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3rd Interim Action Construction Report <br />Kimberly-Clark Upland Site <br /> 0121049.080.084 <br />July 30, 2024 2-4 landauinc.com <br />the Cadman Sand and Gravel pit #D345. Results for nickel did not meet import fill criteria by a direct <br />comparison to the Work Plan criteria; results for other analytes provide satisfactory import fill data. As <br />suggested by Ecology, a 95UCL was calculated for the nickel data sets using EPA ProUCL 5.1 software; <br />the 95UCL for nickel was 28.45 mg/kg. This calculated value is less than the applicable import fill criteria <br />and indicates that these results provide satisfactory import fill data for material represented by these <br />samples. <br />2.2.2.5 Mandan Pit (a) <br />As presented in the December 7, 2021 letter prepared by Aspect Consulting (Aspect), 14 CSBC <br />characterization samples (representative of 10,000 CY) and 14 structural fill samples (representative of <br />10,000 CY) were collected from the Granite Construction Mandan Pit. Results for copper and nickel did <br />not meet import fill criteria by a direct comparison to the Work Plan criteria; results for other analytes <br />provide satisfactory import fill data. As presented in the letter, the nickel and copper data were <br />statistically evaluated by calculating a 95UCL for the nickel data sets using EPA ProUCL 5.1 software; the <br />95UCL for nickel was 28.45 mg/kg. This calculated value is less than the applicable import fill criteria and <br />indicates that these results provide satisfactory import fill data for material represented by these <br />samples. <br />2.2.2.6 Mandan Pit (b) <br />As presented in the March 29, 2022 letter prepared by Aspect, an additional four CSBC characterization <br />samples (representative of an additional 4,000 CY) and 10 additional structural fill samples <br />(representative of an additional 10,000 CY) were collected from the Granite Construction Mandan Pit. Of <br />the four additional CSBC samples and 10 additional structural fill samples collected for this submittal, <br />one analytical result for mercury did not meet import fill criteria by a direct comparison to the Work <br />Plan criteria; results for other analytes provide satisfactory import fill data. As presented in the summary <br />letter, this mercury result was less than two times the criteria and is suspected to be within the range of <br />natural background concentrations; these results were determined to provide satisfactory import fill <br />data for material represented by these samples. <br />2.2.2.7 Other Materials <br />Additional materials imported to the Site during the Project included quarry spalls, pea gravel, and rip <br />rap. Consistent with Ecology’s guidance, because these materials were washed and did not include any <br />fraction smaller than ¼-inch, laboratory analysis for comparison to import fill criteria was not necessary. <br />Use of these materials was consistent with project plans, except for placement of quarry spalls in areas <br />where concrete structures were left in place and/or void spaces beneath existing structures were filled. <br />2.2.3 Abandoned Pipe Decommissioning <br />Abandoned pipes were decommissioned during Site grading activities to support the long-term <br />effectiveness of the grading activities and to reduce the risk of contamination being spread via <br />preferential pathways to surface water. Existing abandoned underground pipes previously identified on <br />historical plans within 75 feet (ft) inland of the shoreline were demolished by filling completely with