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ASPECT CONSULTING <br />30 FINAL PROJECT NO. AS190583A-08  MAY 21, 2025 <br />but was detected at concentrations of 53,000 mg/kg and 7,000 mg/kg in the 7.5-foot and <br />9-foot soil samples, respectively. <br />According to the report, “groundwater and pilings driven randomly spaced at about <br />8-feet bgs impeded further excavation; therefore, soil excavation was suspended, and the <br />pits backfilled with pea gravel to approximately 1 foot above groundwater. The remaining <br />excavations were filled to grade with clean backfill material.” <br />The report also states that additional TPH-contaminated soil identified beneath the boiler <br />room was removed, but does not provide location information or verification soil sample <br />data for the excavation. Likewise, the report states that 15 cubic yards of lead- <br />contaminated soil was removed from beneath the Firing Range building, but does not <br />provide location information or verification soil sample data for the excavation. <br />In August 1997 through October 1998, following demolition of the facility structures, <br />Foster Wheeler conducted characterization soil sampling and analysis from the USTs area, <br />adjacent bilge water tank location and flammable material storage shed, and the Firing <br />Range area. Twenty-four drilled soil borings were advanced to depths of approximately <br />10 feet bgs in the Building 1 area to characterize soil quality around the USTs, bilge water <br />tank location, and flammable material storage shed. Four additional hand-augered borings <br />were also sampled to depths of 1.25 feet bgs around the flammable material storage shed. <br />Twenty-one hand-augered borings were sampled to depths of 3 feet bgs at the Firing <br />Range. The first 14 borings were sampled in September 1997, and the last seven in <br />October 1997; the report presents locations only for the first 14 borings. <br />Following soil removal and site restoration, two monitoring wells were installed in the <br />most contaminated areas to monitor groundwater quality as a reflection of the soil removal <br />effectiveness. The wells were identified as North Well and South Well, but the report does <br />not present locations for them. The January 1998 groundwater samples collected from the <br />two wells contained no detectable TPH or BTEX, and concentrations of the polycyclic <br />aromatic hydrocarbons (PAHs) acenaphthene, fluorene, and naphthalene (up to 4 µg/L) <br />were less than respective groundwater screening levels. <br />3.1.8 Investigation of Bulk Fuel Facilities (1998) <br />On behalf of K-C, Chevron, Texaco, and BNSF, Pacific Environmental Group (PEG) <br />conducted a subsurface investigation to assess petroleum hydrocarbon contamination <br />previously encountered adjacent to the City of Everett Combined Sewer Outfall (CSO) <br />line which runs east-west immediately south of the K-C distribution warehouse in the <br />southeast corner of the mill property, within the Everett Avenue easement. In 1995, <br />petroleum product had been observed discharging from the CSO line into the East <br />Waterway. Investigation determined that petroleum product was entering a segment of the <br />CSO line that was constructed of clay tiles that had settled and cracked. In summer 1996, <br />portions of the CSO line were replaced, and the remaining portions of it were slip-lined. <br />Reportedly, 1,450,800 gallons of water and 23,050 gallons of petroleum product were <br />removed by dewatering conducted during the construction (AMEC, 2010). <br />The purpose of the PEG (1998) investigation was to evaluate soil and groundwater quality <br />in the vicinity of petroleum product bulk facilities located north of the CSO (Standard Oil