REMEDIAL INVESTIGATION/FOCUSED FEASIBILITY STUDY …

975 5th Avenue Northwest, Issaquah, Washington 98027

Tel: (425) 295-0800 Fax: (425) 295-0850

www.farallonconsulting.com

REMEDIAL INVESTIGATION/FOCUSED FEASIBILITY

STUDY REPORT AND CLEANUP ACTION PLAN

WESTWAY CLEANERS

10016 #A EDMONDS WAY

EDMONDS, WASHINGTON

Submitted by:

Farallon Consulting, L.L.C. 975 5

th Avenue Northwest

Issaquah, Washington 98027

Farallon PN: 133-001

For:

Mr. William C. Nelson, III 16508 Northeast 79

th Street

Redmond, Washington 98052

August 28, 2014

Prepared by:

Anna R. Sigel, E.I.T.

Staff Engineer

Andrew E. Seutter

Senior Engineering Geologist

Reviewed by:

Gerald J. Portele

Principal

G:\Projects\133 William C. Nelson, III\133001 Westway Cleaners\Reports\RI-FFS and CAP\RI-FS Report and Cleanup Action Plan.docx

Quality Service for Environmental Solutions

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TABLE OF CONTENTS

1.0 INTRODUCTION.............................................................................................. 1-1 1.1 PURPOSE ................................................................................................ 1-1 1.2 REPORT ORGANIZATION ................................................................... 1-2

2.0 SITE BACKGROUND ...................................................................................... 2-1 2.1 SITE LOCATION AND DESCRIPTION ............................................... 2-1

2.2 SITE HISTORY AND NEARBY PROPERTIES ................................... 2-1 2.3 SITE GEOLOGY AND HYDROGEOLOGY......................................... 2-1

3.0 REMEDIAL INVESTIGATION ...................................................................... 3-1 3.1 DATA GAPS ........................................................................................... 3-1

3.2 RI FIELD ACTIVITIES .......................................................................... 3-1 3.2.1 Key Engineering—1999 .............................................................. 3-1

3.2.2 Associated Earth Sciences, Inc.—2002 ....................................... 3-1 3.2.3 Farallon—July 2008..................................................................... 3-1 3.2.4 Farallon—2013 ............................................................................ 3-2

3.2.5 Farallon—2014 ............................................................................ 3-2 3.3 RI RESULTS ........................................................................................... 3-2

3.3.1 Limited Phase II Site Assessment—July 1999 ............................ 3-2 3.3.2 Subsurface Investigation and Subslab Soil Vapor

Monitoring—July 2008 ................................................................ 3-2

3.3.3 Subsurface Investigation and Subslab Soil Vapor

Monitoring—July 2013 ................................................................ 3-3

3.3.4 Additional Subsurface Soil Characterization —April 2014 ........ 3-3

4.0 CONCEPTUAL SITE MODEL ....................................................................... 4-1 4.1 CONFIRMED AND SUSPECTED SOURCE AREAS .......................... 4-1 4.2 AFFECTED MEDIA ............................................................................... 4-1

4.3 CONTAMINANT FATE AND TRANSPORT ....................................... 4-2 4.3.1 Environmental Fate of PCE in the Subsurface ............................ 4-2

4.4 PRELIMINARY EXPOSURE ASSESSMENT ...................................... 4-3 4.4.1 Soil Pathway ................................................................................ 4-3

4.4.2 Vapor Pathway ............................................................................. 4-3

5.0 EVALUATION OF POTENTIALLY FEASIBLE CLEANUP

ALTERNATIVES .............................................................................................. 5-1 5.1 REMEDIAL ACTION OBJECTIVES .................................................... 5-1

5.2 EVALUATION PROCESS ..................................................................... 5-1 5.3 FOCUSED SCREENING OF POTENTIAL TREATMENT

TECHNOLOGIES ................................................................................... 5-3

5.3.1 Cleanup Alternative 1—SVE System .......................................... 5-4 5.3.2 Cleanup Alternative 2—Soil Excavation and Off-Site

Disposal........................................................................................ 5-5



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5.3.3 Cleanup Alternative 3—Subslab Depressurization and

Venting System ............................................................................ 5-5 5.3.4 Cleanup Alternative 4—No Action ............................................. 5-6

6.0 RECOMMENDED CLEANUP ALTERNATIVE .......................................... 6-1

7.0 CLEANUP ACTION PLAN ............................................................................. 7-1 7.1 CLEANUP ACTION OBJECTIVES ...................................................... 7-1 7.2 CLEANUP ACTION REGULATORY STANDARDS .......................... 7-1 7.3 PROPOSED CLEANUP ACTION SCOPE OF WORK ......................... 7-2 7.4 PERFORMANCE MONITORING AND CONFIRMATION SOIL

SAMPLING ............................................................................................. 7-3

8.0 BIBLIOGRAPHY .............................................................................................. 8-1

9.0 LIMITATIONS .................................................................................................. 9-1

FIGURES

Figure 1 Site Vicinity Map

Figure 2 Site Location Site

Figure 3 Soil Boring Location Map

Figure 4 Site Soil Analytical Results

TABLES

Table 1 Summary of Soil Analytical Results for Halogenated Volatile Organic Compounds

Table 2 Summary of Soil Vapor Analytical Results for Halogenated Volatile Organic

Compounds

Table 3 Cleanup Technology Screening

Table 4 Summary of Cleanup Action Alternative Evaluation

APPENDICES

Appendix A Boring Logs

Appendix B Terrestrial Ecological Evaluation Exclusion



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ACRONYMS AND ABBREVIATIONS

bgs below ground surface

CAP Cleanup Action Plan

DCE dichloroethene

Ecology Washington State Department of Ecology

EPA U.S. Environmental Protection Agency

Farallon Farallon Consulting, L.L.C.

FFS Focused Feasibility Study

HVOCs halogenated volatile organic compounds

Key Engineering Key Engineering, Inc.

mg/kg milligrams per kilogram

µg/l micrograms per liter

MTCA Washington State Model Toxics Control Act Cleanup Regulation

PCE tetrachloroethene

PID photoionization detector

ppmv parts per million volume

Site Westway Cleaners facility at 10016 #A Edmonds Way in Edmonds,

Washington action

SVE soil vapor extraction

TCE trichloroethene

TEE Terrestrial Ecological Evaluation

VCP Voluntary Cleanup Program

WAC Washington Administrative Code

1,1-DCE 1,1-Dichloroethene

cis-1,2-DCE cis-1,2-Dichloroethene

trans-1,2-DCE trans-1,2-Dichloroethene



1-1

1.0 INTRODUCTION

Farallon Consulting, L.L.C. (Farallon) has prepared this Remedial Investigation (RI)/Focused

Feasibility Study (FFS) Report and Cleanup Action Plan (CAP) to document the results of an

investigation of soil and subslab soil gas, evaluate and screen technically feasible remedial

alternatives, present appropriate cleanup standards, and recommend implementation and

confirmation of a cleanup action alternative at the Westway Cleaners facility at 10016 #A

Edmonds Way in Edmonds, Washington (herein referred to as the Site) (Figures 1 and 2). The

RI and Cleanup Action are focused on a localized area in the southwestern portion of the

commercial building on the Westgate Village property that is occupied by Westway Cleaners.

Farallon conducted the work at the Site on behalf of the property owner, Westgate Village.

The work being conducted at the Site is being performed as an independent remedial action in

accordance with the Washington State Model Toxics Control Act Cleanup Regulation (MTCA),

as established in Chapter 173-340 of the Washington Administrative Code (WAC 173-340). At

the conclusion of the cleanup action at the Site, an application will be prepared and submitted to

the Washington State Department of Ecology (Ecology) to facilitate enrollment of the Site in the

Ecology Voluntary Cleanup Program (VCP) to facilitate the issuance of a No Further Action

determination for the Site.

The work performed at the Site by Farallon included a phased subsurface investigation to address

data gaps identified after an initial site characterization conducted by Key Engineering, Inc. (Key

Engineering) in 1999. The dry cleaning solvent tetrachloroethene (PCE) was identified at

concentrations exceeding the MTCA Method A soil cleanup level for unrestricted land uses in

soil samples collected from beneath the western portion of the Westway Cleaners tenant space

and proximate to the east and west sides of the dry cleaning machine.

To support the RI/FFS, Farallon conducted additional soil investigation in July 2008 that

included drilling and sampling soil borings FB-1 through FB-3, collecting soil vapor samples

from two previous Key Engineering boreholes, and installing a subsurface monitoring probe to

facilitate sub-slab soil vapor sampling. In July 2013, Farallon drilled and sampled soil borings

FB-4 through FB-6, and collected an additional sub-slab soil vapor sample. In April 2014 a

video survey was conducted of a sanitary sewer pipeline running beneath the dry cleaning

machine area, and soil borings FB-7 through FB-12 were drilled and sampled. Subsequent to the

2013 phase of investigation, the former PCE-based dry cleaning machine was removed from the

Site and replaced with a machine that uses a non-halogenated dry cleaning solution.

1.1 PURPOSE

The purpose of the RI was to define the lateral and vertical distribution of PCE at concentrations

that exceeded the MTCA Method A cleanup level in soil at the Site, and to provide sufficient

information to enable evaluation and selection of a final cleanup action under the VCP.

Individual phases of subsurface investigation conducted by Key Engineering in 1999 and

Farallon in 2008, 2013, and 2014 together comprise the RI.



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The purpose of the FFS was to develop and evaluate cleanup action alternatives to facilitate

selection of a final cleanup action alternative at the Site in accordance with

WAC 173-340-350(8). The FFS was conducted to screen cleanup action alternatives and

eliminate those that were not technically practicable, whose costs were disproportionate under

WAC 173-340-360(3)(e), and that would be unduly disruptive of the existing tenant’s operations.

The purpose of the CAP is to describe the Site, environmental conditions, cleanup action

objectives, and appropriate cleanup action standards selected under MTCA. The CAP also

describes the confirmation testing proposed for the Site as part of the cleanup action.

1.2 REPORT ORGANIZATION

This report has been prepared to document the RI/FFS that was conducted under

WAC 173-340-350 and to meet the general requirements for a CAP under WAC 173-340-380.

This report has been organized into the following sections:

Section 2—Site Background. This section provides a description of the Site features

and location; a summary of historical Site use; and a description of the local geology,

hydrogeology, and land use pertaining to the Site.

Section 3—Remedial Investigation. This section provides a summary of phased

subsurface investigation activities conducted at the Site by Farallon and others between

1999 and 2014, and includes a discussion of the results from the investigation. This

section also includes a discussion of the Terrestrial Ecological Evaluation (TEE)

requirement under MTCA.

Section 4—Conceptual Site Model. This section provides a summary of the conceptual

site model derived from the results from the environmental work performed at the Site.

Included is a discussion of the confirmed and suspected source areas of the constituents

of concern, affected media, fate and transport characteristics of the releases of hazardous

substances, and the preliminary exposure assessment.

Section 5—Screening of Potential Cleanup Alternatives. This section presents

remedial action objectives, an overview of the evaluation of potential treatment

technologies, and the screening of potential treatment technologies.

Section 6—Recommended Cleanup Alternative. This section presents the cleanup

action alternative recommended for implementation at the Site and the rationale for its

recommendation.

Section 7—Cleanup Action Plan. This section describes the cleanup action objectives,

the appropriate cleanup action standards, the proposed work to be conducted for the

cleanup action, and verification testing proposed as part of the cleanup action.

Section 8—Bibliography. This section provides a list of the source materials used in

preparing this report.

Section 9—Limitations. This section presents Farallon’s standard limitations associated

with conducting the work reported herein and preparing this report.



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2.0 SITE BACKGROUND

This section defines the Site and provides a description of Site features and surrounding land use.

Also included is a summary of the Site history, nearby properties, and local geology and

hydrogeology.

2.1 SITE LOCATION AND DESCRIPTION

The Site is located within Westgate Village in the southwest quadrant of the intersection of

Edmonds Way and 100th

Avenue West in Edmonds, Snohomish County, Washington. The

Westway Cleaners tenant space is in the southern portion of a one-story commercial that

comprises a total of five tenant spaces (Figure 2). The building that includes the Westway

Cleaners facility is surrounded by parking and landscaped areas, with a Bartell Drugs store

occupying a separate building southwest-adjacent to the Site. These buildings together compose

the Westgate Village shopping center. The Site comprises the area immediately beneath and

surrounding the dry cleaning machine in the rear portion of the Westway Cleaners tenant space

(Figure 2).

2.2 SITE HISTORY AND NEARBY PROPERTIES

The current one-story commercial building at the Westgate Village property was constructed in

1962. Records identifying specific tenant spaces occupied by various historical businesses and

tenants are incomplete, but previous tenants are believed to have included a grocery store, a

barber shop, a glass company, a furniture store, a print and copy shop, a shoe repair shop,

restaurants, a coffee shop, a nail shop, and a locksmith. Westway Cleaners began operations in

the building and at its current location in 1991.

The commercial building at the property is currently configured with five individual tenant

spaces and houses (from north to south) a Starbucks coffee shop, a Subway sandwich shop, a

UPS copy and shipping store, a hair salon, and Westway Cleaners.

Adjacent and nearby properties typically have been developed for residential and various

commercial and retail business purposes. Current use of nearby properties includes the Bartell

Drugs store southwest-adjacent to the Site; Key Bank across 100th

Avenue West, east of the Site;

a PCC Natural Markets store diagonally across the Edmonds Way and 100th

Avenue West

intersection northeast of the Site; a QFC grocery store across Edmonds Way north of the Site;

and a vacant residence west of the Site. Historical nearby businesses with a potential for

historical chemical use or storage have included gasoline service stations across the streets from

the Site on each of the southeast, northeast, and northwest corners of the Edmonds Way and

110th

Avenue West intersection.

2.3 SITE GEOLOGY AND HYDROGEOLOGY

The surface geology at the Site is mapped as Pleistocene-aged advance continental glacial

outwash deposits (Washington State Geologic Information Portal 2014). These types of glacial

deposits typically consist of a mixture of sands, silts, and gravels, with the largest percentage



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fraction being composed of sand. Observations made during drilling and sampling at the Site

were consistent with the regional geological mapping of the area.

Soil borings drilled at the Site encountered fill soils directly beneath the concrete building slab,

sidewalk, and asphalt pavement. The fill was described as loose, fine- to medium-grained silty

sand with gravel, and was approximately 3 to 6 feet thick. The fill presumably was derived

locally during construction. Native materials beneath the fill consisted of dense, well-graded to

poorly graded sand.

The exterior ground surface at the Site is at an approximate elevation of 319 feet above mean sea

level. Surface water drainage near the Site would tend to flow toward the northwest and parallel

to Edmonds Way, which occupies the central part of a low canyon that drains toward Puget

Sound approximately 1.6 miles northwest of the Site.

Groundwater was not encountered during drilling at the Site. Based on groundwater monitoring

wells installed at the nearby former gasoline service station property northeast of the Site,

groundwater near the Site occurs at a depth of approximately 55 feet below ground surface (bgs)

(Sound Earth Strategies 2014). The slope of the hydraulic gradient is anticipated to be

approximately parallel to the ground surface topographic gradient, with groundwater flow likely

toward the west and northwest.



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3.0 REMEDIAL INVESTIGATION

Individual phases of environmental assessment, subsurface investigation, and sampling at the

Site were performed by Key Engineering, Inc. in 1999, Associated Earth Sciences, Inc. in 2002,

and Farallon in 2008, 2013, and 2014. Because each investigation phase was conducted to

address certain data gaps that had resulted from the previous investigation phase, the combined

investigative work at the Site is herein described as the RI.

3.1 DATA GAPS

The individual phases of environmental investigation conducted by Key Engineering and

Farallon were not sufficient to complete the RI phase of the project until the lateral and vertical

limits of PCE-contaminated soil were established with the 2014 soil characterization. Data gaps

relating to characterization of the lateral and vertical distribution of PCE in soil were identified

following each of the early phases of investigation.

3.2 RI FIELD ACTIVITIES

Field activities were designed to address data gaps apparent following the earlier phase of

investigation. The individual phases of RI field work are described below.

3.2.1 Limited Phase II Site Assessment—1999

Key Engineering conducted an environmental due diligence and limited Phase II assessment for

the Site in 1999. The assessment noted the presence of cracks in the concrete floor slab in the

vicinity of the dry cleaning machine, and the lack of secondary containment associated with the

dry cleaning machine. As part of the assessment, soil borings S-1 and S-2 were drilled east- and

west-adjacent to the dry cleaning machine, respectively, and sampled (Figure 3). The findings of

the due diligence process and the limited assessment were documented in the Phase I

Environmental Audit and Limited Phase II Site Assessment report dated July 30, 1999, prepared

by Key Engineering (1999).

3.2.2 Site Inspection—2002

Associated Earth Sciences, Inc. (2002) conducted a Site inspection in 2002 and noted that

housekeeping practices at the Site had improved, the cracks in the floor had been repaired, and a

secondary containment system had been installed for the dry cleaning machine.

3.2.3 Subsurface Investigation and Subslab Soil Vapor Monitoring—2008

Farallon (2008) drilled and sampled soil borings FB-1 through FB-3 east- and north-adjacent to

the dry cleaning machine to evaluate the lateral limits of the PCE previously identified in soil

(Figure 3). Soil borings FB-1, FB-2, and FB-3 reached a total depth of 9 feet bgs, and a total of

eight soil samples were collected from the borings. Farallon also collected soil samples from

1999 Key Engineering soil borings S-1 and S-2, which had been left secured with threaded

polyvinyl chloride (PVC) pipe caps. Farallon installed a subsurface monitoring probe



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north-adjacent to the location of the former PCE-based dry cleaning machine and collected a

subslab soil gas sample from this location (Figure 3).


Farallon (2013) advanced and sampled soil borings FB-4 through FB-6 using direct-push drilling

technologies in July 2013 (Figure 3). Six soil samples were collected from soil borings FB-4

through FB-6 for laboratory analysis. Farallon also collected a subslab soil gas sample from the

subsurface monitoring probe that had been installed in 2008.

3.2.5 Additional Subsurface Soil Characterization—2014

A sanitary sewer pipeline that runs inside and parallel to the rear exterior wall of the building

(Figure 2) beneath the location of the former PCE-based dry cleaning machine was accessed via

a cleanout in the bathroom of a nearby tenant space, and a video camera probe was run inside the

pipeline to evaluate pipeline integrity and to aid in locating the pipeline in the area downstream

from the dry cleaning area (Farallon 2014).

In April 2014, soil borings FB-7 through FB-12 were drilled using direct-push drilling

technologies and sampled (Figure 3). Borings FB-7 through FB-10 were drilled to establish the

lateral limits of soil containing PCE, previously detected at concentrations exceeding the MTCA

Method A cleanup level near the former PCE-based dry cleaning machine location. Borings

FB-11 and FB-12 were drilled along the subsurface sanitary sewer pipeline outside and south of

the building to evaluate the potential for discharges to and releases from the sewer pipeline to

have affected soil along the pipeline.

3.3 RI RESULTS

The results of the RI activities described in Section 3.2 are provided below. Boring logs for the

borings drilled at the Site are provided in Appendix A.

3.3.1 Limited Phase II Site Assessment—1999

Key Engineering (1999) drilled and sampled soil borings S-1 and S-2 east- and west-adjacent to

the dry cleaning machine, respectively (Figure 3). PCE was detected at concentrations

exceeding the MTCA Method A soil cleanup level of 0.05 milligrams per kilogram (mg/kg) in

the soil samples collected from soil borings S-1 and S-2 at depths of 2 and 4 feet bgs,

respectively. PCE was not detected at a concentration at or exceeding the laboratory practical

quantitation limit (PQL) in a second soil sample collected from boring S-2 at a depth of 6 feet

bgs several days after the initial sampling (Figure 4). Analytical results for the three soil samples

collected from borings S-1 and S-2 are summarized in Table 1.

3.3.2 Subsurface Investigation and Subslab Soil Vapor Monitoring—July 2008

The materials and soil encountered in borings FB-1 through FB-3 during July 2008 consisted of

approximately 8 inches of concrete slab underlain by poorly graded sand and poorly graded sand

with gravel. Elevated photoionization detector (PID) readings or odors were not noted in soil

samples collected from the Site borings.



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A total of 10 soil samples were submitted for laboratory analysis for halogenated volatile organic

compounds (HVOCs) by U.S. Environmental Protection Agency (EPA) Method 8260B,

including eight samples from borings FB-1 through FB-3 and one sample each from prior boring

locations S-1 and S-2. PCE was detected at concentrations less than the MTCA Method A

cleanup level of 0.05 mg/kg in seven of the eight samples collected from borings FB-1 through

FB-3 (Table 1; Figure 4). PCE was detected at concentrations of 0.10 and 0.059 mg/kg in the

soil samples collected from borings S-1 and S-2, respectively, exceeding the MTCA Method A

cleanup level. No other HVOCs were detected at concentrations at or exceeding laboratory

PQLs in the soil samples analyzed from borings FB-1, FB-2, FB-3, S-1, or S-2.

PCE was detected at a concentration of 2,000 micrograms per cubic meter (µg/m3) in the July

2008 subslab soil gas sample collected from the subsurface monitoring probe. The screening

level for PCE in soil vapor is 501.7 µg/m3 based on the MTCA Method B cleanup level of

50.17 µg/m3 for indoor air for a commercial setting (Table 2). No other HVOC constituents

were detected at concentrations at or exceeding the laboratory PQLs in the subslab soil gas

sample (Farallon 2008).


Soil and other materials encountered in borings FB-4 through FB-6 during July 2013 consisted of

approximately 7 inches of concrete slab underlain by silty sand with gravel and well-graded sand

with gravel. No elevated PID readings or odors were noted in the soil samples collected from

borings FB-4 through FB-6.

Six soil samples from this phase of investigation were submitted for laboratory analysis for

HVOCs by EPA Method 8260C. PCE was not detected at concentrations exceeding the MTCA

Method A cleanup level of 0.05 mg/kg in five of the six soil samples collected from borings

FB-4 through FB-6 (Table 1). PCE was detected at a concentration of 0.10 mg/kg in the soil

sample collected from boring FB-4 at a depth of 1.7 feet below the top of the concrete slab,

which exceeds the MTCA Method A cleanup level of 0.05 mg/kg (Figure 4). No other HVOCs

were detected at concentrations at or exceeding the laboratory PQLs in the soil samples analyzed

from borings FB-4 through FB-6 (Farallon 2013).

PCE was detected at a concentration of 6,300 µg/m3 in the soil gas sample collected from the

subsurface monitoring probe, which exceeds the Modified MTCA Method B screening level for

soil gas for commercial use PCE of 501.7 µg/m3. Trichloroethene (TCE) was detected at a

concentration of 67 µg/m3, which exceeds the Modified MTCA Method B screening level for

soil gas for commercial use of 19.4 µg/m3. No other HVOC constituents were detected at

concentrations at or exceeding the laboratory PQLs in the subslab soil gas sample (Farallon

2013).

3.3.4 Additional Subsurface Soil Characterization—2014

Because of the previous use of dry cleaning fluids at the Site, a sanitary sewer pipeline running

under the floor, inside and parallel to the rear exterior wall of the building at an approximate

depth of 3 feet below the former PCE-based dry cleaning machine area was evaluated for

pipeline integrity and the possible presence of PCE in nearby soil (Figure 4). In addition to the



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sanitary sewer line integrity evaluation, borings FB-7 through FB-12 were completed at the Site

to further delineate the extent of potential PCE contamination east and west of the former

PCE-based dry cleaning machine area, in the exterior area west of the former PCE-based dry

cleaning machine, and in the exterior areas proximate to the sanitary sewer line (Farallon 2014).

The sewer pipeline was accessed via a cleanout in the bathroom of the nearby Subway tenant

space, and a video camera probe was deployed inside the pipeline to evaluate the pipeline

integrity and to aid in locating the pipeline in the area downstream from the dry cleaning area.

The pipeline was observed to be of cast iron construction along the reach beneath the Westway

Cleaners tenant space, and out to a point approximately 5 feet beyond the south exterior wall of

the building, where it had been replaced with a plastic pipeline. The video survey identified an

approximately 2-foot-long area of scaling or possible pipeline surficial corrosion beneath the

southern building wall of the Westway Cleaners tenant space. No other areas of potential

concern pertaining to the integrity of the pipeline were noted in the video survey. Based on the

pipeline video survey and on the utility locating effort, the locations of soil borings FB-11 and

FB-12 were adjusted to assess the area of potential pipeline corrosion and the area where the

surveyed pipeline joined a larger sewer lateral in the driveway south of the Site, respectively.

The materials encountered in borings FB-7 through FB-12 consisted of between 1.5 to 9 inches

of concrete or asphalt, underlain by silty sand with gravel and well-graded sand with gravel. The

soils were characterized as fill materials. No elevated PID readings or odors were noted in the

soil samples collected from the borings.

A total of 12 soil samples (two samples each from borings FB-7 through FB-12) were submitted

for laboratory analysis for HVOCs by EPA Method 8260C during this investigation phase. No

HVOCs included in the laboratory analysis, including PCE, were detected at concentrations at or

exceeding the laboratory PQLs in the soil samples analyzed from borings FB-7 through FB-12.

Soil analytical results are summarized in Table 1 and are shown on Figure 4.



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4.0 CONCEPTUAL SITE MODEL

A conceptual site model identifies suspected sources of contamination, affected media, transport

mechanisms, contaminant fate, and potential receptors and exposure pathways, and is a basis for

developing technically feasible cleanup alternatives and selecting a final cleanup action. A

conceptual site model is dynamic, and may be refined throughout a cleanup action as additional

information becomes available.

This section discusses the components of the conceptual site model developed for the Site based

on completion of the various phases of investigation conducted by Farallon and others that

compose the RI portion of the project. Included in the following sections is a discussion of the

confirmed and suspected source areas, affected media, contaminant fate and transport, and the

preliminary exposure assessment.

4.1 CONFIRMED AND SUSPECTED SOURCE AREAS

A source area is the location of a release of PCE that has affected soil and/or air quality at a site.

The information derived from the subsurface investigation phases of this project has established

that the former PCE-based dry cleaning machine area in the Westway Cleaners tenant space is a

confirmed source area. This area consists of the western portion of the tenant space where the

former PCE-based dry cleaning machine was located. This former dry cleaning machine is the

primary source of the PCE releases at the Site. Concentrations of PCE up to 0.63 mg/kg were

detected in the 1999 soil samples collected from this area. Therefore, soil beneath the former dry

cleaning machine area is considered to be a secondary source of contamination.

PCE was detected at concentrations exceeding the MTCA Method A cleanup level of 0.05 mg/kg

in 3 of the 12 borings advanced in the vicinity of the dry cleaning machine at depths ranging

from 1.7 to 4.5 feet bgs.

4.2 AFFECTED MEDIA

Concentrations of HVOCs have been confirmed in soil and subslab soil gas at the Site. The

distribution of the HVOCs in the affected media has been investigated sufficiently for definition

of the Site under MTCA, identification of the media of concern for future cleanup action, and

evaluation and recommendation of a cleanup action alternative. Details of the affected media

follow.

Soil has been confirmed as an affected medium of concern at the Site. The distribution of

HVOCs in soil has been sufficiently defined for evaluation of potential feasible remedial

technologies. Cleanup would be limited to areas where soil with concentrations of PCE

exceeding the MTCA Method A cleanup level poses a potential threat to indoor air quality via

the vapor intrusion pathway.

Indoor air has been retained as a medium of concern based on the detected concentrations of

PCE in soil and the corresponding detections of PCE and TCE in the subslab soil gas samples.

Preliminary screening results have identified concentrations of PCE and TCE exceeding the



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MTCA Method B cleanup levels in soil gas, triggering a need for further action under MTCA.

However, the cessation of dry cleaning operations using PCE cleaning fluid and the anticipated

cleanup of affected soil are expected to result in elimination of indoor air as a medium of

concern.

Groundwater was not encountered during drilling at the Site. Based on an investigation at the

former gasoline service station property directly across 100th

Avenue West from the Site,

groundwater beneath the Site is believed to occur at a depth of approximately 55 feet bgs. In the

deeper soil samples collected at the Site, PCE was either not reported at concentrations

exceeding the laboratory PQL or was reported at concentrations less than the MTCA Method A

cleanup level, and was rapidly attenuating relative to the shallower soil samples; therefore, PCE

is not considered a potential threat to groundwater beneath the Site. Groundwater is not

considered an affected medium.

4.3 CONTAMINANT FATE AND TRANSPORT

This section includes a discussion of the fate and transport characteristics of the HVOCs

identified in the affected media at the Site that are relevant to the evaluation of potentially

feasible remedial technologies. These HVOCs include PCE and TCE, which are confirmed to be

present in soil and/or subslab soil gas at levels requiring further action under MTCA. Other than

TCE, which is considered a likely degradation product of PCE, concentrations of PCE-related

degradation compounds have not been detected in environmental media, suggesting that little

chemical or biologic degradation of PCE has occurred.

Subsurface investigation activities conducted at the Site have demonstrated the following:

PCE in soil at concentrations exceeding the MTCA Method A cleanup level is localized

near the dry cleaning machine;

PCE in soil at concentrations exceeding the MTCA Method A cleanup level has migrated

to a depth of 4.5 feet bgs; and

PCE and TCE at concentrations exceeding the screening criteria for protection of human

health are present in soil vapor near the dry cleaning machine area.

Because both PCE and TCE share similar environmental fate and transport characteristics and

are present in the same media, PCE and TCE will be discussed together.

4.3.1 Environmental Fate of PCE in the Subsurface

When PCE enters the subsurface, chemical attenuation processes such as hydrolysis, direct

mineralization, and reductive dehalogenation may affect HVOCs in soil, resulting in a natural

reduction or breakdown of the HVOCs into non-toxic components such as chloride and carbon

dioxide. Biological attenuation processes such as reductive dechlorination and cometabolic

degradation also may affect the reduction of HVOCs in soil under conducive subsurface

conditions. If biodegradation of PCE is occurring, the first line of evidence is the presence of

degradation compounds that include TCE, dichloroethene (DCE) isomers, and vinyl chloride.



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These degradation products were not detected in soil samples. However, the TCE reported in a

subslab soil gas sample suggests that some PCE degradation may be occurring at the Site.

PCE and TCE are volatile organic compounds, and will volatilize into a gaseous state from soil.

Volatilization of PCE and TCE from the soil matrix appears to be occurring based on subslab

soil gas analytical results. Once present in indoor or outdoor air, PCE and TCE would be subject

to photodegradation.

4.4 PRELIMINARY EXPOSURE ASSESSMENT

The two types of risk for exposure associated with the presence of PCE and TCE at the Site are

terrestrial ecological risk and human health risk. Because the Site qualifies for a TEE exclusion

in accordance with WAC 173-340-7491, based on the lack of undeveloped land and suitable

habitat for ecological receptors at or near the Site, mitigating the human health risk associated

with PCE and TCE in the affected media at the Site is the primary objective of any cleanup

action implemented. Appendix B contains the justification for the TEE exclusion based on

Ecology guidelines. This section presents the evaluation and conclusions pertaining to the

human health risk at the Site. The goal of this section is to identify potential exposure scenarios

to assist in the evaluation of potential feasible remediation technologies.

4.4.1 Soil Pathway

The exposure pathways for shallow soil include the direct contact pathway, which comprises

direct contact via dermal contact with and/or ingestion of soil beneath the Site. Direct contact

with soil would require excavation activities. At present, a concrete slab and a building structure

cover the source area of PCE. Furthermore, no concentrations of PCE exceeding the 1.9 mg/kg

level considered protective of the direct contact pathway for dermal contact and/or ingestion

have been detected at the Site. The concrete surface covering this area, the depth of

contamination, and the concentrations of PCE make the risk of direct contact negligible.

4.4.2 Vapor Pathway

PCE and TCE, detected in subslab soil gas at concentrations exceeding 501.7 and 19.4 µg/m3,

respectively, have the potential to result in vapor intrusion to indoor and outdoor air. Potential

human exposure to PCE and TCE could occur through the vapor inhalation pathway in the dry

cleaner tenant space. Although soil gas sampling was not conducted outside the immediate dry

cleaning area, neither PCE or TCE were detected in soil samples collected from outdoor soil

boring locations. Therefore, the potential for exposure to these contaminants in outdoor air is

considered very low.

Although no indoor air sampling was conducted, the concrete building floor slab and interior

epoxy floor coating likely serve as a partial vapor barrier to the secondary PCE source

(i.e., contaminated soil) beneath the Westway Cleaners tenant space. Operation of the heating

and ventilation system as an engineering control in the dry cleaner tenant space in a manner that

would maintain or increase the rate of outside air exchange also would further reduce potential

concentrations of PCE and TCE in indoor air pending initiation of a cleanup action.



5-1

5.0 EVALUATION OF POTENTIALLY FEASIBLE CLEANUP ALTERNATIVES

This section presents the evaluation of potentially feasible cleanup alternatives for the Site with

respect to the requirements set forth in MTCA under WAC 173-340-350 through 173-340-370.

Cleanup actions under MTCA are required to: protect human health and the environment;

comply with cleanup standards; comply with applicable state and federal laws; provide for

compliance monitoring; use permanent solutions to the maximum extent practicable; provide for

a reasonable restoration time frame; and consider public concerns. During the selection of

potentially feasible remedial alternatives, Farallon also considered Site-specific conditions,

including the distribution of PCE in the affected media, and impacts to current and/or future use

of the building and current and future tenants. This section presents remedial action objectives,

an overview of the evaluation of potential remediation technologies conducted by Farallon, and

the screening of potential remediation technologies.

5.1 REMEDIAL ACTION OBJECTIVES

Remedial action objectives are the key objectives that a remedial action should achieve to be

retained for further evaluation for the feasibility study. The remedial action objective for the

cleanup action at the Site is to remediate contaminated soil that poses a potential threat to human

health via the direct contact and vapor inhalation pathways in an efficient and cost-effective

manner that minimizes the impacts to building use to the maximum extent practicable. This

objective also would meet the requirements for successful completion of a cleanup action under

MTCA with no institutional controls or further actions required.

5.2 EVALUATION PROCESS

Farallon used a two-step process to evaluate potential feasible cleanup alternatives, including an

initial screening of potential remediation technologies typically applied to sites contaminated

with PCE and associated HVOCs for a series of minimum requirements (Table 3), followed by a

more-detailed evaluation of cleanup alternatives that are applicable to Site-specific conditions,

using criteria drawn from WAC 173-340-360 and the remedial action objective (Table 4). The

remediation technologies had to meet the following requirements at a minimum to pass the initial

screening process:

Protectiveness—whether a remedial technology was protective of human health and the

environment;

Permanence—whether the remedial technology resulted in a permanent solution;

Implementability—whether the remedial technology was practicable based on Site-

specific conditions and/or could be reasonably assured of meeting the cleanup standards;

Restoration time frame—whether the remedial technology would result in achievement of

the remedial action objective within a time frame acceptable under MTCA; and

Cost—whether the cost of using a remedial technology was proportionate to the benefit

relative to the other screening criteria and alternative remedial technologies.



5-2

A number of remediation technologies were eliminated during the initial screening process.

These technologies included but were not limited to in-situ bioremediation, in-situ thermal

(electrical resistance or 6-phase) treatment, and soil flushing (co-solvents) and extraction.

Farallon also considered “no action” and institutional control alternatives, but these did not meet

the remedial action objective, protectiveness criteria, and/or permanence minimum requirements.

The criteria used by Farallon to qualitatively evaluate potentially applicable cleanup alternatives

were derived from WAC 173-340-360(3)(f) and include:

Protectiveness: Overall protectiveness of human health and the environment, including

the degree to which existing risks are reduced, time required to reduce risk at the Site and

attain cleanup standards, on-Site risks resulting from implementing the alternative, and

improvement of overall environmental quality.

Permanence: The degree to which the alternative permanently reduces the toxicity,

mobility, or volume of hazardous substances, including the adequacy of the alternative in

destroying the hazardous substances, the reduction or elimination of hazardous substance

releases and sources of releases, the degree of irreversibility of waste treatment processes,

and the characteristics and quantity of treatment residuals generated.

Cost: The cost to implement the alternative, including the cost of construction, the net

present value of any long-term costs, and Ecology oversight costs under the VCP. Long-

term costs include operation and maintenance costs, monitoring and performance

verification sampling costs, and reporting costs.

Effectiveness over the long term: Long-term effectiveness includes the degree of

certainty that the alternative will be successful, the reliability of the alternative during the

period of time that hazardous substances are expected to remain on the Site at

concentrations that exceed cleanup levels, and the magnitude of residual risk with the

alternative in place. The following types of cleanup action components may be used as a

guide, in descending order, when assessing the relative degree of long-term effectiveness:

reuse or recycling; destruction or detoxification; immobilization or solidification; on- or

off-Site disposal in an engineered, lined, and monitored facility; on-Site isolation or

containment with attendant engineering controls; and institutional controls and

monitoring.

Management of short-term risks: The risk to human health and the environment

associated with the alternative during construction and implementation, and the

effectiveness of measures that will be taken to manage such risks. This criterion includes

the ability to manage risks to workers and customers at businesses adjoining the former

Westway Cleaners tenant space resulting from implementation of the cleanup alternative.

Technical and administrative implementability: The ability to be implemented, including

consideration of whether the alternative is technically feasible, administrative and

regulatory requirements, permitting, scheduling, size, complexity, monitoring

requirements, access for construction operations and monitoring, and integration with the

tenant’s business operations.

Consideration of public concerns: Whether the community has concerns regarding the

alternative and if so, the extent to which the alternative addresses those concerns. This



5-3

process includes concerns from individuals, community groups, local governments,

federal and state agencies, or other organizations that may have an interest in or

knowledge of the Site.

5.3 FOCUSED SCREENING OF POTENTIAL TREATMENT TECHNOLOGIES

The screening of potential technically feasible cleanup alternatives considered the practicable

remedial alternatives confirmed to be effective at treating PCE in the affected media of concern.

Farallon also considered constraints on implementing specific technologies that could preclude

their application due to creation of a greater risk to human health and/or the environment, or

result in incremental costs not proportional to the benefit of applying the alternative.

The key assumptions used by Farallon in the initial screening of cleanup alternatives were:

The distribution of PCE and TCE in soil and soil vapor described in Section 4,

Conceptual Site Model, has been defined sufficiently to support the evaluation of

potential remediation technologies;

MTCA Method A cleanup levels for soil will be the target cleanup level for PCE.

Attaining this level will be required to obtain an opinion of sufficiency for the cleanup

action from Ecology, and to eliminate the vapor intrusion pathway for protection of

indoor air quality;

The remedy will not rely on long-term institutional or engineering controls that

potentially would limit the current and/or future use of the Site as a component of the

cleanup action;

Existing land use will not change for the duration of the cleanup action; and

The existing building structure will remain in-place, and the remediation technologies

selected should minimize the impact to current and future building use to the extent

practicable without affecting the ability to meet the remedial action objective.

Based on these key assumptions and the cumulative subsurface RI results, the following cleanup

alternatives were retained for further consideration:

Cleanup Alternative 1—Soil Vapor Extraction (SVE) System;

Cleanup Alternative 2—Soil Excavation and Off-Site Disposal;

Cleanup Alternative 3—Subslab Depressurization and Venting System; and

Cleanup Alternative 4—No Action.

With the exception of No Action, the identified cleanup alternatives meet the criteria under

MTCA for protection of human health and the environment, compliance with cleanup standards,

permanence of the remedy, and completion within a reasonable time frame. The implementation

of these alternatives likely would not result in public concern, due to the small scale of the Site.

In addition, these cleanup alternatives can be completed with minimal impact to the Site and

surrounding areas. Table 4 provides the detailed evaluation and quantitative scoring of the



5-4

cleanup action alternatives relative to the MTCA evaluation criteria. Table 4 provides a

comparison of estimated costs for the cleanup action alternatives. A description of the

components of each cleanup alternative follows.

5.3.1 Cleanup Alternative 1—SVE System

Cleanup Alternative 1 includes using relatively generic SVE system assumptions to design and

construct a small-scale SVE system to remediate soil containing concentrations of PCE

exceeding the MTCA Method A cleanup level of 0.05 mg/kg. PCE-contaminated soil is present

in the area depicted on Figure 4, extending to a depth of approximately 6 feet bgs. A conceptual

remedial design for the SVE system includes the following components:

Two shallow SVE wells with well screens set at a depth ranging from approximately 1 to

6 feet bgs;

An aboveground skid-mounted Gast Model R4H3060A 6-horsepower high-pressure

regenerative vacuum blower, anticipated to produce an operating vacuum of

approximately 180 inches of water and a flow of approximately 40 standard cubic feet

per minute;

A condensate/fluid knockout system to capture extracted or condensed moisture from the

SVE well and piping prior to the connection with the vacuum blower;

Conveyance piping for extracted vapor to be vented to the atmosphere on the building

roof, with monitoring ports and valves to control flow from each SVE well; and

The concrete floor of the Site building, which is considered a cap because the

contaminated soil is beneath the floor, and therefore is part of the cleanup action

alternative.

Because Westway Cleaners operates equipment having electrical requirements similar to those of

the SVE equipment, on-Site electrical system modifications likely would be minimal. The SVE

equipment would be located in the tenant space occupied by Westway Cleaners.

Operation and maintenance typically would be performed twice monthly during the first

3 months of operation, and monthly thereafter. The preliminary cost estimate for Cleanup

Alternative 1 assumes that cleanup would take approximately 2 years of SVE system operation.

Confirmation soil sampling to a depth of 6 feet bgs would be required following cleanup. Upon

confirmation that concentrations of PCE in soil were below the MTCA Method A soil cleanup

level of 0.05 mg/kg, the SVE system would be decommissioned, and a Site Closure Report

requesting an Opinion Letter on the sufficiency of the cleanup action would be submitted to

Ecology.

Cleanup Alternative 1 has the potential to effectively remediate PCE-contaminated soil with

minimal long-term impact to the building and tenants. This alternative also would mitigate

potential vapor intrusion into the Site building.

A preliminary estimate of the cost to complete Cleanup Alternative 1 is approximately $155,000,

which assumes 2 years of SVE system operation. If additional time is required to achieve the



5-5

remedial action objective, the cost would be incrementally higher. The time frame to implement

and achieve the remedial action objective likely ranges from 1 to 2 years from SVE system start-

up.

5.3.2 Cleanup Alternative 2— Soil Excavation and Off-Site Disposal

Soil with concentrations of PCE exceeding the MTCA Method A cleanup level of 0.05 mg/kg is

present beneath a portion of the Westway Cleaners space. This cleanup alternative assumes that

PCE-contaminated soil will be removed to a depth of 6 feet bgs. Farallon estimates the area of

concrete flooring and shallow soil that would be excavated (i.e., soil to a depth of 3 feet bgs) to

total approximately 65 square feet, and the area of deeper soil that would be excavated, from

approximately 3 to 6 feet bgs, to measure approximately 48 square feet (Figure 4). This depth of

excavation would be technically feasible to achieve using either a slot-cutting excavation

technique or engineering controls (e.g., shoring) to maintain the structural integrity of the

building. The excavation field work would be managed to minimize the impact to the majority

of the building tenants. Because of the subsurface sewer pipeline, excavation deeper than the

pipeline would need to be conducted when the building tenant businesses upstream (north) of the

Site were closed and the sewer pipeline could be temporarily cut and capped, or the pipeline

would need to be supported and maintained while digging during normal business hours.

Cleanup Alternative 2 assumes that approximately 10.5 cubic yards (18 tons) of in-place soil

would be excavated. Soil excavation and off-Site disposal would remove PCE present at the Site

exceeding MTCA Method A cleanup levels. During the cleanup action, options would be

identified to allow business operations to continue. Engineering controls such as bracing and

shoring likely would not be required because of the small excavation area and the potential to use

the slot-cutting technique. Farallon anticipates that excavated soil could be transported via truck

to a Subtitle D landfill facility under a contained-in designation authorized by Ecology.

Following excavation, confirmation soil samples would be collected, the excavation would be

backfilled with controlled-density structural fill, and the sanitary sewer pipeline and building

would be repaired, including replacement of the concrete floor slab and the epoxy surface

coating.

A preliminary estimate of the cost to complete Cleanup Alternative 2 is $82,000, which includes

planning, permitting, implementing the action, and meeting the reporting requirements under

MTCA. The time frame to implement and achieve the remedial action objective likely would

range from 3 to 6 weeks from the start of floor slab saw-cutting and removal.

5.3.3 Cleanup Alternative 3—Subslab Depressurization and Venting System

Under this alternative, an array of several perforated pipes would be installed horizontally

beneath the concrete floor slab within the upper portion of the soil horizon. The piping array

would be connected to a small continuously-running electrical fan that would induce a small

vacuum, and then convey extracted subslab air from beneath the floor to the building roof area to

be vented to the atmosphere. This cleanup action alternative would reduce the concentrations of

PCE in subsurface soil gradually over time. The contaminant removal rate would occur slowly,

controlled for the most part by the rate of contaminant diffusion in soil pore space. The primary



5-6

benefit of a subslab depressurization and venting system would be to minimize the potential for

soil contaminants to migrate to indoor air in the building space.

Operation and maintenance typically would be performed on an annual basis. The preliminary

cost estimate for Cleanup Alternative 3 assumes that cleanup would take approximately 5 years

of system operation. Confirmation soil sampling to a depth of 6 feet bgs would be required

following cleanup. Upon confirmation that concentrations of PCE in soil were less than the

MTCA Method A soil cleanup level of 0.05 mg/kg, the subslab depressurization and venting

system could be either decommissioned or allowed to continue running to reduce potential

migration of residual contaminants into the building, and a Site Closure Report requesting an

Opinion Letter on the sufficiency of the cleanup action would be submitted to Ecology.

This cleanup action alternative has the potential to effectively remediate PCE-contaminated soil

with minimal long-term impact to the building and tenants. However, this remediation would

occur very slowly. As described above, this alternative also would mitigate potential vapor

intrusion into the Site building, a benefit that would occur rapidly upon system start-up, and

would continue as long as the system was in operation.

A preliminary estimate of the cost to implement Cleanup Alternative 3 is approximately $74,000,

which includes planning, construction, 5 years of operation and maintenance, final verification

soil sampling, and Site closure reporting requirements under MTCA. If additional time is

required to achieve the remedial action objective, the cost would increase. The time frame to

implement and achieve the remedial action objective likely would range up to 5 years or beyond

from system installation and start-up.

5.3.4 Cleanup Alternative 4—No Action

Under this alternative, no additional work would be conducted at the Site. Soil containing

concentrations of PCE, and soil gas containing concentrations of PCE and TCE exceeding

MTCA cleanup and screening levels would remain in the subsurface beneath the Site. There

would be no disruption of business at the Site or additional cost. Under the No Action cleanup

action alternative, no PCE would be removed from the subsurface soil or from the Site.



6-1

6.0 RECOMMENDED CLEANUP ALTERNATIVE

The evaluation of Cleanup Alternatives 1 through 4 relative to the criteria presented in MTCA is

summarized in Table 4. Because of the qualitative nature of the scoring and the fact that not all

evaluation criteria are equal in importance, the ranking of cleanup alternatives is not based on a

simplistic mathematical summing of the scores to determine the preferred alternative. This

section presents the rationale for recommending Cleanup Alternative 2, Soil Excavation and Off-

Site disposal, for implementation at the Site.

Cleanup Alternative 2 meets the requirements set forth in WAC 173-340-360(3) and

WAC 173-340-370. This cleanup alternative received favorable scores for the evaluation criteria

of protectiveness, permanence, and long-term effectiveness. A favorable rating was assigned to

the evaluation criteria of short-term risk management, implementability, and public concerns.

Although the scores for Cleanup Alternative 2 are only slightly more favorable than those for

Cleanup Alternative 1, SVE System, the cost and time frame to conduct the cleanup and to likely

achieve formal Site closure from Ecology are significantly more favorable under Cleanup

Alternative 2 than under the other alternatives evaluated.

The Cleanup Action Plan provided in Section 7 includes a detailed scope of work for the

proposed cleanup action and the monitoring program that will be implemented to document

effectiveness and ensure that human health and the environment continue to be protected

throughout the cleanup action.



7-1

7.0 CLEANUP ACTION PLAN

This section describes the cleanup action objectives, the appropriate cleanup action standards

selected under MTCA, the scope of work anticipated for the cleanup action, and the performance

monitoring program.

7.1 CLEANUP ACTION OBJECTIVES

The primary cleanup action objective is to restore the Site to a condition that does not pose an

unacceptable risk to human health or the environment. A secondary objective is to minimize

disruption of the ongoing business operations of Westway Cleaners. To fulfill the primary

cleanup action objective, PCE-contaminated soil beneath the Site will be removed to reduce

concentrations of PCE in soil to less than the MTCA Method A cleanup level for unrestricted

land uses. By meeting the cleanup action objectives, the requirements for successful completion

of a cleanup action under MTCA with no institutional controls or further actions required also

will be met.

7.2 CLEANUP ACTION REGULATORY STANDARDS

Soil at the Site was contaminated with the dry cleaning fluid PCE. The PCE degradation product

TCE also was detected in a soil gas sample from the Site.

MTCA Method A cleanup levels are designed for facilities undergoing routine cleanup actions

that involve relatively few hazardous substances (WAC 173-340-700[5][a]). The conditions for

using MTCA Method A cleanup levels are met at this Site because numerical standards are

available for the identified hazardous substances in the media of concern

(WAC 173-340-704[1][b]). Additionally, MTCA Method A cleanup levels are appropriate

because HVOCs have been identified at concentrations exceeding cleanup levels

(WAC 173-340-700[2]). Therefore, the following MTCA Method A soil cleanup levels for

unrestricted land use will be used at the Site:

PCE—0.05 mg/kg; and

TCE—0.03 mg/kg.

Because the following compounds do not have promulgated MTCA Method A soil cleanup

levels the following MTCA Method B soil cleanup levels are applicable to the Site cleanup

action:

1,1-dichloroethene (1,1-DCE)—4,000 mg/kg;

cis-1,2-dichloroethene (cis-1,2-DCE)—160 mg/kg;

trans-1,2-dichloroethene (trans-1,2-DCE)—1,600 mg/kg; and

Vinyl chloride—0.67 mg/kg.



7-2

Excavated soil and concrete floor slab materials will be disposed of off the Site in a Subtitle D

facility under a contained-in determination authorized by Ecology (WAC 173-303).

7.3 PROPOSED CLEANUP ACTION SCOPE OF WORK

Soil excavation and off-Site disposal of PCE-contaminated soil at a permitted Subtitle D landfill

constitutes the proposed cleanup action. The rationale for selecting and recommending this

cleanup alternative is provided in Sections 5 and 6. The anticipated scope of work for the

proposed cleanup alternative includes the following elements:

Preparation of a Site-specific Health and Safety Plan;

Disconnecting of electrical power, water service, sewer service, and possibly natural gas

service utilities within the work area;

Removal and temporary relocation of the existing dry cleaning machine and other

business equipment;

Saw-cutting, demolition, and removal of the concrete floor slab;

Loading of concrete debris into a storage/transportation container;

Excavation of soil across the excavation target area to the depth needed to expose the

subsurface sanitary sewer pipeline (approximately 3 feet below grade);

Loading and securing of excavated soils in a storage/transportation container;

Off-hour disconnection and plugging of sanitary sewer pipeline, or support and protection

of sewer pipeline during business hours;

Excavation of one slot to a depth of approximately 6 feet below grade;

Collection of confirmation soil samples from the excavation bottom and sidewall(s);

Temporary restoration of the sanitary sewer pipeline pending receipt of analytical

laboratory results;

Backfilling of the excavated slot with controlled density fill/cement-sand slurry and

allowing to cure, following receipt of acceptable confirmation soil sample analytical

results;

Continuation of off-hour sewer pipeline termination, sequential slot-cut soil excavation,

confirmation soil sampling, laboratory analysis, excavation backfill, and sewer pipeline

restoration on one or two additional slots if the slot-cutting technique is recommended by

a structural engineer to preserve the building footing;

Permanent restoration and replacement of the sanitary sewer pipeline and backfilling of

the excavation to the grade needed for replacement of the concrete floor slab;

Pouring, finishing, and curing of the concrete floor slab;

Restoration of the epoxy floor coating, replacement of the dry cleaning machine and

other associated equipment, and restoration of utility connections and service; and



7-3

Manifesting, transporting, and disposing of concrete debris and excavated soil at an

approved Subtitle D facility.

7.4 PERFORMANCE MONITORING AND CONFIRMATION SOIL SAMPLING

The point of compliance for the cleanup action at the Site will be all soil remaining at the Site.

The cleanup action will be conducted by excavating and removing subsurface soils to a depth of

approximately 6 feet below the concrete floor slab. The excavation may be performed with a

slot-cutting technique, with either two or three slots excavated perpendicular to the western

exterior building wall footing to minimize the length of the building footing exposed to the open

excavation and potential instability.

Because of the relatively shallow excavation depth, only collection of confirmation soil samples

at the final limits of the proposed soil excavation is planned. No intermediate-depth progress soil

sampling is planned. Soil removed from the excavation will be monitored with a PID to monitor

excavation progress, for health and safety purposes, and to verify assumptions made during the

cleanup action planning stage.

To verify that the cleanup action is successful in meeting the cleanup action objective of

removing soil containing PCE at concentrations exceeding the MTCA Method A cleanup level,

the following performance monitoring sampling program will be followed:

From each soil excavation subarea, one excavation bottom soil sample will be collected,

for a total of either two or three excavation bottom soil samples submitted for chemical

analyses, depending on the number of excavated slots (Additionally, deeper soil samples

will be collected from below the excavation bottom, and held at the laboratory on a

contingent basis for possible chemical analyses if the primary excavation bottom

samples’ analytical results exceed MTCA Method A soil cleanup levels.); and

From the soil excavation as a whole, one excavation side wall soil sample from each of

the north, west, south, and east sidewalls will be collected, for a total of four excavation

sidewall soil samples, distributed among the excavated slots so as to represent the central

part of the full excavation sidewalls.

Confirmation soil samples will be analyzed for HVOCs by EPA Method 8260B.

Confirmation soil sample analytical results will be compared to the cleanup action regulatory

standards for the Site. If confirmation soil sample analytical results indicate that the soil

remaining in the excavation sidewalls or bottom contains PCE or its degradation products at

concentrations that exceed regulatory standards, the excavation will be expanded laterally and/or

deepened vertically as needed, resampled, and retested until the cleanup action regulatory

standards have been attained.



8-1

8.0 BIBLIOGRAPHY

Associated Earth Sciences, Inc. 2002. Occurrence of Tetrachloroethene Impacted Soils,

Westway Cleaner. February 22.

Farallon Consulting, L.L.C. (Farallon). 2008. Environmental Assessment, Westway Cleaners,

10016 #A Edmonds Way, Edmonds, Washington. August 1.

———. 2013. Soil Investigation, Westway Cleaners, 10016 #A Edmonds Way, Edmonds,

Washington. September 9.

———. 2014. Additional Soil Characterization, Westway Cleaners, 10016 #A Edmonds Way,

Edmonds, Washington. June 3.

Key Engineering, Inc. 1999. Phase I Environmental Audit and Limited Phase II Site

Assessment. July 30.

Sound Earth Strategies, Inc. 2014. Phase I Environmental Site Assessment. March 26.

Washington State Geologic Information Portal. 2014.

<https://fortress.wa.gov/dnr/geology/?Theme=wigm>. (July)

https://fortress.wa.gov/dnr/geology/?Theme=wigm



9-1

9.0 LIMITATIONS

The conclusions and recommendations contained in this report/assessment are based on

professional opinions with regard to the subject matter. These opinions have been arrived at in

accordance with currently accepted hydrogeologic and engineering standards and practices

applicable to this location, and are subject to the following inherent limitations:

Accuracy of Information. Certain information used by Farallon in this

report/assessment has been obtained, reviewed, and evaluated from various sources

believed to be reliable. Although Farallon’s conclusions, opinions, and recommendations

are based in part on such information, Farallon’s services did not include verification of

its accuracy or authenticity. Should such information prove to be inaccurate or

unreliable, Farallon reserves the right to amend or revise its conclusions, opinions, and/or

recommendations.

Reconnaissance. Farallon performed a reconnaissance of the Site that is the subject of

this report/assessment to document current conditions. Farallon focused on areas deemed

more likely to exhibit hazardous materials conditions, while other areas received limited

attention or were inaccessible at the time of the reconnaissance.


FIGURES

REMEDIAL INVESTIGATION/FOCUSED FEASIBILITY STUDY REPORT

AND CLEANUP ACTION PLAN

Westway Cleaners

10016 #A Edmonds Way

Edmonds, Washington


ST

EE

P W

OO

DE

D H

ILLS

ID

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PARKING LOT

P

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SHOPPING CENTER

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WESTGATE VILLAGE

PARKING LOT

100th A

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BARTELL DRUGS

W

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SEE FIGURE 3

FOR DETAIL

(BUILDING A)

(BUILDING B)

LEGEND

BOUNDARY OF WOODED AREA

CENTER LINE

DIRECTION OF SLOPE

ALL LOCATIONS ARE APPROXIMATE

ARALLONF ONSULTINGC

FIGURE 2

WESTWAY CLEANERS

BOILER-

ROOM

BATH

ROOM

DRY CLEANER MACHINE

SHOPPING CENTER

WESTGATE VILLAGE

G

R

E

A

S

E

T

R

A

P

FB-5

FB-6

FB-4

FB-10

FB-7

FB-8

FB-9

FB-12

FB-11

DRIVEWAY

PARKING

(SUITE A)

(BUILDING B)

LEGEND

SOIL BORING (KEY ENGINEERING 1999)

FARALLON BORING (FARALLON CONSULTING 2008)

FARALLON PROBE (FARALLON CONSULTING 2008)


FB-6BORING LOCATION (FARALLON 2013)

BORING LOCATION (FARALLON 2014)

APPROXIMATE UNDERGROUND SEWER PIPELINES

FB-12

ARALLONF ONSULTINGC

FIGURE 3

FB-10

FB-7

FB-8

FB-9

FB-12

FB-11

WESTWAY CLEANERS

BOILERROOM

BATH

ROOM

DRY CLEANER MACHINE

SHOPPING CENTER

WESTGATE VILLAGE

G

R

E

A

S

E

T

R

A

P

PARKING AREA

FB-5

FB-6

FB-4

2.0' 0.044

5.0' 0.0075

9.0' 0.017

1.9' <0.010

3.2' <0.010

2.4' <0.010

3.5' <0.010

3.7' <0.010

5.8' <0.010

1.2' <0.010

3.6' <0.010

1.8' <0.010

4.6' <0.010

2.0' <0.010

5.0' <0.010

1.7' 0.10

4.6' 0.010

2.0' 0.027

5.0' 0.020

2.0' 0.0033

6.0' 0.0092

9.0' <0.00091

4.0' 0.63

4.5' 0.059

6.0' <0.053

1.4' 0.024

8.4' <0.00065

4.0' 0.0092

7.2' 0.013

2.0' 0.27

2.5' 0.10

LEGEND

SOIL BORING (KEY ENGINEERING 1999)


SOIL VAPOR PROBE (FARALLON 2008)


FB-6



APPROXIMATE UNDERGROUND SEWER PIPELINES

FB-12

1.9' <0.010

DEPTH IN FEET BELOW GROUND SURFACE (BGS) AND SOIL CONCENTRATION OF

TETRACHLOROETHENE (PCE) IN MILLIGRAMS PER KILOGRAM (mg/kg), BOLD

WHERE CONCENTRATION EXCEEDS WASHINGTON STATE MODEL TOXICS

CONTROL ACT CLEANUP REGULATION (MTCA) METHOD A CLEANUP LEVEL

APPROXIMATE LIMIT OF SOIL FROM 0.5 TO 3 FEET BGS WITH PCE

CONCENTRATION EXCEEDING MTCA METHOD A CLEANUP LEVEL

APPROXIMATE LIMIT OF SOIL FROM 3 TO 6 FEET BGS WITH PCE CONCENTRATION

EXCEEDING MTCA METHOD A CLEANUP LEVEL

ARALLONF ONSULTINGC

FIGURE 4


TABLES



Westway Cleaners


Edmonds, Washington


Table 1

Summary of Soil Analytical Results for Halogenated Volatile Organic Compounds

Westway Cleaners

Edmonds, Washington


PCE TCE

cis 1,2-

Dichloroethene

trans 1,2-

Dichloroethene

Vinyl

Chloride

FB1-2-070908 2.0 0.044 <0.0010 <0.0010 <0.0010 <0.0010

FB1-5-070908 5.0 0.0075 <0.00094 <0.00094 <0.00094 <0.00094

FB1-9-070908 9.0 0.017 <0.00079 <0.00079 <0.00079 <0.00079

FB2-2-070908 2.0 0.027 <0.00097 <0.00097 <0.00097 <0.00097

FB2-5-070908 5.0 0.020 <0.0014 <0.0014 <0.0014 <0.0014

FB3-2-070908 2.0 0.0033 <0.00083 <0.00083 <0.00083 <0.00083

FB3-6-070908 6.0 0.0092 <0.00082 <0.00082 <0.00082 <0.00082

FB3-9-070908 9.0 <0.00091 <0.00091 <0.00091 <0.00091 <0.00091

FB4-1.7 1.7 0.10 <0.00086 <0.00086 <0.00086 <0.00086

FB4-4.6 4.6 0.010 <0.00068 <0.00068 <0.00068 <0.00068

FB5-4.0 4.0 0.0092 <0.00065 <0.00065 <0.00065 <0.00065

FB5-7.2 7.2 0.013 <0.00066 <0.00066 <0.00066 <0.00066

FB6-1.4 1.4 0.024 <0.00059 <0.00059 <0.00059 <0.00059

FB6-8.4 8.4 <0.00065 <0.00065 <0.00065 <0.00065 <0.00065

FB7-2.0-040614 2.0 <0.010 <0.010 <0.010 <0.010 <0.010

FB7-5.0-040614 5.0 <0.010 <0.010 <0.010 <0.010 <0.010

FB8-1.8-040614 1.8 <0.010 <0.010 <0.010 <0.010 <0.010

FB8-4.6-040614 4.6 <0.010 <0.010 <0.010 <0.010 <0.010

FB9-1.2-040614 1.2 <0.010 <0.010 <0.010 <0.010 <0.010

FB9-3.6-040614 3.6 <0.010 <0.010 <0.010 <0.010 <0.010

FB10-3.7-040614 3.7 <0.010 <0.010 <0.010 <0.010 <0.010

FB10-5.8-040614 5.8 <0.010 <0.010 <0.010 <0.010 <0.010

FB11-2.4-0406014 2.4 <0.010 <0.010 <0.010 <0.010 <0.010

FB11-3.5-040614 3.5 <0.010 <0.010 <0.010 <0.010 <0.010

FB12-1.9-040614 1.9 <0.010 <0.010 <0.010 <0.010 <0.010

FB12-3.2-040614 3.2 <0.010 <0.010 <0.010 <0.010 <0.010

S1 7/21/1999 Key 2.0 0.27__ __ __ __

S1-2.5-070908 7/9/2008 Farallon 2.5 0.10 <0.0010 <0.0010 <0.0010 <0.0010

7/21/1999 4.0 0.63__ __ __ __

7/29/1999 6.0 <0.053__ __ __ __

S2-4.5-070908 7/9/2008 Farallon 4.5 0.059 <0.0011 <0.0011 <0.0011 <0.0011

0.053

0.033

1604

1,6004

0.674

NOTES:

Results in bold denote concentrations above Washington State Model Toxics Control Act Cleanup Regulation (MTCA) cleanup levels.Farallon = Farallon Consulting, L.L.C. __

= not analyzed HVOCs = halogenated volatile organic compounds

< denotes analyte not detected at or above the laboratory practical quantitation limit indicated. PCE = tetrachloroethene 1Depth in feet below top of concrete slab. TCE = trichloroethene

2Analyzed by U.S. Environmental Protection Agency Method 8260B/C.

Farallon

4/6/2014

4/6/2014

4/6/2014

4/6/2014

4/6/2014

Farallon

Farallon

Farallon

Farallon

Farallon

Boring

Location

Sample

Identification

Date

Sampled

Sample

Depth

(feet)1

Analytical Results2 (milligrams per kilogram)

Sampled By

Farallon

Farallon

Farallon

S-2

S-1

S2 Key

FB-4

FB-2 7/9/2008

FB-1

FB-3

7/9/2008

7/9/2008

Farallon

Farallon

MTCA Cleanup Levels for Soil

3MTCA Cleanup Regulation Method A Soil Cleanup Level, Table 740-1 of Section 900 of Chapter 173-340 of the Washington

Administrative Code, as revised November 2007.4Washington State Cleanup Levels and Risk Calculations under MTCA, Standard Method B Formula Values for Soil

(Unrestricted Land Use) - Direct Contact (Ingestion Only) and Leaching Pathway,

https://fortress.wa.gov/ecy/clarc/Reporting/ChemicalQuery.aspx.

Farallon

FB-5

FB-6

7/8/2013

7/8/2013

7/8/2013

FB-7

FB-8

FB-9

FB-10

FB-11

FB-12 4/6/2014

G:\Projects\133 William C. Nelson, III\133001 Westway Cleaners\Reports\RI-FFS and CAP\Tbls 1, 2 Soil and Soil Gas Tables

1 of 1

Table 2

Summary of Soil Vapor Analytical Results for Halogenated Volatile Organic Compounds

Westway Cleaners

Edmonds, Washington


PCE TCE

Farallon Probe FP-070908 7/9/2008 2,000 <1,000

Farallon Probe FAR-37340-070813 7/8/2013 6,300 67

501.7 19.4

NOTES:

Farallon = Farallon Consulting, L.L.C.

HVOCs = halogenated volatile organic compounds__

= not analyzed PCE = tetrachloroethene

< denotes analyte not detected at or above the laboratory practical quantitation limit indicated. TCE = trichloroethene1Analyzed by U.S. Environmental Protection Agency (EPA) Method TO-15.

2 Modified MTCA Method B Soil Gas Screening Levels based on forthcoming changes to be presented in an update to the Cleanup Levels and Risk Calculations (CLARC)

database. These changes are based on February 2012 updates to the EPA Integrated Risk Information System (IRIS) database regarding toxicological data for these

compounds.

Sample Location Sample Identification Sample Date

Analytical Results (micrograms per cubic meter)1

Modified MTCA Method B Screening Levels for Soil Gas (Commercial)2

Results in bold denote concentrations above Washington State Model Toxics Control Act Cleanup

Regulation (MTCA) screening levels.

G:\Projects\133 William C. Nelson, III\133001 Westway Cleaners\Reports\RI-FFS and CAP\Tbls 1, 2 Soil and Soil Gas Tables

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Table 3

Cleanup Technology Screening

Westway Cleaners

Edmonds, Washington


Secondary

Criterion Score2

Media General Response Action Technology Process Option1

Implementability Effectiveness Relative Cost Total Score2

Rank3

Retain4

No Action None None 3 0 3 6 2 Y

Monitored Natural Attenuation Natural Degradation

Processes, Monitoring,

Modeling

Sample Collection and Analysis, Predictive Modeling 3 0 2 5 1 N

Soil Treat In-Situ Biological Bioventing 1 2 2 5 3 N

Enhanced Bioremediation 1 2 2 5 3 N

Chemical Chemical Oxidation 1 2 2 5 3 N

Physical Soil Flush 1 1 1 3 5 N

Soil Vapor Extraction 2 2 2 6 2 Y

Thermal Remediation 1 3 0 4 3 N

Sub-Slab Depressurization and Venting 2 2 2 6 2 Y

Biological Biopile 1 2 0 3 4 N

Biological Remediation 1 2 1 4 4 Y

Chemical Chemical Oxidation 1 2 1 4 4 N

Physical Excavate and Send to Landfill 2 3 2 7 1 Y

Thermal Desorption 1 3 0 4 3 N

Containment Capping Physical Barriers and Constructed Cover 3 2 3 8 1 Y

NOTES:

2Primary and Secondary Scores: 0 least favorable, 3 most favorable; with respect to the relatively small scale of the Site.

3Rank: Relative to the environmental medium at the Site (i.e., shallow soil).

4Retain: Y = Yes, retain for consideration in cleanup alternative(s). N = No, do not retain for consideration in cleanup alternative(s).

Primary

Criteria Score2

Non-Specific

Excavate and Treat or Contain

On or Off the Site

1Process options in bold and larger font are retained for consideration in the Cleanup Alternatives.

G:\Projects\133 William C. Nelson, III\133001 Westway Cleaners\Reports\RI-FFS and CAP\Tbl 3 Technology Screening Tbl Westway 1 of 1

Table 4

Summary of Cleanup Action Alternative Evaluation

Westway Cleaners

Edmonds, Washington


Alternative 1 - Soil Vapor ExtractionAlternative 2 - Soil Excavation and

Off-site Disposal

Alternative 3 - Sub-Slab Depressurization and

Venting SystemAlternative 4 - No Action

Description A soil vapor extraction (SVE) system will involve

installation of one or two wells in the contaminated

soil area. The wells will be placed under a strong

vacuum with a blower, which then discharges to the

atmosphere. The stronger vacuum creates a radius

of influence likely beyond the limits of

contaminated soil, and thereby pulls PCE into the

wells and removes it from the subsurface soil.

This alternative includes soil excavation and

removal of impacted soil, off-Site soil disposal at a

permitted landfill, backfilling excavated area, and

capping excavated area with concrete.

A sub-slab depressurization system will involve

installation of a sub-slab piping array that will be

placed under a slight vacuum with a small fan. The

fan and vacuum will direct air flow into the piping

array which then discharges to the atmosphere. Note,

this alternative does not treat PCE but does reduce

the potential for vapor migration into the building.

No action. No additional measures will be taken

to clean up property or to provide protection

from exposure to PCE remaining at the Site.

Protection of Human Health and the

Environment

Yes - Alternative will protect human health and the

environment by eliminating PCE through source

excavation and removal, and mass excavation of all

impacted soil.

Yes - Alternative will protect human health and the

environment by source excavation and removal

which will limit future PCE exposure and migration.

Yes - Alternative will protect human health by

eliminating exposure via inhalation. Alternative will

not protect the environment because system will not

be designed to remove PCE.

No - Alternative will not provide additional

protection to human health and the environment.

Compliance with Cleanup Standards Yes - Active SVE system will result in compliance

with cleanup standards in approximately one to two

years.

Yes - Soil excavation and offsite disposal will result

in compliance with cleanup standards once the work

is complete.

No - Alternative will not comply with cleanup

standards except over a very long period of time.

PCE will remain above cleanup levels longer than if a

higher-vacuum, SVE system were used.

No - Alternative will not comply with cleanup

standards except over a very long period of time.

PCE will remain above cleanup levels until

attenuated naturally.

Compliance with Applicable State and Federal

Laws

Yes - Alternative complies with applicable laws. Yes - Alternative complies with applicable laws. No - Alternative does not comply with MTCA

cleanup levels.

No - Alternative does not comply with MTCA

cleanup levels.

Provision for Compliance Monitoring Yes - Alternative includes provisions for

compliance monitoring.

Yes - Alternative includes provisions for compliance

monitoring.

Yes - Alternative includes provisions for compliance

monitoring.

No - Alternative does not include provisions for

compliance monitoring.

Permanent and Protective to the Maximum

Extent Practicable (see detail below)

Yes - Alternative is permanent and protective with

the SVE system actively removing contaminants

from soil, and the current containment system/floor

slab remaining in place.

Yes - Alternative is permanent and protective to the

maximum extent practicable, with removal of all

soil containing PCE at concentrations exceeding the

MTCA cleanup level.

No - While the alternative is permanent, in that PCE

is removed from subsurface soil, cleanup standards

will be achieved over a longer period of time

compared to other alternatives. The alternative is

protective to the maximum extent practicable.

No - While alternative is permanent and

protective with the current containment systems,

cleanup standards will be achieved only over a

very long period of time and this alternative does

not provide for protectiveness beyond that

provided by the existing floor slab.

Restoration Time Frame Concentrations of PCE in soil will be removed

completely over a period of approximately one to

two years. The restoration time frame is

considered to be reasonable under MTCA.

The restoration time frame for soil is expected to be

very short, and completed following the removal

and offsite disposal of contaminated soil.

Concentrations of PCE will be removed and lowered

below cleanup levels over many years. Some natural

degradation of contaminants will also likely occur

over the same time period.

Concentrations of PCE will degrade below

cleanup levels over many years, possibly many

decades. Because no additional protective

controls or monitoring will be employed, the

restoration time frame is not considered to be

reasonable under MTCA.

Protectiveness

(30% weighting Factor)

Alternative provides protection by removing PCE

over a period of several years.

= 7.

Alternative provides protection by removing source

materials.

= 8.

Alternative provides protection by removing PCE,

but over a period of many years.

= 5.

Alternative will not provide additional

protectiveness beyond that provided by existing

the floor slab and does not include an

environmental covenent or monitoring; cleanup

standards achieved over a long time period

through natural attenuation.

= 7.

Permanence


Alternative has the potential to pernamently reduce

the toxicity or volume of haxardous substances

given optimal soil conditions.

= 7.

Alternative will permanently reduce the volume of

hazardous substances with source excavation.

= 8.

Alternative will not permanantly reduce the

toxicity of volume of hazarsous substances except

via natural attenuation process and low levels

M17of air stripping.

= 4.

Alternative will not pernamently reduce the

toxicity or volume of haxardous substances

except via natural attenuation processes; the

existing containment system/floor slab will

reduce the overall mobility of PCE.

= 3.

Long-Term Effectiveness


Alternative is considered to provide effective

protection over the long-term by removing PCE.

= 8.

Alternative provides effective protection over the

long-term by source excavation and disposal off-

Site at a permitted facility and by containment of

residual levels of COCs.

= 9.

Alternative is considered to provide effective

protection over the long-term by removing PCE,

but it does not remove PCE as quickly as the other

alternatives.

= 6.

Alternative does not provide effective

protection over the long-term because it does not

actively remove contaminants.

= 2.

Short-Term Risk Management


Alternative requires minimal disturbance of

affected soil media but does volatilize PCE and

vents it to the atmosphere, possibly exposing

workers and visitors to the PCE.

= 6.

Alternative disturbs affected media, presenting short-

term risk to workers, proximate property occupants,

and during waste transport for off-Site disposal.

= 5.

Alternative requires minimal disturbance of

affected soil media, thereby limiting PCE

exposure to remediation workers and nearby

building workers and visitors.

= 6.

Alternative does not disturb affected media in

the short term; no short-term risk management

needed.

= 9.

Implementability


Alternative is implementable, but may cause one or

two days of business disruption.

= 9.

Alternatives is implementable but will require

additional coordination due to limited access,

underground utilities, and buisness hours. Will

likely cause several weeks of business disruption.

= 5.

Alternative is constructable, but may cause several

days of business disruption.

= 7.

Alternative is implementable, but does not

reduce PCE concentrations. Does not cause any

business interuption.

= 10.

Public Concerns


Alternative requires installation and operation of an

SVE system; little to no public exposure to PCE is

expected to occur during SVE system construction,

but some minor PCE exposure could occur due to

venting to the atmosphere.

= 8.

Alternative requires excavation and removal of

impacted soil in an area zoned for mixed residential

and commercial use which may result in public

exposure during excavation.

= 7.

Alternative requires installation and operation of a

sub-slab depressurization system; little to no

public exposure to PCE is expected to occur

during system construction, but some minor PCE

exposure could occur due to venting to the

atmosphere.

= 9.

Alternative leaves impacted soil in place. Site is

in area zoned for mixed residential and

commercial use. Public exposure may occur.

= 5.

MTCA Composite Benefit Score1 7.4 7.6 5.7 4.3

Overall Cleanup Action Alternative Ranking2 2 1 3 4

Cost $155,000 $82,000 $74,000 $0

NOTES:

THRESHOLD REQUIREMENTS

OTHER REQUIREMENTS

Evaluation Criteria for Permanence to the Maximum Extent Practicable1

1 Basis for overall Washington State Model Toxics Control Act Cleanup Regulation (MTCA) Composite Benefit Score provided quantitatively with a "score" from 0 (least favorable) to 10 (most favorable) for each of the six evaluation criteria

for permanence to the Maximum Extend Practicable above. MTCA Composite Benefit Scores are calculated by summing the mathematical product of the score multiplied by the indicated weighting factor for each of the six criteria. The basis

for the weighting factors for the six criteria to evaluate permanence to the maximum extent practicable are obtained from Washington State Department of Ecology guidance cited in the text.

2 Overall Cleanup Action Alternative Ranking from 1 (most favorable) to 4 (least favorable) based on the MTCA Composite Benefit Score (above).

G:\Projects\133 William C. Nelson, III\133001 Westway Cleaners\Reports\RI-FFS and CAP\Tbls 4, 5 Alternative Screen and Cost Est WestwayTbl 4 Detailed Alternative Eval

1 of 1


APPENDIX A

BORING LOGS



Westway Cleaners


Edmonds, Washington


Date/Time Started:

Date/Time Completed:

Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:

Depth of Water ATD (ft bgs):

Total Boring Depth (ft bgs):

Log of Boring:

Farallon PN:

Lithologic Description

% R

eco

very

Page 1 of 1

Logged By:

Dep

th (

feet

bg

s.)

Blo

w C

ou

nts

8/8

/8

Drive Hammer (lbs.):

US

CS

US

GS

Gra

ph

ic

Client:Project:

Location:

Total Well Depth (ft bgs):

PID

(p

pm

)

Sam

ple

Inte

rval

Sample ID

Boring/WellConstruction

Details

Sam

ple

An

alyz

ed

Filter Pack:Ground Surface Elevation (ft):

Well Construction InformationMonument Type:

Casing Diameter (inches):

Screen Slot Size (inches):

Top of Casing Elevation (ft):

Annular Seal:Screened Interval (ft bgs):

Boring Abandonment:

Y:X:Surveyed Location:

Surface Seal:

0

5

10

Westway CleanersEdmonds, WA

FB-4

7/08/2013 1045

7/08/2013 1100

GP 420M

Cascade

Brad Hanratty

William C. Nelson, III

133-001

Dincer Kayhan

3' Macro-core

Geoprobe

NE

6.0

Auto

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Jet Set

0.0-0.5' bgs: Concrete.

0.5-1.7' bgs: Silty SAND with gravel (50% sand, 30% silt, 20% gravel),fine to medium sand, fine to coarse gravel, brown, dry, loose, noodor.

1.7-3.0' bgs: No recovery.

3.0-4.6' bgs: Well-graded SAND with silt and gravel (60% sand, 30%gravel, 10% silt), fine to coarse sand, fine to coarse gravel, brown, dry,dense, no odor.


Refusal at 6.0' bgs.

40

53

CO

SM

SW

6.8

3.1

X

X

FB4-1.7@ 1047

FB4-4.6@ 1058

Concrete

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% R

eco

very

Page 1 of 1

Logged By:

Dep

th (

feet

bg

s.)

Blo

w C

ou

nts

8/8

/8


US

CS

US

GS

Gra

ph

ic

Client:Project:

Location:


PID

(p

pm

)

Sam

ple

Inte

rval

Sample ID


Details

Sam

ple

An

alyz

ed







Boring Abandonment:


Surface Seal:

0

5

10


FB-5

7/08/2013 1108

7/08/2013 1127

GP 420M

Cascade

Brad Hanratty


133-001

Dincer Kayhan

3' Macro-core

Geoprobe

NE

7.5

Auto

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Jet Set




3.0-4.6' bgs: Well-graded SAND with silt and gravel (60% sand, 30%gravel, 10% silt), fine to medium sand, fine to coarse gravel, brown togray (color change at 4.0' bgs), dry, dense, no odor.


6.0-7.2' bgs: Well-graded SAND with silt and gravel (60% sand, 30%gravel, 10% silt), fine to medium sand, fine to coarse gravel, brown,dry, dense, no odor.



50

53

80

CO

SM

SW

SW

6.9

3.7

4.9

5.5

14.0

X

X

FB5-2.0@ 1112

FB5-4.0@ 1121

FB5-4.6@ 1123

FB5-6.0@ 1134

FB5-7.2@ 1130

Concrete

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% R

eco

very

Page 1 of 1

Logged By:

Dep

th (

feet

bg

s.)

Blo

w C

ou

nts

8/8

/8


US

CS

US

GS

Gra

ph

ic

Client:Project:

Location:


PID

(p

pm

)

Sam

ple

Inte

rval

Sample ID


Details

Sam

ple

An

alyz

ed







Boring Abandonment:


Surface Seal:

0

5

10


FB-6

7/08/2013 1135

7/08/2013 1215

GP 420M

Cascade

Brad Hanratty


133-001

Dincer Kayhan

3' Macro-core

Geoprobe

NE

9.0

Auto

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Jet Set





Driller indicated rock at bottom of rod.

6.0-8.4' bgs: Well-graded SAND with silt and gravel (60% sand, 30%gravel, 10% silt), fine to medium sand, fine to coarse gravel, brown togray (color change at 7.0' bgs), dry, dense, no odor.



27

0

80

CO

SM

SW

9.2

3.8

9.4

X

X

FB6-1.4@ 1159

FB6-6.0@ 1212

FB6-8.4@ 1215

Concrete

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-7

4/6/2014 1020

4/6/2014 1050

Geoprobe 420 M

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

7.0

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete

0.0-0.8 Concrete (cored)

0.8-2.3 Silty SAND with gravel (50% sand, 35% silt, 15% gravel), finesand, fine to coarse gravel, light brown to brown at 2.0 bgs, dry tomoist at 2.0 bgs, no odor.

2.3-3.8 No Recovery

3.8-4.8 Silty SAND with gravel (40% sand, 30% silt, 30% gravel), finesand, fine to coarse gravel, light brown to brown at 2.0 bgs, dry tomoist at 2.0 bgs, no odor.

4.8-5.8 Well-graded SAND with gravel and silt (60% sand, 30% gravel,10% silt), fine to medium sand, fine to coarse gravel, light brown, dry,no odor.

5.8-6.8 No Recovery

6.8-7.0 No Recovery

Refusal at 7.0 bgs

50

73

0

CO

SM

SM

SW-SM

0.0

0.0

X

X

FB7-2.0-040614

FB7-5.0-040614

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-8

4/6/2014 1055

4/6/2014 1120

Geoprobe 420 M

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

6.0

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete


0.6-1.8 Silty SAND with gravel (50% sand, 30% silt, 20% gravel), finesand, fine to coarse gravel, brown, dry, no odor.

1.8-3.6 No Recovery

3.6-4.6 Silty SAND with gravel (50% sand, 30% silt, 20% gravel), fineto coarse sand, fine to coarse gravel, brown, dry, no odor.

4.6-6.0 No recovery

Refusal at 6.0 bgs

40

42

CO

SM

sm

0.0

0.0

X

X

FB8-1.8-040614

FB8-4.6-040614

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-9

4/6/2014 1123

4/6/2014 1145

Geoprobe 420 M

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

4.0

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete


0.6-1.2 Silty SAND (60% sand, 30% silt, 10% gravel), fine sand, fine tocoarse gravel, brown, dry, no odor, scraps of plastic in soil.

1.2-3.6 No Recovery

3.6-4.0 Silty SAND (60% sand, 30% silt, 10% gravel), fine sand, fine tocoarse gravel, brown, dry, no odor, scraps of plastic in soil.

Refusal at 4.0 bgs

20

100

CO

SM

SM

0.0

0.0

X

X

FB9-1.2-040614

FB9-3.6-040614

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-10

4/6/2014 1247

4/6/2014 1315

Geoprobe 420 M

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

6.0

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete


0.6-1.3 Silty SAND with gravel (50% sand, 30% silt, 20% gravel), finesand, fine to coarse gravel, brown, dry, no odor, scattered brick debris.

1.3-3.6 No Recovery

3.6-3.7 Silty SAND with gravel (50% sand, 30% silt, 20% gravel), fineto coarse sand, fine to coarse gravel, brown, dry, no odor, scatteredbrick debris.

3.7-5.0 No recovery

5.0-5.8 Well-graded SAND with gravel and silt (60% sand, 30% gravel,10% silt), fine to coarse sand, fine to coarse gravel, brown, dry, noodor.

5.8-6.0 No Recovery

Refusal at 6.0 bgs

23

7

80

CO

SM

SM

SW-SM

0.0

0.0

0.0

X

X

FB10-1.3-040614

FB10-3.7-040614

FB10-5.8-040614

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-11

4/6/2014 1321

4/6/2014 1345

Geoprobe 54 LT

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

4.0

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete


0.1-2.4 Silty SAND (60% sand, 30% silt, 10% gravel), fine sand, fine tocoarse gravel, brown, moist, no odor, organic roots throughout andscattered brick debris.

2.4-3.1 No Recovery

3.1-3.5 Silty SAND (60% sand, 30% silt, 10% gravel), fine sand, fine tocoarse gravel, brown, wet, no odor, organic roots throughout andscattered brick debris.

3.5-4.0 No Recovery

Refusal at 4.0 bgs

43

44

CO

SM

SM

0.0

0.0

X

X

FB11-2.4-040614

FB11-3.5-040614

Bentonite

Date/Time Started:


Equipment:

Drilling Company:

Drilling Foreman:

Drilling Method:

Sampler Type:



Log of Boring:

Farallon PN:


% Recovery

Page 1 of 1

Logged By:

Depth (feet bgs.)

Blow Counts 8/8/8


USCS

USGS Graphic

Client:

Project:

Location:


PID (ppm)

Sample Interval

Sample ID


Details

Sample Analyzed







Boring Abandonment:


Surface Seal:

0

5

10

Westway Cleaners

Edmonds, WA

FB-12

4/6/2014 1350

4/6/2014 1415

Geoprobe 54 LT

Cascade Drilling

Frank Scott


133-001

Dincer Kayhan

3' macro core

Direct Push

NE

3.5

AUTO

NA

NA

NA

NA

NA

NA

NA

NA

Bentonite

NA

NANA

Concrete

0.0-0.3 Asphalt

0.3-1.9 Silty Sand (60% sand, 30% silt, 10% gravel), fine to mediumsand, fine to coarse gravel, brown, moist, no odor, asphalt and brickdebris throughout.

1.9-3.0 No Recovery

3.0-3.2 Silty Sand (60% sand, 30% silt, 10% gravel), fine to mediumsand, fine to coarse gravel, brown, moist, no odor, asphalt and brickdebris throughout.

3.2-3.5 No Recovery

Refusal at 3.5

63

40

AC

SM

SM

0.0

0.2

X

X

FB12-1.9-040614

FB12-3.2-040614

Bentonite


APPENDIX B

TERRESTRIAL ECOLOGICAL EVALUATION EXCLUSION



Westway Cleaners


Edmonds, Washington


ECY 090-300 (revised April 2011) 1

Voluntary Cleanup Program Washington State Department of Ecology

Toxics Cleanup Program

TERRESTRIAL ECOLOGICAL EVALUATION FORM

Under the Model Toxics Control Act (MTCA), a terrestrial ecological evaluation is necessary if hazardous substances are released into the soils at a Site. In the event of such a release, you must take one of the following three actions as part of your investigation and cleanup of the Site:

1. Document an exclusion from further evaluation using the criteria in WAC 173-340-7491.

2. Conduct a simplified evaluation as set forth in WAC 173-340-7492.

3. Conduct a site-specific evaluation as set forth in WAC 173-340-7493.

When requesting a written opinion under the Voluntary Cleanup Program (VCP), you must complete this form and submit it to the Department of Ecology (Ecology). The form documents the type and results of your evaluation.

Completion of this form is not sufficient to document your evaluation. You still need to document your analysis and the basis for your conclusion in your cleanup plan or report.

If you have questions about how to conduct a terrestrial ecological evaluation, please contact the Ecology site manager assigned to your Site. For additional guidance, please refer to www.ecy.wa.gov/programs/tcp/policies/terrestrial/TEEHome.htm.

Step 1: IDENTIFY HAZARDOUS WASTE SITE

Please identify below the hazardous waste site for which you are documenting an evaluation.

Facility/Site Name: Westway Cleaners

Facility/Site Address: 10016#A Edmonds Way, Edmonds, WA

Facility/Site No: VCP Project No.:

Step 2: IDENTIFY EVALUATOR

Please identify below the person who conducted the evaluation and their contact information.

Name: Andrew E. Seutter Title: Engineering Geologist

Organization: Farallon Consulting L.L.C.

Mailing address: 975 5th Avenue NW

City: Issaquah State: WA Zip code: 98027

Phone: (425) 295-0800 Fax: (425) 295-0850 E-mail: [email protected]

http://www.ecy.wa.gov/programs/tcp/policies/terrestrial/TEEHome.htm


Step 3: DOCUMENT EVALUATION TYPE AND RESULTS

A. Exclusion from further evaluation.

1. Does the Site qualify for an exclusion from further evaluation?

Yes If you answered “YES,” then answer Question 2.

No or Unknown

If you answered “NO” or “UKNOWN,” then skip to Step 3B of this form.

2. What is the basis for the exclusion? Check all that apply. Then skip to Step 4 of this form.

Point of Compliance: WAC 173-340-7491(1)(a)

All soil contamination is, or will be,* at least 15 feet below the surface.

All soil contamination is, or will be,* at least 6 feet below the surface (or alternative depth if approved by Ecology), and institutional controls are used to manage remaining contamination.

Barriers to Exposure: WAC 173-340-7491(1)(b)

All contaminated soil, is or will be,* covered by physical barriers (such as buildings or paved roads) that prevent exposure to plants and wildlife, and institutional controls are used to manage remaining contamination.

Undeveloped Land: WAC 173-340-7491(1)(c)

There is less than 0.25 acres of contiguous# undeveloped± land on or within 500 feet of any area of the Site and any of the following chemicals is present: chlorinated dioxins or furans, PCB mixtures, DDT, DDE, DDD, aldrin, chlordane, dieldrin, endosulfan, endrin, heptachlor, heptachlor epoxide, benzene hexachloride, toxaphene, hexachlorobenzene, pentachlorophenol, or pentachlorobenzene.

For sites not containing any of the chemicals mentioned above, there is less than 1.5 acres of contiguous# undeveloped± land on or within 500 feet of any area of the Site.

Background Concentrations: WAC 173-340-7491(1)(d)

Concentrations of hazardous substances in soil do not exceed natural background levels as described in WAC 173-340-200 and 173-340-709.

* An exclusion based on future land use must have a completion date for future development that is acceptable to Ecology.

± “Undeveloped land” is land that is not covered by building, roads, paved areas, or other barriers that would

prevent wildlife from feeding on plants, earthworms, insects, or other food in or on the soil. # “Contiguous” undeveloped land is an area of undeveloped land that is not divided into smaller areas of

highways, extensive paving, or similar structures that are likely to reduce the potential use of the overall area by wildlife.


B. Simplified evaluation.

1. Does the Site qualify for a simplified evaluation?

Yes If you answered “YES,” then answer Question 2 below.

No or Unknown

If you answered “NO” or “UNKNOWN,” then skip to Step 3C of this form.

2. Did you conduct a simplified evaluation?


No If you answered “NO,” then skip to Step 3C of this form.

3. Was further evaluation necessary?


No If you answered “NO,” then answer Question 5 below.

4. If further evaluation was necessary, what did you do?

Used the concentrations listed in Table 749-2 as cleanup levels. If so, then skip to Step 4 of this form.

Conducted a site-specific evaluation. If so, then skip to Step 3C of this form.

5. If no further evaluation was necessary, what was the reason? Check all that apply. Then skip to Step 4 of this form.

Exposure Analysis: WAC 173-340-7492(2)(a)

Area of soil contamination at the Site is not more than 350 square feet.

Current or planned land use makes wildlife exposure unlikely. Used Table 749-1.

Pathway Analysis: WAC 173-340-7492(2)(b)

No potential exposure pathways from soil contamination to ecological receptors.

Contaminant Analysis: WAC 173-340-7492(2)(c)

No contaminant listed in Table 749-2 is, or will be, present in the upper 15 feet at concentrations that exceed the values listed in Table 749-2.

No contaminant listed in Table 749-2 is, or will be, present in the upper 6 feet (or alternative depth if approved by Ecology) at concentrations that exceed the values listed in Table 749-2, and institutional controls are used to manage remaining contamination.

No contaminant listed in Table 749-2 is, or will be, present in the upper 15 feet at concentrations likely to be toxic or have the potential to bioaccumulate as determined using Ecology-approved bioassays.

No contaminant listed in Table 749-2 is, or will be, present in the upper 6 feet (or alternative depth if approved by Ecology) at concentrations likely to be toxic or have the potential to bioaccumulate as determined using Ecology-approved bioassays, and institutional controls are used to manage remaining contamination.


C. Site-specific evaluation. A site-specific evaluation process consists of two parts: (1) formulating the problem, and (2) selecting the methods for addressing the identified problem. Both steps require consultation with and approval by Ecology. See WAC 173-340-7493(1)(c).

1. Was there a problem? See WAC 173-340-7493(2).


No If you answered “NO,” then identify the reason here and then skip to Question 5 below:

No issues were identified during the problem formulation step.

While issues were identified, those issues were addressed by the cleanup actions for protecting human health.

2. What did you do to resolve the problem? See WAC 173-340-7493(3).

Used the concentrations listed in Table 749-3 as cleanup levels. If so, then skip to Question 5 below.

Used one or more of the methods listed in WAC 173-340-7493(3) to evaluate and address the identified problem. If so, then answer Questions 3 and 4 below.

3. If you conducted further site-specific evaluations, what methods did you use? Check all that apply. See WAC 173-340-7493(3).

Literature surveys.

Soil bioassays.

Wildlife exposure model.

Biomarkers.

Site-specific field studies.

Weight of evidence.

Other methods approved by Ecology. If so, please specify:

4. What was the result of those evaluations?

Confirmed there was no problem.

Confirmed there was a problem and established site-specific cleanup levels.

5. Have you already obtained Ecology’s approval of both your problem formulation and problem resolution steps?

Yes If so, please identify the Ecology staff who approved those steps:

No


Step 4: SUBMITTAL

Please mail your completed form to the Ecology site manager assigned to your Site. If a site manager has not yet been assigned, please mail your completed form to the Ecology regional office for the County in which your Site is located.

Northwest Region: Attn: VCP Coordinator

3190 160th Ave. SE

Bellevue, WA 98008-5452

Central Region: Attn: VCP Coordinator

15 W. Yakima Ave., Suite 200 Yakima, WA 98902

Southwest Region: Attn: VCP Coordinator

P.O. Box 47775 Olympia, WA 98504-7775

Eastern Region: Attn: VCP Coordinator

N. 4601 Monroe Spokane WA 99205-1295

If you need this publication in an alternate format, please call the Toxics Cleanup Program at 360-407-7170. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

Table 749-1 Westway Cleaners Site, Edmonds, Washington

Simplified Terrestrial Ecological Evaluation-Exposure Analysis Procedure

Estimate the area of contiguous (connected) undeveloped land on the site or within 500 feet of any

area of the site to the nearest 1/2 acre (1/4 acre if the area is less than 0.5 acre).

1) From the table below, find the number of points corresponding to the area and

enter this number in the field to the right.

4

Area (acres) Points

The estimated area of undeveloped land is 0.25 acres or less 4

0.5 5

1.0 6

1.5 7

2.0 8

2.5 9

3.0 10

3.5 11

4.0 or more 12

2) Is this an industrial or commercial property? If yes, enter a score of 3. If no, enter

a score of 1

3

3)a

Enter a score in the box to the right for the habitat quality of the site, using the

following rating systemb. High=1, Intermediate=2, Low=3

3

4) Is the undeveloped land likely to attract wildlife? If yes, enter a score of 1 in the

box to the right. If no, enter a score of 2.c

2

5) Are there any of the following soil contaminants present: Chlorinated

dioxins/furans, PCB mixtures, DDT, DDE, DDD, aldrin, chlordane, dieldrin,

endosulfan, endrin, heptachlor, benzene hexachloride, toxaphene, hexachlorobenzene,

pentachlorophenol, pentachlorobenzene? If yes, enter a score of 1 in the box to the

right. If no, enter a score of 4.

4

6) Add the numbers in the boxes on lines 2-5 and enter this number in the box to the

right. If this number is larger than the number in the box on line 1, the simplified

evaluation may be ended.

12

Notes for Table 749-1

a It is expected that this habitat evaluation will be undertaken by an experienced field biologist. If

this is not the case, enter a conservative score of (1) for questions 3 and 4.

b Habitat rating system. Rate the quality of the habitat as high, intermediate or low based on your

professional judgment as a field biologist. The following are suggested factors to consider in

making this evaluation:

Low: Early successional vegetative stands; vegetation predominantly noxious,

nonnative, exotic plant species or weeds. Areas severely disturbed by human

activity, including intensively cultivated croplands. Areas isolated from other

habitat used by wildlife.

High: Area is ecologically significant for one or more of the following reasons:

Late-successional native plant communities present; relatively high species

diversity; used by an uncommon or rare species; priority habitat (as defined by the

Washington Department of fish and Wildlife); part of a larger area of habitat where

size or fragmentation may be important for the retention of some species.

Intermediate: Area does not rate as either high or low.

c

Indicate "yes" if the area attracts wildlife or is likely to do so. Examples: Birds frequently visit

the area to feed; evidence of high use b mammals (tracks, scat, etc.); habitat "island" in an

industrial area; unusual features of an area that make it important for feeding animals; heavy use

during seasonal migrations.

[Area Calculation Aid] [Aerial Photo with Area Designations] [TEE Table 749-1] [Index of

Tables]

[Exclusions Main] [TEE Definitions] [Simplified or Site-Specific?] [Simplified Ecological

Evaluation] [Site-Specific Ecological Evaluation] [WAC 173-340-7493]

[TEE Home]

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