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ASPECT CONSULTING <br />PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 61 <br /> <br />5.3 Development of Soil, Groundwater, and Air Preliminary <br />Cleanup Levels <br />Sections 5.3.1, 5.3.2, and 5.3.3 describe the derivation of PCLs for groundwater and soils, <br />and air, respectively. In accordance with MTCA, PCLs are not set at concentrations less <br />than the analytical practical quantitation limit (PQL) or natural background conditions. <br />Points of compliance where the PCLs apply are discussed in Section 8. <br />5.3.1 Groundwater PCLs <br />Because drinking water is not a practicable future use for groundwater at the Upland Area, <br />the groundwater PCLs address the most stringent criteria for protection of the adjacent <br />marine water body (East Waterway) and protection from VI into current and future <br />structures (indoor air) on the property. However, for the purposes of the RI, groundwater <br />cleanup levels based on drinking water (potable) use are applied if surface water quality <br />criteria are not available, in accordance with WAC 173-340-720(6)(b)(i). Sections 5.3.1.1 <br />and 5.3.1.2 describe the criteria for marine protection and protection against VI, <br />respectively, which are incorporated into the groundwater PCLs. Section 5.3.1.3 describes <br />the application of potable groundwater criteria. For arsenic, a Site-specific background <br />concentration was established at 9 µg/L and this background value is used as the <br />groundwater PCL for the RI (Appendix E). <br />Based on an evaluation of the metals data from unfiltered groundwater samples versus <br />filtered groundwater samples (“total” versus “dissolved” metals data, respectively) <br />(Aspect, 2014e), Ecology determined that dissolved metals are the appropriate <br />measurement to represent groundwater quality for the Upland Area. Consequently, for this <br />RI/FS, the groundwater PCLs for metals apply to dissolved metals data. In accordance <br />with the RI/FS Work Plan prepared prior to Ecology’s determination, the RI groundwater <br />samples were analyzed for total metals, and unfiltered samples with total metal(s) detected <br />at concentrations greater than the PCLs were subsequently also analyzed for dissolved <br />metals. The concentration resulting from a total metals analysis will generally be greater <br />than the concentration resulting from a dissolved metals analysis of the same groundwater <br />sample. Therefore, for samples lacking a dissolved metals analysis, total metal(s) <br />concentrations less than the PCL for that dissolved metal comply with the PCL. The data <br />tables and mapping in this report apply that convention. <br />The federal and state water quality criteria for ammonia are established for the un-ionized <br />form (toxic form); therefore, groundwater PCLs apply to un-ionized ammonia not total <br />ammonia. <br />Table 5-1 presents the water quality criteria incorporated into the groundwater PCL <br />derivation, and the resulting most stringent groundwater PCLs to be applied for the RI to <br />the industrial use area of the Upland Area, including the City Utility Property and Norton <br />Terminal. Table 5-2 presents the water quality criteria incorporated into the groundwater <br />PCL derivation for the Warehouse Subarea, which considers protection of vapor intrusion <br />for unrestricted land use in consideration of potential future repurposing of the warehouse <br />for commercial uses. Note that Tables 5-1 and 5-2 only include constituents that were <br />detected in samples of either soil or groundwater collected from the Upland Area;