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ASPECT CONSULTING <br />60 FINAL PROJECT NO. AS190583A-08  MAY 21, 2025 <br />In addition to these pathways, contaminants in soil can leach to groundwater, acting as a <br />secondary source. <br />The K-C Upland Area qualifies for an exclusion from conducting a terrestrial ecological <br />evaluation (TEE) in accordance with WAC 173-340-7491(1)(b). That exclusion specifies <br />that no TEE is required if: <br />“All soil contaminated with hazardous substances is, or will be, covered by <br />buildings, paved roads, pavement, or other physical barriers that will prevent <br />plants or wildlife from being exposed to the soil contamination. To qualify for <br />this exclusion, an institutional control shall be required by the department <br />under WAC 173-340-440. An exclusion based on planned future land use shall <br />include a completion date for such development that is acceptable to the <br />department.” <br />These conditions will be met for the planned future use of the Upland Area. Under the <br />planned future land use, soil across the entire Upland Area, contaminated or not, will be <br />covered by pavement, buildings, and/or landscaped areas (soil covers) that provide an <br />effective physical barrier to prevent plants or wildlife from being exposed to underlying <br />soil contamination where present. <br />In conjunction with the environmental capping, an institutional control (environmental <br />covenants) would be executed by the City and by the Port, in accordance with WAC <br />173-340-440, requiring the periodic inspection and maintenance of the environmental caps <br />after the cleanup action is implemented. These cleanup elements would be incorporated <br />into the CAP for the Upland Area. The completion date for achieving the required <br />containment of the Upland Area soil will be determined with Ecology by the time the CAP <br />is executed. <br />5.2.2 Groundwater Exposure Pathways <br />Section 5.1 of the RI/FS Work Plan (Aspect, 2013c) explains the rationale for classifying <br />the Upland Area groundwater as nonpotable water in accordance with WAC <br />173-340-720(2). That information is not reiterated herein. Because of this classification, <br />potable use of groundwater is not considered a potentially complete exposure pathway. <br />Current and future potentially complete exposure pathways for groundwater include the <br />following: <br /> Construction or utility workers contacting contaminated groundwater during <br />excavation or other construction-related activities; <br /> Industrial or commercial workers (including construction workers) inhaling indoor or <br />outdoor air containing contaminants that have volatilized from shallow groundwater; <br /> Marine ecological receptors receiving direct exposure to groundwater contaminants <br />discharged to sediment or surface water; and <br /> Higher-trophic-level marine organisms or humans consuming marine ecological <br />receptors contaminated by groundwater discharges to sediment or surface water.