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3rd Interim Action Construction Report <br />Kimberly-Clark Upland Site <br /> 0121049.080.084 <br />July 30, 2024 4-1 landauinc.com <br />4.0 COMPLIANCE MONITORING <br />MTCA requires compliance monitoring for all cleanup actions, as described in WAC 173-340-410. <br />Compliance monitoring is conducted for the following three purposes: <br />• Protection monitoring to confirm that human health and the environment are adequately <br />protected during construction and operation and maintenance of the cleanup action. <br />• Performance monitoring to confirm that the cleanup action has attained cleanup standards and <br />any other performance standards. <br />• Confirmational monitoring to confirm the long-term effectiveness of the cleanup action once <br />the cleanup standards and other performance standards have been attained. <br />Compliance monitoring for the Interim Action was limited to protection monitoring and performance <br />monitoring for verification that the Project scope is completed as planned. Subsequent remedial <br />investigation work at the Upland Area will evaluate the effectiveness of the Interim Action relative to <br />final cleanup standards for the Upland Area, which will inform development of the final cleanup action. <br />4.1 Protection Monitoring <br />Protection monitoring implemented during the Interim Action included measures for the protection of <br />human health and protection of the environment. <br />4.1.1 Protection of Human Health <br />Monitoring for protection of human health addresses worker safety for activities related to <br />construction, operation, and maintenance of the cleanup action and was addressed in a Site-specific <br />health and safety plan (HASP) developed by the contractor, which was also adopted by additional <br />personnel onsite. Additionally, a Landau-specific project HASP was developed during preparation of the <br />Work Plan. The HASPs were implemented to monitor and mitigate physical and chemical hazards <br />associated with Site activities, consistent with the requirements of WAC 173-340-810. <br />4.1.2 Protection of the Environment <br />Environmental protection monitoring was conducted during the construction activities. This included <br />monitoring for dust, preparation and implementation of a stormwater pollution prevention plan <br />(SWPPP), and implementation and monitoring of best management practices (BMPs) to minimize dust <br />generation and/or control stormwater runoff from contaminated soil cleanup actions during <br />construction. During construction, a certified construction erosion and sediment control lead (CESCL) <br />monitored performance of the BMPs and recommended changes in approach or application, if <br />necessary. The CESCL also visually monitored the Site to verify that stormwater runoff was not being <br />impacted by Site activities. <br />The Port also conducted quantitative dust monitoring throughout the duration of the Project. Dust <br />monitoring was conducted on days when intrusive or site grading activities were conducted and when <br />there was no recorded precipitation. Daily dust readings were collected upwind, adjacent to, and