Feasibility Study Former Sumner Towing Property 810 Alder … · 2018-03-24 · , dated September 15, 2016, was used to develop this FS. Information collected during the RI is summarized

Feasibility Study Former Sumner Towing Property 810 Alder Avenue Sumner, WA 98390

Prepared for: Mr. Leslie Reynolds c/o Foster Pepper PLLC Ken Lederman 1111 3rd Avenue, Suite 3000 Seattle, WA 98101 Prepared by: G-Logics, Inc. 40 2nd Ave SE Issaquah, WA 98027 Telephone: (425) 391-6874 Facsimile: (425) 313-3074

February 15, 2017 G-Logics Project 01-0620-K

G-Logics, Inc. 40 2nd Avenue SE

Issaquah, WA 98027 T: 425-391-6874, F: 425-313-3074

February 15, 2017 G-Logics Project 01-0620-K Mr. Leslie Reynolds c/o Foster Pepper PLLC Ken Lederman 1111 3rd Avenue, Suite 3000 Seattle, WA 98101

Subject: Feasibility Study Former Sumner Towing Property 810 Alder Avenue Sumner, WA 98390 Dear Mr. Reynolds:

G-Logics is pleased to present this Feasibility Study (FS) for the subject property. This FS describes several cleanup-action alternatives to address soil, groundwater, and soil vapor that contain petroleum contaminants. Based on available information and analysis, these contaminants are understood to be associated with a release of gasoline from the former automobile-fueling systems and from surface spills during fuel deliveries.

When this FS is submitted to the Washington Department of Ecology (Ecology), we will request a written opinion from Ecology as to whether the remedial alternative(s) identified in this FS will be likely to meet the substantive requirements for cleanup actions under Washington’s Model Toxics Control Act (MTCA), specifically WAC 173-340-360.

01-0620-K FSRT.doc Copyright 2017 G-Logics, Inc. Page 2 of 2

We trust the information presented in this document meets your needs at this time. Should you require additional information or have any questions, please contact us at your convenience. Thank you again for this opportunity to be of service.

Sincerely, G-Logics, Inc.

Rory L. Galloway, LG, LHG Dan Hatch, PMP Principal Remediation Manager

01-0620-K FSRT.doc Copyright 2017 G-Logics, Inc. Page i of iii

TABLE OF CONTENTS

1.0 DOCUMENT PURPOSE ----------------------------------------------------------------------------------------- 1 1.1 Purpose and Objective 1 1.2 Report Organization 2

2.0 INTRODUCTION -------------------------------------------------------------------------------------------------- 2 2.1 Background 2

2.1.1 Site Characteristics 2 2.1.2 Property History 3 2.1.3 Site Investigations 4 2.1.4 Geology 5 2.1.5 Hydrogeology 6 2.1.6 Interim Actions 6

2.2 Additional Investigations 8 2.3 Conceptual Site Model 8

2.3.1 Fate and Transport 8 2.3.2 Soil Pathway for Exposure 9 2.3.3 Groundwater Pathway for Exposure 9 2.3.4 Soil-Vapor Pathway 10 2.3.5 Surfacewater Pathway 11

2.4 Cleanup Levels 11 2.4.1 Cleanup Levels, Soil 11 2.4.2 Cleanup Levels, Groundwater 11 2.4.3 Screening Levels, Soil Vapor / 11

2.5 Points of Compliance 12 2.5.1 Point of Compliance, Soil 12 2.5.2 Point of Compliance, Groundwater 12 2.5.3 Point of Compliance, Soil Vapor 12

2.6 Applicable Regulations 14

3.0 REMEDIAL ALTERNATIVES ------------------------------------------------------------------------------- 16 3.1 Remedial-Action Objectives 17 3.2 Reviewed Remedial Alternatives 17 3.3 Retained Remedial Alternatives 19

3.3.1 Alternative 1, Containment and Institutional Controls 19 3.3.2 Alternative 2, Monitored Natural Attenuation 19 3.3.3 Alternative 3, Excavation and Off-Site Disposal 20 3.3.4 Alternative 4, In-situ Aerobic Bioremediation 20

01-0620-K FSRT.doc Copyright 2017 G-Logics, Inc. Page ii of iii

3.3.5 Alternative 5, In-Situ Chemical Oxidation 21 3.3.6 Alternative 6, Air Sparge and Soil Vapor Extraction 21 3.3.7 Alternative 7, Excavation and Off-Site Disposal, AS/SVE, MNA 22

4.0 EVALUATION AND SELECTION OF ALTERNATIVES --------------------------------------------- 22 4.1 Threshold Requirements 22

4.1.1 Protection of Human Health and the Environment 23 4.1.2 Compliance with Cleanup Standards 23 4.1.3 Compliance with Applicable State and Federal Laws 23 4.1.4 Provision for Compliance Monitoring 23 4.1.5 Restoration Time Frame 24

4.2 Disproportionate Cost Analysis (DCA) Ranking Criteria 24 4.2.1 Protectiveness 25 4.2.2 Permanence 25 4.2.3 Costs 25 4.2.4 Long-Term Effectiveness 26 4.2.5 Short-Term Risks 26 4.2.6 Implementability 26 4.2.7 Public Consideration 27

5.0 REMEDY SELECTIONS --------------------------------------------------------------------------------------- 27 5.1 Excavation Areas 27 5.2 AS and SVE Areas 28 5.3 Bioremediation Areas 28 5.4 MNA Areas 28

6.0 LIMITATIONS --------------------------------------------------------------------------------------------------- 29 FIGURES

Figure 1: Site Location Maps Figure 2: Site Diagram, Exploration and Cross-Section Locations Figure 3: Site Diagram, Potential Historical Sources of Contamination Figure 4: Site Diagram, GRO Concentrations in Soil Figure 5: Site Diagram, Benzene Concentrations in Soil Figure 6: Site Diagram, GRO Concentrations in Groundwater Figure 7: Site Diagram, Benzene Concentrations in Groundwater Figure 8: Site Diagram, Groundwater Contours 5/25/2016 Figure 9: Conceptual Site Model Figure 10: Cross Section A-A’ GRO Concentrations in Soil and Groundwater Figure 11: Cross Section B-B’ GRO Concentrations in Soil and Groundwater Figure 12: Cross Section C-C’ GRO Concentrations in Soil and Groundwater Figure 13: Site Diagram, Proposed Remedial Alternative Locations

01-0620-K FSRT.doc Copyright 2017 G-Logics, Inc. Page iii of iii

TABLES

Table 1: Soil Sample Analyses Summary Table 1a: Soil Sample Analyses Summary Continued Table 2: Groundwater Sample Analyses Summary Table 3: Soil Vapor Sample Analyses Table 4: Initial Evaluation for Cleanup Action Alternatives Table 5: Detailed Evaluation of Cleanup Action Alternatives and DCA Table 6: Feasibility Level Cost Estimate, Excavation with Off-Site Disposal Table 7: Feasibility Level Cost Estimate, In-situ Aerobic Bioremediation Table 8: Feasibility Level Cost Estimate, In-situ Chemical Oxidation Table 9: Feasibility Level Cost Estimate, Air Sparge and Soil Vapor Extraction Table 10: Feasibility Level Cost Estimate, Source Excavation, AS/SVE, Bio, and MNA GRAPH

Graph 1: Disproportionate Cost Analysis APPENDICES

Appendix A Drinking-Water Well Location Map


1.0 DOCUMENT PURPOSE

The purpose of this Feasibility Study (FS) is to develop and evaluate cleanup-action alternatives such that an appropriate action(s) can be selected for the Sumner Towing Site (Site), to address the contaminants originating and migrating from the Sumner Towing Property (Property). Historically, releases of gasoline are understood to have occurred from underground storage tanks (UST) systems previously located at the Property and surface spills during tank filling.

For the purposes of this document, the “Property” refers to the legal parcels owned by Leslie and Lois Reynolds located at 810 Alder Avenue in Sumner, WA (Figure 1). The “Site” refers to the areas of soil and groundwater that have been impacted with petroleum hydrocarbons originating from Property (Figure 2).

This FS report discusses several remedial options to address the documented soil, groundwater, and soil-vapor contaminants at the Site. The primary contaminants of concern (COCs) for the Site are gasoline-range organics (GRO) and benzene.

This FS has been completed in accordance with the requirements of Washington’s Model Toxic Control Act (MTCA) regulations, specifically WAC 173-340-350, and Ecology’s Feasibility Study Checklist (May 2016, Publication 16-09-007). Additionally, this work has been performed in accordance with the Washington Department of Ecology (Ecology) Voluntary Cleanup Program (VCP), as project number SW0868.

1.1 Purpose and Objective

This FS will be submitted to Ecology for review. With this submittal, we also will request that Ecology provide a written opinion as to whether the remedial action(s) identified by this FS are likely to meet the substantive requirements for cleanup actions under the MTCA regulations, specifically WAC 173-340-360.

With Ecology approval, G-Logics also recommends that a Cleanup Action Plan (CAP) be prepared to address the requirements and steps necessary to initiate remediation at this Site. Following approval of the CAP, additional documents can be prepared, such as an Engineering Design Document. This document would describe system-operation specifics, such as equipment, capacities, locations, and monitoring requirements.


1.2 Report Organization

This FS report is organized per Ecology’s Feasibility Study Checklist, guidance dated May 2016. Primary sections of this report are described below.

Section 1.0 - The first section of this report introduces and describes the purpose of the Feasibility Study.

Section 2.0 – This section provides background information for the Site, including its history, Remedial-Investigation efforts, the nature and extent of contamination, a conceptual site model, cleanup levels, points of compliance, and a listing of other applicable regulations.

Section 3.0 – This section discusses the Remedial Action Objectives and compares several cleanup alternatives for possible use.

Section 4.0 – This section presents a detailed discussion of the threshold and other requirements and presents a disproportionate cost analysis for the retained alternatives.

Section 5.0 – This section describes the rationale for selecting the preferred remedial alternative(s), how the alternative meets the expectations described in WAC 173-340-370, and how the alternative addresses public concerns.

2.0 INTRODUCTION

The data collected during the Remedial Investigation (RI), as discussed in the G-Logics Remedial Investigation Report, dated September 15, 2016, was used to develop this FS. Information collected during the RI is summarized below. A conceptual site model (CSM), cleanup levels, points of compliance, and other applicable requirements for the Site also are described below.

2.1 Background

The following section presents background information for the Property and Site.

2.1.1 Site Characteristics

The Site is located in the central business district of the City of Sumner. Areas northwest of the Property are zoned for commercial and mixed-use developments. Outside of the business district, areas to the north, south, and east of the Property are zoned for residential use.


In 2015, G-Logics conducted a historical review of the area that surrounds the Property. For the historical review, G-Logics reviewed Sanborn Fire Insurance maps, historical aerial photography, Environmental Data Resources (EDR) Radius Report, historical-topographic maps, and reverse-telephone directories. G-Logics also requested documentation from Ecology and the City of Sumner regarding contaminated properties and cleanups.

The historical review is documented in the G-Logics report titled Soil-Vapor and Groundwater Sampling Report, dated July 3, 2015. That review demonstrated that additional sources of petroleum contamination may exist on properties to the north and northeast of the Sumner Towing property, specifically, on properties located north of Maple Street (Figure 3).

The Property is currently open and undeveloped. To the immediate northwest of the Property is a vacant building, formerly a Red Apple Grocery Market. The Property is bordered by Alder Street to the east. To the immediate south of the Property is a vacant building, formerly used as bank and currently owned by the City of Sumner. The Property immediately to the west is a paved parking area used by the City of Sumner for transit parking. Beyond the parking lot to the west is Kincaid Avenue, followed by residential homes.

The local topography at the Site is generally characterized as a flat-lying river valley. The Site is located at an approximate elevation of 70 feet above mean sea level.

2.1.2 Property History

A review of historical records shows that the Property and surrounding areas were occupied by farms and residential dwellings, from the late-1800s to the mid-1950s. In 1958, Richfield Oil Corporation (“Richfield Oil”) acquired the Property and constructed a gas station on the parcel, which opened for business in 1959 as a Richfield Gas Station. In 1960, Richfield Oil conveyed the Property to the Forfield Corporation, which then leased it back to Richfield Oil to continue operating the gas station. In 1966, Richfield Oil merged with Atlantic Refining Company to form Atlantic Richfield Company (ARCO).


In approximately 1971, Mr. Reynolds entered into a sublease agreement with ARCO for the parcel and renamed the station Sumner Towing and Automotive Repair. Under the agreement, it was understood that Mr. Reynolds would operate the Property as an automotive-repair facility and gasoline-fueling station, and that Mr. Reynolds would only purchase fuel from ARCO.

On November 22, 1974, ARCO took title to the Property from Forfield Corporation, and Mr. Reynolds entered into a new lease agreement with ARCO. In February of 1975, Mr. Reynolds purchased the Property from ARCO.

From 1971 through June 1982, it is understood that Sumner Towing was exclusively a dealer of ARCO gasoline and purchased all gasoline sold on the Property from ARCO. In June 1982, Mr. Reynolds entered into a contract with Mobil Oil Corporation, and began exclusively selling Mobil gasoline at the Property. In 1988, Mobil terminated the contract and all sales of gasoline on the Property ceased. After the termination of the Mobil contract, the USTs were emptied, closed in-place, and filled with concrete (in 1988).

Automobile-repair operations continued on the Property until 2007, when the USTs, fueling lines/systems, and service-station building were removed. The Property has remained vacant and unpaved since the tank removal work in 2007.

2.1.3 Site Investigations

Environmental Associates Inc. (EAI) performed a preliminary subsurface assessment of soil and groundwater conditions at the Property in of March 2000. The EAI exploration discovered petroleum-contaminated soil and groundwater in the UST and dispenser areas. Analytical data from this exploration is summarized in Tables 1, 1a, and 2 of this FS report.

In November 2000, Saltbush Environmental Services (Saltbush) completed several additional borings to assist in evaluating the extent of petroleum contamination. Saltbush discovered petroleum contamination extending laterally and vertically beyond what was previously identified by EAI. Analytical data from this exploration is summarized in Tables 1, 1a, and 2 of this FS report.


G-Logics conducted additional explorations at the Site, which are documented in G-Logics Remedial Investigation Report, (RI) dated September 15, 2016. In total, G-Logics and others have completed 84 soil borings at the Site, completing 28 as groundwater-monitoring wells, and five as permanent soil-vapor sampling points.

The remedial exploration efforts found that GRO and benzene are the targeted chemicals of concern (COCs) for the Site. Analytical results for the exploration efforts are summarized in Tables 1, 1a, 2, and 3.

The remedial-investigation efforts found that petroleum contaminants remain on the Property at concentrations above MTCA Method A cleanup levels (cleanup levels). These areas are associated with the former USTs and immediately to the west of the former tanks (Figures 4 through 7). Based on soil-analytical data gather during the Saltbush exploration efforts (Table 1), it appears that petroleum contaminants were found at depths higher than the bottom of the USTs. Specifically, boring “Bore 1” found concentrations of gasoline at an approximate depth of 5-6 feet, which is understood to be higher than the bottom of the former USTs, understood to be at an approximate depth of 9.5 feet. Petroleum contaminants found at these shallower depths may be from releases from supply lines, vent lines, and/or surface spills that occurred during tank filling.

Petroleum contaminants have migrated via groundwater transport to approximately 185 feet west of the Property, crossing Kincaid Avenue and migrating beneath residential properties. After completing a vapor-intrusion assessment in these residential areas including several rounds of sampling, it is understood that vapor intrusion does not present a concern for the Site and specifically, for the residential areas west of Kincaid Avenue.

2.1.4 Geology

A review of a regional geologic map (WA DNR, 1987) indicates that the surface of the Site is underlain by Quaternary Alluvium (Qa). Qa deposits are typically silt, sand, and gravels deposited in stream beds and river valleys.

Soil borings generally encountered fine-grained materials (sand, silt, and clay) to a depth of 15-20 feet, with a silt/clay layer present within this unit across the Site. On the Property, this layer is generally encountered 7 to 18 feet below the ground surface. This layer is observed to be present at shallower depths to the west and south of the Property, extending from approximately depths of six to ten feet. This fine-grained soil appears to be


continuous, and frequently the potentiometric surface of the water table is measured within this unit. Deeper borings recovered coarser grain sands and gravels, including pumice and wood debris, between 15-30 feet below the surface. These materials are believed to be associated with eroded and redeposited sediments from the deeper Osceola Mud Flow, eruptive material from Mount Rainier approximately 5,500 years ago. Cross-sections showing the subsurface geology are presented on Figures 10, 11, and 12.

2.1.5 Hydrogeology

Groundwater at the Site is generally found to be 10 to 20 feet below the ground surface with a flow direction toward the west-southwest (Figure 8). The depth to groundwater varies seasonally, with water levels approximately three to four feet higher in the wet, winter months than when measured in the dry summer months.

The White River is located approximately a quarter-mile to the west/northwest, and the Puyallup River is located approximately a half-mile to the southwest (Figure 1). These rivers converge and flow west toward Puget Sound. Groundwater ultimately discharges into one or both of these rivers

2.1.6 Interim Actions

Automobile-repair operations continued on the Property until 2007, when the USTs, fueling lines/systems, and service-station building were removed. As part of this work, Environmental Corporation (EnCo) removed the four single-wall steel USTs (and associated lines) from the Property between August 27 and September 6, 2007. EnCo did not prepare a UST Closure Report for this effort. Analytical data from the EnCo tank-closure work is summarized in Tables 1 and 1a of this FS report.

EnCo conducted soil sampling after the UST excavations, with a total of ten samples collected from the bottom and sides of the gasoline UST excavation. The excavations were limited to the immediate tank area and were not extended to pursue cleanup of petroleum-impacted soils. EnCo also conducted post excavation sampling for the fuel dispenser area and in the service garage for a hydraulic hoist and an oil-water separator. All of the collected and analyzed soil samples in the gasoline-UST excavation contained concentrations of gasoline and benzene above cleanup levels. One of the four samples collected in the dispenser area (from a depth of 2 feet) reported concentrations above these cleanup levels.


Approximately 100 cubic yards of suspected petroleum-impacted soil was removed from the tank excavations and placed on plastic at the northwest corner of the Property. The covered stockpile was left on the Property and not disposed offsite at the time of the UST-excavation work.

EnCo did not prepare a UST Closure Report for this tank-removal effort. As a tank-closure report was not prepared, G-Logics compiled information collected from the Tacoma Peirce County Health Department (TPCHD) and EnCo regarding the UST excavation and closure efforts. This information is summarized in the G-Logics UST Closure Site Assessment Report, dated March 9, 2009. We understand that Mr. Kemp indicated (in an email dated September 24, 2009) that he “observed and have photographed several large holes in the gasoline tanks that were removed from the site”. However, Mr. Rob Olsen, a UST Inspector for the TPCHD was present and observed portions of the excavation for the four USTs. To obtain information for the 2009 report, G-Logics talked with Mr. Olsen regarding his recollection of his site visit during the excavation effort. Mr. Olsen indicated that the associated fuel and vent lines also were removed during the UST-removal efforts, though the dispensers had previously been removed several years earlier. Mr. Olsen stated that he did not observe any obvious holes in the tanks and surmised that petroleum releases were due to overfills and possibly fuel-line leaks. Mr. Olsen indicated that other than localized water present in the tank backfill, groundwater was not encountered in the excavations.

To provide additional review in regards to the observed conditions of the USTs during their removal, G-Logics prepared a memo, titled Opinion Letter, Review of UST Photographs, dated September 13, 2013. Based on the review of EnCo photographs taken at the time of tank removal, G-Logics recognized that corrosion was present on the USTs, noting that several small holes may have been present on one of the tanks. However, obvious indications of “large holes” in the USTs were not visible in the photographs (other than the large holes introduced by the excavation equipment). Additionally, it was noted in the photographs that fuel staining was not observed on the tanks.

In February 2015, the 2007-stockpiled soil from the UST excavations was removed from the northeast corner of the Property and disposed offsite. This effort is documented in G-Logics Stockpiled Soil Removal memo, dated March 4, 2015.


2.2 Additional Investigations

As of the date of this FS, no additional investigations have been completed at the Site, beyond those discussed in the referenced RI report.

2.3 Conceptual Site Model

As discussed above, releases of gasoline originated from the Sumner Towing Property in the areas of the former USTs and fuel/vent lines. The analytical data collected during the RI demonstrate that the primary COCs for the Site are GRO and benzene. Soil and groundwater have been confirmed as impacted media. Indoor air remains a potential concern, based on elevated concentrations of petroleum contaminants in soil and groundwater beneath the Site. The following sections include discussion of the fate and transport of the hazardous substances, impacted media, and potential exposure pathways. The conceptual site model for this Site is illustrated on Figure 9.

2.3.1 Fate and Transport

The Site COCs are transported from the source area throughout the subsurface in three phases. These include soil (sorbed onto soil particles), groundwater (dissolved and suspended in the water), and soil vapor (existing above the water table). The contaminants generally migrate away from areas of high concentration by diffusion and advective methods, transported by gravity (vertical), and groundwater flow (lateral). Contaminant concentrations decreases with distance from the source area based on several factors , including volume of the release, the duration of the release, soil characteristics (porosity and permeability), groundwater transmissivity (gradient and volume), geologic deposits, subsurface utilities (preferential pathways), and biodegradation of the contaminants.

Soil concentrations are highest in the area of the former tanks and in areas to the west. Soil contaminants attenuate with distance from the source and can be degraded by bioremediation when sufficient oxygen is present.

Groundwater and associated contaminants generally flow to the west-southwest. Contaminant-flow directions do not strictly mirror the mapped groundwater gradient, indicating that preferential pathways, such as more permeable materials, are present. Like the soil contaminants, groundwater contaminants also attenuate with distance from the source and can biodegrade with sufficient oxygen.


The primary COCs, GRO and benzene, will volatilize from soil and groundwater into a gaseous state. In areas of the Site where a cover (e.g., asphalt pavement) is not present, these vapors will escape into the atmosphere. Once in the atmosphere, the vapors will rapidly attenuate and degrade. Where these vapor contaminants cannot directly escape, the primary transport mechanisms are diffusion (from the contaminated groundwater and within the vadose zone) and possibly advection (assuming subsurface-pressure differences). Soil vapors attenuate with distance from the source and also can be degraded by bioremediation with sufficient oxygen. For each media, additional information is presented below.

2.3.2 Soil Pathway for Exposure

No ongoing releases are occurring because the USTs were emptied in 1988 and removed in 2007. The contaminated soil in the UST area continues to act as a source for contamination of groundwater and soil vapor.

Contaminated soils typically present a potential impact to human health and the environment through possible ingestion and direct contact. If contaminated soils are exposed, inhalation of contaminants volatilizing from contaminated soils also presents a potential exposure.

Contaminated soils at this Site are not currently present at the ground surface. Additionally, beyond the Property boundary, contaminated soils are generally covered by paved surfaces or buildings. However, direct contact with these contaminated soils could occur during development excavations and/or utility-maintenance activities.

The extent of the identified soil contamination is presented on Figures 4 and 5. The highest concentrations of soil contamination are located in the western half of the Property. Soil concentrations rapidly diminish to the west, with concentrations dropping below cleanup levels near Kincaid Avenue.

2.3.3 Groundwater Pathway for Exposure

Based on the current and probable future use of the Site, human ingestion and dermal contact with contaminated groundwater is not expected to occur. Specifically, the Site and surrounding areas are served by municipal water. According to the Ecology well-log database, drinking-water supply wells are not located within the Site or in downgradient


locations (Appendix A). However, direct contact with contaminated groundwater could occur during development excavations and/or utility-maintenance activities.

Figures 6 and 7 present interpretations of the extent of the identified groundwater contamination. The highest concentrations of groundwater contamination are located in the western half of the Property and immediately west of the Property. Groundwater concentrations rapidly diminish west of the Property, with concentrations dropping below cleanup levels just west of Kincaid Avenue, where the residential properties in the area are located.

2.3.4 Soil-Vapor Pathway

Soil-vapor contaminants present a potential risk to human health through possible inhalation. Specifically, an exposure pathway exists for benzene to migrate into indoor air via vapor intrusion.

As discussed in Section 2.1.1 of this report, the Property is undeveloped, the bank building to the south is vacant, and the former Red Apple Market building to the northwest also is vacant. With the review presented in Section 3.7.4 of the RI report, empirical data and the petroleum-vapor intrusion (PVI) assessment demonstrate that vapor intrusion (resulting from contaminated groundwater at this Site) is not resulting in unacceptable exposure concentrations in the downgradient-residential areas. The soil-vapor pathway was not evaluated in the vicinity of the source area, as no occupied buildings are present in this area. Accordingly, further assessment or mitigation may be warranted in the area of the Property, should adjoining properties (such as the bank building to the south) become reoccupied.

While inhalation exposure could occur to workers during development/maintenance excavations in the area the magnitude and duration of such exposure would be limited. Specifically, excavations would be open to the atmosphere and/or mechanically-ventilated, thereby reducing potential vapor exposure to workers. Additional protective equipment also could be worn if needed.


2.3.5 Surfacewater Pathway

Groundwater in the region is expected to eventually discharge into the Puyallup River and/or the Cedar River (approximately 1,300 feet west of the Site). However, based on the findings of the site-characterization efforts and as documented in the RI mapping identified above, it is understood that Site contaminants are attenuating with distance from the Property, and therefore do not present a threat to surfacewater.

2.4 Cleanup Levels

Soil, groundwater, and soil-vapor cleanup levels have been identified for this Site and can be used when determining if additional investigation and/or cleanup is necessary. For each media, cleanup levels for the identified COCs are discussed below. If, during the course of future remediation work these cleanup levels become impracticable to achieve, due to cost-versus benefit considerations, then land use restrictions and/or alternative cleanup levels may be considered.

2.4.1 Cleanup Levels, Soil

Detected contaminants have been compared to the MTCA Method A cleanup levels for unrestricted use. Soil cleanup levels for the Site COCs are listed in Tables 1 and 1a. These conservative levels are described to be protective of the direct-contact and ingestion pathways and are protective of groundwater for drinking-water uses.

2.4.2 Cleanup Levels, Groundwater

Detected contaminant concentrations and groundwater cleanup levels are summarized in Table 2. The presented cleanup levels are the conservative and unrestricted-use MTCA Method A cleanup levels.

2.4.3 Screening Levels, Soil Vapor /

Soil-vapor concentrations are compared against the current Ecology published soil-vapor screening levels, as shown in Table 3.


2.5 Points of Compliance

The points of compliance for soil, groundwater, and soil vapor are discussed below.

2.5.1 Point of Compliance, Soil

The point of compliance for direct contact is from the ground surface to a depth of 15 feet. However, in order to facilitate groundwater remediation, the point of compliance for soil at the Site shall extend to all depths where soil may act as a source of ongoing groundwater contamination and as a source of unacceptable levels of soil vapors (vapor intrusion to overlying and nearby structures). Figures 10, 11, and 12 show the depths/elevations where soil contaminants have been identified at concentrations greater than the identified cleanup levels.

2.5.2 Point of Compliance, Groundwater

The point of compliance for groundwater is the uppermost level of the saturated zone extending vertically to the lowest depth that potentially could be impacted by Site contaminants throughout the plume of contaminated groundwater. Figures 10, 11, and 12 show the depths/elevations where groundwater contaminants have been identified at concentrations greater than the identified cleanup levels.

2.5.3 Point of Compliance, Soil Vapor

For this Site, the point of compliance for soil vapor will be indoor ambient air throughout the Site in accordance with the lateral and vertical inclusion zones, as presented in the following discussion and summary.

2.5.3.1 Lateral-Inclusion Zone

Based on the petroleum vapor-intrusion guidance documents published by the United States Environmental Protection Agency (EPA, June 2015) and Ecology (Review DRAFT October 2009, Revised 2016 and Memorandum No. 14 dated March 2016), existing and/or future buildings located laterally and/or vertically within set distances of subsurface contamination may experience unacceptable vapor-intrusion impacts.


Based on the soil-vapor guidance documents, buildings that are laterally within 30 feet of subsurface petroleum contamination with groundwater concentrations above screening levels may experience unacceptable vapor-intrusion impacts. This distance is referred to as the lateral-inclusion zone and is defined as the area surrounding a petroleum-contaminant source through which vapor-phase contamination might travel and intrude into buildings at unacceptable concentrations.

The lateral distance to subsurface contamination should first be identified to assess if a building or buildings are within the lateral-inclusion zone. If existing or planned buildings are not in the lateral inclusion zone (30 feet), then the initial PVI assessment process is complete. Specifically, a 30-foot horizontal separation distance from the edge of the contamination to a structure is likely to provide an adequate separation distance to exclude soil-vapor concerns.

2.5.3.2 Vertical Separation Distance

If a building or buildings are within the lateral-inclusion zone, the vertical separation distance between the contaminant source and the building foundation also should be considered to assess if unacceptable vapor-intrusion impacts may occur. The vertical separation distance represents the thickness of clean, biologically-active soil between the source of petroleum-hydrocarbon vapors and the deepest point of a structure.

For the vertical-separation distances, contaminant concentrations in soil and groundwater must be assessed separately. As described in Ecology’s Memorandum No. 14, the depths of contaminants in soil and/or groundwater are compared to the concentrations of benzene and/or total petroleum-hydrocarbons (TPH). The vertical separation distances for petroleum contaminants in soil and groundwater are shown in the following table.


Recommended Vertical Separation Distances Between Contamination and Building Basement Floor, Foundation, or Crawlspace

Media Benzene TPH

Vertical Separation

Soil (mg/kg)

≤ 10 ≤ 100 (for unweathered GRO)

≤ 250 (for weathered GRO & DRO) 6’

> 10 > 100 (for unweathered GRO)

> 250 (for weathered GRO & DRO) 15’

Groundwater (μg/L)

≤ 5,000 ≤ 30,000 6’

> 5,000 > 30,000 15’

The depth to subsurface contamination should be assessed to identify if a building or buildings are within the specified vertical-separation distance. Dependent on contaminant concentrations, if the separation-distance criteria are met (as specified in the table above) based on the measured soil and groundwater concentrations for benzene and TPH, then the initial PVI assessment process is complete.

2.6 Applicable Regulations

The state law that guides the soil remediation process at sites located within Washington State is the Model Toxics Control Act (MTCA). The regulations implementing MTCA are located in the Washington Administrative Code (WAC), Chapter 173-340. MTCA is administered by the Washington Department of Ecology (Ecology).

MTCA “establishes administrative processes and standards to identify, investigate, and cleanup facilities where hazardous substances have come to be located” (WAC 173-340-100 to 140). MTCA regulations also list prescriptive, numerical Method A cleanup levels where the “cleanup action may be routine (WAC 173-340-700 to 760) or may involve relatively few hazardous substances.”


The MTCA regulations also require that site cleanups comply with other applicable state and federal laws. Accordingly, other potentially applicable regulatory requirements for a cleanup action at this Site include the following.

• The Federal Clean Water Act (33 USC Section 1251)

• Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 40 CFR 300

• The Resource Conservation and Recovery Act (RCRA), 40 CFR 239-282

• USDOT Hazardous Materials Regulations (HMR), 40 CFR 100 through 185

• The Toxic Substances Control Act (TSCA), 15 USC Section 2601

• The Occupational Safety and Health Act (OSHA) (Part 1910 of Title 29 of the Code of Federal Regulations, 29 CFR 1910)

• Washington’s Dangerous Waste Regulations (Chapter 70.105 RCW; Chapter 173-303 WAC)

• Washington’s Solid Waste Handling Standards (Chapter 173-350 WAC)

• Water Quality Standards for Groundwaters of the State of Washington, Chapter 173-200 WAC

• Washington’s Water Quality Standards for Surface Waters of the State of Washington, Chapter 173-201A WAC

• Federal and State Clean Air Acts (42 USC 7401 et seq.; 40 CFR 50; RCW 70.94; WAC 173-400, 403)

• The State Environmental Policy Act (SEPA) (RCW 43.21C; WAC 197-11)

• Washington’s General Occupational Health Standards (WAC 296-62)

• Washington’s Safety Standards for Construction Work (WAC 296-155)

• Minimum Standards for Construction and Maintenance of Wells (WAC-173-160)

• Shoreline Management (Chapter 90.58 RCW, Chapters 173-14 through 173-28 WAC)

• Water Resources (Chapter 18.104 RCW, Chapter 173-160 WAC)

• Underground Injection Control (UIC) Program (WAC 173-218)

• Guidance for Evaluating Soil Vapor Intrusion in Washington State: Investigation and Remedial Action, Review Draft, October 2009, Publication Number 09-09-047


• Technical Guide For Addressing Petroleum Vapor Intrusion At Leaking Underground Storage Tank Sites, (U.S. Environmental Protection Agency, June 2015)

• Native American Graves Protection and Repatriation Act (NAGPRA), 43 CFR 10

• Indian Graves and Records, RCW 27.44

• Archaeological Resources Protection Act (ARPA), 16 US Code Chapter 1B

• Regulations, codes, and permits from local cities and counties (e.g., Water Quality, Road Closure, etc.)

3.0 REMEDIAL ALTERNATIVES

Cleanup actions often involve a combination of active-remedial methods, such as the treatment of soil and groundwater contamination in high-concentration areas. If complete cleanup is impracticable, passive remediation techniques or containment of remaining contamination are potential options. As stated in the MTCA regulations (WAC 173-340-370), Ecology expects that the considered cleanup methods will minimize the need for long-term management of contaminated materials and that all hazardous substances will be destroyed, detoxified, and/or removed to concentrations below cleanup levels throughout the Site. However, Ecology also recognizes that engineering controls, such as containment, need to be implemented at sites where the treatment/cleanup of large volumes of hazardous substances (with relatively low concentrations) is impracticable.

With the identified cleanup standards (cleanup levels and points of compliance), several “Cleanup Action Alternatives” (CAAs) can be reviewed to achieve compliance. This Feasibility Study evaluates these CAAs, as discussed below.


3.1 Remedial-Action Objectives

Possible CAAs need to meet the remedial objectives for the Site, which include the protection of human health and the environment and compliance with MTCA and other regulatory requirements. Site-specific objectives also include the following.

• Protection from direct contact and ingestion of contaminated soil

• Protection of groundwater for drinking-water use

• Protection of indoor air quality

3.2 Reviewed Remedial Alternatives

Summarized below and presented on Table 4 are potential CAAs for soil, groundwater, and soil vapor. Table 4 also describes the advantages and disadvantages of each potential CAA and the determination if the CAA has been retained for further consideration. The following CAAs were evaluated for the Site:

• No Action. No further action will be taken at the Site.

• Containment and Institutional Controls. This method identifies possible land-use restrictions to minimize exposure pathways. Restrictions can include fencing, signage, capping, barriers, land-use limitations, and title/deed restrictions. Institutional controls would likely require long-term monitoring, maintenance, and public notification. The method may be applicable after completion of active remedial methods.

• Monitored Natural Attenuation (MNA). Natural attenuation relies on natural processes to decrease concentrations of contaminants in soil and groundwater. This alternative requires monitoring the subsurface conditions to verify that natural attenuation is occurring.

• Excavation and Off-Site Disposal. This alternative involves excavation of accessible soils with elevated concentrations of COCs. Excavated soils can be treated, reused, or disposed.

• In-Situ Stabilization/Solidification. This method involves introduction of compounds to immobilize the contaminants and prevent migration.

• In-Situ Thermal Treatment. This technique generally utilizes the application of heat into the contaminated soil and groundwater to volatilize the petroleum hydrocarbons. Vapors are then extracted with vapor-extraction wells.

• In-Situ Aerobic Bioremediation. This method remediates contaminated soil and groundwater through the injection of oxygen or oxygen-release


compounds. This effort can be enhanced with supplements of natural microorganisms and trace nutrients.

• In-Situ Chemical Oxidation Treatment. This method addresses contaminated soil and/or groundwater with an addition of an oxidation compound, such as Fenton’s Reagent (concentrated solution of hydrogen peroxide and an iron-sulfate catalyst), ozone, persulfate, or permanganate.

• Soil-Vapor Extraction System (SVE). With this method, volatile and semi-volatile organic compounds are volatilized and removed from unsaturated soils by a Soil SVE system. The SVE process draws air through the contaminated vadose zone (soils above the water table). This method also frequently draws oxygen through the subsurface, enhancing bioremediation. The effectiveness of this method to address groundwater contamination is limited, largely limited to reducing contaminant migration from the soil into the groundwater.

• Air Sparging (AS). With this method, air is injected into soil below the water table causing volatilization of dissolved contaminants, with subsequent upward migration of volatile contaminants into the vadose zone. This method also adds oxygen to the subsurface, enhancing bioremediation. A SVE system likely will be required to draw the volatilized contaminants out of the vadose zone.

• Dual-Phase Extraction (DPE). With this method, groundwater is extracted with vacuum pumps, depressing the water table, allowing volatile components in the vadose zone to be removed by similar to SVE.

• Barrier Wall. This alternative involves construction of a barrier wall, either by excavation and backfill with impermeable materials, mixing of impermeable materials, or installation of overlapping sheet piles.

The purpose of identifying and screening potential CAAs is to eliminate those CAAs that clearly are not applicable, not practicable, or are not technically feasible due to Site conditions or other constraints. Eliminated alternatives were not found to be protective, permanent, effective, easy to implement, applicable to Site conditions, and/or too expensive compared to the resulting benefits.


Based on the review completed in Table 4, the following alternatives were not retained for further consideration.

• No Action

• Solidification/Stabilization

• In Situ Thermal Remediation

• Dual Phase Extraction

• Barrier Wall

3.3 Retained Remedial Alternatives

As summarized in in Table 4, seven CAAs were retained as possible remediation technologies for this Site. The seven alternatives are described below.

3.3.1 Alternative 1, Containment and Institutional Controls

Institutional Controls assume environmental impairment is low and the risk to the environment is minimal. Based on the current understanding of Site conditions, direct contact or the ingestion of contaminated soil and groundwater do not appear to be occurring nor are they likely to occur under current land uses. However, exposures may occur in the future, with land-use changes or development opportunities. Furthermore, this CAA only limits access to subsurface contaminants and assumes contaminants are not migrating, or are diminishing by natural attenuation. Institutional controls are not a permanent solution and likely would not meet protectiveness criteria.

3.3.2 Alternative 2, Monitored Natural Attenuation

As per Institutional Controls, Monitored Natural Attenuation assumes that environmental impairment is low and the risk to the environment is minimal. MNA also assumes that contaminants are not migrating and are diminishing by natural processes, such as diffusion, dispersion, and bioremediation. Again, based on the current understanding of Site conditions, direct contact or the ingestion of contaminated soil and groundwater do not appear to be occurring and likely would not occur under current land uses. However, exposures may occur in the future, with land-use changes or development opportunities. MNA, while being a low-cost alternative, is not a permanent solution and likely would not independently meet the protectiveness criteria.


3.3.3 Alternative 3, Excavation and Off-Site Disposal

Soil excavation and off-site disposal can offer superior permanence, protectiveness, and long-term effectiveness, given that contaminants are physically removed and treated/disposed. Confirmation samples also can be readily collected to evaluate the effectiveness of the excavation. For comparative purposes, this alternative assumes that excavation and off-site disposal will address soil and groundwater contamination throughout the Site.

Excavation has short-term risks including exposure to contaminants via direct contact and inhalation and safety issues related to this type of construction work. While soil excavation is frequently used and easily implemented, several Site conditions also need to be evaluated, such as shoring, slope stability, dewatering, and backfill/compaction. Contaminants found at high concentrations and close to the surface makes excavation in specific areas more cost-effective. In areas downgradient of the Property, contamination is present approximately 15 feet below clean overburden soils, making excavation significantly more expensive.

3.3.4 Alternative 4, In-situ Aerobic Bioremediation

Bioremediation, using oxygen and trace nutrients, can result in complete destruction of Site contaminants. However, this method could require five to ten or more years of treatment in order to achieve cleanup levels throughout the Site. The rate of success is driven by the size and scope of the installed treatment system. For example, oxygen can be delivered using simple compressors and perforated-piping systems or can include the use of multiple injections of oxygen-releasing compounds. Additionally, the effectiveness of this process is dependent upon a uniform delivery of oxygen into contaminated areas. Furthermore, depending upon installed system components, bioremediation may be less effective for soils located in the vadose zone and the vapor-phase contaminants present in these soils. Bioremediation in areas of elevated contaminant concentrations would require considerable effort and resources to achieve cleanup levels.

Based on Site conditions, this alternative likely is most applicable in areas downgradient of the Property, where contaminants are dispersed laterally and at lower concentrations. Given the complexities of the Site’s geology, compliance monitoring also may identify the need for additional treatment in select areas.


3.3.5 Alternative 5, In-Situ Chemical Oxidation

Like bioremediation, chemical oxidation can result in complete destruction of Site contaminants. This method uses the introduction of oxidizer compounds, such as permanganate, ozone, and peroxides, and could require three to five or more years of treatment in order to achieve cleanup levels throughout the Site. Oxidizers can be delivered by multiple injections of oxidizing compounds into the subsurface or installation of permanent injection points/galleries, using simple pumps and perforated-pipe systems. The schedule of performance and the rate of success are driven by the size and scope of the installed treatment system. The effectiveness of this process also is dependent upon a uniform delivery of treatment compounds into contaminated areas. Chemical oxidation also is not effective for soils located in the vadose zone and the vapor-phase contaminants present in these soils. Application of chemical oxidizers to the elevated contaminant concentrations in the source area on the Property would require considerable effort and resources to achieve cleanup levels.

This alternative, like bioremediation, is predominantly applicable in areas downgradient of the Property, where contaminants are found dispersed laterally and at lower concentrations. Given the complexities of the Site’s geology, compliance monitoring also may identify the need for additional treatment in select areas.

3.3.6 Alternative 6, Air Sparge and Soil Vapor Extraction

A treatment system using air sparging and soil-vapor extraction (AS/SVE) can quickly begin to remove soil, groundwater, and soil-vapor contaminants. The AS components can be simple compressors used to inject air into soils below the water table. This action both volatilizes contaminants and provides oxygen to promote microbial activity. The SVE components use vacuum pumps to remove soil vapors from the vadose zone, using vertically or horizontally placed perforated-piping. These systems are fairly inexpensive to install, operate, and maintain. An AS/SVE system provides remediation benefits by mechanically separating contaminants from the subsurface media. SVE systems also reduce the potential for vapor-intrusion risks.

As discussed above for alternative 4, the addition of oxygen into the subsurface enhances bioremediation, acting as a secondary benefit. Contaminant-extraction rates and volumes will need to be monitored to evaluate if air-treatment systems may be needed in the initial


stages of cleanup. Compliance monitoring also may identify the need for additional treatment in select areas.

3.3.7 Alternative 7, Excavation and Off-Site Disposal, AS/SVE, MNA

Given the complexity of site geology and contaminant locations, a combination alternative also has been retained for further review. As shown on Table 5 and Graph 1, alternative 7 considers the complementary use of several remedial technologies, each located in specific areas of the Property.

For this alternative, soil excavation and off-site disposal is recommended for targeted areas on the Property. Beyond and below the excavated area, AS and SVE systems can be installed to remediate deeper contaminants. The SVE component also can help to remove soil-vapor contaminants. With the addition of oxygen by the AS component, bioremediation also will occur, further reducing Site-contaminant concentrations. Following these active remediation methods, MNA may be applicable for residual concentrations at the Site.

4.0 EVALUATION AND SELECTION OF ALTERNATIVES

MTCA requires that remedial alternatives selected for a Site meet certain minimum threshold and other requirements, per WAC 173-340-360(2), and use permanent solutions to the maximum extent practicable. Specifically, CAAs need to meet the following threshold requirements in order to be retained for possible use.

• Protect human health and the environment

• Comply with cleanup standards

• Comply with applicable state and federal laws

• Provide for compliance monitoring

4.1 Threshold Requirements

A detailed review of the retained alternatives, relative to the listed threshold criteria, has been completed and is presented as Table 5. These threshold criteria are further discussed below.


4.1.1 Protection of Human Health and the Environment

Protection of human health and the environment includes “the degree to which existing risks are reduced, the time required to reduce risks at the Site and to attain cleanup standards, any on-site and off-site risks resulting from implementing the alternative, and improvement of the overall environmental quality.”

4.1.2 Compliance with Cleanup Standards

Cleanup standards are intended to provide for a uniform, statewide approach to site cleanups. However, WAC 173-340-700 (4)(a) states “The actual degree of cleanup may vary from site to site and will be determined by the cleanup action alternative selected under WAC 173-340-350 through 390”. Two primary components of the standards must be established for each site. These components are cleanup levels (CULs) and points of compliance (POC). A third component of the standards is compliance with all applicable state and federal laws.

4.1.3 Compliance with Applicable State and Federal Laws

For the Site, typical construction applications and permits are likely to be necessary. Other potentially applicable regulatory requirements for the Site have been discussed in Section 2.6 of this report.

4.1.4 Provision for Compliance Monitoring

Compliance monitoring may consist of many different sampling, analysis, and evaluation activities in all environmental media. However, there are three distinct types of compliance monitoring. These are described below:

• Protection Monitoring - Human health and the environment are adequately protected during the construction, operation, and maintenance of the selected remediation options.

• Performance Monitoring - Confirms the selected remediation options have attained the cleanup standards. The performance monitoring includes provision for initiating contingency actions if needed.

• Confirmational Monitoring - Confirms the long-term effectiveness of the selected remediation options once cleanup standards have been attained.


4.1.5 Restoration Time Frame

The MTCA regulations require selected remediation options to include permanent solutions to the maximum extent practicable, provide for a reasonable restoration time frame, and consider public concerns, given consideration of the following factors:

• Potential risks posed by the Site to human health and the environment

• Practicability of achieving a shorter restoration time frame; for purposes of this review, time frame is interpreted to mean the time period required for achievement of cleanup standards

• Current use of the Site, surrounding areas, and associated resources that are, or may be, affected by releases from the Site

• Potential future use of the Site, surrounding area, and associated resources that are, or may be, affected by releases from the Site

• Availability of alternative water supplies

• Likely effectiveness and reliability of institutional controls

• Ability to control and monitor migration of hazardous substances from the Site

• Toxicity of the hazardous substances at the Site

• Natural processes which reduce concentrations of hazardous substances and have been documented to occur at the site or under similar site conditions

4.2 Disproportionate Cost Analysis (DCA) Ranking Criteria

As discussed above, Table 5 identifies the alternatives that have been retained per the initial review, which presents consideration of the threshold criteria. The MTCA regulations also identify seven additional criteria necessary to rank each alternative, from least to most permanent. Specifically, each alternative needs to be ranked using weighting factors for the additional criteria. Also considered on Table 5, these criteria are listed and further discussed below.

• Protectiveness

• Permanence

• Cost

• Long-term effectiveness

• Management of short-term risks


• Technical and administrative implementability

• Consideration of public concerns

4.2.1 Protectiveness

Protectiveness is described as the “overall protection of human health and environment.” Specifically, this review considers “the degree to which existing risks are reduced, time required to reduce risk at the facility and attain cleanup standards, on-site and off-site risks resulting from implementing the alternative, and improvement of the overall environmental quality.”

4.2.2 Permanence

The MTCA regulations state a preference for permanent solutions, to the maximum extent practicable. This is defined as the degree to which alternative reduces toxicity, mobility, and volume, including the adequacy of the alternative in destroying the hazardous substances, the reduction or elimination of continued releases, and the degree of irreversibility of the treatment process. MTCA-specified cleanup technologies, in order of decreasing preference, are presented below.

• Reuse or recycling

• Destruction or detoxification

• Immobilization or solidification

• On-site or off-site disposal in an engineered, lined and monitored facility

• On-site isolation or containment with attendant engineering controls

• Institutional controls and monitoring

4.2.3 Costs

Most feasibility studies assume that the reviewed alternatives will be used individually in order to address the site contaminants. However, this Site presents geological and land-use complications that limit the effectiveness of only one alternative. For comparison purposes, the estimated costs for alternatives 1 through 6 assume that each alternative will be individually used for the entire Site. Alternative 7, however, is a combination of several alternatives, each targeting specific areas of the Site.


Each retained alternative has been reviewed for possible duration period and remediation costs. If the permanent-solution rankings for the reviewed alternatives are similar, MTCA allows for the use of a lower-cost alternative. Specifically, the anticipated costs are compared against the benefits of the alternatives, allowing for the selection of the alternative whose incremental costs are not disproportionate to the incremental benefits.

Budgeting estimates are based on G-Logics experience at similar sites, but are subject to numerous assumptions. These estimates are approximate and only should be used for FS comparison of the alternatives, not for construction purposes. Additionally, order-of-magnitude costs have been used rather than detailed cost estimates. The presentation of these costs is intended to allow for a comparison of the cost of one alternative relative to the other alternatives for the stated efforts. These costs include typical expenses for design, equipment, operation, monitoring, maintenance, repairs, and preparation of required documentation. For the active-remediation alternatives, estimates assume a period of five years (Table 5).

The selected and Ecology-approved alternative(s) will be described in more detail in a Cleanup Action Plan. Estimated costs would be refined after selection of an alternative and the identification of a specific workscope/timeline. The refined costs would be presented in with an engineering-design report for the selected alternative.

4.2.4 Long-Term Effectiveness

This criterion requires a review of the degree of certainty of success, reliability of the alternative during the period of time that hazardous substances are expected to remain on-site at concentrations that exceed cleanup levels, the magnitude of the residual risk with the alternative in place, and the effectiveness of controls required to manage remaining wastes.

4.2.5 Short-Term Risks

This criterion considers the risk to human health and environment during construction and implementation.

4.2.6 Implementability

This criterion considers whether the alternative is technically possible given site access and restrictions.


4.2.7 Public Consideration

A review also must be completed to consider if the community, including individuals, community groups, tribes, state and federal agencies, have concerns regarding the cleanup alternative.

5.0 REMEDY SELECTIONS

Each of the seven retained CAAs has been reviewed for compliance with the threshold and other requirements and has been ranked from least to most permanent. Estimated costs also have been identified for the seven alternatives. Our review of this information has been summarized in Table 5. Information in this table is based on our professional experience and our ranking values on a scale of one to ten, adjusted by the weighting-factor calculations. The cumulative-ranking value is then compared against the estimated remediation costs. The more complicated alternatives are estimated on Tables 6 through 10. This Disproportionate Cost Analysis also is presented graphically as Graph 1. The findings of this review are summarized below.

This Site presents several complicating elements, specifically extensive petroleum contamination on the subject Property and contaminants extending toward residential neighborhoods to the southwest. The contamination conditions and the subsurface geology impede the ability to select only one alternative for the entire Site. Additionally, it is our opinion that selection of only one alternative would not meet MTCA requirements, would not be feasible, and would not be cost-effective.

With the FS and DCA findings, alternative 7 has been identified for use. This alternative includes components of several other alternatives, which would be used in select areas of the Site. These combined alternatives, specifically Soil Excavation, AS/SVE, and MNA, support and complement one another. Bioremediation also will occur with the use of AS/SVE equipment, and can be enhanced with the addition of supplements. This approach meets the requirements identified in WAC 173-340-370. The suggested use and placement of the individual alternatives are further described below and illustrated on Figure 13.

5.1 Excavation Areas

Soil excavation and off-site disposal are recommended for the areas with elevated concentrations of contaminants. These areas are located beneath the source-area on the


Property. Excavation in this area would likely extend down to the water table, and would include the partial removal of the silt/clay layer. The benefits of excavation include rapid and certain removal of highly-contaminated media, which can be readily documented with confirmation sampling. Shoring and slope-stability measures are not considered to be needed, nor will excavation dewatering. Prior to backfilling and compaction, treatment piping can be installed on the western wall of the excavated area, supporting one or both of the In-situ treatment methods described in Sections 5.2 and 5.3 below.

5.2 AS and SVE Areas

Beyond and beneath the excavated area, to the southwest toward Kincaid Avenue and Academy Street, AS and SVE systems can be installed to remediate the contaminants in these areas. The SVE systems also can be positioned to remove soil-vapor contaminants, helping to mitigate vapor-intrusion concerns. Installed AS and SVE lines can be directed to one or more equipment-storage buildings, given further system evaluations and permissions. The equipment can be modeled and positioned in a way that promotes potential redevelopment of the Property or areas surrounding the Property. Performance and confirmation sampling can be conducted during the operation of the system to document that they are operating as intended and that remedial-action objectives can be achieved.

5.3 Bioremediation Areas

Bioremediation will be enhanced coincidentally with the use of the AS and SVE systems. Groundwater monitoring can include a review of geochemical properties, used to assess if adequate oxygen is present and if trace nutrients are required. Except for possible nutrients-infiltration lines or injection points, no additional treatment systems are anticipated to be necessary for bioremediation to be added as a secondary component of continued treatment of soil and groundwater.

5.4 MNA Areas

When treatment systems are found to be less effective in reducing contaminant concentrations (asymptotic conditions), and where residual concentrations are shown not to present an unacceptable threat to human health or the environment, the active remediation systems will be discontinued and removed. At this point in time, MNA would be used to document protectiveness for all media and to provide evidence that natural biodegradation continues for all areas of the Site. If monitoring demonstrates that remedial efforts for the


Site have not met the identified cleanup levels at their respective points of compliance, further treatment, identification of remediation levels, additional MNA, and/or the recording of environmental covenants can be considered.

6.0 LIMITATIONS

This document was prepared in accordance with generally-accepted professional practices, for similar services, locations, and at the time the work was performed. Our services were not intended to identify all environmental problems, do not eliminate all risk, and were limited to the information described above.

This report is prepared for the sole use of our client. The scope of services performed may not be appropriate for the needs of other users. Re-use of this document or the findings, conclusions, or recommendations presented herein, are at the sole risk of said user(s). Non-compliance with any of these requirements will release G-Logics from any liability resulting from the use of this report by any unauthorized party. G-Logics also does not warrant or guarantee the presented budgeting estimates, especially if others conduct the remediation work.

Budgeting estimates only should be used for comparison of the alternatives, for decision-making considerations, as described in Section 4.2.3 of this report. Estimates of remediation costs are subject to numerous unknowns, including subsurface conditions, planned remediation methods, contractor capabilities, discovery of additional contaminants, required schedules, project financing, and the ultimate determination of “how clean is clean”.

Other activities that are not specifically described in this document are excluded and are therefore not part of our services or the provided budgeting estimates. Our understanding of the Property also may change as new data becomes available or during additional site exploration, remediation, and/or redevelopment.

The identified site cleanup approach is intended to support regulatory closure (a No Further Action Determination) for the subject site through the Voluntary Cleanup Program of Ecology. However, we cannot explicitly or implicitly guarantee that regulatory closure by Ecology will result after the completion of this program of services.

No warranty, either express or implied, is made.

FIGURES

Site Location Maps Figure

101-0620-K-F1.vsdProject File:

Mapping Reference: Delorme and Google Maps

Site

Sumner, Washington

Sumner Towing

810 Alder Avenue

Site

Puyallup River

White R

iver

Property

Alder Street

Photo Circa 2007

VP-3

VP-5

VP-4

Figure

2Mapping Reference: PLS Inc., Google Maps, Exploration Reports, G-Logics Site Visits.

01-0

620-K

-F2

.vsd

Pro

ject

File:

Sumner, Washington

Sumner TowingSite Diagram, Exploration and Cross-Section Locations

810 Alder AvenueNote: This figure contains information in color. Black & white photocopies may not be suitable for review.

Approximate Drawing Scale: 1" = 60'

0 ft. 36 ft. 60 ft. 120 ft.

Legend

Property Boundary

Former UST Location

G-Logics Permanent Vapor

Point

VW-6

MW-4

MW-10

MW-2

MW-5

MW-7

MW-8

MW-3

MW-4

MW-1

Frontier Bank

MW-12

MW-11

MW-9

MW-13

MW-14

MW-15

MW-17

MW-16

VW-2

VW-1

VW-3

VW-5

VW-4

Former Gas Station

Building Location

Bore 2

Bore 4

Bore 5

Bore 6

Bore 7

B-1

B-3

B-4

B-6B-2

Bore 1

Bore 6 Soil Boring (Saltbush

Environmental, November

2000)

Soil Boring (EAI, March 2000)

GL-10

GL-11

GL-12

GL-9

GL-9 Soil Boring (G-Logics, April

2010)

Soil Sample (EnCo 2007)

B-5

MW-6

MW-18

MW-20

MW-21

MW-23

MW-22

MW-19

G-Logics Groundwater

Monitoring Well

VP-8

VP-7

Red Apple

Residential House

(Approximate

Location)

Frontier Bank

Academy St. Academy St.

Kin

caid

Ave

.

Ch

erry

Ave

.

Ald

er S

t.

VP-6

VP-1

VP-2

VP-6 G-Logics Temporary Vapor

Point

?

?

MW-25

MW-26

MW-27

GL-16

GL-15

GL-14

MW-28

GL-13

Maple Street

H2O

H2O

H2O H2O

H2

OH

2O

H2

O

SD

UGP

UG

P

UG

P

SD SD SD SD SD SDSDSDSDSD

SD

T TPM TPM TPM TPM

SD

Bore 3

SD

SD

S

UG

PU

GP

B

B’

C

C’

A

A’

Kin

caid

Ave

.

S

SSSS

SSSS

GAS

H2

O

GA

S

GAS

H2

O

H2O

H2O

H2O

H2O

H2O

H2O

S

SSSSP-05P-04

P-03

P-01

P-02

MW-24

P-06

P-07P-08

SS

GAS

H2O

SD

UGP

S

T

Natural Gas Line

Sanitary Sewer

Storm Sewer

Water Line

Underground Power

Catch Basin

Gas Valve

Storm Drain Manhole

Storm Drain Manhole

TPM Telephone Line Paint Marks

Sanitary Sewer Manhole

*All utilities understood not to exceed a depth of 6 feet.

1A

B-4

Soil Boring (Rothman &

Associates, 2015)P-02

Understood Site Boundary

Figure

3Mapping Reference: Google Maps and EDR.

Sumner Towing

Sumner, Washington

810 Alder Avenue

Site Diagram, Potential Historical Sources of Contamination01-0

620

-K-F

3.v

sd

Pro

ject

File:

Note: This figure contains information in color. Black & white photocopies may not be suitable for review.


0 ft. 60 ft. 100 ft. 200 ft.

Legend

Gas and Oil 1944-53

Auto Repair, Gas and Oil

1944-53

Auto Repair/Gas

and Oil 1944

280 Gallon UST (1919-1927)

Auto Repair (1919)

Auto Service Station1944-53

CSCSLLUST

Grease Building

1944

Subject Property Sumner Towing, 810 Alder Avenue

Property A: Fire Station, 1102 Maple Street

Property B: Gas Station, 904 Alder Avenue

Property C: Gas Station, 906 Kincaid Avenue

Property D: Gas Station, 914 Kincaid Avenue

Property E: Grease Building, 921 Alder Avenue

Property F: Auto-repair shop, no address given on Sanborn mapA

D

CB

E

F

A Property Identifier

2 USTs removed

(1990)

Subject Property

G

Property G: Auto-Service Station, 922 Ryan Avenue

South End Auto

Wrecking

H

Sounder SquareICSCSLLUST

Property H: South End Auto Wrecking, 905 Kincaid Avenue

Property I: Sounder Square LLC, 926 Main Street

VP-3

VP-5

VP-4

VP-2

Figure


01-0

620-K

-F4 S

oil G

RO

.vsd

Pro

ject

File:

Sumner, Washington

Sumner TowingSite Diagram, GRO Concentrations in Soil

810 Alder Avenue



0 ft. 36 ft. 60 ft. 120 ft.

MW-10

MW-2

MW-5

MW-7

MW-8

MW-3

MW-4

MW-1

MW-12

MW-11

MW-9

MW-13

MW-14

MW-15

MW-17

VW-2

VW-1

VW-3

VW-5

VW-4

GL-10

GL-11

GL-12

GL-9

MW-6

MW-18

MW-20

MW-21

MW-23

MW-22

VP-8

VP-7

Red Apple

Frontier Bank


Kin

caid

Ave

.

Ch

erry

Ave

.

Ald

er S

t.

VP-6

VP-1

P-05P-04

P-03

P-01 P-02

Legend

G-Logics Vapor PointVW-6

MW-4

GL-9 Soil Boring (G-Logics,

April 2010)


Monitoring Well


Associates, 2015)

Property Boundary

Former UST

Location

Inferred gasoline

concentrations in soil

greater than 1,000 mg/kg

Inferred gasoline concentrations in

soil greater than MTCA Cleanup

Levels (30 mg/kg)

Inferred gasoline

concentrations in soil

greater than 100 mg/kg

Inferred gasoline concentrations in soil

detected, less than MTCA Cleanup

Levels (30 mg/kg)

P-02

Former Gas Station

Building (Approximate

Location)

Structures

(Approximate Location)

?

?

?

?

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

GL-14

MW-28

GL-13

MW-16

S

SSSS

SSSS


SD

T TPM TPM TPM TPM

H2

O

GAS

GA

S

GAS

H2

O

H2O

H2O

H2O

H2O

H2O

H2O

S

P-06

P-07P-08

MW-19

SS

GAS

H2O

SD

UGP

S

T

Natural Gas Line

Sanitary Sewer

Storm Sewer

Water Line

Underground Power

Catch Basin

Gas Valve

Storm Drain Manhole

Storm Drain Manhole




SD


Point

?

VP-5

VP-4

VP-2

VP-3

Figure5

Mapping Reference: PLS Inc., Google Maps, Exploration Reports, G-Logics Site Visits.

01-0

620-

K-F

5 So

il B

enz.

vsd

Proj

ect F

ile:

Sumner, Washington

Sumner TowingSite Diagram, Benzene Concentrations in Soil

810 Alder Avenue



0 ft. 36 ft. 60 ft. 120 ft.

MW-10

MW-2

MW-5

MW-7

MW-8

MW-3

MW-4

MW-1

MW-12

MW-11

MW-9

MW-13

MW-14

MW-15

MW-17

MW-16

VW-2

VW-1

VW-3

VW-5

VW-4

GL-10

GL-11

GL-12

GL-9

MW-6

MW-18

MW-20

MW-21

MW-23

MW-22

VP-8

VP-7


Kinc

aid

A ve .

C he r

ry A

ve.

Alde

r St.

VP-6

VP-1

P-04P-03

P-01 P-02

Legend

Property Boundary

Former UST Location


MW-4

GL-9 Soil Boring (G-Logics, April 2010)

G-Logics Groundwater Monitoring Well

Inferred benzene concentrations in soil greater than 10 mg/kg

Inferred benzene concentrations in soil greater than MTCA Cleanup Levels (0.03 mg/kg)

Inferred benzene concentrations in soil greater than 1 mg/kg

Inferred benzene concentrations in soil detected, less than MTCA Cleanup Levels (0.03 mg/kg)

Soil Boring (Rothman & Associates, 2015)

P-02

Former Gas Station Building (Approximate Location)

Structures(Approximate Location)

?

?

?

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

GL-14

MW-28

GL-13


SD

T TPM TPM TPM TPMS

SSSS

SSSS

MW-19

P-05

H2O

GAS

GAS

GAS

H2O

H2O

H2O

H2O

H2O

H2O

H2O

S

SSSS

P-06

P-07P-08

SS

GAS

H2OSD

UGP

S

T

Natural Gas Line

Sanitary Sewer

Storm SewerWater LineUnderground Power

Catch Basin

Gas Valve

Storm Drain ManholeStorm Drain Manhole




SD

?

VP-6 G-Logics Temporary Vapor Point

VP-3

VP-4

VP-5

Figure


01-0

620-K

-F6 G

W G

RO

.vsd

Pro

ject

File:

Sumner, Washington

Sumner TowingSite Diagram, GRO Concentrations in Groundwater

810 Alder Avenue



0 ft. 36 ft. 60 ft. 120 ft.

MW-10

MW-2

MW-5

MW-7

MW-8

MW-3

MW-4

MW-1

MW-12

MW-11

MW-9

MW-13

MW-14

MW-15

MW-17

MW-16

VW-2

VW-1

VW-3

VW-5

VW-4

GL-10

GL-11

GL-12

GL-9

MW-6

MW-18

MW-20

MW-21

MW-23

MW-22

VP-8

VP-7

Red Apple

Frontier Bank


Kin

caid

Ave

.

Ch

erry

Ave

.

Ald

er S

t.

VP-6

VP-1

VP-2

?

P-05P-04P-03

P-01 P-02

Legend

Property Boundary

Former UST Location


MW-4


2010)


Monitoring Well


groundwater greater than 100,000 ug/L


groundwater greater than MTCA

Cleanup Levels (800 ug/L)


groundwater greater than 10,000 ug/L


groundwater detected, less than MTCA



Associates, 2015)

P-02

Former Gas Station Building


Structures(Approximate Location)

?

?

?

?

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

GL-14

MW-28

GL-13

MW-19


SD

T TPM TPM TPM TPMS

SSSS

SSSS

H2

O

GAS

GA

S

GAS

H2

O

H2O

H2O

H2O

H2O

H2O

H2O

S

SSSS

P-06

P-07P-08

SS

GAS

H2O

SD

UGP

S

T

Natural Gas Line

Sanitary Sewer

Storm Sewer

Water Line

Underground Power

Catch Basin

Gas Valve

Storm Drain Manhole

Storm Drain Manhole



*All utilities understood

not to exceed a depth of 6

feet.

SD

?


Point

?

Figure


01-0

620-K

-F7 G

W B

en

z.v

sd

Pro

ject

File:

Sumner, Washington

Sumner TowingSite Diagram, Benzene Concentrations in Groundwater

810 Alder Avenue



0 ft. 36 ft. 60 ft. 120 ft.

MW-10

MW-2

MW-5

MW-7

MW-8

MW-3

MW-4

MW-1

MW-12

MW-11

MW-9

MW-13

MW-14

MW-15

MW-17

MW-16

VW-2

VW-1

VW-3

VW-5

VW-4

GL-10

GL-11

GL-12

GL-9

MW-6

MW-18

MW-20

MW-21

MW-23

MW-22

VP-5

VP-8

VP-7

Red Apple

VP-4

Frontier Bank


Kin

caid

Ave

.

Ch

erry

Ave

.

Ald

er S

t.

VP-3

VP-6

VP-1

VP-2

?

P-05P-04

P-03

P-01 P-02

Legend

Property Boundary

Former UST Location


MW-4


2010)

G-Logics Groundwater Monitoring

Well

Inferred benzene concentrations in

groundwater greater than 1000 ug/L

Inferred benzene concentrations in groundwater

greater than MTCA Cleanup Levels (5 ug/L)


groundwater greater than 100 ug/L


groundwater detected, less than MTCA



Associates, 2015)P-02

Former Gas Station Building


Structures


?

?

?

?

?

?

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

GL-14

MW-28

GL-13


SD

T TPM TPM TPM TPMS

SSSS

SSSS

H2

O

GAS

GA

S

GAS

H2

O

H2O

H2O

H2O

H2O

H2O

H2O

S

MW-19

P-06

P-07P-08

SS

GAS

H2O

SD

UGP

S

T

Natural Gas Line

Sanitary Sewer

Storm Sewer

Water Line

Underground Power

Catch Basin

Gas Valve

Storm Drain Manhole

Storm Drain Manhole




SD


Point

Frontier Bank

Figure


01-0

620-K

-F8 G

W C

on

tou

r.vsd

Pro

ject

File:

Sumner, Washington

Sumner TowingSite Diagram, Groundwater Contours 5/25/2016

810 Alder Avenue



0 ft. 36 ft. 60 ft. 120 ft.

Legend

Property Boundary

Former UST

Location

MW-10

57.59'

MW-2

59.52'

MW-5

57.54'

MW-7

59.76'

MW-8

57.49'

MW-3*

MW-4

57.48

MW-1

57.54'

Frontier

Bank

MW-12

57.12'

MW-11

57.42'

MW-9

57.36

'

MW-13

57.38'

MW-14

56.82'

MW-17

52.68'

MW-16

56.48'

Former Gas Station

Building Location

MW-6

59.82'

MW-18

59.47'

MW-20

52.85'

MW-21

55.89'

MW-23

52.41'

MW-22

52.38'

MW-19

56.45'

Red Apple

Residential House

(Approximate

Location)

Academy St.

Kin

caid

Ave.

Ch

err

y A

ve.

Ald

er

St.

MW-25

57.20'MW-24

56.82'

MW-26

56.76'

MW-28

56.56'

MW-4G-Logics Groundwater

Monitoring Well,* denotes

destroyed well (Elev. Ft.)

50' Groundwater Elevation

Contour (feet above mean

sea level)

51.61'

52.5'

53'

55' 56'

56.5'

57'

57.5'

59'58'

54'

MW-15

53.35'

MW-27

56.77'


Sumner Towing

Sumner, Washington

810 Alder Avenue

Conceptual Site ModelFigure

9

01-0

620-K

-F9 C

SM

.vs

dP

roje

ct

File:

Not to Scale

Former Sumner TowingResidence

Groundwater Flow Inferred to the Southwest

Groundwater Table LNAPL (Including Smear Zone/Residual

and Free Phase)

Dissolved Gasoline/BTEX Plume

West EastSoil-Gas Migration

Volatilization of Gasoline/BTEX into Soil Gas

Utility Corridor

Utility Lines

Dispersion and Dilution

Alder StreetKincaid Avenue

ML

SP

Figure

10Sumner Towing

Sumner, Washington

810 Alder Avenue

Cross Section A-A’ GRO Concentrations in Soil and Groundwater Co

py (

1)

of

01-0

620-K

-F10 X

S-A

.vsd

Pro

ject

File:

Important Note: This figure contains information in color. Black & white photocopies may not be suitable for review.

Mapping Reference: King County iMap, On-Site Measurements.

A’West

East

Property Boundary

0 ft. 30 ft. 50 ft. 100 ft.

Approximate Vertical Drawing Scale: 1" = 10'Approximate Drawing Scale: 1" = 50'

MW

-10

MW

-6

MW

-3*

MW

-1

A

Property Boundary

SM

SM

Kincaid Ave.

SM

SP

nd

411

nd

40

178

30

nd

nd

nd

nd

15

22

nd

15

35

nd

nd

25,300

ML

MW

-16

This image represents an interpretation of available data. Site interpretations may change with additional measurements and/or data points.

Groundwater analytical data is summarized in Table 1. Groundwater concentrations presented in this cross-section are from the latest available sampling event for each location. Groundwater concentrations are presented in µg/L.

Soil analytical data and collection dates are summarized in Table 2. Soil concentrations are presented in mg/kg.

11

70'

65'

60'

55'

50'

70'

65'

60'

55'

50'

45' 45'nd

GL-12

MW-20

MW-21

MW-23

A

A’

MW-16

MW-10

MW-11

MW-9

GL-9

MW-5

MW-4

MW-3

MW-2

MW-6

MW-7

GL-11

MW-8

GL-10

MW-1

Legend

Approximate Water Table Elevation (Based on 5/2016 Measurements)

Groundwater-Monitoring Well

Soil Boring (Saltbush 2000)

Approximate Extent of GRO Contamination above cleanup levels(Soil and Groundwater)

Approximate UST Excavation Area

MW

-23

nd

nd

ML SM

ML

Silt

Silty Sand

Well-Sorted Sand

See boring logs for full description

Kin

caid

Ave

.

SP

SM

ML

Greater than 100,000 ug/kg

Greater than MTCA Cleanup Levels (800 ug/kg)


Detected, less than MTCA Cleanup Levels (800 ug/kg)

Soil SampleGRO concentrationsless than 30 mg/kg

Soil SampleGRO concentrations greater than 30 mg/kg

Groundwater SampleGRO concentrationsgreater than 1,000 µg/L

Groundwater SampleGRO concentrations less than 1,000 µg/L

Well Screen Interval

Boring/Monitoring Well

Inferred gasoline concentrations in groundwater

Approximate Elevation Above Sea Level (Feet)

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

MW-19

P-05P-04

P-03

P-01

P-02

Soil Boring (Rothman & Associates 2015)

MW

-26

MW-3* Well Destroyed

26,600

23,800

69,7002,530

40' 40'

Cross Sections B and C intersect

B

B’

C

C’

B

B’Cross Section Line

GL-14

GL-13

GL-13

nd

nd

nd

nd

GRO Groundwater Plume

MW-2

MW-5

MW-7

MW-8

MW-3*

MW

-4

MW

-1

MW

-9

Bore 2

Bore

3

Bore 4

Bore

6

Bore 7

B-1

B-3

B-4

B-6

B-2Bore 1

GL-10

GL-11

GL-12

GL-9

B-5

MW-6

?

B B’

8

7

3

17

16

15

21

20

19

18

23

11

10

12

9

41

5

14

22

13

6

2A

, 2B

, 2C2

4

B-4

8


Sumner Towing

Sumner, Washington

810 Alder Avenue

Cross Section B-B’ GRO Concentrations in Soil and Groundwater Figure

11

01-0

620-K

-F1

1 X

S-B

.vsd

Pro

ject

File:


0 ft. 12 ft. 20 ft. 40 ft.Note: This figure contains information in color. Black & white photocopies may not be suitable for review.

Property BoundaryProperty Boundary

B

South NorthGL-10

MW-8

13B-2

2214

GL-12

Bore-1

17

16

15

21 19

6

7

20

nd

10

nd4,100

24 nd

nd

34

745

2,800

25

5,000

2,500360nd

36

nd

Approximate Vertical Drawing Scale: 1"= 6.5'

SMSM

MLML ML

SPSP

19

55

6915,000

4,400

7,900

12,0004,200

11,000

400

22

B’7

nd

78

26

Ap

pro

xim

ate

Elev

atio

n A

bo

ve S

ea L

evel

(Fe

et)

Ap

pro

xim

ate

Elev

atio

n A

bo

ve S

ea L

evel

(Fe

et)

GL-16GL-15

GL-15

GL-16

nd

22,700

12

nd

21,700

Legend















Silt

Silty Sand

Well-Sorted Sand


SP

SM

ML

15,000

30,100

30,100

B


Soil Boring (Saltbush, 2000)

Soil Boring (G-Logics, 2010)

Soil Sample (EnCo 2007)

G-Logics Groundwater Monitoring Well

MW-4

GL-9

1A

Bore 6

B-4 Soil Boring (EAI, 2000)






40'40'

70'

65'

60'

55'

50'

70'

65'

60'

55'

50'

45' 45'

Figure

12Note: This figure contains information in color. Black & white photocopies may not be suitable for review.


0 ft. 18 ft. 30 ft. 60 ft.

Legend


G-Logics Borings

Silt

Silty Sand

Well-Sorted Sand


SP

SM

ML







MW-2

MW-5

MW-3

MW-4

MW-1

MW-12

MW-9

GL-10

GL-12

GL-9

MW-6

MW-25

MW-24

GL-16

GL-15

C C’

P-05

P-04

P-03

P-01

P-02

Soil Boring (Rothman & Associates, 2015)

MW-7

GL-11

MW-8

MW-10

MW-11

MW

-11

MW

-4

MW

-3*

MW

-6

ML

ML ML

SM SM SM

SP

SM

SP

GL-16

GL-15

GL-12

P-01

P-04

Sumner Towing

Sumner, Washington

810 Alder Avenue

Cross Section C-C’ GRO Concentrations in Groundwater and Soil01-0

620-K

-F12 X

S-C

.vsd

Pro

ject

File:



SMnd

9,270

114,00023,800


nd

nd

nd

nd

nd

22,700

12

nd

23

23nd

38,800

30,100

15,000

745

34

nd

40

40

30

nd

nd

nd

nd

nd

15

22








B


nd

Approximate Vertical Drawing Scale: 1" = 10'

C C’

South North





Figure

13Sumner Towing

Sumner, Washington

810 Alder Avenue

Conceptual Layout for Proposed Remedial Alternatives 01-0

620-K

-F13 X

S-A

.vs

dP

roje

ct

File:

Important Note: This figure contains information in color. Black & white photocopies may not be suitable for review.


0 ft. 30 ft. 50 ft. 100 ft.

Approximate Vertical Drawing Scale: 1" = 10'Approximate Drawing Scale: 1" = 50'


GL-12

MW-20

MW-21

MW-23

A

A’

MW-16

MW-10

MW-11 GL-9

MW-5

MW-4

MW-3

MW-2

MW-6

MW-7

GL-11

MW-8

GL-10

MW-1

Kin

caid

Ave

.

MW-25

MW-24

MW-26

MW-27

GL-16

GL-15

P-05P-04

P-03

P-01

P-02

GL-14

GL-13

ML

SP

A’

EastProperty Boundary

MW

-10

MW

-6

MW

-3*

MW

-1

Property Boundary

SM

SM

Kincaid Ave.

SM

SP

nd

ML

MW

-16

60'

55'

50'

70'

65'

60'

55'

50'

45' 45'

MW

-23

ML SM

ML

MW

-26

GL-13

Silt

Silty Sand

Well-Sorted Sand


SP

SM

ML

MW-12 MW-13MW-17

Academy St.

Area of NMA Area of AS/SVE

Area of ExcavationMW-9

`

A

65'

70'

Legend


Soil Boring (Saltbush 2000)


G-Logics Soil Vapor Probe, GRO concentrations in µg/m³


West

Soil Boring (Rothman & Associates 2015)

Cross Section Line

Area of Proposed Source Excavation

MW-19

A

A’

Area of Proposed AS/SVE and/or Bioremediation

Area of Proposed MNA

TABLES

TABLE 1Soil Sample Analyses Summary (1)Sumner Towing, Sumner, WA

Exploration Location Sample Number Depth (feet) PID Ben

zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

EAI

B-1 B-1 @ 7 7 0.33 3.2 1.60 9.20 --- nd --- nd nd --- --- --- --- --- ---

B-2 B-2 @ 7 7-8" 0.33 2.6 0.65 1.1 --- nd --- nd nd --- --- --- --- --- ---

B-3 B-3 @ 10 10-11" 4.2 9.8 2.1 10.0 55 --- --- --- nd --- --- --- --- --- ---

B-4 B-4 @ 10 10 1.0 6.0 1.0 6.5 25 --- --- --- --- --- --- --- --- --- ---

B-5 B-5 @ 7 7 nd nd nd nd nd --- --- --- nd --- --- --- --- --- ---

B-6 B-6 @ 7 7 nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

Saltbush

Bore 1 0-1 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 1 @ 5-6 5 >2,500 6.1 >50 13 >50 2,800 --- --- --- --- --- --- --- --- --- ---

5-7 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7-9 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

13-15 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

15-17 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 1 @ 18-20 18 >2,500 6.5 >50 13 >50 2,800 --- --- --- --- --- --- --- --- --- ---

19-21 780 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 2 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore2 @ 2-3 2 108 nd nd nd 1.1 21 --- --- --- --- --- --- --- --- --- ---

3-5 51 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5-7 500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7-9 250 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore2 @ 12 12 131 1.1 1.9 0.42 1.9 25 --- --- --- --- --- --- --- --- --- ---

MTCA Cleanup Level (2) 0.03 7 6 9 100(a)/30(b) 2,000 4,000 2,000 250 NA 2.00 0.005 11 0.1 0.1

March, 2000

November, 2000

01-0620-K T1-Soil.xlsx 1 of 14



zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

Bore 3 0-1 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3-5 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5-7 35 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore3 @ 8 8 50 nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

Bore 3 @ 8 Dup 8 --- nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

9-11 14 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 3 @ 13-14 13 --- nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

Bore 3 @ 13-14 Dup 13 --- nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

15-17 18.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 11.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3-5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5-7 1,199 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 @ 8-9 8 936 1.1 2.7 0.68 3.5 43 --- --- --- --- --- --- --- --- --- ---

Bore 4 @ 10 10 >2,500 >50 >50 >50 >50 >5,000 --- --- --- --- --- --- --- --- --- ---

11-13 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

13-15 2,300 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

15-17 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

17-19 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 @ 20 20 >2,500 0.26 0.84 0.08 0.64 nd --- --- --- --- --- --- --- --- --- ---

Bore 5 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 8.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 5 @ 4-6 4 10.9 nd nd nd nd nd --- --- --- --- --- --- --- --- --- ---

5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7-9 10.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

14-15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

Bore 5 Cont. Bore 5 @ 16 16 >2,500 >50 >50 >50 >50 >5,000 --- --- --- --- --- --- --- --- --- ---

17-19 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

19-21 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 6 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 19.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3-5 28.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7-9 18.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 6 @ 15 15 557 0.83 1.2 0.23 0.93 27 --- --- --- --- --- --- --- --- --- ---

Bore 6 @ 18 18 >2,500 >50 >50 >50 >50 >5,000 --- --- --- --- --- --- --- --- --- ---

Bore 7* 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

1-3 43 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3-5 10.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7-9 168 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 389 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

13-15 148 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

15-17 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

EnCo

1 1A 11 --- 7 21 4 26 280 1,100x --- <250 --- --- --- --- --- --- ---

1B 15.5 --- 20 47 9 47 450 180x --- <250 4.84 --- --- <0.05 <0.05 <0.05 <0.01

2 2A 12 --- <0.02 <0.03 <0.02 <0.08 <2 <50 --- <250 --- --- --- --- --- --- ---

2B 14 --- <0.03 <0.05 <0.05 <0.1 <2 <50 --- <250 4.69 13.8 <1 <0.05 <0.05 <0.05 <0.01

2C 16 --- 160 1,200E 310 1,600 15,000 7,100x --- <250 --- --- --- --- --- --- ---


August 22, 2007




zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

3 3A 9 --- 77 850 220 1,400 9,000 (4) 3,000x --- <250 7.32 9.33 <1 <0.05 <0.05 <0.05 <0.01

3B 13 --- 160 790 140 750 5,700 5,300x --- <250 --- --- --- --- --- --- ---

3C 15 --- 60 530 150 850 6,800 3,000x --- <250 --- --- --- --- --- --- ---

3D 16 --- 160 1,200E 310 2,300 20,000 3,000x --- <250 --- --- --- --- --- --- ---

4 4A 2 --- <0.03 <0.05 <0.05 <0.1 <2 9,000 --- 19,000 40.2 --- --- <0.05 <0.05 <0.05 0.8714B 5 --- 0.49 2.9 1.3 8.0 26 <50 --- <250 2.36 --- --- <0.05 <0.05 <0.05 <0.01

4C 6.5 --- 0.98 6.5 1.9 11 78 81x --- <250 3.33 --- --- <0.05 <0.05 <0.05 <0.01

5 5A 6.5 --- 0.71 3.5 1.4 8.0 49 <50 --- <250 2.40 --- --- <0.05 <0.05 <0.05 <0.01

5B 8.5 --- 12 150 58 320 2,400 9,200x --- <250 --- --- --- --- --- --- ---

6 6A 9.5 --- 0.15 0.14 0.10 4.6 69 <50 --- <250 4.53 --- --- <0.05 <0.05 <0.05 <0.1

7 7A 9.5 --- 23 710E 370 2,000E 15000 (4) 3,900x --- <250 16.3 --- --- <5 <5 <5 <0.1

8 8A 9.5 --- <2 93 120 690 4,400 1,400x --- <250 7.86 --- --- <0.05 <0.05 <0.05 <0.1

9 9A 2 --- 6.7 9.1 0.49 1.5 41 <50 --- <250 10.8 --- --- --- --- --- ---

10 10A 2 --- <0.03 <0.03 <0.03 <0.12 <3 <50 --- <250 22.1 --- --- --- --- --- ---

11 11A 2 --- <0.03 <0.03 <0.03 <0.12 <3 <50 --- <250 --- --- --- --- --- --- ---

12 12A 2 --- <0.02 0.05 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

13 13A 3.5 --- <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 66.6 --- --- <0.05 <0.05 <0.05 <0.01

13B 9 --- <0.03 <0.03 <0.03 <0.12 <2 <50 --- --- --- --- --- --- --- --- ---

14 14A 9 --- 1.6 82 57 330 2,500 (4) <50 --- <250 --- --- --- --- --- --- ---

15 15A 9.5 --- 20 570 250 1,400 11,000 3,500x --- <250 --- --- --- --- --- --- ---

16 16A 9.5 --- 3.5 38 8.4 48 400 70x --- <250 --- --- --- --- --- --- ---

17 17A 9.5 --- 13 500 180 1,000 8,400 (4) 1,600x --- <250 8.33 --- --- <0.5 <0.5 <0.5 ---

18 18A 9.5 --- 0.25 0.09 0.58 4.1 37 <50 --- <250 --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

19 19A 9.5 --- 17 370 130 770 7,900 2,000x --- <250 11.1 --- --- --- --- --- ---

20 20A 9.5 --- 120 1,300E 290 1,500 12,000 350x --- <250 --- --- --- --- --- --- ---

21 21A 9.5 --- 8.7 150 71 460 4,200 720x --- <250 --- --- --- --- --- --- ---

22 22A 9 --- 0.22 8.4 6.4 39 360 760x --- <250 --- --- --- <0.5 <0.5 <0.5 ---

23 23A 1.5 --- 0.03 5.2 6.4 39 <2 <50 --- <250 --- --- --- --- --- --- ---

24 24A 1.5 --- <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

G-Logics, Inc.

GL-1/MW-1 GL1-16 16 0 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL1-20 20 >80 3.76 21.5 5.03 26 411 <25 <40 <40 <5.0 --- --- <0.005 <0.02 <0.05 ---

GL1-23 23 0.1 0.34 0.93 0.24 1.26 11 <25 <40 <40 --- --- --- --- --- --- ---

GL1-28 28 0 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL1-28 Dup 28 0 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL-2/MW-2 GL2-20 20 >63 <0.02 3.18 2.96 14.3 325 <25 <40 <40 --- --- --- --- --- --- ---

GL2-24 24 7.9 <0.02 0.10 0.045 0.26 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL2-26 26 3.7 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL2-28 28 <2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-3/MW-3 GL3-5 5 1.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL3-7 7 -- 0.46 0.17 1.54 9.26 40 <25 <40 <40 --- --- --- --- --- --- ---

GL3-10 10 >27 2.98 17.7 4.44 25.0 178 <25 <40 <40 --- --- --- --- --- --- ---

GL3-20 20 --- 2.17 7.52 1.20 6.39 30 <25 <40 <40 --- --- --- --- --- --- ---

GL3-23 23 <5 <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---

GL3-25 25 --- <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---


September, 2009




zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

GL-4/MW-4 GL4-5 5 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL4-10 10 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL4-13 13 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL4-18 18 3.2 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL4-21 21 >40 6.70 17.0 2.77 12.1 65 <25 <40 <40 --- --- --- --- --- --- ---

GL4-25 25 <15 4.31 6.14 0.87 4.24 21 <25 <40 <40 --- --- --- --- --- --- ---

GL4-25 Dup 25 <15 4.79 7.43 1.26 6.05 23 <25 <40 <40 --- --- --- --- --- --- ---

GL-5/MW-5 GL5-5 5 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL5-10 10 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL5-14 14 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL5-18 18 --- 1.19 132 E 50.2 E 240 E 1,700 E <25 <40 <40 <5.0 --- --- --- --- --- ---

GL5-22 22 --- 0.068 11.6 2.58 13.4 55 <25 <40 <40 --- --- --- --- --- --- ---

GL5-25 25 1.1 <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---

GL-6/MW-6 GL6-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL6-10 10 0 0.13 0.16 0.48 3.4 22 <25 <40 <40 --- --- --- --- --- --- ---

GL6-15 15 0 0.083 0.074 0.39 1.86 15 <25 <40 <40 --- --- --- --- --- --- ---

GL6-19 19 --- <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL6-19 Dup 19 --- --- --- --- --- --- <25 <40 <40 --- --- --- --- --- --- ---

GL6-20 20 0.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL6-22 22 --- <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---

GL6-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-7/MW-7 GL7-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL7-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL7-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL7-18 18 --- <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL7-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL7-23 23 0 <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

GL-8/MW-8 GL8-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL8-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL8-15 15 0 <0.02 <0.02 0.042 0.48 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL8-18 18 --- 0.35 127 E 114 E 484 E 4,100 E <25 <40 <40 <5.0 --- --- 0.015 <0.02 <0.05 ---

GL8-22 22 >31 <0.02 0.18 0.21 1.11 19 <25 <40 <40 --- --- --- --- --- --- ---

GL8-25 25 <3 0.023 0.14 0.39 2.02 24 <25 <40 <40 --- --- --- --- --- --- ---

GL8-25 Dup 25 <3 0.024 0.13 0.38 2.05 26 --- --- --- --- --- --- --- --- --- ---

GL-9 GL9-8 8 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL9-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL9-15 15 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL9-18 18 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL9-20 20 --- 0.34 4.40 0.84 4.40 22 <25 <40 <40 --- --- --- --- --- --- ---

GL9-24 24 7.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL9-25 25 --- 0.096 <0.02 0.26 0.26 nd <25 <40 <40 --- --- --- --- --- --- ---

GL-10 GL10-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL10-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL10-18 18 --- <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL10-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL10-25 25 21 <0.02 0.053 0.29 1.51 10 <25 <40 <40 --- --- --- --- --- --- ---

GL10-30 30 0 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL10-30 Dup 30 0 --- --- --- --- --- <25 <40 <40 --- --- --- --- --- --- ---

GL-11 GL11-10 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL11-15 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL11-18 18 <0.02 <0.02 <0.03 <0.03 <10 <25 <40 <40 --- --- --- --- --- --- ---

GL11-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL11-24 24 <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

GL-12 GL12-5 5 0 <0.02 0.1 0.11 0.65 <10 --- --- --- --- --- --- --- --- --- ---

GL12-10 10 >500 48.3 950 E 293 E 1,440 E 15,000 E <25 <40 <40 30 --- --- --- --- --- ---

GL12-15 15 >120 38.4 85.9 14.9 73.7 745 --- --- --- --- --- --- --- --- --- ---

GL12-15 Dup 15 >120 37 82.9 14 69.8 635 --- --- --- --- --- --- --- --- --- ---

GL12-18 18 >150 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL12-20 20 24 3.15 1.95 0.8 4.31 34 --- --- --- --- --- --- --- --- --- ---

GL12-20 Dup 20 24 3.12 2 0.89 4.69 39 --- --- --- --- --- --- --- --- --- ---

GL12-23 23 9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL12-25 25 8.2 0.18 0.12 <0.03 0.23 <10 --- --- --- --- --- --- --- --- --- ---

GL12-29 29 6.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL12-30 30 0.2 <0.02 <0.02 <0.03 <0.03 <10 --- --- --- --- --- --- --- --- --- ---

G-Logics, Inc.

MW-9 MW9-15 15 0 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW9-15 Dup 15 0 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW9-20 20 0 0.57 0.6 1.42 4.05 40 --- --- --- --- --- --- --- --- --- ---

MW9-25 25 0 0.55 nd 0.37 0.73 13 --- --- --- --- --- --- --- --- --- ---

MW-10 MW10-15 15 --- 0.32 <0.10 0.39 0.48 15 --- --- --- --- --- --- --- --- --- ---

MW10-20 20 --- 2.32 0.79 0.99 2.52 35 --- --- --- --- --- --- --- --- --- ---

MW10-25 25 --- <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-11 MW11-20 20 --- <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW11-25 25 --- 0.38 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-12 MW12-20 20 --- <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW12-20 Dup 20 --- <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-13 MW13-25 25 --- <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---


February 12, 2010




zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

G-Logics, Inc.

MW-14 MW-14-8.5 8.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-14-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-14-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-14-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-14-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15 MW-15-3.5 3.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15-7.5 7.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16 MW-16-4.5 4.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16-8 8 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16-20 20 26.9 0.14 0.37 0.49 0.93 11 --- --- --- --- --- --- <0.005 <0.03 <0.05 ---

MW-16-26 26 9.1 <0.02 0.031 0.16 0.20 <10 --- --- --- --- --- --- <0.005 <0.03 <0.05 ---

MW-16-30 30 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17 MW-17-5 5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


December 19, 2014




zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

G-Logics, Inc.

MW-18 MW-18-12 12 3.3 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-18-15 15 2.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-18-20 20 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-19 MW-19-12 12 3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-19-16.5 16.5 680 16 13 13 24 3,400 --- --- --- --- --- --- --- --- --- ---

MW-19-20 20 20 0.084 0.17 0.010 0.22 26 --- --- --- --- --- --- --- --- --- ---

MW-19-23 23 3.9 0.032 0.15 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-20 MW-20-5 5 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-20-10 10 4.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-20-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-20-20 20 5 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-20-25 25 2.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21 MW-21-5 5 2.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21-10 10 3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21-20 20 4.2 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-21-25 25 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22 MW-22-5 5 1.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22-10 10 3.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22-15 15 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22-20 20 4 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-22-25 25 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


November 4, 2015

01-0620-K T1-Soil.xlsx 10 of 14



zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

MW-23 MW-23-10 10 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-23-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-23-20 20 3.3 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

MW-23-25 25 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-1 VW-1-5 5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-1-10 10 1.8 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

VW-2 VW-2-5 5 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-2-10 10 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-2-15 15 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-3 VW-3-5 5 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-3-10 10 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-3-15 15 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-3-20 20 3.3 <0.02 <0.10 <0.05 <0.15 <10 --- --- --- --- --- --- --- --- --- ---

VW-4 VW-4-5 5 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-4-10 10 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-4-15 15 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-5* VW-5-5 5 0.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-5-10 10 1.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-5-15 15 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-5-20 20 0.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


01-0620-K T1-Soil.xlsx 11 of 14



zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)Rothman and Associates

P-01 P-01-05 5 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-01-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-01-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-01-16 16 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-02 P-02-05 5 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-02-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-02-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-02-20 20 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-03 P-03-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-03-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-03-17 17 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-03-20 20 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-04 P-04-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-04-16 16 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-04-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-05 P-05-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-05-16 16 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-05-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-06 P-06-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-06-15 15 NR <0.02 <0.02 <0.02 <0.06 <2 <50 --- <250 --- --- --- --- --- --- ---

P-06-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-07 P-07-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-07-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-07-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-08 P-08-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


November 25, 2015

01-0620-K T1-Soil.xlsx 12 of 14



zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)

G-Logics, Inc.

MW-24 MW-24-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-24-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-24-20 20 7.9 0.646 <0.0621 <0.0311 <0.0932 <6.21 --- --- --- --- --- --- --- --- --- ---

MW-24-25 25 13.7 0.349 <0.0863 0.104 <0.13o 18.0 --- --- --- 1.46 --- --- --- --- --- ---

MW-25 MW-25-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-25-25 25 0 <0.0144 <0.0720 <0.0360 <0.108 <7.20 --- --- --- --- --- --- --- --- --- ---

MW-26 MW-26-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-26-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-26-20 20 21.3 0.0143 0.378 0.408 1.44 15.3 --- --- --- --- --- --- --- --- --- ---

MW-26-25 25 14.8 0.0549 <0.0678 <0.0925 <0.154 <6.16 --- --- --- --- --- --- --- --- --- ---

MW-26-30 30 0 <0.0120 <0.0598 <0.0299 <0.0897 <5.98 --- --- --- --- --- --- --- --- --- ---

MW-27 MW-27-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-27-15 15 0 0.0176 <0.0734 <0.0367 <0.183 <7.34 --- --- --- --- --- --- --- --- --- ---

MW-27-20 20 0 <0.0129 <0.0645 <0.0323 <0.0968 <6.45 <25.0 --- <50.0 --- --- --- --- --- --- ---

MW-27-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-28 MW-28-15 15 0 <0.0165 <0.0823 <0.0411 <0.123 <8.23 <27.9 --- <55.8 --- --- --- --- --- --- ---

MW-28-20 20 0 <0.0131 <0.0656 <0.0328 <0.0985 <6.56 --- --- --- --- --- --- --- --- --- ---

MW-28-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-13 GL-13-10 10 0 <0.0137 <0.684 <0.0342 <0.137 <6.84 --- --- --- --- --- --- --- --- --- ---

GL-13-15 15 0 <0.0136 <0.0682 <0.0341 <0.102 <6.82 --- --- --- --- --- --- --- --- --- ---

GL-13-20 20 0 <0.0106 <0.0529 <0.0264 <0.0793 <5.29 --- --- --- --- --- --- --- --- --- ---

GL-13-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ------


May 17, 2016

01-0620-K T1-Soil.xlsx 13 of 14



zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e Ran

ge Organ

ics

(GRO)

Diesel

Mineral O

il

Oil Lead

Chromium (Total

)

Cadmium

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Polycyc

lic ar

omatic

hydroca

rbons (PAHs)

(3)

(units in mg/kg)GL-14 GL-14-6 6 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-14-11 11 0.1 0.0236 0.0766 1.240 2.67 71.2 --- --- --- --- --- --- --- --- --- <0.0190

GL-14-16 16 714 <0.138 9.89 22.9 109 1,980 --- --- --- 3.87 --- --- <0.0688 <0.0344 <0.0688 <0.0216

GL-14-20 20 0 <0.0140 <0.0702 <0.0351 <0.105 <7.02 --- --- --- --- --- --- --- --- --- ---

GL-14-25 25 3.9 <0.0126 <0.0630 <0.0315 <0.0946 <6.30 --- --- --- --- --- --- --- --- --- ---

GL-15 GL-15-8 8 548 0.510 108 529 3,150 38,800 272 --- <50.0 19.6 --- --- --- --- --- <0.0216

GL-15-18 18 708 215 1,710 484 2,828 30,100 167 --- <50.0 --- --- --- <0.759 <0.379 <0.759 <0.0168

GL-16 GL-16-10 10 0 <0.0191 <0.0955 <0.0478 <0.143 <9.55 --- --- --- --- --- --- --- --- --- ---

GL-16-17 17 386 <0.145 61.7 219 669 22,700 --- --- --- 7.98 --- --- <0.724 <0.362 <0.724 <0.0192

GL-16-20 20 2.3 0.032 0.123 0.170 1.03 12.4 --- --- --- --- --- --- --- --- --- ---

GL-16-30 30 5.2 <0.0113 <0.0565 <0.0282 <0.0847 <5.65 --- --- --- --- --- --- --- --- --- ---


Notes: Refer to site diagram(s) for sampling locations.

(1) See attached lab reports for analytical methods.

(2) Available Method A and/or Method B Soil Cleanup Levels (mg/kg) for Unrestricted Land Use; MTCA, Amendments adopted in November 2013.

(3) c-PAH results has been calculated using Toxity Equivalency Factors

(4) Other gasoline consituents detected in sample. See analytical report for details.

(a) Soil Cleanup Level For Gasoline With No Detectable Benzene In The Soil.

(b) Soil Cleanup Level For Gasoline With Detectable Benzene In The Soil.

Dup Duplicate

nd Analytical laboratory reports not available. Data not reviewed. +

NR Not Recorded

E Indicates that the concentration is above the linear range of the instrument and is an estimate.

x Pattern of peaks present not indicative of Diesel

--- Not Analyzed.

* Soil Samples were not collected.

27 Bold Number(s) Indicates Contaminant Detected.

250 Bold Number and Yellow Shading Indicates Concentration Exceeds MTCA Cleanup Level Defined in Footnote 2.

<0.759 Laboratory reporting limits exceeded the cleanup level.

01-0620-K T1-Soil.xlsx 14 of 14

01-0620-K T1a-Soil.xlsx 1 of 12

TABLE 1aSoil Sample Analyses Summary Continued(1)Sumner Towing, Sumner, WA

Exploration Location Sample Number Depth (feet) PID 1-M

ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

EAI

B-1 B-1 @ 7 7 --- --- --- --- --- --- nd --- --- --- --- --- --- --- --- --- --- --- --- ---B-2 B-2 @ 7 7-8" --- --- --- --- --- --- nd --- --- --- --- --- --- --- --- --- --- --- --- ---B-3 B-3 @ 10 10-11" --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---B-4 B-4 @ 10 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---B-5 B-5 @ 7 7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---B-6 B-6 @ 7 7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Saltbush

Bore 1 0-1 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 1 @ 5-6 5 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---7-9 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---9-11 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---13-15 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---15-17 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 1 @ 18-20 18 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---19-21 780 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 2 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore2 @ 2-3 2 108 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3-5 51 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---7-9 250 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore2 @ 12 12 131 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MTCA Cleanup Level (2) 34.5 NA 5.00 0.05 0.03 240 NA NA NA NA NA 1.00 14.3 NA NA NA NA 0.500 0.500 0.500

March, 2000

November, 2000




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

Bore 3 0-1 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3-5 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 35 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore3 @ 8 8 50 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore 3 @ 8 Dup 8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9-11 14 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore 3 @ 13-14 13 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore 3 @ 13-14 D 13 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

15-17 18.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 11.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3-5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 1,199 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 @ 8-9 8 936 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore 4 @ 10 10 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11-13 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---13-15 2,300 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---15-17 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---17-19 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 4 @ 20 20 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 5 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 8.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 5 @ 4-6 4 10.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---7-9 10.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---11-13 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---14-15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 5 Cont. Bore 5 @ 16 16 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---17-19 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---19-21 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

Bore 6 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 19.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3-5 28.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---7-9 18.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---11-13 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 6 @ 15 15 557 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---Bore 6 @ 18 18 >2,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 7* 0-1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1-3 43 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3-5 10.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---5-7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---7-9 168 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---9-11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---11-13 389 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---13-15 148 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---15-17 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

EnCo

1 1A 11 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---1B 15.5 --- 4.5 10 7.2 --- --- --- --- --- --- --- --- <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

2 2A 12 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---2B 14 --- <0.01 <0.01 <0.05 --- --- --- --- --- --- --- --- <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.12C 16 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3 3A 9 --- 31 66 53 --- --- --- --- --- --- --- --- <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.13B 13 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3C 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---3D 16 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

4 4A 2 --- --- --- <0.05 --- --- --- --- <0.05 <0.05 <0.05 <0.05 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.14B 5 --- --- --- 0.32 --- --- --- --- <0.05 <0.05 <0.05 <0.05 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.14C 6.5 --- --- --- 2.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


January 1, 2007




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

5 5A 6.5 --- --- --- 0.17 --- --- --- --- --- --- --- --- <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.15B 8.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

6 6A 9.5 --- --- --- 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

7 7A 9.5 --- --- --- 110 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

8 8A 9.5 --- --- --- 33 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

9 9A 2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

10 10A 2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11 11A 2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

12 12A 2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

13 13A 3.5 --- --- --- <0.05 --- --- --- --- --- --- --- --- <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.113B 9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

14 14A 9 --- --- --- 16 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

15 15A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

16 16A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

17 17A 9.5 --- --- --- 41 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

18 18A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

19 19A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

20 20A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

21 21A 9.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

22 22A 9 --- --- --- 4.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

23 23A 1.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

24 24A 1.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

G-Logics, Inc.

GL-1/MW-1 GL1-16 16 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL1-20 20 >80 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL1-23 23 0.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL1-28 28 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL1-28 Dup 28 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-2/MW-2 GL2-20 20 >63 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL2-24 24 7.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL2-26 26 3.7 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL2-28 28 <2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-3/MW-3 GL3-5 5 1.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL3-7 7 -- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL3-10 10 >27 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL3-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL3-23 23 <5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL3-25 25 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-4/MW-4 GL4-5 5 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-10 10 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-13 13 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-18 18 3.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-21 21 >40 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-25 25 <15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL4-25 Dup 25 <15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-5/MW-5 GL5-5 5 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL5-10 10 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL5-14 14 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL5-18 18 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL5-22 22 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL5-25 25 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


September, 2009




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

GL-6/MW-6 GL6-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-19 19 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-19 Dup 19 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-20 20 0.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-22 22 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL6-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-7/MW-7 GL7-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL7-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL7-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL7-18 18 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL7-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL7-23 23 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-8/MW-8 GL8-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-18 18 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-22 22 >31 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-25 25 <3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL8-25 Dup 25 <3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-9 GL9-8 8 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-15 15 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-18 18 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-24 24 7.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL9-25 25 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

GL-10 GL10-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-18 18 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-25 25 21 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-30 30 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL10-30 Dup 30 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-11 GL11-10 10 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL11-15 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL11-18 18 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL11-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL11-24 24 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-12 GL12-5 5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-10 10 >500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-15 15 >120 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-15 Dup 15 >120 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-18 18 >150 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-20 20 24 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-20 Dup 20 24 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-23 23 9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-25 25 8.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-29 29 6.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL12-30 30 0.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

G-Logics, Inc.

MW-9 MW9-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW9-15 Dup 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW9-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW9-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-10 MW10-15 15 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW10-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW10-25 25 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


February 12, 2010




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

MW-11 MW11-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW11-25 25 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-12 MW12-20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW12-20 Dup 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-13 MW13-25 25 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

G-Logics, Inc.

MW-14 MW-14-8.5 8.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-14-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-14-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-14-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-14-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15 MW-15-3.5 3.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-15-7.5 7.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-15-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-15-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-15-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-15-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16 MW-16-4.5 4.5 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-8 8 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-11 11 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-20 20 26.9 --- --- 0.20 --- --- --- (4) --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-26 26 9.1 --- --- 0.11 --- --- --- (4) --- --- --- --- --- --- --- --- --- --- --- --- ---MW-16-30 30 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17 MW-17-5 5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-17-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-17-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-17-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-17-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


December 19, 2014




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

G-Logics, Inc.

MW-18 MW-18-12 12 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-18-15 15 2.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-18-20 20 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-19 MW-19-12 12 3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-19-16.5 16.5 680 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-19-20 20 20 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-19-23 23 3.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-20 MW-20-5 5 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-20-10 10 4.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-20-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-20-20 20 5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-20-25 25 2.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21 MW-21-5 5 2.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-21-10 10 3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-21-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-21-20 20 4.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-21-25 25 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22 MW-22-5 5 1.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-22-10 10 3.6 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-22-15 15 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-22-20 20 4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-22-25 25 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-23 MW-23-10 10 3.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-23-15 15 3.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-23-20 20 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-23-25 25 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-1 VW-1-5 5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-1-10 10 1.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


November 4, 2015




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

VW-2 VW-2-5 5 1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-2-10 10 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-2-15 15 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-3 VW-3-5 5 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-3-10 10 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-3-15 15 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-3-20 20 3.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-4 VW-4-5 5 1.1 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-4-10 10 1.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-4-15 15 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

VW-5* VW-5-5 5 0.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-5-10 10 1.4 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-5-15 15 0.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---VW-5-20 20 0.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Rothman and Associates

P-01 P-01-05 5 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-01-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-01-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-01-16 16 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-02 P-02-05 5 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-02-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-02-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-02-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-03 P-03-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-03-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-03-17 17 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-03-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-04 P-04-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-04-16 16 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-04-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


November 25, 2015




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

P-05 P-05-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-05-16 16 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-05-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-06 P-06-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-06-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-06-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-07 P-07-10 10 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-07-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---P-07-20 20 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

P-08 P-08-15 15 NR --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

G-Logics, Inc.

MW-24 MW-24-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-24-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-24-20 20 7.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-24-25 25 13.7 <0.229 <0.0602 <0.173 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-25 MW-25-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-25-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-26 MW-26-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-26-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-26-20 20 21.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-26-25 25 14.8 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-26-30 30 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-27 MW-27-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-27-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-27-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-27-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-28 MW-28-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-28-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---MW-28-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---


May 17, 2016




ethyln

aphthale

ne

2-Meth

ylnap

thalene

Naphthale

ne

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCS (8

260)

t-Butyl

Alcohol (T

BA)

Ethyl t-B

utyl Ether

(ETBE)

t-Amyl

Methyl

Ether (TAME)

Diisopryl

Ether (D

IPE)

Total p

olychlorin

ated

biphenyls

(PCBs)

Aroclor 1

016

Aroclor 1

221

Aroclor 1

232

Aroclor 1

242

Aroclor 1

248

Aroclor 1

254

Aroclor 1

260

Aroclor 1

262

(units in mg/kg)

GL-13 GL-13-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-13-15 15 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-13-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-13-25 25 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-14 GL-14-6 6 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-14-11 11 0.1 0.0997 0.257 0.113 --- --- --- --- --- --- --- --- <0.0114 <0.0114 <0.0114 <0.0114 <0.0114 <0.0114 <0.0114 <0.0114 ---GL-14-16 16 714 12.6 25 14.7 <0.0344 0.0344 <0.0344 (4) --- --- --- --- --- --- --- --- --- --- --- --- ---GL-14-20 20 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-14-25 25 3.9 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

GL-15 GL-15-8 8 548 18.5 37.0 29.5 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-15-18 18 708 13.6 26.2 17.1 <0.379 <0.379 <0.379 (4) --- --- --- --- <0.0117 <0.0117 <0.0117 <0.0117 <0.0117 <0.0117 <0.0117 <0.0117 ---

GL-16 GL-16-10 10 0 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-16-17 17 386 11.8 23.1 15.3 <0.362 <0.362 <0.362 (4) --- --- --- --- --- --- --- --- --- --- --- --- ---GL-16-20 20 2.3 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---GL-16-30 30 5.2 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---



(1) See attached lab reports for analytical methods.

(2) Available Method A and/or Method B Soil Cleanup Levels (mg/kg) for Unrestricted Land Use; MTCA, Amendments adopted in November 2013.

(3) c-PAH results has been calculated using Toxity Equivalency Factors

(4) Other gasoline consituents detected in sample. See analytical report for details.

(a) Soil Cleanup Level For Gasoline With No Detectable Benzene In The Soil.

(b) Soil Cleanup Level For Gasoline With Detectable Benzene In The Soil.

Dup Duplicate

nd Analytical laboratory reports not available. Data not reviewed.

NR Not Recorded

E Indicates that the concentration is above the linear range of the instrument and is an estimate.

x Pattern of peaks present not indicative of Diesel

--- Not Analyzed.

* Soil Samples were not collected.

27 Bold Number(s) Indicates Contaminant Detected.

250 Bold Number and Yellow Shading Indicates Concentration Exceeds MTCA Cleanup Level Defined in Footnote 2.


01-0620-K T2-GW.xls Page 1 of 6

TABLE 2Groundwater Sample Analyses Summary (1, 2)Sumner Towing, Sumner, WA

Exploration Location Sample Date Sample Number Ben

zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

Environmental Associates, Inc.B-3 4/13/2000 B-3 GW 23 640 440 2,500 7,100 nd nd nd --- 5.7 --- --- --- --- --- --- --- --- --- nd ---

B-5 4/13/2000 B-5 GW 12 240 170 970 3,300 --- --- --- --- 4.4 --- --- --- --- --- --- --- --- --- --- ---

Saltbush Environmental Services, Inc.Bore 1 11/13/2000 Bore 1 31 160 47 230 2,400 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 3 11/13/2000 Bore 3 11 21 11 46 580 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 5 11/13/2000 Bore 5 >2000 >2000 >2000 >2000 82,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

Bore 7 11/13/2000 Bore 7 75.2 22.4 9.88 32.6 603 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

G-Logics, Inc.MW-1 9/30/2009 MW-1 2,940 9,490 1,020 5,160 40,800 <200 <400 <400 --- --- <0.01 <1.0 <5.0 --- --- --- --- --- --- --- ---

9/30/2009 MW-20 (Dup) 2,750 8,690 921 5,650 54,800 <200 <400 <400 --- --- <0.01 <1.0 <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-1 1,990 7,240 1,280 5,640 74,700 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

11/4/2015 MW-1 2,250 9,050 1,750 8,600 31,500 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/18/2016 MW-1 3,270 9,040 1,330 6,730 69,700 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-2 9/30/2009 MW-2 <1.0 <2.0 <1.0 <2.0 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-2 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/4/2015 MW-2 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-3* 9/30/2009 MW-3 1,480 4,250 779 4,020 23,800 --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- --- ---

MTCA Cleanup Level (2) 5 1,000 700 1,000 1,000(a)/800(b) 500 500 500 15 15 0.01 5 20 400 16** 160** 5 5 0.2 NA 160




zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

MW-4 9/30/2009 MW-4 28,600 23,600 8,470 34,800 293,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-4 16,500 3,980 2,430 6,500 107,000 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

11/4/2015 MW-4 23,200 4,640 4,030 8,960 120,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-4 20,100 6,690 2,790 7,750 114,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-5 9/30/2009 MW-5 700 35,900 6,640 36,300 333,000 <200 <400 <400 17.9 --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-5 27.6 10,800 2,430 11,600 90,100 --- --- --- --- 5.7 --- --- --- --- --- --- --- --- --- --- ---

MW-5 (Dup) 26.4 9,900 2,480 11,800 90,900 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-5 12.5 13,500 4,440 21,600 127,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-5 <50.0 16,100 3,130 16,470 127,000 --- --- --- 13.1 --- <5.00 <5.00 <10.0 <5.00 <5.00 <5.00 <5.00 <5.00 <5.00 nd ---

MW-6 9/30/2009 MW-6 <1.0 <2.0 1.2 7.4 170 <200 <400 <400 --- --- --- --- --- --- --- --- --- --- --- --- ---

9/30/2009 MW-6 (Dup) <1.0 <2.0 1.4 9.9 150 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-6 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-6 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-6 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-7 9/30/2009 MW-7 <1.0 <2.0 <1.0 <2.0 <100 <200 <400 <400 --- --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-7 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-7 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-8 9/30/2009 MW-8 19.4 1,840 680 3,400 16,000 <200 <400 <400 6.8 --- --- --- --- --- --- --- --- --- --- --- ---

3/23/2015 MW-8 9.2 492 900 4,290 26,400 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-8 8.1 633 1,100 5,270 29,700 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-8 <4.00 371 640 3,030 21,700 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

MW-9 3/1/2010 MW-9 14,900 707 2,840 4,640 24,300 --- --- --- <5.0 --- <0.01 <1.0 <5.0 --- --- --- --- --- --- --- 20212/22/2014 MW-9 978 13 245 142 2,060 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-9 3,610 65.5 857 684 19,700 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-9 698 18.4 241 152 4,670 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-9 643 19.5 693 405 8,260 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-10 3/1/2010 MW-10 2,880 2,380 370 1,230 23,400 --- --- --- <5.0 --- <0.01 <1.0 <5.0 --- --- --- --- --- --- --- 1023/1/2010 MW-10 (Dup) --- --- --- --- 22,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

12/22/2014 MW-10 846 361 322 685 6,040 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-10 732 417 332 780 11,300 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-10 1,440 204 326 597 5,300 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-C (Dup) 1,260 239 301 555 4,650 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/19/2016 MW-10 238 36.7 69.4 150 2,530 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-C (Dup) 233 31.1 82.2 186 3,060 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-11 3/1/2010 MW-11 9,510 191 254 213 5,770 --- --- --- <5.0 --- <0.01 <1.0 <5.0 --- --- --- --- --- --- --- 11712/22/2014 MW-11 7,450 34 393 188 4,610 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-11 7,020 24.6 106 113 10,000 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-11 5,270 238 336 528 20,200 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-11 3,140 18.4 148 51.1 9,270 --- --- --- <0.200 --- --- --- --- --- --- --- --- --- --- --- ---

MW-12 3/1/2010 MW-12 <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- <5.0

12/22/2014 MW-12 <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-12 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-12 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

MW-13 3/1/2010 MW-13 <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- <5.0

12/22/2014 MW-13 <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-13 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-13 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-14 12/22/2014 MW-14 <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

12/22/2014 MW-14 (Dup) <1.0 <2.0 <1.0 <1.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-14 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-14 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-15 12/22/2014 MW-15 <1.0 <1.0 <1.0 <3.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-15 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-15 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-16 12/22/2014 MW-16 321 1,570 1,920 5,170 28,700 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-16 713 1,530 2,240 6,220 48,200 --- --- --- --- <5.0 --- --- --- --- --- --- --- --- --- --- ---

MW-A (Dup) 581 1,090 1,910 5,140 38,700 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/6/2015 MW-16 432 1,360 2,500 6,400 18,000 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-A (Dup) 289 1,540 2,560 6,950 44,200 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-16 895 219 1,630 1,250 22,000 --- --- --- 0.378 --- --- --- --- --- --- --- --- --- --- --- ---

MW-A (Dup) 958 217 1,730 1,400 25,300 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-17 12/22/2014 MW-17 <1.0 <1.0 <1.0 <3.0 <100 --- --- --- --- --- --- --- <5.0 --- --- --- --- --- --- --- ---

3/23/2015 MW-17 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-B (Dup) <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

11/5/2015 MW-17 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

MW-18 11/9/2015 MW-18 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-18 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-19 11/9/2015 MW-19 <1 <2 18.8 33.4 3,760 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-19 0.553 5.18 67.8 76.9 3,890 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-20 11/9/2015 MW-20 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-20 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-21 11/9/2015 MW-21 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-21 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-22 11/9/2015 MW-22 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-22 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-23 11/9/2015 MW-23 <1 <2 <1 <3 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

5/20/2016 MW-23 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-24 5/19/2016 MW-24 1,340 <50.0 40.5 <75.0 5,500 <76.9 --- <154 --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-25 5/19/2016 MW-25 <0.200 <1.00 <0.500 <1.50 <100 --- --- --- --- --- <0.500 <0.500 <1.00 <0.500 <0.500 <0.500 <0.500 <0.500 <0.500 nd ---

MW-26 5/20/2016 MW-26 204 1,190 902 2,684 22,600 275 --- <162 --- --- <50.0 <50.0 <100 <50.0 <50.0 <50.0 <50.0 <50.0 <50.0 nd ---

MW-27 5/20/2016 MW-27 <0.200 <1.00 1.97 3.39 108 <76.9 --- <154 --- --- --- --- --- --- --- --- --- --- --- --- ---

MW-28 5/20/2016 MW-28 <0.200 <1.00 <0.500 <1.50 <100 <76.9 --- <154 --- --- --- --- --- --- --- --- --- --- --- --- ---





zene

Toluene

Ethylben

zene

Xylenes

Gasolin

e

Diesel

Mineral O

il

Oil Total Lea

d

Dissolve

d Lead

1,2-D

ibromoethan

e

(EDB)

1,2-D

ichloroeth

ane

(EDC)

Methyl

tert-B

utyl Ether

(MTBE)

1,1-D

ichloroeth

ene

cis 1,

2-Dich

loroethen

e

trans-1

,2-Dich

loroethen

e

Tetrac

hloroethen

e (PCE)

Trichloroeth

ene (

TCE)

Vinyl Chlorid

e

Other VOCs (

8021

B)

Total Nap

hthalenes

(units in μg/L)

Rothman and AssociatesP01 11/25/2015 P01 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P02 11/25/2015 P02 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P03 11/25/2015 P03 12 <1 <1 <3 180 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P04 11/25/2015 P04 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P05 11/25/2015 P05 6.9 <1 21 3.6 160 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P06 11/25/2015 P06 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P07 11/25/2015 P07 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---

P08 11/25/2015 P08 <1 <1 <1 <3 <100 <50 --- <250 --- --- --- --- --- --- --- --- --- --- --- --- ---



1 See attached lab reports for analytical methods.

2 Available Method A and/or most conservative Method B Cleanup Levels, MTCA, Amendments adopted in November 2013.

Exceeding Cleanup Levels does not necessarily trigger requirements for Cleanup Actions under MTCA.

(a) Groundwater Cleanup Level for Gasoline with no detectable benzene in the groundwater.

(b) Groundwater Cleanup Level for Gasoline with detectable benzene in the groundwater.

nd Not Detected, concentration less than the laboratory method detection limit.

Dup Duplicate

--- Not Analyzed27 Bold Number(s) Indicates Contaminant Detected.

250 Bold Number(s) and Shading Indicates Concentration Exceeds MTCA Cleanup Level.

* MW-3 found destroyed.

** Most Conservative Method B Cleanup Level

Light orange shading indicates the most recent sampling event.


Important Note: This Table Contains Information in color.

Black & white photocopies may not be suitable for review

01-0620-K T3-Vapor.xls Page 1 of 1

TABLE 3Soil Vapor Sample Analyses (1)Sumner Towing810 Alder Ave, Sumner, WAAnalytical Methods: Gasoline by NWTPH-GX & VOCs by EPA 8260C and/or TO-15Units reported in ug/m3

Exploration LocationCollection Date

Sample Name

Sample Depth (feet) Ben

zene

Toluene

Ethylben

zene

Xylenes

Naphthale

ne

Gasolin

e Ran

ge

1,2-D

ibromoethan

e (EDB)

1,2-D

ichloroeth

ane (

EDC)

Methyl

tert-B

utyl Ether

(MTBE)

Tetrac

hloroethen

e (PCE)

April 14, 2015 (Shallow Points, 8260C Analyses)VP-1 VP-1 5 43 229 67 340 <100 <5000 <10 <100 <100 ---VP-2 VP-2 5 22 161 59 313 <100 5,200 <10 <100 <100 ---VP-3 VP-3 5 36 137 61 280 <100 <5000 <10 <100 <100 ---VP-4 VP-4 5 40 136 60 294 <100 <5000 <10 <100 <100 ---VP-5 VP-5 5 93 352 146 671 <100 10,700 <10 <100 <100 ---VP-6 VP-6 5 34 134 <50 227 <100 <5000 <10 <100 <100 ---VP-7 VP-7 5 24 <100 <50 170 <100 8,700 <10 <100 <100 ---VP-8 VP-8 5 18 J <100 <50 163 <100 <5000 <10 <100 <100 ---

VP-8 Dup 5 20 <100 <50 156 <100 <5000 <10 <100 <100 ---TO-15 AnalysisVW-1 12/8/2015 VW-1 11.5 <0.639 <0.754 <1.30 0.904 <1.57 10.1 <1.54 <0.809 <0.721 4.66

5/28/2016 VW-1 11.5 <1.28 <1.51 <2.61 <1.74 <0.439 26.3 <0.137 <1.62 <1.44 4.485/28/2016 VW-Dup 11.5 <1.28 <1.51 <2.61 <1.74 <0.439 18.5 <0.137 <1.62 <1.44 4.61

VW-2 12/8/2015 VW-2 12 <0.639 <0.754 <1.30 <0.868 <1.57 <2.97 <1.54 <0.809 <0.721 2.035/28/2016 VW-2 12 <3.51 <4.14 <7.16 <4.77 <1.21 <16.3 <0.376 <4.45 <3.96 <11.2

VW-3 12/8/2015 VW-3 12 <0.639 0.771 <1.30 2.25 8.30 402 <1.54 <0.809 <0.721 2.965/28/2016 VW-3 12 <1.28 <1.51 <2.61 <1.74 0.629 21.3 <0.137 <1.62 <1.44 5.02

VW-4 12/8/2015 VW-4 14.5 <0.639 0.759 <1.30 <0.868 <1.57 7.7 <1.54 <0.809 <0.721 <2.035/28/2016 VW-4 14.5 <1.28 <1.51 <2.61 <1.74 <0.439 <5.93 <0.137 <1.62 <1.44 <4.07

VW-5 12/8/2015 VW-5 15.5 <0.639 <0.754 <1.30 9.78 <1.57 10.3 <1.54 <0.809 <0.721 <2.035/28/2016 VW-5 15.5 <1.28 <1.51 <2.61 <1.74 <0.439 <5.93 <0.137 <1.62 <1.44 <4.07

Ecology Soil Gas Screening Levels 0'-15' ug/m3 (1) 10.7 76,200 15,200 1,520 2.45 NA 0.139 3.21 321 321

Notes Refer to site diagram(s) for sampling locations.(1) Screening Levels from Department of Ecology's Guidance for Evaluating Soil Vapor Intrusion in Washington State. Investigation and Remedial Action, Draft Document, October 2009 with amended values, June 2012 and January 2015. nd Not Detected, concentration less than the laboratory method detection limit.

Dup. Duplicate Sample for QA/QC.27 Bold Number(s) Indicates Detection.25 Bold Number(s) and Shading Indicates Concentration Exceeding Ecology Soil-Gas Screening Levels.NR No available screening level--- Sample Not Analyzed

01-0620-K T4 CAA Inital Eval.xlsx Page 1 of 3

Table 4Initial Evaluation for Cleanup Action Alternatives Sumner Towing810 Alder Avenue, Sumner, WA

Remediation Option Description Advantages DisadvantagesFurther Consideration

No Action Perform no remedial action. No additional costs considered in administrative and physical expenses.

Limited property use, possible elevated-health risk. No

Containment and Institutional Controls

Possible land-use restrictions, such as fencing, signage, deed restrictions, and/or title restrictions, are required to minimize exposure pathways,

Easy to implement for owned property, low costs, minimal disruption to existing land uses. Can be used to support/supplement active remediation methods.

Not a permanent solution, less preferable MTCA Cleanup. Not applicable for off-property areas. May be applicable after completion of active remedial methods.

Yes

Monitored Natural Attenuation Monitoring the reduction of contaminants by natural processes, such as volatilization, dispersion, and bioremediation.

Low costs, minimal disruption to site operations, easy to implement. Can be used to support/supplement active remediation methods.

Less preferable under MTCA. Remediation will likely require multiple years to achieve cleanup levels. Does not address immediate or future exposures. Not a permanent solution for vadose-zone contamination. Needs to be considered for use in conjunction with other remedial technologies.

Yes

Excavation with Off-Site Disposal Excavation of contaminated soils to an off-site landfill for final disposal (or possible treatment and disposal).

For shallow soils, excavation is relatively easy to implement and contaminant removal is easy to document, regulatory-agency acceptance is easier. Permanent and rapid solution.

Deeper excavation would require soil sloping/shoring and the demolition of the bank building on the south-adjacent property. Additionally, Alder and Kincaid streets also would require shoring. Excavation costs increase with depth.

Yes

Solidification/Stabilization Addition of compounds that would immobilize the contaminants from further migration. For example, for metal contaminants, these compounds generally consist of pozzolanic or cementatious materials. For organic contaminants, these compounds generally consist of granular activated carbon.

In-situ solidification/stabilization renders contaminants immobile. Bioremediation then can be used to degrade the retained organic contaminants.

Deep soil mixing or trenching would be required. Could conflict with future commercial-site uses. May need to be used in conjunction with other remedial technologies. Individually, not a permanent solution.

No




In-situ Thermal Remediation Heat is applied to the subsurface (various methods) to volatilize organic contaminants. Extraction wells capture and extract contaminants in vapor/water/NAPL phases and are treated Ex-situ. Typically used as a source-area treatment.

Highly effective in mobilizing organic contaminants for extraction. Very short duration for remediation, after initial startup. Can treat NAPL source areas and areas high concentration of contaminants. Permanent solution for source-area contamination.

Requires significant surface and subsurface construction. Remedy is typically used for source area/high contaminant zones, frequently those at greater depths. Very expensive remedy (special equipment, electricity demands, construction).

No

In-situ Aerobic Bioremediation In-situ biological processes are enhanced with the injection of oxygen or addition of oxygen releasing compounds. Trace nutrients may be introduced as necessary.

Treatment can occur without significant disruption to surface improvements. Good for petroleum contaminants. Permanent solution. Minimal site disruption after installation of treatment equipment.

Cold climates/low temperature slows the remediation process. Bioremediation is typically a long-term technology which may take several years. Microbial growth also may foul treatment-system equipment. Not effective at low contaminant concentrations. Surfactants also may be needed to facilitate surface contact. Good understanding of geochemistry is required.

Yes

In-situ Chemical Oxidation Treatment Chemical oxidation using compounds such as permanganate, ozone, and hydrogen peroxide, can be introduced into the subsurface to oxidize organic contaminants.

Chemical oxidation can destroy subsurface organic contaminants and/or breakdown the contaminants to more biodegradable compounds. Less effective in soils with high organic content. Permanent solution. Minimal site disruption after installation of treatment equipment.

Can degrade microbes, create acidic conditions(possibly mobilizing metals contaminants), and/or can create high temperatures (possibly impacting subsurface utilities). Rapid reaction can produce contaminant vapors (vapor-intrusion concerns) and contaminants can become more mobile. For heavy organic contaminants or elevated concentrations, multiple applications are required. Surfactants also may be needed to facilitate surface contact. Good understanding of geochemistry is required. Less effective for contaminated vadose-zone soils.

Yes




Soil-Vapor Extraction Air is drawn through In-situ contaminated soils causing the volatilization and removal of contaminants from the vadose zone. Reduces concentration of contaminants entering groundwater systems.

Vapor extraction is easy to implement if soil types, groundwater depth, and contaminant properties are suitable. Minimal site disruption. Addresses possible soil-vapor intrusion concerns. Airflow also facilitates bioremediation.

Requires treatment structures/facilities to be in place, with ongoing operation, maintenance, and monitoring. Contaminants are not destroyed but are transferred to the atmosphere (if not treated). Requires possible permits if discharge concentrations are high. Fine-grained soils limit removal of contaminants, increasing operational duration.

Yes

In-situ Air Sparging Forced air is injected into the groundwater, causing volatilization of dissolved contaminants into the vadose zone.

Air sparging is easy to implement if soil types, groundwater depth, and contaminant properties are suitable. Air flow results in secondary-benefit bioremediation.

Often used in tandem with a vapor-extraction system to remove volatiles from the vadose zone (if vapor intrusion is possible). Requires treatment structures/facilities to be in place, monitoring and maintenance of equipment.

Yes

Dual-Phase Extraction (DPE) Groundwater extraction is used to lower the water table below the contaminated-soil zone. Removed water is treated/discharged. Volatile components in the expanded vadose zone are removed by air pulled through the subsurface (by SVE).

Site contaminants are removed from the subsurface, increased area of remedial influence, and decrease of contaminant migration. Can be used to access inaccessible areas.

Dual-phase extraction equipment is expensive and requires engineering design and intensive operation and maintenance. Large volumes of contaminated water may be generated and may require problematic treatment and/or disposal.

No

Barrier Wall A groundwater barrier (also can be purposed as a vapor barrier) can be constructed to prevent migration of contaminants in a certain direction. Would be constructed of less permeable materials (e.g., cement bentonite, sheet piles). Often considered when access to the source areas limited.

Fairly easy to construct, different methods can be used depending upon specific site conditions and geology. Can be incorporated into project-development efforts. Easy to document effectiveness.

Contaminants and groundwater behind the barrier wall need to be appropriately managed. May cause groundwater mounding behind the barrier, resulting in movement over or around the barrier wall. Long-term monitoring of conditions behind the wall. Does not treat the source area. Provides limited effectiveness for vapor-phase contaminants.

No

Table 5Detailed Evaluation of Cleanup Action Alternatives and DCASumner Towing810 Alder Avenue, Sumner, WA

Alternative

Compliance with MTCA Threshold and Other Criteria

DCA Evaluation Criteria Rank Value Rank Value Rank ValueInstitutional Controls would provide long‐term administrative protection for the contaminated areas.

4 1.2 Without an active cleanup, MNA would provide limited long‐term protection for the contaminated areas.

1 0.3 This Excavation would be designed to remove the majority of contaminated soils at the Site, to a depth of approximately 25 feet, providing protection for direct‐contact, vapors, and terrestrial and ecological receptors. Contaminated soil would be transported to a disposal facility.

7 2.1

Individually, this method provides a low‐ranked preference for permanence. 2 0.4 Individually, MNA provides a low‐ranked preference for permanence. 1 0.2 This method provides for the permanent removal of contaminated soils and groundwater in the excavated areas, thereby reducing contaminant mass.

8 1.6

Given the relatively mobility of the contaminants and the presence of groundwater impacts, Institutional Controls can provide notice for future construction and land‐use. Institutional Controls is less preferable for Long Term Effectiveness.

3 0.6 Given the relatively mobility of the contaminants and the presence of groundwater impacts, continued monitoring would record the degradation of Site contaminants over time. The method would satisfy long‐term effectiveness criteria.

2 0.4 Removal of source‐area soils would satisfy long‐term effectiveness criteria. 8 1.6

This Alternative can manage short‐term risks, with the use of land‐use restrictions, preventing or minimizing exposure to residual contamination.

3 0.3 This Alternative poses a short‐term risk as contaminant concentrations remain above established cleanup levels until such time that natural attenuation occurs.

2 0.2 Excavation of the entire Site would require the design and permitting for shoring. This work would create construction hazards and would create worker‐exposure conditions to the Site contaminants. Alternative poses the most short‐term risk due to the nature of the work (construction safety‐related concerns).

4 0.4

Institutional controls for the property can be implemented, but are undesirable to the State of Washington. Site restrictions cannot be placed on downgradient properties.

4 0.4 Unlikely to be implementable without site remediation. However, groundwater monitoring is easily performed at the Site.

4 0.4 Excavation of the Site will require design, permitting, and oversight of shoring. Site access would be restricted and noise/traffic disruptions could occur. Backfilled areas would require compaction or future‐construction modification.

4 0.4

May be perceived as not doing anything to protect the public. Without prior active‐remediation efforts, public concern regarding Institutional Controls at this Site may be an issue.

2 0.2 May be perceived as not doing anything to protect the public. Without prior active‐remediation efforts, public concern regarding Institutional Controls at this Site may be an issue.

2 0.2 Alternative maximizes removal and disposal of impacted soils. Noise, access restrictions, dust/odors, and traffic disruptions could adversely impact the neighborhood.

4 0.4

Overall Ranking 3.1 1.7 6.5Estimated Cost

Alternative 2,Monitored Natural Attenuation

Alternative 1,Institutional Controls

Alternative 3,Excavation with Off‐Site Disposal

Alternative will provide protection for human health and the environment, given the identified restrictions are followed.

Individually, this Alternative does not comply with cleanup standards. Active remediation is required.

Six to twelve months for recording of Institutional Controls, would need to be maintained for indefinite number of years.

This Alternative does not include provisions for compliance monitoring.

Alternative complies with applicable laws.

Alternative will protect human health and the environment.

Active remedial methods can be used to address contaminated‐environmental media in order to comply with cleanup standards.

Alternative can be designed to comply with applicable laws.

Alternative includes provisions for compliance monitoring (soil and groundwater sampling).

Six to twelve months needed to complete excavation of the entire Site. This time period includes the design, permitting, setup, excavation, and Site/surface restoration efforts. This alternative will require extensive shoring along Alder and Kincaid Avenues and the removal of the bank building.

Alternative will ultimately provide protection for human health and the environment, given that contaminant concentrations will eventually attenuate to levels below risk‐based cleanup levels.

Without the removal of source of other elevated contaminant concentrations this alternative does not comply with Cleanup Standards.

Alternative includes provisions for compliance monitoring (i.e., groundwater sampling).

Without source‐area remediation and adequate oxygen an undetermined number of years could be expected for contaminant concentrations at the entire Site to degrade below cleanup levels.

Alternative complies with applicable laws.

$150,000 $5,800,000

Protection of Human Health and the Environment

Compliance with Cleanup Standards

Compliance with Applicable State and Federal Laws

Provision for Compliance Monitoring

Restoration Time Frame

Protectiveness (30% Weighted Factor)

Permanence (20% Weighted Factor)

Long‐Term Effectiveness (20% Weighted Factor)

Short‐Term Risk Management (10% Weighted Factor)

Implementability (10% Weighted Factor)

Public Concerns (10% Weighted Factor)

$50,000

01-0620-K T5 DCA Final Eval.xlsx 1 of 3


Alternative


DCA Evaluation Criteria Rank Value Rank Value Rank ValueWith addition of oxygen‐releasing compounds and trace nutrients, this Alternative will begin remediation of soil and groundwater. Over the long‐term, In‐situ Aerobic Bioremediation will achieve protection for soil and groundwater. Soil vapor also will be symbiotically addressed, given reduction of source concentrations and benefit of bacterial degradation.

4 1.2 With addition of oxidizing compounds, this Alternative will begin remediation of soil and groundwater. Contaminant‐mass removal rates are anticipated to be higher at the initiation of the treatment. Accordingly, In‐situ Chemical Oxidation will achieve protection for soil and groundwater. Soil vapor also will be symbiotically addressed, given reduction of source concentrations.

3 0.9 With initiation of treatment, this Alternative will begin remediation of soil and groundwater. Contaminant‐mass removal rates are anticipated to be higher at the initiation of the treatment. An AS/SVE system will achieve protection for soil and groundwater. Soil vapor also will be addressed, directly by the SVE and by reduction of source concentrations.

5 1.5

Over the long term, this alternative removes the majority of the contaminant mass. Residual concentrations may remain.

4 0.8 Over the long term, this alternative removes the majority of the contaminant mass. Residual concentrations may remain.

4 0.8 Alternative utilizes AS/SVE to quickly remove volatile contaminants from the vadose zone, which pose the concern for vapor intrusion. With the addition of oxygen to the subsurface, bioremediation also is enhanced. Over the long term, this Alternative removes the majority of the contaminant mass, resulting in a permanent solution.

5 1.0

Degradation of contaminants would satisfy long‐term effectiveness criteria. Effectiveness limited by Site geology.

5 1.0 Degradation of contaminants would satisfy long‐term effectiveness criteria, but is expected to be less effective in the vadose zone due to reduction of microbes by the oxidizer compounds.

5 1.0 Site contaminants would be removed/degraded, resulting in long‐term effectiveness. Site geology in the source area is problematic for AS/SVE.

5 1.0

Alternative poses moderate short‐term risks as it requires drilling/trenching and related construction activities, which present some short‐term risks to human health, primarily to remediation‐system workers.

4 0.4 Alternative poses moderate short‐term risks as it requires drilling/trenching and related construction activities, which present some short‐term risks to human health, primarily to remediation‐system workers. Additionally, the handling of oxidizer chemicals included in this alternative will present a higher level of short‐term risk to works (exposures to oxidizers) and would reduce bacteria available for bioremediation.

3 0.3 Alternative poses moderate short‐term risks as it requires drilling/trenching and related construction activities, which present some short‐term risks to human health, primarily to remediation‐system workers. SVE will quickly address soil‐vapor concerns.

5 0.5

Moderately easy to implement, but layout design and injections will increase the technical and administrative requirements. Site access would be restricted and noise disruptions could occur during field operations. Periodic injections and monitoring of performance would present minimal impact to the Site.

4 0.4 Moderately easy to implement, but layout design and injections will increase the technical and administrative requirements. Site access would be restricted and noise disruptions could occur during field operations. Periodic injections and monitoring of performance would present minimal impact to the Site.

3 0.3 Moderately easy to implemented, but system design and installation will increase the technical and administrative requirements. Site access would be restricted and noise disruptions could occur during system installation. Once the system is installed, regular operation and monitoring of the system would present minimal impact to the Site.

4 0.4

Noise, Site access restrictions and traffic disruptions during system installation could adversely impact the neighborhood. However, the alternative utilizes equipment that can be placed in unobtrusive areas, therefore it is not likely to be a high concern for residents or other members of the community.

4 0.4 Noise, Site access restrictions and traffic disruptions during system installation could adversely impact the neighborhood. However, the alternative utilizes equipment that can be placed in unobtrusive areas, therefore it is not likely to be a high concern for residents or other members of the community. Oxidizer chemicals may pose a community concern.

4 0.4 Noise, Site access restrictions and traffic disruptions during system installation could adversely impact the neighborhood. However, the alternative utilizes equipment that can be placed in unobtrusive areas, therefore it is not likely to be a high concern for residents or other members of the community.

5 0.5

Overall Ranking 4.2 3.7 4.9Estimated Cost *

Alternative 4,In‐situ Aerobic Bioremediation

Alternative 5,In‐situ Chemical Oxidation Treatment

Alternative 6,Air Sparge and Soil Vapor Extraction

Alternative can include provisions for compliance monitoring (soil, groundwater, and soil‐vapor sampling).

Five to ten years needed to complete the remedial effort. This time period includes the design, permitting, setup, installation of the system, and the ongoing operation and maintenance of system equipment.








$1,100,000

Alternative can protect human health and the environment.




Five to ten years needed to complete the In‐situ remedial effort. This time period includes the design, permitting, setup, installation of the system, and the ongoing operation and maintenance of system equipment.

Three to five years needed to complete the In‐situ remedial effort. This time period includes the design, permitting, setup, installation of the system, and the ongoing operation and maintenance of system equipment.



Alternative can protect human health and the environment. Alternative can protect human health and the environment.




$2,250,000 $1,650,000







Alternative


DCA Evaluation Criteria Rank Value9 2.7

9 1.8

10 2.0

6 0.6

7 0.7

7 0.7

Overall Ranking 8.5Estimated Cost







Three to five years needed to complete the remedial effort. This time period includes the design, permitting, setup, installation of the systems, and the ongoing operation and maintenance of system equipment.




Combined alternatives can be designed to comply with applicable laws.

Combined alternatives include provisions for compliance monitoring (soil, groundwater, and soil‐vapor sampling).


Combined alternatives can protect human health and the environment.


$1,650,000

Excavation could be designed to remove the majority of contaminated soils in the source area, to a depth of the water table (approximately 13 feet), without shoring (assumes bank building removed by others). The soil would be transported to a disposal facility, creating risks during excavation, transport, and disposal. However, this is offset by the benefit of the removal of accessible soils with sorbed petroleum contamination. Following excavation, an AS/SVE system will begin remediation of soil and groundwater throughout the areas of the Site that contain elevated concentrations of petroleum contaminants. Contaminant‐mass removal rates are anticipated to be higher at the initiation of the treatment.

The excavation portion of this alternative (excavation only in the source area) provides a high permanence through source removal, followed by AS/SVE technology to quickly remove volatile contaminants from the vadose zone, which pose the concern for vapor intrusion. With the addition of oxygen to the subsurface, bioremediation also is enhanced. Over the long term, this Alternative removes the majority of the contaminant mass, resulting in a permanent solution.

Site contaminants would be physically removed and degraded, resulting in long‐term effectiveness. Site geology away from the source area is less problematic for AES and SVE.

Source‐area excavation would require some design engineering (slope stability) and permitting. This work would create construction hazards and would create worker‐exposure conditions to the Site contaminants. Alternative AS/SVE poses moderate short‐term risks as it requires drilling/trenching and related construction activities, which present some short‐term risks to human health, primarily to remediation‐system workers.

A source‐area excavation can be easily implemented, but will require design, permitting. Site access would be restricted and noise/traffic disruptions would occur. Likely limited to high concentration (source) areas. Backfilled areas would require compaction or future‐construction modification. The AS/SVE portion of the system can also be easily implemented, but system design and installation will increase the technical and administrative requirements. Site access would be restricted and noise disruptions could occur during system installation. Once the AS/SVE system is installed, regular operation and monitoring of the system would present minimal impact to the Site.

Alternative maximizes removal and disposal of contaminated soils. Noise, access restrictions, dust/odors, and traffic disruptions could impact the neighborhood. The AS/SVE system can utilize equipment that can be placed in unobtrusive areas, therefore it is not likely to be a high concern for neighborhood residents.

Alternative 7,Source‐Area Excavation, AS/SVE, Bio, MNA

The presented estimates are based on five years of monitoring/operation and G‑Logics experience on similar Sites. These estimates are subject to numerous assumptions based on currently the known information. These estimates should be used only for comparison use of the alternatives. For purposes of this Feasibility Study, order‐of‐magnitude costs have been used rather than detailed cost estimates. Alternative rankings are from 1 to 10, low to high. The presented estimates assume that G‐Logics will perform/manage all work discussed.



Feasibility-Level Cost EstimateAlternative 3, Soil ExcavationSumner Towing810 Alder Avenue, Sumner, WA

Item No. Source Area Excavation with Off-Site Disposal (1, 2) Quantity Units Unit Price Cost

1 Preliminary Design and PermittingSoil Engineer Study 1 LS $10,000 $10,000

Grading Permit 1 LS $4,000 $4,000

Shoring Design 1 LS $8,000 $8,000

Dewatering System Design 1 LS $8,000 $8,000

$30,000

2 Excavation and DisposalMonitoring Well Decommissioning 15 Each $600 $9,000

Excavation Contractor (Mobilization/Equipment Operating) (3) 35833 Tons $25 $895,833

Transportation and Disposal (4) 35833 Tons $70 $2,508,333

Overburden Excavation Handling and Backfill Material (5) 45833 Tons $20 $916,667

Resurfacing (Asphalt, Striping) 22000 SF $3 $55,000

Bank Building Demolition, Disposal, Asbestos Survey, (6) 1 SF $50,000 $50,000

Utility Termination 1 FA $12,500 $12,500

Shoring Along Kincaid and Alder Avenues (7, 8) 12000 VSF $79 $948,000

Easement and Right-of-way Leases for Shoring Tiebacks (8) 1 Each $75,000 $75,000

Property/Parking Rental/Relocation Fee (City of Sumner Property) (9) 1 Each $10,000 $10,000

G-Logics Field/Excavation Oversight & Expenses 2 Each $75,000 $150,000

Analytical (Soil and Water) 120 Each $180 $21,600

$5,651,933

3 Confirmation Sampling/Reporting/AdministrativeG-Logics Reporting/Communication/Project Planning and Management 1 Each $100,000 $100,000

$100,000

$5,781,933

Notes: 1 Assumes excavation of all contaminated soil between Kincaid and Alder Avenues (no excavation beneath Kincaid).2 Assumptions are based on Sections 4.2.3 and 6.0 of Feasibility Report.3 Volumes based on excavation areas of 125x155x25, 120x145x10, using multiplier of 1.5 cubic yards to tons.4 Material will not be designated as Dangerous Waste.5

6 Estimated Costs from Contractor and BuildingJournal.com, assuming 7,000 Sq. Ft. of building.7 Assumes Soldier Pile and Tieback methods.8 Estimate from Contractor/Experience.9 Estimate based on project experience.

Volumes based on the volumes specified above and an overburden excavation area of 120x145x10, using multiplier of 1.5 cubic yards to tons, Assumes overburden and backfill soils will be reused/compacted.

Table 6

ESTIMATE TOTALS

Subtotal

Subtotal

Subtotal

Feasibility-Level Cost Estimate Alternative 4, Aerobic BioremediationSumner Towing810 Alder Avenue, Sumner, WA

Item No. In-situ Aerobic Bioremediation (1, 2) Quantity Units Unit Price Cost

1 Preliminary Design and StudyPilot Study 1 LS $70,000 $70,000

G-Logics Task Activities and Project Management 1 Each $10,000 $10,000

$80,000

2 In-situ Installation and Injections System/Injection Point Installation and Injections (3) 3 Each $600,000 $1,800,000

Monitoring, Quarterly Groundwater Sampling, Analysis, assumes 5 years 20 Each $10,000 $200,000


G-Logics Field Tasks and Expenses 1 Each $40,000 $40,000

$2,050,000


$100,000

$2,230,000

Notes: 1 Assumes active remediation between Kincaid and Alder Avenues.2 Assumptions are based on Sections 4.2.3 and 6.0 of Feasibility Report.3 Amount based on contractor ROM estimates.4 Estimate based on project experience.

Table 7

Subtotal

Subtotal

Subtotal

ESTIMATE TOTALS

Feasibility-Level Cost EstimateAlternative 5, Chemical OxidationSumner Towing810 Alder Avenue, Sumner, WA

Item No. In-situ Chemical Oxidation (1, 2) Quantity Units Unit Price Cost

1 Preliminary Design and StudyPilot Study 1 LS $70,000 $70,000


$80,000

2 In-situ InjectionsSystem/Injection Point Installation and Chemical Injections (3) 3 Each $400,000 $1,200,000

Monitoring, Quarterly Groundwater Sampling, Analysis, assumes 5 years 20 Each $10,000 $200,000



$1,450,000


$100,000

$1,630,000

Notes: 1 Assumes active remediation between Kincaid and Alder Avenues.2 Assumptions are based on Sections 4.2.3 and 6.0 of Feasibility Report.3 Amount based on contractor ROM estimates.4 Estimate based on project experience.

Table 8

Subtotal

Subtotal

Subtotal

ESTIMATE TOTALS

Feasibility-Level Cost EstimateAlternative 6, AS/SVESumner Towing810 Alder Avenue, Sumner, WA

Item No. Air Sparge and Soil Vapor Extraction (1, 2) Quantity Units Unit Price Cost

1 SVE/AS Design & Pilot StudyPilot and Preliminary System Design

Pilot - SVE/AS Well and Monitoring Port Installations (construction and surface repairs) 1 Each $150,000 $150,000

System Equipment Installation and Placement 1 Each $10,000 $10,000

G-Logics Monitoring, Engineering, and Project Management 1 Each $20,000 $20,000

$180,000

2 SVE System InstallationSystem Installation and Activity Coordination

Permits, Bonding, Power Drop 1 Each $10,000 $10,000

SVE and AS Well Installations 1 Each $70,000 $70,000

System Trenching, Piping, and Surface Restoration 1 Each $200,000 $200,000



G-Logics Task Activities, Engineering, and Project Management 1 Each $25,000 $25,000

$390,000

3 System Operation and Remediation MonitoringMonitoring, Air/Groundwater Sampling & Analysis (Quarterly/5 years) 20 Each $15,000 $300,000

System Maintenance 1 Each $100,000 $100,000

G-Logics Project Management 1 Each $25,000 $25,000

$425,000


$100,000

$1,095,000

Notes: 1 Assumes active remediation between Kincaid and Alder Avenues.2 Assumptions are based on Sections 4.2.3 and 6.0 of Feasibility Report. 3 Estimate based on project experience.

Subtotal

Table 9

ESTIMATE TOTALS

Subtotal

Subtotal

Subtotal

Feasibility-Level Cost Estimate Alternative 7, Source Excavation, AS/SVE, and MNASumner Towing810 Alder Avenue, Sumner, WA

Item No. Excavation/Air Sparge-Soil Vapor Extraction, MNA (1, 2) Quantity Units Unit Price Cost

1 Source Area Excavation and Offsite DisposalMonitoring Well Decommissioning 9 Each $600 $5,400

Excavation Contractor (Mobilization/Equipment Operating)(3, 5) 6666 Tons $25 $166,658

Transportation and Disposal (4, 5) 6666 Tons $70 $466,643

Overburden Handling and Backfill Material (5) 6666 Tons $20 $133,327


G-Logics Field/Excavation Oversight & Expenses 1 Each $25,000 $25,000

Analytical (Soil and Water) 40 Each $180 $7,200

$814,228

2 AS/SVE Design & Pilot StudyPilot and Preliminary System Design

Pilot - SVE/AS Well and Monitoring Port Installations (construction and surface repairs) 1 Each $75,000 $75,000


G-Logics Monitoring, Engineering, and Project Management 1 Each $20,000 $20,000

$105,000

3 AS/SVE System InstallationSystem Installation and Activity Coordination

Permits, Bonding, Power Drop 1 Each $10,000 $10,000

SVE and AS Well Installations 1 Each $70,000 $70,000

System Trenching, Piping, and Surface Restoration 1 Each $200,000 $200,000


G-Logics Task Activities, Engineering, and Project Management 1 Each $20,000 $20,000

$350,000

4 System Operation and Remediation MonitoringMonitoring, Air/Groundwater Sampling & Analysis (Quarterly/5 years)* 20 Each $11,000 $220,000

System Maintenance 1 Each $20,000 $20,000

G-Logics Project Management 1 Each $25,000 $25,000

$265,000

5 Confirmation/MNA Sampling/Reporting/AdministrativeG-Logics Reporting/Communication/Project Planning and Management 1 Each $100,000 $100,000

$100,000

$1,634,228

In-situ Bioremediation

System/Injection Point Installation and Injections (7) 2 Each $125,000 $250,000

G-Logics Field Tasks and Expenses 1 Each $25,000 $25,000

$275,000

Notes: 1 Assumes targeted excavation of contaminated soil on Property and additional active remediation between Kincaid and Alder Avenue.2 Assumptions are based on Sections 4.2.3 and 6.0 of Feasibility Report. 3 Assumes bank building will not be removed and shoring not necessary.56 Estimate based on project experience. 7 Amount based on contractor ROM estimates.* Assumes 30 water and 4 Air Samples per event

Calculations based on a footprint of 8571 square feet, 14 feet thick, using a multiplier of 1.5.

Subtotal

Subtotal

ESTIMATE TOTALSSupplemental Bioremediation Enhancement

Table 10

Subtotal

Subtotal

Subtotal

Subtotal

GRAPH

Alternative 1, Institutional Controls

Alternative 1,Institutional

Controls

Alternative 2,Monitored Natural

Attenuation

Alternative 3,Excavation withOff-Site Disposal

Alternative 4,In-situ AerobicBioremediation

Alternative 5,In-situ Chemical

OxidationTreatment

Alternative 6,Air Sparge and Soil

Vapor Extraction

Alternative 7,Source-AreaExcavation,

AS/SVE, Bio, MNA

Rank 3.1 1.7 6.5 4.2 3.7 4.9 8.5 Cost $50,000 $150,000 $5,800,000 $2,250,000 $1,650,000 $1,100,000 $1,650,000

$0

$1,000,000

$2,000,000

$3,000,000

$4,000,000

$5,000,000

$6,000,000

$7,000,000

0

1

2

3

4

5

6

7

8

9

Bud

getin

g C

osts

MTC

A B

enef

it R

anki

ngs

Graph 1, Disproportionate Cost Analysis

APPENDIX A

Pro

ject

Nu

mb

er:

01-0

620

-J A

A M

ap

.vsd

Mapping Reference: Washington Department of Ecology Well Log Map

Sumner Towing

Sumner, WA

810 Alder Avenue

Appendix A, Drinking Water Well Location Map Note: This figure contains information in color. Black

& white photocopies may not be suitable for review.0 ft. 840 ft. 1400 ft. 2800 ft.

Approximate Scale: 1" = 1400'

Property

Legend

North Wells

Location of Drinking Water Wells

Drinking Water Well Identification

North 1

North 2North 3

South 4

South 2South 1

West 1

South 3

Mapped Groundwater Gradient

North 1 Logs

North 2 Logs

North 3 Logs

Construction (Group 1 of 3)

Construction Notice of Intent Number: SE54448

Decommissioning Notice of Intent Number: AE31427

Property Owner Name: St Andrews Catholic Church

Property Owner Address:

RESOURCE PROTECTION WELL REPORTThis is a report of the activities of a licensed Washington well driller and serves as the official record of work done within theborehole and casing and describes the amount of water encountered.

ConstructionType of Well: Geotech Soil BoringNumber of Wells in Group 1: 1 wellType of Work: NewMethod: AugerDrilling Start Date: 4/6/2015Drilling Completion Date: 4/6/2015Received by Ecology: 4/10/2015 9:46 AM

Dimensions:

Borehole Diameter: 8 inDepth of completed well: 21 ft 6 in

Dimensions:


Construction Details

Well Group 1 of 3Construction Notice of Intent Number: SE54448


Unique Ecology Well ID Tag Number: N/A


Property Owner Address: 1401 Valley Ave E, Sumner, WA 98390


Well Location:

Well Street Address:

City, State, Zip: WA

County: Pierce

Well Location:



County: Pierce

Township: 20N Range: 5E Section: 19 in the SW 1/4 of the NW 1/4

Well Head Elevation:

Elevation Datum:

Elevation Method:

Latitude (DD): Longitude (DD):

Datum:

Horizontal Coordinate Collection Method:

Elevation Method:


Datum:


Tax parcel No.:

Casings:

From Depth To Depth Type Diameter Stickup

N/A

Perforations:

Type Size TotalPerforations

FromDepth

ToDepth

N/A

Screens:

Manufacturer Type Dia-meter

SlotSize

FromDepth

ToDepth

N/A

Sand/Gravel Packings:

Material FromDepth

ToDepth

N/A

Additional Well Construction Information

None

Lithology

Layer: Describe by color, character, size of material and structure, andthe kind and nature of the material in each layer penetrated, with atleast one entry for each change of information.

From To Material

Lithology


From To Material

0 ft 0 in 10 ft 0 in Grey Sandy Silt with Gravels

Lithology


From To Material


10 ft 0 in 20 ft 0 in Grey Sandy Silt

Lithology


From To Material



20 ft 0 in 21 ft 6 in Wet Coarse Sand

Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Individual Well Details (Group 1 of 3)

Well Driller's Identifier Water Level

1 Dry Hole

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Dry Hole



1 Dry Hole


None

Well Construction Certification: I constructed and/or accept responsibility for construction of this well and its compliance with all Washingtonwell construction standards. Material used and information reported above are true to the best of my knowledge and belief.

Driller/Engineer/Trainee Printed Name: DAVID PUCKETT Drilling Company: Holocene Drilling Co

Driller or trainee License Number: 2769 Address: 11412 62nd Ave E

If trainee, Driller's License Number: City, State, Zip: Puyallup, WA, 98373

Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.

Decommissioning






Decommissioning Type of Well: Geotech Soil BoringNumber of Wells in Group 1: 1 wellType of Work: NewMethod: AugerDrilling Start Date: 4/6/2015Drilling Completion Date: 4/6/2015Received by Ecology: 4/10/2015 9:46 AM

Dimensions:

Diameter of borehole before decommissioning: 8 inWell depth before decommissiong: 21 ft 6 in

Dimensions:



Well Group 1 of 3 for DecommissioningConstruction Notice of Intent Number: SE54448






Well Location:



County: Pierce

Well Location:



County: Pierce



Elevation Datum:

Elevation Method:


Datum:


Elevation Method:


Datum:


Tax parcel No.:

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Additional Well Decommissioning Information

None

Lithology


From To Material

Lithology


From To Material


Lithology


From To Material



Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material





Well Driller's Identifier Decom Sealing Materials

1 Bentonite

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Bentonite



1 Bentonite


None


Driller/Engineer/Trainee Printed Name: DAVID PUCKETT Drilling Company: Holocene Drilling Co



Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.








Dimensions:


Dimensions:









Well Location:



County: Pierce

Well Location:



County: Pierce



Elevation Datum:

Elevation Method:


Datum:


Elevation Method:


Datum:


Tax parcel No.:

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A


None

Lithology


From To Material

Lithology


From To Material


Lithology


From To Material



Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material






1 Dry Hole

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Dry Hole



1 Dry Hole


None


Driller/Engineer/Trainee Printed Name: MATT GRAHAM Drilling Company: Holocene Drilling Co



Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.

Decommissioning







Dimensions:


Dimensions:









Well Location:



County: Pierce

Well Location:



County: Pierce



Elevation Datum:

Elevation Method:


Datum:


Elevation Method:


Datum:


Tax parcel No.:

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A


None

Lithology


From To Material

Lithology


From To Material


Lithology


From To Material



Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material






1 Bentonite

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Bentonite



1 Bentonite


None





Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.








Dimensions:


Dimensions:









Well Location:



County: Pierce

Well Location:



County: Pierce



Elevation Datum:

Elevation Method:


Datum:


Elevation Method:


Datum:


Tax parcel No.:

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A


None

Lithology


From To Material

Lithology


From To Material


Lithology


From To Material



Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material






1 Dry Hole

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Dry Hole



1 Dry Hole


None





Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.

Decommissioning







Dimensions:


Dimensions:









Well Location:



County: Pierce

Well Location:



County: Pierce



Elevation Datum:

Elevation Method:


Datum:


Elevation Method:


Datum:


Tax parcel No.:

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A


None

Lithology


From To Material

Lithology


From To Material


Lithology


From To Material



Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material




Lithology


From To Material






1 Bentonite

Casings:


N/A

Perforations:


FromDepth

ToDepth

N/A

Screens:


SlotSize

FromDepth

ToDepth

N/A


Material FromDepth

ToDepth

N/A

Lithology


From To Material




Lithology


From To Material






1 Bentonite



1 Bentonite


None





Th

e D

epar

tmen

t o

f E

colo

gy

do

es N

OT

War

ran

ty t

he

Dat

a an

d/o

r th

e in

form

atio

n o

n t

his

Wel

l Rep

ort

.

South 1 Logs

South 2 Logs

South 3 Logs

South 4 Logs

West 1 Logs

Documents

Feasibility Study Former Sumner Towing Property 810 Alder … · 2018-03-24 · , dated September 15, 2016, was used to develop this FS. Information collected during the RI is summarized