gallons per minute. Flow through the barrier wall is influenced by the drop in water level across the wall, the length of the wall, the saturated thickness of the aquifer, and the permeability and thickness of the wall. For purposes of this analysis, the water level drop across the wall will be assumed to be 1 foot, the length of the wall 2,600 feet, and the effective saturated thickness 60 feet. Three different wall materials will be considered: steel with a thickness of 0.25 inch and an effective permeability of 5 x 10 cm/s or 1 x 10 " cm/s, soil -clay with a thickness of 3 feet and a permeability of either 1 x 10-6 cm/s or 1 x 10 cm/s, and Impermix with a thickness of 0.5 foot and an effective permeability of 1 x 10 " cm/s. The expected flow rates through the different wall configurations for these conditions are shown in Table 1A. The total quantity of water to be pumped is the sum of the water flowing through the aquitard and the water flowing through the wall. This combined flow is illustrated in Table 1B. As can be seen, the flow through the sheet pile wall is significant compared to the flow through the aquitard. Flow through the soil -clay wall is insignificant at permeabilities equal to or lower than 1 x 10 cm/sec. Finally, the expected flow through the Impermix wall is similar in magnitude to the flow through the soil -clay wall with a hydraulic conductivity of 1.0 x 10 cm/sec. Hydraulic Performance of Wall During Periods of Pumping Interruption: When pumping is interrupted, the average gradient across the site is expected to return to approximately the existing average gradient of 0.003 ft/ft. However, unlike the current situation, most but not quite all of the head loss will occur across the upgradient and downgradient walls. For purposes of this analysis, the entire head loss that presently occurs across the area to be contained will be assumed to occur across a barrier wall assumed to be twice the wall thickness anticipated for Technical Memorandum No.3 4 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 installation at the site (i.e., two barrier walls in series). The total head loss is calculated to be 02.25 ft (0.003 ft/ft times 750 feet). The calculated fluxes through an Impermix barrier system and a clay -soil barrier system with a saturated aquifer thickness of 60 feet are summarized in Table 2. Flow through a sheet pile wall is expected to be somewhat greater than the calculated flow through a clay barrier with a permeability of 1 X 10 cm/sec, as shown on Table 2. The former Rhone- Poulenc site under current conditions with no barrier wall present has an estimated groundwater flux across the site of approximately 0.14 gallons /day /ft which is two orders of magnitude greater than that estimated for the soil/clay and Impermix barriers anticipated for interim action . This indicates that the proposed interim action will result in an immediate benefit to human health and the environment. Conclusion: The analysis presented herein demonstrates that the construction of a barrier wall will effectively increase the effectiveness of the pumping system by decreasing the influence of the nearby waterways on recharge to the shallow groundwater; reduce the pumping (groundwater extraction) needed to hydraulically control the COCs, and reduce the flux of groundwater across the site and into the adjacent waterways by at least two orders of magnitude from current conditions. The permeability requirement of the barrier wall is not critical as long as the permeability is roughly equivalent to the permeability of the aquitard or lower. Therefore a permeability of 10 cm/s is sufficient as a performance requirement for the barrier wall. Permeabilities lower than 10 -6 cm/s have marginal benefit in meeting the short term project objectives; however, lower permeabilites could provide some additional long -term benefit. A barrier wall of soil - bentonite, soil -clay, cement - bentonite, or Impermix will readily meet the performance criteria for a low permeability barrier wall. A typical sheet pile wall installation will not meet the performance requirements and will result in much higher pumping rates in order to maintain an inward gradient to the site. In addition, the sheet pile wall provides poor long -term performance in comparison to other wall types. Technical Memorandum No.3 �M6aW�mi 5 z 6 JU 00 ❑ J = H • w w 0 Q = • a I- 11 Z I- 0 z F- w • w U ❑ O Y w w z 0 z . •t.'• '� Y!:j" % .HST � a ' ^)' `' �. 3 �. > `:: L4 4/yi A � '`L`NJ' .v..� +T /,t ' + : •. $ :+` Y� S.G �.t� " y� mss `. � .�::�in� -t �' f 'V' 1�' t:h,• a. } , . + ?1; i ,. �.,�, � v:3 -... .,�^: ^*�f t• • q 7-i .v3'. 23' ti - t. .. �:f ;l. t. ..f. ?37£;. t...t t , \ � •' . k;,.:y . . . 'i``': • r.5 .:: a , •- Ym �`k;:�..:; � v .., _�? � 1' • : ?^S ,�ii. � "34 .`.T .S• �r...: .1:a�� �i��'S . Y.. • .. }. :.r t - ti°.. .i s. 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L . 4 � F, .. ) . � ��`': .. � -:- �.4 : V610 ��. � a dtr {y . -✓�, � :.3 .. feetfda r �.�..k;�'� Y)�:�. .. —:.0 a cted Travel ,: C � .. :<TimerThrou -' •: g = f :. ;(' y;[�; ... da ears Soil -Clay 1x10 [0.00283] 3 1/3 156,000/2,600/60 0.8 4.91x 10 2,037,000 [5,600] 1x10 - [0.000283] 3 1/3 156,000/2,600/60 0.08 4.91x 10'' 203,700 [560] Impermix 1x10 " [0.0000283] 0.5 1/0.5 156,000/2,600/60 0.05 2.94x10"' 1,700,000 [4,600] Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 a Hydraulic conductivity Technical Memorandum No.3 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. .. .,. ..„, - . -a le 4 . - k.: 4 1 k- - .• - ,-.7 ' . 114 , -.'' . 1 / 4 kk .1., 1......., ,, I . : ,..,,,,, 4 ,...,,,, x , ....., -b ;,... otWitt n ePuniped :w --.-- ,....,..,f,,,,-, .,,,,,,,,,,/,„,.. X' -xtNAtat:x.... ' f•''''W1W14'4 k inieriRlioneiPoulenelCOn e ifBarrieice. . -.P st- ,:::,:r4,....,,,,...,.....„„,,... Type A-- of Barrier ,...,.:..k.. .:,: , '' etrifea Ili -v.f [f :4,4-7.7 -, , : c sec, ...,„, , - T - 4 A•''',' '-'"' - '"W"P" idii" 'Ps:5 2itiotA, ' , oaten . - ' . , 4:, ,V _ Ji t„F Feat., ee ""... 7-4 0,-..leVic (-g ' * ' : - a o er,Kt.,, .,- „,„,-..., . ..,..r.., fitel'''A Soil-Clay and Aquitard Soil-Clay 1x10 [0.00283] 0.33 156,000 1 Aquitard 5x10 [0.00142] 0.06 420,000 2 Total Flow 3 Soil-Clay lx10 [0.000283] 0.33 156,000 0.1 Aquitard 5x10 [0.00142] 0.06 420,000 2 Total Flow 2 Impermix and Aquitard Impermix 1x10 [0.0000283] 2 156,000 0.05 Aquitard 5x10 6 [0.00142] 0.06 420,000 2 Total Flow 2 1 _ = Container Properties, Properties, L.L.C. 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Soil -Clay and Impermix Soil -Clay 1x10' [0.00283] 0.38 33,000 0.008 Soil -Clay 1x10 [0.00028] 0.38 33,000 0.0008 Impermix 1x10' [0.0000283] 3.38 33,000 0.0007 Current Conditions None 5x1 0' 6 [0.00142] 0.003 33,000 0.14 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 Technical Memorandum No.3 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Technical Memorandum No.4 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 TECHNICAL MEMORANDUM NO. 4 INTERIM MEASURES PERFORMANCE MONITORING Purpose of this Memo: The U.S. EPA has completed its review of the Hydraulic Control Revised Interim Measures Work Plan (IM Work Plan) submitted by Container Properties on November 15, 2000, for the former Rhone- Poulenc facility (the Site) located on Marginal Way in Tukwila, Washington. EPA has informed Container Properties that in accordance with paragraph 7.1 of the Administrative Order on Consent for Corrective Action (Order), it intends to conditionally approve the IM Work Plan with modifications. The key components of the planned hydraulic control measures include installation of a low- permeability subsurface barrier wall surrounding the contaminated area and installation of a groundwater recovery system to maintain an inward hydraulic gradient. The proposed conditional approval also requires that an approved performance monitoring plan be implemented with the approved interim measure. The performance monitoring program requirements specified in the conditional approval include immediate detection of a failure or release from the containment area and verification of whether the barrier wall is meeting approved performance standards. Additional EPA requirements for the performance monitoring program include monitoring the rate of migration of contaminants outside the wall, in the riverbank, and monitoring the health of the near -shore critical habitat. Container Properties agrees with EPA that performance monitoring is needed to support the interim measure. However, Container Properties proposes an alternative scope of monitoring to be associated with the interim action. This memo outlines Container Properties' proposed performance monitoring plan for the 1 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 interim action. This approach has been prepared with the intent to initiate discussions and reach consensus with EPA prior to submitting a performance monitoring plan as part of the 30% design submittal. w 6 Specifically, the basics of the proposed performance monitoring approach are as follows: o o u) cnw J = - • As part of the interim measures construction, installation of 12 performance w monitoring wells outside the barrier wall area and three wells within the containment J area. • Pre- construction baseline monitoring of groundwater conditions within and outside 1- i z� the proposed containment area, including monitoring of water levels and groundwater z o uj chemistry. U 0 • Performance monitoring for water level elevations on a continuous basis for 1 month 0 D- o I-- following completion of the barrier wall and initiation of the groundwater pumping. = • Monthly monitoring of field parameters (Specific conductance, pH, dissolved oxygen, u. 0 z and temperature) for the first year. After 1 year, these parameters will be measured o Cl) along with the chemical monitoring program. z 1- • Quarterly chemical monitoring for key indicator constituents of concern (toluene, and copper) until statistical analysis shows that the frequency of monitoring can be reduced. The above monitoring program is sufficient to assess the performance and effectiveness of the interim measure. Monitoring for migration of contaminants in the river bank and for the health of the near -shore habitat is not needed to assess interim measures performance, and is considered more appropriate to be addressed in conjunction with the Corrective Measures Study. Performance and Compliance Monitoring Objectives: The objective of the performance and compliance monitoring is to verify that the hydraulic control interim Technical Memorandum No.4 2 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 measures meet the performance standards approved by EPA. The objective of hydraulic control is to prevent further migration of constituents of concern (COCs) from the z proposed containment area of the site. As such, the performance monitoring needs to be = ~ w able to verify (1) that groundwater pumping within the containment area maintains an e 2 inward hydraulic gradient of adequate magnitude, (2) that the barrier wall is effective in -I p 0 reducing groundwater pumping, and (3) The wall minimizes the potential for further w ( � releases of COCs through the wall and mobilization of COC's outside and in the vicinity o w of the wall. Immediately following completion of the barrier wall installation, 2 groundwater monitoring will be performed in conjunction with conventional barrier wall u- monitoring to verify that construction meets the performance standards of the design (i.e., I i that the construction was successful and there are no gaps in the barrier wall). z !- o z'— Groundwater monitoring will continue after construction to evaluate the wall's longer term effectiveness. o o — N 01— ELI 2 L I o .. z w co O Monitoring Well/Piezometer Network: To monitor the hydraulic performance of the barrier wall and pumping system, a total of 15 monitoring wells or piezometers will be installed (please see Figure 1). On the outside and within 30 feet of the wall, a total of five nested pairs of wells will be installed on the downgradient sides of the barrier, between the wall and the shoreline. Each well pair will consist of a shallow well with a screen interval bottoming at less than 20 feet below grade and a deeper well with a screen bottoming at approximately 50 feet depth. For upgradient and cross- gradient monitoring, one shallow (i.e., 20 feet deep) monitoring well will be placed along the east and north sides of the wall (two wells total). Within the containment area, a total of three shallow piezometers will be installed along the south, west, and north walls. Monitoring of Inward Hydraulic Gradient: An inward hydraulic gradient will be maintained into the containment area by groundwater withdrawal from within the barrier wall area. The performance standard for maintaining the inward gradient will be maintaining the mean level of the groundwater within the containment area at a level 1 foot below the groundwater level measured in monitoring wells outside the barrier. Technical Memorandum No.4 3 z Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 This approach is considered equivalent in protectiveness to maintaining a 1 foot difference in water level relative to the Duwamish, as proposed by EPA. This approach will simplify water level monitoring, will be used to control pumping, and will improve safety. The proposed monitoring system will include piezometers and/or monitoring wells inside and outside the wall area, which will allow water level measurements to be taken and confirm that performance criteria are met. The pumping system will be designed to operate using pressure transducers placed within a single well inside the wall and within one well located outside the containment area. The pump controller will be set to automatically maintain the desired difference between the mean groundwater levels in the selected wells. An appropriate statistical procedure will be used to determine the mean groundwater level. The proposed continuous water level monitoring approach can easily be installed and maintained, allowing real time acquisition and continuous measurements, whereas it would be difficult to install and maintain an automated data acquisition system using a river gauge. In addition, controlling the water level inside the barrier relative to a monitoring well outside the barrier could be more conservative than measuring the 1 foot differential for the river, as proposed by EPA. Assuming that the groundwater level is properly controlled inside the barrier, a slight inward gradient, could occur between the barrier and the mean river level. If the barrier groundwater level (inside the wall) were maintained 1 foot below the mean river level, the difference in water levels for wells outside and inside the wall would be less than 1 foot. A final reason supporting use of wells rather than the river level is that the dampening effect in the aquifer and the absence of wakes will make interpretation of results more reliable. Use of monitoring wells equipped with pressure transducers to control the groundwater level will also provide continuous groundwater level data to document attainment of an inward gradient for the two well locations. During start-up operations, eight of the Technical Memorandum No.4 4 Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 monitoring wells located outside the wall and the three wells located within the barrier wall will be monitored for a period of 1 month on a continuous basis using data loggers equipped with pressure transducers. These monitoring data will be used to confirm that there are no significant failures in the barrier wall, since a response to pumping at monitoring points along the outside of the wall would indicate if there is a significant leak in the wall. These data will also provide a basis for selection of the wells to be used for controlling the water level inside the barrier wall. For the longer term, monthly manual monitoring of water levels in all 15 wells both inside and outside the barrier wall will be conducted in addition to continuous monitoring of the two wells for control purposes. This monitoring frequency will be adequate to confirm performance of the barrier wall and groundwater recovery system, and to detect failure with sufficient frequency to provide for mitigation, if appropriate. Water Quality Monitoring: The proposed conditional approval includes requirements for monitoring water quality in addition to performance monitoring. The objective of water quality monitoring is to assess changes in groundwater chemistry outside the wall and to determine if COCs are passing through the barrier wall. The proposed conditional approval prepared by EPA includes monthly groundwater quality monitoring until it is demonstrated that no adverse effects have occurred on groundwater downgradient from the bather wall. Due to the very slow dynamics typical of groundwater systems, long- term monthly monitoring is excessive. Instead, it is proposed that monthly water quality monitoring be performed for 1 year after installation of the bather, followed by quarterly monitoring consistent with the long -term chemical monitoring program. This sampling would be performed on the six nested well pairs (12 wells total) located along the shoreline downgradient from the barrier wall (Figure 1). This would provide water quality data for deep and shallow groundwater, and would occur with a frequency sufficient to allow timely mitigation, if warranted. The specific concerns regarding changes in water chemistry were not described in the proposed conditional approval. It is believed that the primary concern is the potential for Technical Memorandum No.4 5 F"7744 n'" '"7.'iRS, Gtr`•.41 .7. a5crrrs�; Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 mobilization of metals (either sorbed to soils or precipitated) that could be caused by changes in water chemistry in the area downgradient from the planned barrier wall. If metals become mobile, they could migrate with groundwater. Container Properties will support EPA by monitoring water quality downgradient from the barrier wall. The water chemistry changes that could lead to desorption of metals include the following: • • Decrease in pH that could increase metal solubility Change in the oxidation/reduction state that could increase metal solubility or affinity for sorption to soil • Change in salinity, that could cause desorption of metals sorbed to soils It is proposed that the water quality monitoring program consist of measuring pH, oxidation/reduction potential, dissolved oxygen, specific conductance, and temperature using a flow - through cell. These parameters must be monitored in the field for accurate results. Measurement of pH and the oxidation/reduction potential enables the chemical state of the groundwater to be assessed to evaluate changes in solubility. Monitoring of specific conductance will enable changes in salinity to be tracked; samples could be collected if warranted based on specific conductance measurements for direct measurement of salinity. Groundwater monitoring for COCs is proposed (toluene and copper), since this is adequate given the slow rate of change expected for these constituents in the region downgradient from the barrier wall. Samples will be collected from selected downgrading monitoring wells for dissolved copper, and toluene. The need for continued and/or changed frequency of monitoring will be reviewed annually. Conclusion: Barrier wall performance and groundwater quality changes in the area downgradient from the site can be adequately monitored through a combination of water Technical Memorandum No.4 6 a 'Y'. ; c , s -k ;%4S e . , . a ur: { • ..J Container Properties, L.L.C. Former Rhone Poulenc Site Hydraulic Control Interim Measures April 10, 2002 level measurement, field measurements, and chemical monitoring for COCs. The proposed program includes the following: • Installation of 12 performance monitoring wells outside the barrier wall area and 3 wells within the containment area • Pre- construction baseline monitoring of groundwater conditions • Performance monitoring for water level elevations on a continuous basis for 1 month following completion of the interim action • Monthly monitoring of field parameters (Specific conductance, pH, dissolved oxygen, and temperature). • Quarterly chemical monitoring for key indicator constituents of concern (toluene and copper). Technical Memorandum No.4 7 Co Drawing N to Scala 'ORS 4, Perbtmams MoritoringWell (Proposed) FORM ER RHCN E POULENC SITE INTERIM ACTION Rhme.Pculenc Ma rginal Way Facility Tukwila, Washington FIGURE 1 1.7"1 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. o 0 0 = a p p co 0 (D CD O • 0 7.1 • Fir FT; §". cu n ✓n ., NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. SPILL PREVENTION AND CONTAINMENT PLAN Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site June 2002 URS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101-1616 (206) 438-2700 53-01000496.00 01000 ' CONTENTS 1.0 INTRODUCTION 1 2.0 FACILITY IDENTIFICATION 2 3.0 SITE DESCRIPTION AND PROJECT BACKGROUND 2 4.0 EXISTING SITE DRAINAGE SYSTEM 3 5.0 POTENTIAL SPILL SOURCES AND SPILL PREVENTION AND CONTAINMENT FEATURES 3 5.1 CONSTRUCTION OF BARRIER WALL 4 5.1.1 Potential Spill Source 4 5.1.2 Spill Prevention and Containment Features 4 5.2 GROUNDWATER RECOVERY SYSTEM 4 5.2.1 Potential Spill Source 4 5.2.2 Spill Prevention and Containment Features 4 5.3 FUEL /CHEMICAL STORAGE 5 5.3.1 Potential Spill Source 5 5.3.2 Spill Prevention and Containment Features 5 6.0 SPILL RESPONSE PROCEDURES 6 6.1 NOTIFICATION 6 6.2 SPILL REPORTING AND DOCUMENTATION 7 6.3 SPILL RESPONSE AND CONTROL 10 6.3.1 Fuel/Oil Spills 10 6.3.2 Other Spills 12 6.3.3 Spill Response Equipment 12 7.0 TRAINING 12 TABLES 1 Spill Notification 6 2 Spill Response Notification Form 8 W:W0496\0207.017\Spill Prevention Plan.doc 1 July 2002 personnel. 1.0 INTRODUCTION A Resource Conservation and Recovery Act (RCRA) interim action is being performed at the former Rhone - Poulenc, Inc. facility located in Tukwila, Washington. The purpose of this Spill Prevention and Containment Plan (Plan) is to ensure practices and procedures are in place to minimize the potential for a spill or release into navigable waters of the United States during construction activities associated with the RCRA interim action. This Plan addresses the w following: J U • Potential spill sources associated with the project U W J F— • N O w • � ? c a • Spill response procedures in the event a spill occurs. Z I-- O A copy of this Plan shall be kept at the construction site and shall be familiar to all construction w w 2 UC3 O S i2 The remainder of this document is organized as follows: w U • Section 2 provides facility identification information. u. o — Z • Section 3 provides a site description and project background. v 0 E- • Section 4 describes the existing stormwater drainage system at the site. Z Procedures, methods, equipment, and other requirements to prevent spills from occurring and potentially discharging into navigable waters; Who to contact in the event of a spill; and • Section 5 identifies potential spill sources at the construction site and describes spill prevention and containment measures that will be implemented to prevent spills /releases. • Section 6 describes the procedures that should be implemented in the event of a spill at the site. • Section 7 describes training procedures that will be implemented to ensure on -site workers understand the potential spill sources and spill response procedures. W:\00496\0207.017\Spill Prevention Plan.doc 1 July 2002 2.0 FACILITY IDENTIFICATION Facility Name: Former Rhone - Poulenc Inc. (RPI) Property Type of Facility: RCRA Corrective Action Site Location of Facility: 9229 East Marginal Way South Tukwila, Washington 98108 Township and Range: Owner /Operator of Facility: Person Responsible for Implementation of this Plan — Spill Response Coordinator: W:100496\0207.01 RSpill Prevention Plan.doc Township 24 North, Range 4 East, Section 33 Container Properties, L.L.C. PO Box 1668 Sumner, WA 98390 Kurt Dressen RCI Construction Group Environmental Phone: 253- 863 -5300 Fax: 523- 859 -5702 Cell: 523- 606 -6820 3.0 SITE DESCRIPTION AND PROJECT BACKGROUND The former Rhone- Poulenc facility is located in southwestern King County, City of Tukwila, Washington, in Township 24 North, Range 4 East, Section 33, Willamette Meridian at 9229 East Marginal Way South. The site is flat industrial land bordering the east bank of the Duwamish Waterway and the north bank of Slip 6. The area surrounding the facility is also zoned for heavy industrial use. Kenworth Truck Company is located to the north, the Boeing Developmental Center is located to the south, and East Marginal Way and the King County International Airport lie to the east. The property covers about 21.5 acres, 19.5 of which are onshore and 2.0 of which are offshore intertidal areas in the Duwamish Waterway. There are currently no manufacturing activities ongoing at the site. The facility closed in 1991, at which time process equipment (mostly tanks) and several of the buildings were dismantled or removed. The property is surrounded by fencing and secured gates. A container company (Northwest Container Services) is currently leasing the facility and using it as a shipping center for its ocean -going containers. Drawing No. 2 (included in Attachment 1) shows current site conditions. The interim measures for this site includes demolition/removal actions along the Duwamish Waterway, installation of a low- permeability barrier wall system around the upland site 2 July 2002 ■ perimeter, a groundwater recovery system for hydraulic control, and modifications to the site's groundwater monitoring network. The barrier wall will be installed in two sections along the site. The first section lies along the south (Slip 6) and west (Duwamish Waterway) boundaries of the site and will be constructed using Impermix barrier material. Vibrating -beam technology (no excavation) will be used to ~ W install this section of the wall. The length of the first section will be 1,300 feet. The second r section of the barrier wall will extend along the north and east portions of the site. This section J v will be constructed using slurry trench techniques and soil - bentonite backfill. The length of the v co o second section will be 1,050 feet. Section 5 of the Interim Measure Construction Work Plan u) IA PIMP) describes the planned construction activities. u) LL w 0 The groundwater recovery system is intended to maintain an inward (to the site) hydraulic 2 gradient in the shallow groundwater. The proposed system includes groundwater recovery wells, • Q piping, a water pretreatment system, and discharge to the local sanitary sewer system. cn a Additionally, new groundwater monitoring wells will be constructed at the site prior to barrier = � wall installation (for preconstruction monitoring and long -term performance monitoring) and z after barrier wall installation (for long -term performance monitoring). z O 4.0 EXISTING SITE DRAINAGE SYSTEM p co 1- w c The site is relatively flat and mostly paved or gravel surfaced, with little if any surface 1J 0 vegetation. There is an existing stormwater drainage system at the site, which consists of a iii z co system of catchbasins and underground piping. According to the Interim Measures Report for the Rhodia Inc Tukwila, WA Facility Consent Order No. 1091- 11- 20- 30085(h) (April 8, 1998), p F- all stormwater at the site is currently discharged through a single outfall to the Duwamish . Z Waterway. The outfall (Outfall 7) is located near the northwest corner of the site (see Attachment 2). All other outfalls were abandoned or plugged. During construction activities, a perimeter berm will be placed around the entire construction site to provide complete containment. A partial asphalt berm already exists at the site. The asphalt berm is located along portions of Slip 6 and partially along the Duwamish Waterway. Temporary soil berms will be added to the remainder of the perimeter to provide complete containment. Therefore, a spill at the site will only reach a navigable waterway if the spill enters a storm drain. As previously described, all storm drains located onsite discharge through Outfall 7 into the Duwamish Waterway. 5.0 POTENTIAL SPILL SOURCES AND SPILL PREVENTION AND CONTAINMENT W:'00496\0207.017\Spill Prevention Plan.doc FEATURES This section identifies potential spill sources at the construction site and describes spill prevention and containment measures that will be implemented to prevent spills /releases. 3 July 2002 __1 5.1 CONSTRUCTION OF BARRIER WALL 5.1.1 Potential Spill Source During construction of the barrier wall, there will be a potential for slurry or contaminants to be released to the adjacent water bodies. 5.1.2 Spill Prevention and Containment Features A pre - trench will be excavated to a depth of 20 feet along the entire alignment. The purpose is to positively identify any potential conduits, gravel, rock, or void areas that could present a potential release of slurry or contaminants to the adjacent water bodies. This trench will be a minimum of 6 inches wide to the planned depth and may be filled with potable water or other inert liquid during the trenching, or immediately following completion of a section of the trench, to positively identify that no conditions are present that would represent a significant slurry loss during full -scale barrier construction. Any conduits or materials that could represent a pathway for slurry loss will be removed and/or sealed. Slurry mixing will occur inside a completely contained area. A temporary soil berm will be placed around the entire slurry mixing area. Catch basins within the active work areas will be isolated by capping the inlet grates, constructing small berms around the catchbasins, or placing hay bales or sandbags around the catchbasins. Hay bales and sandbags will only be used for catchbasins not located in the direct path of a potential sediment or slurry release. 5.2 GROUNDWATER RECOVERY SYSTEM 5.2.1 Potential Spill Source Groundwater extracted from the three groundwater recovery wells will be piped to a surge tank (195- gallon capacity). The surge tank will be equipped with a nitrogen blanketing system to prevent contact of the groundwater with oxygen, thus reducing the possibility for iron precipitation. Groundwater in the surge tank will be pumped through a bag filter to remove fines and silts and then through two granular- activated carbon (GAC) units placed in series. All units will be capable of treating the expected flow volume and constituent concentrations. Groundwater discharge from the GAC units will be discharged to an on -site discharge point for the King County sewer system, in accordance with an approved discharge permit. 5.2.2 Spill Prevention and Containment Features The pretreatment system will be located inside an existing building onsite. The system will be surrounded by a berm, a minimum of 6 inches high, for spill containment. The floor within the berm will have a low point sump, which will be equipped with a level sensor to alert personnel of a leak. Sump contents will be removed with a portable sump pump for disposal in accordance with applicable requirements. W:W0496\0207.017\Spill Prevention Plan.doc 4 July 2002 The groundwater pretreatment system will be equipped with a programmable logic controller (PLC), which will monitor and adjust well pump flow rates, pretreatment system flow rates, and pressure differentials through the pretreatment equipment. The PLC will provide alarms and run status and be capable of remotely alerting personnel of alarm conditions. Additionally, if the sump alarm is triggered, the PLC will automatically shut -off the groundwater recovery system, thus preventing additional water from reaching the sump. 5.3 FUEL /CHEMICAL STORAGE 5.3.1 Potential Spill Source No fuel storage tanks will be located onsite. A tanker truck will periodically come on -site to fuel construction equipment. A central fueling area will not be used. Instead, the tanker truck will travel around the site and fuel equipment where they are located. Other potential fuel/chemical spill sources are leaks of hydraulic fluid from the construction equipment and leaks or spills during maintenance and repair of construction equipment. Maintenance activities typically involve oil changes, hydraulic system draindown, greasing, cleaning, etc. When possible, maintenance of equipment will be performed in a contained area, such as the decontamination area. 5.3.2 Spill Prevention and Containment Features The following procedures will be implemented to prevent spills during equipment fueling and maintenance operations: • The vendor tanker truck driver as well as an onsite construction worker will be present during all fuel transfers. • The amount of fuel to be added to equipment should be determined prior to starting fueling operations. • Oil and fuel absorbent material will be readily available during all oil and fuel handling and transfer operations. • Spill buckets will be used during all fuel and oil transfers to catch any drips or leaks during fueling and maintenance operations. • Storm drains (catchbasins) in the immediate vicinity of the equipment tank being filled or equipment maintenance area will be covered with a mat, plug, or other suitable device during fueling and maintenance operations. This process will prevent the flow of product into the drain in case of a leak or spill. If a spill occurs, storm drain covers will not be removed until the spilled material and any associated contaminated soil has been removed. • When transferring petroleum products, connections and transfer points will be carefully monitored for leaks. W:W0496\0207.0171SpiIl Prevention Plan.doc 5 July 2002 Personnel/Agency PHONE NUMBER National Response Center (NRC) 1- 800 -424 -8802 Washington Division of Emergency Management 1- 800 - 258 -5990 or 1- 800 - OILS -911 Washington Department Of Ecology (Northwest Regional Office) Spill Compliance Section 1-425 -649 -7000 Environmental Protection Agency, Region 10 1- 206 -553 -1263 • Equipment fuel tanks will never be topped off completely. Adequate headspace at the top of the tank will be left to allow for product expansion. • Equipment receiving fuel and oil will be carefully checked prior to and during delivery to ensure that there are no leaks or open drain valves. A spill kit will be maintained onsite (see Section 6.3.3) to handle potential fuel or oil leaks /spills from construction equipment. This section describes the procedures that should be implemented in the event of a spill at the site. 6.1 NOTIFICATION Discovery of any spill at the site shall be immediately reported to: Discovery of any spill at the site that reaches an uncovered storm drain inlet (catchbasin) or nearby waterway (Duwamish Waterway or Slip 6) shall be immediately reported to the agencies listed in Table 1. Discovery of any spill at the site that enters the sanitary sewer (Metro sewer) shall be immediately reported to the King County Industrial Waste Program at 206 - 263 -3000. W:100496\0207.017\Spill Prevention Plan.doc 6.0 SPILL RESPONSE PROCEDURES Kurt Dressen RCI Construction Group Phone: 253- 863 -5300 Fax: 523- 859 -5702 Cell: 523- 606 -6820 Table 1 Spill Notification 6 July 2002 a taN.i�, a�AiW't"*Nr"'fAds"��•.+iui4L- • •Vhhi..,: • ,.. 4 4 In the event of a fire or security problem associated with the discharge, the following shall be immediately contacted as appropriate for emergency assistance: FIRE: Tukwila Fire Department, Phone 911 POLICE: Tukwila Police Department, Phone 911 z 1 1-:..,, 6.2 SPILL REPORTING AND DOCUMENTATION 6 m 0 0 In the event of a spill, notifications shall be performed to the personnel identified in Section 6.1. co w The onsite supervisor shall be responsible for completing the Spill Notification Form (Table 2), I located at the end of this section. It is not necessary to complete the Spill Notification Form u) o before calling the agencies listed in Section 6.1. All spills at the site, regardless of volume, w shall be documented. The designated Spill Response Coordinator (identified in Section 2.0) is responsible for any verbal and follow -up reporting with the regulatory agencies deemed necessary based on discussions with site personnel. = d F- m ill z Agencies may request written follow -up notification following a verbally reported spill incident. 1- 0 The Spill Notification Form (Table 2) will be used for any required written notification to local, LL h- . w state, and federal government agencies. U co For hazardous substance releases, Washington Department of Ecology (Ecology) regulations o E- [WAC- 173 - 303- 360(k)] require written notification within 15 days of the spill incident. The = v notification report must include: 1; 0 .z w U = 0 • Name, address, and telephone number of the owner or operator • Name, address, and telephone number of the facility • Date, time, and type of incident (spill to water, spill to land, fire, etc.) • Name and quantity of material(s) involved • The extent of injuries, if any • An assessment of actual or potential hazards to human health or the environment, where applicable • Estimated quantity and disposition of recovered material that resulted from the incident • Cause of incident • Description of corrective action taken to prevent reoccurrence of the incident The report must be submitted to the following address: W:'00496\0207.017\Spill Prevention Plan.doc Washington Department of Ecology - Northwest Regional Office Hazardous Waste and Toxics Reduction Department 3190 160th Avenue SE Bellevue, WA 98008 -5452 7 . ,,.... ; ,.Rw: July 2002 . z * NAME AND PHONE NUMBER OF PERSON COMPLETING FORM Date & lime Form Completed/Updated REPORTER INFORMATION Date and Time Initial Spill Report Received REPORTER'S NAME (LAST, FIRST) REPORTER'S PHONE NUMBER Company Position Reporters Location Street: City: State and Zip Code: INCIDENT DESCRIPTION *MATERIAL RELEASED ❑ Oil /FuelType of Fuel ❑ Hazmat/Unknown Chemical Name & CHRIS Code Is material a CERCLA Hazardous Substance? ❑ Yes ❑ No Is material an Extremely Hazardous Substance? ❑ Yes ❑ No Best Estimate of Quantity Released to Land (include units) Best Estimate of Quantity Released to Water (include units) Is material still being released ❑ Yes ❑ No Current Spill Rate *TYPE OF INCIDENT (CHECK ALL THAT APPLY) Inside building or containment area Navigable Water (freshwater, marine, wetland, storm drain) Release to sanitary sewer Fire Explosion Air Release *SOURCE AND CAUSE OF INCIDENT • *DATE AND TIME OF INCIDENT *INCIDENT ADDRESS /LOCATION Street City, State and Zip Code County Township, Range, Section Nearest City & Distance from City (miles) Container Type & Capacity (include units) Weather Conditions Wind speed and direction; Temperature • Precipitation Rate and Type Wave\Current Information Table 2 Spill Response Notification Form W: \00496\0207.017\Spill Prevention Plan.doc 8 July 2002 t ie Z _ ~ W _J C.) 00 0) o CD tu J H • W W u_? • d = W Z 1. I— O Z I— W • W U� O N D 1— W I 0 r- u .• W U= O H Z RESPONSE ACTIONS Initial Actions Taken Actions Taken to Stop Release Actions Taken to Contain Release Actions Taken to Cleanup Release IMPACT /HEALTH THREATS • NUMBER OF INJURIES • NUMBER OF DEATHS • • EVACUATION(S) REQUIRED ❑ Yes ❑ NO Description of Areas to be Evacuated and Areas Already Evacuated including Number Evacuated Was There Any Property Damage? ❑ YES ❑ NO Damage in Dollars (estimated) Environmental Media Affected • Description of Environmental and Health Threats Additional Information Any information about the incident not recorded elsewhere in the report AGENCY NOTIFICATIONS National Response Center ❑ YES TIME: ❑ NO NRC Call No. WA State Dept. of Emergency Mgmt. ❑ YES 0 NO TIME: WA State Dept of Ecology ❑ YES 0 NO TIME: Environmental Protection Agency, Region 10 ❑ YES ❑ NO TIME: Other (List) ❑ YES ❑ NO TIME: Other (Ust) ❑ YES ❑ NO TIME: Other (List) 0 YES ❑ NO TIME: Other (Ust) ❑ YES ❑ NO TIME: W:10049610207.0171Spill Prevention Plan.doc Table 2 Spill Response Notification Form 9 July 2002 6.3 SPILL RESPONSE AND CONTROL When a spill occurs, the following basic actions shall be implemented if safe to do so: • Control the access area • Identify the hazards ' ~ w • Rescue personnel • Stop or control further releases v o • Contain the spilled material co o • Implement clean-up measures w z F_. • Recover the spilled substance 1 co u. • Establish proper decontamination procedures w o g =. Section 6.3.1 describes the spill response procedures for fuel/oil spills. Section 6.3.2 describes li- the spill response procedures for all other types of spills. = a I- m ill 6.3.1 Fuel/Oil Spills ~O zF- This section discusses the response and control of minor fuel/oil spills (less than 10 gallons) and ■ 2 n major fuel/oil spills (greater than 10 gallons). o 0 o1— w I F- I- Minor spills can occur from disconnection of hoses, hose or fitting leakage or failure, pump - z leaks, and overfilling of tanks. These types of spills are typically less than 10 gallons and are di N limited to the surface area around the equipment fueling or maintenance area. These types of r I � spills can typically be cleaned up by trained personnel or contractors. z Minor Spills (less than 10 gallons) If minor spills do occur, the onsite supervisor shall (1) direct clean-up of the spill using personnel or contractors and adsorbent materials on hand at the facility, (2) report the spill as directed in Section 6.1, and (3) fill out the Spill Notification Form (Table 2). Do not dispose of spill clean-up waste in the facility's trash containers. Any fuel/oil that has been released or any fuel/oil- contaminated media (such as absorbent materials) from a spill or overfill must be properly disposed of in accordance with all applicable local, state, and federal regulations. Major Spills (greater than 10 gallons) In a worst -case scenario, the maximum amount of fuel/oil to be released would be the entire contents of a fuel tanker truck, estimated at approximately 5,000 gallons. The site will be completely contained by a temporary berm, and nearby storm drains will be covered during fueling operations. However, if these measures were to fail, a spill onsite could possibly enter a storm drain and then discharge to the Duwamish Waterway via a single outfall (Outfall 7) located on the northwest corner of the site. W: \00496\0207.017■Spill Prevention Plan.doc 10 July 2002 '.! r: ..,.'7 sax "; �:; �� �' ,.P' � ''�. �` •r, �, � ��'t�: +!' .... �"�'�' .., "� � ..�_'.?. If a major release occurs, the following actions shall be immediately implemented, if safe to do so: 1. Stop the release if safely possible and practical. For example, z • Apply Personal Protective Equipment. = t • Close valves. W • Shut off pumps. 6 0 • Seal holes with nonmetallic plugs or caps. 0 o • Remove oil from the tank to below the level of the hole where the oil is being w = released. —1 F- O 2. Follow the notification procedure in Section 6.1 of this Plan. 2 g J : 3. Identify and mitigate fire, explosion, and vapor hazards: a = w • Eliminate possible sources of ignition. z i_ • Shut off engines, if necessary. z O • Shut off electrical power, if necessary. Do 4. Contain the spill and stop it from spreading: o ww • Soak up as much of the spilled material as possible with absorbent materials. E S2 • Identify the drainage route of the spill and locate a capture site where the spilled — z material may pond or be diverted or contained. Blocking drainage using w absorbent materials is preferred over ditching when practical. i v —.—.. I • Place absorbent materials and booms at the entrance to any nearby drains (if they z are not already covered) or bodies of water. • Put up "CAUTION" tape or other temporary barriers to prevent unauthorized personnel from entering the spill area, if necessary. 5. Assist spill response personnel, if requested to do so: • Continue to monitor and mitigate fire and safety hazards. • Clean affected surfaces of residual spillage. • Dispose of all dispensable contaminated materials properly. Do not place these materials in standard waste containers. Any fuel/oil that has been released or any fuel/oil- contaminated media (such as absorbent materials) from a spill or overfill must be properly disposed of in accordance with all applicable local, state, and federal regulations. 6. Document the spill: • Fill out the Spill Notification Form (Table 2). W:'00496\0207.017\Spill Prevention Plan.doc 11 July 2002 6.3.2 Other Spills Whereas most oil products tend to behave in a consistent manner and require similar spill response procedures, spill response procedures for hazardous substances vary according to the nature of the substance. For this reason, spill response personnel should use extreme caution until the hazardous substance is identified. It may be necessary to delay response actions until safe levels of exposure are determined. Spill response procedures should be based on the hazardous substances' chemical behavior and potential health effects. Copies of Material Safety Data Sheets (MSDS) for all hazardous materials brought onsite will be attached to this plan (Attachment 3) so that they are readily available in the event of a spill. 6.3.3 Spill Response Equipment A spill kit containing the following items shall be maintained at the facility: • • • • • • • • 20- gallon plastic container /recovery drum Sorbent booms and socks Sorbent pads Storm drain covers (mats) Disposal bags /ties Barrier tape Sorbent material Plastic shovel Broom Rubber boots, gloves, safety glasses, etc. 7.0 TRAINING All personnel onsite shall be familiar with the spill prevention and response procedures described in this Plan. Prior to starting any work onsite, personnel shall be briefed on the contents of this Plan and shall be made aware of where the Plan is maintained onsite. W: \00496\0207.017\Spill Prevention Plan.doc 12 July 2002 �b. Sfi5 .ti3t:+a4i?y:1t5 • NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. STORMWATER POLLUTION PREVENTION PLAN Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site June 2002 URS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 (206) 438 -2700 53- 01000496.00 01000 Z ;i— 6 DI � W 00 • U) J F-. N LL W 0. u. cn • 2. Z H_ F- 0 Z .0 ' ❑ W UJ; 2 F . U. Z:• • W • 0 0 ~' 2.0 SITE DESCRIPTION PROJECT BACKGROUND 1 2.1 SITE DESCRIPTION AND PROJECT BACKGROUND 1 3.0 EXISTING SITE DRAINAGE SYSTEM 2 4.0 STORMWATER MANAGEMENT APPROACH 2 4.1 MARK CLEARING LIMITS 3 4.1.1 Maintenance Requirements 3 4.2 ESTABLISH CONSTRUCTION ACCESS 3 4.2.1 Maintenance Requirements 3 4.3 CONTROL FLOW RATES 4 4.4 INSTALL SEDIMENT CONTROLS 4 4.4.1 Maintenance Requirements 5 4.5 STABILIZE SOILS 5 4.5.1 Maintenance Requirements 6 4.6 PROTECT SLOPES 6 4.7 PROTECT DRAIN INLETS 6 4.7.1 Maintenance Requirements 7 4.8 STABILIZE CHANNELS AND OUTLETS 7 4.9 CONTROL POLLUTANTS 7 4.10 CONTROL DE- WATERING 8 4.11 MAINTAIN BEST MANAGEMENT PRACTICES 8 4.12 MANAGE THE PROJECT 9 _J 1.0 INTRODUCTION 1 W:\00496\0207.017\SWPPP.DOC CONTENTS i July 2002 z i ~ w : J0: 00 co IJJ: W =. CD u_ w o =w • • F- M. z � I-0' Z �— D O o rn o w W' � Z 0— 0 z 1.0 INTRODUCTION A Resource Conservation and Recovery Act (RCRA) interim action is being performed at the former Rhone - Poulenc, Inc. (RPI) facility located in Tukwila, Washington. The purpose of this Construction Stormwater Pollution Prevention Plan (SWPPP) is to identify the procedures that will be implemented at the site to prevent adverse stormwater impacts from the construction activities associated with the RCRA interim action. The Stormwater Management Manual for Western Washington, Volume II (Ecology August 2001) was used to prepare this SWPPP. Section 2.0 provides a site description and project background. Section 3.0 describes the existing stormwater drainage system at the site. Section 4.0 describes the best management practices (BMPs) that will be implemented for stormwater protection and erosion and sediment control. 2.0 SITE DESCRIPTION PROJECT BACKGROUND 2.1 SITE DESCRIPTION AND PROJECT BACKGROUND The former RPI facility is located in southwestern King County, City of Tukwila, Washington, in Township 24 North, Range 4 East, Section 33, Willamette Meridian at 9229 East Marginal Way South. The site is flat industrial land bordering the east bank of the Duwamish Waterway and the north bank of Slip 6. The area surrounding the facility is also zoned for heavy industrial use. Kenworth Truck Company is located to the north, the Boeing Developmental Center is located to the south, and East Marginal Way and the King County International Airport lie to the east. The property covers about 21.5 acres, 19.5 of which are onshore and 2 of which are offshore intertidal areas in the Duwamish Waterway. Drawing No. 2 (included in Attachment 1) shows current site conditions. There are currently no manufacturing activities ongoing at the site. The facility closed in 1991, at which time process equipment (mostly tanks) and several of the buildings were dismantled or removed. The property is surrounded by fencing and secured gates. A container company (Northwest Container Services) is currently leasing the facility and using it as a shipping center for its ocean-going containers. The interim measures for this site includes demolition/removal actions upland of the Duwamish Waterway, installation of a low - permeability barrier wall system around the upland site perimeter, a groundwater recovery system for hydraulic control, and a modification of the site's groundwater monitoring network. The barrier wall will be installed in two sections along the site. The first section lies along the south (Slip 6) and west ( Duwamish Waterway) boundaries of the site and will be constructed using Impermix barrier material. Vibrating -beam technology (no excavation) will be used to install this section of the wall. The length of the first section will be 1,300 feet. The second section of the barrier wall will extend along the north and east portions of the site. This section W:\00496\0207.017\SWPPP.DOC 1 July 2002 the stormwater drainage system. Catchbasins within the active work areas will be isolated by capping the inlet grates, constructing small berms around the catchbasins, or placing hay bales or sandbags around the catchbasins. Hay bales and sandbags will only be used for catchbasins not located in the direct path of a potential sediment or slurry release. The design and installation specifications for storm drain inlet protection measures will meet the w requirements specified in BMP C220 (Storm Drain Inlet Protection) of the Stormwater Management Manual for Western Washington, Volume II (August 2001) (see Attachment 3). o cn o o CO III 4.7.1 Maintenance Requirements W 1 Wa_ Following are the maintenance requirements for storm drain inlet protection: w o g • Catchbasin filters will be inspected frequently, especially after storm events. If Q the insert becomes clogged, it will be cleaned or replaced. = a = Z • For systems using stone filters, if the stone filter becomes clogged with sediment, 1... p the stones will be pulled away from the inlet and cleaned or replaced. If cleaning w w the stones is not feasible, the stones will be replaced with new stones. Sediment o must not be washed into storm drains while cleaning. 0 !P- o w 4.8 STABILIZE CHANNELS AND OUTLETS 1 .z Temporary onsite conveyance channels are not required for this project. Therefore, BMPs for v co stabilizing channels and outlets are not required. F 4.9 CONTROL POLLUTANTS Section 5 of the IMCWP describes pollution - control procedures for the following activities: • Staging and storage areas • Decontamination stations • Waste handling, transportation and disposal • Waste sources • Waste accumulation/storage areas Slurry mixing will occur inside a completely contained area. A temporary soil berm will be placed around the entire slurry mixing area. Catchbasins within the active work areas will be isolated by capping the inlet grates or by constructing small berms around the catchbasins. The following procedures will be implemented to prevent spills during equipment fueling and maintenance operations: • The vendor tanker truck driver as well as an onsite construction worker will be present during all fuel transfers. W: \00496\0207.01 WPPP.DOC 7 July 2002 z • 4.1 MARK CLEARING LIMITS The site is largely clear of significant vegetation. Site clearing and grubbing will be limited to miscellaneous surface vegetation removal along the proposed barrier wall alignment and the alignment of the buried piping for the groundwater recovery system. Barrier tape, temporary construction fencing, and/or portable barriers will be used to define the active work zones and control access routes in the immediate area. As the trenching activities progress, barriers will be adjusted to accommodate equipment operations and slurry installations. The design and installation specifications for the fence/barrier will meet the requirements specified in BMPs C103 (High Visibility Plastic or Metal Fence) and C104 (Stake and Wire Fence) of the Stormwater Management Manual for Western Washington, Volume If (August 2001) (see Attachment 3). 4.1.1 Maintenance Requirements If the fence/barrier has been damaged or visibility reduced, it will be repaired or replaced immediately and visibility restored. 4.2 ESTABLISH CONSTRUCTION ACCESS A single construction access /exit point will be established for the site. This access /exit point will be stabilized with quarry spall or crushed rock to minimize the tracking of sediment onto public roads. A wheel wash will also be constructed at the access /exit point to reduce the amount of sediment transported onto paved roads by construction vehicles /equipment. The design and installation specifications for the stabilized construction entrance and the wheel wash will meet the requirements specified in BMPs C105 (Stabilized Construction Entrance) and C106 (Wheel Wash) of the Stormwater Management Manual for Western Washington, Volume II (August 2001) (see Attachment 3), respectively. 4.2.1 Maintenance Requirements Following are the maintenance requirements for the stabilized construction entrance: • Quarry spalls will be added if the pad is no longer in accordance with the specifications. • Any sediment that is tracked onto pavement will be removed by shoveling or street sweeping. The sediment collected by sweeping will be removed or stabilized onsite. • Any quarry spalls that are loosened from the pad and end up on the roadway will be removed immediately. W: \00496 \0207.017\S W P P P. DO C 3 July 2002 Following are the maintenance requirements for the wheel wash: • The wash water should be changed a minimum of once per week. • Wheel wash or tire bath wastewater will be discharged to the sanitary sewer upon approval from the local sewer district, or reused for dust control along or within the barrier wall alignment. 4.3 CONTROL FLOW RATES Increases in the volume, velocity, and peak flow rate of stormwater runoff are not expected to occur as a result of the construction activities. As mentioned in Section 4.1, the site is largely clear of significant vegetation, and the amount of impervious surface will not be increased. Therefore, BMPs for controlling flow rates are not required. 4.4 INSTALL SEDIMENT CONTROLS A perimeter berm will be placed around the entire construction site to provide complete containment. A partial asphalt berm already exists at the site. The asphalt berm is located along portions of Slip 6 and partially along the Duwamish Waterway. Temporary soil berms will be added to the remainder of the perimeter to provide complete containment. Minor erosion is anticipated from sheet flow that contacts the exterior of the perimeter berm due to run -on from outlying areas. However, to prevent soil eroded from the temporary soil berm from leaving the site, a silt fence will be placed around the perimeter berm along the portions of the Duwamish Waterway and Slip 6 that have a soil berm and along the north and east sides of the perimeter. If installation of a silt fence is not feasible, a plastic cover will be placed over the temporary soil berm for erosion control. Prior to installation of the barrier wall, stormwater control berms (about 1.5 feet high with a two - foot wide crest) will be installed around the perimeter of the slurry wall alignment to control run - on and runoff and prevent escape of slurry by surface flow to the environment. Temporary berms will be constructed along each side of the barrier wall alignment, up to 20 feet from the centerline of the barrier wall during active trenching and slurry installation. As the wall installation progresses, new interior berm sections will be constructed and unnecessary berms will be removed or graded for subsequent construction of the protective cap. During installation of the underground piping system for the groundwater recovery system, berms or hay bales will be used to divert stormwater runoff away from shallow pipe trenches. The design and installation specifications for sediment control measures will meet the requirements specified in BMP C230 (Straw Bale Barrier) and BMP C233 (Silt Fence) of the Stormwater Management Manual for Western Washington, Volume II (August 2001) (see Attachment 3). Drawing No. 2 (see Attachment 1) shows the planned erosion and sediment control measures. W:\00496\0207.017NSWPPP.DOC 4 July 2002 ant e IL 1- O Following are the maintenance requirements for silt fences: w w U 0 • Any damage will be repaired immediately. 0 _ n 01- • If concentrated flows are evident uphill of the fence, they must be intercepted and Li, 0 L - 1 1 ~ o w z 1 ' - `1 • The uphill side of the fence will be checked for signs of the fence clogging and .-..a acting as a barrier to flow, thus causing channelization of flows parallel to the z 1- fence. If this occurs, replace the fence or remove the trapped sediment. J 4.4.1 Maintenance Requirements Following are the maintenance requirements for straw bale barriers: z • Straw bale barriers will be inspected immediately after each storm event and at z 1= least daily during prolonged rainfall. 're 2w • Close attention will be paid to the repair of damaged bales, end runs, and v o undercutting beneath bales. w = F- • Necessary repairs to barriers or replacement of bales will be accomplished U) �- properly. W O u_ • Sediment deposits will be removed after each storm event. They must be u) D removed when the level of deposition reaches approximately one -half the height = w of the barrier. Z = • Sediment deposits will either be removed when the deposit reaches approximately one -third height of the silt fence, or a second silt fence will be installed. • If the filter fabric (geotextile) has deteriorated due to ultraviolet breakdown, it will be replaced. 4.5 STABILIZE SOILS conveyed to a sediment trap. Excavation spoils will initially be maintained within the bermed work areas. Periodically, unsuitable soil and debris will be segregated, removed from the active work area, and placed in a central interim storage area. The central storage area will be lined with polyethylene sheeting and be completely contained by temporary soil berms. The berms will be approximately 1.5 feet high and have sufficient space available for material and potential stormwater accumulation. Additionally, the soil will be covered with plastic sheeting at the end of each work day. Plastic sheeting will be placed over imported fill stockpiles at the end of each work day. W:\00496\0207.017\SWPPP.DOC 5 July 2002 From October 1 through April 30, and as deemed necessary by the site engineer, protective cover measures will be applied to disturbed areas that remain unworked for 2 days or more. From May 1 through September 30, and as deemed necessary by the site engineer, protective cover measures will be applied to disturbed areas that remain unworked for 7 days or more. The design and installation specifications for the plastic covering will meet the requirements specified in BM? C123 (Plastic Covering) of the Stormwater Management Manual for Western if- w Washington, Volume II (August 2001) (see Attachment 3). 6 0 Site restoration will include the following: U 0 W I • Repair and replacement of concrete and asphalt surfaces disturbed by construction I cn iLI activities w 0 • Filling, regrading, or repair of heavily rutted or scarred surface soil to pre- u construction conditions or better I a 1— w Z • Inspection of catchbasins, manholes, and permanent storm water controls at the 0 site, and the removal and disposal of any accumulated solids w O w • Final grading and stabilization of surface areas disturbed by construction, v N including mulching, hydroseeding, or other protective measures to prevent 0 E— erosion and sedimentation = W E- S2 1L 0 • Removal and relocation of temporary protective actions for existing work and , return of surface equipment, materials, or other features their original location N H = 0~ 4.5.1 Maintenance Requirements Following are the maintenance requirements for plastic covering: • Tom sheets will be replaced and open seams repaired. • If the plastic begins to deteriorate due to ultraviolet radiation, it will be completely removed and replaced. 4.6 PROTECT SLOPES Cut and fill slopes are not required for this project. Therefore, BMPs for slope protection are not required. 4.7 PROTECT DRAIN INLETS Catchbasin inserts will be placed in all catchbasins located within the main perimeter of the construction site to prevent sediment and construction- related petroleum products from entering W:\00496 6 July 2002 z the stormwater drainage system. Catchbasins within the active work areas will be isolated by capping the inlet grates, constructing small berms around the catchbasins, or placing hay bales or sandbags around the catchbasins. Hay bales and sandbags will only be used for catchbasins not located in the direct path of a potential sediment or slurry release. The design and installation specifications for storm drain inlet protection measures will meet the requirements specified in BMP C220 (Storm Drain Inlet Protection) of the Stormwater Management Manual for Western Washington, Volume II (August 2001) (see Attachment 3). 4.7.1 Maintenance Requirements Following are the maintenance requirements for storm drain inlet protection: • Catchbasin filters will be inspected frequently, especially after storm events. If the insert becomes clogged, it will be cleaned or replaced. • For systems using stone filters, if the stone filter becomes clogged with sediment, the stones will be pulled away from the inlet and cleaned or replaced. If cleaning the stones is not feasible, the stones will be replaced with new stones. Sediment must not be washed into storm drains while cleaning. 4.8 STABILIZE CHANNELS AND OUTLETS Temporary onsite conveyance channels are not required for this project. Therefore, BMPs for stabilizing channels and outlets are not required. 4.9 CONTROL POLLUTANTS Section 5 of the IMCWP describes pollution - control procedures for the following activities: • Staging and storage areas • Decontamination stations • Waste handling, transportation and disposal • Waste sources • Waste accumulation/storage areas Slurry mixing will occur inside a completely contained area. A temporary soil berm will be placed around the entire slurry mixing area. Catchbasins within the active work areas will be isolated by capping the inlet grates or by constructing small berms around the catchbasins. The following procedures will be implemented to prevent spills during equipment fueling and maintenance operations: • The vendor tanker truck driver as well as an onsite construction worker will be present during all fuel transfers. W:\00496\0207.017\SWPPP.DOC 7 July 2002 equipment. • The amount of fuel to be added to equipment should be determined prior to starting fueling operations. • Oil and fuel absorbent material will be readily available during all oil and fuel handling and transfer operations. z • Spill buckets will be used during all fuel and oil transfers to catch any drips or dr— cc 2 6 J U U • Storm drains (catchbasins) in the immediate vicinity of the equipment tank being ° filled or equipment maintenance area will be covered with a mat, plug, or other W suitable device during fueling and maintenance operations. This process will 1 w o prevent the flow of product into the drain in case of a leak or spill. If a spill w occurs, storm drain covers will not be removed until the spilled material and any LL g associated contaminated soil has been removed. • When transferring petroleum products, connections and transfer points will be carefully monitored for leaks. z � 1- 0 Z 1- wW • Equipment fuel tanks will never be topped off completely. Adequate headspace . - o at the top of the tank will be left to allow for product expansion. o cn O 1— • Equipment receiving fuel and oil will be carefully checked prior to and during = v delivery to ensure that there are no leaks or open drain valves. u. o A spill kit will be maintained onsite to handle potential fuel or oil leaks /spills from construction v o ~' 4.10 CONTROL DE- WATERING Stormwater that accumulates within the bermed area of the barrier wall installation will be incorporated into the slurry mix when possible. Stormwater that cannot be incorporated into the slurry mix, as well as any other stormwater that accumulates within contained areas of the site, will be discharged appropriately (i.e., to the King County sewer system [only after testing] or offsite disposal facility). Stormwater from the containment areas will not be discharged to the stormwater drainage system. 4.11 MAINTAIN BEST MANAGEMENT PRACTICES Erosion and sediment control BMPs will maintained and repaired as needed to ensure continued performance of their intended function. Maintenance and repair will be conducted in accordance with the maintenance requirements specified in Sections 4.1, 4.2, 4.4, 4.5, and 4.7. Erosion and sediment control BMPs will be inspected weekly or after a storm event (which may be daily during the wet season from October 1 through April 30). W:\00496\0207.017\SWPPP.DOC leaks during fueling and maintenance operations. 8 July 2002 z Trapped sediment from the erosion and sediment control measures will be removed and transported to the central storage location for excavated spoils for interim storage. 4.12 MANAGE THE PROJECT The erosion and sediment control measures described in this SWPPP will be constructed and in operation prior to the start of any construction activity. These measures will be maintained for the duration of the project and until permanent stabilization is established. All temporary erosion and sediment control measures described in this SWPPP will be removed upon project completion. A Certified Professional in Erosion and Sediment Control will be responsible for inspecting the BMPs described in this SWPPP. This SWPPP will be maintained onsite or within reasonable access to the site. The SWPPP will be modified whenever there is a significant change in the design, construction, operation, or maintenance of any BMP. W:\00496\0207.017\SWPPP.DOC 9 July 2002 !�., :.... -v. "-- .• �ri1 .YiY'r,.kiY+ini.L..aluwo44;M�Yi NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Prepared For : November 15, 2000 Container Properties L.L.C. 1216 140 Avenue Court East Sumner, Washington 98390 PUBLIC PARTICIPATION PLAN HYDRAULIC CONTROL INTERIM MEASURES FORMER RHONE - POULENC, INC. FACILITY 9229 EAST MARGINAL WAY SOUTH TUKWILA, WASHINGTON RCI Environmental P.O. Box 1668 Sumner, Washington 98390 253/863 -5300 Project No. 20051 -29942 RT1 AGI Technologies 11811 N.E. 1s` Street, Suite 201 Bellevue, Washington 98005 425/453 -8383 sue.. � .wwwn,.-- :.,:.,..n :�: r.� .,,._......�.: , ll. ,»..:. . .»K:;L�,.- ».....%.4:1.�_.,.M,.r S.:w �' 1J:.:: . ....✓:,.��.i...u...:.:a��*... z cc Lk J U , 00 w 0. W = J � N LL. W 0 • N R = d ; w , 2 Z H0 Z 2 lir U� : N 0 . :o u- O .. z. w U =i 0 z 1 1.0 INTRODUCTION 1 2.0 PROJECT HISTORY 2 2.1 FACILITY DESCRIPTION 2 2.2 FACILITY HISTORY 2 2.3 SITE OWNER INFORMATION 2 2.4 REGULATORY ACTIONS 3 3.0 COMMUNITY CONCERNS 4 4.0 OBJECTIVES OF THE PLAN 5 5.0 PUBLIC PARTICIPATION ACTT VI HES 6 6.0 PROJECT CONTACTS 7 FIGURES TABLE OF CONTENTS z z J U O 0: U) 0. U)1,1.1. w = J H' w 0 . • Q: _ z 1- 0 z O .C 0 I- w' '2 H H ` IL 0 , w U) O 2 r7, 5 E 0 - z41 c < p =oo o 0) 0 ook 8 (A " CD Q. CC C4 =IL rn NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1.0 INTRODUCTION The purpose of a public participation plan is to provide the stakeholders the opportunity for improved cooperation and communication in the RCRA permitting process. This plan concerns the recent action taken by the EPA at the former Rhone- Poulenc (RP1) facility on East Marginal Way in Tukwila. The EPA action is addressed in a letter dated March 13, 2000 to the Respondent regarding the need for an Interim Measures Workplan to abate potential release of metal and organic contaminates to the Duwamish Waterway. This plan consists of the following sections: • Project History • Community Concerns • Objectives of the Plan • Public Participation Activities • Project Contacts 2.1 FACILITY DESCRIPTION 2.0 PROJECT HISTORY The RPI Marginal Way Facility is physically located in southwestern King County, City of Tukwila, Washington in Township 24 North, Range 4 East, Section 33 Willamette Meridian at 9229 East Marginal Way South (Figure Al). The area surrounding the facility is zoned for heavy industry. The Kenworth Truck Company is to the north of the facility, the Boeing Company Development Center and the Duwamish Waterway Slip No. 6 are to the south, the Duwamish Waterway is to the west, and East Marginal Way and the King County International Airport are to the east. The facility covers about 21.5 acres; 19.5 acres are onshore and 2.0 acres are intertidal offshore of the Duwamish Waterway. Currently, there are no manufacturing activities at the facility. The facility closed in 1991, at which time the process equipment, tanks, and several of the buildings were dismantled and removed. The facility is surrounded by fencing and secured gates, and routine maintenance is performed. A container company (Northwest Container Services) is currently leasing the facility for a shipping center for its ocean going containers. 2.2 FACILITY HISTORY I.F. Laucks, a chemical company, owned the facility until 1946, when the Monsanto Company purchased it. Monsanto began the manufacture of dry glues and resins at the site in 1948. The manufacture of these products and hardeners and extenders ceased in 1969 -70. Vanillin, an artificial vanilla used in food and pharmaceutical products, was produced from 1952 to 1991. The production of vanillin generated hazardous and non - hazardous byproducts. RPI assumed the responsibility for handling the waste and reporting to EPA in 1986 when RPI purchased the company from Monsanto. The hazardous byproducts were initially reported to EPA and subsequently the Washington State Department of Ecology. A RCRA Part A Permit Application was completed and permission was granted by EPA to store waste under RCRA Interim Status Regulations. Since 1986 several site investigations have been conducted at the facility to evaluate the potential for . contaminant release. These investigations have included a site assessment conducted for Monsanto by Dames & Moore in 1986, a RCRA Facility Assessment (RFA) conducted for the EPA by PRC Environmental Management Inc. in 1989 -90, and a RCRA Facility Investigation (RFI) conducted by CH2M Hill in 1995. In 1998, the property was purchased by Container Properties, L.L.C. Subsequent to the purchase, Container Properties, L.L.C. completed a tidal study and commenced a quarterly groundwater monitoring program. These investigations and groundwater monitoring have identified concerns with soil and groundwater at the site, with the primary constituents of concern being toluene and copper. 2.3 SITE OWNER INFORMATION The current site owner is Container Properties L.L.C. -G2- ',�4x:N.rM4�ww�:iw+is�lfa 'px?: ••••;‘, •••• • ,•.+i• i5 > „ < ,a'x. i t t • 1 L 2.4 REGULATORY ACTIONS Site regulatory actions have included fulfilling the requirements of the Administrative Order of Consent between RPI and EPA Region 10 dated March 31, 1993 as amended in February 1999 to add Container Properties, L.L.C. as a respondent, and the action addressed in the EPA's letter dated March 13, 2000. -G3- z Z , � W. 00 N O. U) W UJ= J H W 0 L L . < N d f w ; Z H: F- 0 Z I- LL! tu M 0 - .0'- W m LIJ I- - 0 w U (1) H H ; z 3.0 COMMUNITY CONCERNS Based on experience with the site to date and a review of the EPA guidance on establishing the level of community concern for public participation for a RCRA facility, it is anticipated that the level of interest, and therefore public concern for this facility, will be low to moderate. The level of concern, however, will be re- z evaluated as the public participation activities progress. w The EPA guidance consulted includes a discussion of the type of RCRA action, community members' 0 relationships with the facility and the regulatory agency, and the larger community context. Community co ❑ interviews were not conducted, nor are they anticipated to be conducted, for this plan. The community w =' concerns at the site are anticipated to be the potential release of heavy metals and organic compounds, -' F. u_ including copper and toluene, to the Duwamish Waterway. W O: The community environment adjacent to the site is characterized by heavy industrial use. This includes the -- g 5 . Kenworth Truck Company, the Boeing Aircraft Company, the King County International Airport, and various other medium to heavy industrial businesses. H W z � Z0 [ g w O 2 W ' O F .. Z W O • Z -G4- �:,'''> ' �•�:�'';u K �.- K' ''2: � t l '��i:1:.aiL' " "`,. ,,,,, F .:y,`w;:' �r� �- =`""iu Y ....�; -. � 1:, i.: Objectives of this plan include: 4.0 OBJECTIVES OF THE PLAN Provide information on issues of interest to ensure understanding by the community of actions being taken. • Maintain positive contact with the community and EPA. • Provide the community opportunities for involvement. • Provide accurate and timely information on site activities. -G5- tr.i.411.4 .:•c:.>ar.: z • � • D. J '0 O; o • WI J i- W O: L E a ek I--i O: .z ww O ff ' . O I—' W lll 2 H U • — O, W z: ( b O • z Public participation activities will include: 5.0 PUBLIC PARTICIPATION ACTIVITIES • Designate EPA and Container Properties, L.L.C. contacts to respond to questions from the community. • Identify an information repository for the community. • Coordinate with the EPA and provide informational bulletins or fact sheets on issues regarding applicable activities at the site. • Notify the community regarding the progress made at the facility. • Prepare a mailing list of interested stakeholders. Stakeholders may indude immediate neighbors, appropriate local special interest groups, appropriate members of local government, and news media. -G6- •rL,:,fim.x:i:.4° +•k�:.}o� ... ..... - :<1� . .- �c,.r.w.w , �uw..,.._+.. rs-.: �e:+ t...: iun. uc+;. o. k� ..us.�sYn:¢aiu:,rcr.Lwi�nrraa�.r .a+'t!aK�!:�F' a. rt!c.. »��a}iYtiif,�i:r, 11:7 W{ {Jlpb 1 rat . �uM 9e,! z rt W. J U 00, U) U) W J H u_ WO 2 g LL. - d W ' z � I- O Z r. 111 uj U O - C1 F-- =V O . .• z W O N, z . • `", The following is a list of project contacts: Christy Brown EPA — Region 10 1200 Sixth Avenue Seattle, Washington 98101 Telephone 206 - 553 -8506 Peter Wold RCI Environmental, Inc. P.O. Box 1668 Sumner, Washington 98390 Telephone 253- 863 -5300 6.0 PROJECT CONTACTS -G7- NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • 3 HEALTH AND SAFETY PLAN Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site June 2002 URS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 (206) 438 -2700 53- 01000496.00 01000 Health and Safety Plan Page iii TABLE OF CONTENTS DOCUMENT IDENTIFICATION AND APPROVALS v ABBREVIATIONS AND ACRONYMS vii 1.0 INTRODUCTION 1 1.1 PURPOSE 1 1.2 SCOPE OF WORK 2 2.0 RESPONSIBILITIES 5 2.1 REGIONAL HEALTH & SAFETY MANAGER- 5 2.2 PROJECT MANAGER: 5 2.3 SITE COORDINATOR! SITE HEALTH AND SAFETY OFFICER: 6 3.0 PERSONNEL MEDICAL QUALIFICATIONS AND TRAINING REQUIREMENTS 7 4.0 POTENTIAL SITE HAZARDS ANALYSIS 8 4.1 CONTAMINANTS OF POTENTIAL OCCUPATIONAL HEALTH CONCERN 8 4.2 CHEMICAL HAZARDS 8 4.2.1 Hazard Communication Materials 9 4.2.2 Site Constituents 9 4.3 BIOLOGICAL HAZARDS 10 4.4 PHYSICAL HAZARDS 11 4.4.1 Slips, Trips, and Falls 11 4.4.2 Skeletal - Musculature Injury 11 4.4.3 Noise 12 4.4.4 Hand Tools 12 4.4.5 Heavy Equipment 12 4.4.6 Underground and Aboveground Utilities 13 4.4.7 Trenching and Excavation 13 4.4.8 Heat Stress 14 4.4.9 Cold Weather Stress (Hypothermia and Frostbite) 14 4.4.10 Electrical Safety 14 4.4.11 Machine Guarding 15 4.4.12 Project Hazard Analysis 16 5.0 HAZARD CONTROL MEASURES 16 5.1 PERSONAL PROTECTIVE EQUIPMENT 16 5.1.1 General Personal Protective Equipment 16 5.2 ADMINISTRATIVE CONTROLS 17 5.2.1 Site Preparation 18 W: \00496\0207.017Wealth and Safety Plan.doc Health and Safety Plan Page iv z z iu 2 JU 0 0 CO 0 W = J ( i) 1L in 0 �¢ a. z I-0 z I- w 0 0 ' 0 N 0 I-- 3 -1 Training requirements for personnel involved in site activities 8 = 0 uj 6.0 EMERGENCY RESPONSE 6.1 POTENTIAL INCIDENTS 6.2 OPERATIONS SHUTDOWN 6.3 EMERGENCY RESPONSE PROCEDURES TABLES FIGURES 5.3 SITE SECURITY 5.4 SITE COMMUNICATIONS 5.4.1 Tailgate Safety Meetings 5.5 DECONTAMINATION PROCEDURES 5.5.1 5.5.2 5.5.3 5.5.4 5.6 MONITORING EQUIPMENT ATTACHMENT Safety Plan Compliance Agreement W: \00496 \0207.017\Health and Safety Plan.doc TABLE OF CONTENTS (CONTINUED) 18 19 19 19 19 20 21 21 21 General Decontamination Procedures Sanitation Decontamination - Medical Emergencies Decontamination of Tools 22 22 22 23 ..z W co 1 -1 Required Equipment and Personal Protective Equipment Checklist 3 z 1 -2 "Site Location Map" 4 6 -1 "Route to Medical Center" 24 Document Title: Site - Specific Health and Safety Plan Former Rhone- Poulenc Site Duwamish Waterways Document Coverage: This report presents the Health and Safety Plan for Construction Services performed by RCIE at the Former Rhone- Poulenc Site. This plan is provided for the use of RCIE employees. Project Manager: Health and Safety Plan Page v Site Health and Safety Officer: Approval: Name: Title: Corporation: W: \00496\0207.017\Health and Safety Plan.doc DOCUMENT IDENTIFICATION AND APPROVALS Signature: Date: • Health and Safety Plan Page vii ACGIH American Conference of Governmental Industrial Hygienists bgs below ground surface CB citizens band CFR Code of Federal Regulations CGI combustible gas indicator CPR cardiopulmonary resuscitation EKG electrocardiogram FID flame ionization detector GW groundwater H &S health and safety HSP Health and Safety Plan HEPA high - efficiency particulate air HSM Regional Health and Safety Manager IDW investigation- derived waste LEL lower explosive limit MSDSs Material Safety Data Sheets mg/m milligrams per cubic meter MTCA Model Toxics Control Act NIOSH National Institute for Occupational Safety and Health OSHA Occupational Safety and Health Administration OV organic vapor PEL permissible exposure limit PID photoionization detector PM project manager ppb parts per billion PPE personal protective equipment ppm parts per million SC site coordinator SHSO site health and safety officer SSI Supplemental Site Inspection STEL short-term exposure limit TLV threshold limit value TWA time - weighted average URS URS Corporation VOCs volatile organic compounds W: \00496\0207.017\Health and Safety Plan.doc ABBREVIATIONS AND ACRONYMS ....h �;`.t ^.._. ` ` +�.v::w:: .ve+7t 4+ Health and Safety Plan Page I The health and safety (H &S) requirements for RCIE employees performing activities described below at the former Rhone- Poulenc Site are provided in this Health and Safety Plan (HSP). The HSP establishes the guidelines and requirements for the safety of RCIE personnel, personnel contracted by RCIE, and site visitors throughout the duration of site activities. A copy of the HSP will be maintained at the site during all field operations. Contaminants of concern at the site include toluene, heavy metals and by- products of the Vanillin process including some mineral oils. 1.1 PURPOSE 1.0 INTRODUCTION This Health and Safety Plan (HSP) is designed to provide general support to all activities likely to be encountered in the execution of site investigation, design, or construction activities performed at the site. This HSP will address the specific tasks, hazards and controls associated with activities at the former Rhone- Poulenc Site. The HSP is subject to routine updates to ensure the adequacy of its coverage relative to changing contract and project specific needs. This plan will be reviewed at least annually or more often as deemed necessary by the Site Safety Officer. The purpose of this HSP is to summarize the health and safety hazard information for the tasks related to construction activities. Site background information, key personnel and their responsibilities, personnel medical qualifications and training requirements, site hazards analysis, hazard control measures, and emergency response procedures are provided in this document. Detailed information regarding the construction- related tasks is provided in the Work Plan and Field Sampling Plan for this project. It is essential that personnel associated with the field effort are aware of the nature and extent of the potential hazards associated with each task, as well as the need for safety planning and implementation of appropriate safety procedures, safety equipment, and control measures identified in this HSP to minimize the risk of exposure to these hazards. The HSP was prepared in accordance with the H &S standards, provisions, and requirements specified in the following regulations and guidance documents: • OSHA Occupational Safety and Health Standards. 29 CFR Parts 1910 and 1926. • WISHA Occupational Safety and Health Standards. WAC 296 -62, 296 -24 and 296 -155. • National Institute for Occupational Safety and Health (NIOSH). Pocket Guide to Chemical Hazards. Department of Health and Human Services. W: \00496\0207.017\Health and Safety Plan.doc Health and Safety Plan Page 2 All RCIE personnel planning to visit the site must read, understand, and abide by this plan and sign the Acknowledgment of Understanding form attached to this plan. This plan will be reviewed by the site health and safety officer (SHSO) periodically, and any changes to this HSP must be approved by the Health and Safety Manager (HSM). During fieldwork mobilization, the Required Equipment and Personal Protective Equipment (PPE) Checklist (Figure 1 ❑ 1) will be consulted to ensure that all health and safety- related supplies and equipment are available at the site. 1.2 SCOPE OF WORK For this plan, project activities have been broadly divided into the following tasks: Demolition/removal actions along the Duwamish Waterway Earthwork along the Duwamish Waterway Installation of a low- permeability barrier wall system around the site perimeter Installation of a groundwater recovery system for hydraulic control Expansion of the site's groundwater monitoring network W: \00496\0207.017\Health and Safety Plan.doc I r Health and Safety Plan Page 3 Figure 1 -1 Required Equipment and Personal Protective Equipment Checklist Safety Equipment Personal Protective Equipment (per person) Air- purifying respirator (full face) - on hand Cartridges (specify type: organic vapor/HEPA) — on hand SCBA Airline system X Safety boots Chemical- resistant boots with steel toes Chemical- resistant coveralls (specify type ) X Coveralls (Tyvek or cotton) X Hard hat Face shield (as needed) X Latex gloves (box - 12 pair) Viton gloves (box - 12 pair) X Nitrile gloves (box - 12 pair) Other chemical or heat - resistant gloves (specify type X Safety glasses with side shields or goggles X Ear plugs Ear muffs Other (specify) Misc. PPE/First Aid and Emergency Equipment X Eyewash Solution (Portable Bottles) X First aid kit X Drinking water X Fire extinguisher (5 -pound Class A:B:C) Portable air horn Air supply system (compressed air cylinders) X Radio (or other form of communication) Oral thermometer W: \00496 \0207.017\Health and Safety Plan.doc (check those that apply) Monitoring/Sampling Equipment Radiation Oxygen level/CGI (MSA 361), H FID Toxic gas monitor (MSA 361) PlD Aerosol monitor Draeger tubes (box) (specify type(s): ) Air compressor Interface Probe/Water level meter Peristaltic pump/Dedicated bladder pumps Sorbent tubes (specify type: Water Quality Meter Decontamination Equipment X Tub DI water Potable water Buckets (5 gallons) X Plastic garbage bags 15- gallon poly -drums (2) X Brushes X Hand - pressurized portable water sprayer X Detergent (non - phosphate) X Paper towels Table Benches Other (specify) z ~ W 6 00 co 0 W = H WO g Q . co = I... w Z I— O Z W • 0 O - o w 2 I— w z Li; U � O 1— z sor 4 t ffYiswtx, 0 r Pb.., l■. . •.- .t1 9r.r.•wva .l NOTICE: N THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Health and Safety Plan Page 4 Figure 1 -2 "Site Location Map" W: \00496 \0207.017\Health and Safety Plan.doc Health and Safety Plan Page 5 2.0 RESPONSIBILITIES z = 1 w eG J 00 CO CO W J CD w w • Plan, organize, direct, coordinate, review, and evaluate the RCIE health and safety . g program; w co ▪ a w _ z � The following text identifies the individuals responsible for the implementation of this plan and describes the primary duties assigned to each position. 2.1 REGIONAL HEALTH & SAFETY MANAGER: The health and safety manager (HSM) is the health and safety professional who coordinates the RCIE health and safety program. In addition, the HSM will perform the following activities: • Supervise the employee health and safety training program; 1-O • Advise on matters of health and safety and provide recommendations for solving w w n • O O • N c ww 1L 0 . w z U 2 , ,, ;' 0 1- health and safety problems; • Review and approve all site safety plans and modifications; and • If warranted, evaluate site operations to ensure compliance with the site HSP and take corrective actions when necessary. 2.2 PROJECT MANAGER: The project manager (PM) will monitor all site operations and project implementation. In addition, the PM will perform the following activities: • Ensure that adequate resources are available to implement and carry out all site safety activities; • Ensure that all personnel assigned to the site receive all necessary health and safety training; • Familiarize all on -site personnel with site safety requirements; • Assign key safety duties and responsibilities to team members; • Ensure that all necessary PPE (including respiratory) is available and on site; and • Enforce the health and safety requirements specified in this plan. W:\ 00496\0207.017\Health and Safety Plan.doc z Health and Safety Plan Page 6 2.3 SITE COORDINATOR/ SITE HEALTH AND SAFETY OFFICER: z = 1-- z it 2 6 J U 0 0 c w W H w 0 u. Q U) I • Assist supervisory personnel when investigating all accidents and exposures to ~- Wm determine the cause, and make recommendations to prevent recurrence of the Z '- incident; Z o 11J w • Conduct on -site air monitoring and appropriate sampling to ensure compliance v N O oF- W � w z co O~ The site coordinator (SC /SHSO) shall implement this HSP, act to correct any safety deficiencies, and help select PPE, ensure that it is approved by the HSM, and that it is on site and properly used. The SC /SHSO will also perform for the following activities: • Ensure that on -site inventories can adequately support operations and site visitors; • Maintain a field log of all site visitors. • Maintain exposure /injury reporting and documentation and on -site health and safety record keeping; with appropriate action levels; • Verify that necessary safety and PPE is available and properly used; • Suspend site activities if conditions arise that present imminent danger to site personnel or visitors; the SHSO shall immediately notify the HSM and PM following the suspension of work; • Inform local emergency facilities about the nature of work being performed, dates and times of site activities, and possible injury types; • Maintain a health and safety activities in the logbook to record all field measurements, site activities, and decisions that might alter the HSP; • Conduct weekly health and safety meetings that shall include reviewing activities and hazard analyses; and • Document weekly health and safety meetings including date, attendance, and subjects discussed. W: \00496\0207.017\Health and Safety Plan.doc z Health and Safety Plan Page 7 3.0 PERSONNEL MEDICAL QUALIFICATIONS AND TRAINING REQUIREMENTS The required qualifications depend on an employee's level of involvement at the site, the amount of time spent on site, and the specific tasks the employee will be involved in when on site. In accordance with a company Hazard Communication Program, workers will be trained on the hazards they are exposed to while working on the site. For assessment of medical and training qualifications, all personnel entering the site will have the approval of the SHSO. In addition to 40- hour hazardous waste initial and annual 8 -hr refresher training, all site personnel will participate in weekly briefings to discuss the effectiveness of controls and the need for revisions. All site workers will have Confined Space Entry training and training on the specific hazards associated with the site. This training will include coverage of bloodborne pathogens. In addition, members of the field crew dedicated to this project will have current Adult Cardiopulmonary Resuscitation (CPR) and First Aid training (Red Cross certified). This training will be obtained prior to commencing fieldwork at this site. Each team member must have a physical examination prior to participation in field activities to verify that the worker is capable of wearing respiratory protective equipment (if necessary), capable of working in a physically taxing environment, and free of medical conditions that may be aggravated while working on site. The HSM is contacted before the annual physical and afterward (if the occupational health physician poses additional questions or concerns). A copy of each employee's clearance letter and fit -test will be available on site, whereas the more extensive health records are kept in secured offices at the contracted clinic. The employee also receives his/her own copy of the individual medical report. In the specific case of the work performed under this task, the basic annual physical will meet the requirements for the work scheduled. If additional tasks are added or if the scope of work changes dramatically, the medical surveillance requirements will be modified as necessary. W:\00496\0207.017\Health and Safety Plan.doc f. Health and Safety Plan Page 8 Table 3 -1 Training requirements for personnel involved in site activities "tr 'vSLi� sMY f ,,,y. 4 r ¢ t�'�.. peMAY -;or not ,e &ki >:�, 3V>�inimums. `revel Crairiipgr7 °" t Technicians, Laborers, Equipment Operators • Site Orientation • Read and sign Site Health and Safety Plan • Hazard Communication • Confined Space Entry (if applicable) Bloodborne Pathogens This section presents an assessment of the H &S hazards that may be encountered by site personnel during the course of work tasks associated with site activities. 4.1 CONTAMINANTS OF POTENTIAL OCCUPATIONAL HEALTH CONCERN Chemical hazard descriptions of those chemicals that could potentially be encountered while working at the former Rhone- Poulenc Site. Site activities may expose contaminated soil. Contaminants of concern at the site include toluene, heavy metals and by- products of the Vanillin process including some mineral oils. Potential respiratory, ingestion, and dermal exposure to soil, dust, wastewater, vapors and residue contaminated with chemicals are possible at the site. It is anticipated that airborne concentrations will be well below any regulatory limits for occupational exposure. The use of personal protective equipment to protect against these hazards will be utilized. 4.2 CHEMICAL HAZARDS W:V)0496\0207.017\Health and Safety Plan.doc 4.0 POTENTIAL SITE HAZARDS ANALYSIS There are two categories of chemical hazards associated with site activities: • Chemicals used to conduct the site work • Site Constituents Health and Safety Plan Page 9 The chemicals that are brought on site in order to conduct the work may be hazardous and subject to regulation under OSHA's Hazard Communication Standard (29 CFR 1910.1200). Site constituents are those which exist at the site and are the cause for conducting site activities. 4.2.1 Hazard Communication Materials Materials which are considered hazardous materials under the OSHA Hazard Communication Standard (29 CFR 1910.1200) may be used during this project. Proper chemical labeling, a current inventory of hazardous chemicals brought to the site, and Material Safety Data Sheets (MSDSs) will be provided at each project site. This project is not expected to store bulk quantities of hazardous chemicals. The SHSO will make copies of these MSDSs available to any subcontractors (i.e. drillers, excavators) on this project. RCIE written Hazard Communication program shall be maintained on site. 4.2.2 Site Constituents At this time, the site is not considered to have chemical constituents that may pose a hazard to those working on the site; however, site activities, site investigations or other events may potentially expose chemical hazards. If contamination is suspected that may expose workers to hazardous chemicals at the site, work activities will be halted. Contaminants of concern at the site include toluene, heavy metals and by-products of the Vanillin process including some mineral oils. Previous investigations of a section of the facility, performed by CH2MHill and AGI have identified the presence of toluene, food grade mineral oil, dissolved copper and a high pH in soils and groundwater. Copper WISHA PEL =0.1 mg/m3 (fume) TLV = 0.2 mg/m3 (fume) PEL1.0 mg/m3 (dust) 1.0 mg/m3 (dust) Chronic human intoxication rarely occurs from copper exposure. Ingestion exposure of large doses of copper is limited by its emetic effect. Inhalation of copper fume from welding processes has produced upper respiratory tract irritation and metal fume fever in exposed workers. Copper is also an essential element in human nutrition; normal intake is approximately 2 mg/day. Adverse effects have been demonstrated only at high exposure levels, and low levels of exposure are unlikely to be of concern. W: \00496\0207.017\Health and Safety Plan.doc Health and Safety Plan Page 10 Toluene CAL /OSHA PEL = 50 PPM; STEL = 150 PPM Fed/OSHA PEL = 200 ppm WISHA PEL = 100 PPM TLV = 50 ppm "skin" REL = 100 ppm Toluene is a central nervous system depressant. Symptoms include headache, nausea, dizziness and fatigue, but such symptoms typically do not occur at exposures below 200 ppm. Repeated and prolonged contact with liquid toluene may cause drying of the skin and dermatitis. Mild, transitory eye irritation may be experienced with exposure to vapors above 200 ppm. Toluene is not considered carcinogenic. Toluene's mean odor threshold is 3 ppm, which gives it good warning properties. Toluene's ionization potential (1P) is 8.82 eV, and its vapor pressure is 22 mm Hg. Toluene is known to the State of California to cause reproductive toxicity under the criteria of Proposition 65. Corrosives (Acids and Caustics) Corrosives are low pH (acids) or high pH (caustics or alkalis) substances that, by direct chemical action, are injurious to body tissue or can damage metal. Corrosive injury may be minor (irritation) or severe (causing burns or blindness). Caustic burns can be particularly dangerous because strong alkalis gelatinize tissue. Initial contact may not be painful, but prolonged contact and/or high concentrations can cause deep penetrating burns. The effects of solid corrosives (such as dusts) are largely dependent on their solubility in skin, moisture, and duration of contact. Eye, face, and skin protection should be worn whenever there may be contact with materials suspected of being contaminated with caustics. Nitric Acid WISHA/OSHA PEL/TLV/REL = 2 ppm STEL = 4 ppm Nitric acid is an extremely corrosive liquid and may cause severe burns, ulcers, and necrosis of the skin, mucous membranes, and eye tissues. Continued exposure to the vapor and mist of nitric acid may result in chronic bronchitis, with more severe exposure leading to chemical pneumonitis. 4.3 BIOLOGICAL HAZARDS Biological hazards may be encountered during field activities. Common biological hazards include: ticks, poison plants, mosquitoes, and snakes. Workers will be aware of the biological hazards that may be present on the site and the symptoms associated with exposure to these hazards. Exposure to biological hazards will be minimized through the use of personal protective W:\00496 \0207.017\Health and Safety Plan.doc z = 1- 1-1 0 0 to 0 W = F w 2 L ? • a = w z l.. 1— 0 Z ~ 0 O S • i2 O 1— W W u. 0 . ..z U= O 1 z Health and Safety Plan Page II equipment and proper hygiene. Personal protective equipment to be used may include: gloves, long sleeved shirts and long pants, and insect repellent. Workers will wear gloves for work handling wastewater, and face - shields where there is the potential for splash hazards. Workers will be instructed to wash their hands before they eat, smoke or leave the site. 4.4 PHYSICAL HAZARDS Potential non - chemical hazards associated with this site are described below. 4.4.1 Slips, Trips, and Falls Slips, trips, and falls are a potential source of trauma because of steep terrain, uneven ground, wet conditions or sampling equipment not properly stored in staging areas. Care should be taken to ensure proper footing and hand holds. The sampling area should be kept uncluttered and good housekeeping should be enforced. Construction debris, scrap metal, and other materials that pose puncture hazards should be picked up and disposed of properly. Proper footwear and careful attention to the terrain and the immediate vicinity are necessary to prevent injuries. Workers will be required to use fall protection if working at heights greater than 10 feet in accordance with the Washington State Fall Protection Standard for Construction Work. 4.4.2 Skeletal- Musculature Injury Field activities may require some lifting of heavy objects (ex. air compressor). No one is to attempt to lift large or heavy objects without assistance. The field task manager will ensure that appropriate equipment is available when it is necessary to move heavy equipment or objects. The following guidelines will be followed whenever lifting equipment such as, portable generators, compressors, coolers filled with samples, objects that are an odd size or shape or that weigh over 40 pounds. • Portable generators and/or compressors will be lifted using a two- person lift. • When moving heavy objects such as drums or containers, use a dolly or other means of assistance. • Plan the lift. If lifting a heavy object, plan the route and where to place the object. In addition, plan communication signals to be used (i.e., "1,2,3 lift "). • Wear sturdy shoes in good condition that supply traction when performing lifts. • Keep your back straight and head aligned during the lift and use your legs to lift the load. Do not twist or bend from the waist. W:\00496\0207.017\Health and Safety Plan.doc i�� Health and Safety Plan Page 12 4.4.3 Noise Regulations governing hearing conservation are provided in 29CFR 1910.95. Engineering controls will be used to dampen excessive noise at or above Occupational Safety and Health Administration (OSHA) Action Level of 85 dBa. Hearing protection, such as ear plugs, are required when working near an heavy equipment or speech is difficult to distinguish using a normal speaking voice. All RCIE field personnel should be participating in a Hearing Conservation Program and have had baseline exams and where appropriate, annual audiograms. 4.4.4 Hand Tools Eye injuries, puncture wounds, cuts, or lacerations could result from use of hand tools while collecting samples or repairing equipment. Tools should be in good condition and the right tool should be selected for the job. Safety glasses with side shields or safety goggles should be worn whenever projectiles are a potential problem. Loose clothes or jewelry will not be worn while operating hand tools. Steel -toed shoes should be worn when there is any risk that something could fall on the foot. Tools should be stored safely, with sharp edges protected. Screwdrivers should not be used as chisels, because their tips could break or fly off. The head could fly off a hammer with a loose or cracked wooden handle. Impact tools, such as chisels or wedges, with mushroomed heads might shatter on impact, sending sharp fragments flying. Knives, saw blades, and scissors must be sharp. 4.4.5 Heavy Equipment Operation of heavy equipment during site activities presents potential physical hazards to personnel. The following precautions must be observed whenever heavy equipment is in use: Personal protective equipment (PPE) such as steel -toed shoes, safety glasses or goggles, and hard hats must be worn whenever such equipment is present. Personnel must at all times be aware of the location and operation of heavy equipment, and take precautions to avoid getting the way of its operation. Never assume that the equipment operator sees you; make eye contact and use hand signals to inform the operator of your intent, particularly if you intend to work near or approach the equipment. Traffic safety vests are required for URS personnel working near mobile heavy equipment, such as backhoes and other excavators. W: \00496\0207.017\Health and Safety Plan.doc mo Health and Safety Plan Page 13 Never walk directly in back of or to the side of, heavy equipment without the operator's acknowledgment. When an equipment operator must operate in tight quarters, the equipment subcontractor should provide a person to assist in guiding the operator's movements. Keep all non - essential personnel out of the work area. 4.4.6 Underground and Aboveground Utilities The Site Manager or SHSO is responsible to ensure that underground utilities are located prior to the commencement of any subsurface (> 0.3 meters (1 ft.) activities. Resources include site plans, utility companies, and regional utility locating services. The proper utility company personnel shall certify in writing to the Site Manager or SHSO the deactivation of underground utilities, and the certification retained in the project files. Excavation, drilling, crane, or similar operations adjacent to overhead lines shall not be initiated until operations are coordinated with the utility officials. Operations adjacent to overhead lines are prohibited unless one of the following conditions is satisfied: Power has been shut off and positive means (e.g. lockout/tagout) have been taken to prevent lines from being energized. Wherever possible, the URS SHSO will observe power shut off and place a lock and tag on the switch. In all cases utility company personnel shall certify in writing to the Site Manager or SHSO the deactivation of overhead utilities, and the certification retained in the project files. The Site Manager or SHSO must also attempt to verify power shut off by checking that power is no longer available to the affected building or equipment. Equipment, or any part of the equipment, cannot come within the following minimum clearance from energized overhead lines (note — some states may have more stringent requirements): Power Lines Nominal System (kv) Minimum Required Clearance 0 -50 10 feet 51- 200 15 feet 201 -300 20 feet 301 -500 25 feet 501 -750 35 feet 751 -1000 45 feet 4.4.7 Trenching and Excavation All RCIE personnel are prohibited from entering a trench or excavation until it has been inspected by a competent person in accordance with 29 CFR 1926.650 -651 or the State Equivalent. If personnel are required to enter a trench or excavation that is deeper than four feet, W:\00496 \0207.017\Health and Safety Plan.doc N ,,, k 44 ' f4 ? e r, , ' A•ayr.N X532+ u v , .: 1. xNwrtA".:! LYYb' tC9.", S'; 5�' FVCMAA ".1 "P�TL•T'M.9P!�Nd'0.,.'4 Health and Safety Plan Page 14 the following provisions must be provided prior to entry by the contractor who created the excavation: z re ~ w � 00 0 67 CO W W l— w 0 2 �Q A copy of the Fed -OSHA Excavation Standard can be obtained from the HSM. All provisions of w this regulation must be complied with when working in a trench or excavation. Please note that z = t._ state equivalents may be more stringent. z 0 w U • 0 O N O l— W z If hazardous atmospheres are suspected, any trench or excavation more than four feet deep must be monitored. Adequate shoring, sloping, or benching techniques must be employed. Adequate means of employee access and egress must be utilized. The contractor's trained, competent person must inspect the trench or excavation on a daily basis, before work commences and on an as- needed basis throughout the day. 4.4.8 Heat Stress Field personnel involved in work tasks at each site may be susceptible to heat stress during periods of elevated ambient temperatures or humidity, or during the performance of strenuous activities, particularly if impervious protective clothing is worn. Personnel will be monitored for early signs of heat stress, whenever ambient temperatures reach or exceed 85 °F. Whenever impervious clothing (e.g., Tyvek) is worn, personnel will be monitored when temperatures exceed 70°F. Worker rotation schedules should be established as necessary. Drinking water and electrolyte beverages will be available at each work site and personnel will be encouraged to drink sufficient fluids to prevent salt loss and dehydration. Personnel should be cognizant of the early signs of heat stress and the necessary treatment procedures. 4.4.9 Cold Weather Stress (Hypothermia and Frostbite) Care must be taken to limit cold exposure by providing proper protective clothing, access to warm shelter, and a temperature- dependent work regimen limiting periods of outdoor activity, if necessary. Protection against cold stress should be initiated when temperatures drop below 45 4.4.10 Electrical Safety Ground fault circuit interrupters (GFCI) shall be used on all extension cords. All extension cords shall have a non - current carrying grounding conductor, and shall be equipped with strain relief. Cords with damaged insulation, plugs, or sockets shall not be used. Damaged extension cords are not to be repaired and shall be taken out of service. The SHSO is responsible for performing periodic inspections on portable extension cords and GFCIs. Extension cords that are used in the work area are to be inspected weekly. The SHSO is responsible for establishing a system of unique identifiers for extension cords and GFCIs, and a means of denoting that the system passed • _ W: \00496 \0207.017\Health and Safety Plan.doc z W • = 0 F- Health and Safety Plan Page 15 the periodic inspection. All portable tools shall be grounded or fabricated of approved, double insulated construction. Personnel are required to lockout and tagout any equipment (e.g. electrical, pumps, blowers) on which they will be performing any kind of maintenance or work which could result in an injury in the event of an unexpected startup. Warning signs will be posted on all equipment requiring lockout. "Lockout" involves physically locking out the energy source(s) to a piece of equipment scheduled for maintenance or repair to prevent an accidental movement or startup of the equipment. The lockout rule applies to almost every piece of utilized equipment. The exception to this is cord -and -plug equipment if it is unplugged and the plug is in the control of the worker at all times, and if there are no other sources of energy to the equipment. The types of work activities which could require Lockout/Tagout procedures include installing a piece of equipment, modifying a piece of equipment, and adjusting, maintaining, or servicing a piece of equipment in a manner in which an unexpected movement or startup of the equipment could cause injury. The types of energy that may need to be addressed include electrical and mechanical. Where a piece of equipment has more than a single source or type of energy, each must be addressed. The lockout hardware used is to be durable for the type of use it will receive, identifiable as to its purpose and owner, and individually assigned so that only the worker using the lock has the key. Workers who will be conducting work which will involve Lockout/Tagout procedures are to notify any other workers who may be affected by the Lockout. No worker is to attempt to remove the lock of another and restart locked and tagged out machinery. Only authorized and trained personnel will perform lockout and tagout. Training will be provided by the SHSO during the startup safety briefing. Authorized personnel will receive training during site safety briefing on what equipment requires lockout/tagout and proper lockout and tagout procedures. 4.4.11 Machine Guarding Remediation equipment such as blowers present hazards from nip points and rotating parts. Equipment must be provided with machine guarding (e.g. cages, shields) to protect employees. This guarding must be designed to prevent the operator from having any part of his body in the danger zone where it could be caught or struck by moving parts during the operating cycle. Machine guarding must not be removed for any reason except during necessary maintenance and repair. Proper lockout and tagout procedures must be followed to prevent the accidental energizing of equipment during maintenance and repair. Machine guards must be put back in place following maintenance and repair work. Warning signs will be posted at all machine guards indicating that personnel are not to operate the equipment unless guards are in place. W:\00496 \0207.017\Health and Safety Plan.doc Health and Safety Plan Page 16 4.4.12 Project Hazard Analysis This work involves the use of heavy equipment used for earth moving and other equipment commonly used during construction activities. Typical activities would involve mobilization, site preparation, demolition, earthwork, handling of waste, and the installation of a grownwater recover and monitoring system. Tasks involving the potential for contact with contaminated soils and wastewater may include all of the above. 1. Oversight Construction 2. Excavation 3. Installation of systems 4. Inspection • h h 1.4".t<41. tHzd$ • Med. High High Med. - High nv �+ Stres Med. Med. Med. Med. Med. Med. Med. Med. Med. Med. Med. Med. th f i g Med. Med. Med. Med. High High High Med. Low Low Low Med. Med. Med. Med. Low xca" t ation!- Low High Med. Low High — Exposure likely more than 50% of the time Med — Exposure likely 10 -50% of the time Low — Exposure likely less than 10% of the time n/a — Exposure not anticipated 5.0 HAZARD CONTROL MEASURES Hazard control measures are the primary steps taken to reduce the potential for accidents or exposures. All appropriate hazard control steps must be taken. Hazard control measures include Personal Protective Equipment (PPE), administrative controls, and air monitoring. 5.1 PERSONAL PROTECTIVE EQUIPMENT 5.1.1 General Personal Protective Equipment Level D PPE is expected to provide adequate protection for most tasks involving construction oversight and inspection. Level D PPE requirements are as follows: • Safety glasses with side shields or goggles are to be worn when working near the drill rig and/or handling chemicals (ex. preserving bottles); • A hard hat is to be worn when overhead hazards exist; • Work clothing; • Steel -toed boots are to be worn when in any area where equipment, drums, or other heavy items could crush feet; W: \00496 \0207.017\EIealth and Safety Plan.doc Health and Safety Plan Page 17 • Ear plugs are required when working near noise in excess of 85 dBA or speech is difficult to distinguish using a normal speaking voice; and • Work gloves as needed for working with sharp items or contaminated materials. The next level of protection would be an upgrade to Modified Level D PPE as determined necessary by the SHSO. Modified Level D PPE requirements are as follows: • Safety glasses with side shields or goggles are to be worn when working near the drill rig and/or handling chemicals (ex. preserving bottles); • A hard hat is to be worn when overhead hazards exist; • A Tyvek protective coverall is to be worn within contaminated areas; • Steel -toed boots are to be worn when working in any area where equipment, drums, or other heavy items could crush feet; • Ear plugs are required when working in an area in excess of 85 dBA or speech is difficult to distinguish using a normal speaking voice; and • Latex gloves are to be worn during sample collection or work with wastewater. • A face shield may be added to prevent splash hazards associated with wastewater. PPE for Confined Space Entry may be encountered. Confined Space Entry will be performed in accordance with RCIE, federal, state and local requirements. 5.2 ADMINISTRATIVE CONTROLS The following administrative controls will be used throughout the duration of field activities: • All site personnel will read, understand, and sign the HSP prior to project site activities; • The HSP must be present on site and will be followed by all site personnel; • Hands and face must be washed when leaving the work area and before engaging in any other activity, especially eating, drinking, or smoking; W:\00496\0207.017\Health and Safety Plan.doc Health and Safety Plan Page 18 5.2.1 Site Preparation • Protective clothing and equipment will be worn at the work site at the protective level specified in this HSP or by the SHSO; • All personnel will be trained in site - specific emergency procedures, including knowing the location of emergency telephone numbers and hospital route maps; • Personnel must use the "buddy system" as deemed necessary by the SHSO. Under no circumstances will employees work alone on site; • Safety briefings will be held weekly, or as needed, by the SHSO. Appropriate records will be kept of all meetings and decisions, which will be recorded in the field logbook; • Personnel will be instructed to record all of their activities and responsibilities in their field logbooks; • Possession or use of alcoholic beverages or drugs on site is prohibited. Employees may not report for work or perform duties while under the influence of intoxicants or drugs. Excessive consumption of alcoholic beverages is discouraged during off -duty hours because of the incompatibility of alcoholic beverages and site hazards; and • All personnel must immediately bring to the attention of the field supervisor, SHSO, or other supervisory personnel any condition, practice, or circumstance they believe is unsafe. To eliminate or control physical hazards encountered on site, use existing roadways rather than crossing unpaved areas, if possible. This practice will help transport personnel, materials, and equipment safely. 5.3 SITE SECURITY Site security at sites will be necessary to limit site access to authorized personnel only. Site security is the responsibility of the SC /SHSO or designee. Lock equipment within a fence or in a portable storage unit or secure off site during off - hours. W: \00496 \0207.017\Health and Safety Plan.doc z ~ w JU 00 to ❑ -I1.— U) u_ w 0 2 g? z a = z 1- 0 z I— w 0 O— ❑ I-- w w I- O w z U = o • . z Health and Safety Plan Page 19 5.4 SITE COMMUNICATIONS Two sets of communication systems will be established and checked daily prior to the start of work: • Internal communication among personnel on site will consist of hand signals; and • External communication (telephone and radio) between on -site and off -site personnel will be established by the SC /SHSO. The SC /SHSO will have a radio or cellular phone or will locate the nearest available phone in order to contact essential personnel in the event of emergency. 5.4.1 Tailgate Safety Meetings Tailgate safety meeting will be conducted upon the initiation of each discrete type of task. These meetings shall be conducted by the SHSO and will cover specific health and safety issues, site activities, changes in site conditions and a review of topics to be covered in the initial health and safety meeting as they apply to task - specific activities. Issues addressed in the tailgate meeting will be documented in the field logbook. Documentation of who attended the tailgate meeting shall be retained by the HSM with copies forwarded to the project records. 5.5 DECONTAMINATION PROCEDURES 5.5.1 General Decontamination Procedures If the monitoring instrument readings reach the Action Level in the OBZ or visible airborne dust indicate respirator use, the following steps will be followed whenever personnel leave the Exclusion Zone or work area: 1. Remove all equipment, sample containers, and notes from EZ and place in the CRZ. 2. Scrub boots with a stiff - bristled brush, wash with a decontamination solution, and then rinse with water. Washtubs and chairs will be provided. 3. Remove outer gloves (and boot covers, if used). 4. Remove Tyvek coverall; discard in provided container. 5. Remove hardhat; wash outer layer, rinse. 6. Remove eye protection. W: \00496\0207.017Wealth and Safety Plan.doc The decontamination area will be covered with plastic sheeting, which will be replaced when torn or heavily soiled, and at the end of each shift. • Health and Safety Plan Page 20 7. Remove hearing protection. 8. Remove inner gloves. z 9. Thoroughly wash hands, neck, and face. 6 J 0 10. Proceed to SZ. co o ill Redress in street clothes and exit. w 2 u_? a Each worker will be responsible for cleaning, sanitizing, and storing their own respirator in accordance with manufacturer's guidance (i.e., washing in warm water and detergent or z F- sanitizing solution, air drying, and storing in a plastic storage bag). Cartridges will be changed z O in accordance with the Company Health and Safety Program. 2 w U 0 All investigation- derived wastes (IDW) will be segregated into one of three categories: rn o— O F- LU • w • Wastewater (includes well purge water and decontamination water) F— • Soil (includes drill cuttings and sediment from decontamination containers) LI o • Solids (includes disposable PPE and sampling equipment) v P _ Each waste type will be placed in an appropriate container such as an open- topped, 550gallon z drum. Labels identifying the contents will be placed on each container. Waste containers will be stored on site pending laboratory analysis. Ultimate disposal will be coordinated with the PM and in accordance with relevant regulations. 5.5.2 S anitation Potable water will be made available at the site, either from a pressurized source or commercially available bottled water. Drinking cups will be supplied so personnel will neither drink directly from the source of water nor have to share drinking cups. Sources of non - potable water shall be clearly labeled as such. Unless toilet facilities are available on site or transportation is readily available to transport personnel to nearby (within 5 minutes) toilet facilities, portable toilet facilities, such as chemical toilets, will be provided on site. Washing facilities will be provided on site, and will be located in the decontamination area or the r support area. Soap, clean water, wash basins, and single -use towels will be available for personnel use. W: \00496\0207.017\Health and Safety Plan.doc Health and Safety Plan Page 21 5.5.3 Decontamination — Medical Emergencies In the event of physical injury or other serious medical concerns, immediate first aid is to be administered in lieu of further decontamination efforts. z w -1 C.) O 0 U) 0 J 1- 1— Cf)LL w g Q = • d t-- _ . zF.. 1-0 Z 1— w w . U 0 o f The use of monitoring equipment is not anticipated due to the semi - volatile nature of oil. If site w w conditions change or odors are noted that cause concern, a photoionization detector may be used 1 to determine airborne concentrations to total hydrocarbons. The following may be utilized: _. ` z � Organic Vapor Analyzer, Microtip, Hnu, Organic Vapor Monitor, MiniRAE PID v 5.5.4 Decontamination of Tools When all work activities have been completed, contaminated tools will be either appropriately decontaminated or properly disposed of as hazardous waste. Tools that can be decontaminated are constructed of non - porous, non - absorbent materials. Decontaminate tools (shovels, auger flights, etc.) by brushing them with a decontamination solution (e.g., Alconox and water) and rinsing with water. A high- pressure steam cleaner may also be used for decontamination. All visible particles are to be removed before the tool is considered clean. All waste and spent decontamination solutions, will be properly contained. Any tool, or part of a tool, that is made of a porous /absorbent material will be discarded and disposed of as a hazardous waste if it cannot be properly decontaminated. 5.6 MONITORING EQUIPMENT (0) The monitoring equipment must be calibrated in accordance with the manufacturer's instructions. In addition, the results of daily instrument calibrations shall be logged in the field logbook, or on a Daily Instrument Calibration Check Sheet. W: \00496\0207.017\Health and Safety Plan.doc L livnYb z '!.: r ,'-;� na e , in f 'hy p 'w" ?I, t t e ...y- . ^, ,�x?Auradon�' *:n . - 1•�...a %.: .. _!•,• .n�`'t•,'d� =� t�;;�c.Ac4on�,- ,�,i•,;Y,�� .- ••,-a,4`hi:YM_;y'Y�i� ,::•,. }: •. ., t`c.; � xP .e e`•Equipm ents <5 ppm Point of operations/release source point -- Continued periodic monitoring Minimum Level D site ensemble <5 ppm First Action Level OBZ -- No respirators required Minimum Level D site ensemble 5 - 20 ppm Second Action Level OBZ > 1 minute Provide respiratory protection. Contact the RHSM to discuss personal monitoring Add half -face respirators with organic vapor cartridges >20 ppm Third Action Level OBZ >1 minute Increase respiratory protection Replace half -face respirators with full -face respirators with organic vapor cartridges. >100 ppm Fourth Action Level OBZ OBZ >1 minute • Stop work; move upwind while vapors dissipate. If elevated levels remain, cover boring and cuttings, evacuate upwind and notify HSM or PM. As specified by HSM Health and Safety Plan Page 22 ACTION LEVELS (for Photo Ionization Detector) *above background readings $Substitute poly- coated Tyvek if there is potential for contact with liquids (groundwater, mud, etc) OBZ= Operator's Breathing Zone 6.1 POTENTIAL INCIDENTS 6.2 OPERATIONS SHUTDOWN W: \00496\0207.017\Health and Safety Plan.doc 6.0 EMERGENCY RESPONSE Although unlikely to occur, the following situations would require emergency response action: • A heat/cold stress - related injury; • Serious injury as a result of fall hazards on steep or uneven terrain; • Back injury; and • Impact injury caused by dropping a heavy object (such as a flight auger) on an extremity. Should any of the above - mentioned incidents occur, any member of the field crew may temporarily suspend field operations. The SC /SHSO will immediately order an evacuation of the site and notify the appropriate emergency service. In the event of a major fire with explosion potential, all personnel within the immediate vicinity of the emergency will be notified of the situation. Health and Safety Plan Page 23 6.3 EMERGENCY RESPONSE PROCEDURES In case of a medical emergency, an immediate response, or a rapid response situation, the following procedures will be implemented and are outlined below. 1. Survey the scene; 2. Do a primary survey of victim(s), check for unresponsiveness (airway, breathing, circulation); 3. Phone emergency medical services. For police, ambulance, or fire emergency, call 911; 4. Do a secondary survey including interview, vital signs, head -to -toe exam; 5. Apply first aid as appropriate; and 6. Notify Client and RCIE PMs. An eyewash station will be available at the job site to treat minor eye injuries caused by splashing contaminants or particles. A first -aid kit will be available at the job site to treat other minor injuries. All injuries will be reported to the PM and HSM as soon as possible. An injury/illness report will be completed by the SHSO and forwarded to the HSM within 24 hours of the incident. W:\00496 \0207.017\Health and Safety Plan.doc ' 0, 4 4 '.•ftk , Health and Safety Plan Page 23 Figure 6-1 "Route to Medical Center" Hospital/Clinic Virginia Mason Hospital Address 925 Seneca Street, Seattle, WA 98101 Paramedic 911 Fire Dept. 911 Police Dept. 911 10005 \GLG1Health sad Safety PlansW.aampie Construction Hat Waste HASP.doc Directions 1. Starting on DUWAMISH AVE S 2. Turn Right on S SPOKANE ST 3. Continue towards COLUMBIAN WAY(I-5 N) 4. Continue on WEST SEATTLE BRG 5. Take the 1-5 NORTH ramp towards VANCOUVER BC 6. Merge on 1-5 NORTH 7. Take the 1-90 EAST/DEARBORN STJJAMES ST./MADISON ST. exit towards SPOKANE, exit #164A 8. Continue on 7TH AVE 9. Turn Right on SENECA ST Phone No. 206-583-6433 Distance 0.2 . 0.8 0.1 0.1 0.3 0.8 1.5 0.1 0.1 0 • . 4 l � F: Y - • � Y f i y , • x a ` ^ j � ame to .t �• L,* �'. y'�' ', {� " � ri �'- .�r3�4 � _a. � < ' rt . y; i ' ":. kt, '4:1.4 Y , ,a :¢. S na �_ re ; t ,�� c ::a ; i +' � l., ∎_.{ � y ` a • H" � a 1.1-,: 4, °• -::w . t ny • Health and Safety Plan Page 25 HEALTH AND SAFETY PLAN — FORMER RHONE - POULENC SITE SAFETY PLAN COMPLIANCE AGREEMENT I have received a copy of the Health and Safety Plan for the site activities. I have reviewed the plan, understand it, and agree to comply with all of its provisions. I understand that I could be prohibited from working on the project for violating any of the health and safety requirements specified in the plan. W: \00496\ 0207.017\Health and Safety Plan.doc { r , APPENDIX. I NSTRUCTION= QUALITY ASSURANCE PLAN :J+x :.:i.�,:mrbds:ar 3 "7 _.J CONSTRUCTION QUALITY ASSURANCE PLAN Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site June 2002 UPS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 (206) 438 -2700 53- 01000496.00 01000 Z = 1- +�. 2 J 0 U W = J F W O g 1. co d : = Z _ F- O. Z F— O U u j • U LLI Z U u O z. J TABLE OF CONTENTS Page 1.0 INTRODUCTION 1 -1 1.1 GENERAL 1 -1 2.0 ADMINISTRATION 2 -1 2.1 PROJECT RESPONSIBILITY AND AUTHORITY 2 -1 2.2 CQA RESPONSIBILITY 2 -2 2.3 PROJECT COORDINATION 2 -2 2.3.1 Preconstruction Meeting 2 -2 2.3.2 Coordination Meetings 2 -2 2.3.3 Problem Resolution Meetings 2 -3 3.0 CONSTRUCTION AND INSPECTION ACTIVITIES 3 -1 3.1 CONSTRUCTION MONITORING 3 -1 3.2 SITE PREPARATION 3 -1 3.3 DEMOLITION 3 -2 3.4 EARTHWORK 3 -2 3.4.1 Soil Selection 3 -3 3.4.2 Placement and Compaction 3 -3 3.4.3 Soil Testing 3 -3 3.5 BARRIER WALL SYSTEM 3 -3 3.5.1 Soil - Bentonite Barrier Wall Construction Monitoring 3 -4 3.5.2 Soil - Bentonite Barrier Wall Protective Cap 3 -5 3.5.3 Impermix ® Barrier Wall Construction Monitoring 3 -6 3.6 GROUNDWATER RECOVERY AND MONITORING SYSTEMS 3 -7 3.6.1 Material Selection 3 -7 3.6.2 Material Installation 3 -7 3.6.3 Testing 3 -8 3.7 WASTE HANDLING 3 -8 3.8 SITE RESTORATION 3 -8 4.0 RECORD DOCUMENTATION 4 -1 4.1 GENERAL 4 -1 4.2 DAILY SUMMARY REPORTS 4 -1 4.3 MONTHLY PROGRESS REPORTS 4 -1 4.4 DRAFT AND FINAL REPORTS 4 -1 4.5 DOCUMENT STORAGE 4 -1 5.0 DATA MANAGEMENT 5 -1 5.1 GENERAL 5 -1 ATTACHMENT 1 - APPROVED DATA MANAGEMENT PLAN W: \00496\0207.017\DRAFT REPORT APPENDIX I.DOC 1 1.1 GENERAL This plan is also intended to be a working template, upon which additional site- and activity - specific procedures and protocols may be developed and incorporated as amendments throughout the construction period. Upon review and approval of amendments by QA/QC personnel, amendments will be documented and copies of the policy, procedure, or checklist will be added to this document. This appendix presents the construction quality assurance (CQAP) plan to support construction z of the Hydraulic Control Interim Measures (Interim Measures) for the former Rhone- Poulenc = I= facility (the site) located on East Marginal Way in Tukwila, Washington. Quality control (QC) re w of materials and workmanship is included in the Construction Quality Assurance (CQA) program 2 for the project. The Interim Measures are part of a Resource Conservation and Recovery Act v p (RCRA) corrective action being conducted at the former facility. As required by the Consent Order, this CQAP plan addresses: W i . • Responsibilities, qualifications, and authority of organizations involved in the Interim w o Measures, and essential design and construction personnel g u_ Q. • Specific Quality Assurance /Quality Control ( QA/QC) requirements and performance s D standards 1- W zF.. • Inspection activities, observations, and tests, including materials sampling requirements z 1.11 O • Procedures for documenting and reporting QA/QC activities v 0 O- This plan provides a framework for assuring that quality is integrated into every aspect of this w ~ project. The plan defines the processes that will assure that technical, regulatory, health and i v safety, budget, and schedule commitments are met in a satisfactory manner. It is intended to be a �- p guide for CQA personnel for lines of authority and to specific sections of the specifications that iii z contain QA/QC requirements of the work. Specific QA/QC requirements for submittals, testing 1 I and documentation are contained in the referenced sections. o z W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 1.0 INTRODUCTION 1 -1 2.1 PROJECT RESPONSIBILITY AND AUTHORITY This section summarizes the responsibilities and authority of each organization involved in the z construction of the Interim Measures for the site. The primary parties involved in this project, =1= 2 • EPA -EPA is the lead regulatory agency for this interim measure, which is being o p per under Administrative Order on Consent for Corrective Action (Consent Order) w W Numb 1091- 11- 20- 3008(h) between Container Properties L.L.C., Rhodia, Inc., and z EPA Region X dated March 31, 1993, and amended in February 1999. EPA has an 1 G7 u_ oversight role for the proposed design and construction activities, evaluating their w o compliance with the Consent Order, and has the authority to approve or reject any part of the work determined not to be in compliance. EPA will also review QA/QC activities a and corrective actions for conformance with the requirements of the Consent Order. = c3 F. z w • Container Properties, L.L.C— Container Properties has assumed overall responsibility I.- for financing and implementing the Interim Measures. To facilitate these efforts, w o Container Properties has selected RCI Environmental (RCIE) as its design/build ■ ? o contractor. U 0 I- • RCI Environm —RCIE will manage and direct overall design and construction w w activities of this project. RCIE will report to EPA any QA/QC issues associated with 1 implementation of this project. RCIE will be responsible for compliance with, and I'-- z implementation of, the design criteria, dr and technical specifications for the w U) Interim Measures. F- I 0 z and their role, are as follows: C w • Subcontractors — Subcontractors (to be selected by RCIE prior to the start of construction) will be responsible for compliance with, and implementation of, the design criteria, drawings, and technical specifications for specialty portions of the Interim Measures for which they are subcontracted. Subcontractors will provide access to the work for testing and inspection and will promptly correct all deficiencies during performance of their work. • Laboratories— Materials testing and analytical laboratories (to be selected by RCIE prior to the start of construction) will be responsible for analyzing samples to support construction QA/QC activities. RCIE will select the laboratories based on certification by the American Council of Independent Laboratories and demonstrated experience in specific aspects of required testing. • URS Corporation (URS) —URS is the Engineer for the Interim Measures. URS will assist RCIE in CQA activities during the project. W:\00496\0207.017\DRAFT REPORT APPENDIX I.DOC 2.0 ADMINISTRATION 2 -1 2.2 CQA RESPONSIBILITY RCIE will be responsible for the provision of CQA services for the construction of the interim measure. The CQA personnel will be representatives for RCIE. RCIE's CQA personnel and their general responsibilities are as follows: • CQA Project Director — The CQA Project Director shall be a registered professional engineer (PE) in the State of Washington, and will be responsible for all of the activities of the CQA program for RCIE. The CQA Project Director will review all onsite activities, including laboratory test results, and directly address deficiencies that are encountered. The CQA Project Director will make periodic site visits to review the operations and progress. • CQA Field Manager — The CQA Field Manager will be the onsite representative of the CQA program for RCEI. The CQA Field Manager will act as liaison between RCIE and its subcontractors, and will supervise all CQA Field Monitors. • CQA Field Monitors — The CQA Field Monitors will assist the CQA Field Manager with the provision of monitoring and documentation of the Contractor activities. CQA personnel will have appropriate experience on similar projects for installation of materials proposed for this interim measure. 2.3 PROJECT COORDINATION 2.3.1 Preconstruction Meeting Before the start of construction, RCIE will arrange a preconstruction meeting with EPA. RCIE's key personnel will be introduced at the meeting and contact information provided to the meeting participants. Representatives from permitting agencies and major subcontractors also may be in included in this meeting, if appropriate. The meeting agenda will include a discussion of project execution requirements, administrative procedures, recordkeeping, and construction sequencing and schedules. The meeting will also review of general QA/QC administration, including: • Responsibility and authority of the primary parties, permitting agencies, and their representatives. • RCIE's responsibilities for providing access, samples, or other assistance to EPA, and permitting agencies. • RCIE's responsibility for implementation and control of the QA/QC process, including notifications to EPA regarding QA/QC problems and corrective actions. 2.3.2 Coordination Meetings Coordination meetings will occur on a periodic basis, to be agreed upon during the preconstruction meeting, throughout the construction period. These meetings will address on- W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 2 -2 going construction activities, schedules, field modifications of design or construction requirements, and contractor QA/QC activities. Informal progress meetings will also be held between RCIE and its subcontractors as appropriate. The meetings will serve as a forum for discussing QA/QC issues, assuring that appropriate notifications and submittals are performed, and resolution of technical, administrative, and budgetary issues. 2.3.3 Problem Resolution Meetings When QA/QC issues arise that may affect overall project quality or impede the construction schedule, RCIE will arrange special meetings with the primary parties and appropriate permitting agencies or subcontractors to assure prompt resolution. Corrective actions agreed upon during these meetings will be documented, implemented, and their effectiveness monitored by RCIE. W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 2 -3 ...... vs:!' �w�!*+T AI +7+S tianva:ul+w ::a+pr�i.a:yve2?tiy i.4s r'�s�; at4;; `r ''k";a.. 3.0 CONSTRUCTION AND INSPECTION ACTIVITIES This section summarizes construction activities anticipated for this project. It also describes the general CQA inspections, measurements, and physical testing that will be performed during execution of these construction activities. Additional activity - specific requirements are indicated in the design drawings and technical specifications. 3.1 CONSTRUCTION MONITORING The construction of this interim measure will be carried out as a series of discrete, but interdependent, activities. Each activity has its own implementation and control requirements for proper execution of the work. The following major construction activities have been identified for this project: • Site preparation • Demolition and well abandonment • Earthwork • Barrier wall system • Groundwater recovery system • Groundwater monitoring system • Waste handling, transportation, and disposal • Site restoration 3.2 SITE PREPARATION Site preparation activities will include: • Set up of site management systems such as, survey controls, temporary accommodation, site security, access routes, work areas and decontamination facilities • Establishment of staging areas, storage areas, and waste accumulation areas • Protection of existing features to be retained • Completion of utility locates and abandonment • Installation of Temporary Erosion and Sedimentation Control (TESC) stormwater management controls, and dust and noise control measures Site preparation activities will be completed in accordance with Specification Sections 01500 — Temporary Facilities and Controls and Section 02270 — Erosion and Sedimentation Control. Materials required to complete the work will be subject to approval by RCIE, and the Engineer. Materials will either be accepted or rejected based on conformance with the Specifications. Specific material requirements are detailed in the Specifications. W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 3 -1 RCIE, with the assistance of URS, will monitor and inspect site preparation activities to verify compliance with the Specifications. TESC, stormwater management controls and dust and noise control measures will be maintained for the duration of the work in accordance with the requirements of the Specifications. 3.3 DEMOLITION Demolition of existing structures will primarily occur along the alignment of the barrier wall system. Expected items that will require demolition include concrete slabs and foundations from previously removed structures, existing berms, abandoned rail tracks, asphalt pavements and previously abandoned conduits and piping. Demolition activities will be completed in accordance with Specification Section 02130 — Removal of Existing Structures. RCIE will monitor and inspect demolition activities to verify compliance with the Specifications. Particular attention will be paid to demolition of existing underground piping, conduits or structures. When any underground structure is encountered, it will be exposed, evaluated to determine if it is "live," and the appropriate utility provider contacted to allow proper shut down, plugging, or termination or abandonment outside of the work area. 3.4 EARTHWORK Earthwork activities will include: • Clearing and grubbing of miscellaneous surface vegetation along the proposed barrier wall alignment • Surface grading, as necessary for the control of surface water runoff • Pre - trenching along the barrier wall alignment, to identify subsurface conditions that may cause difficulties during the barrier wall construction • Construction of temporary berms and surface barriers for the control of surface water runoff and containment of slurry used in construction of the barrier walls Earthwork will be completed in accordance with Specification Sections 02110 — Excavation, Handling, and Disposal of Hazardous Materials, 02200 — Earthwork, and 02324 — Trenching. Perform all handling, testing, and classification of potentially hazardous soils and water as specified in Section 02110 — Excavation, Handling, and Disposal of Hazardous Materials. Indication parameters are identified in the Interim Measures Work Plan. Document all activities as specified in 02110 — Excavation, Handling, and Disposal of Hazardous Materials, and in accordance with applicable regulations. W: \00496\0207.017\DRAFr REPORT APPENDIX I.DOC 3 -2 3.4.1 Soil Selection Soils will be selected in accordance with the Specifications. Soil materials will be approved by the CQA Field Manager prior to placement as part of the work. Laboratory test results and samples will be used to determine each materials conformance with the Specifications. Specific testing requirements are detailed in the Specifications. 3.4.2 Placement and Compaction cc 2 RCIE's CQA personnel will shall monitor and inspect soil material placement and compaction to v o verify compliance with the Specifications. Placement of soils in bermed areas and as part of the w = soil - bentonite protective cap will be completed in compliance with Specification Section -' F. N 0 02200 - Earthwork. w o Refer to the Section 3.5 of this CQA Plan for the placement and compaction requirements of g materials placed as part of the barrier wall construction. "- 3.4.3 Soil Testing Z z Laboratory testing of the soils materials to be used shall be carried out for the purpose of z o materials selection and for materials quality assurance during construction operations. Soil testing will be carried out in accordance with the methodologies and frequencies described in the v Specifications. The primary soil testing methodologies to be carried out will be gradation and o - . Atterberg Limits. _ w 0 Samples will be collected from materials delivered to the site for the purpose of conformance L—`' Z testing. The samples will be shipped to the laboratory for completion of the conformance testing analysis. The CQA Field Manager will evaluate the test results and accept the material prior to o H incorporation of the material as part of the work. Additional testing will be performed during construction for quality assurance purposes. This testing ensures that the materials do not vary significantly or adversely during the course of the work and that the materials consistently meet the Specifications. Where required by the Specification, in situ testing of the soils after placement and compaction shall also be completed to determine their as- compacted properties and verify conformance with the Specifications. The primary in situ soil testing to be carried out is the field determination of dry density and moisture content using a nuclear density gauge. 3.5 BARRIER WALL SYSTEM The barrier wall will be constructed using two installation methods. The north and east portions of the proposed barrier wall will be installed by trenching with slurry methods to the upper aquitard, and using a soil - bentonite backfill to create the barrier. The remaining south and west portions of the proposed barrier wall will be installed using a vibrated beam method (no excavation). Each installation method will key the bottom of the barrier wall at least 2 -feet into the upper aquitard. W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 3 -3 The soil - bentonite barrier wall will be constructed in accordance with Specification Section 02395 - Soil - Bentonite Barrier Wall. The barrier wall installed using the vibrated beam method will be constructed in compliance with Section 02396 - Impermix ® Vibrating Beam Barrier Wall. The CQA Field Manager will compile and review the results of construction quality control z testing and construction quality assurance testing daily. i z IX w 3.5.1 Soil - Bentonite Barrier Wall Construction Monitoring JU 00 The following section delineates QA/QC procedures for materials required for the construction u) w of the soil - bentonite barrier wall. The subcontractor will perform testing and provide verbal w _ results to RCIE immediately and written results within 24 hours. Test methods and frequencies 1 _1 will be as per Specification Section 02395 - Soil - Bentonite Barrier Wall. O gQ • Horizontal Alignment —The horizontal alignment of the barrier wall will be monitored as excavation proceeds. Measurements will be taken at 50 -foot intervals at the point of = a trenching to compare the excavation centerline with the proposed wall centerline. Z I- O • Width —The width of the barrier wall will be monitored as the excavation proceeds. The z I LLI minimum width of the soil - bentonite barrier wall will be 3 feet. • ? o 0 • Depth —Depth measurements will be performed at 20 -foot intervals to ensure that the o h- trench has reached the required depth. In addition the excavated material near the = w proposed bottom of the trench will be observed to compare the excavated soil with the ►- expected soil. The soil at the target depth will consist of a plastic silt defining the upper "-- O z aquitard. Lb w 0 1- • Slurry Level —The slurry level will be visually monitored on a continual basis. In addition, the level will be measured and recorded at the beginning and end of each 8 -hour work shift. Slurry should be added, if necessary, to maintain the level at a maximum depth of one foot below the ground surface. W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC • Dry Bentonite —The barrier wall subcontractor will provide a statement from the supplier certifying that the properties and composition of the bentonite complies with the Specifications for each truck load delivered to the site. The statement will include specified physical properties, chemical purity and dry fineness. • Water —Water used for the slurry and barrier wall backfill shall be tested weekly for conformance with the Specifications. Water analysis will include pH, conductivity, total hardness and total dissolved solids. • Fresh Slurry Fresh slurry will be tested at least twice each day prior to introduction into the trench. Testing will include temperature, pH, unit weight, viscosity, and filtrate loss. FAV 3 -4 1 • Trench Slurry —Slurry from the bottom of the trench at the toe of the backfill slope and at the point of trenching will be tested at least, at the beginning and end of each 8 -hour workday. Testing will include temperature, pH, unit weight, viscosity, and sand content. • Backfill — Backfill will be tested for slump and density at a frequency of 1 test per 200 z cubic yards of backfill and at least once per day of backfill placement. Gradation, Atterberg Limits and water content shall be tested at a frequency of one test per 800 cubic 1- W yards, flexible wall hydraulic conductivity shall be tested at a frequency of 1 test per 6 D 2,000 cubic yards. v 0 U) o • Backfill Slope —The depth to the slope of the backfill will be measured and recorded at w = 20 -foot intervals at the beginning and end of each 8 -hour work shift. If there is an F- indication of soil accumulation on the backfill slope since the end of the previous shift, w 0 the accumulated soil will be removed before proceeding. n J u-Q • Stability —The site will be monitored daily for indications of potential instability. Any w a such indications, including but not limited to sloughing of the trench walls, movement of Y s the ground surface, or squeezing of the trench, will be recorded and corrective actions z (- instigated. z o wW 3.5.2 Soil - Bentonite Barrier Wall Protective Cap D o O N The following section delineates QA/QC procedures for materials required for the construction ° I- of the soil - bentonite barrier wall protective cap. Test methods and frequencies will be as per the i v specification sections listed below. u.. ~o z Lii • Backfill Soil —The backfill soil used for the barrier wall protective cap will be inspected o to meet the requirements for Structural Fill described by Specification Section 02200 - p . - Earthwork and Section 3.4 of the CQA Plan. z • Geogrid —The geogrid used for the barrier wall protective cap will be inspected to ensure that it is supplied and installed to meet the requirements described by Specification Section 02273 - Geogrid Material. The geogrid manufacturer will provide written certification that the material supplied complies with all requirements of the specification including: thickness; tensile strength; junction strength; creep behavior and long term design load; and open area. Backfill soil will be placed over the geogrid in a manner that ensures the geogrid and the underlying materials are not damaged. • PVC Geomembrane —The PVC geomembrane used for the barrier wall protective cap will be inspected to ensure that it is supplied and installed to meet the requirements described by Specification Section 02776 - PVC Geomembrane. The PVC geomembrane manufacturer will provide written certification that the material supplied complies with all requirements of the specification. The surface on which the geomembrane is to be placed will be inspected prior to installation of the geomembrane to ensure that no conditions exist that could be detrimental to the geomembrane. Backfill soil will be placed over the PVC geomembrane in a manner that ensures the geomembrane is not damaged. W:\ 00496 \0207.017\DRAFr REPORT APPENDIX I.DOC 3 -5 ATi'l. Y. F3Zt?! nL�: IS? ty/ ift4 'cCC.24'c:Ai +h:R'}^�i�+:v51.: +a 3.5.3 Impermix ® Barrier Wall Construction Monitoring The following section delineates QA/QC procedures for materials required for the construction of the Impermix ® barrier wall. The subcontractor will perform testing and provide verbal results to RCIE immediately and written results within 24 hours. Test methods and frequencies will be as per Specification Section 02396 – Impermix ® Barrier Wall. • Horizontal and Vertical Alignment —The horizontal alignment of the barrier wall will be monitored as excavation proceeds. Measurements will be taken at 50 -foot intervals at the point of trenching to compare the excavation centerline with the proposed wall centerline. Guide leads will be used to ensure the vertical alignment of the wall is within 1 percent of plumb. The verticality of the barrier wall will be measured for each insertion of the vibrating beam using hand levels. • Width —The width of the barrier wall will be monitored as the excavation proceeds. The width of the barrier wall will be monitored by comparing the daily area of barrier wall constructed in relation to the volume of slurry consumed. • Depth— Barrier wall depth will be monitored based on depth the vibrating beam reaches during the wall construction. The required barrier wall depth will be determined in the field by evaluation of available subsurface information, including data obtained during construction such as observations of driving resistance. In general, the depth of the vertical barrier will be determined based on achieving the designed penetration of the upper aquitard. • Water— Water used for the slurry and barrier wall backfill will be tested weekly for conformance with the Specifications and whenever the source of the water is changed. Water analysis shall include pH, conductivity, total hardness and total dissolved solids. • Slurry as mixed —Slurry will be tested immediately before entering the trench at a frequency of every 20,000 gallons, or twice daily (whichever requires the most tests). Testing shall include unit weight and viscosity. • Slurry in wall —Slurry placed in the trench shall be tested for hydraulic conductivity. The frequency of the testing shall be determined in consultation with the subcontractor but will be not less than 1 sample per 200,000 gallons. • Stability The site will be monitored daily for indications of potential instability. Any such indications, including but not limited to sloughing of the trench walls, movement of the ground surface, or squeezing of the trench, will be recorded and corrective actions instigated. W:\00496\0207.017\DRAFT REPORT APPENDIX I.DOC 3 -6 ■ 3.6 GROUNDWATER RECOVERY AND MONITORING SYSTEMS The groundwater recovery and monitoring systems will include: • Three 6 -inch diameter PVC groundwater extraction wells, with extraction pumps, constructed within the barrier wall system; z _ w I '~ • A groundwater storage and treatment system. The groundwater extraction wells will be c connected to the storage and treatment system via a below ground piping network. -J v Groundwater that has been treated will be discharged to the Metro sewer system; v o co co w • A system of groundwater monitoring wells, both inside and outside the area enclosed by -I I 1 - the barrier wall. The groundwater monitoring wells will include both existing wells and w o new wells, installed as part of the construction. 2 J 3.6.1 Material Selection c All materials required for the groundwater recovery and monitoring systems will comply with Z 1 the requirements of the Specifications and Drawings. As required by the Specifications, the 0 manufacturer of each component of the systems will provide written certification that the w '— material supplied complies with requirements of the specification. Specific material D 0 requirements are detailed in the Specifications and on the Drawings and include the following: vo of- • Groundwater extraction pumps will conform to the requirements of Section 11312 — = W Submersible Pumps and Accessories. o ..z • Groundwater extraction wells and groundwater monitoring wells will conform to the v requirements of Drawing 9 and Specification Section 02210 — Well Drilling. o T z • The groundwater recovery well and treatment system discharge piping will conform to the requirements of the Division 15 and 16 Specifications, as applicable. • The groundwater treatment system will conform to the requirements of Section 11345 — Treatment Equipment, and the Division 15 and 16 Specifications, as applicable. • Concrete foundations and supports required as part of the groundwater recovery and groundwater monitoring systems will conform with the requirements of Section 03300 — Cast -in -Place Concrete. 3.6.2 Material Installation RCIE will monitor and inspect activities associated with construction of the groundwater recovery and monitoring systems to verify compliance with the Specification. In addition to the requirements of the Specification, groundwater well installation, documentation, and abandonment, as appropriate, will be completed in compliance with Section 02210 — Well Drilling, Section 02220 — Well Abandonment, and with the Washington Administrative Code (WAC) Chapter 173 -160. W: \00496\0207.0I7\DRAFT REPORT APPENDIX 1.DOC 3 -7 t:A ast'ta�a 7 r;.,— Inspections will include erected formwork and reinforcement to ensure that work is in accordance with the design, and that supports, fastenings, wedges, ties, and items are secure. 3.6.3 Testing Pipe and fittings shall be pressure- tested in compliance with the requirements of Specification Section 15105 — Pipes and Tubes. In general: • Sewage and water piping, except concrete sewer pipe and drain pipe, will be hydrostatically pressure tested. • Gas and air piping and fittings will be air pressure tested. Cast -in -Place concrete shall be tested for compressive strength and slump, in accordance with Specification Section 03300 — Cast -in -Place Concrete. 3.7 WASTE HANDLING Waste handling activities will include the characterization, accumulation, temporary storage transport and disposal of project derived wastes in accordance with local, state and federal requirements. Initial waste characterization will be carried out at the point of generation, based on the source or process generating the waste and generator knowledge of the probable regulatory status of the wastes. Based on characterization activities, wastes will be accumulated in interim, centralized storage areas. Drums and bulk containers will be properly labeled in accordance with the appropriate local, state and federal regulations. Municipal type solid waste will be handled in accordance with King County Code, Title 10 Solid Wastes. RCIE or its subcontractors, depending on the type and characterization of the waste, will transport wastes from the site for disposal. The packaging, labeling, and placarding of waste loads will be performed in accordance with 49 CFR 172. Individual waste shipments will be tracked, by transporter and manifest or bill of lading, from the site until received by the designated disposal facility. Waste records will be maintained to verify waste acceptance, quantities and compliance with the relevant regulations. 3.8 SITE RESTORATION Site preparation activities will include: • Repair and replacement of existing pavements surfaces with asphalt concrete pavement • Regrading and stabilization of areas of the site impacted by the construction operations W:\ 00496 \0207.017\DRAFt REPORT APPENDIX I.DOC 3 -8 z w 00 co w= J i- 0 LL w i I 0 g W IL ~O ..z w U co z W:\ 00496 \0207.017\DRAFT REPORT APPENDIX I.DOC 3 -9 • Inspection and repair, as necessary, of permanent erosion control and stormwater management measures • Removal of temporary features and demobilization Site restoration activities will be completed in accordance with Specification Section 01500 — Temporary Facilities and Controls. Materials required to complete the work will conform with the Specifications. Specific material requirements are detailed in the Specifications. RCIE will monitor and inspect site restoration activities to verify compliance with the Specifications. N%+icti✓i -W.n . 4 �� +•. � • 1.� •r �4i•J.:'.4.M�i..K6'rr .• . .. 1+. ...wwr:'`Y.::�i...`:Y.S�.a•1�1� �Lfiu]aa. 4.1 GENERAL 4.2 DAILY SUMMARY REPORTS 4.3 MONTHLY PROGRESS REPORTS 4.0 RECORD DOCUMENTATION Documentation will be required to provide a long -term record of construction activities as they were completed in accordance with the work plan. This will include documentation of daily activities as they are occurring, as well as preparation of final record documents. Each of these documentation procedures is further discussed in the following sections. A daily summary report or field construction inspection report (FCIR) will be used to document observations on a daily basis. An example of this report is attached. The FCIR will be used to document daily activities and as a problem tracking tool. An FCIR will be completed each day and reviewed by the RCIE site manager. Unsatisfactory conditions will be noted in the margin of the FCIR in the space provided. The date of reported unsatisfactory conditions will be listed at the top of each day's FCIR in the space provided. When unsatisfactory conditions have been corrected and accepted by the site supervisor, the date and the corrective action will be documented in the FCIR. Once corrected, the unsatisfactory conditions will no longer be listed in following FCIRs. Additional documentation will be filled out on a daily basis associated with health and safety requirements and/or sampling and testing requirements. The status of barrier wall construction activities will be provided to the EPA in a monthly progress report. 4.4 DRAFT AND FINAL REPORTS Within 60 days of project completion, a draft report will be submitted to the EPA documenting that the barrier wall was completed in a manner consistent with the work plan. 4.5 DOCUMENT STORAGE Document storage will include both temporary storage while work is being performed and long- term storage of project documents. Complete copies of design documents will be stored at RCIE • corporate offices, Container Properties, L.L.C. corporate offices, and onsite while activities are being performed. After construction starts, original copies of daily reports will be maintained in an onsite file. These reports will also be mailed or faxed to both RCIE and Container Properties, L.L.C. corporate headquarters weekly. In this manner, records will be maintained at three locations until completion of the project. Upon completion of the project, RCIE will maintain a file containing original documents at its corporate headquarters in Sumner, Washington. W:\ 00496 \0207.017\DRAFr REPORT APPENDIX I.DOC 4 -1 !' 1 The DMP describes the individual record forms that will be used for field data management, sample tracking and management, document control, and inventory. The DMP includes the following key elements: fl • Field Data Management • Sample Tracking and Management • Document Control and Inventory kkood 5.1 GENERAL 5.0 DATA MANAGEMENT Data generated during execution of the interim measure will be managed in accordance with a Data Management Plan (DMP) developed specifically for the work. This DMP has been previously reviewed and accepted by the EPA and is applicable to the proposed work. A complete copy of the DMP is included as Attachment 1 in this document. The objective of the DMP is to ensure that all field observations, field measurements, laboratory results, and quality control (QC) data are managed by consistent and reliable methods. Consistent and reliable methods ensure data of known and acceptable quality that is suitable for future use. The DMP establishes a management information system capable of receiving, validating, sorting, and entering data into project files. It is based upon the U.S. Environmental Protection Agency's (EPA) Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, October, 1988. W: \00496\0207.017\DRAFC REPORT APPENDIX 1.DOC NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Prepared For: Container Properties L.L.C. 1216 140 Avenue Court East Sumner, Washington 98390 DATA MANAGEMENT PLAN HYDRAULIC CONTROL INTERIM MEASURES FORMER RHONE - POULENC, INC. FACILITY 9229 EAST MARGINAL WAY SOUTH TUKWILA, WASHINGTON November 15, 2000 RCI Environmental P.O. Box 1668 Sumner, Washington 98390 253/863 -5300 Project No. 20051 -29942 RT1 AGI Technologies 11811 N.E. 1 Street, Suite 201 Bellevue, Washington 98005 • 425/453 -8383 z i• 6 1-1 JU 0 0: cn W I .. W gQ . N W Z I- O: z � IV i►i U =. O ~ z 1.0 INTRODUCTION 1 1.1 GENERAL 1 1.2 OBJECTIVE 1 1.3 ORGANIZATION 1 2.0 FIELD DATA MANAGEMENT 2 2.1 GENERAL 2 2.2 PROJECT FILE 2 2.3 FIELD CONSTRUCTION INSPECTION REPORT 2 2.4 FIELD INSPECTION DAILY REPORT 3 2.5 WELL DRILLING AND INSTALLATION LOG 3 2.6 DATALOGGER ASSIGNMENT FORM 3 2.7 WATER LEVEL MEASUREMENTS RECORD 3 2.8 SURVEY DATA REPORT 3 3.0 DOCUMENT CONTROL 4 3.1 GENERAL 4 3.2 DOCUMENT FILING 4 3.2.1 Field Monitoring and Testing Documents 4 3.2.2 Health And Safety Program Documents 5 3.3 EXISTING DOCUMENTS 5 3.4 COMPUTER FILES 5 .s „,``, + ..`i.i +r ,..:,.a.'t.;'$ L. w ...:"�..,�...).:,,r".'M::.'ik�, L•:1'!': _Lyb:�. 4 .... Wit:__ .;,•sr sl ∎∎01 1kr1 ;C: tili.: a..ti.s tea' ei.w'+'.a..'..^.GU t• -. �^ z i1 Z . Ce w JU U W W w w LL 1 0 zI LU UCa • ( L ) : w uj. U. F..; w z o 1 z 2.1 GENERAL 2.0 FIELD DATA MANAGEMENT z This section identifies the field data management records that will be utilized during project = z activities. 3, '� 6 J 0 2.2 PROJECT FILE 0 0 u) The RCI Environmental (RCIE) Project Manager or a representative will keep a project file. The J H : file will contain a detailed summary of all monitoring and sampling activities, including, but not w 0 limited to, the following: 2 • Name and title of author, date and time of entry, and physical/ environmental u. a conditions during field activity. co Cl 1 ...w • Purpose of monitoring or sampling activity. o zE- • Location of monitoring or sampling activity. 2 D D • Name(s) and title(s) of field personnel. 0 • Monitoring or sample collection method. i 0 • Number and volume of sample(s) taken. u.i z • Date and time of collection. P. I z • Sample identification number(s). • Sample distribution (e.g., laboratory). • Field observations. • Field sampling records (as completed). • Summary of daily tasks and documentation of any corrective actions requested or undertaken. The following sections describe individual field records, reports, and logs; examples of these documents are attached. 2.3 FIELD CONSTRUCTION INSPECTION REPORT Field Construction Inspection Reports will be prepared by a field engineer and added to the project file. These reports are a record of construction activities and observations while on site. - A1-2 - 2.4 FIELD INSPECTION DAILY REPORT Field Inspection Daily Reports will be prepared by field team leaders and added to the project fire. These reports are a record of the field team's activities and observations while on site. 2.5 WELL DRILLING AND INSTALLATION LOG The Well Drilling and Installation Log will be used to record soil sampling equipment and methods, soil types and depth to groundwater encountered during piezometer installation. The log also documents drilling start and completion times, piezometer construction materials and methods, surface conditions, soil sample and groundwater depths, and other data. This log will be used for all piezometers. 2.6 DATALOGGER ASSIGNMENT FORM The Datalogger Assignment Form identifies water level measurements and reference point elevations, and documents site conditions, measurement devices, time points, and comments and observations associated with the placement of pressure transducers and data loggers for the collection of groundwater levels. 2.7 WATER LEVEL MEASUREMENTS RECORD The Water Level Measurements Record identifies water level measurements and reference point elevations, and also documents site conditions, measurement devices, time points, and comments and observations. Water level elevations will be calculated based on the documented information and entered on the record. - A1-3 - _ 2.8 SURVEY DATA REPORT Piezometer, monitoring wells, and stilling well locations and elevations will be surveyed by a qualified surveyor. The location, identification, coordinates, and elevations of the piezometers /wells and their monuments will be plotted on suitable maps to show their locations with reference to important surface features within the site. A tabulated list of the piezometers /wells and monuments, including their coordinates and elevations and all computation sheets will be kept in the project file. The tabulation will consist of the designated number of the piezometer /well, the State Plane coordinates, and all required elevations. IION :.M 3.1 GENERAL 3.0 DOCUMENT CONTROL Two methods will be used during the project to protect data from intentional or accidental destruction or damage. First, all written records, reports, and other project documents will be stored in a project file. Second, selected technical and project management data will be stored in computer files. Each of the methods is described below. 3.2 DOCUMENT FILING Originals of all documents received and generated during the project will be placed in the project file. This file will be under the control of the RCIE Project Manager or a representative. To the extent practical, original documents will not be removed from the file for purposes other than photocopying. The project file will include both field monitoring and sampling, and health and safety program documents. 3.2.1 Field Monitoring and Testing Documents Field monitoring and testing documents will be received in various formats. They will be organized by activity placed into the project file. The following steps will be taken to maintain document control: • Document packages will be checked for discrepancies and legibility. Any problems, such as missing or illegible information or discrepancies, will be identified and resolved with the RCIE Project Manager or a representative as soon as possible. • Selected monitoring documents and performance records will be photocopied. The original document package will be placed in the project files. Photocopied packages will be stored on -site. The most important aspects of data management in these steps are: • To provide records of traceability, adherence to prescribed protocols, nonconformity events, corrective actions, and inherent data deficiencies. • To ensure records cannot be tampered with, lost, or damaged. • To maintain timing and scheduling requirements with field work and data turnaround. • To provide guidance on formulating corrective measures. - A1-4 - 3.2.2 Health And Safety Program Documents Health and safety program documents of particular importance during performance of this work are described in the project Health and Safety Plan (HASP) and include: • Personnel Training Document • Respirator Fit Testing Document • Proof of Medical Monitoring Clearance • Site Visitors' Log • HASP Review and Emergency Data • Accident /Incident Report • Site Safety Officer's Daily Log • Equipment Calibration Log • Air Quality Monitoring Log • Daily Safety Meeting Report 1 1 A copy of the site HASP, Personnel Training Document, Respirator Fit Testing Document, and Proof of Medical Monitoring Clearance will be maintained on -site and in the project file. All original reports and logs generated during field activities will be photocopied and a copy will be placed on -site. 3.3 EXISTING DOCUMENTS Reports of previous investigations are part of the project file and their results are cited during the preparation of new project documents. Previous reports generally contain information on site description, history, and environmental setting. Site description includes location, size, ownership, and physiographic setting. History includes operating practices, waste disposal practices, previous sampling events, legal actions, regulatory violations, and changes in ownership. Environmental setting includes geology, pedology, hydrogeology, hydrology, and meteorology. 3.4 COMPUTER FILES Computer files will be used to store groundwater level monitoring data. The files described below are preliminary and subject to change and expansion as the project progresses. The groundwater level data will be stored as Microsoft EXCEL files Additional data management needs will be met by using other data analysis software. All files will be periodically backed up on floppy diskettes. A hard copy of all computerized data will be maintained at all times. Groundwater level monitoring data will be submitted to EPA on a floppy disk. Computer files resident on this disk will be in a data table format generated using Microsoft EXCEL. - A1-5 - • �x5• w.� . . w. .x Na ;NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Project I Report No. Location Job No. Day /Date Time on Site From To From To Reviewed By Prepared By Weather Conditions Equipment in Use UNSATISFACTORY CONDITIONS PREVIOUSLY REPORTED (Give report date only. Circle dates of items corrected this report and explain below.) . • 0 t; O O C D o O Si E 0 0 Z 3 m t (n m a. v m m p• o U • 1 r I Visitors Q Continued see next page Attachments Initial Distribution - AGI TECHNOLOGIES C......... i nto " Y:;+. i. it e:'! nb' x. w .ri+ialR'�tit%+�+•_*.'+"fiu'f�`;. ifa FIELD CONSTRUCTION INSPECTION REPORT Sheet of O:IFORM W ORKIFIELD \FCIR.p65 COMPLETED BY PROGRAMMER . COMPLETED BY INSTALLER COMPLETED UPON REMOVAL Data Dumped By p y • Channel TRANDUCERS Stilling Well Piezo/ ID Measuring Point Transducer Depth Water Level ** Date Time Water Level ** Date Time Make S/N Reading PSI Units • WOS - • • DD - Drawdown • DTW - Water Over Depth to Sensor Water Equipment Installed By: Equipment Installed on (date /time): ** Independently Measured by Sounder - Removed By Removed On (date /time): DATALOC :R ASSIGNMENT FORM COMPLETED BY PROGRAMMER Datalogger Make & Model: Datalogger Serial No: Data Programmed: Name of Programmer: Program Loaded: Main Battery Voltage: Backup Battery Voltage: Logging Interval: Monitoring Interval: Memory Will Be Full After: ❑ Logging Initiated in Office by Programmer ❑ Logging Initiated in Field by: Logging Initiated (data /time): Project Description: Monitoring Location: NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. .sign DATA RETRIEVAL REMARKS Data Dumped By p y Date/Time File Name(s) Loggia Resumed (da eltime) DATALOC :R ASSIGNMENT FORM COMPLETED BY PROGRAMMER Datalogger Make & Model: Datalogger Serial No: Data Programmed: Name of Programmer: Program Loaded: Main Battery Voltage: Backup Battery Voltage: Logging Interval: Monitoring Interval: Memory Will Be Full After: ❑ Logging Initiated in Office by Programmer ❑ Logging Initiated in Field by: Logging Initiated (data /time): Project Description: Monitoring Location: NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. .sign AGI TECHNOLOGIES FIELD INVESTIGATION DAILY REPORT Sheet of Project Job No. Location Date Equipment Rental Company To Equipment Hours F.E. Time from: to: By EXAMPLE Visitors: Attachments ❑ Continued Distribution Initial fld.01/09.94 . 'r" • ". .., ,. ' i"a'R F ev" °j"" f rr �8 "" '"' ` <YwP,. r .r ksa ^u � arra* t. a nuns aua,sxvc�. ,.!t:":. Harz,^:.".•, y -;a;?'+%tw'.n;', ":<3;w;+'iliei. ' tM giJ tmr.`,!3.,..zz 'f.,-4P.Yw...1`.?'1' LOCATION SKETCH • Surface Elevation: AGI WELL NO. TECHNOLOGIES Total Depth WELL DRILLING AND INSTALLATION LOG Sheet of Project: Start Drilling: Time: Date: Project Manager: _ Job No.: Complete Drilling: Time: Date: Logged By: Edited By: Start installation: Time: Date: Drilling Contractor: Driller's Name: Complete Installation: Time: . Date: Sampling Methods: Date Time Depth to Water Completion Designation Elevation D atum : Drill RI T e• 9 yP Well Installation Notes Details of Well Construction Depth In Feet Casing Type and Dia.: Hammer Weight: Drop: Surface Conditions: ' 11 IT TT II II It +1 0 1 2 3 4 5 6 7 8 9 r USCS Soil Description Sample Sample Stows 0.6 Fool Driven - Fool end c�ond lion — — — _ — • EXAMPLE . - ' - - _ rte% NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Well Installation Notes Details of Well Construction Depth in Feet uscs Soil Description Eta . Depth 6.mpt. Type Blom Per 0.6 Fos Feel Orton F..i R.cov- ered I 1E= II I I II - _ r - - - '"a - - - 1. AGI TECHNOLOGIES is WELL DRILLING AND INSTALLATION LOG - cont. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. WELL NO. Sheet r i of COMPLETED BY PROGRAMMER Datalogger Make & Model: Main Battery Voltage: Datalogger Serial No: Backup Battery Voltage: Data Programmed: Logging Interval: Name of Programmer: Monitoring Interval: Program Loaded: Memory Will Be Full After: DATA RETRIEVAL REMARKS Data Dumped By Date/Time File Name (date/time) Loggin Resumed a 12006 V29942/Datalo00er Assgnment v am DATALOt =R ASSIGNMENT FORM Monitoring Location: ❑ Logging Initiated in Office by Programmer ❑ Logging Initiated in Field by: Logging Initiated (data /time): Channel COMPLETED BY PROGRAMMER TRANDUCERS Make S/N Reading PSI Units • WOS - Water Over Sensor • DD - Drawdown • DTW - Depth to Water Transducer Depth Stilling Well Piezo/ ID COMPLETED BY INSTALLER Measuring Point EXAM PLE Water Level ** Date Time Equipment Installed By: Equipment Installed on (date /time): ** Independently Measured by Sounder Water Level ** Date Removed By Removed On (date /time): Time COMPLETED UPON REMOVAL r� NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. AGI TECHNOLOGIES WATER LEVEL MEASUREMENTS Project Job No. Weather Conditions Date Site Conditions Measured By Measurement Device Calculations By Elevation Datum Well Time Depth to Water Reference EXA Reference Elevation Water Elevation Comments • Additional Comments fiektx/9-94 v.: -: .,, " 7 ., . -,'.f i,::• ..., :..,.... . •1,•-... J: fi2., - I_,.;•.;.. , 7. ;:-.. ..- 1 , ',. 7, -, '.• 7. ' • l.,4:7:1.-AratVA.-.:......--r.v . 'f. ' , ' . - - t:'. - ' - ' it . -'. i'. ' ;‘ , ;t - l ' illT ' ' tr: j . . ... ..-.-.7,-. p:1:..;;;Vnr.A.,-,?;.%.,1/47,-....1...,:tt, ,i --t • -:,•;- 7.:•,p, .,...,..,' 4.- , .. r * , ; : ' ' '.'- , F 5 i 'c.., 4 ' %,-7 '-.' '•`. ' ' ! '3 ' i : - f-. 1 :6 - ..• ..1•4;':•-'. ' " c' •Y` — it:. ..,-,:.•;,‘.... " .F.c -i.;:t.r•-"-s. .4:,..? ,--,: '';ie i -; :ia:;":4; ; t7 . :4P.. —5X' 4 :{ ''' :: '...44' Ei4 ' • s,..-,. ''',4'''''';2F(V■i1-4";', - et.e ...t. t.,, ' 4 c , -;ft. • ::: - 4`. 17.4,.. : ..-,kk:,..,•.. ,,,;:: , )....t...,:, -.'A".• -e. - R• - 0' .. o•c/ ••-. V:.:• -.es -../.•,... 4.0 4, , . „,.0-t:„.t.,V, -,.%), : • F,:ff=. .J ;!:,;,,,, .1 j . • 4f NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. { J J PERFORMANCE MONITORING PLAN Prepared for Container Properties, L.L.C. Former Rhone Poulenc Site June 2002 URS 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 (206) 438 -2700 53- 01000496.00 01000 RCI ENVIRONMENTAL INC. ENVIRONMENTAL CONTRACTORS & ENGINEERS `- t 1 .1- June 11, 2002 VIA HAND DELIVERY Ms. Christy Brown Project Coordinator US Environmental Protection Agency Region 10 (WCM -121) 1200 Sixth Avenue Seattle, WA 98101 Re: Draft Performance Monitoring Plan — Hydraulic Control Interim Measures Administrative Order on Consent for Corrective Action ( "Order') Docket Number 1091- 11- 20- 3008(h) Former Rhone-Poulenc East Marginal Way Facility Container Properties L.L.C./Rhodia. Inc. Dear Ms. Brown: On behalf of Container Properties L.L.C., and in accordance with your May 2, 2002 Interim Measures Approval with Modifications letter, attached herewith are four complete copies of the draft Performance Monitoring Plan associated with the forthcoming Hydraulic Control Interim Measures. This plan was prepared in accordance with your May 2, 2002 conditional approval letter and informal technical discussions held on May 8 and May 30, 2002. Should you have any questions, please don't hesitate to contact me at (253) 863 -5300. Pete Wold . Project Coordinator cc: Hank Landau Gary Dupuy Rod Brown, Esq. Donald J. Verfurth, Esq. Jennifer G. McDonald, Esq. Paul Linskey Byung Meang P.O. Box 1668 Sumner, WA 98390 Sumner Tel 253.863.5300 Kent Tel 253.852.4254 Fax 253.859.5702 Contractors Lio. 2 IENI'0959NK An Equal Opportunity Employer t. DRAFT PERFORMANCE MONITORING PLAN FOR CONTAINER PROPERTIES, L.L.C. FORMER RHONE POULENC SITE Prepared by URS Corporation 1501 4th Avenue, Suite 1400 Seattle, Washington 98101 -1616 Project Number: 53- 01000496.00 00010 June 12, 2002 Z SH w U0 co 0 • W = J �. W 0.. LL Q, = W Z �. F-0. •z I -. w wi U c) ` 0 cn; W w. U 0_ ltl Z' 0 ! O . • On behalf of Container Properties, L.L.C., I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to evaluate the information submitted. I certify that the information contained in or accompanying this Performance Monitoring Plan is true, accurate, and complete. As to those portions of the plan for which I cannot personally verify accuracy, I certify under penalty of law that this plan and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who may manage the system, or those directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. By: Mr. Pete Wold, Project Coordinator Date: v— I -0 -2_ 1.0 INTRODUCTION 2.0 MONITORING PLAN OBJECTIVE 3.0 WELL INSTALLATION AND PRE - CONSTRUCTION MONITORING 3.1 BARRIER WALL MONITORING NETWORK 3.2 PRE - CONSTRUCTION MONITORING 3.3 PRE - CONSTRUCTION MONITORING SCHEDULE 4.0 PERFORMANCE MONITORING 4.1 PERFORMANCE MONITORING — WATER LEVEL MEASUREMENT 4.1.1 Pre - Operational Water Level Monitoring 4.1.2 Operational Water Level Monitoring 7 4.2 PERFORMANCE MONITORING — WATER QUALITY MONITORING 8 4.2.1 General Parameters 8 4.2.2 Chemical Analyses 8 4.3 PERFORMANCE MONITORING SCHEDULE 10 5.0 WELL ABANDONMENT 10 6.0 QUALITY ASSURANCE/QUALITY CONTROL 10 7.0 REPORTING 11 TABLES Table 3 -1 FIGURES Figure 3 -1 Figure 3 -2 Figure 4 -1 Figure 4 -2 APPENDICES TABLE OF CONTENTS Proposed Pre - Construction Groundwater Monitoring and Performance Monitoring Programs At Former Rhone Poulenc Site Proposed Barrier Wall Monitoring Network Proposed Pre - construction Water Quality Monitoring Locations Performance Monitoring Water Level Measurements • Performance Monitoring Quarterly and Annual Chemical Analyses Appendix A Tidal Comparison Data Tables and Charts Page 1 1 2 2 3 5 5 6 6 1.0 INTRODUCTION The U.S. EPA has completed its review of the Hydraulic Control Revised Interim Measures Work Plan (1M Work Plan) submitted by Container Properties on November 15, 2000, for the former Rhone - Poulenc facility (the Site) located on Marginal Way in Tukwila, Washington. EPA has informed Container Properties that in accordance with paragraph 7.1 of the Administrative Order on Consent for Corrective Action (Order), it intends to conditionally approve the IM Work Plan with modifications. The conditional approval was issued by EPA on May 2, 2002 and received on May 13, 2002. The key components of the planned hydraulic control measures include installation of a low - permeability subsurface barrier wall surrounding the contaminated area and installation of a groundwater recovery system to maintain an inward hydraulic gradient. The conditional approval also requires that an approved performance monitoring plan be implemented with the approved interim measure. The performance monitoring program requirements specified in the conditional approval include: • Immediate detection of a failure or release from the barrier wall. • Verification of whether the interim measure is performing as required. • Monitoring the rate of migration of contaminants remaining in the river bank and critical habitat outside the barrier wall. This document presents the performance monitoring plan for the barrier wall interim measure. Details concerning the goals and objectives of the monitoring plan are described in Section 2.0. Informal technical meetings were held with EPA staff on May 8 and May 30, 2002 to clarify the expectations for the performance monitoring plan and identify potential issues with the proposed performance monitoring plan. This plan is based on discussions at those meetings. 2.0 MONITORING PLAN OBJECTIVE The objective of this monitoring plan is to respond to the three requirements identified by the EPA as stated above. Additionally the objective is to present a robust monitoring plan for both pre- and post- construction monitoring, also as noted in EPA's May 2, 2002 Conditional Approval letter. Section 3.0 describes the pre- construction monitoring program, and Section 4.0 presents the performance monitoring plan that will be implemented upon completion of interim action construction. Section 5.0 discusses the general approach to well abandonment that will be implemented after performance monitoring commences. The performance monitoring quality assurance /quality control plan is referenced in Section 6.0. Section 7.0 summarizes the reports that will be submitted as part of performance monitoring. 1 3.0 WELL INSTALLATION AND PRE- CONSTRUCTION MONITORING The pre - construction period is defined as the time period between the approval of the performance monitoring plan and construction of the barrier wall. The objective of pre - construction monitoring is to establish baseline chemical conditions along the west and south sides of the proposed barrier wall path. In order to establish the baseline conditions, new groundwater monitoring wells will be installed outside the proposed barrier wall alignment. Once installed, it will be necessary to sample these wells to provide baseline chemical conditions prior to installation of the wall. These baseline concentrations will provide a basis for comparison to chemical changes observed in these same wells after the wall is constructed. The pre- construction phase includes: • Installation of new monitoring wells outside the proposed barrier wall path. • Monitoring the new and the existing wells that are part of the barrier wall network for general parameters (indicators of water quality, including pH, temperature and electrical conductivity). • Monitoring new wells for baseline water quality (BTEX, dissolved metals, and general parameters) prior to construction of the wall. • Monitoring six selected wells in the southwestern corner for major cations and anions. • Monitoring selected wells inside the barrier wall path for BTEX, dissolved metals, and general parameters. The pre - construction monitoring schedule is presented in Section 3.3 3.1 Barrier Wall Monitoring Network Figure 3 -1 shows the location of the proposed wells to be installed at the facility. The wells will be installed as a series of well pairs inside and outside of the barrier wall at approximately 300 to 400 -foot spacing. Existing wells will be adopted or used as either interior or exterior wells, depending on the exact location of the barrier. Each well pair will consist of a shallower well screened between 10 and 25 feet below ground surface (bgs) (approximate screen elevation of 6 to -9 feet mean sea level [msl]) to evaluate groundwater conditions in the upper portion of the aquifer, and a deeper well screened between 35 to 45 feet bgs (approximate screen elevation -19 to —29 feet msl) to evaluate groundwater conditions in the lower portion of the aquifer. Only shallower wells will be placed along the northern and eastern sides of the barrier since no significant contaminants have been identified in these areas. If it is necessary to locate wells higher than the typical site elevation (i.e. on the berm), the depths of the wells will be adjusted accordingly to ensure the screens are placed at the target elevation. Approximately 25 wells will be installed (or adopted where possible) as wells that will specifically monitor the performance of the wall. These wells are referred to as the barrier well 2 �: fs:( �; �; ryY� :•:...'atx.- tW::�,.rl..:�wk�.. .�.,.'ve�rw,.�'e x,ro++. °+i:.:v:,� network. The proposed well locations were selected based on reviewing the concentration patterns of dissolved metals (principally copper, arsenic and mercury) and the distribution of elevated pH readings as noted in the direct -push investigations performed at the site. The wells are proposed based on these distributions, and the spacings between the well pairs meet the z recommendations of the EPA guidance document regarding sub - surface engineered barriers F z (EPA, August 1998). This document recommends a minimum spacing between wells of cc w 400 feet, with wells located within 30 feet of the barrier wall. 6 v 00 The proposed well depth intervals are based on the monitoring intervals currently used on -site, 0 vi w with wells in the Upper Aquifer divided into a shallow zone (called the Upper zone) and deeper J 1 zone (the Intermediate/Lower zone). The Upper zone has slightly higher permeability sediments co IL o than those present in the deeper Intermediate/Lower zone. These two depth intervals were W selected to ensure consistency with historic groundwater monitoring practices at the site. Monitoring water levels at the two depth intervals will allow for rapid identification of potential u_ leakage through the barrier wall, and will provide some indication of vertical groundwater flow = (75 through the aquitard layer. Z I The exterior network wells next to the west and south barrier wall alignment will be installed w O tu prior to construction of the wall to permit collection of baseline samples (See Section 3.2 for ? o details). The tracked heavy equipment used to build the wall needs a minimum clearance of v 0 20 feet from the wall center for existing and new monitoring wells. All wells that will be 0 CI - installed or adopted into the program must have subgrade completions and be clearly marked in i w order to not be disrupted during construction. Figure 3 -1 shows which network wells will be I— i"- constructed prior to installation of the wall. Any network wells which are not installed prior to L 0 z construction will be installed as soon as wall construction has been completed. i to o P _ O ~ z 3.2 Pre - Construction Monitoring Table 3 -1 lists the different water quality monitoring programs that will be conducted at the site, including pre - construction water quality monitoring. During the pre - construction period it is proposed that the current groundwater monitoring program be replaced with the monitoring program proposed in this plan. Figure 3 -2 shows the well locations included in the proposed program and their sampling frequency. The proposed pre - construction chemical monitoring program will consist of: • The newly installed wells in the barrier wall network west and south of the barrier wall along the shoreline, will be sampled quarterly for benzene, toluene, xylenes, and ethyl benzene (BTEX), dissolved metals (consisting of arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, thallium, vanadium, and zinc) in addition to general parameters (temperature, pH, electrical conductivity, dissolved oxygen, oxidation - reduction potential). The existing exterior wells that are adopted into the barrier wall network south and west of the wall will be sampled quarterly for the same parameters as the new wells. • Groundwater samples from the six exterior barrier network wells near the southwestern corner of the barrier wall alignment (from existing DM -8 to wells adjacent to H -9) will be 3 collected once only, during the first quarterly monitoring event. These samples will be analyzed for major cations and anions, as requested by EPA. • Groundwater monitoring within the barrier wall path will be substantially reduced in number of wells and sampling frequency compared to the current program. Nine wells will be sampled annually for BTEX, dissolved metals (a reduced analytical suite of arsenic, chromium, copper, lead, mercury, nickel, vanadium, and zinc). • Samples will be collected from the pre - construction monitoring wells without regard of the tidal stage because existing sampling data suggests that there is no consistent pattern that would favor one tide or another for all analytes present in a given well. The following paragraphs discuss the rationale for each of these bullets. The rationale for only sampling the wells south and west of the barrier wall is that these wells will monitor changes associated with the barrier wall that may affect the distribution of constituents of concern that will remain in the aquifer outside the barrier. The newly installed wells will not have been sampled for the full set of analytes as in the case of the existing wells, collecting samples on a quarterly basis will provide baseline data for comparison. Quarterly chemical sampling of the new wells on the north and east sides of the wall is not proposed since the groundwater beyond the wall is either not affected by site - related constituents of concern, or that changes in chemistry could be attributed to off -site sources. During the first quarterly sampling event, samples will be collected for analysis for major cations and anions. The analytical results will be plotted on ternary diagrams to help in identifying changes in groundwater chemistry. EPA requested that these samples be collected to help track these changes once the wall has been installed. The southwestern exterior of the wall has substantial concentrations of constituents of concern, so changes in the groundwater chemistry would have the largest potential impact in this area. The six wells in this area will be sampled for major cations and anions. The analytes proposed for the quarterly sampling are those analytes which pose the greatest threat through possible migration from the site and that are considered indicator parameters for the site as a whole. Sampling for VOCs will be limited to BTEX since toluene and benzene have been repeatedly and widely detected during the past 15 rounds of groundwater sampling. The metals suite is the same as that used during the latest Round 15 groundwater sampling event. Monitoring of wells within the interior of the barrier wall area will be reduced from the current 33 wells to 9 wells. These wells will be sampled annually. Fifteen rounds of groundwater sampling have been performed on -site since January 1994. Enough data has been collected from these wells to characterize the site, and collecting additional samples has little additional value, since the wall is scheduled to be installed as soon as possible. Most of the wells dropped from the sampling schedule are located within the wall area, or are located upgradient of the proposed wall. Additional monitoring data from these wells will not affect the placement of the wall so dropping them from the sampling schedule will have minimal impact. The remaining proposed performance monitoring wells will be sampled annually until the wall is constructed. 4 --, For monitoring wells located within the proposed barrier wall alignment, the reduction in the number of metals being reported is justified since cadmium, selenium and thallium have either not been detected, or have been detected sporadically since monitoring commenced. Samples will no longer be collected at different tidal stages. Review of past analytical results for toluene, arsenic, chromium, and copper indicates that no one tidal stage is suitable for all analytes, and results from wells sampled at high and low tides vary independently even for a single analyte like toluene. Tables listing the relative percent differences (RPDs) for these analytes for wells sampled at different tidal stages are included in Appendix A. RPDs show the variability between different sets of samples. RPDs for duplicate samples collected at the same time typically have RPDs of 20% to 30 %. Differences greater than this suggest that the variability between samples might be caused by another factor like the tidal stage. RPDs for samples collected during low and high tides show a wide range in RPDs, with either high tide or low tide showing a higher concentration. However, this variability is not consistent between sampling events, or between analytes. Sampling a well at either high or low tide does not clearly ensure that a given analyte will be higher or lower in concentration than at the opposite tidal stage. Therefore, collecting samples specifically at high or low tide stages is not justified. Data through Round 15 is qualitatively presented in charts for wells sampled during the different tidal stages. Charts showing concentration trends over time from the Round 15 Groundwater Monitoring Report (GeoEngineers, April 2002) are also included in Appendix A. Examination of these curves suggests that while the analytical results differ between tidal stages, the variability is not consistent. Because the differences in concentration during different tidal stages are not consistent or discernable, this variability is not linked to a particular tidal stage. Therefore, collecting samples specifically at high or low tide stages is not justified. 3.3 Pre - Construction Monitoring Schedule The pre - construction monitoring program will commence as soon as the Performance Monitoring Plan receives EPA approval, and will continue until the wall and the groundwater recovery system are installed. Once these systems are installed, the performance monitoring program will replace the pre- construction monitoring program. This section describes the proposed performance monitoring program to be initiated after the barrier wall has been installed and pumping has been initiated. Performance monitoring will focus on determining whether the interim action system is meeting the performance goals and objectives specified in EPA's May 2, 2002 conditional approval. Section 4.1 describes how water level measurements will be recorded and evaluated to determine if the interim action system is providing adequate hydraulic containment. Section 4.2 describes the groundwater quality monitoring that will be used to determine if the wall has controlled the release of COCs, or if mobilization of COCs outside and in the vicinity of the wall has occurred. 4.0 PERFORMANCE MONITORING 5 4.1 Performance Monitoring — Water Level Measurement Water level monitoring will be the primary determinant of whether the wall is meeting the performance goals. The following discussion clarifies how measurement of water levels can Z determine how the wall is performing. -- _ t: ,- w The barrier walls and the aquitard will behave ideally if they minimize the response within the 2 wall to tidal fluctuations. Ideal behavior can also be demonstrated if pumping within the wall v v o causes no noticeable change in water level outside the barrier wall. If the barrier wall is u) o performing to specifications and if the aquitard is relatively homogenous, the ideal behavior of w = water levels inside the wall in response to pumping will be relatively uniform and flat across the - J (- site away from the immediate vicinity of the extraction well(s). This is because the wall will E w o ideally limit horizontal inflow of groundwater in response to the imposed inward hydraulic 2 gradient. If the wall leaks, then the uniform pattern will be altered, and the wells near the leak along the interior of the wall should show higher groundwater elevations than those away from u a the leak. Such mounding could occur in either of the aquifer zones since the wall has the _ potential for leakage along its entire length and depth. This mounding would impart a detectable ? r slope to the water table as water leaks through the wall. z o wW However, even if the barrier wall is performing ideally, the underlying aquitard may leak and the . -t v o tidal signal could be transmitted inside the wall. If the aquitard has a preferential vertical flow 0 D- o path, then apparent groundwater mounding will occur in the deeper (Intermediate/Lower) zone w wells across the site, since the water will be flowing vertically upwards from aquitard in response i v to pumping. During pump operation, water levels will need to be collected from the barrier well u- p network and across the site using existing monitoring wells to diagnose these differing types of w Z behaviors. Relatively little overall change in water levels is expected once groundwater flow v conditions within the wall have reached steady state. Even if the walls or aquitard leak, steady z ~ state control of water levels as needed to attain the appropriate inward gradient can be achieved by pumping larger quantities of groundwater. The magnitude and impact of the leakage will be determined before any decisions are made concerning the need for mitigation efforts. The water level data collected during the pre - operational monitoring phase prior to startup of the extraction system will ensure that the most representative well pair is used to control the operation of the groundwater extraction system. Collection of pre - operational and post - operational water levels is discussed fully in the following subsections. t_ 4.1.1 Pre - Operational Water Level Monitoring During start-up operations, 13 of the exterior barrier network wells and the 12 interior barrier network wells will be monitored for a period of 1 month on a continuous basis using data loggers equipped with pressure transducers. The water level data will be used to confirm that there are no significant failures in the barrier wall, as described above. Figure 4 -1 shows the location of the wells that will be monitored by transducers for pre - operational monitoring. Due to the stated EPA concerns regarding whether the Impermix wall has cured sufficiently, both the 1 -month long water level monitoring program and any groundwater extraction pump tests will be initiated 6 after the continuous water levels have been collected. after the wall has cured for one month. It should be noted that water level monitoring will occur The continuous water level data will be used to select the wells that will control the water level inside the barrier wall. This approach is described in detail in the following section. 4.1.2 Operational Water Level Monitoring An inward hydraulic gradient will be maintained into the containment area by groundwater withdrawal from within the barrier wall. The performance standard for maintaining the inward gradient will be maintaining the mean level of the groundwater within the containment area at a level 1 -foot below the mean groundwater level as measured in monitoring wells outside the barrier. This approach is considered equivalent in protectiveness to maintaining a 1 -foot difference in water level relative to the Duwamish Waterway, as proposed by EPA. This approach will simplify water level monitoring, will improve overall effectiveness of the monitoring system, will be used to automatically control pumping, and will improve safety when compared to direct monitoring at the river level. Differences in water levels between the Upper and Intermediate/Lower zone wells in each well pair will be compared as described in Section 4.1 to monitor for leakage through the wall, or vertical groundwater flow through the aquitard. The proposed barrier wall groundwater water level measurements will be collected to confirm that hydraulic gradient performance criteria are met. The pumping system will be designed to operate using pressure transducers placed within a single well inside the wall and a similarly constructed well located outside the barrier wall. The pump controller will be set to automatically maintain the desired difference between the mean groundwater levels in the selected wells. An appropriate statistical procedure will be used by the automatic control system to determine the mean groundwater level both inside and outside the barrier wall for the same time period. The proposed continuous water level monitoring approach can be easily implemented and maintained, allowing real time acquisition and continuous measurements, whereas it would be difficult to install and maintain an automated data acquisition system using a river gauge. Measuring water level in the aquifer outside the wall takes advantage of the dampening effect in the aquifer and the absence of wakes will make interpretation of results more reliable. Ready access provided by installation in a well will simplify maintenance and improve reliability. Forthe longer term, and until steady state is reached, monthly manual monitoring of water levels in all 25 barrier network wells both inside and outside the barrier wall will be conducted in addition to continuous monitoring of two wells for control purposes. In addition, water levels will be manually measured in nine existing interior monitoring wells during the same event to determine how the water table within the wall responds to pumping. Figure 4 -1 shows the location of the wells that will be monitored manually along with the barrier network wells. Monthly water level monitoring of the wells shown in Figure 4 -1 will be adequate to confirm performance of the barrier wall and groundwater recovery system, and to detect failure with . .a.�n o-w.su .+veMee +.vu.w.a � +'er.'tr� �*, vr+. trna'^!+ t�. 9' ���i" �,' �•!:',{,' �FJ: �+,• i �" +MQ2f�gyyrN2Rr�xaJlFtiKeY7�1'iN .,alie�eur.., 7 i 3Cun3bti'dA: sufficient frequency to provide for mitigation, if appropriate. It will take up to several months to establish steady state conditions within the barrier wall, so monthly monitoring of water levels will be sufficent. Once conditions within the wall have reached steady state, it is proposed that the water level monitoring frequency be changed to quarterly since it is unlikely that the wall or Z aquitard performance will change markedly. ~w 4.2 Performance Monitoring — Water Quality Monitoring w 6 J U Water quality monitoring during the performance monitoring period will consist of measuring v o general parameters and specific chemical analyses to determine if the if the wall has minimized w w the potential for release of COCs through the wall, or identify mobilization of COCs outside and -I IL in the vicinity of the wall. Section 4.2.1 describes the general parameter monitoring program, w o and Section 4.2.2 describes the chemical analyses that will be used to monitor the wall 2 performance. Table 3 -1 lists the details of the proposed water quality monitoring program. g Q co 4.2.1 General Parameters I w Z The conditional approval includes requirements for monitoring water quality as part of w O performance monitoring. The objective of water quality monitoring is to assess changes in g w groundwater chemistry outside the wall and to determine if COCs are passing through the barrier v a wall. The conditional approval prepared by EPA includes monthly groundwater quality D o!– monitoring until it is demonstrated that no adverse effects have occurred on groundwater w w downgradient from the barrier wall. It is proposed that monthly general water quality parameter F (pH, oxidation/reduction potential, dissolved oxygen, specific conductance, and temperature) - o measurements be performed after installation of the barrier. These general parameters are di indicative of changes in geochemistry. Specifically a significant change in pH or ORP could s indicate the potential for affecting either metals migration or metals adsorption. Groundwater z flow through the wall will be very slow, so the monthly general parameter monitoring will be more than sufficient to monitor geochemical changes in the aquifer. The general parameter sampling frequency will begin as monthly, and may decrease in frequency to quarterly sampling if changes outside the wall indicate steady state conditions have been reached. General parameter sampling will be performed on the barrier network exterior wells (those wells located to the west and south of the barrier wall). This will provide water quality data for deep and shallow groundwater, and will occur with a frequency sufficient to allow timely mitigation, if warranted. Diurnal tidal fluctuations and the presence of a low permeability barrier will limit the rate of geochemical change in the aquifer west and south of the wall. This anticipated rate of change should be slow enough so that monthly monitoring is sufficient to allow for timely mitigation of off -site changes in water chemistry, if required. 4.2.2 Chemical Analyses It is proposed that chemical analyses for BTEX and dissolved metals be collected quarterly in the barrier wall network well pairs that are west and south of the wall, and annually in a reduced number of monitoring wells on the inside of the barrier wall. Figure 4 -2 shows the location of wells that will be included in the chemical monitoring program. 8 C-r Only the exterior well pairs west and south of the wall should be monitored for water quality since: • Affected groundwater will remain west and south of the wall after installation. z • The wall will alter existing groundwater flow patterns, but only the changes in groundwater ;IL. w flow west and south of the wall will have the potential to result in significant releases from 6 the site. v p co o • Monitoring for BTEX, metals and general parameters in the wells north and east of the wall w is not proposed since the groundwater beyond the wall in these areas is either not affected by cn u_ site - related constituents of concern, or observed changes in chemistry could be attributed to w off -site sources. U_ Chemical monitoring will be conducted quarterly for barrier wall network wells (annually for a selected interior wells) until it is shown that steady state conditions have been established outside F the wall. Once steady state conditions have been achieved the monitoring frequency will be Z decreased. The annual monitoring report will evaluate the need for either more frequent w O monitoring or reduction in monitoring frequency. The analytes that will be monitored outside the wall will remain the same as those specified during the preconstruction monitoring program: v O N O H • BTEX will analyzed as the representative VOCs in the groundwater samples; w w • Samples will be analyzed for dissolved metals including arsenic, cadmium, chromium, o copper, lead, mercury, nickel, selenium, thallium, vanadium, and zinc. U = • Groundwater samples will be collected from the six exterior barrier network wells along the O~ southwestern border of the wall (from DM -8 wells adjacent to H -9) for analysis of major cations and anions. These samples would be collected during the first and third groundwater sampling events after the start of performance monitoring. The rationale for selecting these analytes is the same as that cited for the pre - construction monitoring program; these VOCs have been shown to be present during past groundwater sampling and this suite of metals has been extensively monitored on -site prior to wall construction. Reduction in the number of analytes in the future should be considered if justified by the analytical results. The rationale for sampling a limited number of wells inside the barrier wall on an annual basis is justified because the chemical conditions inside the wall will change slowly, and the significance of any changes is limited because all of these wells will be hydraulically isolated within the barrier wall. After pumping commences and the wall is performing to specifications, changes in water quality inside the wall will have limited importance as long as the extracted groundwater meets Metro discharge criteria. Therefore, the number of wells sampled for chemical analyses and the frequency of sampling will be significantly reduced compared to the pre- construction monitoring program. 9 : Seven interior monitoring wells will be sampled annually, and the samples will be analyzed for BTEX and the limited metals suite (arsenic, chromium, copper, lead, mercury, nickel, vanadium, and zinc) The reduction in the number of metals being reported is justified since cadmium, selenium and thallium have either not been detected, or have been detected sporadically since monitoring commenced. '~ w The six exterior wells sampled for major cations and anions will be the same as those sampled 2 previously for the same analyses during pre- construction monitoring. These samples will be J o collected during the first and third quarterly groundwater sampling events. These results will o o help show changes in groundwater chemistry after the wall has been installed. The data will be w w plotted on ternary diagrams to show how water chemistry has changed after wall installation. - 'r O 4.3 Performance Monitoring Schedule 2 Performance monitoring for water levels will commence as soon as the wall is installed. The co a ' groundwater extraction system operation, and operational performance monitoring for water = w cr levels, BTEX, dissolved metals and general parameters will start approximately two months after z the initial water levels have been recorded, interpreted, and the control wells selected. z o w 5.0 WELL ABANDONMENT a E o U w Once the wall is complete many existing monitoring wells inside the barrier wall will be o E- abandoned since there is little justification for maintaining such a large network of wells and the = v wells could interfere with site operations and could lead to additional contamination. After the O performance of the barrier wall has been established and steady state conditions have been z reached, Container Properties will prepare, for EPA's review, a list of wells that will be v c abandoned following Ecology monitoring well abandonment guidelines. r r:." 6.0 QUALITY ASSURANCE /QUALITY CONTROL All groundwater samples and water levels collected during the pre - construction and performance monitoring programs will be collected and analyzed in accordance with: • Groundwater Monitoring Plan, Former Rhone - Polenc Inc. Facility, 9229 East Marginal Way South, Tukwila, Washington (AGI, August 29, 1999). • Appendix F, Data Management Plan, Hydraulic Control Interim Measures Former Rhone - Polenc, Inc. Facility, 9229 East Marginal Way South, Tukwila, Washington (AGI, November 15, 2000). • Appendix G, Data Collection and Quality Assurance Plan, Hydraulic Control Interim Measures Former Rhone - Polenc, Inc. Facility, 9229 East Marginal Way South, Tukwila, Washington (AGI, November 15, 2000). 10 z • • u,. 7.0 REPORTING Reporting during the pre - construction monitoring period will consist of: • Quarterly data reports will be issued following each of the first four quarterly sampling events. The data reports will be a memo transmitting data tables and trend charts for the COCs for each of the wells monitored. Minimal interpretation will be included in the data reports. • After completion of construction a pre - construction monitoring report will be submitted summarizing the data from the quarterly sampling events as well as the annual sampling event. The report will include data tables, trend charts, groundwater elevation contour maps, isoconcentration diagrams, and complete data listings for the previous year. A single pre - construction report will be issued, and any additional data will be included in the first performance monitoring annual report. After the performance monitoring period begins, reporting will consist of: • A technical report summarizing the results of the month -long initial water level monitoring program, including water level trend graphs for each well, and representative water level elevation contour map for the low low -tide, mean water level, and high high -tide. A compact disk containing Excel tables of the continuous water level data will also be submitted. The technical report will also include interpretation of the water level results as an indication of how the wall and aquitard are performing, and recommendations as to which wells will be used to control groundwater extraction within the barrier. • Monthly data reports listing tabulated water level data for that month for all wells manually measured, and water level trend charts for each of the control wells. These reports will also include data tables, trend charts, for the general parameters that were measured during each months sampling event. • Quarterly groundwater monitoring reports will be prepared after each sampling event, and will include the relevant monthly reports as an appendix. The quarterly reports will present data tables, trend charts, groundwater elevation contour maps, isoconcentration diagrams, and complete data listings for that quarter. • An annual performance report will be prepared each year summarizing the previous year's data, and will include data tables, trend charts, groundwater elevation contour maps, isoconcentration diagrams, and complete data listings for the previous year. When steady state is reached and the frequency of sampling decreases, only an annual performance report will be prepared. 11 Program Wells Included Sampling Frequency Analytes Comments Pre - construction All newly installed wells west and south of the proposed barrier wall path (western and southern sides) Quarterly BTEX, Dissolved Metals Suite A, General Parameters Baseline water quality monitoring for new wells. Any existing exterior wells west and south of the wall that are adopted into the barrier wall network. Quarterly BTEX, Dissolved Metals Suite A, General Parameters Monitoring for wells with existing historical chemical data in conjunction with baseline monitoring of the new exterior wells west and south of the wall. Six exterior network wells in southwestern corner (DM -8 to H -9) Once Major cations and anions Baseline monitoring for general chemistry as requested by EPA Selected monitoring wells inside the barrier wall path Annual BTEX, Dissolved Metals Suite B, General Parameters. Reduction in number of wells monitored and in sampling frequency from current program justified by proposed installation of barrier wall in the next year. Performance Monitoring (immediately after wall construction, prior to start of GW pumping) Barrier wall performance monitoring well network (25 wells) Continuous Water Levels Water levels will be monitored for a one month period within two months of barrier wall construction. Performance Monitoring Barrier wall network wells and selected interior wells Monthly Water Levels Water levels outside and inside the wall will be monitored and recorded manually!" After steady state conditions are attained, water levels will be monitored quarterly. Barrier wall network exterior wells west and south of the wall Monthly General Parameters Monthly monitoring continues until steady - state conditions are established. Quarterly BTEX, Metals Suite A Quarterly sampling of wells west and south of the barrier wall will continue until steady state conditions are established. Six exterior network wells in southwestern corner (DM -8 to H -9) Twice Major cations and anions Monitoring for changes in overall water chemistry after wall is installed. Samples will be collected during the first and third quarterly sampling events. Selected interior wells (2) Annually BTEX, Metals Suite B, General Parameters Selected wells in Upper and Intermediate/Lower Zones will be sampled yearly for changes in water chemistry related to operation of the interim measure. Notes: BTEX = benzene, toluene, xylenes, and ethyl benzene analyzed using EPA 8021 Dissolved Metals Suite A = As, Cd, Cr, Cu, Pb, Hg, Ni, Se, Tl, V, Zn Dissolved Metals Suite B = As, Cr, Cu, Pb, Hg, Ni, V, Zn (see text for discussion) General Parameters = Temperature, pH, electrical conductivity, dissolved oxygen, oxidation- reduction potential (1) Note that one selected pair of Upper Zone Well will be used to control the groundwater extraction rate inside the barrier wall. Monthly manual measurements will be used to track potential leakage through the wall and vertically through the aqu;urd. s Anysf ing or ring d by 1 'is a cc' t for z " lg the- ted gr• rater w' dded • orogr t" • .; r' • r Table 3 -1 Proposed Pre - Construction Groundwater Monitoring and Performance Monitoring Programs At Former Rhone Poulenc Site NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Table C1 Relative Percent Difference (RPD) Calculations Tidal Stage Wells GWMP Addendum 3 Former Rhone Poulenc Facility Tukwila, Washington Round 6 < 0.002 Round 7 <0.002 Round 8 <0.002 Round 9 <0.002 Round 10 <0.002 Round 11 <0.002 Round 12 <0.002 Round 13 <0.002 Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 0.19 0.14 0.090 0.038 0.125 0.131 0.023 0.038 <0.002 0.00% <0.002 0.00% <0.002 0.00% <0.002 0.00% <0.002 0.00% <0.002 0.00% 0.014 UND <0.002 0.00% 0.013 0.014 0.016 0.015 0.012 • 0.025 0.018 •0.014 0.012 0.016 0.023 0.018 0.020 0.024 0.023 0.017 -8.00% 13.33% 35.90% 18.18% 50.00% - 4.08% 24.39% 19.35% < 0.010 < 0.010 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.14 - 30.30% 0.027 0.018 - 40.00% 0.075 0.14 0.00% 0.021 < 0.025 UND 0.066 0.046 - 64.71% 0.043 0.020 - 73.02% 0.053 0.031 - 20.29% 0.016 0.009 - 56.00% 0.029 0.147 16.18% 0.021 0.016 - 27.03% 0.048 0.128 -2.32% 0.015 0.014 -6.90% 0.051 0.021 -9.09% 0.010 0.010 0.00% 0.040 0.029 - 26.87% 0.016 0.010 - 46.15% 0.029 < 0.010 < 0.010 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.065 0.068 0.037 0.034 0.054 0.050 0.044 0.026 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 0.00% < 1.0 - 14.29% 2.99% - 35.56% 15.87% 11.76% -1.98% 9.52% -10.91% 4.2 1.6 40 < 1.0 1,100 < 1.0 < 1.0 < 1.0 <'1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 0.00 %; 0.00% 0.00 %; 0.00 %: 0.00% 0.00% 0.00 %' 0.00 %; eTo 7:+^Wll:�%r_s.. iuene= ; a ,;Tole_ ells' 210,000 270,000 250,000 230,000 160,000 280,000 200,000 160,000 14 1.8 8.1 < 1.0 160 < 1.0 < 1.0 < 0.2 107.69 %! 11.76% - 132.64 %j 0.00% -149.21%1 0.00% 0.00 %: Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 tOlito < 0.0020 0.0042 0.003 0.004. 0.003 0.005 0.007 0.007 0.0020 < 0.0040 0.002 0.005 0.003 0.005 0.010 0.004 UND UND -40.00% 22.22% 0.00% 0.00% 35.29% - 54.55% 1 : 0 1 4 5 4 I 0.010 0.011 0.008 0.007 0.005 0.003 0.003 0.004 0.010 < 0.010 0.008 0.006 0.006 0.003 0.002 0.003 0.00% UND 0.00% - 1 18.18% 0.00% - 40.00% - 28.57% < 0.010 < 0.010 <0.005 <0.005 0.007 <0.005 <0.005 <0.005 < 0.010 < 0.010 <0.005 <0.005 0.006 <0.005 <0.005 <0.005 0.00% 0.00% 0.00% 0.00% - 15.38% 0.00% 0.00% 0.00% 190,000 300,000 230,000 130,000 95,000 290,000 210,000 190,000 .KYU - 10.00% 10.53 %i -8.33% - 55.56 %: - 50.98 %! 3.51%: 4.88 %: 17.14% Page 1 of 3 20051131222 - RND 12B1Table C1 RPD metals by wells.xls NOTICE: NOTICE IT IS DUE TO THIS THIS N QUALITY OF THE DOCUMENT. c Table Cl Relative Percent Difference (RPD) Calculations Tidal Stage Wells GWMP Addendum 3 Former Rhone Poulenc Facility Tukwila, Washington Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 0.21 0.14 0.102 0.126 0.142 0.120 0.115 0.102 0.16 0.13 0.120 0.130 0.208 0.099 0.104 0.115 =1} M M fr =TPC� 0.066 0.060 - 9.52% < 0.010 < 0.008 --- 0.016 0.021 27.03% 0.019 0.037 64.29% 0.049 0.048 -2.06% 0.022 0.041 60.32% 0.026 0.029 10.91% 0.020 0.014 - 35.29% �rsen c- s zgN9,.[ 0.026 0.030 14.29% < 0.005 < 0.005 0.00% 0.073 0.047 - 43.33% 0.0085 0.012 34.15 %' 0.032 0.038 17.14 %' 0.013 0.014 7.41% 0.034 0.029 - 15.87% 0.010 0.011 9.52% 0.032 0.028 - 13.33% 0.012 0.014 15.38% 0.030 0.021 - 35.29% 0.008 0.010 22.22% 0.021 0.019 - 10.00% 0.009 0.010 10.53% 0.036 0.024 - 40.00% 0.007 0.008 13.33% - 27.03% -7.41% 16.22% 3.13% 37.71% - 19.18% - 10.05% 11.98% 0.051 0.031 - 48.78% < 0.030 < 0.025 0.03 0.03 0.00% 0.030 0.03 0.00% 0.022 0.024 8.70% 0.028 0.030 6.90% 0.027 0.024 - 11.76% 0.030 0.036 18.18% fWf� Copper ..;X IUIW 17 0.026 0.019 0.031 0.038 0.035 0.024 0.024 0.014 MW1,7RIW 0.026 0.027 0.027 0.037 0.025 0.025 0.017 0.011 < 0.010 < 0.010 0.015 0.021 0.022 0.007 0.015 0.022 0.35 0.27 0.176 0.233 0.26 0.234 0.238 0.189 0.00% 0.045 34.78% < 0.010 - 13.79% 0.015 -2.67% 0.012 - 33.33% 0.022 4.08% 0.013 - 34.15% 0.010 - 24.00% 0.007 < 0.010 < 0.010 0.016 0.018 0.018 0.009 0.013 0.024 0.28 0.25 0.209 0.237 0.30 0.194 0.217 0.235 ��' _ �: _',ms �r.� .._ . :. • - y�, ,, -�. ,.� P.DC M ,1oTL CkaM .74 PD 0.040 < 0.010 0.018 0.022 0.021 0.021 0.014 0.007 0.00% 0.00% 6.45% - 15.38% - 20.00% 25.00% - 14.29% 8.70% - 22.22% -7.69% 17.14% 1.70% 14.29% - 18.69% -9.23% 21.70% - 11.76% 0.00% 18.18% 58.82% - 4.65% 47.06% 33.33% 0.00% < 1.0 < 1.0 4.3 < 1.0 < 1.0 3.2 < 1.0 < 1.0 83 78 47 15 3.4 52 33 11 < 1.0 < 1.0 15 < 1.0 < 1.0 3.9 < 1.0 < 1.0 0.00% 0.00 %. 110.88 %; 0.00% 0.00 %; 19.72%1 0.00 %1 0.00 %; 15.56% 21.71% 4.17% - 6.90 %' 47.19% 19.13% 5.88 %, 92.68 %, 97 97 49 14 5.5 63 35 30 ITb 570,0001 90,000 280,000 380,000 460,000 420,000 350,000 490,000 530,000 110,000 310,000 350,000 420,000 550,000 370,000 440,000 NOTICE: OTICE IT IS DUE TO THE QUALITY THAN THIS TY OF THE DOCUMENT. - 7.27 %; 20.00% 10.17% - 8.22% - 9.09% 26.80 %i 5.56 %I - 10.75 %t Page 2 of 3 20051 \31222 -RND 12B1Table C1 RPD metals by wells.xls Table C1 Relative Percent Difference (RPD) Calculations Tidal Stage Wells GWMP Addendum 3 Former Rhone Poulenc Facility Tukwila, Washington Round 6 Round 7 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 Round 6 Round 7 Round 8 i Round 9 Round 10 Round 11 Round 12 Round 13 Round 8 Round 9 Round 10 Round 11 Round 12 Round 13 0.0042 0.0042 0.004 0.005 0.009 0.007 < 0.002 < 0.002 0.0059 < 0.0060 0.005 0.003 0.012 0.008 0.004 < 0.002 =2 0.10 0.13 0.043 0.008 0.009 0.005 0.004 < 0.002 341V1 F2.5t, � � 'RP 0.12 18.18% 0.15 14.29% 0.036 0.007 0.011 0.005 0.004 < 0.002 0.127 0.133 0.124 0.146 0.135 0.120 0.111 0.118 0.110 0.117 0.067 0.065 33.66% UND 22.22% - 50.00% 28.57% 13.33% UND 0.00% - 17.72% - 13.33% 20.00% 0.00% 0.00% 0.00% 4.62% 16.30% - 11.76% 6.11% 6.17% -3.03% 0.0082 0.0070 0.005 0.005 0.009 0.015 0.012 .0.010 2b W; 0.085 0.093 0.080 0.090 0.084 0.072 0.062 0.046 0.0086 <0.010 0.007 0.006 0.007 0.007 0.009 0.009 0.086 0.097 0.082 0.072 0.084 0.070 0.064 0.041 '1 NiG 46{1= 7Ar111111U -36 0.122 0.117 0.114 0.106 0.092 0.100 0.092 0.088 0.078 Notes: UND - Undetermined value. All values are milligrams per liter (mg /L). < - analyte not detected at or greater than the listed concentration. Bold - RPD greater than 20 %. Negative RPDs Indicate higher concentrations detected during low tidal stage. Positive RPDs indicate higher concentrations detected during hightidai stage. 4.76% UND 33.33% 18.18% - 25.00% - 72.73% - 28.57% - 10.53% 1.17% 4.21% 2.47% - 22.22% 0.00% -2.82% 3.17% - 11.49% - 4.18% -7.27% 8.33% 0.102 10.31% 0.086 - 2.30% 0.066 - 16.67% AW,, 25 0.047 0.050 0.017 < 0.005 0.007 0.006 <0.005 0.006 < 0.010 < 0.010 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 .0.707 0.082 0.096 0.113 0.103 0.070 0.043 < 0.010 < 0.010 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.007 sr+w- w '. t tfrirnium 0.061 0.015 0.005 0.007 0.005 <0.005 0.005 < * Oil ttim 0.090 0.118 0.110 0.094 0.073 0.044 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% UND 0.048 2.11% 9.30% 20.56% - 2.69% -9.14% 4.20% 2.30% a 1'RP �tlfll 19.82% - 12.50% UND 0.00% - 18.18% 0.00% - 18.18% 670,000 560,000 470,000 440,000 520,000 540,000 350,000 310,000 7,200 < 1.0 < 1.0 30 < 1.0 < 1.0 11 < 1.0 < 1.0 1.0 1.6 1.2 < 1.0 0.4 640,000 500,000 430,000 370,000 550,000 510,000 400,000 350,000 -4.58% - 11.32% -8.89% - 17.28% 5.61% -5.71% 13.33% 12.12% - ZoIilene• 25 2,200 < 1.0 < 1.0 50 < 1.0 < 1.0 41 < 1.0 Toluene - JI, W 6 FI1 < 1.0 < 1.0 < 1.0 < 1.0 < 1.0 < 0.2 NOTICE: N IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. - 106.38% 0.00 %1 0.00% 50.00 %j 0.00% 0.00% 115.38 %1 0.00% 0.00% UND' UND UND 0.00% UND Page 3 of 3 20051\31222 -RND 12B \Table C1 RPD metals by wells.xls ' S ..% 1,000,000 100,000 10,000 1,000 100 10 1 0 Jan -93 Jan -94 • Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -95 Jan -96 —0—MW -17 LT (Well in Toluene Plume) — 6 —MW -18 LT (Well in Toluene Plume) — O —MW -25 LT (Well in Toluene Plume) Jan -99 Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov -99. —E—MW-17 HT (Well in Toluene Plume) — A — MW -18 HT (Well In Toluene Plume) — 4 — MW -25 HT (Well in Toluene Plume) Jan -02 Upper Aquifer - Upper Interval Toluene Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 12a GeoEngineers 857400200 /Figs12- 14(toluene).xls,12a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1,000,000 100,000 10,000 1,000 100 10 0 Jan -93 H10 C❑ 0 MW -14 Jan -94 Jan -95 Jan -96 a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -97 Jan -98 Sampling Date Jan -99 Li ri� ❑ _ V a Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov -99. - -0 —H10 LT (Well in Toluene Plume) -- — - (Well Peripheral to Plume) • - -3 — H10 HT (Well in Toluene Plume) Jan -02 Upper Aquifer - Upper Interval Toluene Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 12b Ge0Engineers 857400200 /Figs12- 14(toluene).xls, NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. H11 n V n .m -hi..... n .. • ❑ � MW -2 a a a 1,000,000 100,000 10,000 1,000 . 100 10 1 0 Jan -93 Jan -94* Jan -95 Jan -96 Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. Note. HT = samples collected during high tide. Jan -99 Jan -00 Jan -01 Low and high tide sampling commenced Nov -99. - -� —H11 (Well in Toluene Plume) —f— MW -17 HT (Well in Toluene Plume) -0 —MW -17 LT (Well in Toluene Plume) — A— MW- 27(Well Peripheral to Plume) Jan -02 Upper Aquifer - Upper Interval Toluene Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 12c GeoEngineers • I 857400200 /Figs 12 - 14 (toluen e).xls, 12c NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1,000,000 100,000 10,000 1,000 100 10 0 Jan -93 GeoEngineers MW -15 DM -8 Jan -94 Jan -95 a Jan -96 a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -97 Jan -98 Sampling Date Jan -99 Jan -00 J -01 Note: Low and high tide sampling commenced Nov -99. — —MW -15 (Well in Toluene Plume) - -0-DM -8 LT (Well. adjacent to the Duwamish Waterway) - -E —DM -8 HT (Well adjacent to the Duwamish Waterway) — 0 —MW -26 (Well Peripheral to Plume) Upper Aquifer - Intermediate Interval Toluene Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 13 857400200 /Figs12 -14 (toluene).xls,13 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. Jan -02 Y C 1 ,000,000 100,000 10,000 1,000 100 10 1 MW -15 MW -16 0 Jan -93 Jan -94 • Jan -95 Jan -96 Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -99 Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov -99. -- A — MW -15 (Well in Toluene Plume) — 0—MW -16 LT (Well Peripheral to Plume) — ;• -MW -16 HT (Well Peripheral to Plume) Jan -02 Upper Aquifer - Intermediate and Lower Intervals Toluene Concentrations vs Time Round 15 Ground Water Monitoring • FIGURE 14 GeoEngineers f f 857400200 /Figs 12- 14(toluene).xls,14 NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • GeoEngineers 0.150 0.125 J E 0.100 In O w I°- c 0.075 0 U 0 U g 0.050 0.025 0.000 Jan -93 H11 MW -1 MW -2 ■ u • A MW-24 Jan -94 • Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Note: Low and high tide sampling commenced Nov- 99. Jan -01 -- C- -MW -25 LT (Well in Toluene Plume) — o —MW -24 (Well Peripheral to Plume) - -9 —MW -14 (Well Peripheral to Plume) — f —MW -25 HT (Well in Toluene Plume) —4—H11 (Well in Toluene Plume) Jan -02 Upper Aquifer - Upper Interval Arsenic Concentrations vs Time Round 15 Ground Water Monitoring • 857400200 /Figs 15 -16 (arse n ic).xls,15a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. FIGURE 15a 0.150 0.125 3 0.100 E 0 0 0.075 0 U o 0.050 d 0.025 0.000 Jan -93 Jan -94 Jan -95 Jan -96 — O — - LT (Well In Toluene Plume) — A —MW -27 (Well Peripheral to Plume) Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -99 Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov -99. — NI- -MW -17 HT (Well in Toluene Plume) —0—H6 (Well Adjacent to Duwamish Waterway) Jan -02 Upper Aquifer - Upper Interval Arsenic Concentrations vs Time Round 15 Water Monitoring FIGURE 15b GeoEngineers 857400200 /Figs15- 16(arsen ic).xls,15b NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. MW -27 . . MW -17 . .H ❑ \ �� n /� a te❑ 0.150 0.125 3 0.100 E 0 0 0.075 0 U o 0.050 d 0.025 0.000 Jan -93 Jan -94 Jan -95 Jan -96 — O — - LT (Well In Toluene Plume) — A —MW -27 (Well Peripheral to Plume) Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -99 Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov -99. — NI- -MW -17 HT (Well in Toluene Plume) —0—H6 (Well Adjacent to Duwamish Waterway) Jan -02 Upper Aquifer - Upper Interval Arsenic Concentrations vs Time Round 15 Water Monitoring FIGURE 15b GeoEngineers 857400200 /Figs15- 16(arsen ic).xls,15b NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. GeoEngineers . E� - 857400200 /Figs15- 16(arsenic .xls,16a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 0.050 . 0.045 . • DM -8 ❑ • 0.040 `or 0.035 E en 0 0.030 c ❑ • m 0.025 u v • • 0.020 ■ • ,� 31 N 0.015 MW -15 ♦ a A \� - ❑ 0.010 MW-26 0.005 a • 0.000 Jan -93 I I I Jan -94 . Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Jan -01 Sampling Date - a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. Note: HT = samples collected during high tide. • Low and high tide sampling commenced Nov -99. Jan -02 — t HT adjacent to the Duwamish Waterway) D —DM -8 LT (Well adjacent to the Duwamish Waterway) — - - DM -8 (Well -- -MW Peripheral to Plume) — —MW -15 (Well in Toluene Plume) -26 (Well ' Upper Aquifer - Intermediate Interval Arsenic Concentrations vs Time FIGURE Round 15 Ground Water Monitoring I 6 a • • . GeoEngineers . E� - 857400200 /Figs15- 16(arsenic .xls,16a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • 0.050 0.045 0.040 3 en 0.035 E ta g 0.030 DM -2A E 0.025 U U c o 0 0.020 U . MW -28 N 0.015 a 0.010 a A 40 0.005 0.000 Jan -93 Jan 4 4 -94 Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 . Jan -00 Jan -01 • Sampling Date • a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. Note: HT = samples collected during high tide. Low and high tide sampling commenced Nov -99. Jan -02 — 4 —DM adjacent to the Duwamish Waterway) -- -MW -28 (Well Peripheral to Plume) -2A (Well Upper Aquifer - Intermediate Interval Arsenic Concentrations vs Time FIGURE Round 15 Ground Water Monitoring I 6 b. • • ... • GeoEngineers " igs15 - b(arse x ls ., NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. A 111 H6 )er Concen c U • MW -27 ❑ M v- v ❑ \ff rg "V • fl a Ai • u.uu Jan -93 Jan -94 - Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Jan -01 • Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. Note: HT = samples collected during high tide. Low and high tide sampling commenced Nov -99. Jan -02 HT in Toluene Plume) — —MW -17 LT (Well in Toluene Plume) —4—MW-17 (Well --* —H6 Adjacent to Duwamish Waterway) - - MW -27 (Well Peripheral to Plume) (Well • Upper Aquifer - Upper Interval Copper Concentrations vs Time FIGURE • Round 15 Ground Water Monitoring 1 7 a • GeoEngineers 857400200/Figs 17- 19(copper).xls,17a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. GeoE gineers •%i 857400200/Figs 17- 19(coppe r).xls, l 7b NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 0.60 • • 0.50 -I E E 0.40 N c O ra - H O • . c 0.30 c 0 U 6" o. 0.20 c. 0 C) 0.10 H10 • 0 MW -18 O MW-29 �� „ n --A- -. ^ ....♦._v gr.7r._,r-w' Jan -02 0.00: Jan -93 Jan -94 Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Jan -01 Sampling Date' a = 1/2 SQL was used for results reported as ND. LT • samples collected during low tide. Note: HT = samples collected during high tide. Low and high tide sampling commenced Nov -99. HT in Toluene Plume) — 0--H10 LT (Well in Toluene Plume) —; —H10 (Well BMW HT in Toluene Plume) — O —MW -18 LT (Well in Toluene Plume) — -18 (Well Peripheral Plume) —0-- H9 LT Adjacent to Duwamish Waterway) —X— MW-29 (Well to (Well - 4 - H9 HT (Well Adjacent to Duwamish Waterway) Upper Aquifer - Upper Interval Copper Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 17b GeoE gineers •%i 857400200/Figs 17- 19(coppe r).xls, l 7b NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. GeoEngineers r . ..._ .l J 0.40 0 c 0.30 0 c - 0 U L. a 0.20 o. U 0.50 0.10 Jan -94 Jan -97 Jan -98 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -95 Jan -96 Jan -99 — O —MW -25 LT (Well in Toluene Plume) --MW -24 (Well Peripheral to Plume) —e —H11 (Well in Toluene Plume) -- E —MW -25 HT (Well in Toluene Plume) — F —MW -14 (Well Peripheral to Plume) Jan -00 Jan -01 Note: Low and high tide sampling commenced Nov- 99. Jan -02 Upper Aquifer - Upper Interval Copper Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 17c 857400200 /Figs 17- 19(copper).xls,17c NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. G eoEngineers igs -7 J(copper ).xls, NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. A A • • DM -2A • ' MW -28 (JAM Jan ft../ `� "op . -93 Jan -94 1 -� , 1 r Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Jan -01 ' Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. Note: HT = samples collected during high tide. Low and high tide sampling commenced Nov -99. • Jan -02 to the Duwamish Waterway) — A —MW -28 (Well Peripheral to Plume) — 4—DM -2A (Well adjacent , • • Upper Aquifer - Intermediate Interval Copper Concentrations vs Time FIGURE Round 15 Ground Water Monitoring 18 . . . G eoEngineers igs -7 J(copper ).xls, NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. GeoEngineers E O L 0.40 . 0.30 C 0.20 d ci O V 0 0. 0. 0 v 0.10 0.00 Jan -93 MW -16 MW -15 • 0 o ■11141 ,,. ■ • 1). ■ -r►❑ Jan -94 . Jan -95 Jan -96 Jan -97 Jan -98 Jan -99 Jan -00 Jan -01 Jan -02 Sampling Date a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. A a Note: Low and high tide sampling commenced Nov -99. — I3—MW -16 LT (Well Peripheral to Plume) — A — MW -15 (Well in Toluene Plume) — 1E —MW -16 HT (Well Peripheral to Plume) Upper Aquifer - Intermediate and Lower Intervals Copper Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 19a 857400200 /Figs17- 19(copper).xis,19a NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1 0.30 0� y 0 19 0.40 c 0.20 v 0 U 1 d 0. 0. 0 ° 0.10 0.00 Jan -93 DM -8 0 [7 MW -1 Jan -94 H . Jan -95 Jan -96 a = 1/2 SQL was used for results reported as ND. LT = samples collected during low tide. HT = samples collected during high tide. Jan -97 Jan -98 Sampling Date ■ MW -2 ,, Jan -99 Jan -00 Note: Low and high tide sampling commenced Nov -99. -- — - LT'(Well adjacent to the Duwamish Waterway) — f — MW - 15 (Well in Toluene Plume) —X—H1 (Well Peripheral to Plume) —� — DM -8 HT (Well adjacent to the Duwamish Waterway) f MW - 26 (Well Peripheral to Plume) Jan -01 Jan -02 Upper Aquifer - Intermediate and Lower Intervals Copper Concentrations vs Time Round 15 Ground Water Monitoring FIGURE 19b Ge0Engineers 857400200 /Figs17- 19(copper).xls,19b NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1 Ci4 °t tli imi • E 1■1 et) * E ui � N t-, A� e �. c::) = •I. TO o"` NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR -THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 I N THE MATTER OF: EXHIBIT "B" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10, 1200 SIXTH AVENUE SEATTLE, WASHINGTON ) Rhone- Poulenc, Inc. and ) Rhone- Poulenc Specialty ) Chemicals, L.P. ) Marginal Way Facility, ) Seattle, Washington ) (WAD009282302), ) ) Respondent ) CONSENT ORDER - Page 1 ADMINISTRATIVE ORDER ON CONSENT U.S. EPA Docket No. 1091- 11- 20- 3008(h) Proceeding under Section 3008(h) of the Resource Conservation and Recovery Act, 42 U.S.C. § 6928(h) March 31, 1993 YATj'}4`RN NF�t ✓.+hYN,.E: ',, i�iY -�' +t!rY ix::iw:a✓ Z :1 . J U' U O. CO CV • NW: W =• CO U WO g = - _ Z I- O Z U . � N O 0 I- w w . _ I- — w � — O: w Z: . � , 0 I- O .Z 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 TABLE OF CONTENTS Pace TABLE OF CONTENTS 2 ATTACHMENTS 3 DEFINITIONS 4 I. JURISDICTION 9 II. PARTIES BOUND /APPLICABILITY 10 III.' STATEMENT OF PURPOSE 12 IV. U.S. EPA FINDINGS OF FACT 13 V. U:S. CONCLUSIONS OF LAW AND DETERMINATIONS . 25 VI. WORK TO BE PERFORMED 27 A. STABILIZATION /INTERIM MEASURE(S) 28 B. RCRA FACILITY INVESTIGATION ( "RFI ") 31 C. RISK ASSESSMENT /MEDIA CLEANUP STANDARDS. • • 33 D. CORRECTIVE MEASURES STUDY (CMS) 34 E. CORRECTIVE MEASURES IMPLEMENTATION (CMI) . 38 VII. AGENCY APPROVAL /SUBMISSIONS /ADDITIONAL WORK. • • 40 A. EPA APPROVALS 40 B. SUBMISSIONS 43 C. PROPOSED CONTRACTOR /CONSULTANT 44 D. ADDITIONAL WORK 45 VIII. QUALITY ASSURANCE 46 IX. COMMUNITY RELATIONS /PUBLIC COMMENT AND PARTICIPATION 47 X. ON -SITE AND OFF -SITE ACCESS 48 XI. SAMPLING AND DATA /DOCUMENT AVAILABILITY 51 XII. RECORD PRESERVATION 52 XIII. PROJECT COORDINATOR 53 XIV. NOTIFICATION AND DOCUMENTATION CERTIFICATION 54 XV. • DELAY IN PERFORMANCE /STIPULATED PENALTIES. . 56 XVI. DISPUTE RESOLUTION 60 XVII. FORCE MAJEURE AND EXCUSABLE DELAY 62 XVIII. RESERVATION OF RIGHTS 65 XIX. JUDICIAL REVIEW 67 XX. OTHER CLAIMS 68 XXI. OTHER APPLICABLE LAWS 68 XXII. INDEMNIFICATION OF THE UNITED STATES GOVERNMENT 69 XXIII. FINANCIAL RESPONSIBILITY 69 XXIV. MODIFICATION 71 XXV. SEVERABILITY 72 XXVI. TERMINATION AND SATISFACTION 72 XXVII. SURVIVABILITY /PERMIT INTEGRATION 74 XXVIII. EFFECTIVE DATE 75 _..flEP. - Pace March 31, 19 9 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 :l„%�:�•`�: i ra�2 ` e;' �xxi�± � +,.:'� *a�c'i�rt�rr;;,avuwswt.��• -. 2 Figure 1 - Location Map Figure 2 - Site Map Figure 3 - Composite Soil Sampling Map Figure 4 - Well Location Map Attachment A - RCRA Facility Investigation Scope of Work and Workplan Requirements Attachment B - Sampling and Analysis and Data Management Program Requirements Attachment C - Scope of Work for the Corrective Measures Study Requirements Attachment D - Scope of Work for the Corrective Measure Implementation CONSENT ORDER - ATTACHMENTS 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 CC S E: T ORDER - P, e A. DEFINITIONS 1. Act or RCRA shall mean the Resource Conservaticr. and Recovery Act, as further amended by the Hazardcus and Solid Waste Amendments of 1984, 42 U.S.C. §§ 6901 et sea. 2. Additional work shall mean any activity or requirement that is not expressly or impliedly covered by this Consent Order or its attachments but is necessary to complete the purpose of this Consent Order as presented in the Purpose Section of this Consent Order. 3.. Administrative Record shall mean the record compiled and .. maintained by U.S. EPA relative to this Consent Order. The Administrative Record may include, but is not limited to, information on the work performed and to be performed under this Consent Order, the factual findings supporting this Order, the selection of corrective measures for this facility, correspondence on the approval, disapproval or modification of work required of the Respondent and the existence and resolution of any dispute pursuant to the Dispute Resolution provisions of this Consent Crder. 4. Area of Concern or AOC shall mean any area where a release to the environment of hazardous waste(s) or hazardous constituents has occurred, is suspected to have occurred, or may occur regardless of the frequency and duration of the release. 5. CERCLA shall mean the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended, 42 U.S.C. §§ 9601, et sea. 6. Chemicals of Potential Concern shall mean chemicals that are potentially site - related and whose data are of sufficient quality for use in a quantitative risk assessment. 7. Comply, to comply, to be in compliance with, compliance may be used interchangeably and shall mean completion of an activity or requirement in the manner and time specified in this Consent Order, its attachments or written U.S. EPA directives. The Respondent must meet both the quality and timeliness components of a particular requireirtent to be considered to be in compliance with the terns and conditions of this Consent Order. 8. Corrective measure shall -jean those actions cr measures necessary to permanently control, prevent or mitigate the release or potential release of hazardous waste or hazardous constituents into the environment. • 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25i Corrective Measures Implementation or CMI_ shall mean those activities necessary to initiate, complete, monitor and maintain the remedies U.S. EPA may select or has selected to protect human health or the environment from the release or potential release of hazardous wastes, including hazardous constituents, into the environment from the facility. The activities required for the CMI are detailed in the CMI Scope of Work included as Attachment D. 10. Corrective Measures Study or CMS shall mean the investigation and evaluation of potential remedies which will protect human health and the environment from the release or potential release of hazardous wastes, including hazardous constituents, into the environment from the facility. The activities required for the CMS is detailed in the CMS Scope of Work included as Attachment C. 11. 1981 Dames & Moore Study and 1986 Dames & Moore Study shall mean the environmental assessments conducted in 1981 and ,1986 by Dames & Moore Consultants on behalf of Respondent on the Facility, which U.S. EPA and RPI both possess and are familiar with. 12. Data Quality Objectives shall mean qualitative or quantitative statements specified to ensure that data of known and appropriate quality are obtained. 13. Dav shall mean a calendar day unless expressly stated to be a working day. Working day shall mean a day other than a Saturday, Sunday, or Federal Ho.liday. In, computing any period of time under this Consent Order, where the last day would fall on a Saturday, Sunday, or Federal Holiday, the period shall run until the end of the next working day. 14. Director shall mean the Director of the Hazardous Waste Division for the U.S. EPA Region 10, or his designee. 15. EPA or U.S. EPA shall mean the United States Environmental Protection Agency, Region 10 Office. 16. Facility or site shall mean all contiguous property under the control of the owner /operator subject to permit requirements under RCRA. This definition also applies to facilities implementing corrective action under RCRA Section 3008(h). 17. Hazardous Constituents shall mean those constituents listed in Appendix VIII to 40 C.F.R. Part 261 or any constituent identified in Appendix IX to 40 C.F.R. Part 264. . Hazardous Waste shall be as defined in Section 1004(5) cf RCRA, 42 U.S.C. 6903(5), or 40 C.F.R. 5 260.10. • . i.i .. ..TT �)RDE � - Xarch 31, 1993 .7V 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 Hazardous Waste Management Unit shall mean a contiguous area of land on or in which hazardous waste is placed, or the largest area in which there is significant likelihood of mixing hazardous waste constituents in the same area. 20. Landau Report or Landau and Associates Site Assessment shall mean the environmental assessment conducted in 1991 on the Facility by Landau & Associates, which both U.S. EPA and RPI possess and are familiar with. 21. Innovative technologies shall mean those technologies for treatment of soil, sediment, sludge, and debris other than incineration, solidification /stabilization;.and.as those technologies for control of groundwater other than pumping with conventional treatment for groundwater. 22. Interim measures or IM shall mean those actions required in advance of selection of the final corrective action for a facility and which are necessary to expeditiously initiate clean -up actions at a site and control or eliminate the release or potential release of hazardous wastes or hazardous constituents at or from the facility. 23. Off -site, when used in relation to the facility or site, shall mean all areas which are not on -site. 24. On -site shall mean the same or geographically contiguous property within the Facility which may be divided by public or private right -of -way, provided the entrance and exit between the properties is at a cross -roads intersection, and access is by crossing as opposed to going along, the right - of -way. Non - contiguous properties owned by the same person but connected by a right -of -way which he controls and to which the public does not have access is also considered on- site property. •25. Operator shall mean the persons responsible for the overall operation of a facility. 26. Owner shall mean the person or persons who own(s) a facility or part of a facility. 27. Performance audit or OA /OC audit shall mean U.S. EPA's inspections or audits of laboratories used by the Respondent to evaluate samples collected or required pursuant to this Consent Order. 28. Person shall mean an individual, trust, firm, joint stock 25 company, Federal =.aenc': , corporation (including a government corporation) , partnership, association, State, z un..__:a_. t: , commission, Do , ._i:al :5u i _sion of ? State, or any ,l r::OW-._.. RD' - • 8 9 .0 .1 L2 • 14 15 16 17 18 19 20 21 22 23 24 25 34. Receptors shall mean those animal(s) or plant(s) which are or may receive or be affected by releases of hazardous waste, including hazardous constituents, from the facility. 30. Regional Administrator shall mean the Regional Administrator for the U.S. EPA Region 10, or her designee. 31. Release shall mean any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles containing hazardous wastes or hazardous constituents). 32. RCRA Facility Investiaation or RFI shall mean the • investigation and characterization of the nature, extent, direction, rate, movement and concentration of releases of hazardous waste, including hazardous constituents, that have been or are likely to be released into the environment from the facility. The activities required for the P.FI are detailed in the RFI Scope of Work included as Attachment A. 33. Respondent shall mean Rhone- Poulenc, Inc. ( "RPI "). Solid Waste Management Unit or SWMU shall mean any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste. Such units include spill or production areas at a facility at which solid wastes have been routinely and systematically released into or onto the environment. 35. Stabilization shall mean the techniques intended to control or abate threats to human health and /or the environment, and to prevent or minimize the spread of contamination while long -term corrective action alternatives are evaluated. 36. Statement of Work or SOW shall mean the outline of work required for implementation of an Interim Measure(s), a RCRA Facility Investigation, a Corrective Measures Study or a Corrective Measures Implementation as set forth in Attachments A, B, C and D to this Consent Order. The Statements of Work are incorporated into this Consent Order and are an enforceable part of this Consent Order. 37. Violate, Violations or Noncompliance of this Consent Order shall mean those actions, or failures to act by the Respondent which do not meet the quality and timeliness requirements of this Consent Order, its attach eats or U.S. EPA written directives. ): ;:'... ORDER - P ,aco 'RY'.L': .. ywffitl[F . Y^Y LNNTd 2 1 J 4 5 J 6 7 0 9 10 11 12 14 15 16 17 18 19 20 • 21 22 23 • 38. Work or Obligations or Performance of Work shall mean any activity the Respondent must perform to comply with the terms and conditions or requirements of this Consent Order and its attachments. 39. Workplan shall mean the detailed plans prepared by the Respondent to satisfy the requirements of the corresponding Scopes of Work. The required elements of each Workplan are presented in Section VI, Work to be Performed. : '!l -. -h 3 L _ L 2 2 3 4 5 6 7 8 9 10 11 12 13 i4 15 16 17 18 19 20 21 22 23 24 25 27 COP:SENT ORDER - Page 9 I. JURISDICTION 1.1 This Administrative Order on Consent ( "Consent Order" or "Order ") is issued pursuant to the authority vested in the Administrator of U.S. EPA pursuant to Section 3008(h) of the Solid Waste Disposal Act, commonly referred to as the Resource Conservation and Recovery Act of 1976 ( "RCRA "), as .amended by the Hazardous and Solid Waste Amendments of 1984, . U.S.C. § 6928(h). The authority vested in the Administrator has been delegated to the Regional Administrator by U.S. EPA Delegations No. 8 -31 and 8 -32 and further delegated to the Director, Hazardous Waste Division by Regional delegation, R1O 1281.7. 1.2 This Consent Order is issued to 'Rhone- Poulenc, Inc. ( "RPI ") ( "Respondent "), the owner and controlling entity of the RPI facility located at 9229 East Marginal Way South, in Tukwila, Washington. Respondent consents to and agrees not to contest U.S. EPA's jurisdiction to issue this Consent Order and to enforce its terms. Further, Respondent will not contest U.S. EPA's jurisdiction to: compel compliance with this Consent Order in any subsequent enforcement proceedings, either administrative or judicial; require Respondent's full or interim compliance with the terms of this Consent Order; or impose sanctions for violations of this Consent Order. Accordingly, Respondent waives any rights it may have pursuant to Section 3008(b) of RCRA, 42 U.S.C. 5 6928(b), or )otherwise, to contest issuance and /or entry and /or the validity March , _'?9 1 2 3 4 5 6 7 8 9 10 11 12 14 15 ( )binding upon Respondent and its officers, directors, employees, 16 17 18 19 20 21 22 23 24 25 of this Consent Order, including any right to a public hearing. Respondent waives any rights it may have to assert any error under 40 C.F.R. Subparts 22 or 24 regarding the issuance and/or entry of this Consent Order. 1.3 On January 30, 1986, U.S. EPA granted the State of Washington authorization to operate a hazardous waste program in lieu of the federal hazardous waste program to Section 3006(b) of RCRA, 42 U.S.C. § 6926(b). The State of Washington, however, has not been delegated the authority to enforce Section 3008(h) of RCRA, 42 U.S.C. § 6928(h). II. PARTIES BOUNDIAPPLICABILITY 2.1 This Consent Order shall apply to and be ) agents, successors and assigns, trustees, receivers, and upon all persons, including, but not limited to, independent contractors, contractors, and consultants acting under or on behalf of Respondent. 2.2 No change in ownership of the Facility or of any interest therein, or in Respondent's business organization or forms of operation will in any way alter Respondent's responsibilities under this Consent Order. Respondent will be responsible for and liable for any failure to carry out all activities required of Respondent by the express terms and conditions of the Consent Order, irrespective of its use of employees, agents, consultants or successor owners or operators to perform such tasks. CONSENT CKDER - Pace 19 1, 1993 2.3 Respondent shall provide a copy of this Consent Order to all contractors, subcontractors, laboratories, and consultants retained to conduct or monitor any portion of the z work performed pursuant to this Consent Order within one (1) week H W of the effective' date of this Consent Order or date of such w v UO retention, whichever occurs later, and shall condition all such N 0 w= contracts on compliance with the terms of this Consent Order. cu 1 w� 2.4 Respondent shall provide a copy of this w successor in interest at least sixty (60) L.- ,N _ g 5 I Consent Order to any cn days prior to transfer of any interest in the Facility, or F— w Z = F- L transfer of any responsibility for the operation of the Facility, w O Y y (30) days prior to any D w 2 and shall notify U.S. EPA at least thirt ( ) Y P Y 0 Q U ��ich transfer. � = w H U . 4 2.5 Respondent ag to undertake all actions w H —O W z 5 required by the terms and conditions of this Consent Order and U = O ~ .6 consents to the entry of this Consent Order without a hearing as Z .7 a Consent Order entered pursuant to Section 3008(h) of RCRA, 42 L8 U.S.C. § 6928(h). L9 2.6 Respondent is entering into this Consent 20 Order for the purpose of conducting the requirements of this 21 Consent Order. Respondent's execution of this Consent Order 22 shall not be construed in any way as an admission of liability or 23 of any findings of fact or conclusion of law stated herein. 24 III. STATEMENT OF PURPOSE 25 3.1 In entering into this Consent Crder, the 1 ! mutual objectives of U.S. E and Respondent are: 27 CONSENT ORDER - Pa,:.- -1 , :r+_y� wl la ~ o-1✓ .e: » l•`1�^'t_•eLwr...' 2 3 4 5 6 7 8 0 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 (1) To complete all site investigation and cleanup activities at the RPI Marginal Way Facility. (2) To implement stabilization and interim measures to relieve threats to human health and /or the environment. (3) To perform a RCRA Facility Investigation ( "RFI ") to determine fully the nature and extent of any release of hazardous waste and /or hazardous constituents at or from the Facility and for Respondent to prepare an RFI Report. (4) To perform a Corrective Measures Study ( "CMS ") to identify and evaluate the corrective action alternatives necessary to prevent or mitigate any release or migration of hazardous wastes and /or hazardous constituents at or from the Facility. (5) To implement to U.S. EPA's satisfaction the corrective action or response measures approved by U.S. EPA. U.S. EPA will determine whether such actions or measures are required, based on results of the RFI and CMS. (6) To perform other activities to correct actual or potential threats to human health, welfare and /or the environment resulting from the release or potential release of hazardous wastes or hazardous substances or constituents at the Facility. ":i... ')PDEP - Page 12 • ..arch 3 1'393 2 3 4 5 6 7 8 9 10 11 u 12 1 .3 previously was operated by Monsanto Industrial Chemicals Company, 14 which manufactured a variety of chemical products in addition to 15 16 17 18 19 20 21 22 23 24 (7) To accomplish all of the foregoing in a manner consistent with RCRA, and applicable U.S. EPA regulations, guidance documents, and policies. IV. U.S. EPA FINDINGS OF FACT 4.1 Respondent is an owner and operator of a hazardous waste facility located at 9229 East Marginal Way South, Tukwila, Washington. Until its closure in April, 1991, Respondent engaged in storage, of hazardous waste at the Facility subject to interim status requirements under 40 C.F.R. Part 265 and WAC § 173 - 303 -400. The RPI Marginal Way Facility chemically manufactured vanillin, used as a food flavoring and as an intermediate in the production of pharmaceuticals. The Facility vanillin, including dry glues, resins, hardeners, and extenders. Figure 1 attached shows the Facility•in relation to its surroundings and a site map of the Facility is shown in Figure 2. 4.2 The Monsanto Industrial Chemicals Company purchased the property in 1946 and began vanillin production at the Facility in June of 1952. Respondent purchased the Facility in October of 1986, and operated the Facility until April of 1991, when the Facility ceased operations. 4.3 Monsanto and RPI have owned and operated the Facility as a hazardous waste management facility on or after November 19, 1980, the applicable date which renders facilities )subject to interim status requirements or the requirement to have '•!arc 3 1992 2 3 4 5 6 • 7 8 9 10 11 12 1?- 4 14 15 16 17 18 19 20 21 22 23 24 25 11 f a permit under Sections 3004 and 3005 of RCRA, 42 U.S.C. §§ 6924 and 6925. 18 1 4.4 Pursuant to Section 3010 of RCRA, 42 U.S.C. § 6930, Monsanto notified U.S. EPA on August 14, 1980 of its hazardous waste activity. In its notification, Monsanto identified itself as a generator of hazardous waste and an owner /operator of a treatment, storage, and /or disposal facility for the following listed wastes: (a) D001, D002 and D003 (hazardous wastes exhibiting the characteristics of ignitability, corrosivity, or reactivity identified at 40 C.F.R. SS 261.20- 261.23); (b) FOOL (hazardous wastes from non - specific sources identified at 40 C.F.R. § 261.31); and (c) U013, U080, and U220 (commercial chemical products, manufacturing chemical intermediates, off - specification commercial chemical products, or manufacturing chemical intermediates identified at 40 C.F.R. § 261.33(f)). 4.5 The relevant regulatory history of the Facility is as follows: (a) November 12, 1980 -- Monsanto filed a RCRA Part A Permit Application Form 1 and Form 3, and listed tank storage capacity as 4,500 gallons and identified itself as handling D002, D003, F001, U013, U080, and U220 wastes at the Facility. COPTS E NT ORDER - [Dag'? 1.4 r , • 9 2 3 4 5 6 7 8 9 10 13 15 16 17 18 19 20 21 22 23 24 25 5 2 7 ^� 2 (b) September 30, 1982 -- Monsanto filed a revised RCRA Part A Permit Application Form 3 to include a container storage listing, to amend the D002 listing, to specify the quantity of D002 wastes as 1,000 tons, and to eliminate the U013 and U080 hazardous waste designations. Respondent states that UO13 and UO80 were eliminated from Monsanto's Form 3 because it did not generate those wastes. (c) October 15, 1982 -- Monsanto filed a modified RCRA Part A Permit Application Form 3 to revise the quantity of D002 hazardous waste from 1,000 tons .to 5,000 tons. (d) August 1, 1984 -- Monsanto filed a Notification of Dangerous Waste Activities Form 2 with the Washington Department of Ecology ( "Ecology "). The Facility identified itself as a generator and storage facility of the dangerous waste WT02 (mineral oil containing phenolics from vanillin manufacturing). It reported 125 tons as the estimated or actual annual waste quantity. (e) April 11, 1985 -- Monsanto filed a revised Notification of Dangerous Waste Activities Form 2 with Ecology which listed the following wastes and estimated or actual quantity weights respectively: (1) still bottoms from vanillin manufacturing (WT02) at 1,000 tons; (2) vanillin black liquor solids from vanillin manufacturing (D002) at 12,000 tons; (3) phenolic CONSENT ORDER - Page 15 March 31, _ 003 • 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 2 4, contaminated mineral oil from vanillin manufacturing (WT02) at 50 tons; and (4) strainer solids containing copper from vanillin manufacturing (D002) at 120 tons. (f) August 18, 1986 -- Monsanto submitted to Ecology a Closure and Post - Closure Reo P /M, regarding the on- site area hazardous waste storage area. (g) October 2, 1986 -- Monsanto filed a revised -Notification of Dangerous Waste Activities Form 2 with Ecology which described certain new wastes generated and /or revised the estimated or actual weights of existing wastes as: (1) vanillin black liquor solids from vanillin manufacturing (D002) at 6,000 tons; (2) strainer solids containing copper from vanillin manufacturing (WT02) at 100 tons; (3) spent methylene chloride solvent (F001) at 200 lbs; (4) waste shop solvent (WT02) at 200 lbs; (5) used Penneteck oil residue (WT02) at 25 tons. The October 2, 1986 Notification also indicated the 1986 change of ownership from Monsanto to Rhone - Poulenc Inc. (h) November 17, 1986--Rhone-Poulenc,. Inc. submitted to Ecology a second copy of the Closure and Post - Closure Rearuirements plan, prepared by Monsanto in August 1986, regarding the on -site RCRA hazardous waste storage area. (i) April 24, 1987 -- Rhone- Poulenc, Inc. filed a revised Part A Permit Application Form 1 showing new a«:or name and address. - ^a ;larch 31, 1993 2 3 4 5 6 7 8 9 10 11 12 16 17 18 19 20 21 22 23 24 25 -)3 (j) May 26, 1988 -- Rhone-Poulenc Inc., filed a Notification of Dangerous Waste Activity Form 2 to Ecology. (k) June 14, 1988 - -U.S. EPA sent a Notice of Violation and Warning, and Request for Information, to Rhone- Poulenc, Inc. based on findings from an inspection on March 31, 1988, and on information gathered during a subsequent investigation. Noncompliance items included: (1) failure to submit a revised Part A Permit Application due to the change of ownership from Monsanto to Rhone - Poulenc, Inc.; (2) failure to properly acknowledge in the interim status permit the storing of an F002 hazardous waste; and (3) failure to comply with the interim status financial requirements of 40 C.F.R. Part 265, Subpart H. U.S. EPA also sent a Notice of Violation and Warning, and Request for Information, to the Monsanto Company on June 27, 1988 indicating Monsanto failed to comply with the interim status financial requirements. (1) July 19, 1988 -- Rhone - Poulenc, Inc. responded to the Notice of Violation and Warning, and Request for Information. It forwarded a revised Part A, Forms 1 and 3, updating operator local address, description, and quantities of hazardous wastes. (m) August 19, 1988 -- Rhone-Poulenc, Inc. submitted an amended Closure and Post-Closure Recuirements plan to Ecology. CONSENT ORDER - Page 1 7 '_ 9 3 2 3 4 5 6 7 8 9 10 11 12 ) 14 15 16 17 18 RPI. 19 4.6 A RCRA Facility Assessment ( "RFA ") was 20 conducted by U.S. EPA at the Marginal Way Facility in 1989 (final 21 report dated March 19, 1990). The purpose of the RFA was to 22 identify and evaluate environmental releases, and to explore the 23 potential for releases of hazardous wastes and constituents from 24 solid waste management units ( "SWMUs ") and areas of concern 25 ( "ADCs ") at the Facility. The RFA reviews, evaluates, and 27 (n) January 16, 1989 -- Rhone- Poulenc, Inc. submitted a notification of Dangerous Waste Activity Form 2 to Ecology, which added the waste "Black Liquor Solid (Dry Cake)" from vanillin manufacturer at 6,750 tons (WT01). (o) May 19, 1989 and July 20, 1989 -- Rhone- Poulenc, Inc. submitted a second and third amended Closure and Post - Closure Requirements plan to Ecology. • (p) February 23, 1990 -- Rhone- Poulenc, Inc. submitted a notification of Dangerous Waste Activity Form 2 to Ecology to indicate a change in operation of the Facility to its wholly -owned subsidiary Rhone- Poulenc Specialty Chemicals Limited Partnership and to change the designation of strainer solids containing copper from vanillin manufacturing from WTO1 to WT02. (q) April 5, 1990 -- Rhone- Poulenc, Inc. filed a revised Part A Permit Application Forms 1 and 3 to indicate a change in ownership of the Facility to its wholly -owned subsidiary CONSENT ORDER - Pace 18 1 9a 2 2 3 4 5 6 7 8 9 10 11 12 13 14 • 15 16 17 18 19 20 21 22 23 24 25 ncorporates soil and groundwater data generated by Dames and Moore in its 1981 and 1986 studies. 4.7 The RFA identified the following wastes generated at the Facility: (a) Vanillin black liquor solid ("VBLS") slurry (D002) identified as a hazardous waste exhibiting the characteristic of corrosivity as identified in 40 C.F.R. § 261.22. The slurry contains trace amounts of toluene. (b) VBLS dry cake identified as a Washington State Extremely Hazardous Waste (WTO1). (c) Copper- contaminated strainer solids identified as a Washington State Dangerous Hazardous Waste (WT01), which was later redesignated as WT02. (d) Used phenolic- contaminated Peneteck oil residues identified as a Washington State Toxic Dangerous Waste (WT02) . (e) Spent methylene chloride (F002) identified as hazardous waste from non - specific sources identified at 40 C.F.R. § 261.31. (f) Used shop solvents identified as a Washington State Extremely Hazardous Waste (WT01). (g) The RFA also concluded that the Facility has generated and stored hazardous wastes, and has handled materials containing various hazardous constituents (as listed in Appendix VIII to 40 C.F.R. Part 261) such as 1 _3'I3FN `' ORDER - g 19 March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 ) toluene and methylene chloride. Those hazardous constituents are also hazardous substances as listed in 40 C.F.R. 5 302.4. 4.8 The RFA identified twelve (12) SWMUs and three (3) AOCs at the Facility, where hazardous wastes and /or hazardous constituents have, or may have been released into the environment. (See Figure 2.attached to this Consent Order for a site map identifying the location of SWMUs). The twelve (12) SWMUs are as follows: (a) A RCRA hazardous waste storage area used for storing spent methylene chloride, copper- containing strainer solids, spent solvents, and Peneteck oil residues; (b) A storage /distribution center complex and boneyard used to store plant equipment and materials; (c) A general processing area; (d) An oil storage area; (e) A satellite accumulation area for methylene chloride laboratory wastes; (f) Containment reservoirs and sumps which can hold mixtures of contaminated, surface run -off waters and process waste waters from various locations around the Facility, in which contaminants could include SWL, VBL, copper, sodium hydroxide, and other wastes; I CONSENT ORDER - 1962 2 3 4 5 6 7 8 9 10 11 12 '3 14 15 16 17 18 19 20 21 22 23 24 25 27 (g) A storage and maintenance building area with four tanks once used for mersize storage, in which lubricating and parts cleaning solvents were used; (h) Storage tanks in the pier area which stored raw materials, byproducts, and waste streams including SWL, sodium hydroxide, toluene, isopropyl alcohol, and dioctylphthalate, and wastewaters of various.mixtures from plant -wide sources (from which at least three spills of VBL to the Duwamish River Waterway occurred and a leak of about 5,000 pounds of caustic soda from an underground pipe leading from ..the caustic holding tanks to the process area); (i) A VBLS clarifier and filter building; (j) Waste water treatment units (API separators) that were used to process facility waste water streams; (k) Site of former maintenance shop /storage building; and (1) North surface storage open ground area used to store other plant wastes. 4.9 Releases of hazardous wastes and /or hazardous constituents have occurred at and /or from the Facility. Recorded releases to the environment associated with specific Facility SWMUs as shown in Figure 2 include: (a) SWMU No. 3 At least five (5) recorded spills occurred consisting of toluene, VBL, and SWL. These spills discharged into the CONSENT ORDER - Page 21 March 31, 1 1 1 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 city sewer system and into the storm drainage system leading to the Duwamish River Waterway. Other releases identified in this area include spills of VBL which was used for weed control between 1952 and 1965, and spent mineral oil (Peneteck) and VBL, which dripped and leaked to the ground between 1952 and 1965. File documents also suggest that there was at least one (1) burial of sulfuric acid tank solids on site in 1969. Composite soil sampling at or near SWMU No. 3 in Sampling Areas H, I, J, as shown in Figure 3 attached hereto, identified the presence of hazardous constituents. (b) SWMU No. 5 Compressor oil dripped and leaked to the ground from this SWMU between 1952 and 1980. In 1979, a one -time disposal of VBLS was also reported. Composite soil sampling at or near SWMU No. 5 in Sampling Area K, as shown in Figure 3 attached hereto, identified the presence of hazardous constituents. (c) SWMU 'No. 11 This SWMU may have contained lubricating oils and cleaning solvents similar to solvents used in the current maintenance building on site. File documents suggest that in the maintenance shop, waste oils and solvents were disposed onto the ground between 1952 and 1980. Composite soil sampling at or near SWMU No. 11 in Sampling. Area A in Ficur "_ 3 identified the presence of hazardous constituents. March 31, 1993 3 4 5 6 7 8 9 LO 11 12 13 -4 15 16 17 18 19 20 21 22 23 24 25 27 2 8 of hazardous environment. by Dames and identified the presence of hazardous constituents at or near the following- listed SWMUs: ACTIVITY: SAMPLING AREA SWMUs SWMU No. 2 SWMU No. 6 SWMU No. 7 SWMU No. 10 SWMU No. 12 4.10 Several SWMUs have no known recorded releases waste and /or hazardous constituents However, analyses of composite soil Moore from the Sampling Areas shown CONSENT ORDER - Page Pentachlorophenol use Surface run -off waters and process wastewaters collection Mersize production area Process wastewater handling Plant Waste Storage to the samples, taken on Figure 3, F B, D C H, B G 4.11 Groundwater monitoring wells were installed at the Facility (See Figure 4 attached hereto for location of wells) during the Site Assessment study performed by Dames and Moore in 1986. Dames and Moore identified well DM -1A as being up- gradient from on -site activities. Dames and Moore identified wells DM -4 and DM -5 as being down - gradient from DM -1A. Samples were collected by Dames and Moore from groundwater monitoring wells DM -1A, DM -4, and, DM -5. The analytical results were as follows: 2 3 4 5 6 7 8 9 10 11 12 '.3 14 15 16 17 18 19 20 21 22 23 24 25 27 2S dell # Compounds Groundwater Perched Water Sample DM -1A Toluene Not Detected DM -4 Toluene 5,500 ppb 470,000 ppb DM -5 Toluene 330 ppb Groundwater sampled from well DM -4 identified toluene at a concentration of 5,500 ppb. Liquid sampled from boreholes DM -4 and DM -5 also showed above - background concentrations of toluene. In this liquid, laboratory results identified toluene (470,000 ppb in a DM -4 perched water sample and 330 ppb in a DM -5 perched water sample). The toluene levels identified in well DM -4 and ,boring DM -4 exceed the Safe Drinking Water standard for toluene, of 1,000 ppb, 56 Fed. Req. 3525 (January 30, 1991). 4.12 Hazardous wastes and /or hazardous constituents at the Facility have been and may continue to be released from the Facility into the soil and groundwater beneath and beyond the Facility. These hazardous wastes and hazardous constituents may be released from the Facility to the environment through adjoining surface water drainage areas, directly into and through the groundwater, into the air, into human work areas, and into faunal and floral habitat areas, and faunal migration routes. The proximity of the Facility to the Duwamish River Waterway makes this receptor an area of potential impact. Contaminants may migrate from aquifers beneath the Facility to }the Duwamish River Waterway. Groundwater in the upper aauifer CONSENT ORDER - Page 24 Mare. 31 1 993 2 3 4 5 6 7 8 9 LO L1 L2 11 1 .3 15 16 17 18 19 20 21 22 23 24 25 J 2 ' i , Ltimately migrates toward and discharges into the Duwamish River Waterway. Discolored water was found (in some boreholes) and was interpreted by Dames and Moore to be related to on -site production activities. 4.13 The hazardous wastes and /or hazardous constituents identified and /or referenced above, include documented and suspected carcinogens, and may pose a threat to human health and the environment. Ingestion, inhalation or dermal contact with hazardous constituents identified in the soils and groundwater at the Facility can cause a wide range of deleterious human health effects if the concentrations of these substances exceed health -based exposure standards. The levels of toluene contamination reported in liquid obtained from boring DM- (up to 470,000 ppb) are much higher than the 17,500 ppb level recommended for protection of aquatic life found at 45 Fed. Rea. 79318 (Nov. 28, 1990). Based on the *available data, it is unclear whether aquatic organisms in the adjacent Duwamish River Waterway have been affected, but those organisms are potential receptors of any contamination which has been or is migrating. V. U.S. EPA CONCLUSIOrS OF LAW AND DETERMINATIONS Based on the foregoing findings of fact, and the Administrative Record, U.S. EPA Region 10 has made the following conclusions of law and determinations: 5.1 Respondent is a company which is doing business in the State of Washington and is a "person" within the CONSENT ORDER - _ =ce March 31, 19 9 3 2 3 4 5 6 7 8 9 10 11 1 12 13_ 14 15 16 17 18 19 20 21 22 23 24 25 11 meaning of Section 1004(15) of RCRA, 42 U.S.C. § 6903(15), and Washington Rev. Code § 70 105.010(7). 5.2 Respondent is a generator, owner and operator of a facility that has operated or is operating under interim status subject to Section 3005(e) of RCRA, 42 U.S.C. § 6925(e). . 5.3 The Facility is a "facility" within the meaning of 42 U.S.C. § 6901(9). 5.4 Certain wastes and constituents thereof found at the Facility are hazardous wastes and /or hazardous constituents as defined by Section 1004(5) of RCRA, 42 U.S.C. § 6903(5). These are also hazardous wastes and /or hazardous constituents within the meaning of Section 3001 of RCRA, 42 U.S.C. § 6921, and 40 C.F.R. Part 261. Monsanto operated the facility after November 19, 1980 (the applicable date which renders facilities subject to the interim status requirements under Sections 3004 and 3005 of RCRA, 42 U.S.C. §§ 6924 and 6925) to October 1, 1986; Respondent has operated the Facility as a hazardous waste management facility from October 1, 1986 until April 1991. 5.5 There has been a release of hazardous wastes and /or hazardous constituents into the environment from Respondent's Facility, which may be continuing. It is necessary to determine the concentrations of these wastes and /or constituents at and beyond the Facility, and to assess whether such concentrations present unacceptable risks to human health or welfare or the environment. CONSENT ORDER - Page 26 'larch 3 .1.9':13 2 .9 :0 :1 a2 ?3 24 25 _6' 27 5.6 The actions required by this Consent Order are deemed necessary to protect human health, welfare or the environment. 5.7 Pursuant to the Findings of Fact in Section IV of this Order, U.S. EPA has determined the following: a. The nature of existing contamination has not been demonstrated to be limited to the compounds reported in the Dames and Moore studies. b. The horizontal and vertical extent of contaminant migration at and from the Facility has not been and cannot be, determined from data currently available to U.S. EPA. It is believed that the findings of the Landau and Associates Site Tssessment should provide an improved understanding of the extent of site contamination and U.S. EPA will consider such Assessment's data and analysis in approving any proposed RFI Workplan. c. The nature of the ground water contamination at the Facility and the migration within such ground water of hazardous constituents of materials previously stored or generated by Respondent may present an imminent and substantial endangerment to human health or the environment. VI. WORK TO BE PERFORMED 6.1 Based on the foregoing, and pursuant to Section 3008(h) of RCRA, 42 U.S.0 § 6928(h), Respondent agrees to perform, and is hereby ORDERED to perform the following acts, in jze manner and by the dates specified herein. All work CONSENT ORDER - Page 27 ! 31, 1 2 3 4 5 6 7 8 a 10 11 12 14 15 16 17 18 19 20 21 22 23 24 5 u ndertaken pursuant to this Consent Order shall be performed manner consistent with this Consent Order, its Attachments, and in a all items incorporated or to be incorporated herein, including the IM Plan, if required pursuant to this Consent Order, the RFI Plan, the CMS Plan, the CMI Plan, RCRA and all regulations • promulgated thereunder, and all applicable U.S. EPA guidance documents including, but not limited to, the "RCRA Groundwater Monitoring Technical Enforcement Guidance Document" ( "TEGD ") (October 1986), OSWER Dir. No. 8850.1, and the RFI Guidance, Volumes I -IV, ( "RFI Guidance Manual "), (May, 1989), U.S. EPA Document No. EPA 530 /SW- 89/031. These named guidance documents are incorporated herein by this reference. A. Stabilization /Interim Measure(s) 6.2 Respondent shall continually evaluate available data and assess the need or opportunity for interim measures throughout the duration of this Consent Order. Interim measures shall be used whenever possible to achieve the stabilization goals which are to control or abate immediate threats to human health and the environment, and to prevent or minimize the spread of contaminants while long -term corrective action alternatives are being evaluated. 6.3 Within sixty (60) days after the effective date of this Consent Order, Respondent shall submit to U.S. EPA and Ecology, an Interim Measures Assessment Report which evaluates available data, assesses the need and opportunity for Lnter;m measur =s C 0 S ... 1 L O t D E R ^ .. � .. . and, ',J' r noses any :DDrooriate interim .measures ?.arch 31, ' 2 3 4 5 6 11 7 8 9 10 11 12 1 3 i.4 15 16 17 18 19 20 21 22 23 24 25 rcessary to further the achievement of stabilization goals as identified in paragraph 6.2 above. In the event Respondent identifies an immediate threat to human health or the environment based on such information, Respondent shall immediately notify orally U.S. EPA's Project Coordinator, and shall notify U.S. EPA in writing within seven (7) days describing the immediacy and magnitude of any such identified threat. 6.4 If U.S. EPA identifies or determines that interim measures are necessary to further the achievement of stabilization goals as identified in paragraph 6.2 above, U.S. EPA will notify Respondent in writing. Within sixty (60) days (or by such later date as may be agreed to by U.S. EPA) of receiving U.S. EPA's written notification, Respondent shall -?ubmit to U.S. EPA an IM Workplan that identifies appropriate interim measures. If U.S. EPA determines that immediate action is required, then the U.S. EPA Project Coordinator may orally authorize Respondent to act prior to Respondent's submittal of the IM Workplan. This IM Workplan may be required by U.S. EPA to include: A. Interim Measure Description and Objectives; B. A Health and Safety Plan; C. A Public Involvement (community relations) Plan, as needed; D. A Data Collection Quality Assurance Plan, as needed; E. A Data Management Plan, as needed; F. Bench Scale Treatability Study Plan, as needed; 27 I r CONSENT ORDER - Pace 2'•j ''arc::. _ , - 2 3 4 5 6 7 8 9 10 11 } } 12 1 14 15 16 17 18 19 20 21 22 23 24 25 G. Design Plan and Specifications; H. An Operation and Maintenance Plan; I. A Project Schedule; J. An Interim Measure Construction Quality Assurance Plan; and K. Reporting Requirements. 6.5 The IM Workplan shall ensure that the interim measures are designed to mitigate the identified threat and are consistent with, and can be integrated with, any long term corrective measures at the Facility. The plan shall describe in detail the procedures to be used by the Respondent for the implementation of the proposed interim measures. 6.6 The IM Workplan shall be submitted for U.S. EPA review and approval in accordance with the procedures in Section VII (Submissions /Agency Approval /Additional Work). The Respondent shall perform and implement the interim measures identified and described in the undisputed portions of the U.S. EPA - approved IM Workplan in accordance with the schedules therein contained. Upon agreement or after a final dispute resolution decision on any disputed portions of the IM Workplan, Respondent shall perform and implement interim measures contained in those portions of the IM Workplan in accordance with the schedules therein. 6.7 If at any time Respondent identifies the need or opportunity to conduct an interim or stabilization measure, `hen Respondent shall submit a written request to U.S. EPA for CONSENT ORDER - ?:".q.:?. 30 March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 27 review and approval of the proposed action, unless emergency action is required. Any interim or stabilization measures must be in the public interest and, to the maximum extent practicable, be consistent with future corrective actions. This requirement shall not apply to normal maintenance and operations activities, to the extent that these activities do not affect interim, 'stabilization or corrective measures, or investigations carried out pursuant to this Consent Order. B. RCRA FACILITY INVESTIGATION ( "RFI ") 6.8 Within one hundred and fifty (150) days after the effective date of this Consent Order, Respondent shall submit to U.S. EPA for its review and approval, a RFI Workplan. A copy of the RFI Workplan shall also be submitted to Ecology. The RFI Workplan shall be developed in accordance with the RFI objectives and requirements set forth in Attachments A and B hereto and incorporated herein by this reference, RCRA, all regulations promulgated thereunder, the U.S. EPA RFI Guidance Manual, and all other applicable U.S. EPA guidances and policies. 6.9 The RFI Workplan shall document the procedures and provide a specific schedule that the Respondent shall use to conduct those investigations, when deemed necessary by U.S. EPA, to: (a) characterize the environmental setting; (b) characterize sources(s] and nature of hazardous wastes and constituents; COUSENT ORDER - Page Xarrtl 3 1993 2 3 4 5 6 7 8 9 10 11 necessary by U.S. EPA, include the following: 12 17.- -. ) l 14 15 16 17 18 19 20 21 22 23 24 25 2 (c) characterize concentration, rate, and extent of contamination released at and from the Facility; (d) identify any additional SWMUs or AOCs; (e) develop a Risk Assessment; (f) identify, and implement Stabilization /Interim Measure, and /or Corrective Measure technologies potentially applicable to the Facility; 6.10 In accordance with the provisions of Attachment A herein, the RFI Workplan shall, when deemed (a) Project Management Plan; (b) Data Collection Quality Assurance Plan; (c) Data Management Plan; and (d) Public Involvement (community relations) Plan. 6.11 The RFI Workplan shall detail the methodology for determining the presence, nature, extent, direction, and rate of movement of any hazardous wastes and /or hazardous constituents from or to all affected media within and beyond the Facility boundary. 6.12 The RFI Workplan shall include provisions for identification and characterization of any releases of Appendix IX, 40 C.F.R. Part 264 (hazardous constituents), as specified in Attachment A, from SWMUs and AOCs at the Facility. 6.13 The RFI Workplan shall detail the methodology for assessing the potential risk tc human health and he CONSENT ORDER - Pace • ..arc 2 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 nvironment. This Workplan must be in accordance with U.S. EPA guidance EPA /540/1- 89/002; "EPA Region 10 Supplemental Risk Assessment Guidance for Superfund," dated August 16, 1991; and "Guidelines for Developing Health -Based Cleanup Levels at RCRA Sites in Region 10," U.S. EPA guidance 910/9 -92 -019. The RFI Workplan must also include a detailed description of the methodology proposed to address the four main•components of risk assessment: Contaminant Identification; Exposure Assessment; Toxicity Assessment; and Risk Characterization. 6.14 Within three hundred and twenty (320) days after receipt of written U.S. EPA approval of the final RFI Workplan, Respondent shall submit a Draft RFI Report to U.S. EPA for its review and approval, which shall detail the findings of R espondent's site investigatory activities, and shall discuss and analyze the existence or threat of release of hazardous constituents, substances, pollutants,' or contaminants at or from the Facility. Within twenty (20) days after Respondent's receipt of comments from U.S. EPA on the Draft RFI Report, Respondent shall submit the Final RFI Report in accordance with the procedures set forth in Section VII. C. RISK ASSESSMENT /MEDIA CLEANUP STANDARDS 6.15 Within thirty (30) days of the date the Respondent submits the Final RFI Report, Respondent shall submit to U.S. EPA the Human Health and Ecological Risk Assessment ( "Risk Assessment ") Report and Proposed Media Cleanup Standards =SENT .2RDER - Page 33 rrF. nwwlsh; March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 '3 supporting the limits specified, and the location at which the 14 limits shall be met. 15 16 17 18 19 20 21 22 23 24 25 "MCSs ") in accordance with the U.S. EPA- approved Risk Assessment methodology in the U.S. EPA - approved RFI Workplan. 6.16 A MCS shall be proposed for each hazardous waste and hazardous constituent released from any of the SWMUs or AOCs addressed by this Consent Order and identified as a Contaminant of Potential Concern during the risk assessment process. The MCSs will be used for measuring the necessity for and /or the degree of protection afforded by the corrective measures contemplated under Subsection D below. Respondent shall propose a MCS for each Contaminant of Potential Concern released into each of the media identified in the Final RFI Report. For each standard, Respondent shall include data justifying and 6.17 After Respondent submits the Risk Assessment Report and proposed MCSs, U.S. EPA shall establish final MCSs and the points of compliance or locations at which the MCSs must be met. The Respondent shall design the corrective measures so that the established MCSS can be achieved by the preferred corrective measures chosen by U.S. EPA from those identified in the CMS. D. Corrective Measures Study (CMS) 6.18 Within forty -five (45) calendar days of written receipt of the final EPA established MCSs and points of compliance, Respondent shall submit a Draft CMS Workplan to EPA in accordance with the CMS Scope of Work in Attachment C and in ' NS ENT ORDER - Page :1 March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 13 11. 15 16 17 18 19 20 21 22 23 24 25 r accordance with EPA guidance documents. Consent Order is incorporated herein by reference. 6.19 The CMS shall detail the methodology for developing and evaluating the potential corrective action alternatives to remediate the Facility. Respondent treatment technologies. as site and off -site for the CONSENT ORDER Pace 35 Attachment C 6.20 Potential Corrective Measures that involve any contamination at or released from shall consider the use of innovative a final corrective measure for use on- containment, treatment, remediation, treatment shall require treatability, studies except Respondent can otherwise show to EPA's satisfaction not needed. Where treatability studies are needed, t this and /or disposal of such contamination. Innovative treatment technologies shall be studied in accordance with the CMS Scope of Work and the EPA approved CMS Workplan. Respondent may consider and collect necessary information to propose the use of a Corrective Action Management Unit as provided in 40 C.F.R. 264.552. where the that they are Respondent shall include in the CMS Workplan a description of the type (e.g., bench versus pilot) and design of the study or studies. Within ninety (90) days after Respondent 6.21 receives written notice from EPA of approval of the CMS Workplan, Respondent shall submit to EPA a Corrective Measures Study (CMS) Report which contains the following information, as required by U.S. EPA, for each corrective measure studied: r .r h ' _, ` 9 2 3 4 5 6 7 8 9 10 11 12 17 1 1 i ) 14 15 16 17 18 19 20 21 22 23 24 25 2. (a) an evaluation of any treatability studies performed; (b) an evaluation for the overall protectiveness of human health and of the environment; (c) ability to attain the MCS([s]); (d) ability to control the source(s) of release; (e) an estimate and analysis of quantity, volume, and /or toxicity of the waste generated, including, but not limited to, contaminated soil, sludge and groundwater. (f) methods to minimize the quantity, volume, toxicity and mobility of waste to be generated during the implementation of the approved alternative. (g) an assessment of relevant institutional and legal requirements including the effects of any relevant federal, state or local environmental or public health standards, regulations, and /or ordinances on the design, operation, and timing of each corrective measure alternative; (h) an assessment of short -term and of long -term reliability and effectiveness. This shall include an estimate of short -term and long -term reduction of toxicity, mobility, and volume of waste. (i) an evaluation of ease of implementation; (j) an estimate of the cost including capital and annual operation and maintenance costs; CONSENT ORDER - Page 26 3 1.9' 2 3 4 5 6 7 8 9 10 11 12 , 14 15 16 17 18 19 20 21 22 23 24 25 27 ")6 (k) a recommendation as to which corrective measure((s]), in the Respondent's opinion, is best suited to meet the MCSs. 6.22 As part of the Corrective Measures Study, Respondent also agrees to consider waste minimization options. Respondent shall provide the following information for the preferred corrective measures chosen by U.S. EPA: (a) an estimate and analysis of the quantity, volume, and toxicity of the waste generated, including, but not limited to, contaminated soil, sludge and groundwater, and (b) methods to minimize the quantity, volume, toxicity and mobility of waste to be generated during the implementation of the approved alternative. Respondent shall refer to EPA's Waste Minimization Opportunity Assessment Manual and Draft Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program. (54 Fed. Rea. 25056 June 12, 1989) 6.23 After Respondent submits the CMS Report, EPA will either approve or disapprove the Report in accordance with Section VII. If EPA approves the CMS Report, it shall become final. If EPA disapproves the CMS Report, EPA shall specify the deficiencies and shall establish a time frame within which Respondent shall submit a modified report. If this modified CONSENT ORDER - Page 37 March 2 3 4 5 6 7 8 0 10 11 12 �.3 14 15 16 17 18 10 20 21 22 23 24 25 ;report is not approved, EPA may require further modification or make such modification as deemed necessary. E. CORRECTIVE MEASURES IMPLEMENTATION (CMI) 6.24 Subject to Paragraphs 6.27 through 6.29 below, within sixty (60) days of Respondent's receipt of notification of EPA's selection of the corrective measure, Respondent shall submit to EPA a Corrective Measures Implementation Workplan ( "CMI Workplan "). The CMI Workplan is subject to approval by EPA and shall be performed in a manner consistent with the CMI Scope of Work contained in Attachment D. Attachment D to this Consent Order is incorporated herein by this reference. The CMI Workplan shall be developed in accordance with, at a minimum, RCRA and other applicable Federal laws, their implementing regulations, and relevant EPA guidance documents. 6.25 The CMI Workplan shall be designed to facilitate the design, construction, operation, maintenance and monitoring of corrective measures at the Facility. In accordance with Attachment D herein, the CMI Workplan shall also include: (1) a Program Management Plan; (2) a Community Relations Plan; (3) Design Plans and Specifications;/(4) an Operation and / Maintenance Plan; /(5) a Cost Estimate;, -(6) a Project Schedule; and (7) a Construction Quality Assurance Plan; (8) Data Collection Quality Assurance Plan; "(9) Data Management Plan; and (10) Health and Safety Plan. 6.26 The CMI Workplan shall be submitted for U.S. )EP=. review and approval in accordance with the procedures set COUSENT C.° vDE ti - Pace_ 38 tar 1 199 forth in Section VII. Within thirty (30) days after Respondent 2 receives written approval from U.S. EPA of the CMI Workplan, 3 Respondent shall implement the CMI Workplan in accordance with 4 the schedule therein. 5 6.27 Notwithstanding any other provision in this 6 Consent Order, the parties agree that if conditions contained in 7 Paragraph 6.28 below are met and Respondent does not want to . 8 implement the final corrective measure selected by U.S. EPA under 9 consent, Respondent may withdraw its consent to implement said 10 corrective measure. To be effective, such withdrawal of consent 11 must be in writing, signed by the company signatory(ies) to this 12 Consent Order, and received by the Hazardous Waste Division ? ,Director no later than fifteen (15) days from receipt of the } 14 final dispute resolution decision by U.S. EPA. 15 6.28 Respondent's right to withdraw its consent is 16 limited to implementation of the corrective measure selected by 17 U.S. EPA only and such right to withdraw shall not accrue until: 18 19 20 21 22 23 24 25 (1) U.S. EPA has selected a final corrective measure as provided in this Consent Order; (2) and U.S. EPA issues a final decision under the dispute resolution procedures contained in Section XVI hereto. Nothing in this Section shall affect nor diminish Respondent's consent to any other provision in this Order, including its obligations hereunder to conduct interim measures, a RFI, a CMS, additional work as provided in Section VII, or issuance of stipulated penalties, nor Respondent's waiver of a public hearing under Section 3008 (b) , 42 U.S.C. 5 6923 (b) , and 40 � .." .. CRfl; _. - P 3 M arch , 1 99 J 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 27 1 CFR Parts 22 and 24 as to the issuance /entry and validity of the Order as provided in Section I, Paragraph 1.2 of this Consent Order. 6.29 If Respondent exercises its right to withdraw its consent to implement the corrective measure as provided in this Section, U.S. EPA retains all authorities it has under RCRA and CERCLA to enforce implementation of the corrective measure or conduct response actions related to the Facility. VII. AGENCY APPROVAL /SUBMISSIONS /ADDITIONAL WORK A. EPA APPROVALS 7.1 Unless otherwise specified, and with the exception of monthly progress reports, EPA will review any draft Workplan, report, specification or schedule submitted pursuant to, or required by this Consent Order. EPA will provide its written approval, disapproval, comments and /or modifications to the Respondent. When EPA approves in writing, the submission becomes final. 7.2 Upon approval of any Workplan or report, Respondent shall commence work and implement the tasks required by the approved Workplan within thirty (30) days of its receipt of EPA's approval letter. Such work and tasks to be implemented must be performed in accordance with the standards, specifications and schedules stated in the approved Workplan as it may be modified by U.S. EPA pursuant to Section XXIV of this Consent Order. CONS Ma r'h 31, ` 993 2 3 4 5 6 7 8 9 10 11 12 1 3 L4 15 16 17 18 19 20 21 22 23 24 25i 7.3 Respondent shall submit an initial draft Workplan, report, specification or schedule pursuant to the schedules required by this Consent Order. U.S. EPA will review such document and provide Respondent with its approval, comments and /or required modifications. If Respondent agrees with U.S. EPA's comments and /or required modifications, Respondent shall submit a revised final document to U.S. EPA within thirty (30) days of its receipt of U.S. EPA's comments and /or required modifications. If Respondent disagrees or has questions concerning U.S. EPA's comments and /or required modifications, Respondent must, within five (5) days of receipt of U.S. EPA's comments or required modification request in writing a meeting or telephone conference to resolve the matter. Such written request 4i11 establish a thirty (30) day informal resolution period, and shall include a statement of the concerns Respondent wishes to address in the meeting or telephone conference. The parties will use their best efforts to informally resolve the matters in question. The thirty (30) day informal resolution period shall extend the due date for the resubmittal of the document by the same number of days. The thirty (30) day informal resolution period set forth in this paragraph shall apply only to the initial draft work plan, report, specification or schedule submitted by Respondent, unless U.S. EPA agrees to provide such a period on a subsequent draft. Notwithstanding provisions of this paragraph, upon receipt of a written disapproval letter, Respondent may request an extension to the thirty (30) day 11 CONSENT ORDER - Page 41 March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 ) 24 25 informal resolution period which may be granted in U.S. EPA's sole discretion. If such extension is granted, the due date for the resubmittal of the document will be extended by the same number of days as the extension. 7.4 If agreement is reached within the informal resolution period, Respondent shall submit a revised, final draft plan or report which incorporates the agreed upon comments and /or modifications within thirty (30) days of reaching agreement. If agreement cannot be reached within the thirty (30) day period or extension thereof by U.S. EPA, U.S. EPA shall send a written letter of disapproval to Respondent. Within twenty (20) days of receipt of the written disapproval letter, Respondent shall submit a revised, final draft plan, report, specification or schedule incorporating U.S. EPA's comments and /or modifications unless it invokes the dispute resolution procedures pursuant to Section XVI of this Consent Order. 7.5 Where U.S. EPA and Respondent have reached agreement on a portion of any plan, report, specification or schedule required by this Consent Order, U.S. EPA may approve and make final those agreed upon provisions while other provisions may be subject to dispute resolution. Respondent shall commence work or perform tasks that has been approved and is otherwise undisputed within thirty (30) . days of receipt of U.S. EPA's approval letter. d - .., , r , - . ,.,, 7.6 Verbal advice, suggestions, or comments given by U.S. EPA reDr?sentatives will not constitute an official March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 13_ 14 15 16 17 18 19 20 21 22 23 24 25 ?7 28 approval, nor shall any verbal approval or verbal assurance of approval be considered binding unless related to emergency field activities as provided in this Order. 7.7 Any noncompliance with an approved U.S. EPA document or determination under the dispute resolution provision of this Consent Order constitutes a violation of this Consent Order subject to penalties under Section XV with the exception of Respondent's right to withdraw its consent set forth in Paragraph 6.27 above. B. SUBMISSIONS 7.8 Beginning with the first full month following the effective date of this Consent Order, and throughout the period that this Consent Order is effective, Respondent shall } provide U.S. EPA with monthly progress reports in the first year of the project. Following the first year, an appropriate schedule for submitting progress reports will be agreed upon between EPA and Respondent. Each report shall be due on the tenth day of the following month. The progress reports shall conform to requirements in the relevant Scopes of Work contained in Attachments A, B, C, and D. 7.9 Unless otherwise specified, all documents, including Workplans, reports and other correspondence, submitted by Respondent pursuant to this Consent Order shall be printed on recycled paper and delivered to the following persons at the addresses indicated, and to such other persons as U.S. EPA mar \specify by written notice to Respondent: COUSENT ORDER - Pace 43 Y. _ 2 3 4 5 6 7 8 9 10 11 12 1 1 . 14 15 16 17 18 19 20 21 22 23 24 25 27 (A) Three (3) copies •f all documents to be submitted .b to U.S. EPA should be sent to: (B) Tom ost One copy (C) One copy of each document to be submitted by Respondent should be sent to: C. PROPOSED CONTRACTOR /CONSULTANT 7.10 All work performed pursuant to this Consent Order shall be under the direction and supervision of a professional engineer, hydrologist, or geologist with expertise in hazardous waste site cleanup. The Respondent's contractor, subcontractor, or consultant shall have the technical expertise sufficient to adequately perform all aspects of the work for which they are responsible. Within ten (10) days after the effective date of this Consent Order, Respondent shall notify U.S. EPA in writing of the name, title and qualifications of the primary consultants and their personnel proposed to be used in carrying out the terns of this Consent Order. U.S. EPA will be CONSENT ORDER - Pace 44 U.S. EPA Project Coordinator U.S. EPA, Region 10 1200 Sixth Avenue, HW -104 Seattle, Washington 98101 of all documents should be sent to: Byung Maeng � �� 2 . Department of Ecology 5r' NWRO 3890 160th Avenue S.E. Bellevue, WA 98008 -5452 Attn: Ade Bright FIFER Environmental Associates 32724 6th Avenue S.W. Federal Way, WA 98023 • March , 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 /notified of proposed primary contractors and subcontractors managed by the primary consultants as they are selected. U.S. EPA reserves the right to reject the Respondent's proposed consultant, contractor and /or subcontractor within five (5) days of Respondent's notification. If U.S. EPA disapproves a proposed consultant, contractor or subcontractor, then Respondent must within twenty (20) _days. of U.S. EPA's disapproval notice, notify U.S. EPA in'writing of the name and title, and if appropriate qualifications, of any replacement. U.S. EPA's disapproval shall not be subject to review under the dispute resolution provisions in Section XVI. D. ADDITIONAL WORK 7.11 U.S. EPA may determine or Respondent may propose that certain tasks, including investigatory work, engineering evaluation, or procedure /methodology modifications are necessary in addition to the tasks and deliverables included in a Workplan when new information, unknown conditions or protection of human health and the environment indicates that such additional work is necessary to melt the purposes set forth in the Statement of Purpose (Section III). U.S. EPA shall request in writing that Respondent perform the additional work in this situation and shall specify the basis and reasons for U.S. EPA's determination that the additional work is necessary. Within fifteen (15) days after the receipt of such request, Respondent shall notify U.S. EPA of its willingness to perform �� additional work cr request a meeting with U.S. EPA to discuss D' ;S CORD - Pace - March 31, 1993 W:a�iS si�ec2:suiieiA`r 1 2 3 4 5 6 7 8 9 10 11 12 •ork performed by Respondent under this paragraph shall be 14 performed in a manner consistent with this Consent Order. 15 VIII. OUALITY ASSURANCE 16 17 18 19 20 21 22 23 24 25 �1 27 the additional work requested. If, after such meeting, Respondent disagrees with U.S. EPA's request for additional work, Respondent may invoke dispute resolution in accordance with the Section XVI of this Consent Order. 7.12 If dispute resolution is not invoked 'on U.S.' EPA's written request for additional work, within sixty (60) days of receipt of U.S. EPA's notice, Respondent shall submit for U.S. EPA approval a Workplan incorporating the additional work. U.S. EPA's review and approval of such Workplan shall be subject to the procedures set forth in Section VII. Upon written approval of the Workplan, Respondent shall implement the Workplan in accordance with the schedule contained therein. All additional CONSENT ORDER - P are 4 8.1 Throughout all sample collection and analysis activities, performed pursuant to this Consent Order, Respondent shall use quality assurance, quality control, and chain -of- custody procedures, as identified in Attachment B of this Consent Order and as maybe supplemented in approved Workplans. 8.2 In addition, Respondent shall: (a) Notify U.S. EPA and Ecology of all sampling events at least ten (10) days prior to each sampling event. (b) Inform the U.S. EPA Project Coordinator at least thirty (30) days in advance, which laboratories will be used by Respondent and ensure that U.S. EPA cerscnn March 31, 199 2 3 4 5 6 7 8 9 10 11 12 ' 3 11 14* 15 16 17 18 19 20 21 22 23 24 25 27 1 and U.S. EPA- authorized representatives have reasonable access to the laboratories and their personnel. (c) Ensure that laboratories utilized by Respondent for analysis of samples taken pursuant to this Consent Order perform all analyses according to accepted U.S. EPA methods as set forth in Attachment B hereto. (d) Ensure that all laboratories used by Respondent for analysis of samples taken pursuant to this Consent Order maintain a QA /QC program that, at a minimum, meets the requirements in SW 846. Such laboratories may be required by U.S. EPA to demonstrate the quality of analytical data. Should the demonstration reveal deficiencies in a laboratory's performance or QA /QC, resampling and analysis may be required. 8.2 All data submitted to U.S. EPA must be of known and documented quality. Respondent will be held accountable by U.S. EPA for ensuring and monitoring the quality of data obtained by its contract laboratory. U.S. EPA reserves the right to reject any data not generated in accordance with SW -846 or other protocols approved by U.S. EPA as required by this Consent Order. IX. COMMUNITY RELATIONS /PUBLIC COMMENT AND PARTICIPATION 9.1 EPA may provide the public with an opportunity to review and comment on any approved IM Workplan except for Interim Measures performed due to emergency conditions. EPA may also provide the public with an opportunity CONSENT ORDER - Page 47 'to review 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 and comment on the final draft of the Corrective Measures Study Report and a description of EPA's proposed corrective measure(s) and EPA's justification for proposing selection of such corrective measure(s) (the "Statement of Basis "). 9.2 Following the public review and comment period, EPA will notify Respondent of the final corrective measure selected by EPA. The notification will include EPA's reasons for selecting the corrective measure. EPA may approve the Corrective Measures Study Report or require that the Respondent revise the Report or perform additional corrective measure studies. X. ON -SITE AND OFF -SITE ACCESS 10.1 U.S. EPA, its contractors, subcontractors, employees, or any U.S. EPA representatives are authorized to enter at all reasonable times and freely move about the Facility pursuant to this Consent Order for the purposes of, inter alia: interviewing Facility personnel and contractors; inspecting records, operating log8, and contracts related to the Facility; reviewing the progress of the Respondent in carrying out the terms of this Consent Order; conducting such tests, sampling, or monitoring as U.S. EPA or its Project Coordinator deem necessary, using a camera, sound recording, or other documentary type equipment; and verifying the reports and data submitted to U.S. EPA by the Respondent. Because it is currently not in perat:.on, if the Facility is locked or otherwise closed to March 31, 1993 :)rkers and visitors during regular business hours or at an 2 otherwise reasonable time, Respondent shall make the Facility 3 accessible to U.S. EPA within four (4) hours of oral notice of 4 U.S. EPA's intent to enter the Facility. The Respondent shall 5 permit such persons to inspect and copy all records, files, 6 photographs, documents, and other writings, including all 7 sampling and monitoring data, that pertain to work undertaken Respondent shall grant. the same 8 pursuant to this Consent Order. 9 rights of access and availability of split samples and other 10 oversight activities to Ecology and its contractors and /or 11 representatives that are provided to U.S. EPA under this Consent 12 Order. All persons entering the site shall meet applicable health ", and safety requirements in accordance with the Site Safety Plan. 1411 10.2 To the extent that work being performed Consent Order must be done on property not 1511 pursuant to this 1611 or controlled by 17 efforts to obtain access agreements 18 required by this Consent Order from 23 24 25 CONSENT 3RDE. - r ,, 49 Respondent, Respondent shall use its best of owned necessary to complete work the present owner(s) of such approval of any Workplan for 19 property within thirty (30) days 20 which site access is required or 21 access became known to the Respondent. 22 this paragraph shall include, at a minimum, from Respondent to the present owners of such property requesting access agreements to permit Respondent, U.S. EPA and its authorized representatives and Ecolo4Y and its authorized property and, if requested by an representatives to access such _ of the date that the need Best efforts as used in a certified letter 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 off -site owner, an offer to provide reasonable compensation. Respondent does not receive any response to its second access easement request to an off -site owner or operator controlling access to property within thirty (30) days of receipt of such second request, then Respondent may consider lack of response as denial of access. Any such access agreement shall provide access to U.S. EPA and its. repr.esentatives and Ecology and its representatives, and.Respondent shall ensure that U.S. EPA's Project Coordinator has a copy of any access agreement(s). In the event that agreements for access are not obtained, Respondent shall notify U.S. EPA, in writing, within ten (10) days thereafter regarding both the efforts undertaken to obtain access and its failure to obtain such agreements. The Respondent agrees to indemnify the United States Government as provided in Section XXI (Indemnification) for any and all claims arising from activities on such property. In the event U.S. EPA obtains access, Respondent shall undertake U.S. EPA - approved work on such property. If 10.3 Nothing in this section limits or otherwise affects U.S_ EPA's right of access and entry pursuant applicable law, including RCRA and CERCLA. 10.4 Nothing in this section shall be construed to limit or otherwise affect the Respondent's liability and obligation to perform corrective action including corrective action beyond the Facility boundary, notwithstanding the lack of access. EPA nav determine that additicnal on -site measures must CONSENT ORDER - Pace 50 March 3 1 , 19' 2 3 4 5 6 7 8 9 _0 Ll L2 11 14 15 16 17 18 19 20 21 22 23 24 25 { taken to address releases beyond the Facility boundary if access to off -site areas cannot be obtained. XI. SAMPLING AND DATA /DOCUMENT AVAILABILITY 11.1 The Respondent shall submit to U.S. EPA the results of all sampling and /or tests or other data generated by its employees, divisions, agents, consultants, or contractors with respect to the implementation of the.Consent Order. 11.2 Respondent shall notify U.S. EPA and Ecology, in writing, at least ten (10) days before engaging in any field activities, such as well drilling, installation of equipment, or sampling. If Respondent believes they must commence emergency field activities without delay, Respondent may seek emergency telephone authorization from the U.S. EPA Project Coordinator or if the Project Coordinator is unavailable, his /her Section Chief, to commence such activities immediately. At the request of U.S. EPA, Respondent shall provide or allow U.S. EPA or its authorized representative or Ecology or its authorized representatives to take split samples or duplicate samples of all samples collected by Respondent pursuant to this Consent Order. Similarly, at the request of Respondent, U.S. EPA and Ecology shall allow Respondent or its authorized representative(s) to take split or duplicate samples of all samples collected by theta under this Consent Order. 11.3 Respondent may assert a business confidentiality claim covering all or part of any information )submitted to U.S. EPA pursuant to this Consent Order. Any j CDil ORDER :.larch 31, 19 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 17 assertion of confidentiality must be accompanied by responses to the questions listed at 40 C.F.R. § 2.204(e)(4) or such claim shall be deemed waived. Information determined to be confidential by U.S. EPA shall be disclosed only to the extent permitted by 40 C.F.R. Part 2. If no such confidentiality claim' accompanies the information when it is submitted to U.S. EPA, the information may be made available to the public by U.S. EPA without further notice to the Respondent. Respondent agrees not to assert any confidentiality claim with regard to any physical or analytical data obtained pursuant to this Consent Order. XII. RECORD PRESERVATION 12.1 Respondent agrees that they shall retain, during the pendency of this Consent Order and for a minimum of six (6) years after its termination, all data, records, and documents now in its possession or control or which come into its CONSENT ORDER - Pace 52 possession or in the possession of its division, officers, directors, employees, agents, contractors, successors, and assigns which relate in any way to this Consent Order or to the work performed pursuant to this Consent Order, or to hazardous waste management and /or disposal at the Facility. Respondent shall make such records available to U.S. EPA for inspection or shall provide copies of any such records to U.S. EPA upon written request. Respondent shall instruct its contractors, consultants, and agents to preserve all documents and information of whatever kind relating to the Facility or the performance of work. 25 /Respondent shall notify U.S. EPA in writinc thirty (30) days march 31, 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 26 28 prior to the destruction of any such records, and shall provide U.S. EPA with the opportunity to take possession of any such records. CONSENT ORDER - Page 53 XIII. PROJECT COORDINATOR 13.1 Within ten (10) days of the effective date of this Consent Order, U.S. EPA and Respondent shall each designate - a Project Coordinator. The:parties may change their Project Coordinator but agree to provide at least ten (10) days written notice prior to changing Project Coordinator. Respondent shall notify U.S. EPA, in writing, of the Project Coordinator it has selected. Each Project Coordinator shall be responsible for overseeing the implementation of this Consent Order and for designating a person to act in his /her absence. The U.S. EPA )Project Coordinator will be U.S. EPA's designated representative at the Facility. All communications between Respondent and U.S. EPA, and all documents, reports, approvals, and other correspondence concerning the activities performed pursuant to the terms and conditions of this Consent Order shall be directed through the Project Coordinators. U.S. EPA's initial Project Coordinator shall be:= Tom Post U.S. Environmental Protection Agency RCRA Compliance Section 1200 Sixth Avenue, HW -104 Seattle, Washington 98101 Respondent's initial Project Coordinator shall be : Edwin Liu Rhone - Poulenc, Inc. CN7500 Cranbury, NJ 08512 Marc:. 1993 2 3 4 5 6 7. 8 0 10 11 12 1 - . be sent by fax, express service or certified mail receipt 14 15 16 17 18 19 20 21 22 23 24 25 13.2 The absence of the U.S. EPA Project Coordinator or Respondent's Project Coordinator from the Facility shall not be cause for the stoppage of work. XIV. NOTIFICATION AND DOCUMENTATION CERTIFICATION 14.1 Unless otherwise provided, all written notices of approvals, disapprovals, noncompliance or other decisions by U.S. EPA pursuant to this Consent Order shall be deemed effective upon receipt at the office of Respondent's designated Project Coordinator. Unless otherwise provided, any written notices required by Respondent pursuant to this Consent Order shall be deemed effective upon receipt at the office of U.S. EPA's designated Project Coordinator. All written notices requested. 14.2 Any notice, report, certification, data presentation or other document submitted by Respondent pursuant to this Consent Order which discusses, describes, demonstrates, supports any finding or makes any representation concerning Respondent's compliance with any requirement of this Consent Order shall be certified by a responsible corporate officer of Respondent or a duly authorized representative. A responsible officer means: (a) a president, secretary, treasurer or vice - president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision- making functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating facilities 27 =SENT ORDER - Pace c4 March 21 e 1c Z W CL JU 0 CO 0 - = H � w w 0 2 LL • d = w F- _ Z I- I -- 0 Z F- w Lu 2 U 0 O P O H- W W 2U U. O W Z U= O Z 1 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 261 employing more than 250 persons or having gross annual sales or expenditures exceeding $35 million (in 1987 dollars when the Consumer Price Index was 345.3), if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures. A person is a duly authorized representative only if: (a) the authorization is made in writing by a responsible officer; (b) the authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator of a well or a well field, superintendent or position of equivalent responsibility, or an individual or position having overall responsibility for the company's environmental matters at the regulated facility or ( )activity (A duly authorized representative may thus be either a named individual or any individual occupying a named position.); and (c) the written authorization is submitted to the U.S. EPA. 14.3 The certification of the responsible corporate officer or duly authorized representative required by paragraph (3) above of this Consent Order shall be in the following form: 1 CCONSE:1T ORDER - Page 55 1 "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to evaluate the information submitted. I certify that the information contained in or accompanying this (type of :•! a r U 2 3 4 5 6 7 8 9 14 15 16 17 18 19 20 21 22 23 24 25 submission] is true, accurate, and complete. As to (the /those identified positions] of this [type of submission] for which I cannot personally verify (its /their] accuracy, I certify under penalty of law that this (type of submission] and all attachments were prepared in accordance with procedures designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who may manage the system, or those directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." XV. DELAY IN PERFORMANCE /STIPULATED PENALTIES 15.1 Unless there has been a written modification by U.S. EPA of a compliance date, a written ;,codification by U.S. EPA of an approved Workplan condition, or excusable delay as defined under the "Force Majeure and Excusable Delay" provision, if the Respondent fails to comply with any term or condition set forth in the Consent Order and its Attachments, or any Workplans o under this Consent Order in the time or manner specified Respondent shall pay stipulated penalties as set forth iI ! I _CNSENT - :':arch 31, 1 993 2 3 4 5 6 7 8 9 10 11 12 11 14 15 16 17 18 19 20 21 22 23 24 25 )below upon written demand of U.S. EPA. The stipulated penalties below may apply in U.S. EPA's discretion to work that is not of acceptable quality to U.S. EPA consistent with the relevant Workplan or is not submitted within the specified time schedule approved under this Consent Order. U.S. EPA may, in its discretion, waive imposition of stipulated penalties if it determines that Respondent has attempted in good faith to comply with this Order or in the event of timely cure of defects in initial submissions. (A) For failure to commence, perform, and complete field work in a manner specified in the approved Workplan or at the time required pursuant to this Consent Order: $ 500 per day for the first one to seven (1 -7) days of delay, and $ 1,000 per day for each day of delay thereafter; (B) For failure to complete and submit any Workplans or reports, other than progress reports, in acceptable quality to U.S. EPA or at the time required pursuant to this Consent Order: $ 500 per day for the first one to seven (1 -7) days of delay, $ 1,500 per day for eight to twenty -one (8 -21) days of delay, and $ 3,000 per day for each day of delay thereafter; (C) For failure to complete and submit other deliverables in acceptable quality to U.S. EPA or at the time required pursuant to this Consent Order: COUSENT ORDER - P' 'e - ,,r_ -1Q.. 2 3 4 5 6 7 8 9 10 11 12 16 17 18 19 20 21 22 23 24 2 5 • S 250 per day for the first one to seven (1 -7) days of delay, $ 500 per day for eight to twenty -one (8 -21) days of delay, and $ 750 per day for each day of delay thereafter; (D) For failure to comply with any other provisions cf this Consent Order: $ 250 per day for the first one to seven (1 -7) days of noncompliance, $ 500 per day for eight to twenty -one (8 -21) days of noncompliance, and $ 1,000 per day for each day of noncompliance thereafter. 15.2 All penalties shall begin to accrue on the day after the completed performance is due or the day non- compliance occurs, and shall continue to accrue through the final day of correction of the non - compliance. Non - compliance due to the unacceptable quality of a Workplan, Report or other deliverable shall be deemed to occur no sooner than the date of U.S. EPA's notice letter notifying Respondent of the non- compliance. U.S. EPA will provide written notice for all other violations that are not based on timeliness; nevertheless, penalties for all violations shall accrue from the day non- compliance occurs. 15.3 All penalties owed the United States under this Section shall be due and payable within thirty (30) calendar days of the Respondent's receipt from U.S. EPA of a written demand for payment of the penalties, unless Respondent invokes the dispute resolution procedures under Section KV of this COt SENT ORDER - Page 58 March 3 1952 S . .f qn ?fi ^SiJ':K�.: f.�::f2'wi rt'.fr ✓•1liw�.anw.. '.Y�. w+...w uw..w w«u.r.a au way • -- 3 4 jnsent Order. Such written demand will describe the noncompliance and shall indicate the amount of penalties due. 15.4 U.S. EPA may collect interest on the unpaid stipulated penalty balance beginning on the thirty - first day 5 after Respondent's receipt of U.S. EPA's Rate demand letter 6 established by the Secretary of the Treasury. Interest shall 7 accrue at Current Value of.Funds. Pursuant to 31 U.S.C. § 37.17, 8 a penalty of six (6) percent per annum on the unpaid principal 9 shall be assessed for any payment which is overdue for ninety LO (90) or more days. 15.5 All penalties shall be made payable by 11 12 certified or cashier's check to the Treasurer of the United - 1 - States of America and shall be remitted to: 14 U.S. Environmental Protection Agency (Region 10 Hearing Clerk) 15 P.O. Box 360903M Pittsburgh, Pennsylvania 15251, 16 The check shall reference the name of the Facility, the Respondent's name and address, and the U.S. EPA Docket Number of this action. Copies of the check and letter transmitting the 18 check shall be sent simultaneously to the U.S.'EPA Project 19 Coordinator and the Regional Hearing Clerk, at MS -SO -155, 1200 21 Sixth Avenue, Seattle, WA 98101. 15.6 Respondent may dispute U.S. EPA's assessment 22 of stipulated penalties by invoking the dispute resolution 23 procedures under Section XVI of this Consent Order. The 24 stipulated penalties in dispute shall continue to accrue, but the _.�, not pe paid, during �.he disput e resolution period. If March 31, , yo J ,I CONSENT ORDER - Pace • '"i.QlN titce4 2 3 1 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 27 Respondent does not prevail upon resolution of the dispute and U.S. E ?A has not waived imposition of stipulated penalties, Respondent shall remit to U.S. EPA within seven (7) days of receipt of such resolution any outstanding penalty payment, including any accrued interest, which accrued prior to and during the period of dispute. If Respondent prevails upon resolution of the dispute, no penalties shall be payable. 15.7 Neither invoking dispute resolution nor the payment of penalties shall alter in any way Respondent's obligation to comply with the terms and conditions of this Consent Order. 15.8 The stipulated penalties set forth in this Section do not preclude U.S. EPA from pursuing any other remedies or sanctions which may be available to U.S. EPA by reason of Respondent's failure to comply with any of the terms and conditions of this Consent Order. However, all stipulated penalties which are paid by Respondent may be off -set against any and all penalties for the same violation which U.S. EPA may be entitled to collect as a result of other enforcement actions. XVI. DISPUTE RESOLUTION 16.1 The parties shall use their best efforts to informally and in good faith resolve all disputes or differences of opinion as provided in Section VII of the Consent Order. With exception of the procedures regarding enfor :ement of this Consent Order, the Parties agree_ that the proc.•.ur•=.= contained in this - Paco 3.) -fl--Section are the sole procedures for resolving disputes arising i 2 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 27 18 under this Consent Order. 16.2 If Respondent disagrees, in whole cr in part, with any U.S. EPA written disapproval, modification, or other decision or directive made by U.S. EPA pursuant to the terms of this Consent Order, Respondent shall notify U.S. EPA, in writing, of its objections and the basis therefore not later than fifteen (15) days after Respondent's receipt of U.S. EPA's disapproval, modification, decision or directive. 16.3 To be valid for consideration, such notice must set forth substantially: (1) the specific issue(s); (2) the position Respondent contends should be adopted as consistent with 1 the requirements of this Consent Order; and (3) the basis for and reasoning supporting Respondent's position. 16.4 Not later than fourteen (14) days after U.S. EPA's receipt of such written notice,' U.S. EPA, by the Hazardous Waste Division Director, shall provide to Respondent, in writing, its initial decision and reasons therefore on such dispute. Thereafter, Respondent shall have seven (7) additional calendar days during which to respond to the decision, to provide to U.S. EPA arguments not previously made, and to urge that U.S. EPA reconsider and vacate its initial dispute decision, or reconsider and modify such dispute decision in the respects urged. 16.5 U.S. EPA shall notify Respondent within seven (7) days of receiving Respondent's request to reconsider and 2l )vacate of U.S. EPA's decision on the recuesz. Unless vacaoed or CONSENT ORDER - Page 61 Marr:h 31, z w J U 0O N 0 (0 ILI - _ H w 2 J L1 = w Z = I- 0 wf- ul U O - D H = • U ..z U= O z 2 3 4 6 7 8 9 10 11 12 ) 14 15 16 17 18 19 20 21 22 23 24 251 obligation. The requirement that Respondent exercise "best 2 to fulfill the obligation" shall include, but not be modified, the initial U.S. EPA dispute decision shall be complied with according to its terms by both U.S. EPA and the Respondent seven (7) days after Respondent's receipt of U.S. EPA's decision to reconsider and vacate. Unless otherwise specified in U.S. EPA's initial or modified decision, timeframes contained in Section VII shall apply with respect to submission of a revised draft or commencement of work. 16.6 The existence of a dispute pursuant to this Section, and /or the consideration of matters in dispute, shall not excuse, toll, or suspend any compliance deadline otherwise existing pursuant to this Consent Order, or any performance time incorporated or to be incorporated into this Consent Order. 16.7 In any dispute resolution or proceeding consequent thereon, the administrative record created during the dispute resolution process shall be the primary basis for deciding the dispute. XVII. FORCE MAJEURE AND EXCUSABLE DELAY 17.1 Force Majeure, for purposes of this Consent Order, is defined as any event arising from causes not foreseeable and beyond the control of Respondent or any person or entity controlled by Respondent, including, but not limited to, Respondent's contractors and subcontractors, that delays or prevents the timely performance of any obligation under this Consent Order despite Respondent's best efforts to fulfill the - ^-:ATP ... • n March 1 r 1993 i 5 11 9 0 .1 .2 L4 15 16 17 18 19 20 21 22 23 24 25 nited to, best efforts to anticipate any potential Force Majeure event and address it before, during, and after its occurrence, such that any delay or prevention of performance is minimized as much as possible. Force Majeure does not include increased costs of the work to be performed under this Consent Order or financial inability to complete the work. 17.2 If any event occurs or has occurred that may delay the performance of any obligation under this Consent Order, whether or not caused by a Force Majeure event, Respondent shall notify by telephone U.S. EPA's Project Coordinator or, in his or her absence, U.S. EPA's RCRA Compliance Section Chief, in the event both of U.S. EPA's designated representatives are 'available, the Director of the Hazardous Waste Division, U.S. EPA Region 10, within forty -eight (48) hours of when Respondent first knew that the event might cause a delay. Within seven (7) days thereafter, Respondent shall provide in writing to U.S. EPA the reasons for the delay; the anticipated duration of the delay; all actions taken or to be taken to prevent or minimize the delay; a'schedule for implementation of any measures to be taken to prevent or mitigate the delay or the effect of the delay; Respondent's rationale for attributing such delay to a Force Majeure event if they intend to assert such a claim; and a statement as to whether, in the opinion of the Respondent, such event may cause or contribute to an endangerment to public health, welfare, or the environment. Respondent shall include with any notice all available documentatiCn supporting its claim CO'ISENT ORDER - P°c- 63 March 3 1993 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 that the delay was attributable to a Force Majeure. Failure to comply with the above requirements shall preclude Respondent from asserting any claim of Force Majeure for that event. Respondent shall be deemed to have notice of any circumstances of which its contractors or subcontractors had or should have had notice. 17.3 If U.S. EPA agrees that the delay or anticipated delay is attributable to a Force Majeure event, the time for performance of the obligations under this Consent Order that are affected by the Force Majeure event shall be extended by U.S. EPA for such time as is necessary to complete those obligations. U.S. EPA will notify the Respondent, in writing, of the length of the extension, if any, for performance of the 251 duration of the delay or the extension sought ) 1 61 - warranted under the circumstances, that best efforts wer 1 1 COii.5 ORD:.. - Pa' ;(=. , existence )obligations affected by the Force Majeure event. The of a Force Majeure event shall not, of itself, extend the time for performance of any subsequent obligation. If U.S. EPA does not agree that the delay or anticipated delay has been or will be caused by a Force Majeure event, U.S. EPA will notify Respondent, in writing, of its decision. 17.4 If Respondent elects invoke the dispute resolution procedures set forth in Section XVI, they shall do so no later than fifteen (15) days after receipt of U.S. EPA's notice. Respondent shall have the burden of demonstrating by a preponderance of the evidence that the delay or anticipated delay has been or will be caused by a Force Majeure event, that the was or will be Mar fn 3 _'1193 ti�iiisst =x8iiau 2 3 4 5 6 7 8 9 10 11 12 13 11 14 15 16 17 18 19 20 21 22 23 24 25 )exercised to avoid and mitigate the effects of the delay, and that Respondent complied with the requirements of this Section. If Respondent carries this burden, the time for performance of the obligation will be extended in accordance with the U.S. EPA's final decision. XVIII. RESERVATION OF RIGHTS 18.1 U.S. EPA expressly reserves all rights and defenses that it may have, including the right both to disapprove of work performed by Respondent pursuant to this Consent Order and to request that Respondent perform tasks in addition to those stated in any approved Workplan and /or Scopes of Work pursuant to this Consent Order in accordance with.Paragraph 7.11 herein. 18.2 U.S. EPA hereby reserves all of its statutory and regulatory powers, authorities, rights, and remedies, both legal and equitable, which may pertain to Respondent's failure to comply with any of the requirements of this Consent Order, including without limitation the assessment of penalties under Section 3008(h)(2) of RCRA, 42 U.S.C. § 6928(h)(2). This Consent Order shall not be construed as a covenant not to sue, release, waiver, or limitation of any rights, remedies, powers, and /or authorities, civil or criminal, which U.S. EPA has under RCRA, CERCLA, or any other statutory, regulatory, or common law authority of the United States. 18.3 The entry of this Consent Order and Respondent's consent to comply shall not limit or otherwise /preclude the Agency from taking additional enforcement action CONS NT ORDER - Pace_ 65 M ^ 1 1°93 2 3 4 5 6 7 8 9 10 11 12 14 15 16 11 17 18 19 20 21 22 23 24 25 27 'pursuant to Section 3008(h) of RCRA, 42 U.S.C. § 6928(11), or other available legal authorities should the Agency determine that such actions are warranted. 18.4 If U.S. EPA determines that activities in compliance or noncompliance with this Consent Order have caused or may cause a release of hazardous waste, hazardous constituent(s), pollutant(s), or contaminant(s), or a threat to human health and /or the environment, or that Respondent is not capable of undertaking any studies or corrective measures ordered, U.S. EPA may order Respondent to stop further implementation of this Consent Order for such period of time as U.S. EPA determines may be needed to abate any such release or threat and /or to undertake any action which U.S. EPA determines is necessary to abate such release or threat. This determination is not subject to Part XVI (Dispute Resolution). 18.5 U.S. EPA reserves the right to perform any portion of the work consented to herein or any additional site characterization, feasibility study, and response /corrective actions as it deems necessary to protect human health and /or the environment in the event Respondent fails to do so under the terms of this Consent Order. Nonetheless, U.S. EPA may exercise its authority under CERCLA to undertake response actions at any time. In any event, U.S. EPA reserves any right it may have to seek reimbursement from Respondent for costs incurred by the United States. Notwithszanding compliance with the terms of this Consent Order, Respondent is not released from liabilit,r, if _n: COUS..NT ORDER - Page 6 Marc:, for the costs of any such response actions taken or authorized by 1 ) 2 U.S. EPA. 3 4 5 6 7 8 9 10 11 12 13 _4 ,constituents addressed by this Consent Order. Judicial review of 15 16 17 18 19 20 21 22 23 24 25 ^ �I 27 18.6 Respondent reserves its right to withdraw consent to this Order only as to implementation of the final corrective measure selected by U.S. EPA. Said reservation is limited to the terms and conditions provided in Section VI, Subpart E. CONSENT ORDER - Page 67 March 2 19c2 its XIX. JUDICIAL REVIEW 19.1 The Respondent shall not seek judicial review of this Consent Order in any action except an action by the United States to: 1) enforce this Consent Order; 2) recover costs incurred in connection with this Consent Order; or 3) compel action relating to the releases of hazardous wastes and /or this Consent Order shall be limited to the administrative record. Otherwise applicable principles of administrative law shall govern whether any supplemental materials may be considered by the court. In considering objections raised in any judicial review, U.S. EPA's decisions shall be upheld unless the court finds they were arbitrary and capricious or otherwise not in accordance with law. Nothing in this paragraph shall limit any action by Respondent against any party to recover costs incurred in implementing this Consent Order, or for damages or contribution pursuant to Section 107 of CERCEA, 42 U.S.C. § 9607, or other applicable law; or any action pursuant to Section 310 of 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 ,CERCLA, 42 U.S.C. § 9659, 25 § 6972. XX. OTHER CLAIMS 20.1 Nothing in this Consent Order shall constitute or be construed as a release from any claim, cause of action, or demand in law or equity against any person, firm, partnership, or corporation for any liability it may have arising out of, or relating in any way to, the generation, storage, treatment, handling, transportation, release, or disposal of any hazardous constituents, hazardous substances, hazardous wastes, pollutants, or contaminants found at, taken to, taken or migrating from the Facility. The Respondent waives any claims or demands for compensation or payment under Sections 106(b), 111 and 112 of CERCLA, 42 U.S.C. 55 9606(b), 9611 and 9612, against United States or the Hazardous Substances Superfund established by 26 U.S.C. § 9507 for, or arising out of, any activity performed or expense incurred pursuant to this Consent Order. Additionally, this Consent Order does not constitute any decision on preauthorization of funds under § 111(a)(2) of CERCLA, 42 U.S.C. § 9611(a)(2). XXI. OTHER APPLICABLE TAWS 21.1 This Consent Order is not intended to be nor shall it be construed as a permit. All actions required to be taken pursuant to this Consent Order shall be undertaken in acccr Dance_ with the rPr'^'' "ernents of all applicable local, state, �r.c rec __bons. Responder` shall obtain or or Section 7002 of RCRA, 42 U.S.C. V.arc ' 31 993 2 3 4 5 6 7 8 9 10 11 12 13 r l _. 15 16 17 18 19 20 21 22 23 24 25 2 7 cause its representatives to obtain all permits and approvals necessary under such laws and regulations. XXII. INDEMNIFICATION OF THE UNITED STATES GOVERNt4ENT 22.1 Respondent agrees to indemnify and save and hold harmless the United States Government, its agencies, departments, agents, and employees, from any and all claims or causes of action arising from acts or omissions of the Respondent or its officers, employees, agents, independent contractors, receivers, trustees, and assigns in carrying out activities required by this Consent Order. This indemnification shall not be construed in any way as affecting or limiting the rights or obligations of the Respondent or the United States under their various contracts. Nothing in this Section is intended in any way to: (a) expand or increase any liability of the United States, its agents, or employees under existing law; (b) alter or affect any rule of law; or (c) obligate the United States to pay funds in contravention of the Anti- Deficiency Act 31 U.S.C. § 1341. XXIII. FINANCIAL RESPONSIBILITY 23.1 Within thirty (30) days of entry of this Consent Order, Respondent shall establish and maintain financial security in the amount of $ 7 Million in one of the following forms: (a) A surety bond guaranteeing performance of the necessary work; CONSENT 0RDE7 - 2 3 4 5 6 7 8 0 10 11 12 11 14 15 16 17 18 19 20 21 22 23 24 (b) One or more irrevocable letters of credit equalling the total estimated cost of the work; (c) A trust fund; (d) A guarantee to perform the work by one or more parent corporations or subsidiaries, or by one or more unrelated corporations that have a substantial business relationship with Respondent; or (e) A demonstration that Respondent satisfies the ,° f requirements of 40 C.F.R. § 264.143(f). 23.2 If Respondent seeks to demonstrate the ability to complete the work through a guarantee by a third party pursuant to Paragraph 22.1(d) of this Consent Order, Respondent shall demonstrate that the guarantor satisfies the requirements of 40 C.F.R. § 264.143(f). If Respondent seeks to demonstrate its ability to complete the work by means of the financial test or the corporate guarantee pursuant to Paragraph 22.1(d) or (e), or shall resubmit sworn statements conveying the information required by 40 . C.F.R. § 264.143(f) annually, on the anniversary of the effective date of this Consent Order. In the event that U.S. EPA, determines at any time that the financial assurances provided pursuant to this Section does not meet the requirements of this section, Respondent shall, within thirty (30) days of receipt of notice of U.S. EPA's determination, obtain and present to U.S. EPA for approval one (1) of the other forms of financial ;I assurance listed it Paragraph 23.1 of this Consent Order. I CC:TSENT :RnER - Pac'2 70 • •I March 31 3 1993 espondent's inability to demonstrate financial ability to 2 complete the work shall not excuse performance of any activities 3 required under this Consent Order. 4 XXIV. MODIFICATION 5 24.1 This Consent. Order may be modified by mutual 6 agreement of U.S. EPA and Respondent. Any agreed modifications 7 shall be in writing, be signed by•Respondent and U.S. EPA and 8 shall have as their effective date the date on which they are 9 signed by U.S. EPA, and shall be incorporated into this Consent 10 Order. 11 24.2 Any reports, plans, specifications, 12 schedules, and attachments required by this Consent Order are, 13 upon written approval by U.S. EPA, incorporated into this Consent 14 Order. Unless there is an approved modification as provided in 15 Paragraph 24.1 of this Section, any noncompliance with such 16 U.S. EPA - approved reports, plans, specifications, schedules, and 17 attachments shall be considered a violation of this Consent Order 18 and may subject Respondent to the stipulated penalty provisions 19 of this Consent Order. 20 24.3 Any requests for a compliance date 21 modification and /or revision of an approved Workplan requirement 22 must be made in writing. Such requests must provide 23 justification for any proposed compliance date modification or 24 Workplan revision. U.S. EPA has no obligation to approve such 251 requests. Nothing in this Paragraph shall require an approved }I � I modifLcation an e: :tension to a schedule deadline i= such - ^_ March 31, 1993 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 ) extension was previously agreed upon by the Respondent and the U.S. EPA Project Coordinator and documented in writing. 24.4 No informal advice, guidance, suggestions, or comments by U.S. EPA regarding reports, plans, specifications, schedules, and any other writing submitted by Respondent will be construed as relieving Respondent of its obligation to obtain written approval, if and when required by this Consent Order. XXV. SEVERABILITY 25.1 If any provision or authority of this Consent Order or the application of this Consent Order to any party or circumstances is held by any judicial or administrative authority to be invalid, the application of such provisions to other parties or circumstances and the remainder of the Consent Order shall remain in force and shall not be affected thereby. XXVI. TERMINATION AND SATISFACTION 26.1 The provisions of this Consent Order shall be deemed satisfied upon Respondent's execution and U.S. EPA's receipt of an "Acknowledgment of Termination and Agreement to record Preservation and Reservation of Rights" ( "Acknowledgment "). U.S. EPA will prepare the Acknowledgment for Respondent's signature. The Acknowledgment will specify that Respondent has demonstrated to the satisfaction of U.S. EPA that the terms of this Consent Order, including env additional tasks determined by U.S. EPA to be required pursuant to this Consent Order, have been satisfactorily completed. In addition, the Acknowledgment will ensure that all records will be oreser in CONSENT ORDER - Page 2 3 4 5 6 7 8 9 10. 11 12 13 15 16 17 18 19 20 21 22 23 24 accordance with Section XII (Record Preservation) and Section XVIII (Reservation of Rights) provisions of this Consent Order after the Consent Order is terminated. The acknowledgment required by this Section shall be as follows: 2 5 , ACKNOWLEnCMENT OF TERMINATION AND AGREEMENT TO RECOPO PRESERVATION AND RESERVATION OF RIGHTS 1. The United States Environmental Protection Agency ( "U.S. EPA ") agrees and acknowledges that the terms of Consent Order RCRA- 1091- 11- 20 3008(h) entered into by Respondent and U.S. EPA on ( "the Consent Order "), including any additional tasks determined by U.S. EPA to have been required pursuant to the Consent Order, except Section XII (Record Preservation), have been satisfactorily completed based upon the information available to EPA presently. 2. Respondent agrees and acknowledges that the terms of Section XVII (Record Preservation) of the Consent Order remain in effect. 3. Respondent agrees and acknowledges that Respondent' completion of the terms of the Consent Order does not limit or otherwise preclude U.S. EPA from taking additional enforcement action pursuant to Section 3008(h) of the Solid Waste Disposal Act, commonly referred to as the Resource Conservation and Recovery Act of 1976 ( "PCR ") , as mended by the Hazardous and .. . CONSENT GRD - Pace 73 March 31, , 1993 1 L 2 3 4 5 6 7 9 10 11 12 14 15 16 19 20 211 221 23 q. relieve Respondent of its obl igations to comply with RCRA or any other applicable local, atate,•or federal laws and regulations. IT IS SO AGREED AND ACKNOWLEDGED: By: By: Solid Waste Amendments of 1984, 42 U.S.C. § 6928(h), other available legal authorities should U.S. EPA determine that such actions are warranted. Respondent agrees and acknowledges that Respondent's completi ors th,a (Respondent) terms of the Consent Order does not RANDALL F. SMITH, Director Hazardous Waste Division., Region 10 United States Environmental Protection Agency Date Date or XXVII. SURVIVABILITY /PERMIT INTEGPATION 27.1 Except as otherwise expressly provided in this Section, this Consent Order shall survive the issuance or denial of a RCRA permit for the Facility, and this Consent Order •shall continue in full force and effect after either the issuance or denial of such permit. Accordingly, Respondent shall continue to be liable for the performance of such obligations notwithstanding the issuance or denial of such permit. :ict.:. i _hsrandi::c the Ior=coinc, ii the Facility is issued a RCRA 24 _ and h= _ permit e::press' , ihcorzcra_tes by all or part th.R Con:sen Crd=. , or _ xtr ssL M: :a rcch 1993 3 4 5 6 7 8 9 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 states that its requirements replace some or all of t:..- ,acuirements of this Consent Order, the Respondent shall be relieved of liability under this Consent Order for these specific obligations. Respondent shall comply with all State and Federal closure and post- closure requirements in any permit. If a permit that prescribes closure or post - closure acti vities is issued for the Facility, the corrective actions(s) undertaken by the Respondent pursuant to this Consent Order will be coordinated with the corrective action requirements to be taken pursuant to such permit, in a manner to be determined by U.S. EPA. XXVIII. EFFECTIVE DATE 28.1 The effective date of this Consent Order shall be the date on which it is signed by U.S. EPA. IT IS SO : ED AND ORDERED: By By: CO1:SENT ORDER - Pace 75 JOH HTRICH, Executive V ce President Specialty Chemicals Rhone Poulenc, Inc. RANDALL F. SMITH, Director Hazardous Waste Division, Region 10 United States Environmental Protection Agency Date Date NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. II ii LI' ' 1 1 • 1( MIN ./ • • • ,111 •• • r• Dark! I;I 1011: - 1 Et1C , INC. . 'rE1r►_ria F-i kli r I Y 1 ? S O W • ;1111 1011:.)11 IOPOGr.ktHt1C Qt1AD • it NISEI) I?.8 / 19)3 4%, - Ir11E.r��In11 (4L p. .. iiinIil :1 - — ... . -- - \- 1 •. o k 1 . 1 ' �r.Ko., .I. , Cu. (:•..o •., \ I. 001 c1,.k . 1 �`:‘ i , O1.•• 'At • • 1 • • •I ‘ - \.. ` x.•1.•.1 t.`•` it) ( :•I I 1 • 1 IyIV t1 r 1111 \� • ,1 • 1; • Scale: 1:24,00( (1 ". '2.000') III 41 )fi)O 11n1 IhA Stu• 1 •.• 1111 I . 1 • •. I:• I ��:u i1 1\ • ,, 11,1 r 1... 1• _ 1 l , I 11 . � :i{- ! 1 1 • 1I1 et. • :.r•'7 1. N 3 5 • 1- Site Location 1`:-1,)t) Rhone Poulenc Inc. Seattle , Washington NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. • 1 SW1111 110 1 111 114 1.■.1C.1 t I(I 0 SWI•IU NO. 12 S111.111 110. 2 200 KENNOR11i TRUCK COhPANY SWMU NO. 1 ( fl.ItC. IUiD MAIZE ICuS OFFICE - i r xIKIFf ) SWMU N0 . 41 Coon Feel i l' 2. Detailed Site Plan and SWMU Locations T{ • 1 Of1I C.AL M1.1 /� �• 1QR[ j ri t sroa�c� SWMU 110. 3 _ G = SW1.111 NO 5 _ us, VKIIILIft� _ -1 D ISTRIR COI ttR U -� I I M I SI ED ' o S 11011X...1 V•'wlLLIH I U Prtwx I I ui AREA \, , ' SWMU 110. 8 SWMU 110. 4 SPILL axnrrx. ES: SWMU U0. 6 K EY: 1 )1 E D� SWIIII NO. 11 4 MONI TOR IIIG WELL / / NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEARTHAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. 1 i LLJ 2 ritu , IO,u1 01.1/ li aCuSE , G la 7 ' \ 7: iViiT TI-----1 IF-- - - --- rff J i�,va1 °1!1 151��. �-• f /1r t _ • 7- i:z C rfx UIuS • DI S IR I Wl1 I Ot 12 COt fluMED cctoi s 1 UU1I 1 • 1<EY: 0 KEN-fORTII TRUCK COIPAPIY USP MI LL I tt J ilt+ r I .I; f'< J'1 e. IH , ; 'Lit , `i 41 � � ` ' 1 .1117 -- - ii21 ti PLtCLCI I AALA 11 11 Q 1 MAINlEll n 00 P01ENI IAL COt1IAIII1IAt 1011 SOURCE (SEE LEGEt1O)t101 NECESSARILY TO S O I L • SAmPI. I NG AREA Ali 0 2C0 From: Dames & Moore, 1986, (Original figure 2 -2) Figure 3. Locations of Composite Soil Samples SCALE M PORT OF SEATTLE :r LEGEND: POTENTIAL CONTAMINATION SOURCES . IIICIUERATOR LOCAL ION (AOAIIOONEO) 2. AUTOCLAVE SOLIDS DUMPING AREA (A0AIID3nED) 3. PEIIETECK 0!L AND VOL I11 SOIL 4. WEED CONTROL BY fL000II1G WI1i1 VOL ACID VUI.S (TOTAL RAFIrIATE) S. VDLS DISPOSAL (O1IE -1IHE, 1979) 6. SPILL FROM CAUSTIC 1AtiC 7. GUTACOL AND OIL DISPOSED 01110 GROUIIU (APPROXIHAiELY 1953 - 1963) O. SULftJRIC ACID 1AIIK SOLIDS OURIED (ONE- 1Ilif, I9G4) 9. DISPOSAL OF HAI1ITEUA1ICE SIIOP WASTE 1•LAIERIALS 10. DISPOSAL OF PILO! PLAUI WASTES 11. PYDRAUL SPILL /LEAK AREA 12. PEIITACIILOROPIIE1IOL IIANOLIUG AREA 13. DRL'n RECLAMATION FACILITY 14. REPORTED VDLS STORAGE AREA NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. I II.' 1 ;...C I It r nks1 Lin M- 01S11111•,11.11 MUM fInILICTI S1rnul vN1111111 0 to cxTRlcTlas IPI10Q.CtICH CIS/ 7 � 11(L ` 11) IYtTx.Cl 1O1 'JtU. hl lln(t1 Si Cr DM- IA . i11 0 20) C111114 Io /Qi' A ° " colo a Slori :- P1116' s t + i E)1.1- 2A t%ma' DM -28 staua Ili VN11LI.In From: Dames f. t•loore, 1986 (Original Figure 11.IIIre 4. Monitoring Well Location Map KEMOR 111 1 RUCK (*.UI•I'N4Y • 2 -1) OW MA ) 0 fICE Uric) j Icxtt mT1` ( Ito MCA. YAM tI.In K. 1[ 111 r IUCL SS (k1X s tern f I t 1 - (xltv tjlal _ • I i `$ KEY: PORT OF SEATTLE 4) SHALLOW MONITORING WELL + DUAL COMPLETION WELL BOREHOLE A A CROSS- SCCTION. NOTES: U -2 IS A BOREHOLE FROM A PREVIOUS INVESTIGATION (DANES a MOORE , 1979) DUAL COMPLETION WELLS DESIGNATION "A" REFERS 10 A SIIALI.DII WEI.1. AND 11 1" REFERS 10 A DCEP III I I NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. ATTACHMENT A RCRA FACILITY INVESTIGATION SCOPE OF WORK AND WORKPLAN REQUIRE..'MENTS FOR RESPONDENT IN ADMINISTRATIVE ORDER ON CONSENT - U.S. EPA DOCKET NO. 1091- 11- 20- 3008(h) PURPOSE The RFI Workplan objectives are as follows: (1) Analyze the geology, hydrogeology and subsurface stratigraphy of the Facility area, to determine possible routes of migration of hazardous wastes and hazardous constituents that are, or may have been released at or from the Facility. This shall include the entire area of the Facility plus all areas within the lateral extent of contamination from the Facility. Respondent shall also document information on the installation date, current integrity and completion depths of all wells on the site. (2) Characterize the nature, the direction, the vertical and areal extent, the potential to migrate, and the rate of migration of Facility releases or threats of releases of hazardous wastes and /or hazardous constituents to affected media, including soil, groundwater, air, soil gas, sediments, and surface water at the Facility. This characterization shall include: (i) Releases or threats of releases to the soil, including the migration and potential ;migration of hazardous wastes and/or hazardous constituents within the sci' ; (ii) Releases or threats of releases to subsurface water- bearing zones; potential migration of hazardous wastes and /or hazardous constituents; (iii) Releases or threats of releases to and from surface water and surface water sediments, including the migration and any potential migration of hazardous wastes and /or hazardous constituents wi'thin'these systems, recharge of contaminated surface water to groundwater, and seeps or discharge of contaminated groundwater to surface water, particularly, the Duwamish River Waterway. (iv) Releases or threats of releases to the air from SWMUs and AOCs at the Facility. (3) Determine and develop action levels for constituents of concern in soil, groundwater, air, surface water, and sediments, using the methods specified in Chapter 8 of the RFI Guidance manual (May 1989), and other applicable U.S. EPA guidances and policies. These action levels will be subject to U.S. EPA review and approval. (4) Determine the effect of hydrogeologic conditions on the distributions of Facility hazardous wastes or constituents detected in the area to be characterized, and the contribution, if any, to the adjoining Duwamish River Waterway. • EQUIREME ?ITS The RFI Workplan requirements are as follows: (1) The RFI Workplan shall be consistent with the format and requirements set forth in EPA Document No. EPA 530 /SW 89 -031 "RCRA Facility Investigation (RFI) Guidance ", (May 1989). A phased investigative approach is envisioned, with decision points that may eliminate the need or expand the scope for certain planned subsequent investigative or remedial phases, based on results of prior phases. (2) The RFI Workplan shall document the procedures and provide a specific schedule that the Respondent shall use to conduct those investigations necessary to (i) characterize the environmental setting; (ii) characterize sources[s] and nature of hazardous wastes and constituents; (iii) characterize concentration, rate, and extent of contamination released at and from the Facility; (iv) identify any additional SWMUs or AOCs; (v) develop a Risk Assessment; (vi) identify, and implement Stabilization /Interim Measure, and /cr Corrective Measure technologies potentially applicable to the Facility; (3) The RFI shall include provisions to sample the soil, as necessary to meet the RFI objectives. Respondent shall install soil borings, or use alternative means to characterize the following general sources and locations: (i) Potentially contaminated sources as identified in the 1986 Dames & Moore Study; (ii) SWMUs and AOCs, as identified in the 1990 RFA Report; and (iii) Other contaminated locations as identified in the Landau Environmental Assessment. Respondent shall investigate each of these general contaminated locations, and other areas of concern identified in any other site assessments, to characterize the nature and extent of contamination, to U.S. EPA's satisfaction. This investigation shall provide a statistically valid and representative sampling of the areas'of concern, in accordance with U.S. EPA guidance documents (including Methods for Evaluating the Attainment of Cleanup • Standards, Volume 1: Soils and Solid Media, U.S. EPA 230/02 -89 -042), or other documents approved by U.S. EPA. (4) The RFI Workplan shall include provisions for characterization of site hydrogeologic conditions and groundwater monitoring as necessary to meet the RFI objectives. The nature and scope of this investigation may reflect the results of AV :M•A z;;;Eresrs 5�. tuAo�R`nitieiw`.�MnTr.V.�C�t{ iii :1= `.'�i•�iJ:lii�:iSi�:• ff {jQ.S.n'Sii'ia`i3a�1}if.�l.�n i�;jsrn� y�� �" k r. �rax�u��. e"'" �'� v.+�:.r'� . -p.cility investigations completed to date by Dames & Moore (1986), and Landau & Associates (1991). (5) The RFI Workplan shall include provisions for the investigation of any contamination attributable to the Facility that may have migrated off -site, including contamination that may have become commingled with contamination from any adjacent or nearby facilities. (6) The RFI Workplan shall include provisions for identification and characterization of any releases of Appendix IX (40 C.F.R. Part 264) hazardous constituents, as specified in this Attachment, from SWMUs and AOCs at the Facility. (7) The RFI Workplan shall detail the methodology for assessing the potential risk to human health and the environment. Sp This Workplan must be in accordance with U.S. EPA guidance EPA /540/1 - 89/002; "EPA Region 10 Supplemental Risk Assessment Guidance for Superfund," dated August 16, 1991'; and "Guidelines for Developing Health -Based Cleanup Levels at RCRA Sites in Region 10," U.S. EPA guidance 910/9 -92 -019. The RFI Workplan :must also include a detailed description of the methodology proposed to address the four main components of risk assessment: Contaminant Identification; Exposure Assessment; Toxicity Assessment; and Risk Characterization. (8) The RFI Workplan shall contain a Current Assessment Summary Report that includes all existing past or current data �� to the Respondent. At a minimum, and other information availal e t` the variet1es and quantities s hall include Ga t3 ral3�:.r ?f hazardous wastes and hazardous constituents at the Facility, past disposal practices, and results from any previous sampling events. A copy of the approved Interim Measures Workplan and its status shall be included in this Report. (9) The RFI Workplan should consider the Data Quality Objectives ( "DQOs ") for each data collection activity to ensure that data of known and appropriate quality are obtained and that data are sufficient to support their intended end use(s). ADDITIONAL RFI WORKPLAN REQUIREMENTS The RFI Workplan shall meet the following requirements, in addition to the specific requirements and deadlines set forth in the Order: 1. The RFI Guidance in Volume I Section 2 of U.S. EPA Document Number U.S. EPA 530 /SW -89 -031, "RCRA Facility Investigation (RFI) Guidance ", (May, 1989) shall be followed when developing the RFI Workplan. 2. The RFI Workplan shall include a Project Management Plan which will include a discussion of the technical approach and schedules. 3. The RFI Workplan shall include a Data Collection Quality Assurance Plan and a Data Management Plan, developed as per requirements set forth in Attachment "B" of the Order. 4. The RFI Workplan shall include a Sampling and Analysis Plan, developed as per requirements set forth in Attachment "B" cf the Order. This Plan shall address the sampling techniques, • 'nalytical parameters, and analytical methods to be used for characterization of all media. Rationale shall be provided to support the selection of each technique, parameter and method. z 5. The RFI Workplan shall include a Community Relations i Z c4 w Plan, to be developed in consultation with U.S. EPA, for the QQ D JU 00 dissemination of information to the public regarding RFI 0 o CO activities and results. The Community Relations Plan shall wO specify the Tukwila Branch of the King County Public Library g System as the repository for all submittals and reports required u.< CO d by this Order. The Community Relations Plan shall also specify I _ zj the methodology for identifying interested members of the public z LIJ O w that will be notified of the placement of any information in the v p repository. Interested members of the public shall include, but O pp w not be limited to, the owners and operators of adjacent i0 H LL'O i z . U u facilities. 6. The RFI Workplan shall include provisions for carrying p H , z out investigations necessary to characterize the geology, stratigraphy and hydrogeology beneath the Facility, define the sources, nature and extent of contamination, and identify actual or potential receptors. The site investigations should include evaluating soil and groundwater quality on the terrestrial portion of the property, and sediment and seep quality on the marine portion of the property. 7. The investigations must result in data of adequate technical quality to support the development and evaluation of 4: J i az ` 'MPS +'.; »"At; S nia' kt y¢iia"tiw Ce r4 .`corrective measures in a CMS. Specifically, the RFI Workplan shall include provisions for characterizing the following: A. Environmental Settina The RFI Workplan shall include provisions to collect information to supplement and verify existing information on the environmental setting at the Facility. The RFI Workplan shall provide for characterization of the following: (1) HYdroaeoloav The following shall be provided: a. A description of regional and Facility - specific geologic and hydrogeologic characteristics affecting groundwater flow and contaminant migration beneath and from the Facility. This description shall include, but not be limited to: i) Regional and Facility- specific stratigraphy. At a minimum, this shall include a lithologic description of stratigraphic units beneath the Facility. All soil borings shall be logged, and • lithologic descriptions shall include, classification according to the Unified Soil Classification (USC) system. ii) An identification of areas of groundwater recharge and discharge, their location and characteristics. iii) An evaluation of the lateral continuity of stratigraphic units within the Facility, and a t.i icK.n�xcru• z • w. 0 J U U 0 co 0 0,11J : J CO w 0 g Q w d . = W z � I— O Z F- D U � O - O w W; � —O Z w cn U O z correlation of these units to those of adjacent facilities to the extent information about adjacent facilities is available to RPI. z b. A description of each hydrogeologic unit which may z Z w serve as a contaminant migration pathway at or from the QQ JU O Facility. This description shall be based upon, at a U 0 0 CI =' minimum, field studies, soil and aquifer tests, and w= COIL' w0 soil borings and cores. The description shall identify w O J saturated and unsaturated units at the Facility. The ti co d description shall include, but not be limited to, the = w F- _ Z i- f ollowing information: z O i) Hydrogeologic cross sections, indicating the v o • O � location and extent of each hydrogeologic unit; 0 H w ii) An identification of each geologic formation, i 0 —O P. group of formations, or part of a formation in all w z U= aquifers capable of yielding a.significarit amount of 0 1 ' z groundwater to wells or springs; iii) Hydraulic conductivity and porosity (total and effective) of each hydrogeologic unit, as necessary to characterize the impact of each such' unit on groundwater flow and potential contaminant transport; iv) An identification of zones of contrasting hydraulic conductivity that may affect the migration of contaminants, as necessary to characterize groundwater flow and potential contaminant transport; "' __Li _WG71.h.:+GLCLildtti c. A description of the regional and Facility - specific hydrogeologic flow regime in each hydrogeologic unit of concern. At a minimum, the hydrogeologic flow descriptions shall include the following: i) Water level contour, potentiometric and /or phreatic surface maps using measurements from existing and newly installed wells (if any). These maps shall meet the following requirements: A) Contour maps shall be prepared for each hydrogeologic unit and reflect tidal influences. B) Contour maps shall reflect the presence and influence of any non - aqueous phase liquids. Any measurements necessary to correct water levels for the presence of these * liquids shall be taken at the time of water level measurements. ii) Tabular or graphical presentation of the magnitude of vertical gradients; iii) Discussions of the flow system, including the vertical and horizontal components of flow, as described through flow-vectors or the construction of flow nets, as necessary to identify and characterize potential contaminant transport pathways; iv) Identification and documentation of changes in the hydraulic flew regime due to tidal or seasonal influences; wr �m�wzVC- ,.srsyaracum...w ..r( v) An identification and interpretation of inferred hydraulic interconnection between the units of concern and down - gradient areas from the Facility, hydrogeologic potentially impacted by releases including quantification of recharge to such units of concern; Hydrographs depicting the variation of water levels in on -site wells, over the period of cater level measurements; vii) An evaluation and investigation of any groundwater mounding beneath the site that EPA deems necessary; viii) A specific evaluation of groundwater from site releases, particularly around locations of wells BLA, DM -4, DM -5 and DM -8; ix) An identification of the location and amount of groundwater recharge and discharge, including discharges of groundwater that flows at, or from the Facility to the surface in drainage ditches, and the Duwamish Waterway. d. A description of human influences, including off -site structures and conditions, that may affect the hydrogeology and contaminant migration at, or from the specifically identify � site. The descriptions shall - the following: v !T.P/V fl+:'�iuXS' ": J• .id.".'�t� �it` Al � �1 ?:..M1 "i.v�'�'p�1kf ?`�^3.M!eAk :0�T5�NiawGY'Lh*5Yi A�msuaSVis[fc: (2) i) Active and inactive local water withdrawal wells with the potential to affect groundwater flow at the Facility, and approximate pumping schedules; ii) Structures including, but not limited to, and electric utilities, pipelines, french drains, ditches, unlined ponds, septic tanks, NPDES ouzfalls, sewer pipes, stormwater drains, and retention areas; and iii) The areal and vertical extent of the MW -G5 Plume Area and the Sector B Area, where toluene used in the production of vanillin is inferred to be present in both the soil and groundwater systems. iv) The areal and vertical . extent of the Black Liquid Plume Area where shallow monitoring encountered a dark brown /black liquid resembling the black sulfite liquor, and the Sector H Area, where elevated levels of TOC and metals were detected in the groundwater. Soils a. The RFI shall include characterization of the soils within the MW -G5 Plume Area, the Sector B Area, and in the vicinity of other known and /or suspected contaminant release areas. Such characterization shall include all factors necessary and appropriate to define the potential for contaminant migration and to evaluate contaminant fate and transport in the soil system. wells gas Examples of the descriptions and measurements which may be required include: i. Soil descriptions in accordance with the Unified Soil Classification system; ii. Surface soil distribution; iii. Hydraulic conductivity (saturated); iv. Bulk density; v. Porosity; vi. Cation exchange capacity (SEC); vii. Soil organic matter content; viii.Soil PH; ix. Particle size distribution based on sieve analyses; x. Moisture content xi. Presence of stratification or soil structures that may affect unsaturated flow; xii. Infiltration; xiii.Evapo- transpirati xiv. Storage capacity; xv. Mineral content; xvi. Contaminant attenuation or absorption capacity and mechanisms; xvii.Color photographs of all sampled intervals, with a size scale present in each photograph. b. All soil borings conducted under the RFI Workplan shall include logging for a detailed iithologic description. Unless )otherwise specified in the Order, soil cha`ac "ation shall . -occur for each distinct soil type in all borings. All soil borings shall be abandoned using bentonite or bentonite grout. B. Contaminant Characterization z The RFI Workplan shall include requirements to collect ii- z ce � analytical data on groundwater, soils, air, surface water, anti u� UO sediment contamination at or from the Facility and other areas N O w= J H affected by the Facility operations. This data shall be u_ 0 . w sufficient to define the origin, nature and extent, direction, 1 Q and the rate of contaminant migration. Data shall include time (J) CI = w and location of sampling, environmental conditions during z = E - sampling (including tidal levels for groundwater sampling), media w w sampled, contaminant concentrations, and the identity of the U 0 O N individuals performing the sampling and analysis. Respondent CI H w w '. U shall address the following types of contamination at or from the � . z ui Facility: 0 (1) Groundwater Contamination z a. The RFI Workplan shall include requirements to characterize any groundwater contamination at or from the Facility. This investigation shall, at a minimum, provide the following information: i) A description of the horizontal and vertical extent of any immiscible or dissolved contaminants originating from the Facility, including concentration profiles of all parameters identified in Section C, item 3 of this Attachment; 1 ii) The estimated rate of contaminant migration; - ti • iii) An evaluation of factors influencing the migration of contaminants; iv) A prediction of future contaminant migration, and a justification of any assumptions, calculations or models used to develop the prediction; v) The contribution of contaminated soils to groundwater contamination. vi) The hydraulic interconnection between the respective aquifers, and the potential for cross contamination between aquifers. b. The RFI Workplan shall document the procedures to be used in making the above determinations (e.g., well design, well construction, geophysical investigative methods, groundwater odelling, etc.) . c. The RFI Workplan shall also, include provisions for the installation of additional groundwater monitoring wells, if determined to be necessary based on the results of the initial investigation to further delineate the nature and extent of any contamination at or from the Facility. These requirements shall define the criteria for placement of additional wells, including (i) procedures to be used the design, location and installation meet the objectives of the RFI. The proposed groundwater monitoring system and monitoring well network shall meet the following requirements: The network shall contain urgradient wells or functional equivalents capable of yielding samples to i7M.N".bX�Mk. 3'LAif:yt '%TILE 14.,,i representative of background water quality in the water- bearing zones of concerns that are not affected by releases of hazardous wastes and /or hazardous constituents from any solid waste management unit at the Facility. The number and location of the wells must be sufficient to characterize the spatial variability of background water quality. (ii) The network shall contain downgradient wells capable of detecting any release to groundwater in water bearing zones of concern of hazardous waste and /or hazardous constituents from solid waste management units at the Facility. The number and location of these wells must' be sufficient to characterize the nature and extent of any such releases. (iii) The network shall be capable of operating for a period of time sufficient to provide representative groundwater samples during the RFI and the evaluation and implementation of any corrective measures required at the Facility. (iv) All existing wells at the Facility included in the monitoring network that cannot meet these requirements shall be replaced and /or abandoned, or supplemented by new monitoring wells. (-:) The system shall include provisions to evaluate the results of sampling and analysis 7n+ �e• wqz 'it „ikiWn.i��i:;rwn43J,+:t*�: '. M1'iNt MW�N24Y: tt:w " elb usa o:A.vu,�1') ;iklixY� S N ::x. throughout the investigation, and to modify zne � groundwater monitoring network as necessary. (vi) Respondent shall follow the guidelines and specifications in the Technical Enforcement Guidance Document (U. S. EPA OSWER 9950.1. September 1986 "TEGD ") and Chapter 173 -160 WAC, in completing the items discussed above. The RFI Workplan shall include provisions for measuring water level measurements in all wells currently present (including all wells newly constructed under this Order, if any), at the Facility, on a quarterly basis, or as determined by U.S. EPA. (vii) Wells screened shall be designed to } effectively detect contamination that may be present. Respondent shall be responsible for assuring start cards and boring logs are reported in accordance with WAC 173 -160. d. The RFI Workplan shall include provisions to provide the following information for all groundwater monitoring wells used to meet the RFI requirements: i) A description and map showing well locations, including each well's surveyed surface reference point and vertical reference point elevation. Wells shall be surveyed using, or existing well elevations converted 17 1929, 1 Geodetic Vertical Datum ( GVD) , to, the National �� to an accuracy of within 0_01 foot in - nce with the TEGD. Horizontal surveying accuracy shall be within 1.0 feet; ii) The boring and casing diameter and depth of each well; iii) Specification of well intake design, including a screen slot type, size, and length, filter pack materials, and method of filter pack emplacement; iv) Specification of well casing and screen materials. Well construction materials shall be chosen based on parameters to be monitored, and the nature of contaminants that could potentially migrate from the Facility. Well materials shall: (1) minimize the potential of adsorption of constituents from the samples, and (2) not be a source of sample contamination_ Wells shall be constructed for the purpose of long term monitoring in accordance with Chapter 173 -160 WAC; v) Documentation of methods used to seal the well from the surface to prevent infiltration of water into the well and downward migration of contaminants through the well annulus; vi) Description of well development methods and procedures; including well installation, well screen interval, well log, and soil log for all wells; 1 3 vii) Documentation of all well design and installation parameters specified in Section 3.5 of the TEGD; and z viii) Documentation that all borings, well = z Ce w installations, and well abandonment procedures comply ...Jo with Chapter 173 -160 WAC, and were conducted by a t)0. co w= licensed driller. w co w ix) Any analytical data obtained from groundwater w O sampling of existing wells. e. The RFI Workplan Sampling and Analysis Plan _ z� shall include the following elements specific to the O, W uj groundwater monitoring network: j U i) Parameters for chemical analyses of 0i- w groundwater samples. Selected samples subject to U.S. H H' EPA review and approval from the initial round of w z U N . sampling shall be analyzed for .all constituents 0 H z specified in Appendix IX of 40 C.F.R. Part 264. Parameters for subsequent sampling events shall be selected, subject to U.S. EPA review and approval, based on the results of initial groundwater sampling and analysis, and upon the composition of wastes that were managed at the facility. The rationale for selection of all parameters shall be provided. All sampling rounds shall include analysis for heavy ,:petals. ii) An approved sampling schedule for groundwater monitoring. This schedule shall include collection of groundwater samples for chemical analysis from wells to z characterize temporal trends and variations in = z. 't-' w Ce groundwater contaminant migration. 6 v UO . iii) Provisions for sampling and reporting of the cno w= occurrence, amount, thickness, and composition of any a li LL . non - aqueous phase liquids encountered in all monitoring w0 LL Q co = d (2) Soil Contamination ~ _ 7_ i a. The RFI Workplan shall include requirements to Z O characterize the contamination of the soil at, and from v p O � : the Facility, and any contaminant releases. The ' H Ill al Workplan shall include provisions to extend this i_ characterization as necessary both vertically and tii F= I horizontally to determine the full extent of soil O ' z wells. contamination. Soil sampling shall occur at the following locations, and where necessary to meet the RFI objectives: i) At all general locations specified in the Order, particularly within Sector B and the MW -G5 Plume Area; ii) From selected soil borings as necessary to determine the full extent of contamination. This sampling shall be done at 2.5 feet intervals, or at other intervals - ~ate" f i ed by U.S. EPA. If U.S. EPA determines that contamination has impacted the Lower Aquifer, or existing data or field observations so indicate, soil borings and sampling shall be extended 1 vertically, as necessary to determine the full extent z of contamination; i- z _I O O 0 W W W =: em u. contaminant migration; W O v) Where field observation or testing indicate g 5 u.= greater concentrations of contaminants relative to the N d = W nearest strata that would otherwise be sampled. zF- zo b. The RFI Workplan Sampling and Analysis Plan shall z Ill U document the following for soil sampling: O a 0 h ww H U W P - O. z .. w U °' - _ 0 I' used; iii) At all stratigraphic unit contacts; iv) At the location of any preferred routes of i) The sampling techniques and equipments to be ii) The parameters for chemical analysis, and the rationale for their selection. c. The RFI Workplan shall provide documentation of the following information, including any associated calculations, deriv or assumptions: i) A description of the vertical and horizontal extent of contamination for all 40 C.F.R. Part 264, Appendix IX contaminants detected in the soil at the Facility. ii) A description of contaminant properties and contaminant /soil interactions within the contaminant z source area and plume. Examples of properties and interactions which may be required include contaminant solubility, speciation, adsorption, leachability, retardation coefficients, biodegradability, hydrolysis, photolysis, oxidation, soil cation exchange capacity, and other factors that might affect contaminant migration and transformation. This information shall be presented in sufficient detail to fulfill the • objectives of the RFI. iii) Concentrations of each contaminant in all soil samples. iv) The rate and direction of contaminant migration and a prediction of future contaminant migration rate, including considerations of releases from soils to groundwater. (3) Air Releases a. The RFI Workplan shall include requirements for characterizing air releases of hazardous constituents from solid waste management units and areas of concern at the Facility. b. Specification of activities proposed to determine the rate of releases from the units, and to estimate exposures and risks to receptors and potential receptors of hazardous constituents from air emissions. c. The RFI Workplan shall include provisions to determine the following: f 3r.'s:G 5 5FY-.tAs i) The composition and concentrat'_on of hazardous constituents present in the air over the units and at additional locations identified in the RFI z Workplan; W` Ce ii) The estimated rates of release of hazardous u- -IL) constituents from the pollutant sources and bases for 00 co o w I. determining the estimates, such as observed ...I 1 .... concentrations of constituents at the sources, physical � w sical w O u) u and chemical characteristics of waste constituents, 5 u_ Q co D theoretical assumptions, I—I meteorological data, and any F-w z analytical techniques or models used to arrive at the z O Lul estimates; and v o 1 0 21 iii) The predicted exposures and risks of harmful ;o 2 effects to receptors of air emissions of hazardous w E- H tL Z constituents from the specified sources. All Q, . ii F- H calculations, algorithms, existing and new information, U � • 0 and all assumptions used to estimate the effects of air emissions shall be documented in the findings. (4) Surface Water Contamination The RFI Workplan shall include requirements to determine the nature and extent of surface water and sediment contamination due to releases to surface water at or from the Facility and due to discharges of contaminated groundwater at or from the Facility. The Workplan shall specify the methods and procedures to be used to characterize to 7.tMf�<a'A�iCi' ++4 ' .�, y « 4d:!: Yfd�• M1�9! tlbLl� +diniT+GnY11�hWSM1:wPlvYeuri4 a. The contribution of contaminated groundwater discharges to surface water at, and downgradient from the Facility, including discharges of contaminated groundwater to surface drainage ways and surface waters, and discharges of groundwater to subsurface drainage facilities for stormwater management at, or from the Facility. b. The contribution of contaminated runoff at or from the Facility to surface water, and through any discharges from stormwater collection and management controls structures. c. The nature and extent of surface water and sediment contamination due.to contributions of hazardous wastes and /or hazardous constituents from the Facility, including those sources identified above. d. The RFI Workplan shall include specifications for the following aspects of the surface water contamination investigation: i) The methods and equipment used to collect surface water and sediment samples for analysis. ii) The locations for surface water and sediment sampling, and the rationale for their selection (e.g., groundwater discharge areas identified through flow net construction performed for the hydrogeologic characterization of the Facility and potentially affected dcwngrad'enc ar . At a minimum, sediment samples shall be taken from Facility discharges, outfalls, outlets, catch basins or manholes. iii) Surface water and sediment samples shall be analyzed for all priority pollutant metals, total petroleum hydrocarbons, total solids, and those Appendix IX volatile and semi- volatile organic compounds which are or have been present at the Facility. Analytical methods must be those specified in Test Methods For Evaluating Solid Waste - Physical /Chemical Methods, U.S. EPA Publication Number SW 846, Methods for Chemical Analysis of Water and Wastes, U.S. EPA Report 600/4 -79 -0202, March 1983, or alternate methods approved by U.S. EPA, and which Respondent has demonstrated will perform equal or better than SW -846' methods under conditions expected in the investigation. C. Reporting The RFI Workplan shall specify the outline and format for the RFI Report to present the findings of the investigation. The RFI Workplan shall specify groundwater data reporting procedures which are consistent with U.S. EPA Region X Groundwater Data Management System. These specifications shall include, but are not limited to the following: Contour maps of groundwater concentrations for all contaminants detected at the Facility, and affected down - gradient areas; 2. Flow net constructions of maps and cross sections showing surface discharges of groundwater that flows beneath the Facility, and delineating the extent of discharge of contaminated groundwater, and showing areas of groundwater discharge that may become contaminated due to subsurface contaminant migration. 3. Maps and cross sections depicting. the estimated migration rates for contaminants in groundwater, considering advection, dispersion, adsorption, and degradation processes. The migration evaluations shall be prepared for two species from each of the following classes of compounds that are identified as originating at or migrating from the Facility: volatile organic compounds, base neutral and acid extractable organic compounds, metals and cyanide compounds. In general, the species selected shall be the most mobile contaminants from each class that have been, or are likely to be, released from the Facility. The RFI Workplan shall describe all input data algorithms, estimates, assumptions, boundary conditions, sensitivity analyses, and model calibration procedures used to derive these predictions of groundwater contaminant ...icration; 4. The nature and extent of surface Water and sediment contamination due to releases from the Facility, including maps depicting the concentration distribution over the sample locations; 5. An assessment of the fate and transport of contaminants in surface water and sediments, including maps depicting the maximum extent of exposure of aquatic organisms to contaminant concentrations at levels that may have adverse impacts, to the extent that these impacts can be distinguished from surface water and sediment quality in the area. ambient ATTACHMENT B SAMPLING AND ANALYSIS AND DATA MANAGEMENT PROGRAM REQUIREMENTS FOR RESPONDENTS IN ADMINISTRATIVE E O(h) RDER ON CONSENT U.S EPA DOCKET NO. Each Verification Investigation or RCRA Facility Investigation Workplan shall include a plan to document all monitoring procedures (including all sampling., field measurements, and sample analysis performed during the. investigation to characterize the environmental setting, source of contamination, and concentration of contaminants) so as to ensure that all information, data, and resulting decisions are technically sound, .statistically valid, and properly documented. ..The plan shall include the following: A. Data quality Assurance Plan 1. Data Collection Strategy The strategy section of the Data Quality` Assurance Plan shall include, but not be limited to, the following: a. Description of the intended uses for the data, and the necessary level of precision and accuracy for these intended uses; and b. Description of methods and procedures to be used to assess the precision, accuracy, and completeness of the measurement data; 2. Sampling The Sampling section of the Data Collection Quality f } Assurance Plan shall discuss: a. Sampling methods including, identification of sampling equipment, purging procedures, and decontamination procedures to be used; b. Criteria for selecting appropriate sampling locations, depths, etc.; c. Criteria for providing a statistically sufficient number of sampling sites; d. Methods for measuring all necessary ancillary data; e. Criteria for determining conditions under which sampling should be conducted; f. Criteria for identifying which parameters are to be measured, and criteria for determining where specific parameters will be measured; g. Criteria for identifying the type of sampling (e.g., composites v. grabs) and number of samples to be collected; h. Measures to be taken to prevent contamination of the sampling equipment and cross contamination between sampling points; i. Methods and documentation of field sampling operations and procedures, including: (1) Documentation of procedures for preparation of reagents or supplies which become an integral part of the sample (e.g., filters and adsorbing reagents); (2) Procedures and forms for recording the exact location, sampling conditions, sampling equipment and visual condition of samples; (3) Documentation of specific sample preservation method; (4) Calibration of field devices; (5) Collection of replicate samples; (6) Submission of field- biased blanks, where appropriate; (7) Potential interferences present at the facility; (8) Field equipment listing and sample containers; (9) Sampling order; and (10) Decontamination procedures. j. Selection of appropriate sample containers; k. Sample preservation methods; and 1. Chain -of- custody procedures, including: (1) Standardized field tracking reporting forms to establish sample custody in the field prior to and during shipment; and (2) Pre - prepared sample labels containing all information necessary for effective sample tracking. 3. Field Measurements The Field Measurements section of the Data Collection Quality ssurance Plan shall discuss: a. Selecting appropriate field measurement locations, depths, etc.; b. Providing a statistically sufficient number of field measurements; c. Measuring all necessary ancillary data; d. Determining conditions under which field measurements should be conducted; e. Determining which media are to be addressed by appropriate field measurements (e.g., groundwater, air, soil, sediment, etc.) ; L. Determining which parameters are to be measured and where; g. Selecting the frequency of field measurement and length of field measurements period; and h. Documenting field measurement operations and procedures, including: (1) Procedures and forms for recording raw data and the exact location, tidal conditions, time, and sampling conditions; (2) Calibration of field devices; (3) Collection of replicate measurements; (4) Submission of field - biased blanks, where appropriate; (5) Potential interferences present at the facility; 4sby...i%�V :iler41141444.....N.rbatArA. (6) Field equipment listing; and (7) Decontamination procedures. 4. Sample Analysis The Sample Analysis section of the Data Collection Quality Assurance Plan shall specify the following: a. Chain -of- custody procedures, including: (1) Certification that all samples obtained pursuant to this Order for analysis will be delivered to a responsible person at the recipient laboratory who is authorized to sign for incoming field samples, obtain documents of shipment, and verify the data entered onto the sample custody records; (2) Provision for a laboratory sample custody log consisting of serially numbered standard lab - tracing report sheets; and (3) Specification of chain -of- custody procedures for sample handling, storage, and dispersement for analysis. b. Sample storage procedures and storage times; c. Sample preparation methods; d. Analytical procedures, including: (1) Scope and application of the procedure; (2) Sample matrix; (3) Potential interferences; (4) Precision and accuracy of the methcdology; and (5) Method detection limits. • 5 e. Calibration procedures and frequency; E. Data reduction, validation, and reporting; Internal quality control checks, laboratory g . performance, and systems audits and frequency, (1) Method blank(s); (2) Laboratory control sample(s); (3) Calibration check sample(s); (4) Replicate sample(s); (5) Matrix- spiked sample(s); (6) "Blind" quality control; (7) Control charts; (8) Surrogate samples; (9) Zero and span gases; and (10) Reagent quality control checks. B. Data Management Plan Respondent shall develop and initiate a Data Management Plan to document and track investigation data and results. shall identify and establish data documentation and procedures, project file requirements, and This plan materials 6 including: project- related progress reporting procedures and documents. 1. Data Record The data record shall include the following: a. Unique sample or field measurement code; b. Sampling or field measurement location including surveyed horizontal coordinates and elevation of the sample location, and sample or measurement type; c. Sampling or field measurement raw data; d. Laboratory analysis ID number; e. Result of analysis (e.g., concentration); f. Elevations of reference points for all groundwater level measurements, including water level elevation, top of casing elevation, and ground surface elevation; and g. Magnetic computer records of all groundwater, soil, surface water, and sediment analytical data meeting the format specifications of EPA Region 10 groundwater data management system. C. Data Reportina Respondent shall provide notification of availability to EPA and Ecology of all data obtained pursuant to this order 'within thirty (30) days of receipt by Respondent, or after completion of quality asurance /quality control activities, if applicable. This notification requirement shall also apply to any other information obtained from activities conducted, or data obtained, by Respondent that may influence activities pursuant to this Order. 1. Tabular Displays The following data shall be presented in tabular displays, as appropriate: a. Unsorted (raw) data; b. Results for each medium and each constituent monitored; c. Data reduction for statistical analysis; d. Sorting of data by potential stratification factors (e.g., location, soil layer, topography); and e. Summary data. 2. Graphical Displays At a minimum, the following data shall be presented in graphical formats (e.g., bar graphs, line graphs, area or plan maps, isopleth plots, cross - sectional plots or transects, three dimensional graphs, etc.): a. Displays of sampling location and sampling grid; b. Identification of boundaries of sampling area and areas where more data are required; c. Displays of concentrations of contamination at each sampling location; d. Displays of geographical extent of contamination; Areal and vertical displays of contamination , concentrations, concentration averages, and concentration maxima, including isoconcentration maps for contaminants found in environmental media at the Facility; f. Illustrations of changes in concentration in relation to distance from the source, time, depth, or other parameters; Identification of features affecting intramedia a. transport and identification of potential receptors; h. For each round of groundwater level measurements, maps showing the distribution of head measurements in each aquifer at a scale of one inch equals 50 feet and a contour z interval of one -half foot; and z • i For each well, provide a hydrograph that shows the de 2; J U; distribution of water level measurements taken during the •c.) O. U) CO W; RFI for •the time interval of the investigation. to =: JI—'. CD LL' Lu O, g J LL <' _ : ZF..; I— O. Z I— Dr D Cy i i 'W • • ii i I I - 0' . Z i V cn ? .p O Z zo:: uu? wili.} i2:;:.•cl;:+a'., �. �Si .:`."�3.1:;;6x:;;F:.r:iG:.�aa� .u. • NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEARTHAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. ATTACHMENT C SCOPE OF WORK FOR THE CORRECTIVE MEASURES STUDY REQUIREMENTS U FOR RESPONDENT DOCKET NO. ADMINISTRATIVE 1091-11-20 IS VE R ER ON CONSENT PURPOSE: The develop purpose of this Corrective Measure Study (CMS) is to and evaluate corrective action alternatives and to recommend corrective measure(s) to be taken at the Facility. SCOPE: The scope of the CMS will depend on the needs at the Facility as determined by the RFI; U.S. EPA may determine that an the abbreviated CMS is sufficient for the Facility. In general, F.M:S will consist of the following four tasks: Task 1. Identification and Development of the Corrective Measure Alternatives A. Description of Current Situation B. Establishment of Corrective Action Objectives C. Screening of Corrective Measures Technologies D. Identification of the Corrective Measure Alternatives Task 2. Evaluation of the Corrective Measure Alternatives A. Technical /Environmental /Human Health /Institutional B. Cost Estimate Task 3. Justification and Recommendation of the Corrective Measure(s) A. Technical E. Environmental } C. Human Health Trask 4. Reports A. Draft B. Final Z TASK 1: IDENTIFICATION AND DEVELOPMENT OF THE CORRECTIVE ACTION 1-- W ALTERNATIVES Q Based on the results of the RFI, Respondent shall identify, -JO o screen, and develop the alternatives for removal, containment, J H treatment, and /or other remediation of the contamination based on w O the objectives established for the corrective action. E A. Description of Current Situation (0 = I- d _ . Respondent shall submit an update to the information ZF I- describing the current situation at the Facility and the known w uj U • nature and extent of the contamination as documented by the RFI. :o 52, 01-- w w )Respondent shall also make a Facility - specific statement of the U:0 U I P. purpose for the response, based on the results of the RFI. The Z statement of purpose should identify the actual or potential U = P exposure pathways that should be addressed by corrective measures. • Z B. Establishment of Corrective Action Objectives Respondent, in conjunction with U.S EPA, shall establish Facility - specific objectives for the corrective action. These objectives shall be based on public health and environmental IC' criteria, information gathered during the RFI, U. S. EPA guidance, and the requirements of applicable federal and state statutes. At a minimum, all corrective actions concerning groundwater releases from regulated units must be consistent with, and as stringent as, those required under 4 C.. .R. 5 264.100. C. Screening of Corrective Measure TechnoLoces Respondent shall review the results of the RFI and identify technologies which are applicable at the Facility. Respondent z shall screen corrective measure technologies and any supplement 1- z. technologies to eliminate those that may prove infeasible to cew 6 U O. implement, that rely on technologies unlikely to perform 0 w= satisfactorily or reliably, or that do not achieve the corrective w LL wa measure objective within a reasonable time period. This screening uj process focuses on eliminating those technologies which have sever Q. e g = • w given set of waste and Facility- specific _ limitations for a g ? 1.- conditions. The screening step may also eliminate technologies Z O W in based on inherent technology limitations. v 0 O D-, 0 F_ Facility, waste, and technology characteristics which are used = U } t- F • to screen inapplicable technolog are described in more detail u.1-0. O (Liz below: U z p _ O~ 1. Facility Characteristics: Facility data should be reviewed to identify conditions that may limit or promote the use of certain technologies. Technologies whose use is clearly precluded by Facility characteristics should be eliminated from further consideration. 2. Waste Characteristics Identification of waste characteristics that limit the effectiveness or feasibility of technologies is an important part of the screening process. Technologies clearly limited by waste characteristics at the Facility may be eliminated from the Waste characteristics particularly affect. the z feasibility of on -site methods, direct treatment methods, and land disposal; and 3. Technology Limitations During the screening process the level of technology development, performance record, and inherent construction, operation, and maintenance problems technology considered. Technologies D. 4 should be identified for each that are unreliable, perform poorly, or are not fully demonstrated may be eliminated in the screening process. Identification of Corrective Measure Alternatives Respondent shall develop the corrective measure alternative or alternatives based on the corrective action objectives and analysis of corrective measure technologies. Respondent shall rely on engineering practice to determine which of the identified technologies appear most suitable for the site. Technologies can be combined to form the overall corrective action alternative or alternatives. The alternative or alternatives developed should represent a workable number of option(s) that each appear to adequately address all site problems and corrective action objectives. Each alternative may consist of an individual technology or a combination of technologies. Respondent shall document the reasons for excluding technologies. TASK 2: EVALUATION OF THE CORRECTIVE MEASURE ALTERNATIVE OR ALTERNATIVES Respondent shall describe each corrective measure alternative that passes through the initial screening in Task 1 and evaluate each corrective measure alternative and its components, as deemed necessary by U.S. EPA. The evaluation shall be based on technical, environmental, human health, and institutional concerns. Respondent shall also develop cost estimates of each corrective z measure. _ ~ 1-- w . A. Technical /Environmental /Human Health /Institutional c4 2 ' Respondent shall provide a description of each corrective 0 o. w= measure alternative, as deemed necessary by U.S. EPA, which may ° include, but is not limited to, an evaluation of the following w 0 factors: LL a co a I' w F- _ Z 1... Respondent shall evaluate each corrective measure alternative, Z O zI- w as deemed necessary by U.S. EPA, based on performance, reliability, ? o P implementability, and safety. C . = w a. Respondent shall evaluate performance based on the 1-- L - 6 0 O . effectiveness and useful life of the corrective measure: tiiz i) Effectiveness shall be U e evaluated in terms of the 0 = = z i. Technical ability to perform intended functions, such as containment, diversion, removal, destruction, or treatment. The effectiveness of each corrective measure shall be determined either through design specifications' or by performance evaluation. Any specific waste or site characteristics which could potentially impede effectiveness shall be considered. The evaluation should also consider the effectiveness of combinations of technologies; and ii) Useful life is defined as the length of time the _ be maintain ne d . Most corrective _•?'! = OL effectiveness Can e :i��. _. measure technologies, with the exception of destruction, deteriorate with time. Often, deterioration can be slowed through proper system operation and maintenance, but the technology eventually may require replacement. Each corrective measure shall be evaluated in terms of the projected ser•.ice lives of its component technologies. Resource availability in the future life of the technologies, as well as appropriateness of the technologies, must be considered in estimating the useful life of the project. b. Respondent shall provide information on the reliability of each corrective measure, as deemed necessary by U.S. EPA, including their operation and maintenance requirements and their demonstrated reliability: i) Operation and maintenance requirements include the frequency and complexity of necessary operation and maintenance. Technologies requiring frequent or complex operation and maintenance activity should be regarded as less reliable than technologies requiring little or straightforward operation and maintenance. The availability of labor and materials to meet these requirements shall also be considered; and ii) Demonstrated and expected reliability is a way of measuring the risk and effect of failure. Respondent should evaluate: whether the technologies have been used effectively under similar conditions; whether the combination of `i. -n -I technologies have been used tc;ether :eFieCtl te whether ,4".‘',4;;;;;;4.- failure of any on technology has an immediate impact on receptors; and whether the corrective measure has the flexibility to deal with uncontrollable changes at the Z Facility. w ;t- z re 2 c. Respondent shall describe the implementability 6 n of each corrective measure, as deemed necessary by U.S. ma W = EPA, including the relative ease of installation H w0 • (constructability) and the time required to achieve a 2 J Q given level of response; tn = a i) Constructability is determined by conditions both F- w = Z l- int ernal and external to the Facility conditions and include w O. such items as location of underground utilities, depth to v o 0 N . water table, heterogeneity of subsurface materials, and 0 H W = w location of the Facility (e.g., remote location v. a congested H LL'O urban area). Respondent shall evaluate what measures can be 0 al N taken to facilitate construction under these conditions. Z ~ External factors which affect implementation include the need for special permits or agreements, equipment availability, and the location of suitable off -site treatment or disposal facilities; and ii) Time has two components that shall be addressed: the time it takes to implement a corrective measure; and, the time it takes to actually see beneficial results. Beneficial results are defined as the reduction of contaminants to some acceptable, pre - established level. • d. Respondent shall evaluate each corrective measure alternative with regard to safety. include threats to the safety of environments as well implementation. Factors This evaluation shall nearby communities and as those to workers during to consider are fire, explosion, and exposure to hazardous substances. 2. Environmental Respondent shall perform an Environmental Assessment for each alternative. The Environmental Assessment shall focus on the Facility conditions and pathways of contamination actually addressed by each alternative. The Environmental Assessment for each alternative will include, at a minimum, an evaluation of: the short and long -term beneficial and adverse effects of the response alternative; adverse effects on environmentally sensitive areas; and an analysis of measures to mitigate adverse effects. 3. Human Health Respondent shall assess each alternative in terms of the extent of 'which it mitigates short and long -term exposure to any residual contamination and protects human health both during and after implementation of corrective measure. The assessment will describe the levels and characterizations of contaminants on -site, potential exposure routes, and potentially affected population. Each alternative will be evaluated to determine the level of exposure to contaminations and the reduction over time. For management of mitigation measures, the relative reduction of impact. 'ill be determined by comparing residual levels of each alternative with existing criteria, standards, or guidelines acceptable to U.S. EPA. 4. Institutional Z ' Respondent shall assess relevant institutional needs for each W w UO D alternative. Specifically, the effects of federal, state, and _l p U) public health standards, regulations, -J f- local environmental and p U) u. w O guidance, advisories, ordinances, or community relations on the w and timing of each alterative. D design, operation, an cn = w B. Cost Estimate I- _ ? F- Respondent shall develop an estimate of the cost of each w O w corrective measure alternative (and for each phase of segment of U o o I— the alternative). The cost estimate shall include both capital and w — } w U operation and maintenance costs. Wi O. - Z. TASK 3: JUSTIFICATION AND RECOMMENDATION OF CORRECTIVE U U • MEASURES P H. Respondent shall justify and recommend. a corrective measure O z alternative using technical, human health, and environmental criteria. This recommendation shall include summary tables which allow the alternatives to be understood easily. Trade -offs among health risks, environmental effects, and ether pertinent factors shall be highlighted. U.S. EPA will select the corrective measure(s) to be implemented based on the results of Tasks 2 and 3. At a minimum, the following criteria will he used to justify the final corrective measure(s) A. Technical 1. Performance -- Corrective measures which are most effective at performing their intended functions and ZZ maintaining the performance over extended periods of time will i w 6 � be given preference; U O 0 2. Reliability -- Corrective measures which do not require w =. J 1._ frequent or complex operation and maintenance activities and N Li- wO that have proven effective under waste and Facility conditions 2 g Q similar to those anticipated will be given preference; N d w = 3. Implementability -- Corrective measures which can be Zt I- O constructed and operated to reduce levels of contamination to w w' attain or exceed applicable standards in the shortest period 'U N •O PE- of time will be preferred; and w w �U 4. Safety -- Corrective measures which post the least threat w � ; w Z to the safety of nearby residents and environments as well as o F ~: workers during implementation will be preferred. Z B. Human Health Corrective measures must comply with existing U.S. EPA criteria, standards, or guidelines for the protection of human health. Corrective measures which provide the minimum level of exposure with time are preferred. C. Environmental Corrective measures posting the least adverse impact (or greatest improvement) over the shortest period of time on the environment will be favored. TASK 4: REPORT L.) Respondent shall prepare a Corrective Measure Study Report presenting the results of Tasks 1 through 3 and recommending a corrective measure alternative. z A. Draft U.S. EPA, include at 4--z = w w The Report shall, as deemed necessary by et m JU a minimum: U O 1 . A description of the Facility co =' J 1.-, layouts w w a. Site topographic map and preliminary w O' 2. A summary of the corrective measure(s): ?. w =. a. Description of the corrective measure or measures and co zF O . H = rationale for selection; Z O b. Performance expectations; ? Q ,- criteria and rationale; v C. Prelimina_y design O � o E--: d. General operation and maintenance requirements; and w W =U I- P. e. Long -term monitoring requirements. - z impact on the selected corrective v z 3. A summary of the RFI and imp' F=I- O z measure or measures: a. Field studies (groundwater, surface water, soil, air); and b. Treatability studies (bench scale, pilot scale). I . Design and Implementation Precautions: a. Special technical problems; b. Additional engineering data required; c. Permits and regulatory requirements; d. Access, easement, right -of - way; e. Health and safety requirements; and f. Community relations activities. 5. Cost Estimates and Schedules: a. Capital cost estimate; b. Operation and maintenance cost estimate; and c. Project schedule (design, construction, operation). Final Respondent shall finalize the Corrective Measure Study Report incorporating comments received from U.S. EPA on the Draft Corrective Measure Study Report, asset forth on the Order. • 1 '�i c� .{ L .kN� Yrt+'kL.i:A -�Y W" .FF''iF.M?+.+.•�u' SSdem �r'y ��r.. arti�{�b', �LLYitl'i'fi(•tiCl.�iA'U b .z14"MJ " 4.. 4, { ATTACHMENT 0 SCOPE OF WORK FOR THE CORRECTIVE MEASURE IMPLEMENTATION PLAN FOR REQUIREMENTS FOR RESPONDENT IN ADMINISTRATIVE ORDER ON CONSENT - U.S. EPA DOCKET NO. 1091- 11- 20 300 PURPOSE: The purpose of this Corrective Measure Implementation (CMI) program is to design, construct, operate, maintain, and monitor the performance of the corrective measure(s) selected to protect human health and the environment. SCOPE: The scope of the Corrective Measure Implementation Plan will depend on the needs of the Respondent Facility, as determined by the Corrective Measures Study. As such, the Corrective Measure )Implementation program will include the following four tasks and subtasks as deemed appropriate by U.S. EPA: Task 1. Corrective Measure Implementation Plan A. Program Management Plan k , B. Community Relations Plan Task 2. Corrective Measure Design A. Design Plans and Specifications B. Operation and Maintenance Plan C. Cost Estimate D. Project Schedule E. Construction Quality Assurance Objectives F Health and Safety Plan G. Design Phases ) Task 3. Corrective Measure Construction Responsibility and :_ _- ,n4c? " >1IFrIiSS ' 44,1454,,A46:'.545 MU nvKti�Y'+1Jh5:+h+M1v B. Construction Quality Assurance Personnel Qualifications C. Inspection Activities D. Sampling Requirements E. Documentation Task 4. Reports A. Progress B. Draft C. Final TASK 1: CORRECTIVE MEASURE IMPLEMENTATION PLAN Respondent shall prepare a Corrective Measure Implementation Plan. This program may include the development and implementation of several plans, which require concurrent preparation. It may be necessary to revise plans as the work is performed to focus efforts on a particular problem. The Program Plan includes the following: A. Program Management Plan Respondent shall prepare a Program Management Plan which will document the overall management strategy for performing the design, construction, .v :c... _ operation, selected corrective measure(s). maintenance, and monitoring The plan shall document the responsibility and authority of all organizations and key personnel involved with the implementation. The Program Management Plan will also include a description of qualifications of key personnel directing the Corrective Measure Implementation program, including contractor personnel. of iiid Yo i:3i2 ' ka . vw.krAaia.. Community Relations Plan Respondent may be required to revise the Community Relations Plan to reflect changes in the level of concern or information needs of the community for design and construction activities. 1. Activities which U.S. EPA determines must be conducted during the design stage may include the following: a. Revise the Facility Community Relations Plan to reflect knowledge of citizen concerns and involvement at this stage of the process; and b. Prepare and distribute a public notice and an undated fact sheet at the completion of engineering design. 2 Depending on the level of citizen interest, activities that •)na conducted during the construction stage could range from Y group meetings to fact sheets on the technical status. TASK 2: CORRECTIVE MEASURE DESIGN Respondent shall prepare final construction plans and specifications to implement the corrective measure(s) at the Facility as defined in the CMS and as required by U.S. EPA. A. Design Plans and Specifications Respondent shall develop clear and comprehensive design plans and specifications which may include, but are not limited to the following: . 1. Discussion of the design strategy and the design basics, including: i'.J�eS du S� i s ttk ub; nJx t9' a '?14Twaa ' 14 it b. Minimization of environmental and p ublic impacts. Z the technical factors of importance as w. 2. Discussion of 0C appropriate including: v o a. Use of currently accepted environmental control 0 W H measures and technology; gn u" w0 b. The constructability of the design; and al a; c. Use of currently acceptable construction practices = { F .. w and techniques. z a I-0 3. Description of assumptions made and justification of these W H w U� assumptions; O E 0H )4. Discussion of the possible sources of error and references w w to possible operation and maintenance problems; LI O ui z. 5. Drawings of the proposed design; U z. 6. g ment and specifications; Z ,,, ables listing equip 7. Appendices including: a. Sample calculations (one example presented and explained clearly for significance or unique design calculations); b. Results of laboratory or field tests. B. Operation and Maintenance Plan Respondent shall prepare an Operation and Maintenance Plan to cover both implementation and long -terra maintenance of the corrective measures. The plan shall be composed of some or all } of tte following elements as deemed necessary by U.S. EPA: a. Compliance with all applicable or relevant environmental and public health standards; and ENlibi sdrF.l Description of potential operating problems: a. Description of analysis of potential operation problems; z b. Sources of information regarding problems; and c. Common and /or anticipated remedies. CC I-' JU 2. Description of alternate operation and maintenance: 0 co 0 a. Should systems fail, alternate procedures to 0 111 prevent undue hazard; and w O b. Analysis of vulnerability and additional resource • d requirements should a failure occur. "±" = zt._ 3. Safety Plan: z O UJ a. Description of precautions, or necessary ? o equipment, etc., for site personnel; and 0I-- ) b. Safety tasks required in event of systems failure. _ = w 4. Description of equipment; and iii - • I O I" Equipment identification;. b. Installation of monitoring components; c. Maintenance of site equipment; and d. Replacement schedule for equipment and installed components. 5. Records and reporting mechanisms. a. Daily operating logs; ATTCU.D a . b. Laboratory records; c. Records for operating costs; d. Mechanism for reporting emergencies; and e. Personnel and maintenance records. 5 • `J' . • 'A "". trrawacuceuwcsawv east tc :r: z An initial Draft Operation and Maintenance Plan shall be submitted simultaneously with the Pre -final Design Document submission and the Final Operation and Maintenance Plan with the Final Design Documents. C. Cost Estimate Respondent shall develop cost estimates for the purpose of assuring that the Facility has the financial resources necessary to construct and implement the corrective measure(s). The cost estimate developed in the CMS shall be refined to reflect the more detailedjaccurate design plans and specifications being developed. The cost estimate shall include both capital and operation and maintenance costs. An Initial Cost Estimate shall / be submitted simultaneously with the Pre -final Design submission t and the Final Cost Estimate with the Final Design Document. D. Project Schedule ti and implementation of the corrective measure(s) which identify timing for initiation and completion of critical path tasks. Respondent shall identify projected dates for completion of the project and major interim milestones. An Initial Project Schedule may be required to be submitted simultaneously with the Pre -final Design Document submission and the final Project Schedule with the Final Design Document. Construction _Quality Assurance Oblectives Respondent shall identify and document the objectives and framework for the development of a construction cuality assurance Respondent shall develop a Project Schedule for construction -- program including, appropry ate items such as: responsibility and authority; personnel qualifications; inspection activities; sampling requirements; and documentation. F. Data Collection •ualit Assurance Plan Respondent shall develop the Data Collection Quality Assurance Plan to address the data collection activities to be performed at the Facility to implement the corrective measure(s). G. Data Management Plan Respondent shall develop the Data Management Plan to address the data collected at the Facility during the implementation of corrective measure(s). H. Health and Safety Plan Respondent shall develop the Health and Safety Plan to )address the activities to be performed at the Facility to implement the corrective measure(s). I . Des icrn Phases The design of the corrective measure(s) may include the phases outlined below. 1. Preliminary Design Respondent may be required to submit the preliminary design when the design effort is approximately 30 percent complete. At this stage, if required by U.S. EPA, Respondent shall have field verified the existing conditions of the Facility. The preliminary design shall reflect a level of effort such that the technical requirements cf the project have been addressed and outlined so that they may be reviewed to determine if the final .;.77.11... design will provide operable and usable corrective measure(s). Supporting data and documentation shall be provided with the design documents defining the functional aspects of the program. z The preliminary construction drawings by Respondent shall reflect organization and clarify. � w O The scope of the technical n QQ 0 U specifications shall be outlined in a manner reflecting the final p w =- specifications Respondent shall include with the preliminary F - (0 w: w 0 � submission, design calculations reflecting the same percentage of w p Q completion as the designs they support. . =d N 5 2. Intermediate Design I__ w Z Complex project design may necessitate U.S. EPA's review of w O w the design documents between the preliminary and the v o pre- final /final design. At the discretion of U.S. U.S. EPA, a 0 I- w w design review may be required at 60 percent completion of the Inuj project. This intermediate design submittal should include the w z U= same elements as the pre -final design. O f - . z 3. Correlating Plans and Specifications General correlation between drawings and technical specifications, is a basic requirement of any set of working construction plans and specifications. Before submitting the project specifications, Respondent shall: a. Coordinate and cross -check the specifications and drawings; and b. Complete the proofing of the edited specifications and required cross- checking of all drawings and specifications. } These activities shall be completed prior to any submittals to U.S. EPA. 4. Equipment Start -up and Operator Training As appropriate for the corrective measure(s), the Respondent shall prepare, and include in the technical specifications governing treatment systems, contractor requirements for providing: .appropriate service visits by experienced personnel to supervise the installation, adjustment, start -up, and operation of the treatment systems, and training covering appropriate operations procedures once the start -up has been successfully accomplished. 5. Additional Studies Corrective Measure Implementation may require additional studies to supplement the available technical data. At the direction of U.S. EPA for any such studies required, Respondent shall furnish all services, including field work as required, materials, supplies, plant, labor, equipment, investigations, studies, and superintendence. Sufficient sampling, testing, and analysis shall be performed to optimize the required treatment and /or disposal operations and systems. There may be an initial meeting of all principal personnel involved in the development of the additional studies program. The purpose of the meeting will be to discuss objectives, resources, communication channels, personnel responsibilities, and orientation of the site, etc. An interim and final report documenting additional studies may be required. The interim report may be required to present the Ar c2 . o c ;sults of the testing with the recommended treatment or disposal systems (including options). A review conference may be scheduled after the interim report has been reviewed by all interested parties. The final report will summarize the results of the studies and incorporate relevant test data. 6. Pre -final and Final Design If required by U.S. EPA, the Respondent may submit the pre- final /final design documents in two parts. The first submission shall be at 95 percent completion of design (i.e., pre- final). After approval of the pre -final submission, Respondent shall execute the required revisions and submit the final documents 100 percent complete with reproducible drawings and specifications. ( ±� The pre -final design submittal shall consist of the Design Plans and Specifications, Operation and Maintenance Plan, Capital and Operating and Maintenance Cost Estimate, Project Schedule, Quality Assurance Plan, and Specifications for the Health and Safety Plan. The final design submittal contents may include: the Final Design Plans and Specifications (100 percent complete), Respondent's Final Construction Cost Estimate, the final Operation and Maintenance Plan, Final Quality Assurance Plan, Final Project Schedule, and Final Health and Safety Plan specifications. The quality of the design documents should be such that the Respondent would be able to include them in a bid ,0 nackage and invite contractors to submit bids for the construction project. TASK 3: CORRECTIVE MEASURE CONSTRUCTION Following U.S. EPA approval of the final design, Respondent shall develop and implement a construction quality assurance (CQA) program to ensure, with a reasonable degree of certainty, that the completed corrective measure(s) meets or exceeds associated design criteria, plans, and specifications. The CQA plan is a facility specific document which must be submitted to U.S. U.S. EPA for approval prior to the start of construction. As appropriate, the CQA plan may include the elements summarized below. Upon U.S. EPA approval of the CQA plan, the Respondent shall construct and implement the corrective measure in accordance with the approved design, schedule, and the CQA plan. The Respondent shall also implement the elements of the approved Operation and Maintenance plan. A. Responsibility and Authority The responsibility and authority of participating organizations (e.g., technical consultants, construction firms, etc.) and key personnel involved in the construction of the corrective measure(s) shall be described in the CQA plan. Respondent must identify a CQA officer and the necessary supporting inspection staff as appropriate. Construction Quality Assurance Personnel Qualifications The qualifications of the CQA officer and supporting _nspeczicn personnel shall b e described in the CQA plan, to { - -- remonstrate that they possess the training and experience necessary to fulfill their identified responsibilities. Inspection Activities The observations and tests that will be used to monitor the construction and /or installation of the key components of the corrective measure(s) shall be summarized in the CQA plan. The plan shall include the scope and frequency of each type of inspection. Inspections shall verify compliance with applicable environmental requirements and include, but not be limited to, air quality and emissions monitoring records, waste disposal records (e.g., RCRA transportation manifests), etc. The inspection should also ensure compliance with applicable health and safety procedures. In addition to oversight inspections, and )as required by U.S. EPA, the Respondent may conduct the following activities. 1. A pre - construction Inspection and Meeting to: a. Review methods for documenting and reporting inspection data; b. Review methods for distributing and storing documents and reports; c. Review work area security and safety protocol; d. Discuss any appropriate modifications of the construction quality assurance plan to ensure that site- specific considerations are addressed; and C. lutiv 'uwuc"" vU04.14n¢tiimuca : ",�.;i�'L".fl e. Conduct a site walk- around to verify that the design criteria, plans, and specifications are understood and to review material and equipment storage locations. The pre- construction inspection and meeting shall be documented by a designated person and minutes should be transmitted to all parties. 2. Pre -final Inspection Upon preliminary project completion, Respondent shall notify U.S. EPA for the purposes of conducting a pre -final inspection. The pre -final inspection will consist of a walk - through inspection of the entire project site. The inspection is to determine whether the project is complete and consistent with the contract documents and the U.S. EPA approved corrective ) easure(s). Any outstanding construction items discovered during the inspection will be identified and noted. If required by U.S. EPA, treatment equipment will be operationally tested by Respondent. Respondent will certify that the equipment has performed to meet the purpose and intent of the specifications. Retesting will be completed where deficiencies are revealed. A pre -final inspection report may be required to summarize the outstanding construction items, actions required to resolve items, completion date for these items, and date for final inspection. 3. Final Inspection Upon completion of any outstanding construction items, Respondent shall notify U.S. EPA for the purpose of conducting a 13 ,44,-4:°wrw.w4.wcti =+a;x assz:• 4eb440,--taamhogoe-i, final inspection. The final inspection will consist of a walk - through inspection of the project site. The pre -final inspection report will be used as a checklist with the final inspection focusing on the outstanding construction items identified in the pre -final inspection. Confirmation shall be made that outstanding items have been resolved. D. Sampling Requirements The sampling activities, sample size, sample locations, frequency of testing, acceptance and rejection criteria, and plans for correcting problems as addressed in the project specifications should be presented in the CQA plan. E. Documentation Reporting requirements for CQA activities shall be described in detail in the CQA plan. As deemed appropriate by U.S. EPA, the CQA plan may include such items as daily summary reports, inspection data sheets, problem identification and corrective measures reports, design acceptance reports, and final documentation. Provisions for the final storage of all records also should be presented in the CQA plan. TASK 4: REPORTS Respondent shall prepare plans, specifications, and reports as set forth in Tasks 1 through 3 to document the design, construction, operation, maintenance, and monitoring of the corrective measure. The documentation may include, but not be limited to, the following: A. Progress Respondent shall provide U.S. EPA and Ecology with progress r eports during the design and construction phases, and for operation and maintenance activities: The submittal schedule of the progress reports shall be determined by U.S. EPA and the z the contents of the progress reports cL w Respondent. As appropriate, M may include current status items such as: U m - coo 1. A description and estimate of the percentage of the CMI w = 0 F. � w completed; w 0 2. Summaries_of all findings; M Q 3. Summaries of all changes in the CMI during the reporting u') d period; z H z zo 4. Summaries of all contacts with representatives of the local U 0 community, public interest groups or state government during the cn off w reporting period; w 5. Summaries of all problems or potential problems encountered 1 - 1 = O w z U co 0 z during the reporting period; 6. Actions being taken to rectify problems; 7. Changes in personnel during the reporting period; 8. Projected work for the next reporting period; and 9. Copies of 'daily reports, inspection reports, laboratory /monitoring data, etc. B. Draft 1. Respondent shall submit a draft Corrective Measure Implementation Plan as outlined in Task 1. 2. Respondent shall submit draft Construction Plans and Specifications, Design Reports, Cost Estimates, Schedules, ) A „Operation and Maintenance plans, and Study Reports as outlined in Task 2. 3. Respondent shall submit a draft Construction Quality z Assurance Program Plan and Documentation as outlined in Task 2. 2 z ' ~ w C. Final CL ? _IC) Respondent shall finalize the Corrective Measure 00 cn w 'Implementation Plan, Construction Plans and Specifications, _ H U) u. Design Reports, Cost Estimates, Project Schedule, Operation and Lila Maintenance Plan, Study Reports, Construction Quality Assurance g Q CO D Program Plan /Documentation, and the Corrective Measure I w z Imp lementation Report incorporating comments received on draft I-01 Z i- w • w U � 1. At the "completion” of the construction of the project, 'O N: }Respondent shall submit a Corrective Measure Implementation H U LL H Report to U.S. EPA and Ecology. The Report shall document that z. U N F- _ O ~ submissions. the project is consistent with the design specifications, and that the corrective measure is performing adequately. The Report shall include, but not be limited to, some or all of the following elements as deemed necessary by U.S. EPA: a. Synopsis of the corrective measure(s) and certification of the design construction; b. Explanation of any modifications to the plans and why these were necessary for the project; c. Listing of the criteria, establisned before the corrective measure was initiated, for judging the functioning of • 16 1 :141• . 4 arip v° :s.t.taW j. z the corrective measure and also explaining any modification to These criteria; d. Results of Facility monitoring, indicating that the corrective measure will meet or exceed the performance criteria; and e. Explanation of the operation and maintenance (including monitoring) to be undertaken at the facility. This report should include all of the inspection summary reports, inspection data sheets, problem identification and corrective measure reports, photographic reporting data sheets, design engineers' acceptance reports, deviations from design and material specification (with justifying documentation), and as -built drawings. , r...., . .... PLANNED ACTION INITIAL QUALIFICATIONS (TMC 21.04.152) Please complete the following checklist to demonstrate that all significant adverse environmental impacts have been clearly avoided or mitigated. Please respond on separate sheets as needed. z _1- z Agency Comments: w g JU 00 cn J w u_a I w Proposed start of construction is October 2002. Proposed completion of construction is z November 2002. Only one construction phase is planned for the project with ongoing z O performance monitoring. w w U 0 � CI t- w w 1-- 0 u. O w z 4. Do you know whether applications are pending for governmental approvals of other p F z Applicant Responses: A. BACKGROUND original 1. Date checklist prepared: July 24, 2002 2. Proposed timing or schedule (including phasing, if applicable): 3. Do you have any plans for future additions, expansions, or further activity related to or connected with this proposal? If yes, explain. No future additions, expansions, or further activities are planned as part of this project proposal. proposals directly affecting the property covered by your proposal? If yes, explain. RCI is currently supporting Container Properties LLC (owners) for cleanup of the former Rhone - Poulenc Site. EPA Region 10 is the lead governmental agency for the site. On May 2, 2002, The RCI Construction Group (RCI) received approval with modifications from the EPA for implementation of interim measures at the site. The scope of the interim measures is generally based upon the revised Hydraulic Control Interim Measures (HICM) work plan submitted to EPA Region 10 on November 15, 2000, the "Container Properties Seattle Brownfield Proposal, the Round 12B Groundwater Monitoring Report" dated September 24, 2001, the "2001 Geoprobe Investigation Report" dated October 8, 2001, and five technical memoranda dated April 10, 2002. 5. List any government approvals or permits that will be needed for your proposal. A RCRA corrective action is being conducted under Administrative Order of Consent No. 1091- 11 -20- 3008(12) between Container Properties, L.L.C. , Rhodia Inc., and the USEPA, Region 10, dated March 31, 1993, as amended in FebruaR 2 . E, AUG 2 9 2002 DEVELOPMENT NT Applicant Responses: Agency Comments: which is under contract to Container Properties, is project coordinator for the RCRA corrective action. Based on discussions with the City of Tukwila, permits needed include SEPA Planned Action, Shoreline Permit, and Hauling Permit. A Metro discharge permit for the discharge of the groundwater. A stormwater discharge permit for construction activity will also be applied for from the Department of Ecology. 6. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. Section E requires a complete description of the objectives and alternatives of your proposal and should not be summarized here. A Hydraulic Control Interim Measures (HCIM) is proposed for the site. This HCIM is being done with the concurrence of EPA Region 10. The objective of the HCIM is to control migration of site contaminants into the Duwamish River and Slip 6. The HCIM is a combination of a low permeable barrier wall with groundwater recovery for hydraulic control of the impacted groundwater. The total site is approximately 21.5 (19.5 onshore, 2.0 intertidal) acres. The proposed slurry wall is located in the westerly half of the area of the former Rhone - Poulenc industrial facility. The barrier wall will be approximately 2300 linear feet long and 50 to 70 feet deep. The west__and .;sout portions of the barrier wall will be constructed using "Impermix" a self - hardening cement bentonite slurry wall. The_ north and east portions of the barrier will be constructed using soil bentonite slurry wall. The barrier wall will enclose an area of approximately 6.9 acres. A groundwater extraction system will be located inside the perimeter of the barrier wall to maintain a 1-foot hydraulic head difference between the inside and outside of the barrier wall. The barrier wall alignment will be pretenched with conventional heavy construction equipment to a depth of approximately 20 feet. This will be done to allow the cutting and capping of existing facility piping and to allow the slurry wall installation and contractor uninterrupted access to the aquitard. Following installation of the slurry wall, storm water drainage will be reconnected to existing piping for discharge to the existing outfall. 7. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. The Project is located in the City of Tukwila at: 9229 East Marginal Way South located in Section 33, Township 24 North, Range 4 East, Willamette Meridian. Site plans and 2 Applicant Responses: Agency Comments: maps are provided in the accompanying Interim Measures (Attachment A of Shoreline Permit Application). 8. Does this proposal lie within an area designated on the City's Policy Plan Map as environmentally sensitive? No. This proposal does not lie within an area designated on Land Use Plan Map as environmentally sensitive. B. ENVIROMENTAL ELEMENT 1. Earth a. General description of the site: Flat Construction Work Plan Comprehensive Land Use the City's Comprehensive The site is generally flat with steeper banks to the Duwamish River on the west and Slip 6 on the south side of the site. b. What is the steepest slope on the site (approximate percent slope)? The steepest slope is approximately 12% along a small portion of the western edge of the site. However, the site is primarily flat. c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland. From the ground surface to a depth of 5 to 15 feet soils are hydraulic fill from the Duwamish River. Alluvial silt and sand having a thickness of up to 50 feet underlies the fill. More than 50 feet of marine gravel, sand, silt, and clay underlies the alluvial deposits. d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. There are no significant surface indications or history of unstable soils in the immediate vicinity of the project. e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill. No general filling or grading of the site will be done as part of this project. The excavated trench for the slurry wall will be backfilled with a mixture of cement, excavated soil and bentonite. See the Interim Measures Construction Work Plan for additional information (Attachment A of Shoreline Permit Application). 3 Applicant Responses: Agency Comments: 2. Air f. Could erosion occur as a result of clearing, construction or use? If so, general describe. g. 3. Water Clearing of trees, brush, and grass will not be needed at the site due to its industrial nature. Site demolition of asphalt and concrete and pretrenching along the alignment of the slurry wall will be needed. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? Much of the site is currently covered with impervious and semi - impervious surfaces because of its industrial nature. The proposed project will not significantly change the surface characteristics of the site. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: Proposed measures to reduce or control erosion include silt fences, straw bales, stabilized construction entrances, and equipment decontamination areas. The temporary erosion and sediment control for the project have been planned in accordance with the King County Surface Water Design Manual. a. What types of emissions to the air would result from the proposal (for example, dust, automobile odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known. During construction, air emission will include exhaust from heavy construction equipment and dust from site activities. b. Are there any off -site sources of emissions or odor that may affect your proposal? If so, generally describe. There are no off -site sources of emissions or odor. c. Proposed measures to reduce or control emissions or other impacts to air, if any: Proposed measures to reduce or control emissions include proper maintenance of heavy construction equipment and water for dust control. Additional control measures are discussed in the Interim Measures Construction Work Plan (Attachment A of Shoreline Permit Application). 4 Applicant Responses: Agency Comments: a. Surface: 1) Is there any surface water body on or in the immediate vicinity of the site (including year -round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into. The Duwamish River is located on the West Side of the site. Slip 6 is located on the south side of the site. 2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. The project will require the installation of slurry wall within 200 feet of the Duwamish River and Slip 6. See the Interim Measures Construction Work Plan (Attachment A of Shoreline Permit Application) for additional information. 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area v N of the site that would be affected. Indicate the source of fill material. o w _ � 0 w Z 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if z known. No fill or dredge material will placed in or removed from surface water or wetlands for this project. No surface water withdrawals will be required for this project. Flow of surface water drainage will be maintained to the existing outfall during the installation of the slurry wall. 5) Does the proposal lie within a 100 -year floodplain? If so, note location on the site plan. The proposal does not lie within the 100 year floodplain of the Duwamish River. 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. There are no discharges of waste materials to surface waters as part of this project. 5 z a I - w 6 JO 0 0 CO J = • • w w O g a .0) 0 = � z = �- 0 z E- Applicant Responses: Agency Comments: b. Ground 1) Will groundwater be withdrawn, or will water be discharged to groundwater? Give general description, purpose, and approximate quantities, if known. The groundwater recovery system is intended to maintain an inward (to the site) 1-foot hydraulic gradient in the shallow groundwater. The proposed system includes three groundwater recovery wells, piping, pump controllers, a water treatment system, and discharge to the local sewer system. Individual pumps will be operated at flow rates between 1.5 to 8 gpm. The water treatment system will include a surge tank, bag filter, activated carbon canisters, pumps, flowmeters, and controller equipment. See the Interim Measures Construction Work Plan for additional information. 2) Describe waste materials that will be discharged into the ground from septic tanks or other sources, if any (for example: domestic sewage; industrial, containing the following chemicals...; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve: Waste materials will not be discharged into the ground. Groundwater from the groundwater recovery system will be discharged to Metro for disposal. c. Water Runoff (including storm water): 1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow? Will this water flow into other waters? If so, describe. Runoff is currently collected in a series of manholes, catch basins, and piping and directed to a single outfall to the Duwamish River at the northwest corner of the site. During construction of the slurry wall storm water will continue to be directed to the outfall. Due to the location of the slurry wall temporary storm water piping will be used to direct water runoff to the outfall. At the completion of construction of the slurry wall water runoff will be piped through the slurry wall to existing storm water facilities and to the outfall. 6 x Deciduous tree: alder, maple aspen, other x Evergreen tree: fir, cedar, pine, other x Shrubs x Grass Pasture Wet soil plants: cattail, buttercup, bulrush, Skunk cabbage, other Water plants: water lily, eelgrass, milfoil, other Other types of vegetation i ■ Applicant Responses: Agency Comments: 4. Plants 2) Could waste materials enter ground or surface waters? If so, generally describe. Waste materials are not anticipated to enter ground or surface waters. See the Interim Measures Construction Work Plan (Attachment A of Shoreline Permit Application) for additional information. d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: Proposed measures to reduce or control surface, ground, and runoff water impacts include silt fences, straw bales, stabilized construction entrances, and equipment decontamination areas. The temporary erosion and sediment control measure for the project have been planned in accordance with the King County Surface Water Design Manual. a. Check or circle types of vegetation found on the site: b. What kind and amount of vegetation will be removed or altered? The project site is a former industrial area with asphalt, concrete, and gravel roads and parking areas with little to no vegetation. c. List threatened or endangered species known to be on or near the site. There are no known threatened or endangered species on or near the site. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on this site, if any. Birds Bald eagle Mammals None Fish Salmon, trout Other Applicant Responses: Agency Comments: There is no proposed landscaping plans for the project. 5. Animals a. Circle any birds or animals which have been observed on or near the site or are known to be on or near the site: b. List any threatened or endangered species known to be on or near the site. Summary of recommended findings of effects: Bull trout, Dolly Varden, Chinook and Coho salmon — May affect, not likely to adversely affect. Bald eagle, Steller sea lion, Humpback whale, Leatherback sea turtle — 110 effect. See the "Biological Assessment Covering Federally Listed and Candidate Species for the Barrier Wall Installation at the Former Rhone - Poulenc Site" (Attachment J of Shoreline Permit Application) for additional information. c. Is the site part of a migration route? If so, explain. No. The site is not part of a migration route. d. Proposed measures to preserve or enhance wildlife, if any: Stormwater control berms will be constructed approximately 1.5 feet in height around the perimeter of the slurry wall alignment to control run -on and runoff and to prevent escape of slurry to the environment. A pre- trench will be excavated to identify any voids that could cause a release of slurry or contaminants into the river. Any voids would be sealed to prevent a release of slurry. In addition, accoustic monitoring during the use of the vibrating beam will be conducted for a minimum of one day. Based on the results of the monitoring, additional measures may be implemented to prevent adverse effects of the noise on the nearby fish population. 6. Energy and Natural Resources 8 • o cs ;;a„acbe* ai+w:ar�eri:�ttesv sau�:ra�:�; Applicant Responses: Agency Comments: a. What kinds of energy (electric, natural gals, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. Completed project energy needs will be electricity to operate groundwater pumps and associated equipment. b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe. The project will not affect the potential use of solar energy by adjacent properties. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: 7. Environmental Health Commercially available electrically efficient pumps, controllers, and other instrument and control equipment will be used at the site. a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. There is a RCRA corrective action currently underway at the site. Several major geotechnical or environmental investigations have been conducted at the facility between 1979 to the present. These investigations have contributed to an understanding of contanminant distribution in the subsurface and mobility in the environment. They also provide a scientific and technical basis for establishing the hydraulic control interim measures proposed for the site. The results of the investigation indicated elevated levels of toluene and metals in the groundwater. Other organic compounds were also detected, as well as light nonaqueous phase liquids consisting predominately of white mineral oil and toluene. Environmental health hazards including exposure to toxic chemicals, risk of fire, spills, and hazardous waste is discussed in the site health and safety plan (Appendix H of Attachment A). 1. Describe special emergency services that might be required. 9 • Applicant Responses: Agency Comments: 8. Land and Shoreline Use Special emergency services that may be required for the site are discussed in the site - specific health and safety plan (Appendix H of Attachment A). 2. Proposed measures to reduce or control environmental health hazards, if z any: 1 z �w Proposed measures to reduce or control environmental health hazards are discussed in the site - specific health and safety plan (Appendix H of p Attachment A). 0 w J = b. Noise co u wo 1. What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other). co _ No source of noise exists in the area that will affect the project. _ zF. 2. What types and levels of noise would be created by or associated with w O the project on a short-term or long -term basis (for example: traffic, 2 0 construction, operation, other)? Indicate what hours noise would come v N o— from the site. o E- wW During construction of the project noise will be created by conventional 1 and specialized slurry wall heavy construction equipment. Construction P- o z noise will be generated at the site from approximately 6 am to 6pm v cn Monday through Friday. No heavy construction or other type of heavy o 1 industrial equipment is associated with the long -term operation of the z project. Groundwater pumps and associated controls will cycle on and off periodically, but will not contribute to unacceptable noise levels. 3. Proposed measures to reduce or control noise impacts, if any. Measures to reduce or control noise impacts will include proper maintenance of construction equipment and operating equipment in conformance with applicable noise ordinances. a. What is the current use of the site and adjacent properties? The site is currently being leased by Northwest Container Services for use as temporary storage for shipping container /chassis. A Kenworth truck facility is to the north side of the site. The Duwamish River is on the west. Slip 6 and Boeing property are on the south. East Marginal Way South is on the east side of the site. 10 ".kS.m+'Yh'frieil Applicant Responses: Agency Comments: b. Has the site been used for agriculture? If so, describe. The site has not been used for agriculture. z c. Describe any structures on the site. a: w J 00 w= F- u j 0 d. Will any structures be demolished? If so, what? j z a No building structures will be demolished. Asphalt and concrete I- m roadways /parking areas along the alignment of the slurry wall will be Z demolished. Concrete retaining walls (2' to 3' height) will be demolished along w O the alignment of the slurry wall. 2 U� e. What is the current zoning classification of the site? o (-9-. = w The current zoning classification of the site is — MIC /H. ti. f. What is the current comprehensive plan designation of the site? . P. _ O I The current comprehensive plan designation of the site is — MIC /H. z g. J• Existing structures include three one story office /administration buildings, one maintenance building, one two -story storage building, and one approximate 330,000 gallon steel storage tank. Only a small portion of one of the office /administration building is currently being used by Northwest Container Services for office space. Other facility structures were demolished during previous remediation activities. If applicable, what is the current shoreline master program designation of the site? The current shoreline master program designation for the site is 'Urban'. h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify. No part of the site has been classified as environmentally sensitive. i. Approximately how many people would reside or work in the completed project? This project does not include any residential or other housing units. Approximately how many people would the completed project displace? 11 Applicant Responses: Agency Comments: The completed project does not include any residential or other housing units; no people will be displaced. k. Proposed measures to avoid or reduce displacement impacts, if any: This project will not cause displacement impacts. '~ w projected land uses and plans, if any: - p CO o CO J F- � w w o 9. Housing U) c5 = W a. Approximately how many units would be provided, if any? Indicate whether Z high, middle, or low- income housing. H i-o z �— This proposed project does not include housing units. ? D : b. Approximately how many units, if any, would be eliminated? Indicate whether o D high, middle, or low- income housing. = v 1 = � This proposed project will not eliminate any housing units. O Z CU c. Proposed measures to reduce or control housing impacts, if any: o I Z This proposed project will not cause housing impacts. 10. Aesthetics 1. Proposed measures to ensure the proposal is compatible with existing and Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans include compliance with applicable federal, state, and local codes. a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed? The slurry wall will be at the existing ground surface. No new building or structures are part of the project. b. What views in the immediate vicinity would be altered or obstructed? The project will not alter or obstruct views in the vicinity. c. Proposed measures to reduce or control aesthetic impacts, if any: The project will not cause any aesthetic impacts. 12 Applicant Responses: Agency Comments: 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? The project will not produce light or glare. w b. Will the finished project be a safety hazard or interfere with views? 6 JU 00 The finished project will not be a safety hazard or interfere with views. cn 0 tu J = c . What existing off -site sources of light or glare may affect your proposal? cn � w0 No existing off -site sources of light or glare will affect the project. Q d. Proposed measures to reduce or control light and glare impacts, if any: F w z = The project will not cause light or glare impacts. F 0 z t— 12. Recreation uj . U� a. What designed and informal recreational opportunities are in the immediate o F w uj 0 There are no designed or informal recreational opportunities in the immediate u— `' 0 vicinity. vicinity? u.i 0 2 F I— b. Would the proposed project displace any existing recreational uses? If so, z describe: The project will not displace any existing recreational uses. c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: There are no measures to reduce or control impacts on recreation. 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, National, State or Local preservation registers known to be on or next to the site? If so, generally describe. There are no places or objects listed on, or proposed for, National, State or Local preservation registers known to be on or next to the site. 13 Kei dni' _ 46iu�tfvlk:f': c. Proposed measures to reduce or control impacts, if any: The project will not have direct impacts to the site. 14. Transportation g. The site is currently not served by public transit. Applicant Responses: Agency Comments: b. Generally describe any landmarks or evidence of historic, archaeological, scientific or cultural importance known to be on or next to the site. There are no landmarks or evidence of historic, archaeological, scientific or cultural importance known to be on or next to the site. a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. The site is accessed from East Marginal Way South and is controlled by a signal light. East Marginal Way South is located on the east side of the site. b. Is the site currently served by public transit? If not, what is the approximate distance to the nearest transit stop? c. How many parking spaces would the completed project have? How many would the project eliminate? The project will neither add nor reduce the number of parking spaces. d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private). The project will not require new roads, streets, or improvements to existing roads and streets. e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. The project will not use water, rail, or air transportation. f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. No additional vehicular trips per would be generated by the completed project. Proposed measures to reduce or control transportation impacts, if any: 14 Applicant Responses: Agency Comments: 15. Public Services The project will not have direct impacts to transportation. a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe. The project will not result in an increase in the need for public services. b. Proposed measures to reduce or control direct impacts on public services, if any: The project will not have direct impacts on public services. 16. Utilities a. Utilities currently available at the site: Electricity, water, and telephone services are currently available at the site. Signature. b. Describe the utilities that are proposed for the project, the utility providing the service and the general construction activities on the site or in the immediate vicinity, which might be needed. C. SIGNATURE The utilities proposed for the project include electricity, water, and telephone. Electricity is provided by Seattle City Light. Water is provided by the City of Tukwila. Telephone is provided by US West. The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision. 2 Date Submitted: 15 09/27/2002 13:01 FAX 2537356075 RCI CONSTRUCTION Date: Applicant Name: RCI Environmental Street Address: 1216 140th Ave. Ct. East City, State, Zip: Sumner, WA 98390 Telephone: (253) 863 -5300 DIRECTIONS This Screening Checklist has been designed to evaluate the potential for your project to result in potential "take" of chinook salmon, coho salmon, or cutthroat trout as defined by Section 9 of the Endangered Species Act. The checklist includes a series of "Yes" or "No" questions about your project, organized into four parts. Starting with Part A on Page 1, read each question carefully, circle "Yes" or 'No," and proceed to the next question as directed by the checklist. To answer these questions, you may need to refer to site plans,'grading and drsinage plans, critical areas studies, or other documents you have prepared for your project. The City will evaluate your responses to determine if "take" is indicated. January :S. 200/ City of Tukwila Endangered Species Act Screening Checklist September 27, 2002 Z002 City of Tukwila ESA Screening Checklist 1 1-0 Will the project require any form of grading? Grading is defined as any excavating, filling . clearing, or creation of impervious surface, or any combination thereof. which alters the existing ground surface of the earth (see Tukwila Municipal Code (TMC) Chapter 13.06. Zoning Code, Page 13 -11). Please circle appropriate response. NO - Continue to Question 2 -0 YES Continue to Question 1 -1 (Page 3) 2-0 Will the project require any form of clearing? Clearing means the removal or causing to be removed, through either direct or indirect actions, any vegetation from a site (see Chapter 13.06, Page 13 -3). Please circle appropriate response. NO Continue to Question 3 -0 YES - Continue to Question 2 -1 (Page 4) 3 -0 Will the project require work, during any time of the project, below the ordinary high water mark of a watercourse or the GreenlDuwamish or Black Rivers or in wetlands? Ordinary high water mark is the mark that is found by examining the bed and banks of a stream and ascertaining where the presence and action of waters are so common and usual as to distinctly mark the soil from that of the abutting upland, in respect to vegetation (see TMC Chapter 13.06, Page 13 -15). Please circle appropriate response. NO - Continue to Question 4-0 YES - Continue to Question 3 -1 (Page 5) 4-0 Will the project result in the processing or handling, 'storage, or treatment of hazardous substances? This does not include the proper use of fuel stored in a vehicle's fuel tank. Hazardous substances are any liquid, solid, gas, or sludge. including any material, substance, product, commodity, or waste. regardless of quantity, that exhibits the characteristics or criteria of hazardous waste as defined by Washington Administrative Code 173 -303 (see TMC Chapter 13.06, Tukwila Zoning Code, Page 13 -11). This includes fuel or other chemicals stored on -site during construction. Please circle appropriate response. NO - Continue to Question 5-0 YES Continue to Question 5 -0 5-0 Will the project result in the withdrawal, injection, or interception of groundwater? Examples of projects that may affect groundwater include, but are not limited to: construction of a. new well, change in water withdrawals from an existing well, projects involving prolonged construction dewatering, projects installing French drains or interceptor trenches, and sewer lines. For the purpose of this analysis, projects that require a geotechnical report pursuant to the requirements of TMC 13.45.060 and 13.45.080E.4, or would require a geotechnical report if not exempt under TMC 13.45.0S0A, should answer Yes. Please circle appropriate response. NO - Continue to Question 6 -0 • YES Continue to Question 6 -0 09/27/2002 13:01 FAX 2537356075 RCI CONSTRUCTION lj 003 Cizy of Tukwila ESA Screening Checklist Part A: Please review and answer each question carefully. Consider all phases of your project including, but not limited to, construction, normal operation, potential emergency operation, and ongoing and scheduled maintenance. Continue to the net question as directed for each No or Yes answer. January 25, 2001 09/27/2002 13:02 FAX 2537356075 RCI CONSTRUCTION Il 004 Part A (continued) 6-0 Will the project involve landscaping or re- occurring outdoor maintenance that includes the regular use of fertilizers, pesticides. or herbicides? This does not include the one -time use of transplant fertilizers. Landscaping means natural vegetation such as trees, shrubs. groundcover, and other landscape materials arranged in a manner to produce an aesthetic effect appropriate for the use of the land (see TMC Chapter 18.06, Tukwila Zoning Code, Paee 13- 13). For the purpose of this analysis, this includes the establishment of new lawn or amass. Please circle appropriate response. hecklist Complete S — Checklist Complete Part B: Please answer each question below for projects that include grading. Review each question carefully, considering all phases of your project including, but not limited to construction, normal operation, potential emergency operation, and ongoing and scheduled maintenance. Continue to the next question as directed for each Na or Yes answer. 1 -1 1 -2 Could the construction, operation, or maintenance of the project result in sediment transport off site or increased rates of erosion and/or sedimentation in watercourses, the Green/Duwamish rivers, or the Black River? Most projects that involve grading have the potential to result in increased erosion and/or sedimentation as a result of disturbances to the soil or earth. if your project involves grading and you have not prepared a Temporary Erosion and Sedimentation Control Plan specifically designed to retain 100 percent of the runoff (including during construction) from impervious surface or disturbed soils, answer Yes to this question. If your project is normally exempt under the Tukwila Municipal Code and would not require the preparation of a Temporary Erosion and Sedimentation Control Plan, BUT may still result in erosion or sediment transport off site or beyond the work area, answer Yes to this question. Please circle appropriate response. - Continue to Question 1 - Continue to Question 1 -3 1 - Will the project result in the construction of new impervious surfaces? Impervious surfaces include those hard surfaces which prevent or restrict the entry of water into the soil in the manner that such water entered the soils under natural conditions prior to development; or a hard surface area that causes water to run off the surface in greater quantity or at an increased rate of tiol.v from the flow presented under natural conditions prior to development (see TIeIC Chapter 18.06, Tukwila Zoning Code. Page 13 - 12). Such areas include, but are not limited to, rooftops, asphalt or concrete paving, compacted surfaces, or other surfaces that similarly affect the natural infiltration or runoff patterns existing prior to development Please circle ropriute response. - Continue to Question 2 -0 (Pace 2) YES - Continue to Question 1 -4 January 25, 2001 Will the project involve the modification of a watercourse bank or bank of the Green/Duwarnish or Black Rivers between the ordinary high water mark and top of bank? This includes any projects that will require grading on any slope leading. to a river or stream, but will not require work below the ordinary high water mark. Work below the ordinary high er mark is covered in Part C. Please circle appropriate response. ontinue to Question 1 -2 YES - Continue to Question 1 -2 Ciry of Tukwila ESA Screening Checklist M ==^A!!.fi!ct =', tea?"11 ' `...u. —ri... 3 24 Will the project involve clearing within 200 feet of the ordinary high water mark of a watercourse or the Green/Duwamish or Black Rivers? Please circle appropriate response. NO - Continue to Question 3 -0 (Pate 2) YES - Continue to Question 2 -2 2 -2 Will the project involve clearing of any trees within 200 feet of the ordinary high water mark of a watercourse or the Green/Duwamish or Black Rivers? A tree is defined by TNIC 13.06.345 as any self - supporting woody plant, characterized by one main trunk, with a potential diameter - breast - height of 2 inches or more and potential minimum height of 10 feet. Please circle appropriate response. NO - Continue to Question 2 -3 • YES - Continue to Question 2-3 2 -3 Will the project involve clearing of any evergreen trees from within 200 feet of the ordinary high water mark of a watercourse or the Green/Duwamish or Black Rivers? For the purpose of this analysis evergreen means any tree that does not regularly lose all its leaves or needles in the Fall. Please circle appropriate response. NO - Continue to Question 2-4 YES - Continue to Question 2-4 2 -4 Will the project involve clearing within 100 feet of the ordinary high water mark of a watercourse or the Green/Duwamish or Black Rivers? Please circle appropriate response. NO - Continue to Question 3 -0 (Page 1) YES - Continue to Question 2-5 2 -5 Will the project involve clearing within 40 feet of the ordinary high water mark of a watercourse or the Green/Duwarnish or Black Rivers? Please circle appropriate response. NO - Continue to Question 3 -0 (Page 2) YES - Continue to Question 3 -0 (Pace 2) 09/27/2002 13:02 FAX 2537356075 RCI CONSTRUCTION 0 005 Part B (continued) City of Tukwila .ESA Screening Checklist 1-4 Will your project generate stormwater from the creation of impervious surfaces that will not be infiltrated on site? For the purpose of this analysis, infiltration includes the use of a stormwater treatment and management system intended to contain all stormwater on site by allowing it to seep into pervious surface or through other means to be introduced into the wound. If your project involves the construction of impervious surface and does riot include the design of a stormwater management system specifically desiffied to infiltrate stormwater, answer Yes to this question. Please circle appropriate response. NO - Continue to Question 2 -0 (Page 2) YES - Continue to Question 2 -0 (Page 2) Part C: Please review each question below for projects that include clearing. Review each question carefully, considering all phases of your project including, but not limited to construction, normal operation, potential emergency operation, and ongoing and scheduled maintenance. Continue to the next question as directed for each No or Yes answer. January 2i, 2001 4 3 -1 Will the project involve the direct alteration of the channel or bed of a watercourse. :he Green/Duwamish rivers, or Black River? For the purpose of this analysis, channel means the area between the ordinary hieh water mark of both banks of a stream, and bed means the stream bottom substrates, typically within the normal wetted -width of a stream. This includes both temporary and permanent modifications. Please circle appropriate response. NO - Continue'to Question 3 -2 . YES - Continue to Question 3 -2 3 -2 Will the project involve any physical alteration to a watercourse or wetland connected to the Green/Duwamish River? For the purpose of this analysis, "connected to the river means" flowing into via a surface connection or culvert, or having other physical characteristics that allow for access by salmonids. This includes impacts to areas such as sloughs, side channels, remnant oxbows, ditches formed from channelized portions of natural watercourses or any area that may provide off channel rearing habitat for juvenile fish from the Duwamish River. This includes both temporary construction alterations and permanent modifications. Watercourses or wetlands draining to the Green/Duwamish River that have a hanging culvert, culvert with a flap gate, diversion, or any entirely man -made or artificial structure that precludes fish access should answer Yes to this question. Please circle appropriate response. NO - Continue to Question 3 -3 YES - Continue CO Question 3 - 3 -3 Will the project result in the construction of a new structure or hydraulic condition that could be a barrier to salmonid passage within the watercourse or the GreenlDuwamish or Black Rivers? For the purpose of this analysis, a barrier means any artificial or human modified structure or hydraulic condition that inhibits the natural upstream or downstream movement of salmonids, including both juveniles and adults. Please circle appropriate response_ NO - Continue to Question 3-4 YES - Continue to Question 3-4 3-4 Will the project involve a temporary or permanent change in the cross - sectional area of a watercourse or the Green/Duwamish or Black Rivers? For the purpose of this analysis, the cross - sectional area is defined as a profile taken from the ordinary high water mark on the right bank to the ordinary high water mark on the left bank. Please circle appropriate response. NO - Continue to Question 3 -5 YES - Continue to Question 3 -5 3 -5 Will the project require the removal of debris from within the ordinary high water mark of a watercourse or the Green/Duwamish or Black Rivers? For the purpose of this analysis, debris includes, but is not limited to fallen trees. logs, shrubs, rocks, piles, rip -rap, submerged metal, and broken concrete or other building materials. Projects that would require debris removal from a watercourse or the Green/Duwamish or Black Rivers as part of a maintenance activity should answer Yes to this question. Please circle appropriate response. NO - Continue to Question 3 -6 YES - Continue to Question 3 -6 January 25. 2001 09/27/2002 13:03 FAX 2537356075 RCI CONSTRUCTION tl0O6 City of Tukwila ESA Screening Checklist Part D: Please review each question below for projects that include work below the ordinary high water mark of watercourses or the Duwamish/Green or Black Rivers or in wetlands. Review each question carefully, considering all phases of your project including, but not limited to, construction, normal operation, potential emergency operation, and ongoing and scheduled maintenance. Continue to the next question as directed for each No or Yes answer. 09/27/2002 13:03 FAX 2537356075 Part D (continued) 3-6 Will the project result in impacts to watercourses or wetlands that have a surface connection to another watercourse or the Green/Duwamislt or Black Rivers but do not contain habitat conditions that support sammonid use? Such areas may include, but not be limited to hillside seeps and wetlands isolated from the watercourse or river that have a surface water connection to the watercourse or river but are not assessable, nor would be assessable to saimonids under natural conditions: Wetlands with a "functions and values" ratins for basefiowi,roundwater support of 9 and above (or moderate) as described in Cooke (1996) should be included. Please circle appropriate response. NO - Continue to Question 3 -7 YES - Continue to Question 3 -7 3 -7 Will the project include the construction of artificial waterways or wetlands connected to a watercourse containing saimonids? For the purpose of this analysis, the construction of artificial waterways or wetlands includes wetlands, channels, sloughs, or other habitat feature created to enhance wildlife use, particularly waterfowl use, or may be attractive to wildlife, particularly waterfowl. Please circle appropriate response. NO - Continue to Question 3 -3 YES - Continue to Question 3-8 3 -3 Will the project include bank stabilization? For the purpose of this analysis, bank stabilization includes, but is not limited to, rip -rap, rock, log, soil, or vegetated revetments. concrete structures, or similar structures. Please circle appropriate response. NO - Continue to Question 4-0 (Page 2) _ YES - Continue to Question 4-0 (Page 2) January 25. 2001 RCI CONSTRUCTION l 007 City of Tukwila ESA Screening Checklisr 6 c.iiv _ G•arrrl„�.,I. "'lJLtY `✓ ,�,,,NO. ZV:3+�i '" 1i" COMMUNITY DEVELOPMENT CHICAGO TITLE INSURANCE COMPANY SUB! ECT TO THE EXCLUSIONS FROM COVERAGE, THE EXCEPTIONS FROM COVERAGE CONTAINED IN SCHEDULE B AND THE CONDITIONS AND STIPULATIONS, CHICAGO TITLE INSURANCE COMPANY, a Missouri corporation, herein called the Company, insures, as of Data of Policy shown in Schedule A, against lose or damage, not exceeding the Amount of insurance stated in Schedule A, sustained or , incurred by the insured by reason of: 1. Title to the estate or interest described in Schedule A being vested other than as stated therein; 2. Any defect In or lien or Encumbrance on. the title; 3. Utunarketability of the title; • 4. Lack of a right of access to and from the land;•. The invalidity or unenforceability of the lien f the insured mortgage upon the title; 6. The priority of any lien or encumbrance over 'Mellen of the insured mortgage; 7. Lack ofptiority of the lien of the insured ntortgaie overany statutory lien far services, labor or materiel: (a) arising llcom an improvement or work related to the land which is contracted for or commenced prior to Date of Policy; or (b) arising from an improvement ar Work related to the land which is contracted for or commenced ' subsequent to Date of Policy and which is financed in Whole or in part by proceeds of the indebtedness secured by the insured mortgage which at Date of Policy the insured hub advanced or is obligated to advance; 8. The invalidity or tmenforcaability ofany assignmetuofthe insured mortgage, provided the assignment Is shown in SchP-Ant.' A, or the failure of the assignment shown in Schedule A to vest` tic to the insured mortgage in the named Insured assignee free'and clear of all liens, The Company will also pay the costa, attorneys' fees and expenses incurred in defense of the title or the lion of the insured mortgage, as insured, but only to the extent provided In the Conditions and Stipulations, in Witness Whereof, CHICAGO TITLE INSURANCE COMPANY has caused this policy to be signed and sealed as ofDate of Policy shown in Schedule A, the policy to become .valid when countersigned by an authorized signatory, Seattle, Washington 98104 (206) 628 -5666 Issued by; CHICAGO was INSURANCE CO` iRANY ' - 1800 Columbia Seafirst Center 701 5th Avenue CHICAGO TITLE 7NStmANCE COMPANY By: ' • awe tresident ✓ By: acc ry 3/,/ .33 7 . f_,•� - tea OEPTION CLEARED ' ���+ � -�r�.i;;r.�,+'��+.*nvca.r':'�s ,� err: �',!t��'��"1Y;�;3"�:�isl�i�✓': -fir �"t �c�•t AMERICAN LAND TITLE ASSOCIATION omit POLICY RECEIVED 1 AUG 2 9 2002. ALTA Loan Policy tl0•17.92) a "'r.4 1 :“.• �.._..._..,.wr,s. ,..• , .....__....!.'".,v.,n�4r � n,.- ....- nY...,. .... s ..+->.. m w ..+.rv+.,m.n A�•nv. --..nom P.2/13 Z :Z w re 6 0 U O J = I•- WLL w �? tu z l-- Z� U1 al U � O H w W I— L O Z Lu c.) O ~ . Z ' t I�i� �� • , . %�i( {I':P; � fir;. � 1 I •• e muu t3. GYJ'UG G • 4dM'I I.HKIYh.Y ,r^'UL LY SM . I H •1 Date atPalicy:013Ly 13, 1998 1. Name of Insured; 2. The estate or interest referred to herein is at Date of Policy vested ia: CONTAINER PAOPERTZES, .L.0 , A W.49HitiGTON LIrII'I'Eri L,IABZLITX COMPANY 3. The estate or lntcre.st is the land described in Schedule A and whirr is encumbered by thc. Insured mortgage e • 4. The insured mortgage, and assignments, thercot, if any, are desotibud as follows; I.a4o OA CE'NTFa 701 STET .AVS SEATTLE, WA 98184 ELNDED NIOD.TC3A.GZE TOLIC SCHEDULE A . it 12 :4B PM ICE? = NATIONS Agarcien Tttn?, A Io i > IWb ASSOCTATZON FEE STOLE ' SEE ATTACELED DESCRIPTION' S. The land rotund to in tip policy is described am fallouts: S8E ATTACHED DESCAIP ION • Policy No.: 498072 Amount of Insurance: 85 790,p NO.0.54 P.3/13 z = W re 2 6 UO U) 0 U) W J I a l a LL a. = CI W 2 z Z 1 W W 2 U O - .. 0 F- Ww I � � o u i Z . CO I":" F— • Z HWV . 13. Gue1G G.41:51 GRANTOR : TRUSTEE : BENEIf''YCTARYz AMOUNT: ' RECORDED: 12ECOA13XTG NUMBER: LOAN NUMBER LHKNI Y, iULLY SMITH 9 d. I , .1•••. ' "�;�'., � I�ii�t�r:;il ���• T 4 BX .NEBD MORTGAGEE POLICY SCHEDULE A (Continua) INSURED MORTGAGE AND .ASSIGNMENTS, IF ANY DEED OF TRUST At3D ASSIt3NMMNT OF . ENTS .XID /OR LEASES AND THB TERMS AND COND/TIONS TFitREOSs • Policy No.: 498072 NO.054 P.4/13 CONTAINER PROPERTIES, X . L . C . , A, A SH;CNGTON 'LIMITED LIABILZT'Y COMPANY C apAGO Tp1 .Tga (RI NCE _ COMPAt3' =Y U= NATxCNAL ASSOCTATCON, A 1kTATXONAL 1i7i nc7.N SQCIxTSpn , $ 5,730.000.00 Meta 13, .998 980713081'8 ' 3113566721. 9001 AML) 31,1353672a. 9002 _1 . Ir e; Jo UO U) p' W = 0 u. Ili 0 tY Q . u. w d . 1 _ z �. � z W • 0 — p I—; 1 44 I- U '. . w 0 I Z LINE A: LINES: �• - ,ur ri , .'Imi I 1LLt T bI'I1 I M ,:• 41 �$Y11UJt;'1.� . •, . 'I;��i�Y�17''I .,� �•.', � ,.'rl ;7. ?Z�i� i. ENDED MORTGAGEE POLICY SCHEDULE A (Continued) . - • LEGAL DES C1W XON Y .• 1 NIS I., .I • •• -- .wsL... , swam . ... _..r Policy No.: 498072 NO.054 P.5/13 THAT PORTION CE''TRACTS 1 AND 2 OP THE MEADOWS, IACCOR)TNG TO THE PARTITION MAP OF PART OF TEE FRANCIS MCNATT DONATION LAND CLAIM. NO. 36 FILED IN KING COUNTY SUPERIOR COURT CAQSE NUMBER. 120097., AND OF THE D.W D PX1 „Q TgE. =RAM= RIVER, ALL I,OCATZO Ili"' - PCTTO1 - 33, - Egg 2A NOR'. U, RANGE. 4, EAST, WILLAMETTE MERIDIAN. IN XING COt1N Y'�, WAiEli TON, AND ALL LING WESTERLY OF THE WESTERLY MARGIN OP EAST mARGIXAL WAY aodirg AND ALSO WESTEg ,,,OP THH.PAVFIT, OP LAND ADJOINING EAST 'MAfiGII+tL WAY WHICH WAS CONVEYED GRbAT NORTHERN RAILWAY COMPANY 82 DEED RECORDED mNDFR &ECORDING NUMBER 47E4818; LYING EASTERLY OF THE EASTERLY MARGIN (]F THE RIGHT OF WAY OF COME/IC/AZ WATERWAY DISTRICT NO. 1 CDUWAMIS WATERWAY) t LYING SONY OF THE HEREINAFTER DESCRIBED "LANE AY, AND LYING NORTHERLY OP THE HEREINAFTER DESCRIBED !MINE Bus BEGINNING O1T THE WESTERLY MARGIN or EAST HAAGYNAL WAY SOCITU, WHZCFI POZA7T SEARS NORTEi 89 "15' 54 WEST A DISTANCE i71:, 2470. -01. P4 .�1LODILA THE DOI+TATYQN 4LAIM LATE AND SOUTH 23 °40' 59" EAST A DISTANCE: OF 646.77 FEET ALODTQ THE WESTERLY MARGIN OF EAST MARGINAL WAY SOUTH ?RCM TEE INTERSECTI0 OP Tug L7rNE _ EETWEEN THE DONATION' CLAIMS OF PRANCES MCNATT AND HENRY VAIU ASSELT WITH THE EAST LINE OF SECTION 33, TOWNSHIP 24 NORTH, RANGO 4 k".AST„ WILLAMETTE M$'RXDIAN, IN RING COUNTY, WA.VINGTON; RUNNING THENCE 02ST A DISTANCE OF 7.E74.72 PEET TO TFTE mmT L 'OF COMMERCIAL WATERWAY NO. 17 r THENCE SOUTH IS° 00 x'00 a' - 5 • ATi01�7p SIAZD EASTERLY L =NE .IA 'D.ST.AMZE OF 231.76 FE ET TO THE TRUE POINT OF BEGINNING or SAID ' L,NE A" F- :. •: THENCE EAST A =STANCE OF 1053 .IQ � PPE'Z'; THENCE SOUTH 23°02'00 EAST A bI5TANCR OF 46 : fr ppEpA _ THENCE EAST A D1STa N rOF 1 PEES TO T . WESTERLY MRRCZN OP EAST MARGINAL WAY SOUTH AND THE TERMINUS OF SAID ' A" 7 DEGINNZNG ON THE WESTERLY MARGIN OF LAST MARGINAL .WAX Sot2TH AT A POINT WHICH BEARS NOR= B9 °15'.54" WEST A DISTANCE! OF, 247Q.01 FR MAIM ALONG THE DONATION LINE AND SOUTH 23 a 40'59" EAST A DISTANCE OF 1374 ; 17 ' EE' ALONG . THE WESTERLY MARGIN OF EAST MARGINAL WAY SOUTH PROM TH4 INTERSECTION 09 THE LINE BETWEEN THE DONATION CLAIMS OF FRANCIS MLNATT AND HENRY VAN ASSEriT. WITH TES EAST LINE OE SECTION 33, TOWNSHIP 24 NORTH, RANGE A EAST, WILI COUNTY, WASHINGTON, SAID POINT BEING AT T E IN HkEECTIoN OF, B ,WW ',SLY wax= OP EAST MARGINAL WAY SOT WITT3 =az NORTH LINE OP V'AN DE V3INTER $TOC1 FARM TRACT AND THE TRUE POINT OF BEGINNING OF SAID 'MINE A °; . THENCE NORTH 89 °27rS0° WET A EISTAATCE OF 14.94 PEET; THENCE NORTH 85 9 S4'59" WEST A DISTANCE OF 486,97 FEET] TRENCH NORTH 94 04" WEST A DTST4d'CFI pa,, T;,,a..,... THENCE SOUTH 83 "S7' S6" _ A Dz$tANC. OP 119.00 FEAT7 THENCE SOUTH 76 °40'29" WEST A DISTANCE OF 110.1.73 FEET; z • ce W __I C.) UO CO 0 al u) u_ • O UL N d = Z f- Z 0 0— 0 W I H� L I Z U= 0 • Z Hwt.,.1.etem 'e:48PM CARNEY, 'OLE'? SMIT Miiinswasmasu4 '.414gba S.. ' , t.'1/4 1 A LUStr.00, €Vekit' -4 4•WAti'idM O X.Ch il4 ~ NO.054 P.G/13 „ „ ..1 ,1,1 ,• 1 14■ 1 1, i Jlo!' I 0 ,14 , 0 g,t/40 1 1 1 , .-orew( " • $44 EXTRNDED MORTGAGEE roucy SCHEDT_TLE A (Of:maul:Led) LtGAL DP...SCRIPTION racy No.: 49E072 THENCE SOOTEL 03.Q 33 '43 " igEsT DUT.ragoR or S 4 0 . p,? MEL, X9_,,pia..EaSTERLy lasz op THE RDGET O TRAY comtvrERCIA17 in). 1 -ANL) THZ TZA.M1NUS 0? SJ LINE la 11 ; TOGETHER WITH THE R/Gall tto moss's= rARCEL cimnyiaD'To dRENT NoRwHERN RhimwAy COMPANY AS RESERVED TX DEED RECORDED UNDER RACORDING NUMBER 4704010. al rmj j. 1J. LYJb'7G .. 4vrri Sf 1I I H 1 rick ,. Tills policy does not insuxc against loss or dan+Hge (ant{ thy; Company will not pay casts, attorneys' fees or expenses) which arise by reason of; A 1. EASEMENT AND TERMS AND CONDITIONS THEREOF: GRANTEE: PURPOSE: AREA AFFECTED: RECORDED: RECoRDZNG NUMBER: GRANTEE: PURPOSE: AREA APPECTED: DISCLOSED EY: RECORDED: RECORD TQ' NUMBER: P.AaT Y SE2 1TEXT PAGE E`CI'ENIDED MORT'OAGEE POLICY ScHEDLTL 3 B (Continued) RECORDED: NOVam8E1Z 2 , 1973 RECORDING. NUMBER: • ., • r 73113Qfl3DB • NO.054 Policy No.: 49 9 072 KING COUNTY, WASHINGTON- CLOSED TILE DRAIN A 10 FOOT STRIP OF LAND AS nzscRitiam ZN SAID mamma= ARIL 2, 7.932 "" 271619a S 2. UNRECORDED EASEMENT AND THE TERMS AND' CONIIITZONS THEREOF : KING COUNTY, WASEINGTQN UNDERGROt7ND STORM DRAIN OUTPALL DIVE A. STRIP OF LAND 10 F'EE'T IN WIDTH AS D ESCFTBED a, SAID,,W RU NT MODIFICATION THEREOF snImmlap 18, 199AA 9509.E09ss AS FOLLOWS: ONShatO TO DF I A:GI, CGSTS PTO I TBpE ', iC P. MAINTAIN, REPAIR, R ONSTRiJZ".L', .R8PZACE AND RELOCATE THREE DRAINAGE O'(7TPALL PIP> I XNES t MONSANTO AS GRANTOR To 8E RE9ppNSSBLEjQ$. COb1PT,ZANC7E WITH ALu APPLICABLE >rVVZFtOeMEtta ANA OTHER LAWS REGARDT't¢G tim DISCHARGE OF WATER Arm TO INDEMNIFY AND SAVE HARMLESS THE PORT AS GRANTEE FROM ANY LIABILITY OR LOSS ARISING k"RMA 'ESE DISCHARGES. P.7/13 SAID EASEMENT HAf 58 7 1QL1t}:TEn SY e MOD�$C�$TxDAi x, RECORt�E{D UNDER 1 ECQRD 7c�. NDMBE& y5051.$Q955; • - • , r_ 3. 17,SS7RxCTZOMS CONTAINED IN INSTRtiMEAte: .Y+ Z = Z '~ w 0 00 U, 0 w _I _ t- u.. w Q S d w z � Z OI- ❑ U O N t— w w I- H I' O Z w — 1 ~ Z N0.054 P. E1/13 ` ..I ,0 " ° }7 ( ,•�, RECORDED: RECORDING NUMBER: RECORDING: • • cuacg.Go TITLE INSURANCE COl PANY =TENDED MORTGAGEE POLICY SCHEDULE B (Continua) PART I L 4, AGREEMENT AND THE TERMS AND CONDITIONS THEREOF: BETWEEN: AND t F S. AGREEMENT AND THE TERMS AND CONDITIONS TF EREOP: Polity No.: 49 8072 CITY Off' SEATTLE, A MUNICIPAL CORPORATION MONSANTO CHEMICAL COMPANY, A DELAWARE CORPORATION J UNE 4 r 1963 5591.646 -- _ "WRR. CONNECTION AGREEMENT BETWEEN: MONSANTO COMPANY AND: PACIFICC CAR,AND FOUNDRY COMPANY RECORDED: .... AUGUST 3.4 lags.. , . " • • RECORDING N'URDER" 6064204 REGARDING: USE OP JOINT SEWER • J 6. ANY PROHIBITION OR LIMITATI= OP USE OCCUPANCY OR IMPROVEMENT OP TH2 LAND RESULTING FROM THB RIGHTS OF TES PUBLIC OR RYP OWNERS EA VSE ANY PORTION WHICH IS NOW OR HAS BEEN FORMERLY COVERED BY WATER, H 7. kARAMOIINT RIGHTS AN$ EASEMENTS IN P .VOR 05 THE UN:TED STATES FOR ComaRCE, NAVIGATION, FISHERIES AND THE PRODUCTION OF POWER. N B. GENERAL AND SPECIAL TAXES AND CHARGES, PAYABLE FEBRUARY 1.5, DELINQUENT IP FIRST HALF UNPAID ON MAY 1, SECOND HALF DELINQUENT Ili UNPAID o NOVEMBER 1. OP THE TAX YEAR (AMO[]rTIS D4 DIOT - INCLUDE, INTEREST .AND PENALTIES) : "- .". • . , • - - YEAR: 1998 TAX ACCOUNT NUMBER: 542260 - 0010 - 04 LEVY CODS: 2430 ASSESSED VALUE -LAND: $ 2.526,000.O ASSESSED WIDE-IMPROVEMENTS: $ 7E0,000.00 GENERAL & SPECIAL TAXES; ob. BILLED: $39 PAID: 018,927.57 [7NPAID: $19427.56 CMIOVZOT41211131.MANCIncoMPANY • MoRGEstiZ idOra Wi, f. • AUG.13.2202 2: 49Pi C a RNE ` ThDLEY !SMITH BT GRANTEE PLRFOSE: AREA AFFECTED: RECORDED: .. RECORDING DTQMB ER ; CHICAGO TITLE INSURANCE COMPANY 83L3'END33O MORTGAGEE POLICY S MEDULE B (continued) PA$'z' I AF 9. EASEMENT AND THE Ttams AND CONDITIONS THEREOF: IMO THE HOEING COMPANY, A DELAWARE CORPORATION COMMUNICATIONS DUCT SAW EA5TmLY POR.TI'ON Or. SAID PREMISES i7�7E Tr, "19 7 a 980s06D93s ENO OP sIZED= 3 - F&.T I ** NO.054 Policy ri ; t9 8a72 4g la, THS 9OLTaOWING MATTERS DISCLOSED BY ggyzY, PAPIPA sc BY SUSS, ROM & HITOHINGS i SI3'C. ,' D 'TEIY1' MAY 9 ,i l9 9 8 , aos NO. 981.02.00: 1. FENCE ENCROACHES NORTH OF THE NORTH LINE; 2. PENCE =mammas SOUTH OF ,TILL SOUTH LINE; 3. FENCE EATCROACF.'$ NORTH OF THE 90XITH LIN 4. comma= PAD ENCROACHES SOUTH OF THE SOUTH LINE; S. BUILDINGS ENCRQJj,CH OVER THE DRAINAGE EASEMENT ARRA. AS ESTABLISHED BY ZTSTRUMF.'NTS RECORDED UNDER R CORDING =MIER 271.6188 AND 8s091a09so; 6. PILINGS FOR WOdb DOaK"EXTEiQD ZN 'O viz =AMISH W- T2RwAX, 7. TRAFFIC' CONTROL SOX .ANn TRAFFIC LIGHT GUY POLE ENCROACH WEST OF THE sT LINE,' . 8. ANY CLAIM OF ADVERSE RIGHTS B�" Tss' EXZS'.I'ENCZ OF RAILROAD SPURS OVER A SOUTHERLY PORTION OF SAID PREMISES FOR WHICH WE FIND NO EASEMENT OR AGREEMENT 0P REECOFLD . ' a ricAOo rauliNsLMANCEI COMPANY - �.fln+nre r.•. sn<,w�. ro'i...0•.1 571 1 ++,+rMa•sieae �++v ^ ±�.'..- s�•C'j'°, ."— 'yv— "'•�;,,. MCIRO1 1 P.9/13 z _I- '�. z re 2 W . 6 00 N CI fA W W g = a Z F Z 0 W U • CO O CO • H WW H F u"O W 1. O H z , tIJV. 1J. LY1C3L • In addition to the matters sct forth in Part I of this SehodUle, the title to the cstate or interest in the land described or referred to in Schedule A Is subject to the following matters, if any be shown, but the; Company insures that such matters art subordinate to the lien or c1 go of the insured mortgage upon said estate or inturost: BS NONE .' a+ere•e LHKiytr, — I Lt.Y sM1 f H ,o-e , rE ( ! ,'i' t l n;. � : i�; .f ,n, ,; 7":111,, '��; : it 'i': ,'t' • AUTHORIZED SIGNATORY Loan Polite Endorsements: 10R, 103 r 3, �,Q3.4. 143.6, B.1, 5.0, 116, 1164, ssSp srarr Owneres polite SndOrnements: N/A Ca:Er- o•o'YTn_t: INeu&A.NCt3 COMPANY 'C RIC'AGO TITLE Adst ANCE COMPANY' EXTENDP—VMORTGAGMI POLICY SC3E1JT.)LE B Cositiinuod) PART Xr ,co-•' TM Or SC EDU Z B ** •..., ,N.. . n , • NO.054 P.10/13 Policy No.: 498472 r• The following matters erns expreeaty excluded *mitre coverage of this policy And Me Company will hat pay luaa or damage, orate, stterneyst fees or expenses which arise by reason of: 1. (a) Any law, ordinance orpovernmental regulation (Including but not limited to betiding and Zoning lame ord(mtnces or regglsdlona) restrict- ing, regu)atfhg, prohibiting or meeting to (i) the occuppancy, use, or enjoyment of the lend; (11) the character, dimensions or tovatIOn of any Improvement now Of henratter erected on the lend; (1 a separation in ownerihlp or a change kr the dimensions or area of the lender any parcel of which the land is or was a part; or (Iv) environmental protection, or the effect of Any violation of these lows, ordinances ar governmental regulatlone, except to the extant that a notice of the enforcement thereof or a notice of a defect, Hurt or encumbrance resulting from a vioietton or alleged violation affecting the land hes been moat .d in the public records at pale et Policy: (b) Ahygovemmental police p ewernot excluded by (a) above, except to the extent that a notice of the exercise thereof era notice of a defect, nen or encumbrance resulting from a violation or alleged violation affecting the land has been recorded In the public records at Data of Policy. 2. Rights of eminent domain unless notice of the exorolssthereot has berm Decor In the pubila records at Date of Polley, but na( excluding from coverage any tatting which hits Gee-erred pdortd Date of Policywhlch would tae binding on the rights or s purehuerforvalue without knowledge. 3. Defects, liens, encumbrances, adverse clams cr outer t1ilutteree (a) created, suffered, assumed or agreed to by the Insure claimant; (b) not known to the c ompany, not recorded in ih6 public records at elate of Policy, but known to the Instead el:emant slid got dlscieeed in writing to the Company byte insured claimant prior to the data the Insured claimant become an insured under this policy; (c) mauftlna In no lose or damage to the Insured ciaimant; (d) attaching or created autmequent to pate of Policy (except to the extent that thla policy Ineuree the priority of the lien of the insured mortgage over any statutory Hen for services. Sabot or material); or (a) resulting In lose or damage which would pat have been sustained If the Tneured claimant had paid value for the Insured mortgage. 4. Unenforeeabillty of Mellen of the insured mortaae becauee of the inebilityor fallure fifths insured at Pate of Policy, orthe inability or failure of any subsequent owner at the indebtedness, to ?amply with applicable doing business lawn of the state In which the land is situated. 3. Invalidity or unanforceabliltyof the lien of the teetered mortge v, or alalm thereof, which artsee out of the transection evidenced by the insured htortgege and Ia based upon usury or any consumer cradlt protection or truth In lending few. 6, Any statutorylieniorservices, leborormateri elv( ortheclaimofpriorityofanystatutory lienf orservlces, laborormaterielsoverthel ienofthe insuredmart gage) anteing tr'om an tmpravementorwork relstedtotha lend which is contracted for and cemmeneed subsequent to Detect Policy and Is nottlnaneed to whole or in part by proceeds of the indebtedness secured by the insured tnortgege which at Dale of Polley the insured has rutvanced or Ti obligated to advance. 7, Any claim, which erases outof the transaction creating the Internet of the mortgagee Insured by thie policy, by reasen dela operational federal bankruptcy, state insolvenay, ar similar oreditota' rllshte laws, that is used on: (q thetnsneacuan creating the interest of the insured Mortgagee being deemed a fraudulent conveyance or iraudulenttransfer; or ' (Ii) the subordination of the interest of the insured mortgagee as a result of the application of the doctrine of equitable subordination: or (tit) r h e eul e s : f n o m li seating The interest of the Invalid Mortgagee being deemed a preferential transfer except where the preferential transfer (a) to timely record the Instrument of transfer, or (b) of such recordation to Impart notice to a purchaser far value or judgment or lien creditor. t, DEFINITION OP TERMS _ 'e lollowtng terms when used in this policy meant ( "Mewed"; the Insured named in $chodulo A. The term "Insured" attic Irre (I) the owner of the indebtedness secured by tfln insured mo'tlgege and each succeaeer in ownership otths Indebtedness except a successor who fa an Obligor under the provisions of Section 12(c) of those Conditions and Stlpulaticns (reserving, however, all rights end deffenees as to any successor that the Company would have had against any predecessor Insured. unless the successor acquired the lndabtedneae ea a purchaser for value without knowledge of the asserted defeat, lien, encumbrance, adverse claim Mother matter insuredaoalnsl by this policy as at—recline title to the estate or intent in the Iced); an any governrnentai agency or governmental InstruntentaUty which lean !neater or guarantor under an Insurance centred or guaranty Insuring or guaranteeing the indebtedness secured hythe insured mortgage. orany pert thereof. Whether named as Ott Insured herein or not; (Ile the parties daslgnaled In Section 2(a) of these Conditions and Stipule: hero. (b) ^Insured claimant ": an Insured claiming lass or demago. edge or notic e whic hrmay b"known_ mputed to an In used by reason ol he pubic records as defined In this policy or any other records which impart construc- tive notice of matters affecting the Tend, (d) "land ": the land deecribed or taloned to In Sohedt4le A, and improve- manta affixed thereto which by law constitute real prep en'. The term' land" does not include any property beyond the tines of the a area described or ref erred to In Sehedula A, nor anyvlght, title. Interest, estate or easement in abuttltiCstreete, roads, avenues, alleys, lanes, ways or waterways, but noth- Ing herein shallmodif yor Omit the extent lawhlch aright o1amasser and from the land 19 insured by this policy, (e) "mortgage ": menage, deed o1 trust, trust deed, or other security Instrument. EXCLUSIONS FROM COVERAGR CONDITIONS AND STIPULATIONS \ ••••. " ^- NO.054 (i) "public records ": records establlehed under State emitters at Date of • Policy for the purpose of Imparting constructive nano of matters relating to real Meade �tel ter value and without knowledge, with respect to Section t a v) of the eccreelons From Covetaeo,''publia reeordse ehall also Include enulronmental protection liens flied in the recorder of the clerk of the. — Untted States district Coen for the district in which the tend Is located. (g) "unmetketabllily of the title ": art alleged or apparerd matter affecting the ilea to the lend, not excluded or excepted from coveravp. which Would entitle a purchaser or the estate or Intermit described in Se =lute A or the Insured montgegeto be released from the obligation to purchase by virtue of a contractual condition requiring the delivery of marketabie Elite, 2. CONTINUATION OF INSURANCE ' (a) After Acquisition of Title. The coverage of this policy dial! Continue in force as of Detect Policy in Tavorof (Q enI rise red who acgelreaau Pert af the estate or interest in the fend py lot ac(osur0, trustee's vele, conveyance In lieu et farecloeure. or other legal manner which dtc harges the lien of the Insured mortgage; (ii) a trwioteme of In estate or Interests,: aoqulredfrom an insured corporation, provided tfle transferee is the parent or whclly'owned subsidiary of the insuredcarrppooratiun, and their corporate successors ley opor- ation of law and not by ptu'chase, subject to any rights Or detensea the Com- pany maY have againstany predecessor I undo; are: Merry governmental agency or ocvemmental Instrumentality w aociUiree an or any part of iho eet$,fO or Interest pursuant to a contract of inaruranta or 9earanry Insuring or guaranteeing the Indebtedness secured by the insured mortgage. (b) After Conveyance of Tllle. The overage of this policy shall continue In farce as of Date of policy In Taxer of an Insured only so long as the Insured retains an estate or treereatlnlhe tand.ar holds an igdabtednees secured bye. purohaae money Mortgage given by a purchoserfrom then Insured, or only so long as the Insured shall have. liability by reason of covenants of warranty made by the Insured In any transfer or conveyance or Ins estate or Interest. This policy shall net continue in forces in favor of any purahaeer from the Insured of either (I) an estate or Intermit in the land. or (II) en indohmdnass secured by apurchase mgney mortgage given lathe Insured. P.11/13 mm .. —t ,,,rV. i.�. �ur�c...� G• �1rIt.. l 11JL.Y beet ' (c) Amountot insurance. The amount of Insurance after the acquisition or after the conveyance shalt in neither event exceed the least on the Amount of insurance stated in $chadulo A; le the amount Of the principal oftheindeb tedn cgs secu rod by the InsUrod .gage as of Dale of Palley, interest thereon, expenses of foreclosure. ►mounts advanced pursuant w the lnaured mortgage to aaaure compliance with !ewe or to protect tfte lien of the Meurer) mortgage prior to eta time of acqul:Itian of Ira oclate or lydpraol In the land and secured thereby end reasonable amounts expanded to prevent deterldraGorr of Improvements. but reduced by the amount of all payments made; or (111) the amount paid by any governmental agency ar governmental lnstrU• mentality, If th e agency or Instrumentality is the insured cleimant, In the acqul• union of the estate or Interest In satisfaction of its insurance contract or guae only. 3. NOTICE OF CLAIM TO BE GIVEN BY INSURED CLAIMANT The Insured shall notify the Company promptly in writing (1) ie ease of any Iftigattee asset forth in Section 4(a) below, (II) I n ease knowledge shall come to an insured hereunder of arty claim of title or interest which le adverse to the agate the estate orinterest or the Ilan of the insured mortgage, as Insured, and which might euuee lase or damage far which the Company may be liable by virtue of this policy, or pit) If title to ilia estate or interest or the Ilan of the Insured mortgage, as insured, is rejected a$ unmariteteele. Ii prompt notice *halt not be seven to the Company, than as to the Insured all liability of the Company shad] terminate with teemed to the mutterermttlere for Mitch prompt notice Is melted: provided, hewover, that failure to notify the Company *half in no Casa prejudice the rights or any insured under this policy unless the p Comp d any shall be proIudfcod by the failure and then only to the extant or the 4. DEFENSE AND PROSECUTION OF ACTIONS; DUTY OP INSURED CLAIMANT TO COOPERATE (a) Upon written request by the hatred and subject to the options can. mined In Section 9 of these Conditions and Stipulations, the Company, at Its own oast and without unreasonable delay, shall provide far the defense of an Insured in iltlffat!on In which any third party ssaertse claim adverse to the title or Interest 8s insured, but only as ei tease Waled causes of action alleging a defeat, lien or anaumbragae or other matter insured against by this polioy, The Company *hall have the tight to Select cattrtsel of Its choice (subject to the right of the lettered to abject for reasonable cause) to represent the Insured as r.- • hogs stated causes of action and shall not be liable for and will not pay the of any other couneeI The Company will not pay any fees, costs or apses inc by the Inaured In the defenwu of those causes of action f allege matters not Inaured against by this policy. (b) The Company ehail have the right, at its own cast, m irto ltuta and prosecute any aotlon or proceeding or to do any ocher set which In its opinion may be necessary or desirable to estabU h the title to the estate or Interest or the lien of the insured reengage, ea it Ured or to prevent or reduce lose or damage to the insured. The Company may late any appropriate action under the terms of thle policy, whether or not it shell be liable hereunder, and shall not thereby concede liability or waive any provision of this polity. If the Company shell exercise its rights under this paragraph, it 4lrall do ao dtilaantly. (c) Whenever the Company shall have brought an notion or Interposed a def ense ea required or permitted by the provisions of this policy, the Company may pwaue any litigation to final aetermtnetton by a court of competent Jude. dictlort end expressly reseIves the fiatht, in its sole discretion, to appeal from any edvetse judgment or order. (d) In all ogees where this pollcypermks or requires the Company to prose- cute or provide forthe defense or any action or proceeding, the Insured shall secure to the Company the right to so prosecute or provide defense In the action Orprooek er n. and all appealetherein, and permit the Company to use, at Its option, the numerates insured forties purpose. Wheneve requested by the Company. the Insured, at the Company's oxpenee, shell give the Com• pony tel reasonable aid (I) in any action or proceeding, esaurtng ovlden,te. abtalrtinG Witnesses, prnaecutiny or defending the action or proceeding, or effecting settlement, and (q) In any other lawful eat which in the opinion of the Company may be necessary or desirable to establish the title to the estate or interest or the lien of the Inaured mortgage, as Inaured. If the Company Is prejudiced by the fell are of the Insured to furnish the required cooperation, the Company's obligations to the Insured under the policy shall terminate, includ- Inc any Lability orabllpatten to defend, proaeoute, or continue any litigation. With regard to the matter or matters rogutring such cooperation. S. PAoOF OF LOSS OR DAMAGE in addition to and after the notices requlre'd under Section 3 of those Cdndl- Mena and 6llpulaflons hove been provided the Company, a proof of toes or damn a weaned and sworn to by the inaurtid claimant ehatt be furufshedto the Company within PP days after the inaurad claimant eholl aucerlain the facts e ell rise to the loss or damage. The proof of lase or damage shall desartbe mat by h this policy which conetic toe he the eal. title, ffleaser dam go end shall to the extent possible, the bads of ealoulatlnti the amount of the 10134 or damage, if the Company is prejudiced by the failure of the insured clatmont to provide the required proof of lass or damage, the Company's obligations to the insured under the poltry shell terminate, inciuding any liability or oblige. Seri to defend, prosecute, or continue any ltigation, with regard to the matter or Matters requiring such proof of loss or damage, In addition, the Insured claimant flirty reasonably Pe required to submit to • examination under meth by any authorized representative of teie Corer: any and shell produce for examination, inspection and copying, at such reason. able times and places ee pray he designated by any authorized representative of the Company, all records, books, ledgers. checks, correspondence one memoranda. whether bearing a date before or after Dale or Policy, which reasonably pertain to the loss Or damage, Further, if requested by any author- ized representative of the Cornpany, the Insured clalipant shall grant as per- mission, In writing, for any authorized representative odthe Company 10 exam- ine, Inspect and copy all records, books, ledgers, crack *, correspondence and memoranda in the custody or control of a third petty. which reasonably pertain to the Lass or damage, All Information deeigrteted as confidential by the insured claimant provided to the Company pursuant to this Section shall not be disclosed to others unless, In the reasonable jug merit of the Corn. pony, It le a in of the claim. Failure of the Insured claimant to nece submit aaty for examination under oath, produce other reeaonahiy requested InfortnaUan or grant permlaslon to secure reasonably necessary information from thins parties as required in ells paragraph, unlace prohibited by law or governmental regulation, shall terminate any liability or the Company ender this poi icy as to that claim, - B. OPTIONS PAY OR OTRERWISB SETTLE CLAIMS; TLRMINATlON OF LIABILITY In ease of a claim under this policy, the Company shall have the lollowing additional options: (a) To Pay or Tender Paymeht of the Amount of !flamenco or to Pttrahaae the indebtedness, (I) to pay or iencler payment of the amounts? Insurance under thla policy together With any teats, attorneys' foes and expenses Incurred !wale Insured claimant. welch were authorized by the Company, Up to the time of payment or tender of payment and Which the Company to obligated to pay: or (ti) to purchase the Indebtedness [toured by the insured mortgage for the amount owing thereon together with any Coats. attorneys tees and expenses incurred WO!) Inaured claimant Which wore authorized by the Company up to the lima of purchase and which the Company is obligated to pay, li the Company ottoman purchase rho indeb twenties as herein provided, the owner of the Indebtedness shall transfer, assign, and convoy the Indebted- ness and the insured mortgage. together with any collateral security, le the Company upon payment therefor, Upon the exercise by the Company of elttrer of the options provided for In paragraphs all) or (Ii), ell liability arid obligations Io the insured under thin policy, other then to make the payment required 1n those paragraphs, shall terminate, inciuding any liability or obligation to defend, prosecute, or mn e Mlle any litigation, and the policy shall be surrendered to theCompany for caneeilatlon, (b) To pay or Otherwise Settle With Parties Other than the Inaured or With the Inserted Claimant, (q to pey or otherwise settle with other parties for or in the name of an Insured claimant a ny claim Insured against under this poltcy, loge therwen any costs, attorneye' fees and expenses Incurred by the insured claimant which ' were authorized by the Company Up to the time of payment and which the Company fa ablI eted to pay; or _ provide ay under ih a policy, , togeth r with any c�ossta, attorneys' or and expenses Incurred by The Insured claimant which were authorized by the Company up teethe time of payment and which the Company le obligated to pa l.. eon the exercise by the Company of either of the nptlons provided for In paragraphs (b)U) or (ii), the Campany nblfgetfanu to the inaurad under eels palely for the alalmed lose or damage, other than the payments required to be made, shat! terminals, Including any liability or obligation to defend. prose - cute or continue any litigation, Z nETERMINATION ANt) PeaTENT OF UAbILITY This poilay is a contract of indemnity ageinet actual monetary leas or dam- age sgatetned or Incurred by the Insured claimant who has suffered loss or damage by reason of mutters insured against by this policy and only to the extent herein described. of• (a) The liability of the Company under this policy shall not exceed the feast (1) the Amount of Insurance gated in Schedule A, or, it applicable, the amount of insurance as defined In Section 2 (o) of these con tans and Stipulatfansi (II) the amount of the unpaid principal Indebtednese secured by the insured rgoftgage as limited or provided under Section 8 at these Conditions end StipPulations or as reduced under Section B at these Conditions and Stipulations, at the time the lose or damage insured agolnat by this policy aeours, teeether with Interest thereon; or F aeeeeeeeeleneeleee Q • Z ~ W 0 co WI H u) LL, L _ d = Lai Z I• -O Z W U � 0 _ I_ W H-- L ie Lt.l co O~ Z ': I •U17, Lo. aweic • (Ili) the difference between the value at the insured °elate or Interest es insured and the value of the Insured estate or Interest eubJect to the defect, lien or encumbrance Insured against by this policy. (b) in the event the Immured has aaqulrad the estate or Interest In the manner described to Section 2(e) of these anditicne and Stipulations or Ilea core veyedthe 1111e. then the liability of the Company shall continuo es sot forth In section Ira) of the Conditions and Stipulations (011ie Company will pay Only those costs, attomaya foes avid expenses intturrod In accOrdance with SeOU0n 4 of these Condition$ and Stipulations. 8. LIMITATION OR toilet-ITV (a) If the Company establishes the title, or removes the alleged defect, lion or encumbrance, or cures the lack of a right el accrue to orircm the land, or cures the claim of unmarketabillty of tile, or otherwlea eetablIshesthe lien of the Insured mortgage, all as lnsered, in a reasonably diligent manner try any method. including Mier tloh and the completion of any appeals therefrom, it shall have fully performed its ob1Igetions wllh respect to that matter and shall not be liable for arty tree or damage caused thereby. (e) In the event el any litigation, Including litigation by the Company or with the Company's eonsant, the Oomneny (shall have no liability for lessor dam• ego until there has been aflnal determination by court of compatentlurlsdio• lion, and disposttest of all appeals therefrom, adverse to the title or to the lien of the Insured mortgage. ae instead. (c) The Company shall not tee tiebte for lose or Omega to any Insered.for liability voiur:tartly assumed by the Insured In settling any claimer suet without the prior written consent 01 the Company. (d) The Company shall not be Negate: Many Indebtedness created aubse- gene to Palo of Policy except for advances made to protect the lien of the insured mortgage and secured thereby and reasonable amounts expended to prevent deterioration of Intprovementei Or (iI) construction loan advances made subsequent to Date of Polity, except construction loan advances made subsequent to Date of Policy for tha purpose of nnancing In whole grin part the construction of an Imprevemenl to the land which n Data of Polley were cecuredby the Insured mortgage andwhlchtheinsured lnuedto be obligated to advance at and after Date of Policy, O. REDUCTION OF INSURANCE; REDUCr10N Ole TERMINATION OF LIP:Wa t (a) All payments under thin policy, except payment* made for costa, attor- neys' feed and expenses, shall reduce the =cure aline Insurance pre tarnto. however, any payments mode prior lathe acquisition of tele lathe estate or Merest as ptnvlded In Setrtion 2(a) of these Conditions and Stip Iations shall not reduce pro tattto the amount of the Insurance afforded under this policy oxcepttothe extent thaithe payments reduce the amount of the Indebtedness secured by the Insured marlgege. (b) Payment in pan by any person of the principal of the indebtedness, or any other obllpatton secured by One Insured rnortgego. ar any voluntary partial satisfaction or release el the Insured mortgage, to ten extant of the payment, erresfeetlon or relapse, shalt reduce the amount of insurance pro Wee. The amount of insurance may thereafter be increased by accruing Interout trod advances roads In treolect the lien of trio insured morlgege end secured thereby, with Interest thereon, provided In no client shall the amount of Mule erica be greater than the Amount of insurance elated In Schedule A. (o Payment In full Ity any person :Vibe voluntary eallefactlon or release of trie insured mortgage shall terminate ail Debility of the Company except as provided In Section 2(a) of teasa Conditions and Slipurailone. ta. LIABILITY NONCUMULATIVE if the insured acquires title to the estate or Interest in satisfaction of the Indebtedness secured by the insured mortgage, or any part thereof, It Is expressly understaod that the amount of insurance under this policy shall be reduced by any amount the Company may pay under any parry Insuring a mortgage to which exception le taken in Schedule B or W which the insured has agreed, assumed, or taKen subject, or which is hereafter executed by an insured end which lea charge or Illan on the estate or Interest deacribed or referred to In Schedule A. and the amount xo paid shalt be deemed a payment under this policy. 11. PAYMENT OF LOSS • (a) No payment shall be made without producing this pansy for Ondoeste men* of the payment unless the policy has been lost or destroyed, In ).rhlch case proof of lose or destruction shall be furnished to the satisfaction of•the Company. (b) When Ileblliiyand the extent of loss or damage has been dennitelyfixed In axordenco with these Conditions and Stipulations, tile loos or damage shag be payable within 50 days thereafter. 12. SUSRQGATiON UPON PAYMENT OR SETTLEMENT a , ,, (a) The Company's We of atsOmpstlnrr. Whenever inn Company shall reeve settled and paid a claim under hfs policy. ell right of subrogation (shall vast in the Company unaffected by any alt of the Insured claimant. Tea Company shall be subrogaled to arid be entitled to all right's and remedies which the insured claimant would have had against any person or properly in reapectta tltaclaim had this policy not been hued, if requested by the Company, the Insured claimant shalt trann ter to the Company all rights ewe* ram Na . eeS7 fit . Ia.17•D7) i..`,h:; Giwnn`?tphRny, 4: �'�- '.,`.Ili •;krr�F«.. _�'r.y3ww.n+..m;a� ...�.... ,... „ LHNINLY " SMITH • • 4 NO.054 P.13/13 end remedies against any person or property necessary In order to perfect this right of (subrogation. The Insured claimant shalt permit the Company to sue, compromise or settle in the name ofthe insured oialntarit and to use the name of the insured claimant In any transaction or litigation Involving iheee rights or remedies. If a payment an. account of a Matra does not hay cover the loss of the Insured claimant, the Company shall be subrooaiad to all rights and remade. or the insured claimant after the InsUmd claimant aetatl have recovered its principal, Interest, and costs of collection. (b) The 'Hound's Rights and LImltallone. Notwithstanding the foregoing. the Owner of he lndobtedeeee secured by the Insured mortgage, provided the priority of the lien oldie insured mortgage or Its ortfareeaeility le not affected, may release qr (substitute the personal liability of any debtor or portion auuarantor, or extend or otherwise modify the terms of insured t a a or release any the llats al s for the indebtedness When the permitted acts of the insured claimant occur andthe Insured has knowledge of any claim of title or Interest adverse to the Mlle to the eetale or interact or the priority or enforceability (tithe flee 01 the Insured mortgage. as insured, the Company shall Re rsqulred to pay only that part of any losses Insured against by this policy which ehail lcsedthe ,arnount,Ifany.lasttothe company by reason of the impairment by the Insured claimant of the Compa- ny's right of subrngatiore (c) The Company's Rights Aoki! Non - insured Obligors. The Company's right of subrogation against non•Insured cello= shell exlul and shall include. without limitation, the rights seta Insured td Indent' niece, guaranties, ether petioles of Insurance or ponds. notwithstanding any terms orcondeldns contained in those Instruments which provide for subroga- tion rights by reason of this policy. 'ilie Company's right of subroyatlan shall not be avoided' be aaqutslttan of the insured mortgage by an obligor (except an Meteor deacrihod In Section 1(a)(Ii) of these Conditions end Sdpulatioris) who acquires the insured more ggge as a result of art indemnity, guarantee, other ponce of Irniuvrance, or bond and the obligor wiil not he an insured under ibis policy. notwittrstending Sere lion 1(e O) of these Conditions and Stipulations, 13. ARBITRATiON Unlace pfohlbited by applicabia law, either lint Company orthe Insured may demand arbltraliorl puleuallt to the Title Insurance Arbitration Rules of the Amerieun ArhbiitrationAasoalaHon .Arbitreble matters may Inctudo,but are not limited to, airy controversy or claim between the Company acrd the Insured arising out of or relating fa thin polity; any service or the Company In connate eon with its Is :Dance or the breach of :sparely provision or otherobllpation, ,4II arbitrable matters when the Amount of Insurance Is 41,000,O130 or lass shall be arbitrated attha option of eiUlerthe Company at the Insured. Ait arbitrable matters when the Amount of Insurance Is In exceea of $1,000,00D shall be arbitrated ene/ when agreed tobyboth the Cornpeny ndtheInsured,Mbttra- lion pursuant In this polfcy,and under the Rules in effect on the date the demand for arbitration is made or, at the option of the inured, the Rules In effect at bate of Policy omen be bindlne upon the partiea.Thu award may include attorneys' road arty It the lawn of the state inwhlch the land Is located" permit a acurt to award attomaYa' fees to a prevailing party. Judgmunt upon the award rendered by the Arbltrator(s) may be entered ln,any court having jurisdiction thereof. The law of the sltus of the land shall apply to an arbltraUnn under the Title insurance Art'ftratlan Rules., A copy rather Rules maybe obtalnedTrorn the Company upon request. 14. LIABILITY LIMITED TO 11418 POLICY; POLICY Ell1RE CONTRACT (h) Thle pohl ytpgalhorwithali endoreemonist, it any hereto by the Company le the entire policy and contract between the !net:redend the c am' • parry. In Interpreting Any provision of this policy, thin policy shall be construed as s whole• Lb) My claim of loss or damage. whether or not based an npgliganua• and which ea out at the status of the Ilan of the Inaurad mongagge Qr clthe title to the estate 4tlnterest covered hereby or by any action asserting such claims shall be restricted to this pcAwy. (C) No amendment of or endareoment to this poky can be made except by smiting endonred hereon qr attached hernia signed by eitherthe President, a Vice P ealdent, the Seerelary. an AMsIatent Saorat , or validating officer or authorized slgnatgry of the Company. 15. 6EVERABILITY in the aveYtt any provision of title Dailey is heir! inir lid or unenfarceabie under Applicable law, the policy shall bedeemed not to include that provision and all other provision shall remain in lull force and effect. 16. NOTICES, voimg 3giiT All notloos required to be given the Compeannyy and any afaameru In Waring required to be furnished the Company shall include the number a(thls palleY end shall be addressed lathe Company at the lasuinp office or to: Chicago Titre insurance Company Claims Department 171 North Clark strut Chicega,111inoia p X504 0 IIRS 1000 Scale in Feet 2000 i•!A`Ai is s> I ' tl Reference: USGS Topographic Quadrangle Map, South Seattle, Washington, Photo Revised 1968 AUG 9 9 2002.1 c;OMMUNITY Figure 1 -1 DEVELOPMENT Vicinity Map Container Properties LLC /Former Rhone - Poulenc Facility Tukwila, Washington 11 ®�.o 2.a[ aana. .o Nua •taa,n ‘. 1 itti) nem wan cum in sox ,.22,11 2.a.a.aa�•Na,aa . ■2222 Vo Canaan !liana - L'' : ' 2.+. m m m• t°°t ....:10111. pO 2 Lon m 21 ia2 -/hAaP •a ,'"'"V22* `r AIPw1l�PwVrY a•al.p arg aa.P il S.W. r4 pi v 2. 4uR. 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T am 1121.0 Ora • • . a.ta . aGOt7d L ^ Rali�fam .. u0 11'22 a9WCw� 2222. • 2. 0.220 410 0.211 WS •� MIMI ♦ • Fm y l a <w�PL 2.51 321V • __...... �... -. • -w2._ lam '. .0 1111 - •VII 11 1220 S .•i 11 •2.•i O iI f a1a , Lyr ajS 0.2201 aS•i • - •f= •• • h.fl H 2.r • 12 H •.l l.•2. TIT.w WIT 7•1 I. a a .•[1 12. 1• - I 2t• • M a • V.•1 tbfw ♦[I N•1 - 2.N It • [[ fa, .M0 Ha - a.t 122 201 2 2 1 1 • n NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. veil ua la.2.2211 l...• 1 N •• L •1. o \ D 11 i a ig, ���:� /112 5 11 H a EE� E11 111/1i 517E ADDRESS 9229 EAST MARGINAL WAY SOUTH ( ji i,pq 'p`j�aj� irool•II ��' -f Ijai= i E i• i j1 1 : ' it t 15' �l�'I i 7 i f + o s.11• iii 3 \ _ 1 i 1 TI ., ii�.i�,ii. pip i: +,1 i �_• i.i !:!s l l 111;41 [iil. 1iiti ti ,.1!. ili :i jf� iil i ![i iii7, +ja11; s a 3I i i 11'77+ 1 j i .Ih 111:, 1 iyi.I.1 l 1 ;Ri , 1 la i s ++ .. Pi •I i 1 al - El Ii1ii111liiiili. it a7�.aia11 I lll u a7 aili ' I A L T A SURVEY PREPARED TOR g t RHONE — POULENC INC. ! N _ r p • + n Y , `:ti \ uF Ii 1111! - ii Iii I• 1 a .. .. .e, Al ,....s.-;, l . lyl ' i 1 ��i • • ' ` . a; • >■ p �NP�ERVJP� . �. BUSH, ROED & HITCHINGS, INC. CIVIL ENGINEERS 6 LAND SURVEYORS :02II.400.11.11 Y.1.1 ..NW BRH e8 1 li 1 111 c44 ui Z. 5 0.0 eD • • * E � d O W � IN) O E. O lu. ci; NOTICE: IF THE DOCUMENT IN THIS FRAME IS LESS CLEAR THAN THIS NOTICE IT IS DUE TO THE QUALITY OF THE DOCUMENT. ■ L i I! TYPICAL NAMES E lid I , I '` : AtfI I Boring GT -1A DESCRIPIN% AL , 2 3 4 • CAR m1... r, re Sr w I R R V R R t R R 1 1. M hs 1w 4w.I1Iw 1e-.. - I. - : 0 L - -10 - as - -a . -N - 1 - as -ID I. R-1 .1 MA...IN..Uir ONfiS ld lz CT Mr malls. M Mein- I.. -1 rime I s S_ maw e-. Y NW: IVO (111. w.p M-. .M. 1b N 1 MT as (a) w, AN 14 tra. I... M -M 113 SL1S All PAYS 1 OL I,r Mrm r a0•• w 4l 1. Ana - - um w e-. sr wr..r. 11r my w Ind Y.Ad14 M 703 MI (l. - Yr1.1. WINN dl MAO. Iona S- SI. Ma M IN I-. Swam o_.I.. IN I4yuM /M.or, XT. 1101/10 1001116 NI Ow, amble* I-13 -44 AGI Technologies Container Properties. LLC. Former Rhone- Poulenc Frailty Tukwilb,' WA Prc.ct NNo: 20051 -29942 A -B I 11 TYPICAL NAMES I] I I Ii j � 1. 3f. Y } I Boring GT -2 I DESCRIP,pN oh .. 171 .� 1 III CAR m1... r, re Sr 11 SP Pa* /dd mask /•w mY le mar u" 11.4 nwi sir .n w la sus SW I IM eon --a re-. • I 113 SL1S All PAYS 1 OL I,r Mrm r a0•• w 4l 1. Ana - IS um w e-. sr wr..r. 11r my w S 152 WILY NON LOIS S DESCRIPTORS FOR SOIL STRATA AND STRUCTURE (ENCUSH/METRIC) NI ES eIS is - her 4 131 0 *of, plow Weely lid Mimed . Meow c DIN N Mope N. Some i.M I1ullrM -p.-- w7p.w.. MAINE DENSITY OR CONSISTENCY VS. SPE N -VALUE : S COIESNE SONS S 2J.7 M= � IS N (16m/S) A=...• L 90001 SIT. fin ki - �RRi8 , i I, °�R9R I 113 e I 7*. M Ile 3.• r (7.13' CO) G.m.Y Sod w Calm 9 CMYwI. S..pr Or OD) 3.•am. Oral LW m U.M.M T.A. Sw/Y o..rwr LA. V mo lalmmil ® a I Men aMY4 all crap mm D o.. IM 1.e- 3. rd Penman T.1 lw, O.M. D ( ' : 0 Jai IlIllIlIl 1111111 7 2/5 12 . I 31s 12 : -S e 2/2 . - II , 31 - - . II 11J IS n . -Is - 11 1/3 Is - -16 S 12 44.7 I - 13 30 II - 14 4 -J0 1s II . IM►e InMdd d IS MI - -A - (1e-)• IMAM MOM MAMA A M0 MAO. - -II . M 3 k (y.} w mM.M --46 --U I - -IS --M W.O.. S. /M N.• M w/ I-. . Swim 0..-.. our [,ywd/II-r.r WT. , na t Land eR 131 In Oman 9-11 -N Container Properties, LLC. Former Rhone-Poulenc Facility Tukwila, WA 1 I I Boring GT -2 Figure: A -3 AGI Technologies g Project No: 20051 -29942 1 MAJOR DIVISIONS TYPICAL NAMES .* ;. /� ! NAVELS 1... es. e... Ir.. NY to re Aar r *Ad pen I.nlr..4 .44.- 1.., le-.. Op • mid O.wY. O•�Md 1:31 IN Vsala molmei-n Mew oh .. 171 .� G C Y" Om green ,..M.• -/••A, Mem NM IYw ti Ill CAR m1... r, re Sr SW r *Ad ma may ..r SP Pa* /dd mask /•w mY le mar u" 11.4 nwi sir .n w la sus SW I IM eon --a re-. • ii 'If � � ! j� SL1S All PAYS it Z wire �Iw Vr r/r Aa 1' OL I,r Mrm r a0•• w 4l 1. Ana SUS All OMS UM M *dm t... um w e-. sr wr..r. 11r my w CH 1-pen Mp. l 144. 1YI4►. I4 MN. OH •e.M No d .rn b M. II.AM .pk WILY NON LOIS PT •. ►.. r AA an Mir aY • DESCRIPTORS FOR SOIL STRATA AND STRUCTURE (ENCUSH/METRIC) NI ES eIS is p-a p I/,S la 7..w 0 r Min Imon WI 1 � ), Memo >fI \(]• 1/245 wan, 4 I p... 0 I/2 M•) IMrs > I p IL IX I,2 -4 her IN. I.YdM Oft . ti b. n/. Ill 45 a .. a Y. 1 ...a.. .Y. 9 . 1 1.- I.-... Min �'� , '-a o *neat AMAIN' apo IMAM 0.4Y ••M aim delta e.A.M M-. Samna MAX IdwM *of, plow Weely lid Mimed . Meow c DIN N Mope N. Some i.M I1ullrM -p.-- w7p.w.. MAINE DENSITY OR CONSISTENCY VS. SPE N -VALUE COIESIOMFSS SONS COIESNE SONS Done N (61m/11) M= � GM.Nt.ry N (16m/S) A=...• L 90001 SIT. fin ki 2RaR 1 ilas °ASR �RRi8 , i I, °�R9R Wry an Sell Nd.w MT Sal 1hey 501 NM w . - e R R SAMPLE TYPE SYMBOLS GROUNDWATER =,A P.Mwen T.1 (IX ON I 7*. M Ile 3.• r (7.13' CO) G.m.Y Sod w Calm 9 CMYwI. S..pr Or OD) 3.•am. Oral LW m U.M.M T.A. Sw/Y o..rwr LA. V mo lalmmil ® a I Men aMY4 all crap mm D o.. IM 1.e- 3. rd Penman T.1 lw, O.M. D ( ' CONTACT BETWEEN UNITS - *NT YeraIA • _ _ =� *WM � Amp Jai IlIllIlIl 1111111 i an er /rYnM MOISTURE DESCRIPTION by - NA d many MY WM O-.M MW. WA -1YIN Im wr. .rand 0 2 6 S a 1! IC Ne Ne ✓ e N ees. ✓ c NC N UL NCX 11 4 I N 11 11 IS 14 IS IS 17 II IS 21 21 ICI 73 u 11.7 X7 31.4 31.7 17.3 10.7 211 2II 16.3 a, 141 413 413 i x. -j S 11 77 12 IS 11 1S I 4 s 4 I -, • i .- .- .- 76- Imam S• T/I CM Ulm Elmoln 1Md e7 M AGI Technologies I,y.d smsm 9L- MINA er C.y1MIA I-11 -10 Container Properties, LLC. Former Rhone-Poulenc Facility ' Tukwila. WA Boring 1 Figure: A -2 20051-29942 Project No: REFERENCES TITLE REVISIONS NO. BY. DATE Boring GT -1 rice mN N O M I N S S ..d4, Ba al .w awe NO INT (N S.A ' lbw le imam ..A l..dl.. Y Ind (4) Son 1..I II. M man d114 Y.. MAX Sad ler. 4d pw- I.. MIL M +MY SIN k. .l es r mad es r .wAn .n4 1-4 bows maw Any .. I.e i, mead Yon WI MY SILT %X Irw. on .- Si. M.IC -MY.O Imen .l 0A. oat see (II). hi. ..L IYr .0A i NI Mom rya MT at (II), Sawa wL mo-plealo b. I!. roe YwYr11.Wien Cep). ..I.r bond M r..wr.r Mw...a d IS MN pen Sod dial le Yoe d oppeo. 22 xi (bp). Maile any sin Is min nom - 10 - - -10 - -. - -a --M DESCRIPTION NO. 8Y. DATE REVISIONS DESCRIPTION DRAWING INFORMATION DRAWING SCALE: AS SHOVM DESIGNED BY: J. GROSS INIT. DATE DRAWN BY: CHECKED BY: APPROVED BY: L. McCAUCNE! FILE: P *.I .1 502...ACI Figures \29042- B- LOG1.4.9 vas 1001 4113, A,..i.., It.. 1490 3..tw.. WA 45101 -1010 T.•p (COS) 430 1700 SOIL CLASSIFICATION LEGEND 1. Soma Amonle 1. Y IN repot m Imo M *ad MI Mowry dr.wl.q .I4M. 1114.M 4MrM /a w.b. maw. /dl .i.. n4 Nada enema one M.W M Y Lnn WM or 11I..U, I..Mp .A. M...4d WM. Mai -wawa dw.YkAo made I -o4Mw .II. ASIN 0 2400 wn .n - w Innlikeileo ee.. 1.1...1.7 4.Y .. -.poly MI -_ = :,M .. M pn. sud.e .I. ANN 0 2457. 2. Neel monk w m4 Y Nan pad. 4 mad .. MA S Y IS pawl Or 3. 1101 -I.ip4 of AM NOT FOR CONSTRUCTION - DRAWING ISSUED FOR REVIEW AND COMMENT ONLY. RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE TUILWIA WASHINGTON BORING LOGS 61 CITE: JOB NO. 53- 01000496.00 REVISION (*AMC NO. 12 I I _..�.. II l_LI• I I1` I I I II I l l I III I l i' I I` I I III �I II III .I I l ih III III :III III III III III I I I 1I I I I 2 I L ,.... 3 ) I I 4 I I I i;I I 5I I I I 6 I Inch. 1118 i. IIIIIIIII I. I. IIIIIIII. IIIIIIIIII�IIIIIIIIII JIIIIIIIIIIIIIIIIIIIIIIII._ O I 6' IB: ._ II LnlllJll. IILLILLIL II_LIIIII. Lu.11lui IIILII LLL I.LLllllll.11lilllll iiiif1lll I L 11 I J _. I k Boring GT-3 DESCINP11011 111 E il I if 377, SU I II - - - --- - , Boring GT-4 DESCRIPTION I d hid X E: 1 , ---- Boring GT-5 1 DESCRIPTION le NCJII IC m NUE re IIC US IC 911 ICJ= NUL m. IC M. 1 2 3 4 131.7 I 7 1 9 le II 13 14 IS 111 I77 It SI n U 1U ISA 24.11 31 314 3U 34.1 U3 U.11 VA 27.2 203 MA US SU ILI 41.1 • i • 13 U 17 21 , St 3 SA • I Pr • r il pr • IN l. r v __, 1111 r III IS ur r II r • r • r IN r II I I III r 1111 vs • II r II Ill r I II ... I ^ r I ,--. -- • ANS Da maw awe A Yew nit IA, bel, erre . 1 ALIT SW ANL mem am A Abe, HUE IA. MT UM ILT *LI bid. v. RN lrerelleme A IVY VA (110 . . 2 NAV Alll 01* MAW allA A Mb eel, Nu A beam . . . • . DM LIA:11L17 1/4 1 r A maw ohne. vet NW wed, ., - • • MT UT ass. AA AIL wet he *Mk A rob* RAN* . Abbe lit II ma mt. ! , , , • - - - . _ - - MI ICA* IRAS IC IR " us 2.. IR A. IA 2 II S 7 I 19 „ 12 13 14 II 17 is I. II 1.1 IBA ILI U.4 113 34.2 1111 I US 1U 11.2 t7.$ su 13.7 IlL7 SU • • • V 4 4 ' I 3 5 S • 14 14 se 41 II 11 24 * U 19 Al V • 17 37 I 3 4 4 1 3 . 2• - II . 5 . u s 5 - " hie se* kb er AK ewe A ew • MOW 1171 a ves hew Al bel. um re. • - • . brew .d • • *Pm derl vie . . . beedkes le owl Eln • . . • . . • • Inerdlbe A 91: AO= diem AWS, .4 IN. A beim A SWAM AIR .. IMY LW 112 011). bib am A Am, let rerr-pirb NI Ise A Wee rebel ANL • Aerie A VA 91.7 AP-140. - - IS .- -- - " - - 1 2 3 e 1 4 7 II 9 le 11 13 le IS 17 1I U se 2, 21 U 140 15.0 ALS IL/ 19.2 VA 31.1 ILI US zu SU tu U3 ILI SU SU SU 2. SU SU • II 19 41 11 a 2 - _ _ - 45 5 n 33 . . • 5 . - . 5 :. .. ... . :: • 4/ • • • , our set oss, ow, w. winos ta. in. OW r d. mid Obry. • • 1111=11. ed. he OM* 111. . • • , • lisin . 1. S. deurldlece A VA ORA Ald Iderbary Mall AAA roped ere Arse et Ad elesnallesa dadd le b _/-_. ebeeh w oadIAL beln NIL be FAA* ellaelle. Ad net arbrad lade 1101 Alarebre IRAs Pm* -mbal A et were ow* bred sbalkollea walbeft pr bas WS AS111 D 24N INAIMullas Ilhwe Ida*, deb we -".m. we bud a en AAA. esellide. A Allt 231V 11 eel riselibehme we ARM emenhase 247. 2. AM sprieb en bed lit Allalle vend Ad and WAI WA 1 Is 12 AMA INA 3 11111 a Wed el bd. swim am Ila im I Ard 614 Orsaeodor errefted d 11J All (14 bedhre Ss U. III PAR OAR WNW* d 7111 Ad51.9. WAR be IA 111. " . • Ihrlw Aimbild d *S Ad • OMNI MAW RI Aloft ftwankt d 1U Ad 944 hp). Aura MAIM Ur WAIL 6•01441er d II hel 61111. AU aureiend MI Op 11-111 • aumbel Op} • MI Op AO Woe Ihrabit ISM' 40411641,1114ma M. MAIO . helm 11.41.1 14.1f 1_; WT. MAUS Seam DINAR 11/I Esbeereflbenow V. NUM NOT FOR CONSTRUCTION - DRAWING ISSUED *PI * 1111. NA bereihd 9-13-0 • *Pa * N Ale Daddid 11-11-U laNd 1 11 MT Ns berAldi 9-11-0 • S AGI Technol.. es • Container Properties, LLC,1 Former Rhono-Peulenc Facility Lando, WA 1 AGI Teehnol• •Ies • Container Pr;. LLC. Fomw Pitons-Poulenc facility Tukwila, WA • . AGI Technolo. es Cordainer rropottles, LLC. Fewer ithons-Poulonc Facility Tukwila; WA FOR REVIEW AND COMMENT ONLY. I Boring GT-5 Figure: A-6 No: 20051-29942 Boring GT-3 Nuns A-4 No: .20051-26942 GT-4 Figure: A-5 P • •• No: 20051-21942 REFERENCES ; REVISIONS . REVISIONS • DRAWING INFORMATION 1001 4tra Abase. Its. HOS Seattle. IA 96111-111111 TH•Pliwn (aos) 4911 RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACIUTY DATE: - JON NO. 53-01000496.00 TITLE NO. BY. DATE DESCRIPTION NO. BY. DATE DESCRIPTION • HYDRAULIC CONTROL INTERIM MEASURE I NKRA, RI/MINTON DRAWING SCALE: AS SHOWN 6 ASON RE - _ INIT. DATE BORING LOGS DESIGNED ETY: J. GROSS DIUNNIC 140. 13 DRAWN BY: CHECKED �Y: -- I APPROVED BY: L. IAGAUGHEY . FILE: Project on SEAS on..AGI intunre \ 2994 2 -8- LOGI de 10' 1 !!t. 11 4.11"ill. 1 11. 1 , 11- 1 1 ME(1 1. 1 -11- q 1 1 1, 1)1, 1 1. 1 1 1 :111\ 1 1, 1 1 1 1 1- 1 1 1 1 1. 1 1 1 14 1 1 1 1 ' •,• 3 •• . 4i: , • 61 • Inch, 1116 I , • • - - . •T• • : • ; -"; :NDi II IIIIIIIII.IIIIIIIII.l.II.IIIIII.IIJIIIIIIIIIIIlIII 11:1111.111 • C REFERENCES TITLE lAt MC Me K K MAU MC IC Me re IC MAU VCM0 MC. M. Boring GT - 6 DESCRIPTION 11* Y � mo. w. M M N.w. 6.. e• Nem MK OM IUD ./SLT or ..M.. 4N. Y Mw, w4 M r 11 M.- M .14 Me web Mb bat MT UT/ SAID (319. Mem Seer. -. M M OAT MIDI lu 00. 1.o. M NAM M. M o.ylml. ML dw M .d. NMMem. Mow MY aT (IML NAM M f, re. M PM NM Mks* =7 NM1..l M Ilw6M A1. Y.. M .m4 #I 114 205 V3 XS 173 273 21.2 Al 233 es 271 m.t 32.3 a A.1 n IS m M II m M 37 S 17 II 24 I 2 7 10 11 Is 12 It IS IS 17 1S a m Al D Mai be >R IY3 selee Douse. 143 I. MF N0 AGI Techno ogles 10 IS I OINC . w�SM w(SP). Noo AM. I. MINA S dl. LIDO MI Mel el XS /M DM. S..Yd MMISwI .1 leMe• Imbed. .Memrd .1 LO I.M (4p} OD ap 5-21 IDy.eeull.mm. !1. MAD eew Om01il S-II -M - IC - S - -a - -a --M Container P LLC. Former Rhone-Poulenc FocN$y Tukwila,'WA Boring GT -6 Figure: A -7 Project No: 20051 -29942 NO. BY. DATE REVISIONS DESCRIPTION NO. BY. DATE REVISIONS DESCRIPTION Boring GT -7 DESCRIPTION 4_ Mb Soho. MON MID � ` (Pl% Me • we WM. MA erns NM bee leme f.olry.6{ e.M.d 110 dr.. w .., r M gab Semi -SyMM, w M • mar pod, Mw O. MIT seer AT (ILL w..e.1M. mil& ML 01.4•M sMrel m.4 M. XV Sett MM DIX lem r. r. Nr s.•700 i MM.. bM bleb Mat MT MY Ie0(!1), wee. ml. be A So. .'.1.. MU MT LIM Imo. N.DU Us Y Yee. .d M M. mum emb. 11m. emrlM .i MAT OAT sea (*O. M M. Imo .m ML DAN 0147 AtNIL Mum w M wive. -S be 0 man -4 SA M1LT 04 Ms M. Ms- +. m.. M .mA MS S�OAAY • 014 very 554 m4N 7M OM ML Mm M M ...m ed..Mi bpi. Min Y *17 2110 MOM Y ems 'MIL am reed MI S.Swe1. Mc MC IIt SID NC ISO YC k ND I it n 11 IS 14 13 IS 17 IS II X 21 1T 23 24 13 IS., 73 SLt II. 373 23 2L7 211 313 113 233 X7 A3 4L1 Al LI I iF S 3 SS / S 2 4 10 IS • IS IS a 22 25 21 11 IS 13 26 15 M 4 X17 MOM M es Ld D/). • Mk* MEW sib MOM M..mleMr mme bbl ./ 21 MM (5 It..Ow M as flee l.Ie. O,M.N lAW I-Ml en AGI Technologies DU Dr 5-M IsImMIw.ee WI. MOO SM. MOM 0.1548 Container Properlis, LLC. Former Rhone- Poulenc FacRHT Tukw9o, WA Pro Project No: 20051 -29942 Figure: A -B • DRAWING INFORMATION DRAWING SCALE: AS MOWN DESIGNED BY: J. GROSS INIT. DATE DRAWN BY: CHECKED BY APPROVED BY: L 11c6MIGWILY FILE: Proj.ct oS 50.2...55 F.gs.. \29942- B- LOW.4p - --a - -45 URS HMI 411 Awmw. L4. 140 51.IW. WA MIST -ISIS TeMbeee. (055) 435 -570 SOIL CLASSIFICATION LEGEND MAJOR DIVLSIONS ih VI if DMUS 11.. M sem MN • IRr Hen IM. 4 m. be MOS bee r r ems Mmes Is 4 Y. 1.r a as, sw .m Me sr s5.. S5S MO CUTS IISdIM be O., SS SILTS NO CATS u_ ml O.S. Sim 40 laity 50MR Sala C0101055ESS SOBS beeN .10 IX 11. IS 5 N ( 01.4 4 Y 10 10 Y b 30 Y 00 Om S0 I CONTACT BETWEDI UNRS - Moe Y S..al. eM =Zoe Mk �� Mm.. r *dMerl Amp MO LINE DESCRIPTION 00 - fr. et m.M.. Mb 50 Dem IN1 24 NM INe tM - MWO1. Mm 00..MI.d TYPICAL NAMES CW M rind PmnM /N-b/ babe co , ►+M men sob. IN016-01•11 ..... GM Gc sly au 50.. .A-5'M nib. 557 'wok 1rad"s 1-1, Idiom Id /..M SJ. O.•.•/ w.Y SP MO "mid nob. S.* seY SY TTT4 155 s+ N+ -AMM. ▪ VIII Zii .1.071, 7 _ . 505.211 _ EL � M ,ri . r OTJW. v-11 OL 88 OM M.. M .p*.1V or • he MOM 1111 IrV„. CH //, weft Ml. M MI/. IwmdV, M OH 0w0 M Al .r. • I10 IM MO. .1.+11 .Ti PT � . /WI r "to WOO NMI M. DESCRIPTORS FOR SOIL STRATA AND STRUCTURE (ENG1JSH/YETRIC) r.re O'L'ICim loo IMM ..r r...M r ...Y MT Waft* Mash Ira .A••.AA Mw.il dy.. FeMd w.1. emsy M.I Mlle MOM deem SIMMS 00r14 Mane O M..I Slag OM w woe err w MI mgM. rye Sled SWIM Yer. M M Me1M e 15. _ Mr. .el. .d g0•u.e MOM ROME DENSITY OR CONSISTENCY K. SPT M -VALI[ "Mat: Ii" 0 - IS IS - 35 35 - LS DS - fS 55 - 100 COMORE SOILS Malay I Ilr IMAIt 0 YMM tee me NY M ISA ..Oe • Y M *O New Me* M Y M .q N (IYw/s) 0 1. 2 21.4 41.11 5 1. 15 1S 1. -4 30 tmitigo the 135 - 910 500 - I000 1000 - 2355 TOM - 4000 34000 SAYNE 1TPE SYMBOLS 8 0 0 sll PoM2.. to Or OD) Tyy. U ISM sauna (113. OD) W .04. MM. (10 OD) 000.5.4 T.M. Mole OM Mies O.. S m-m.M.4 PmdeM. AM (MM MI gm .mils) GROUNDWATER WELL COMNETIONS PHYSICAL PROPER* TEST MM. Wit . re nerr.1.M CND ANN libIlithe pr 0 I .. II e b m . � .C1.-L .I. ..., * , / �.�:. , MI AM ▪ Immday Des DP Mid m Pm.r.M� . K � Ma0 w MON 55 MI W U M.Y4� CD Ms. DIM Nis 1. Imo. Sme40M. M SAe .Mm/ as Mei w 00 W mM Ideram beemlibb M0A * MY MAO m pusuOM rw.1 -M.r M. .e ..m.0ee...D. KIM 0 2455 -. -d m s I4.10e•em bib. M. 1A.W.b7 r M -D.rrm .. r p.mM m.00 .24 Kn 0 2417. 2. 5d .yNrY m. m.A 1. 5555.111. •wM ..4 meet rle Mr 6 Y 12 mob 1wa A 50 . ONO M LM. I NOT FOR CONSTRUCTION - DRAWING ISSUED FOR REVIEW AND COMMENT ONLY. RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE T1/I011111 WASHINGTON BORING LOGS / r r .i .. r ` I I I I.I I i rrl i I 1116.. t.4. VII f.• �IIIiIL III;Iiil��I III. 11111iil . 3 4 5 6 i111.11111111 iltIli. Ill iwiliII. Ilu .Ali.Sidi.IiIIlIu.IJiiilnii iilini lii�II. III�i��ilii�ilnn. I��iil��nliil�I���illiiill�lJj .I��III��II�nIIIi�IInII IrdW1.. MTE: - .LOB era. 53- 01000496.00 RIWMION OIMMII55 1a. 14 r 1M i �� Ir i f \ceo VUE- 13.4.9 T OM: 05/30/02 AT: 05:38 URS ♦ • • 1 ♦I -. a '. \ 1 I y 1\ ' \L O 1 k \\*A" 11 • 1 ' • ♦ 1 _ . ** t..\ . • o so Seale in Feet 1 • • cit ` • U APPROXIMATE HIGH TIDE SHORELINE APPROXIMATE LOW TIDE SHORELINE r L —J \ B � V L / \ � • 0 B5- DM-6 C l. \— APPROXIMATE LOCATION OF METRO LIFT STATION I 1 ,�.,. . {,� / a =FV a fib,'• e rrs: •� i :. I I 8 % I 9 , I 5: I 9 ,4 I E Iz `L. wOl ! I�l II( LIIIIl111L11U 11 IIILIIIIL�IIII�IIII�llllllll .l.Ill I l l l . l l l ( I I I I I I I I I � I I I I L L I I � I I I I IIItiII I ILII IILI�LIII IIII�1111. I �II� IIII IIIII {1111 LEGEND L INTERMEDIATEJLOWER MONITORING POINT U SHALLOW MONITORING POINT EXISTING WELL THAT MAY BE ADOPTED FOR MONITORING 0 PROPOSED MONITORING WELL LOCATION 4 MONITORING WELL • BUILDINGS CURRENTLY EXISTING ON -SITE PROPOSED BARRIER ALL APPROXIMATE � Figure 3 Proposed Monitoring Well Locations Near Barrier Wall Container Properties LLC/Former Rhone - Poulenc Facility Tukwila, Washington m Drawing FILENAME: Q: \Geo \RCIE \RCIE- 13.dwg EDIT DATE: 06/11/02 AT: 09:27 MIS • t Scale In Feet . ...._..._ U r U.-- U 0 DM -3A. A2OI A4* : J, ____ o U U B1 6 QL L A9 � •\ ` 'S \ • I DM -8. 1 Ut I ti MW -36 L,J 4 MW -22 \ 1 1 t. L0L 1 1 1 .0 0 1 1 �•O 1 1 • \ • ` • • • MW -14 W -24 4 L MW -251 U .MW -26 MW -16 MW -17 MW -27 MW -28 U *MW -34 • di '0iili(i111111k m DM-4 L B4 M W - 37 -$•MW -12 H10 U APPROXIMATE LOW TIDE SHORELINE B2' • C) . DM -5 B6 APPROXIMATE HIGH TIDE SHORELINE B5 L 4MW -31 U LO L0901 0 t APPROXIMATE LOCATION OF METRO LIFT STATION � 11 . APPROXIMATE PROPERTY BOUNDARY I'I I I !'I ' I I I II .I ( I til I L I .61 o. �: ,. Y E.jw „' Z • ' r; 'NO III!!!iiI iIIIIIIII�III. I�I! II� IIIII II IIII I IIII I IIII III (I�JIIIIIIII�IIIIIIIIIIIIII DM -6* t — UPPER ZONE MONITORING POINT INTERMEDIATE/LOWER ZONE MONITORING POINT EXISTING WELL THAT MAY BE ADOPTED FOR MONITORING PROPOSED MONITORING WELL LOCATION MONITORING WELL BUILDINGS CURRENTLY EXISTING ON -SITE ••mil•■ PROPOSED APPROXIMATE BARRIER WALL PATH L 69 0 I I LEGEND IMMEDIATELY AFTER TINSTALLED I WALL IS COMPLETED Figure 3 -1 Proposed Barrier Wall Monitoring Well Network Container Properties LLC /Former Rhone - Poulenc Facility Tukwila, Washington 1 L ■ URS • AF MW -2:2 \ \ \\ 1 01∎21 -2A 1 0 50 100 FILENAME: Q: \Ceo \RCIE \RCIE- 15.dwg N EDIT DATE: 06/11/02 AT: 09 :17 Scale In Feet d 1V V ..1 7$ MW -2 MW -28 +M W -34 H11 MW -25 +4MW -26 \:I vv-16- t P;I;V - 15 ' IWV -37 - -MW -12 H10 H•I DM-4 4 3 APPROXIMATE LOW TIDE SHORELINE .62 B1A, f0 11 . Ii APPROXIMATE HIGH TIDE SHORELINE MW-3 APPROXIMATE PROPERTY BOUNDARY • • B54 APPROXIMATE LOCATION OF METRO LIFT STATION Dibl -o C� 000 I I LEGEND U UPPER ZONE MONITORING POINT L INTERMEDIATE /LOWER ZONE MONITORING POINT ti 0 L, I I tt I1nn[I. IIIL IIIIi1 UI1111111111 .IIIIIIIIIIIIIIIII.I 1.11IIIII.IIUIIIIII��il�lll� IIIIIIIIIIII. IIIJIIIIIIIIIIIIIIIIIIIILI I IIfI!_.�rl_ 11llllll1 • EXISTING WELL THAT MAY BE ADOPTED FOR MONITORING PROPOSED MONITORING WELL LOCATION MONITORING WELL OUTLINE OF BUILDINGS CURRENTLY EXISTING ON -SITE PROPOSED APPROXIMATE BARRIER WALL PATH I® WELLS ON THE EXTERIOR OF THE PROPOSED BARRIER WALL WHICH WILL BE SAMPLED QUARTERLY FOR BTEX, AS Cd, Cr, Cu, Pb, Hg, Ni, Se, TI, V, Zn. - DRAFT- Figure 3 -2 Proposed Preconstruction Water Quality Monitoring Locations Container Properties LLC /Former Rhone - Poulenc Facility Tukwila, Washington DM -1A WELLS THAT WILL BE SAMPLED ANNUALLY FOR BTEX, As, Cr, Cu, Pb, Hg, NI, V, Zn. WELLS THAT WILL NOT BE MONITORED WELLS WHICH WILL BE SAMPLED ONCE (ONCE DURING THE FIRST QUARTERLY SAMPLING EVENT) FOR MAJOR CATIONS AND ANIONS. URS C , \ % . , *"..... .... ''''. , \ .. , ..... .0. ■ .., , - , ••• _ ••• 1 1 I 1 1 I 1 I 1 I 1 5„. 1 1 1 1 1 1 \ 1 I 'I 1 I , , / I \ DM 8 1 o 0 50 100 FILENAME: 0: \Cep RCIE \RC a IE-16.dwg imi===1■01 EDIT DATE:. 06/11/02 AT: 09:19 V—r Scale In Feet 1 , 1 1 MW-36 I • \ \ \ \ \ • • \ ••• ••••■ •••• • — 1 14 ''MW 24 \11 •s L MW-2 0 +-flipAvy-26 U • .41. NiNiv.16./4)WITT- 20 ' U APPROXIMATE LOW TIDE SHORELINE T, Inch 4.; APPROXIMATE HIGH TIDE SHORELINE —APPROXIMATE PROPERTY BOUNDARY 1 , r7:7 I E i B5 ■P- LO G-01 I I APPROXIMATE LOCATION OF METRO LIFT STATION LEGEND L a I 0 AB c 6)- j D BU UPPER ZONE MONITORING POINT INTERMEDIATE/LOWER ZONE MONITORING POINT EXISTING WELL THAT MAY BE ADOPTED FOR MONITORING WELL SELECTION DEPENDENT ON EXACT WALL PATH PROPOSED MONITORING WELL LOCATION MONITORING WELL BUILDINGS CURRENTLY EXISTING ON-SITE PROPOSED APPROXIMATE BARRIER WALL PATH 111,1 rift, To711)'1 wow' liii nil • \ 11111 WELLS PROPOSED FOR QUARTERLY CHEMICAL ANALYSES FOR BTEX AND DISSOLVED METALS As, Cd, Cr, Cu, Pb, Hg, Ni, Se, TI, V, Zn. 1111 INTERIOR MONITORING WELLS PROPOSED FOR ANNUAL CHEMICAL ANALYSES FOR BTEX, AND DISSOLVED METALS As, Cr, Cu, Pb, Hg, Ni, V, Zn. ta) WELLS THAT WILL NOT BE MONITORED 2 WELLS WHICH WILL BE SAMPLED TWICE (ONCE DURING THE FIRST AND THIRD QUARTERLY SAMPLING EVENTS) FOR MAJOR CATIONS AND ANIONS. -DRAFT- Figure 4-2 Performance Monitoring Quarterly and Annual Chemical Analyses Container Properties LLC/Former Rhone-Poulenc Facility Tukwila, Washington ItO EI sel _.._..__.__.._._._ --_... _.... ____._._L..___......_._._. ___._._T___. . GT•4 (11' ......_._...._.._._ ___._.._..__...-„ 4, 7 n - - w _._.n 17 • =- -.___, D1 E (1' __..-_ __..._.- __- .- ___-._.- ..._.._... V II It I _..._..._._..._...._._. ._.._._.___.21- Iiil UPPER AQUIFER a Z ONE a _ .____._.__......._.___ 343 OII 27•-21 RI .._.._. I II ._. +- i10•�6L 1 30 I e • III ._-.INTERMEDIATE _LOWER_.__.._. ZONE/ I„ I- - - - -_. ..-� III, .... ..... .._ .. +n ITpPER A1i(1(TARD1 ___-..---..__ -___ _ DM-2A E) ( ____�. IIII_._....._ , till 5__.._.._.___.__ -7 �I�f -] ° I ._..__...__....r.__ 27 III U __._._.__.......____. -` 3 �w -z 1 IIII �'.- 6 IIII ....___.._.__--•_ 17 ___ .____.___IIII__.__._- 'N) (2' I .__..__.tat- i 1 ]w �._ ' 162 aI0 __...._A_._ 2{0 ¢! - -� i •- -..._. IF1 GT-3 E) (21' __.._._..._.._.? 4 /_.._.....,._.. s -ts ' '< ,. -]2 i. ...__.__.___.. ,s -11 3 , - n z< n »__._._„___.. -/4 ,� 1T 1 n st ;e -0e a _._....._._ „.. s __._�...__._ , ___._.___. 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OF RRIER L1 ( T20- 560 _........._....... _ w- I 50 Uo .___ ._____.. .._. - _.. _... 7 _ ` ___..___ `" --' _.._._...-...__..._...... x -ne WALL. ______.__ NI E) (5 a ...__..._._.._........_.. . ....._._ -2o iw-26 n °........._._..._.. _ ....:_...._.. __ m -nd 150 -1 Z fo _. ... ... _.._._..__._._. __.._._.._...._.._.- ..._.....__ •" _.._..._.._.....__ ..._....... . _ _ . _..._.._ _ ..................__.._.._.__....._._._..__..._.......__..__.._...__.__...._.._.__.___...............__......._.........._._.__...._._....._... __.__.- ____..__.__.__._..___... E) „ a 10 ae �e ..._ ' n -13 �, to -na u - ! _..__....... rte- ' _ . _ _ 'u .. _.__ ..._......__.. - GT -2 ( ito I tl .. _ ,-....- .....�_ _ IP1 E) 50 ]._...._.... .......... -3e +�0 -t2 ..... .......... 20 -nd - nn -11 .. .. 5e.me- S_� _ _._.._._.........._._.. 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A w ■ ■ ■ ■ ■ ■ ■ ■ ■ r �E NORTH END OF BERM 10 0 Z z -10 0 -20 G _30 a -50 EL - 60 20 10 w 0 z z -10 O -20 J W -60 -70 20 - 70 20 +00 �.l W_..._...._..__. e- ;UPPER AQUIFEM = 7r// y na -nd 11 1-.._._.__......._...10 -nd ,0 7;1 nd - nd Z TITLE FILENAME: 0: \Geo \RCIE\design \REVI \5- profiles -2.d.g EDIT DATE: 07/11/02 AT: 14:26 an /a REFERENCES SOUTH BARRIER WALL (STA 16 +25.29) VI Ix1 ((�z1 ( ?......_.... ......_._...GT 1 (4' E) (a' E) _30 = s.._...__._._ �e -ne Q z nd - I - 40_.._._._..._..__. _._ O 0 T 1 BOTTOM OF I UPPER AQUITARD a -��. I i ne _... _. ___.....__. L _nd na' p - ne net nd -nd n4 - _.__ l._--__._.. �.---- -...._....___._....T._.._ .BARRIER_..WALL- 1 - �I 21 +00 SUBSURFACE PROFILE WEST WALL (LOOKING WEST) A 3 REVISIONS NO. BY. DATE SUBSURFACE PROFILE WEST WALL (LOOKING WEST) A 3 DESCRIPTION 1 EXISTING GROUND SURFACE 22 +00 NO. BY. DATE 1•- 20' 10® HORIZONTAL - VERTICAL 1'e 20' 1D X 20 HORIZONTAL .i VERTICAL 6 -1.02 5' 13 I NORTH BARRIER WALL C (STA 0 +00) 4r __.._...._._... _...- .....___....___.I ...._..._ " ... ._.....- — .....__ . _. ..... _. _. __.. _.._. UPPER AQUIFER . ... ......... _ 2 .. _ 0 . 1 101 z ._._.._.._..._..._._......._.._ ......... ......._..._.........._........ .......... .._.._ ..... ......_ ....__..._....I,....... _.._...._....... -10 _ 1 P hd nd I --ne ed_ -.� 1 ....- ������ _._ ._... I._..._ 30 W o INTERMEDIATE /LOWER i .---- .at1�. �.... I ....._ .............. -�- a { n ZONE_...:.. - ......__.._....._.._.__. !.... 4o m I , - ,m . z. I 0 ce I 50 I _..__............_... _........_.__... ........... ....._...._.I..__....._._._.___ -60 I en /d7 I ....._..._._._..._..___.... -70 1 23 +00 REVISIONS DESCRIPTION 20 10 70% DESIGN COPPER t •• LEAD CONCENTRATION ,e, ne /CONCENTRATION (µg /I)_ - n5 ]e (/ / DETECTION LIMIT 2 ' DETECTION LIMIT VARIES FROM ,] 6 VARIES FROM 2 TO 10 Etg /I ., , 1 TO 10 µg/I "nd" - NOT DETECTED GEOPROBELEGEND (FOR DRAWINGS 5, 6 AND 7) STANDARD PENETRATION • TEST BLOWS /FOOT OR i IIII 9 s u '' m � I It II a III III BLOWS /INCHES DRIVEN -- DAMES do MOORE SAMPLER, BLOWS /FOOT OR BLOWS /INCHES DRIVEN (DRIVEN WITH 140 -POUND HAMMER) DRAWING INFORMATION DRAWING SCALE: AS SHOMN DESIGNED BY: J. GROSS INIT. DATE DRAWN BY: B. NALMANN CHECKED BY: D. HANK APPROVED BY: L McGAUGHEY GRAPHICAL LOG (SEE SOIL CLASSIFICATION LEGEND) 'n n' GATE COMPLETED NOTE: WOR = WEIGHT OF RODS BORING LEGEND (FORDRAWI 5,6AND7) 20 +00 FILE: Project on 5EA2...AGI r. ., \29942 PROe1LES.d06 20 10 0 -to - 20 - 30 - 40 -50 60 - 70 2. HE WALL PROFILE SHOWN ON THESE PROFILES WALL WILLL I BE DETERMIN D IN HE FIELD BY E THE ENGINEER, AND SHALL 8E BASED ON EXCAVATED MATERIAL CONSISTENT WITH THAT ENCOUNTERED WITHIN THE UPPER AQUITARD I UNIT IN THE GEOTECHNICAL BORINGS. i GEOPROBE DESIGNATION H1� DISTANCE /DIRECTION (3, E)�PROBE6PROJECTED EXISTING GROUND SURFACE (APPROXIMATE) 277 3e 204 31 e n 3 3 BORING DESIGNATION GT 4 DISTANCE /DIRECTION BORING 7, w PROJECTED TO PROFILE WATER LEVEL (AT TIME OF DRILLING) INTERPRETED GEOLOGIC CONTACT vtes 1501 4th Aseaue. Ste. 1600 Seattle, wA 00101 -1110 Telegaone (5*4) 430 2700 I ES FOR DRAWINGS 5, 6, AND 7: 1. SUBSURFACE CONDITIONS ARE KNOWN ONLY AT THE BORING LOCATIONS; VARIATIONS BETWEEN THE GEOLOGIC INTERPRETATION SHOWN ON THESE PROFILES AND ACTUAL SUBSURFACE CONDITIONS MAY EXIST. 3. THE TRENCH SHALL BE EXCAVATED FULL -DEPH (TO A POINT 2 FEET BELOW HE TOP OF THE UPPER AQUITARD B ETWEEN THE STATIO S N NOTED ON THE PROFILES AND ALONG HE ALIGNMENT SHOWN ON DRAWING 3. 4. THE SOUTH AND WES RI T BAR ER WALLS SHALL BE CONSTRUCTED USING VIBRATING BEAM MEHODS. THE NORH AND EAST BARRIER WALLS SHALL BE CONTRUCTED WITH SLURRY TRENCHING MEHODS. 5. FOR DETAILED BORING LOGS SEE HE IMCWP. 6. DATA FROM APPROVED HCIM WORK PLAN AND JUNE 2002 URS GEOTECHNICAL INVESTIGATION. RECEIVED • ►AUG 2 9 2002 COMMUNITY DEVELOPMENT RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE TUKWILA WASHINGTON SUBSURFACE PROFILES (SHEET 1 OF 3) DAZE: JOB N0. 53- 01000496.00 REVISION DRAMING NO. 5 I I I L ri r I -i�l� LI=i'� � I I rj i L) I rI l I rlli i j�1 III ,Ill �_rr�l j 1 rl I I ri 1 I L_I III, I I I III III I Inch I.1/16I 1I I , L. .2L. I ` I I L 3I I .. I. 4I I I I 5I I I 61 91: •l Et.. i � - Fo(_ a s 8 s " ; 5' v E �; a w� IIII•III tilllliliii_llillilll .IlllI.II.11.d.M.II IIIII - IIII IIIIIIII.IIIIIIIIIIIIIIII!!!II IIIIIjIIIIIiII�J IIIII IIIIIIIIIIIIIIIIIIIIIIIIiI� j IIIIIIIIIIIIIIIIIIII_._- 1 SOIL CLASSIFICATION LEGEND (FOR DRAWINGS 5, 6 AND7) TYPICAL NAMES GW : j[' Ma wadd growls. wont -wad mtetwes GP , • rash winded 9rods. w...Fsend Knew GM ' ! Slay greees, wawl- toad -ash mldwed GC •', V clam dare'. 9rewl- sod -dos ,a,eh•a SW %'r: wed waded lads. am.* ads SP '• ..' Park Pad ode, was* ands SM 3 : sal ad. dad -ew oMwa SC . closer dada. sad -car n,edwes ML ( I I J � a , r ° a or r47 slM ` ilgM ”, dMa. m rr CL eMl' ad "enrl e la al r dm r"e°t a . .., OL � • elan ad eI Me � 7Mr tden rah' MH � 'wl asik , a n ju o s or dkMwcesw 1M sadr et CH' � Maack clan of hg h Poekllr, 221 den OH ' i cradle elan el medtwa lo hqA 0:41111. ar9ade Mh PT L I u u Peal ad of w Nglds agorae and A w ■ ■ ■ ■ ■ ■ ■ ■ ■ r �E NORTH END OF BERM 10 0 Z z -10 0 -20 G _30 a -50 EL - 60 20 10 w 0 z z -10 O -20 J W -60 -70 20 - 70 20 +00 �.l W_..._...._..__. e- ;UPPER AQUIFEM = 7r// y na -nd 11 1-.._._.__......._...10 -nd ,0 7;1 nd - nd Z TITLE FILENAME: 0: \Geo \RCIE\design \REVI \5- profiles -2.d.g EDIT DATE: 07/11/02 AT: 14:26 an /a REFERENCES SOUTH BARRIER WALL (STA 16 +25.29) VI Ix1 ((�z1 ( ?......_.... ......_._...GT 1 (4' E) (a' E) _30 = s.._...__._._ �e -ne Q z nd - I - 40_.._._._..._..__. _._ O 0 T 1 BOTTOM OF I UPPER AQUITARD a -��. I i ne _... _. ___.....__. L _nd na' p - ne net nd -nd n4 - _.__ l._--__._.. �.---- -...._....___._....T._.._ .BARRIER_..WALL- 1 - �I 21 +00 SUBSURFACE PROFILE WEST WALL (LOOKING WEST) A 3 REVISIONS NO. BY. DATE SUBSURFACE PROFILE WEST WALL (LOOKING WEST) A 3 DESCRIPTION 1 EXISTING GROUND SURFACE 22 +00 NO. BY. DATE 1•- 20' 10® HORIZONTAL - VERTICAL 1'e 20' 1D X 20 HORIZONTAL .i VERTICAL 6 -1.02 5' 13 I NORTH BARRIER WALL C (STA 0 +00) 4r __.._...._._... _...- .....___....___.I ...._..._ " ... ._.....- — .....__ . _. ..... _. _. __.. _.._. UPPER AQUIFER . ... ......... _ 2 .. _ 0 . 1 101 z ._._.._.._..._..._._......._.._ ......... ......._..._.........._........ .......... .._.._ ..... ......_ ....__..._....I,....... _.._...._....... -10 _ 1 P hd nd I --ne ed_ -.� 1 ....- ������ _._ ._... I._..._ 30 W o INTERMEDIATE /LOWER i .---- .at1�. �.... I ....._ .............. -�- a { n ZONE_...:.. - ......__.._....._.._.__. !.... 4o m I , - ,m . z. I 0 ce I 50 I _..__............_... _........_.__... ........... ....._...._.I..__....._._._.___ -60 I en /d7 I ....._..._._._..._..___.... -70 1 23 +00 REVISIONS DESCRIPTION 20 10 70% DESIGN COPPER t •• LEAD CONCENTRATION ,e, ne /CONCENTRATION (µg /I)_ - n5 ]e (/ / DETECTION LIMIT 2 ' DETECTION LIMIT VARIES FROM ,] 6 VARIES FROM 2 TO 10 Etg /I ., , 1 TO 10 µg/I "nd" - NOT DETECTED GEOPROBELEGEND (FOR DRAWINGS 5, 6 AND 7) STANDARD PENETRATION • TEST BLOWS /FOOT OR i IIII 9 s u '' m � I It II a III III BLOWS /INCHES DRIVEN -- DAMES do MOORE SAMPLER, BLOWS /FOOT OR BLOWS /INCHES DRIVEN (DRIVEN WITH 140 -POUND HAMMER) DRAWING INFORMATION DRAWING SCALE: AS SHOMN DESIGNED BY: J. GROSS INIT. DATE DRAWN BY: B. NALMANN CHECKED BY: D. HANK APPROVED BY: L McGAUGHEY GRAPHICAL LOG (SEE SOIL CLASSIFICATION LEGEND) 'n n' GATE COMPLETED NOTE: WOR = WEIGHT OF RODS BORING LEGEND (FORDRAWI 5,6AND7) 20 +00 FILE: Project on 5EA2...AGI r. ., \29942 PROe1LES.d06 20 10 0 -to - 20 - 30 - 40 -50 60 - 70 2. HE WALL PROFILE SHOWN ON THESE PROFILES WALL WILLL I BE DETERMIN D IN HE FIELD BY E THE ENGINEER, AND SHALL 8E BASED ON EXCAVATED MATERIAL CONSISTENT WITH THAT ENCOUNTERED WITHIN THE UPPER AQUITARD I UNIT IN THE GEOTECHNICAL BORINGS. i GEOPROBE DESIGNATION H1� DISTANCE /DIRECTION (3, E)�PROBE6PROJECTED EXISTING GROUND SURFACE (APPROXIMATE) 277 3e 204 31 e n 3 3 BORING DESIGNATION GT 4 DISTANCE /DIRECTION BORING 7, w PROJECTED TO PROFILE WATER LEVEL (AT TIME OF DRILLING) INTERPRETED GEOLOGIC CONTACT vtes 1501 4th Aseaue. Ste. 1600 Seattle, wA 00101 -1110 Telegaone (5*4) 430 2700 I ES FOR DRAWINGS 5, 6, AND 7: 1. SUBSURFACE CONDITIONS ARE KNOWN ONLY AT THE BORING LOCATIONS; VARIATIONS BETWEEN THE GEOLOGIC INTERPRETATION SHOWN ON THESE PROFILES AND ACTUAL SUBSURFACE CONDITIONS MAY EXIST. 3. THE TRENCH SHALL BE EXCAVATED FULL -DEPH (TO A POINT 2 FEET BELOW HE TOP OF THE UPPER AQUITARD B ETWEEN THE STATIO S N NOTED ON THE PROFILES AND ALONG HE ALIGNMENT SHOWN ON DRAWING 3. 4. THE SOUTH AND WES RI T BAR ER WALLS SHALL BE CONSTRUCTED USING VIBRATING BEAM MEHODS. THE NORH AND EAST BARRIER WALLS SHALL BE CONTRUCTED WITH SLURRY TRENCHING MEHODS. 5. FOR DETAILED BORING LOGS SEE HE IMCWP. 6. DATA FROM APPROVED HCIM WORK PLAN AND JUNE 2002 URS GEOTECHNICAL INVESTIGATION. RECEIVED • ►AUG 2 9 2002 COMMUNITY DEVELOPMENT RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE TUKWILA WASHINGTON SUBSURFACE PROFILES (SHEET 1 OF 3) DAZE: JOB N0. 53- 01000496.00 REVISION DRAMING NO. 5 I I I L ri r I -i�l� LI=i'� � I I rj i L) I rI l I rlli i j�1 III ,Ill �_rr�l j 1 rl I I ri 1 I L_I III, I I I III III I Inch I.1/16I 1I I , L. .2L. I ` I I L 3I I .. I. 4I I I I 5I I I 61 91: •l Et.. i � - Fo(_ a s 8 s " ; 5' v E �; a w� IIII•III tilllliliii_llillilll .IlllI.II.11.d.M.II IIIII - IIII IIIIIIII.IIIIIIIIIIIIIIII!!!II IIIIIjIIIIIiII�J IIIII IIIIIIIIIIIIIIIIIIIIIIIIiI� j IIIIIIIIIIIIIIIIIIII_._- 1 20 10 w 0 W -30 W F -40 0 a -50 -60 -70 20 10 LL. z Z -10 0 a -20 W -30 W X -40 0 cr a - 50 0. 0. —60 —70 & NORTH BARRIER WALL (STA 5 +23.27) 1 F Vr 5-5-02 12 P. WEST BARRIER WALL (STA 0 +00) EXISTING GROUND SURFACE 4 /LOWER — _�_ �'._.._. • FILENAME 0: \Geo \RGE\deslgn \REV1 \ profiles —3.d.g EDIT DATE 06/28/02 AT: 16:05 UPPER AQUITARD REFERENCES TITLE • BOTTOM OF er /02 1 BARRIER .WALL NO. BY. . r I INTERMEDIATE/LOWER ZONE 31 DATE 2 TURNING POINT (STA 6 +20.96) B OTTOM OF BARRIER WALL REVISIONS 5.88.02 (20' Q •/1 — 7 +00 UPPER AQUIFER ZONE DESCRIPTION EXISTING GROUND SURFACE SUBSURFACE PROFILE EAST WALL (LOOKING EAST) O '' ` 20 ' • 1 3 0 ® HORIZONTAL . VERnCAL 2 +00° _._.__..___.__..._.._._.._.._._._....___..___...__.._...._... ..._..__._...._.___.______3 +00 SUBSURFACE PROFILE NORTH WALL (LOOKING NORTH) C 3 NO. BY. DATE UPPER AQUIFER ZONE UPPER AQUITARD 2. e 6 /17/02 REVISIONS J. - - - -t' ^— INTERMEDIATE /LOWER • -43-2 -02 B-4-02 (18' S) 149' S) DESCRIPTION 10 HORIZONTAL - VERTICAL 70% DESIGN TURNING POINT (STA 8 +50) BOTTOM OF BARRIER WALL 31 . 6 1 II . DRAWING INFORMATION DRAWN BY: B. HIU.MANN CHECKED BY: D. HAWK APPROVED BY: L. HeCAUGHEY INIT. 2 2 1 _.... 101 71 •00= f/13/02_ _ INTERMEDATE /LOWER - - - - -- j— _ - - -� - -I ONE Z 2 1 I BOTTOM OF �' _......._. _.. ._._...._.. _......_..._...... .....__ .......... ......_ - WALL..... ....__......__._.._._ UPPER AQUITARD I UPPER AQUITARD 1 I 4d!N2.__.... ..... ___.__._...._ .._____..__ ....:.........._._.. _... '400 - 5100 DRAWING SCALE: AS SHOWN DATE DESIGNED BY: J. GROSS FILE: Project on SEA2...A131 Flour. \29942- PROfILESd.9 8 - (3' E) EXISTING GROUND SURFACE SOUTH BARRIER WALL C (STA 10 +30.45) ups 1601 4th Amu.. 6t.. 1400 S.,ttS.. SA 90102 -1016 T.lgeon. (000) 400 2700 UPPER AQUIFER ZONE NOTES 1. SEE DRAWING 5 FOR GENERAL NOTES, GEOPROBE LEGEND. BORING LEGEND AND SOIL CLASSIFICATION LEGEND. C EAST BARRIER WALL (STA 5 +23.27) 5-5-02 •/10/02 RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE TUK'MRA. MU►91NGT0N SUBSURFACE PROFILES (SHEET 2 OF 3) • - 6 +00 OATS: JOB NO. 53 01000496.00 REHSWN DRAWING NO. 6 1 I' 1 11[I :1 1 I 1'1 170-1 ' I I Inch. 1118 vtJ>'tu 56 4 EIIL tb H • 0 ( ' I I I I I I I tI I I I I 6 i U1I.0 I Ili I I I I I I i. LU.L I I l I) LI I I I I I I I I I I I I I I 1T111 II I I1 I I� I I i t `1I:I 111I I I I I I I I I I I I I II , 51 61 } " ' Z { WO III! !!!�IIIII III UII JJ 11111liii11 lu�Illl1,11)1 iiii.10 00IUII B1 (20' ...........- ........ — 21-1 300 • 360 370 34 nd-nd __________________ ?-..........- S) 24 so ?--- 30 5 133 C4 . I OT•4 6 647, N - 1 ) - ' (16' S (a s) (22' S) OT•5 135 6' ) \ Be (2.5 ' to. ti) • • B 7 (4 N) (16 N • C9 • CB _ (a' N (2' N) OT4 r(e. s) C10 D11' •(14' N) (0' ' Dt N) . ••■• , ( I t; _ .... '... V ia 230 '---- 140 nd-nd _____ktNTERMETHAT.E/LOWER _.-::17: .30 210 %a 1.7..a. IS - SO . ... 10 • -110 30 ZONE ........... e■ IS ................................. 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' I opam _.............—........._,-...,....„.,............___.......-: .,... .......... .. • UPPER AQUITARD . . 0/WOO a . • 6.0 .. • . 11 t - .. BOTTOM OF • • UPPER AQUITARD f/tVo• BARRIER WALL a I 44I i 1 --... UPPER AQUITARD • D13 5' 5) E14 E15 E16 0 3' (STA 10+30.45) .c - 474 n'ind - ndidi 20/00 - 30/nd 50/16 5o/nii 50/44 cc") :-- a 4 ,• UPPER AQUIFER 2°-"d ,:31 ZONE ^ ird nd de 42 nd 5, ntr-nd II ,. 20-nd 14 00-nd • da 39-nd INTERMEDIATE/LOWER ZONE n 0 nd • . n 0 n n I L 00 nd •nd nd nd nd nd • nd-52 , nd-2110 nd-.,d nd-t4 nd-nd n0-00 ••-d 00- , nd re I- 1.. • I • I , "3/90 —..,....-;:::::::..;;;..;..........;.;.;;;.:::t ... ' UPPER AQUITARD I I gi 20 10 tI 0 z LL -10 O > •C -20 La -30 2 _ 0 cc a. -so a. -60 -70 ROME: 0:\Geo\RCIEVInigAREVIVrofies-Ldwg EDIT PM 06/26/02 AT: 16:05 REFERENCES TITLE . WEST BARRIER WALL (STA 16+2S29) 16+00 x z REVISIONS NO. BY. DATE DESCRIPTION r EXISTING GROUND SURFACE 15+00 14+00 SUBSURFACE PROFILE SOUTH WALL (LOOKING NORTH)C 10 0 20 HORIZONTAL VERTICAL 11+00 • • 1 r - 20' SUBSURFACE PROFILE SOUTH WALL (LOOKING NORTH) io 0 20 (CONTINUED) HORIZONTAL VERTICAL EAST BARRIER WALL NO. BY. DATE REVISIONS DESCRIPTION 10+00 70% DESIGN 20 10 0 • z - 10 - 20 > <C La - 30 - 40 M 0 - 50 n a- 60 13+00 DRAWING INFORMATION DRAWING SCALE AS SHOW DESIGNED BY: L CROSS DRAWN BY: B. 1110MANN CHECKED BY: D. HAWK APPROVED BY: L. McGAUGHCY INIT. DATE FILE: Point an SEA2...A0 215wes\211942-.PROFILES.dw9 URS 1501 41h AlIddaso. St.. 1400 54311.14. WA 00101-10111 Telspkwas OM) 430 :ffoo NOTES 12+00 In La z • 1. SEE DRAWING 5 FOR GENERAL NOTES, GEOPROBE LEGEND, BORING LEGEND AND SOIL CLASSIFICATION LEGEND. RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE MOM, WASHINGTON SUBSURFACE PROFILES (SHEET 3 OF 3) ORAVONG NO. 7 DATE; JOB NO. 53-01000496.00 RENSION 1 I 1 1 1 7 1 1 -1- 11 -17 01: 17. 1 ri U 1-11 1 11 [I ! I I101 1 II, 1 Hill I i. 1 HIFI I 1.I) IT I I 1 1 1 1 -1 1 1 1 1 1 1 1 • t4' 434R I 1 I . 2 31 41 ' 1 61 LN 1 1,t/li . • II 1111 111 141° .1111 1111111 1111111. III 1111 11111111.1111 .. 1 . 1111111 1111 1111 1111_1111 1111 1 11 ..1111 II MI 11 1111 1111 ;11'I. z ti /r / /// //r1!/ /1l// /re/1/ flf!lf 111/1 fff!lfll,l :i �. o. II OOOOO MW-2 MV EXISTING BUILDING DRYBENTONRE STORAGE AREA SOIL- BENTONITE MIXING STAGING AREA (BEE NOTES 7 ANDS) TION 0 EXIST BERM TRUCTION OF WALL AS REQUIRED FOR EXCESS STOCKPILE AREA ' . l (BEE NOTE II) 6 -INCH SANITARY S MW -375I MW- 6 - - --- 0 _I...f IF: j3_:... I... �..:._ I....... �,.. q. )�....;...,...1 ».,...I...':::+ MLY•1 1 ; fr . e. • PUMP STAr MW A TE R ID) (SEE NOTE 5) N 193,600 -F 10 -INCH STORM DRAIN (OUTFALL 7) LEGEND STA: 0 +00 N 193614.55 (SEE NOTE 5 X .. .. . + 6 -INCH WATER + 6 -INCH STORM DRAIN STA: 20 +16.94 N 193317.10 E 1636630.75 + 10 -INCH STORM SRAIN (ABAND NED1) 6 -INCH WATER 6 -INCH WATER + WATER REMOVE EXISTING TANK FOUNDATIONS AS REQUIRED + IMPERMIX BARRIER WALL, PER (SEE NOTE 1 p . + PROCESS DRAINAG`UNE AND CATCH BASIN (SEE NOTE 10) as 0i o ■ 40 FOOT RIVER ��■ 100 -FOOT LOW IMPACT 200 -FOOT HIGH IMPACT 0 OM30 + 5T: 16 +25.29 N 192940.81 E 1636731.82 K TELEPHONE CONDUIT 0 B-2-02 SOIL - BENTONITE BARRIER WALL ALIGNMENT, PER (SEE NOTE 1) 6 S uQ tkci REMOVE AND REPLACE. PORTION OF. EXIST. BERM AS REQUIRED FOR CONSTRUCTION OF WALL ELECTRICAL CONDUIT OVERHEAD POWER AND POWER PO ES REMOVE EXIST. BERM REMOVE EXIST. WALL W.L. . . 0 8.4.02 • /BENrONITE HYDRATION POND • (SEE NOTES 7 AND B) • ❑ /r/ /r/ //// • /rr// / / /// •/111/1/ //1 •rrr /rr//r/ !1111 ;rrr // STORM DRAIN STA: 5 +23.27 •N 193606.32 (SEE 'NOTE 6) : •• -- ..... . .._X • • EXISTING 13tILDING \ '61A 4 -INCH SANITARY SEWER PROCESS DRAINAGE LINE (SEE NOTE 10) r" 10 -INCH WATER STA: 6+20.96 (SEE NOTE 6) M1 ` �N 193515.81 E 1637128.38 IMPERMIX BARRIER WALL, PER 3 (SEE NOTE 1) E /,1// . . . S01 BENTONITE BARRIER /r't �/ / WA PER i luii (SEE NOTE 1) I `•• .� •lfr /r/. 2 -INCH r WATER 4 -INCH WATER ROCESS DRAINAGE LINE (SEE NOTE 10) + STORM; GRAIN -INC) WATER REMOVE EXIST. RAILROAD TRACKS AS REQUIRED - X^ X `K- --•it 'nt 0 8 -INCH RM DRAIN (ABANDONED) 8 -INCH STORM DRAIN (ABANDONED) + + + AMEC EARTH AND ENVIRONMENTAL, INC. 11335 N.E. 122nd Way, Suite 100 Kirkland, WA, U.S.A. 98034 -6918 EXISTING BUILDING -''" STA 10 +30.45 N 193178.60 ML'V ADDITIONAL UTIUTIES, THAT ARE NOT SHOWN. :•••t ..; - •:• : t ,.MAY. 114 ............... ADDITIONAL ILITIE''A -- STA; 8+50 (SEE NOTE 6) INCLUDE WATER, SANITARY ,.,..t- r ..-I- r " N ,93286.35 .��,, ' -- E /1637124.24 -17 SEWER, ELECTRIC COND • + / 1 AND PRO,C�SS�--0RATNACE LINES " -; PROCESS ORAI AGE LINE (SEE NEr .,)0),-"•" »'. Ye`' - ... 1 1 STO DRAIN OSAN b) 1.•,T • • I;j(I tl�ill I�: �I III III i��I I ��.IIfi"ilI ICI. L � ._ 3 1 ` 1.. I I ∎ .1: � . : I I, 5I .'. 1 III 1 L 6 I EXISTING BUILDING (.II1�1IIIIIII�lIll IIII1IIii 11.11.1J_IIIIII1�1IIIIIII�I.I I I( I1,JiJ I1II�IIIIIIIII�IIIII_.._ + + 38 -INCH STORM DRAIN + 0 FORMER RHONE - POULENC SITE LIMITS OF RIVER ENVIRONMENT TUKWILA, WASHINGTON 100 SCALE IN FEET 200 RECEIVED ING 2 9 2c102 COMMUNITY DEVELOPMENT FIGURE -10 -7 EXISTING TANK I T':w•' + - 1-- 1-- 4- - + - {.-.I L DECONT T t ---- • � N AREA PER D � ~ Y REMOV AND<EPLACE MVI 20S .4- � , PORTION O EXIST. BERM ` AS REQUIRED FOR EXCESS STOCKPILE AREA -� , : - CONSTRUCTION OF WALL (SEE NOTE I I) p 14a1 k - 13..i__«. MW,3711 1.1W• --••• . MW -19 Lr fit: ,,,,,, EXISTING BUILDING DRY BENTONITE STORAGE AREA SOIL- BENTONITE MIXING/ STAGING AREA (SEE NOTES 7 AND 8) MW-28 / IMPERMIX MIXING STAGING AREA °-- .-..../ (SEES OTES TARO 8) J CPT -1 o e,, rii ii i i ii 6 -INCH SANITARY SEWE .i., .; 80 ,, . • . , ,, • 6 -INCH) WATE ATE uMP / STATIO j STORM( DRAIN N I93.60D -�- 10 -INCH STORM DRAIN (OUTFALL 7) T r T N 193,000 STA: 0 +00 N 193614.55 (SEE NOTE 5 REMOVE EXISTING TANK FOUNDATIONS AS REQUIRED - r IMPERMIX BARRIER - WALL, PER (SEE NOTE 1) FILENAME: 0: \Ceo \RCIE \ design \ REV! \3- WALL.d.g EDIT DATE: 07/11/02 AT: 13:10 REFERENCES T 6 -INCH WATER 6 -INCH STORM DRAIN STA: 20 +16.94 N 193317.10 E 1636630.75 1 10 -INCH T RM RAI (A ANDONED) TITLE 6 -INCH WATER 6 -INCH WATER T WATER • ,17.T1 1 1 + PROCESS DRAINAGE AND CATCH BASIN (SEE NOTE 10) -T- STA: 16 +25.29 N 192940.81 E 1636731.82 NO. BY • 1)M•3083. ■■ �MVCGO MWA7 a�t TA DATE .,,.,,,,,ii ,,,,,,,,,,,, . REVISIONS DESCRIPTION TELEPHONE CONDUIT SOIL - BENTONITE BARRIER WALL ALIGNMENT, PER (SEE NOTE 1) 1 T 09 + REMOVE AND REPLACE PORTION OF EXIST. BERM AS REQUIRED FOR CONSTRUCTION OF WALL (3 B-4-02 / BENTONITE HYDRATION POND • (SEE NOTES 7 AND 8) NO. ELECTRICAL CONDUIT I I STA: 5 +23.27 N 193606.32 y n OVERHEAD POWER g rAND POWER P (SEE NOTE 6) REMOVE EXIST. BERM REMOVE EXIST. WALL BY. DATE STORM DRAIN REVISIONS DESCRIPTION - IMPERMIX BARRIER WALL, PER (SEE NOTE 1)O T -I . REMOVE EXIST. RAILROAD TRACKS AS REQUIRED EXISTING BUILDING 81A1 J •I-4 -INCH $ISNRARY SEWER • _.PROCESS DRAINAGE LINE (SEE NOTE 10) 13-15-0 210-INCH �_ ' WATER \�N 193515 8 6 (SEE NOTE E 6) E 1637128.38 2 -INCH WATE 4 -INCH WATER ROCESS DRAINAGE LINE (SEE NOTE 10) `'- ADDITIONAL UTILITIES, • 95 / / THAT ARE NOT SHOWN, . +• -4--. * T' 8 T F 10 4 ST IN T AREA. _ -DSoI 3 -INCH WATER ST' 8 +50 (SEE NOTE /6) INCLUDE WATER, SANITARY F r, - +._ -} +� (ABANDONED) N/93286.35 + - - { - ` I E 637124.24 SEWER, ELECTRIC7ICSONDUTS, + AND CF.SSARA)NAGE UNES -- _ - -� PROCESS DRAIAGE LINE (SEE NOTE JO),- .,,,,- 1 ' - STORM DRAIN . 4A3A1530,4'6) .. -.- Y �, ' '� �..r ? STA: 10 +30.45 N 193178.60 r'-'7 1 68.43 X � (SEE NOTE 5) �1 8 -INCH RM DRAIN (ABANDONED) 8 -INCH STORM DRAIN (ABANDONED) 70% DESIGN SOIL - BENIONITE BARRIER WALL PER (SEE NOTE 1) 1 UILDNG MW Ol + T + - EXISTING BUILDING 38 -INCH STORM DRAIN DRAWING INFORMATION DRAWING SCALE: AS SHOWN DESIGNED BY: I. GROSS DRAWN BY: B. HILLMANN CHECKED BY: D. HAWK APPROVED BY: L. McOAUGHEY INIT. FILE: Project on SEAS...ACI Figures \29942 WALL.d.g 1111111. 1 11111 1 ' 1 llil' 1 1 1 1III 2 IIl i�IIII)II111111)LII•II1ri1)II I1 11I11I11.IIIII1II1IIII111111111 3 Inch 1/16 - 4 5 6 . v 91- t '1`.. �� 7 'I' £1 6 .k..., 8 • I I I I I I 1 1 1 1 L 1 I 1 1 1 u 1 1 e I 1 I L 1 1 1 1 1 I . 1 1 1 1 . 1 I I I I I P I I I I I J I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ! 1 1 1 1 1 1 1 I I I I I I I 9 11111.111IIIIIIIIII II11 111iIIIIIIJl! III11NH li I IIII DATE W + NOTES 1. AE SOIL- BENTONITEI PERMIX BARRIER WALL PER DETAIL 1/8 SHALL BE CONSTRUCTED FROM STA 0 +00 TO STA 10 +30.45. THE REMAINDER OF THE BARRIER WALL SHALL BE IM, PER DETAIL 3/8 2. UTILITIES CROSSING THE BARRIER WALL ALIGNMENT THAT ARE IDENTIFIED BY THE ENGINEER BARRIER AS WALL. OBSOLETE, SHALL BE PERMANENTLY REMOVED AND CAPPED TO AT LEAST 5 -FEET EITHER SIDE OF THE BARRIER WALL ALIGNMENT PRIOR TO CONSTRUCTION OF THE 3. UTILITIES CROSSING THE IMPERMIX BARRIER WALL ALIGNMENT THAT ARE IDENTIFIED BY THE ENGINEER .AS ACTIVE, SHALL BE TEMPORARILY SHUT DOWN, REMOVED AND CAPPED TO A DISTANCE OF AT LEAST 5 FEET EITHER SIDE OF THE BARRIER WALL ALIGNMENT PRIOR TO CONSTRUCTION OF THE BARRIER WALL. FOLLOWING CONSTRUCTION OF THE BARRIER WALL, THE UTILITIES SHALL BE RE- ESTABLISHED THROUGH THE BARRIER WALL BY EXCAVATING THE WALL TO THE MINIMUM DEPTH REQUIRED FOR RECONSTRUCTION OF THE UTILITY. THE RE- ESTABLISHED UTILITY SHALL INCLUDE A WATER STOP APPROVED BY THE ENGINEER. REPLACE THE EXCAVATED BARRIER WALL WITH A 3 -FOOT THICKNESS OF LOW PERMEABILITY CLAY OR BENTONITE AMENDED SOIL (MAXIMUM PERMEABILITY 1X10 -6 CM /SEC). MINIMIZE THE LENGTH OF BARRIER WALL REMOVED FOR UTILITY RE- ESTABLISHMENT. 4. UTILITIES CROSSING THE SOIL - BENTONITE BARRIER WALL ALIGNMENT THAT ARE IDENTIFIED BY THE ENGINEER AS ACTIVE SHALL BE, AT THE DISCRETION OF THE CONTRACTOR, EITHER: A) TEMPORARILY REMOVED PRIOR TO CONSTRUCTION OF THE BARRIER WALL, AND SUBSEQUENTLY RE- ESTABUSHED THROUGH THE BARRIER WALL, AS DESCRIBED FOR THE IMPERMIX BARRIER WALL (SEE NOTE 3); OR B) RETAINED IN PLACE AND THE SOIL - BENTONITE BARRIER WALL CONSTRUCTED AROUND THEM. UTILITIES TO BE RETAINED SHALL BE PROTECTED AND SUPPORTED THROUGH EACH STAGE OF THE BARRIER WALL EXCAVATION AND CONSTRUCTION. 5. THE IMPERMIX / SOIL - BENTONITE BARRIER WALL CONNECTION. PER DETAIL 4/8 SHALL BE CONSTRUCTED AT LEAST 8 -FEET PAST ANY CHANGES IN DIRECTION OF THE BARRIER WALL ALIGNMENT. EXTEND IMPERMIX WALL AROUND CORNER AT LEAST 8 -FEET AT CONNECTION WITH SOIL - BENTONITE WALL. 6. EXTEND FULL DEPTH SOIL - BENTONITE BARRIER AT LEAST 5 -FEET PAST THE POINT OF INTERSECTION OF ANY CHANGES IN BARRIER WALL ALIGNMENT. AT THE GROUND SURFACE, EXTEND THE SOIL - BENTONITE BARRIER WALL AS NEEDED TO ACHIEVE THE MINIMUM REQUIREMENT FOR THE BARRIER WALL FULL DEPTH. 7. THE MIXING / STAGING AREAS AND BENTONITE HYDRATION POND SHALL BE LOCATED WITHIN THE PERIMETER OF THE BARRIER WALL ALIGNMENT AS SHOWN ON THE DRAWING. 8. CONTRACTOR SHALL ESTABLISH THE LAYOUT AND DIMENSIONS OF THE MIXING / STAGING AREAS AND BENTONITE HYDRATION POND IN ACCORDANCE WITH THE FOLLOWING MINIMUM REQUIREMENTS: URS 1501 4th Avenue, Ste. 1400 SeetUe, IA 90101 -1016 Telephone (204) 438 -2700 A) A MINIMUM FREE -BOARD OF 1 -FOOT SHALL BE PROVIDED FOR ALL FACILITIES USED TO PREPARE AND /OR STORE ANY LIQUID OR SLURRY; B) A CONTAINMENT BERM SHALL BE CONSTRUCTED AROUND EACH AREA USED IN THE PREPARATION AND /OR STORAGE OF ANY LIQUID OR SLURRY; C) CONTAINMENT BERMS SHALL BE CONSTRUCTED FROM COMPACTED FILL AND BE AT LEAST 1.5 -FEET HIGH WITH A MINIMUM CREST WIDTH OF 1 -FOOT; D) PROVIDE A 40 -FOOT OFFSET TO THE BARRIER WALL ALIGNMENT; E) PROVIDE A 30 -FOOT OFFSET TO EXISTING BUILDINGS. 9. BOREHOLE REFUSAL AT LOCATION B -6A -02 (SUSPECT ON REINFORCED CONCRETE) APPROXIMATELY T 8 -FEET BELOW GROUND SURFACE. BOREHOLE RELOCATED TO B -6B -02 10. FORMER PROCESS DRAINAGE LINES HAVE BEEN MODIFIED TO DRAIN INTO THE STORM DRAIN SYSTEM. 11. EXCESS STOCKPILE AREA SHALL CONSIST OF AN AREA CONTAINED BY COMPACTED SOIL. BERMS AND A 20 -MIL PVC LINER OR EQUIVALENT. THE AREA AND CONTAINMENT BERMS SHALL BE DESIGNED TO CONTAIN EXCESS SOIL FROM SOIL - BENTONITE BARRIER WALL I INSTALLATION PLUS SURFACE WATER RUNOFF FROM A 25 YEAR, 24 HOUR DURATION STORM. 12. FIELD ADJUST SLURRY WALL ALIGNMENT TO PROVIDE 10FT MINIMUM CLEARANCE WITH EXISTING MONITORING WELLS. IF NOT POSSIBLE, ABANDON WELL. RECEIVED !AUG 2 9 2002 COMMUNITY DEVELOPMENT 1" = 50' 50 0 100 RCI ENVIRONMENTAL, INC. FORMER RHONE POULENC FACILITY HYDRAULIC CONTROL INTERIM MEASURE TUKWILA, WASHINGTON BARRIER WALL LAYOUT w 1" 0 0 x_ O Z U w W < tJ NW h J J IA tLU <- O DATE: JOB NO. 53 01000496.00 REVISION DRAWING NO. 3 IMPERMIX BARRIER WALL, PER (SEE NOTE 1 m■:*-1,(: SOIL-BENTONITE MIXING/ STAGING AREA (SEE NOTES 7 MD M . , . ". AREA PER SANITARY • (4(11 2 UIB j.. 6-INCH ,,. ,.....• liEMO AE M EUEPLACE AS REWIRED FOR ••••-• S7_7 TRUCTION OF WA i RTION 0 ExItT. BERM / ;*.tr,11141•1:( (SEE NOTE 11) EXCESS STOCKPILE AREA • . •6-INCH SANITARY S LL ;Jet • • • • . ..... STk. 0+00 • N t9614.55 (SEE NOTE 5 4 ---,4•• 0-INCH STORM DRAIN (OUTFALL 7) N193,503 + LEGEND 6-INCH WATER 6-INCH STORM DRAIN STA: 20+16.94 N 193317.10 16 66 0.75 4' 10- I NCH 5g 6-INCH WATER • '' 6-INCH WATER WATER REMOVE EXISTING TANK FOUNDATIONS AS REQUIRED 1 ' es in N. • 40 FOOT RIVER 100-FOOT LOW IMPACT 200-FOOT HIGH IMPACT - PROCESS DRAINACI7LINE AND CATCH BASIN (SEE NOTE 10) + Stk. 16+25.29 N 192940.81 E 1636731.52 1.■ ••■•■ WWI= 0 DM-'.1 6.3.01 TELEPHONE CONDUIT 0 1).2.02 SOIL-BENTONITE BARRIER 0 5-402 WALL AUGNMENT, PER (T\ (SEE NOTE 1 ) IWT / BENTONITE HYDRATION POND (SEE NOTES 7 AND a) 6 REMOVE AND REPLACE PORTION OF EXIST. BERM AS REQUIRED FOR CONSTRUCTION V WALL. ELECTRICAL CONDUIT ‘ 11119.- STA: 5+23.27 2 N 193606.3 & OVERHEAD POWER 1 4 7- 2 AND "- • POWER PO ES (SEE NOTE 6) -1--- t4tv.AD.ri" • .....q • '-' • • ....*•••-• .. + ...-. in . ...■ . ....... . ---1 ...-- REMOVE EXIST, BERM EMOVE EXIST. WALL STORM DRAIN § uJ 4-INCH SANITARY SEWER . --- DRAINAGE LINE (SEE NOTE 10) 5-.02 t B. WATER •• , . .. ,.....• \ 6+20.96 (SEE NOTE 6) 1- 1- , t, \ N 193515.81 E 1637125.38 It IMPERMIX BARRIER WALL. PER (SEE NOTE 1) EX7(717STIN LOIN° 2-INCH WAT 4-INCH WATER ROCESS (RANGE LINE (SEE NOTE 10) STORNI DRAIN 6-INCH) WATER EXISTING BUILDING • MLV!!411 EXISTING • BUILDING • ADDITIONAL UTILMES. / THAT ARE NOT SHOWN, NOTE.') M4Y EXIST IN THIS AREA /6 ADDITION. UTILITIES' MX•e' ..... '" ' -:* 4 SINE-WLEURDEEWLEAcTETRR.m7SAN;IT0AXvirs,:, - • ''''' .. ._. " AND PROKESS:-ORXINAGE LINES , ... - -----%, PROCESS DRAINAGE LINE (SEE NOTE, ).0)..... • .-:::.• :v ...... -. -"- _ "- - • STORM VIAIN v.s.AN9pteij .,..,..., • ' REMOVE EXIST. RAILROAD TRACKS AS REOUIRED Ef, / ATER STA: 8+50 (SEE ) N 193286.35 E 4 1637124,24 N 193175.60 1 7 5-INCH STORM ORAiN (ABANDONED) 8-INCH STORA4 DRAIN (ABANDONED) 38-INCH STORM DRAIN AMEC EARTH AND ENVIRONMENTAL, INC. 11335 N.E. 122nd Way, Suite 100 Kirkland, WA, U.S.A. 98034-6918 riTI: , • • 4i • - 51,- • 61 • Inch • 1/16 1 . • I f 0 • . • • .••.: •!." . TUKWILA, WASHINGTON 0 FORMER RHONE-POULENC SITE LIMITS OF RIVER ENVIRONMENT 100 SCALE IN FEET 200 RECEIVED 1 AUG 2 9 2002 COMMUNITY DEVELOPMENT FIGURE