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3rd Interim Action Construction Report <br />Kimberly-Clark Upland Site <br /> 0121049.080.084 <br />July 30, 2024 2-7 landauinc.com <br />south, which was within the ExxonMobil/ADC MTCA cleanup site. Soil excavated from the <br />ExxonMobil/ADC site was managed separately in coordination with Ecology and was guided by the <br />ExxonMobil/ADC SGMP. <br />Excavated soil generally included 2–5 ft of clean sand fill placed during the 2nd Interim Action and was <br />underlain by hydraulic fill. Field screening was conducted to determine when soil was suitable for on-site <br />backfill; generally, all of the recent sand fill and some of the underlying hydraulic fill was reused onsite. <br />Soil reused onsite was placed only in areas ultimately covered by the low-permeability cap and was <br />placed in approximately the same vertical horizon it originated. However, field screening also indicated <br />significant quantities of potentially contaminated soil, geotechnically unsuitable soil, and in-place <br />concrete structures and rubble. Potentially contaminated soil was consistent with contaminated soils <br />previously observed at the Site; no “new conditions” were observed. Additionally, no crushed <br />demolition debris (crushed material or “CM”) as identified and removed during the 2nd Interim Action <br />was observed. <br />Potentially contaminated and geotechnically unsuitable soil was managed as one material during <br />construction activities; in total, 17,850 tons of soil was excavated and removed from the Site for offsite <br />disposal as non-hazardous waste. In addition, 7.1 million gallons of groundwater was removed from <br />excavations was disposed of in the City of Everett sanitary sewer system. <br />2.6.1 Management of Unsuitable Excavated Soils <br />Excavated materials not reused onsite were managed in accordance with the SGMP. These materials <br />included potentially contaminated soil, geotechnically unsuitable soil, concrete, and wood debris. <br />Following excavation and field screening, potentially contaminated soil and geotechnically unsuitable <br />soil was transported to an onsite temporary stockpile cell. Temporary soil stockpile cells were <br />constructed to contain the soil and prevent rain and stormwater from being in contact with the <br />contaminated soil; details for the temporary soil stockpile construction details are provided in as-built <br />sheets C1.4. Soil for disposal was loaded from the temporary stockpile into containers or trucks for <br />transport to the disposal facility. <br />Soil representative of potentially contaminated and geotechnically unsuitable soil observed throughout <br />the project was sampled for waste characterization purposes. Waste characterization samples were <br />analyzed for diesel- and oil-range total petroleum hydrocarbons (TPH-D/O); benzene, toluene, <br />ethylbenzene, and xylenes (BTEX); PCBs; semivolatile organic compounds (SVOCs); Resource <br />Conservation and Recovery Act (RCRA) 8 metals; and sulfate. The analytical results were provided to <br />Republic Services, Waste Management, and Cadman for development of waste profiles. Depending on <br />container and truck availability, soil was exported to all three of these facilities as non-hazardous waste. <br />Waste characterization laboratory analytical reports are included with the waste profiles presented in <br />Appendix E, and field-screening indicated that these samples were representative of potentially <br />contaminated soil that was removed from the Site during the duration of the project.