3815_PGSF WMVD Pkg 2_Vol 4-2_03.03.2026_BXWA_Certified

ASPECT CONSULTING PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 35 Waterway in 1995. The spill was contained, cleaned up, inspected by Ecology, and the matter closed (Emergency Response Notification System [ERNS] No. 547098). 3.2 Independent Phase 2 ESA (2012) Aspect (2013a) performed an independent Phase 2 ESA in 2012 to address data gaps identified from the prior environmental investigations summarized in Section 3.1, including the RECs/HRECs identified in AECOM’s (2011) Phase 1 ESA. The Phase 2 ESA report can be viewed on Ecology’s website using the weblink provided in Section 1. K-C completed the Phase 2 ESA as an independent remedial action prior to execution of the Agreed Order; however, it was conducted with informal consultation from Ecology, and it was intended to meet the requirements for substantial equivalence under WAC 173- 340-515 involving independent remedial actions. Samples were taken and laboratory analyses were conducted consistent with MTCA requirements. The independent Phase 2 ESA supported, and did not foreclose, selection of a cleanup action consistent with MTCA requirements. The Phase 2 ESA was conducted as a phased investigation program in three rounds (February, May–July, and August–September of 2012). In February 2012, Aspect conducted Round 1 of the Phase 2 ESA to initiate the evaluation of environmental conditions in three areas of the Upland Area. A Work Plan for the independent Phase 2 ESA was subsequently prepared (Aspect, 2012a). This Work Plan can be viewed on Ecology’s website using the weblink provided in Section 1. The objectives of the Work Plan were to:  Synthesize the prior environmental investigation and cleanup information for the Upland Area (including the Round 1 data);  Identify data gaps in the prior environmental investigation/cleanup information and other historical information; and  Define an environmental assessment scope of work to address the identified data gaps. K-C submitted a draft Work Plan to Ecology for review and comment. Ecology provided expedited review and written comments on the draft Work Plan (Ecology, 2012a). Many but not all of the comments were incorporated, and a final Work Plan was prepared (Aspect, 2012a). The assessment scope of work included in the Work Plan constituted Round 2 of the independent Phase 2 ESA. The Work Plan acknowledged that, following completion of the assessment scope of work it defined, an additional round of data collection may be warranted to further define the contaminant nature and extent in the Upland Area. Based on findings from Rounds 1 and 2, an Addendum to the Phase 2 ESA Work Plan (Aspect, 2012b) was prepared, which outlined the rationale and scope of work for an additional round (Round 3) of assessment. The Round 2 data and proposed Round 3 scope of work were discussed with Ecology at that time. In total, the Phase 2 ESA included completion of 106 soil borings, 49 of which were completed as groundwater monitoring wells, completion of about 1,200 chemical analyses of soil and 570 chemical analyses of groundwater, and collection of site-wide hydrogeologic information including completion of a tidal study. The soil data collected