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

ASPECT CONSULTING PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 53 achieve the environmental cap requirements prescribed in the CAP Memorandum for the Utility Property.19 4.5 Groundwater pH Monitoring during CM Removal In January 2018, Ecology notified K-C of its determination that the CM placed across 32 acres of the Site in 2013 (see Section 2.2.3.1) violated state and/or local regulations pertaining to solid waste handling and groundwater quality. Ecology further determined that the CM could not remain on-Site and comply with applicable local, state, and federal laws, and requested K-C to respond as to its willingness to remove all of the material (Ecology, 2018). In response to Ecology’s determination that the CM cannot remain on-Site, K-C indicated its willingness to remove it subject to development of a feasible local off-Site disposition plan (K-C, 2018b). The CM removal did not constitute a MTCA remedial action and was not completed under the Agreed Order for the Site. Rather, it was completed as a solid-waste removal project in accordance with the Plan of Operations for Crushed Material Removal (K-C, 2018c) that K-C prepared in consultation with the local solid waste authority, Snohomish Health District (SHD). The Plan of Operations described guidance and procedures for excavation, transportation, and disposition activities throughout complete removal of the CM. The CM removal project went through SEPA review by the City, and the City then issued permits to K-C authorizing the CM removal work. Between June and October 2020 and concurrent with the second IA, K-C conducted complete removal and off-Site disposition of nearly 252,000 tons of CM. Of the 252,000 tons of CM removed, approximately 249,000 tons (almost 99 percent) were recycled for resale by Snohomish County facilities regulated by SHD, and 3,000 tons were deemed a non-recyclable mixed waste that was properly disposed of at the Roosevelt Regional Subtitle D landfill in Roosevelt, Washington. Following removal of the CM, K-C imported approximately 150,000 tons of uncontaminated dredge sand20 for placement, grading, and compaction across the 32 acres from where CM was removed. The SHD oversaw and reviewed the removal action over its 6-month duration, including conducting visits to the local recycling facilities that processed and recycled the CM for resale. Once all CM was removed, the Engineer of Record, John N. Smith, PE, with David Evans and Associates, Inc., issued a Certification of Completion to confirm that the CM Removal Project was complete (DEA, 2020). At the end of the project, SHD provided to K-C confirmation (SHD, 2021) that the CM removal project was completed in accordance with the conditions agreed to in the Plan of Operations. 19 Based on project plans and specifications http://www.bxwa.com/bxwa_toc/pub/263/ev33_port_gardner_storage_faci_92395/info.php 20 The backfill material used on the site is from the Port of Everett’s Parcel O Dredge Sand generated by the U.S. Army Corp of Engineers from navigational dredging of the Snohomish River. Analytical testing of this material showed that it is below preliminary soil cleanup levels for the contaminants of potential concern identified at the site (Aspect, 2019a).