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ASPECT CONSULTING <br />24 FINAL PROJECT NO. AS190583A-08  MAY 21, 2025 <br />3.1.3 Removal and Investigation of Five USTs (1989-1990) <br />Five USTs at the mill property were permanently decommissioned by removal in <br />November and December 1989 (Landau, 1991). The USTs below are depicted on Figure <br />2-2. The capacity and contents of the USTs reportedly included the following: <br /> One 250-gallon unleaded-gasoline UST (Tank No. 68); <br /> One 1,000-gallon diesel-fuel UST (Tank No. 70); and <br /> Three 12,000-gallon Bunker C fuel-oil USTs (Tanks No. 71, 72, and 73). <br />As part of the UST decommissioning activities, soil and groundwater samples were <br />collected and submitted for laboratory analysis. The laboratory analytical results indicated <br />that releases of petroleum hydrocarbons had occurred at each of the UST locations. Based <br />on the data, contaminated soil was excavated from each UST pit location. <br />Following removal of the five USTs, Landau conducted a subsurface investigation in <br />November and December 1990 to further assess soil and groundwater quality in the <br />vicinity of the USTs. The investigation consisted of advancing seven soil borings, three <br />around UST No. 68 and four around UST No. 70; collecting soil samples for laboratory <br />analysis; completing the seven borings as groundwater monitoring wells; and conducting a <br />groundwater sampling event. During the 1990 investigation, petroleum-related compounds <br />were detected in soil and/or groundwater in these areas, as summarized in the Phase 2 <br />ESA (Aspect, 2013a). During the Phase 2 ESA, residual petroleum contamination was <br />identified in the UST 70 and USTs 71/72/73 areas, but not in the UST 68 area. In <br />2013–2014, K-C’s IA accomplished removal of contaminated material from the UST 70 <br />and USTs 71/72/73 areas, as described in Section 3.4. <br />3.1.4 Investigation in Vicinity of Old Paint Shop (1994) <br />In June 1994, a strong solvent odor and a thin floating layer of a viscous, brown-black <br />substance were observed within a localized length of utility trench excavated proximate to <br />the Central Maintenance Shop (also known as the salvage warehouse). The location is <br />reportedly near a historical paint shop that operated until the early 1970s. This area is <br />identified as HREC 5 in the Phase 1 ESA (AECOM, 2011). A grab sample of water within <br />the trench was collected for chemical analysis of gasoline-, diesel-, and oil-range TPH, <br />volatile organic compounds (VOCs), and polychlorinated biphenyls (PCBs). One VOC, <br />p-isopropyltoluene (i.e., 4-isopropyltoluene or p-cymene), was detected in the water <br />sample at a concentration of 11,000 micrograms per liter (µg/L), along with 380 µg/L <br />gasoline-range TPH. Landau interpreted the p-isopropyltoluene to be a component of <br />turpentine solvent used in the historical paint shop (Landau, 1994b). There are no marine- <br />based or vapor intrusion (VI)-based groundwater screening levels for 4-isopropyltoluene. <br />However, isopropylbenzene (cumene) has been used a surrogate compound for <br />p-isopropyltoluene, based on similar chemical structure, in regulatory programs outside <br />Washington State (Fehling et al, 2011). <br />Subsequently, Landau conducted an investigation in August 1994 to assess soil and <br />groundwater quality in the vicinity of the solvent occurrence. The subsurface investigation <br />consisted of advancing seven soil borings and collecting soil samples and reconnaissance