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ASPECT CONSULTING <br />52 FINAL PROJECT NO. AS190583A-08  MAY 21, 2025 <br />whether there is contaminated soil that requires excavation and off-Site disposal prior to <br />the City’s filling and abandonment of the swale. In one test pit, the excavator bucket broke <br />an 8-inch-diameter concrete pipe at approximately 3 feet below ground surface. The pipe, <br />which ran from east to west, appeared to contain a small amount of water. This broken <br />pipe was decommissioned using procedures described in the Work Plan for Second <br />Interim Action (Aspect, 2019b). <br />The sampling results documented concentrations of selected metals (Arsenic, copper, <br />nickel, and zinc) in soil exceeding preliminary cleanup levels (PCLs) applied in this <br />RI/FS. However, there were no exceedances of MTCA industrial PCLs based on human <br />direct contact at any location in the swale. Concentrations of TPH and PAHs in the <br />samples were below respective PCLs. <br />Following discussion with Ecology, the City agreed with Ecology to take the following <br />remedial actions—documented in a Cleanup Action Plan (CAP) Memorandum <br />(Floyd|Snider, 2021)—to ensure that the conditions at the Utility Property are protective of <br />human health and the environment and will be included in the K-C Upland Area CAP as <br />the only remedial requirements applicable to the Utility Property. The CAP Memorandum <br />for the City Utility Property is included as Appendix D. <br />The City grubbed the swale area to remove vegetation and then backfilled it with the <br />uncontaminated sand. A temporary earthen berm was then constructed along the southern <br />property boundary to separate drainage on the Utility Property from the Port’s property to <br />the south. The entire Utility Property, including the swale, will eventually be paved except <br />for areas of landscaping or open space and the stormwater and combined sewer treatment <br />and storage structures. Any areas that are not contained under paving must have data <br />showing that surface materials (within the top 3 feet) meet MTCA Method A industrial <br />cleanup standards. The City will apply an Environmental Covenant on the Utility Property <br />requiring its use remain industrial and requiring maintenance of pavement and clean <br />surface materials in landscaped areas (Floyd|Snider, 2021; Appendix D). <br />In 2024, the City is undertaking demolition of selected existing waste treatment <br />infrastructure, including the above-grade portions of the effluent pump station building, <br />the gravity thickener buildings, metal-frame storage building, process mechanical <br />infrastructure, chemical storage tanks, above-grade conveyance pipes, and other interior <br />fixtures throughout the facility. The project includes pre-demolition abatement of <br />regulated building materials identified in the City’s regulated building materials <br />assessment for the facility. Subgrade pipelines and tanks to be retained will be video- <br />inspected and cleaned to remove residual process materials or scale, with chemical testing <br />and proper disposition of materials removed. Likewise, soils requiring excavation to <br />accomplish demolition or utility replacement will be chemically tested and disposed of <br />properly. The parking lot on the northeast side of the parcel will remain largely <br />unchanged. Areas disturbed by demolition will be repaved following construction to