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ASPECT CONSULTING <br />PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 63 <br /> <br />concentrations that are protective of direct contact by industrial workers and soil leaching <br />to groundwater. <br />The values considered for each exposure pathway are described in the following <br />subsections. Table 5-3 presents the criteria incorporated into the soil PCL derivation for <br />the protection of industrial workers and the resulting PCLs applied for the RI. Table 5-4 <br />presents the criteria incorporated into the soil PCL derivation for the Warehouse Subarea <br />for the protection of commercial workers and the resulting PCLs applied for the RI. Note <br />that Tables 5-3 and 5-4 only include constituents that were detected in samples of either <br />soil or groundwater collected from the Upland Area; constituents not detected in either <br />medium are not presented to make the table more manageable. <br />5.3.2.1 Direct Contact Exposure Pathway <br />Soil concentrations protective of direct human contact under industrial land use are the <br />more stringent of the MTCA standard Method C soil cleanup levels 23 and, as described <br />below, selected MTCA Method A industrial soil cleanup levels. For the Warehouse <br />Subarea, soil concentrations protective of direct human contact for unrestricted land use <br />are the standard MTCA Method A or Method B unrestricted land use soil cleanup levels. <br />Most MTCA Method A soil cleanup levels are based on either direct contact using the <br />standard Method B equations (WAC 173-340-745[5][b]) or protection of groundwater for <br />drinking water (potable) use. The highest beneficial use of Upland Area groundwater is <br />discharge to marine water, not drinking water. Therefore, the Method A soil cleanup levels <br />based on groundwater protection are not applicable, and this pathway is addressed <br />separately using the most stringent groundwater criteria in accordance with MTCA <br />(described below). In addition, the Method A industrial soil cleanup levels based on direct <br />contact are covered by including standard Method C cleanup levels in the PCL derivation. <br />For the purposes of the RI, the Method A industrial soil values that were included in the <br />derivation of soil PCLs include arsenic (background-based), lead (no Method C value), <br />total PCBs (an applicable or relevant and appropriate requirement [ARAR] from the <br />federal Toxic Substances Control Act [TSCA]), and petroleum mixtures (TPH-G, TPH-D, <br />and TPH-O). <br />5.3.2.2 Soil Leaching to Groundwater Exposure Pathway <br />Soil concentrations protective of the highest beneficial use of groundwater were calculated <br />conservatively using Ecology’s variable parameter three-phase partitioning model (WAC <br />173-340-747(5)) and the most stringent groundwater criteria for protection of VI and <br />marine water quality (described above). Separate values were developed for unsaturated <br />and saturated soil (MTCA-default dilution factors of 20 and 1, respectively), in accordance <br />with WAC 173-340-747(4)(e). MTCA-default parameters (WAC 173-340-747(4) and (5)) <br />were used in the three-phase model, except that a Site-specific soil fractional organic <br />carbon content (foc) of 0.0079 (0.79 percent) was used for calculating soil-water partition <br />coefficients (Kd = Koc × foc) for organics, in accordance with WAC 173-340-747(5)(b)(i). <br />This is the average foc value from 24 Upland Area soil samples collected during the 2012 <br /> <br />23 From Ecology’s Cleanup Level and Risk Calculation (CLARC) database (February 2023). <br />https://fortress.wa.gov/ecy/clarc/CLARCHome.aspx