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APPENDIX B

Environmental Conditions Report

FINAL

Boeing Plant 2


Prepared for The Boeing Company

P.O. Box 3707 Seattle, Washington 98124-2207

Prepared by Floyd|Snider

601 Union Street, Suite 600 Seattle, Washington 98101

December 20, 2011

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Table of Contents

1.0 Introduction ...................................................................................................... 1-1 1.1 PURPOSE .......................................................................................................... 1-1

1.2 SOIL DATA AND EVALUATION CRITERIA ....................................................... 1-2

1.3 GROUNDWATER DATA AND EVALUATION CRITERIA .................................. 1-4

2.0 Northern Shoreline Area ................................................................................. 2-1 2.1 SOIL QUALITY AFTER EXCAVATION .............................................................. 2-1

2.2 FILL QUALITY .................................................................................................... 2-2

2.3 GROUNDWATER .............................................................................................. 2-3

2.3.1 Introduction .......................................................................................... 2-3

2.3.2 North Area Groundwater Results: Protection of Aquatic Species ........ 2-3

2.3.3 North Area Groundwater Results: Protection of Sediment Quality ...... 2-4

2.4 STORMWATER ................................................................................................. 2-4

3.0 Southern Shoreline Area ................................................................................ 3-1 3.1 THE BUILDING 2-41 PROJECT ........................................................................ 3-1

3.1.1 Soil Quality After Excavation ............................................................... 3-1

3.1.2 Fill Quality ............................................................................................ 3-4

3.1.3 2-40s Area Groundwater Results ........................................................ 3-4

3.1.4 Stormwater .......................................................................................... 3-4

3.2 THE SOUTHWEST BANK PROJECT ................................................................ 3-5

3.2.1 Soil Quality After Excavation ............................................................... 3-5

3.2.2 Fill Quality ............................................................................................ 3-8

3.2.3 Southwest Bank Groundwater Results ................................................ 3-8

3.2.4 Stormwater ........................................................................................ 3-10

4.0 Conclusions ..................................................................................................... 4-1 4.1 NORTHERN PROJECT ..................................................................................... 4-1

4.2 SOUTHERN PROJECT...................................................................................... 4-1

4.2.1 The Building 2-41 Project .................................................................... 4-1

4.2.2 The Southwest Bank Project ............................................................... 4-2

5.0 References ....................................................................................................... 5-1

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List of Tables

Table 2.1 Washington Sediment Management Standards

Table 2.2 Northern Project—Summary of Soil Analytical Results Remaining After Excavation in the Building 2–122 Project Area

Table 2.3 Groundwater Results in A-Level Wells in the Vicinity of the Building 2–122 Project: Protection of Aquatic Organisms

Table 2.4 Groundwater Results in B-Level Wells in the Vicinity of the Building 2–122 Project: Protection of Aquatic Organisms

Table 2.5 Groundwater Results in A-Level Wells in the Vicinity of the Building 2–122 Project: Protection of Sediments

Table 2.6 Groundwater Results in B-Level Wells in the Vicinity of the Building 2–122 Project: Protection of Sediments

Table 3.1 Southern Project—Summary of Soil and Sediment Analytical Results Remaining After Excavation in the Building 2-41 Project Area

Table 3.2 Groundwater Results in A-Level Wells in Vicinity of the Building 2-41 Project Area: Protection of Aquatic Organisms

Table 3.3 Groundwater Results in A-Level Wells in Vicinity of the Building 2-41 Project Area: Protection of Sediments

Table 3.4 Southern Project—Summary of Soil and Sediment Analytical Results Remaining After Excavation in the Southwest Bank Project Area

Table 3.5 Groundwater Results in A-Level Wells in Vicinity of the Southwest Bank Project Area: Protection of Aquatic Organisms

Table 3.6 Groundwater Results in B-Level Wells in Vicinity of the Southwest Bank Project Area: Protection of Aquatic Organisms

Table 3.7 Groundwater Results in A-Level Wells in Vicinity of the Southwest Bank Project Area: Protection of Sediments

Table 3.8 Groundwater Results in B-Level Wells in Vicinity of the Southwest Bank Project Area: Protection of Sediments

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Environmental Conditions Report Page iii

List of Figures

Figure 1a Northern Project—The Building 2–122 Project Habitat Restoration Cross Sections

Figure 1b Southern Project—The Building 2-41 Project Habitat Restoration Cross Sections

Figure 1c Southern Project—The Southwest Bank Project Habitat Restoration Cross Sections

Figure 2 Southern Project—Groundwater Wells in the Vicinity of the Building 2-41 and Southwest Bank Project

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Environmental Conditions Report Page iv

List of Abbreviations/Acronyms

2LAET Second Lowest Apparent Effects Threshold

AWQC Ambient Water Quality Criteria

bgs Below ground surface

Boeing The Boeing Company

CMS Corrective Measures Study

CSL Cleanup Screening Level

DSOA Duwamish Sediment Other Area

Ecology Washington State Department of Ecology

FOD Frequency of detect

FOE Frequency of exceedance

LAET Lowest Apparent Effects Threshold

MLLW Mean Lower Low Water

PAH Polycyclic aromatic hydrocarbon

PCB Polychlorinated biphenyl

Plant 2 Boeing Plant 2

RCRA Resource Conservation and Recovery Act

SMS Sediment Management Standards

SQS Sediment Quality Standards

SVOC Semivolatile organic compound

USEPA U.S. Environmental Protection Agency

VOC Volatile organic compound

WAC Washington Administrative Code

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1.0 Introduction

1.1 PURPOSE

In accordance with a Consent Decree between the Natural Resource Trustees (National Oceanic and Atmospheric Administration [NOAA]; U.S. Fish and Wildlife Service [USFWS], Washington State Department of Ecology [Ecology], the Suquamish Tribe, and the Muckleshoot Indian Tribe) and The Boeing Company (Boeing) executed in December 2010, Boeing has agreed to construct two habitat restoration projects at Boeing Plant 2 (Plant 2) along the Duwamish Waterway. The two projects will restore and/or create off-channel and riparian habitats in the Lower Duwamish Waterway in an area where they have been largely eliminated due to the channelization and industrialization of the Lower Duwamish Waterway.

The two projects are:

• North Site—The Building 2-122 Project: Creation of a blind channel at the north end of Plant 2, adjacent to Boeing’s Building 2-122, that will restore shoreline and create off-channel habitat.

• South Site—The Building 2-41 and Southwest Bank Project: Removal of the over-water portion of the Building 2-41 complex at the south end of Plant 2 with subsequent restoration of shoreline along the Southwest Bank and Building 2-41.

The design of each of the projects has been developed based on a series of reports that have been developed in accordance with the Consent Decree. The reports provide analysis of the following:

• The chemical quality of sediment, soil, and groundwater within and adjacent to the footprint of the habitat projects (Environmental Investigation).

• The stability of the post-construction slopes (Geotechnical Investigation).

• The stability of the post-construction surfaces with respect to prevailing river flows (Geomorphological Investigation).

• The physical/chemical characteristics of the water that influence plant communities in the Lower Duwamish Waterway (Habitat Parameter Identification).

This Environmental Conditions Report presents the results of an assessment undertaken to determine the long-term viability of habitat restoration projects at Plant 2. This report relies on the extensive environmental investigations at Plant 2 conducted to satisfy the Resource Conservation and Recovery Act (RCRA) order between Boeing and the U.S. Environmental Protection Agency (USEPA). In a few areas, data was collected to supplement the RCRA data. The largest of such investigations was the North Area Investigation.

The success of the habitat projects at Plant 2 are partially predicated on the following:

• Any residual contamination after completion of the Duwamish Sediment Other Area (DSOA) excavation of contaminated soils and sediments is too low to cause detrimental effects to habitat quality.

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• The fill used to construct the habitat restoration projects and to backfill adjacent areas of the DSOA is of sufficient quality to prevent detrimental effects on habitat quality.

• Groundwater discharging through habitat project areas will not recontaminate the habitat and is protective of aquatic species using the habitat areas.

• Stormwater discharging to the habitat project areas will not recontaminate the habitat and is protective of the aquatic species using the habitat areas.

In order to meet these objectives, this report will discuss the residual soil and sediment quality that remains after the Corrective Measure and Habitat Project Construction. Current and expected future groundwater and stormwater quality will also be discussed.

Two projects will be constructed at Plant 2, one in the North Shoreline Area, called the Building 2-122 Habitat Project, and a second combined project in the South Shoreline Area spanning the shoreline areas in front of the 2-40s complex and the Southwest Bank. For simplicity in this report, they will be referred to as the Northern Project and Southern Project, respectively.

1.2 SOIL DATA AND EVALUATION CRITERIA

The Sediment Management Standards (SMS) constituents published in Washington Administrative Code (WAC) 173-204 and their corresponding Sediment Quality Standards (SQS) and/or Lowest Apparent Effects Threshold (LAET) are the focus of this assessment. The SMS SQS/LAET are expressed as their carbon-normalized form or as their dry weight equivalents. Dry weight equivalents are expressed as LAET criteria, rather than SQS. Similarly, the SMS Cleanup Screening Level (CSL) is the carbon normalized form of the Second Lowest Apparent Effects Threshold (2LAET). Analytical results were compared to SMS LAET and 2LAET for coloration in figures. The terms SMS SQS/LAET and SMS CSL/2LAET are used throughout the text in reference to analytical results. Contaminant levels at the SMS SQS/LAET are considered protective of benthic and ecological health in the habitat project area, while concentrations greater than the SMS CSL/2LAET may be considered not to be protective of benthic and ecological health. SMS criteria expressed as both the carbon-normalized SQS and the dry weight equivalent LAET are presented in Table 2.1.

Soil data at Plant 2 has been collected since the late 1980s using standardized USEPA methods. During this period detection limits have decreased as analytical sensitivity has increased. During the RCRA investigation, additional data was collected during a data gaps process in last decade to ensure that sufficient data existed with acceptable detection limits for decision making. For the evaluation of residual contamination all data, including the older data, have been used. That results in a number of “non-detected results” being greater than the SMS SQS/LAET criteria. Because newer data with acceptable detection limits was used to design the excavation cuts, non-detected values greater than the SMS SQS/LAET do not indicate a “data gap” with respect to residual contamination; they simply reflect historical detection limits.

Figure 1a, Northern Project—The Building 2–122 Project, Habitat Restorations Cross Sections, presents soil sampling locations on cross sections in the vicinity of the Building 2–122 Project. Figures 1b and 1c use the same conventions discussed within this section, but present soil and sediment sampling locations in the vicinity of the Southern Project. Analytical results for each

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location are displayed in callout boxes adjacent to the soil borings. The callout boxes contain the following six columns:

• Depth (in feet below ground surface[bgs]) of the sample

• Elevation (in feet Mean Lower Low Water [MLLW]) of the sample

• Sample ID

• Results for polychlorinated biphenyls (PCBs)

• Results for SMS metals

• Results for SMS semivolatile organic compounds (SVOCs)

Beige coloring in the first two columns indicates that the samples will be removed by excavation, while white coloring indicates that the samples will remain after excavation.

Callout boxes shown in Figures 1a, 1b, and 1c reference SMS SQS/LAET standards by comparing analytical results for SMS constituents to SQS/LAET and CSL/2LAET; however, constituents with a frequency of detected exceedance less than 10 percent AND an exceedance factor less than 2.0 are not included in the list of SMS constituents represented by the callout boxes consistent with the ongoing work under the RCRA Corrective Measure.

The following colors are used in the callout boxes:

• White indicates no sample was collected at this depth.

• Green indicates the constituents are less than SMS SQS/LAET. • Yellow indicates one or more constituents are greater than the SMS SQS/LAET, but

no constituent is greater than the SMS CSL/2LAET. • Red indicates that one or more constituents are greater than the SMS CSL/2LAET.

Gray indicates that the constituent was not detected, but that the detection limit was greater than the SMS SQS/LAET. Note that this only occurs with PCBs in North Area borings from the early 1990s (samples B-29, B-30, B-32, HP-AL-27, HP-AL-28, and HP-AL-31) and for certain butylbenzyl phthalate and 1,2,4-Trichlorobenzene results across the site.

In order to establish that the proposed excavation would remove contaminated soil/sediment sufficient to protect habitat quality, the following factors were considered for the habitat project:

1. Detected and non-detected results do not exceed SMS SQS/LAET. These samples are considered clean with no further qualification.

2. Detected and non-detected results that do exceed SMS SQS/LAET are bounded, and the proposed excavation removes the contaminated soil/sediment within this bounded area. Results are considered vertically bounded when a sample taken from the same location at a deeper depth does not exceed SMS SQS/LAET. Results are considered bounded to the North, South, East, and West by clean samples at similar depths at adjacent locations.

3. Non-detected results that exceed SMS SQS/LAET because of elevated detection limits are “bounded” by nearby samples which have lower detection limits and do not exceed SMS SQS/LAET. These locations are discussed, when appropriate, throughout the text. Alternatively, if there is no reason to believe that that constituent is present at a given location (e.g., the constituent was never

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detected at Plant 2), these samples were not considered detrimental to habitat quality, even if left in place.

The analytical results from soil and sediment locations within and adjacent to the habitat projects have been evaluated. Results for the North Project are discussed in Section 2.1 and the South Project in Sections 3.1 and 3.2. Results for samples that are within the area to be removed as part of the RCRA Corrective Measure, ongoing stormwater system retrofit actions, or the construction of the habitat projects have been excluded when appropriate, and the remaining samples have been used to characterize the quality of the soil and sediment that will remain in-place after construction of the projects.

1.3 GROUNDWATER DATA AND EVALUATION CRITERIA

Groundwater at Plant 2 occurs within an alluvial aquifer that discharges to the Lower Duwamish Waterway. Water within the aquifer has been divided into three zones:

• A-Level: the uppermost zone from approximately +8 MLLW (approximately 11 feet bgs) to -8 MLLW.

• B-Level: the middle zone from approximately -15 to -25 feet MLLW.

• C-Level: the deepest zone below -35 feet MLLW.

The Duwamish Waterway is a tidally influenced marine embayment with a freshwater lens of outgoing river water on top of the denser (saltier) marine waters. As a result a “saline groundwater wedge” has formed beneath the waterway. The presence of a saline groundwater wedge affects the movement of groundwater in the vicinity of the waterway, with the wedge acting as a dense, stable mass that is in dynamic equilibrium with the less saline and less dense groundwater. As less dense fresh groundwater migrates toward the waterway it has an upward flow component that causes it to flow over the dense saline groundwater wedge. The result is that groundwater from all three levels of the aquifer discharges at higher bathymetric elevations than would be predicted by assuming horizontal groundwater flow and all groundwater eventually discharges within the shallow areas of the waterway near the shoreline. For this reason, groundwater from both the A-Level and B-Level were evaluated to potential discharge into the habitat projects. Groundwater from the C-Level, which occurs below -35 feet MLLW and is already saline, discharges too low in the waterway to affect the habitat projects.

Shoreline groundwater quality across Plant 2 is monitored by the Shoreline Monitoring Network, which was installed in 2001 as part of the RCRA program. It monitors water quality from north of the 2-10 Building to south of the property line on Jorgensen Forge. The Shoreline Monitoring Well Network currently consists of twenty nine (29) wells and their replacements, including seventeen (17) A-Level wells, six (6) B-Level wells, and six (6) C-Level wells. The shoreline network wells are routinely measured for volatile organic compounds (VOCs) and metals. All of the shoreline wells were analyzed for SVOCs and PCBs for two quarters in 2007 at the request of USEPA. PCBs and SVOCs, primarily low molecular weight polycyclic aromatic hydrocarbons (PAHs), were only detected in only a few wells. Only those wells with the detections are still monitored for SVOCs and PCBs.

This evaluation is intended to answer two questions with regards to groundwater quality:

1. Would groundwater discharging through the habitat project impact aquatic organisms using the habitat project?

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2. Would groundwater discharging through the habitat project recontaminate the sediments of the habitat project?

To answer question 1, groundwater concentrations in the vicinity of the habitat projects were compared to the lowest of the criteria available for protection of aquatic organisms from chronic effects under both freshwater and salt water conditions. The standards considered include Federal Ambient Water Quality Criteria (AWQC; Clean Water Act Section 304), Federal Toxics Rule Standards (40 CFR 131.36), and Washington Surface Water Quality Criteria (WAC 173-201A). This is consistent with the methodology used to establish groundwater cleanup levels under the RCRA Corrective Measure; however, the cleanup levels under RCRA also consider a potential human health pathway from groundwater to seafood to tribal consumption and are often lower than the values required to protect aquatic species.

Mercury reporting limits of 0.02 µg/L were approved by USEPA for this site and are slightly greater than the lowest of the AWQC of 0.012 µg/L. Non-detections at 0.02 µg/L are considered adequate for demonstrating mercury compliance with requirements. The lowest of the copper AWQC is 2.9 µg/L; this value is less than the background copper groundwater concentration of 8.0 µg/L. Copper concentrations of 8 µg/L and less are considered to be in compliance with the AWQC also.

The evaluation of the potential for sediment recontamination from groundwater was performed as part of the Corrective Measures Study (CMS) for the DSOA, specifically, in Appendix H in the March 2011 document (AMEC and Floyd|Snider 2011). That appendix asked whether existing groundwater concentrations would cause recontamination of the sediment remedy greater than SMS SQS/LAET concentrations. Areas where recontamination was possible, such as the Southwest Bank before its cleanup, were identified. Other areas were found to already be protective of sediment quality. Details will be discussed as they apply to the specific habitat project areas.

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2.0 Northern Shoreline Area

The Northern Shoreline Area contains the Building 2–122 Habitat Project, which creates an intertidal embayment at the north end of Plant 2 adjacent to Boeing’s Building 2-122. After the embayment is constructed the area will be backfilled with approximately 2 feet of clean material to provide a suitable substrate for shoreline restoration. The shoreline will be vegetated with marsh and riparian plantings to provide habitat for fish and wildlife species.

2.1 SOIL QUALITY AFTER EXCAVATION

The majority of the Building 2–122 Project Area had contaminant concentrations less than SMS SQS/LAET prior to any excavation (Figure 1a). Excavation work in this area is primarily defined by the desired final grade of the Building 2–122 Project and not by the need to remove contamination. Table 2.2 is a frequency of detect (FOD) and frequency of exceedance (FOE) table that compares analytical results from samples within and upgradient of the Building 2–122 Project that will be left in-place after construction of the Project to SMS SQS/LAET. There are no detected exceedances of SQS/LAET; however, there are several constituents (six SVOCs and total PCBs) with non-detect values at a detection limit that exceeds SQS/LAET. With the exception of total PCBs, which will be discussed later in this section, none of these constituents were retained for analysis at Plant 2, for the reasons described in Section 1.2.

There are no detected exceedances of SMS SQS/LAET at upgradient locations. Non-detect exceedances of LAET by total PCBs at locations B-32 and HP-AL-28 are an artifact of the reporting limit rather than an indication of the presence of high concentrations of PCBs. In addition to PCB non-detect exceedances, one non-detect butylbenzyl phthalate exceedance of SQS/LAET occurs at a depth of 4 to 5 feet bgs at location NA-DP-38. The reporting limit for this sample was 64 µg/kg, compared to the SQS/LAET of 63 µg/kg dry weight. It is bounded by samples that do not exceed SQS/LAET at depths of 0 to 1 feet bgs and 9 to 10 feet bgs. Upgradient locations are not believed to represent a potential source of contamination to the habitat project post-construction.

Within the Building 2–122 Project Area, sixteen locations were sampled for PCBs, metals, PAHs, and/or other SVOCs. Figure 1a illustrates that for most locations, lab results for all constituents in all samples were either not detected or were detected at concentrations less than SQS/LAET. Exceptions occur at five locations:

• PL2-609A and NA-DP-01 on cross section 1-1’

• NA-DP-02 and NA-DP-41 on cross section 4-4’

• NA-DP-06 on cross section 9-9’

At these locations, the sampled concentrations that exceed SMS SQS/LAET are bounded and the proposed cut is below the deepest sampled concentration exceeding SMS SQS/LAET, thus satisfying condition (2) outlined in Section 1.2. Non-detect total PCB results exceed SMS SQS/LAET at six locations: B-29, B-30, HP-AL-28, and HP-AL-31. As with locations B-32 and HP-AL-27, these locations were sampled and analyzed for total PCBs in August 1990. Several newer sample locations (e.g., NA-DP-05, NA-DP-06, and NA-DP-03) are located adjacent to older samples, and provide confirmation that actual total PCB concentrations in the vicinity of these older sampling locations are lower than SMS SQS/LAET.

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2.2 FILL QUALITY

After a careful examination of available fill sources that meet both chemical and geotechnical specification for the fill, Boeing has proposed fill criteria that are consistent (compliant) with SMS SQS/LAET, and are therefore protective of aquatic organisms. Boeing will ensure that all fill used within the habitat restoration project areas will meet the fill criteria in the table below and approved by USEPA prior to construction.

Acceptable Imported Fill Criteria at Plant 2

Constituent Units SQS/ LAET

Background (or PQL) Proposed Fill Criteria Note Soil Sediment

PCBs µg/kg 130 (0.033) (0.033) ND at 0.033 1 Arsenic mg/kg 51 20 14 14 Cadmium mg/kg 5.1 0.77 0.9 < 5.1 Chromium mg/kg 260 NA 68 68–260 2 Copper mg/kg 390 36 50 50–80 3 Lead mg/kg 450 24 22 250 Mercury mg/kg 0.41 0.07 0.2 < 0.41 4 Silver mg/kg 6.1 NA 0.3 < 6.1 Zinc mg/kg 410 85 95 < 410 Notes: 1 PCB fill criteria are based on an expected PQL of 0.033 µg/kg. PCBs are not expected to be present

in recently excavated sand and gravel fill. 2 Chromium(VI) is not expected to occur in natural sand and fill sources (Allard 1995, Hem

1989,Salomons 1984, Shacklette 1984, Sposito 1983, and Thornton 1983). The SMS SQS/LAET value is considerably less than concentrations considered protective of human health (Ecology’s Model Toxics Control Act Method B lists 240 mg/kg as an acceptable concentration to protect human health for residential land use). Where practicable fill with concentrations less than 260 mg/kg will be selected at USEPA’s request.

3 A copper concentration of 80 mg/kg in soil or sediment in contact with water has been calculated to be protective of aquatic organisms. Boeing proposes using fill sources with 95 percent Upper Confidence Limit copper concentrations of 80 mg/kg or less. Where practical fill with concentrations less than 80 mg/kg will be selected at USEPA’s request.

4 These mercury criteria are based on elemental mercury, which is not present in naturally occurring sand and gravel deposits. The more conservative total mercury concentration in soil will be measured and compared to these criteria.

Abbreviations: LAET Lowest Apparent Effects Threshold

NA Not applicable PCB Polychlorinated biphenyl PQL Practical quantitation limit SMS Sediment Management Standards SQS Sediment Quality Standards

TMCL Target Media Cleanup Level USEPA U.S. Environmental Protection Agency

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2.3 GROUNDWATER

2.3.1 Introduction

The majority of groundwater that discharges through the Building 2–122 Project is from the A- and B-Levels of the aquifer. The Shoreline Monitoring Well Network does not extend far enough North to capture groundwater discharging through the Building 2–122 Project. Therefore, groundwater samples were collected from the following locations, which are shown in Figure 1a: Monitoring Wells: PL2-609A, PL2-610A, and PL2-610B.

Groundwater samples were analyzed for metals, PCBs, SVOCs, and VOCs. Two A-Level and one B-Level monitoring wells have been installed within the footprint of the Building 2–122 Project and were sampled as part of the North Area Data Gap Investigation (EPI and Golder 2009); their locations are shown in Figure 2. Data from monitoring wells represent actual groundwater quality more accurately than data from Geoprobe samples, as water quality parameters (temperature, conductivity, pH, etc.) can be monitored for stabilization before sampling, in order to ensure collection of a minimally disturbed sample. Additionally, the construction of the wells, including the surrounding sand packs, generally allows for the collection of samples with very low particulate loads (low turbidity). For this reason, data from the groundwater monitoring wells has been used for the evaluation.

Dissolved metals from field filtered well samples were used in the evaluation process within the Data Gap Investigation Report, rather than total metals results (EPI and Golder 2009). Field filtered dissolved metals results were selected because the evaluation criteria for metals were developed for the dissolved fraction (with the exception of mercury). Total data were used for mercury. The standard analytical method for mercury has a reporting limit greater than the lowest of the chronic criteria for protection of aquatic species. At Plant 2, in areas where mercury contamination was known to exist, the downgradient groundwater concentrations were analyzed using a more costly and sensitive method to ensure that the extent of the plume was defined; in areas where soil mercury concentrations were low (less than cleanup levels) and no mercury was detected in groundwater using the less sensitive method, the data was considered of sufficient quality to determine that the Site was in compliance for mercury concentrations.

2.3.2 North Area Groundwater Results: Protection of Aquatic Species

Tables 2.3 and 2.4 are FOD and FOE tables for metals and PCBs detected in A- and B-Level groundwater monitoring wells compared to the lowest of the criteria to protect aquatic organisms. SVOCs are not constituents of concern for shoreline groundwater at Plant 2.

Groundwater quality in the 2-122 Project Area was found to be protective of aquatic species, as shown in the following points:

• A-Level Wells: As presented in Table 2.3, there are no detected exceedances of chronic water quality criteria in A-Level wells for metals or PCBs.

• B-Level Wells: As shown in Table 2.4, there are no detected exceedances of water quality criteria in B-Level wells. Reporting limits for cadmium exceed the lowest water quality criterion at location PL2-610B. As shown on Figure 1a, adjacent soil samples at this location do not exceed SMS criteria for cadmium; however, soil in the vicinity of PL2-610B will be excavated and backfilled with 2 feet of clean fill, which will remove any potential mercury or cadmium contamination.

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2.3.3 North Area Groundwater Results: Protection of Sediment Quality

Tables 2.5 and 2.6 are FOD and FOE tables for all chemicals detected in A- and B-Level groundwater monitoring wells compared to groundwater concentrations found to be protective of sediment quality in Appendix H of the CMS. As presented in Tables 2.5 and 2.6, there are no detected or non-detect exceedances of the concentrations of constituents found not to be protective of sediments in groundwater in A- and B-Level wells, respectively. Therefore, groundwater quality in the Building 2-122 Project Area is predicted to be protective of sediment quality.

2.4 STORMWATER

Beginning in 2005, Boeing embarked on an extensive series of stormwater investigations and improvements under the RCRA Order. The northern sections of Plant 2 are served by a recently updated, modern stormwater system that captures all stormwater from Plant 2 north of the 2-10 Building. Stormwater from the northern portion of Plant 2 will be routed through centralized stormwater swales and treatment/filtration systems. After filtration and treatment, stormwater will discharge into Slip 4 through Outfall A. Under high storm water conditions, excess water will discharge through Outfall B into the Lower Duwamish. Both outfalls are outside of the Building 2-122 Habitat Project. Stormwater monitoring will continue to be completed in accordance with the RCRA monitoring program and the NPDES permit. The results of performance monitoring will be used to confirm and optimize the source control upgrades and will be discussed with the Trustees as data are available. Additionally, sediment monitoring, including monitoring in front of stormwater outfalls will be conducted for the next 10 years to confirm that the stormwater releases from Plant 2 are protective of sediment quality.

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3.0 Southern Shoreline Area

The Southern Shoreline Area contains the Building 2-41 and Southwest Bank Habitat Project. It includes the removal of the remaining sections of the Building 2-41 complex (including Building 2-49) that overhang the waterway, removal of subsurface contamination beneath the complex, and construction of a new shoreline habitat area. The work in the Southwest Bank includes removal of a large section of metal- and PCB-containing debris, removal of other contamination, and reconstruction of the shoreline. The 2-41 Building Complex and the Southwest Bank will be discussed separately below because their characteristics are sufficiently different that the discussion is clearer when they are addressed separately.

3.1 THE BUILDING 2-41 PROJECT

This section of the site, which is approximately 1,000 feet in length, was originally beneath a large building complex that was demolished in 2010–2011. There are two areas beneath the building complex where PCB contamination has not been completely bounded due to access issues. On-going sampling and cleanup is occurring in the area during final design (and potentially during implementation) to ensure that cleanup within the habitat project meets the cleanup target of the SMS SQS/LAET (130 µg/kg dry weight). These will be discussed further below.

3.1.1 Soil Quality After Excavation

Figure 1b presents cross sections and callout boxes corresponding to the Building 2-41 Project. These sections are formatted in the same way as the Building 2–122 Project cross sections presented in Figure 1a.

Table 3.1 is an FOD and FOE table that compares samples that will be left in place after construction of the habitat project to SMS SQS/LAET.

The proposed excavation and fill actions for soil and sediment in the Building 2-41 Area are deemed sufficient to protect habitat quality. Details of the proposed excavation and fill actions throughout the area are discussed in the following sections.

SMS Metals

Metals were detected infrequently in the Under-building Area, and generally at concentrations less than SMS criteria. When metals were detected in excess of SQS/LAET, metals exceedances were typically limited to one or two constituents per sample. For example, on cross section 23+18, silver was detected in excess of CSL/2LAET at location 2-31-DP-50 at a depth of 1 foot bgs, but meets SQS/LAET at depths of 5 and 9 feet bgs. No metals exceedances are present in nearby sample SW-48. Metals exceedances at the bottom of the sampled depth interval for any given location, without a deeper sample in compliance with SMS SQS/LAET below the sample with an exceedance, occur at only three locations in the Building 2-41 Project Area; they are discussed below:

• Multiple metals at locations SB-04128 and SB-04129 on cross section 25+04,

• Mercury at location 2-40-DP-039 on cross section 25+97,

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• Lead at the locations in the vicinity of the Lead Debris Interim Measure Area indicated on cross sections 30+26 and 30+46.

All other metals exceedances are bounded and will be removed by the proposed excavation.

Locations SB-04128 and SB-04129 were sampled to a depth of 1 foot bgs. Zinc exceeds SQS/LAET at location SB-04128, while cadmium, chromium, silver, and zinc exceed the CSL/2LAET at SB-04129. The excavation extends at least 2 feet below both of these samples. Nearby soil borings SB-04127 and SD-UB-004 can be used to bound metals contamination. SB-04127 was sampled for metals at depths of seven and 13 feet bgs, and results are in compliance with LAET. SD-UB-004 was sampled for metals at depths of 3, 4, and 5 feet bgs, and results are also in compliance with LAET. This data indicates that metals contamination at SB-04128 and SB-04129 is shallow and will be removed by the proposed excavation.

An isolated mercury exceedance of CSL/2LAET was recorded at a depth of 10 feet bgs at location 2-40-DP-039 using USEPA Method 7471A. Mercury was not detected at depths of 1 or 5 feet bgs from the same location, and samples from locations 30 feet away to the North and South are also in compliance with the SQS/LAET for mercury. The proposed excavation extends 2 feet below the mercury exceedance, and the area will be covered with 4 feet of clean fill. These actions are considered sufficient to provide for the protection of habitat quality.

In the Lead Debris Interim Measure Area, locations DWN-01 and DWN-02 have lead exceedances over a depth interval from 0 to 3 feet bgs. PL2-241IM-CUP and PL2-241IM-CLOW were taken as confirmation samples at the time of the original sampling in this area, at a depth of 3 to 4 feet bgs and 0 to 3 feet bgs, respectively. It is likely that lead exceedances recorded in these samples are due to high lead concentrations in shallower portions of the soil samples taken at this time, as lead results at locations DDS-LOWER and DDS-UPPER indicate that lead contamination in the Lead Debris Area drops off rapidly at a depth of approximately 4 feet bgs. The excavation surrounding samples with lead exceedances extends at least 4 feet bgs, and will be sufficient to remove lead contamination in this area.

Polychlorinated Biphenyls (PCBs)

Throughout the Building 2-41 Project Area, PCB contamination is generally greater at the surface, with diminishing PCB concentrations at progressively deeper sample intervals. Most soil and sediment borings with PCB exceedances in shallower samples also have samples at deeper depths with PCB concentrations in compliance with SMS standards, which bound the contamination. The proposed excavation is designed to remove PCB contamination in excess of SQS/LAET in these instances. Locations with PCB contamination that exceeds SMS criteria at the bottom of the sampled interval are:

• PCBs beneath the Underflow flume: Location 3 and Location 4 on cross section 24+04 and Location 1 on cross section 24+18

• SD-UB-003 on cross section 24+79

• SD-UB-007 on cross section 27+03

Location 3, Location 4, and Location 1 were sampled as part of the historical Underflow Flume Interim Measure. Samples at these locations from a depth of 0 to 2 feet bgs were removed, while samples from a depth of 2 to 3 feet bgs were left in place. Total PCB concentrations range from 500 to 1,200 µg/kg dry weight in the remaining samples. Sediment boring SD-UB-002 was

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placed near these locations as part of the 2008 Under-building Investigation to bound the depth of PCB contamination in this area. At depths of 3, 4, and 5 feet bgs at location SD-UB-002, Total PCB results were non-detect using a detection limit of 20 µg/kg dry weight. The proposed excavation in the vicinity of these locations extends to an elevation of -2 feet MLLW; the sloping excavation will be removing between 4 and 11 feet of material. The area will be covered with at least 5 feet of clean fill. Recent soil samples from locations in the Uplands were analyzed for PCBs at depths of 5–6 and 9–10 feet bgs. While results indicate that elevated concentrations of PCBs are present at a depth of 5–6 feet bgs, concentrations are in compliance with SQS/LAET at 9–10 feet bgs. Further sampling is occurring in this area to confirm that the uplands extent beneath the underflow flume is excavated. These actions are considered sufficient to remove PCB contamination in excess of the SQS/LAET and to protect of habitat quality.

Samples from location SD-UB-003 follow the expected trend of decreasing PCB contamination with increasing depth bgs. At the deepest sample interval (7 to 9 feet bgs), PCB contamination is reported at 440 µg/kg dry weight. Nearby soil boring SB-04140 not analyzed for PCBs. The proposed excavation extends to a total depth of 11 feet bgs in this area. Any remaining PCB contamination below 11 feet bgs will be covered by approximately 10 feet of clean fill. These actions are considered protective of habitat quality.

Location SD-UB-007 was sampled for PCBs at depths of 3, 4, and 5 feet bgs. Total PCBs exceed SQS/LAET at depths of 4 and 5 feet bgs, at concentrations of 240 and 166 µg/kg dry weight, respectively. The proposed excavation in this area extends to approximately 5 feet bgs, which will remove most of the known PCB contamination. The area will then be backfilled with approximately 8 feet of clean fill. These actions are considered protective of habitat quality.

Other Semivolatile Organic Compounds

Nine of the SVOCs that were never detected in the Building 2-41 Project area contain detection limits that are greater than their SQS/LAET. Eight of these nine chemicals were analyzed in hundreds of soil and sediment samples at Plant 2 and were eliminated as constituents of concern because they were detected infrequently and at low concentrations. The remaining constituent, butylbenzylphthalate, was retained for analysis in callout boxes showing analytical results. In Figure 1b, samples are colored grey where butylbenzylphthalate was not detected, but with a detection limit exceeding SQS/LAET.

Similar to metals, SVOCs were detected infrequently at concentrations exceeding SQS/LAET or CSL/2LAET within the Building 2-41 Project Area. The only exceedance of SMS criteria among other SVOCs that is not being removed by the proposed excavation occurs at SD-UB-013 on cross section 30+46. At this location, flouranthene was detected at a concentration exceeding CSL/2LAET at a depth of 2 to 3 feet bgs. Flouranthene is less than SQS/LAET at samples from deeper sample intervals at this location (samples intervals of 3 to 4 and 4 to 5 feet were also analyzed for SVOCs). The proposed excavation extends approximately 3 feet bgs in the vicinity of SD-UB-013. The area will be covered with 3 feet of clean fill. This action is considered sufficient to provide for the protection of habitat quality.

The only other SVOC detected at concentrations exceeding SQS/LAET in the Building 2-41 Project Area is 1,2,4-Trichlorobenzene. 1,2,4-Trichlorobenzene was detected at a concentration exceeding CSL/2LAET at a depth of 1 foot bgs at location SD-DUW28 on cross section 32+16. SVOCs were not analyzed for at deeper intervals at this location, and nearby samples were not analyzed for SVOCs. However, the primary use of 1,2,4-trichlorobenzene was

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as a dielectric mixed with PCBs in transformers, capacitors, and hydraulic fluids; therefore it is likely that they are co-located contaminants at this location and PCBs are well-bounded in the adjacent samples. At location SD-DUW28, PCB contamination exceeds CSL/2LAET at a depth of 2 feet bgs, but is clean (non-detect at 78 µg/kg) over the depth interval from 3 to 7 feet bgs.

3.1.2 Fill Quality

Fill quality criteria will be determined in the Building 2-41 Project Area in the same way that fill quality was determined for the Building 2–122 Project. The reader is referred to Section 2.2 for the requirements for fill quality for Plant 2.

3.1.3 2-40s Area Groundwater Results

Protection of Aquatic Species

The general characteristics of the aquifer along the shoreline in the South Area of Plant 2, including the Building 2-41 Project Area, are the same as the characteristics of the aquifer previously described in Section 1.3. The Shoreline Monitoring Network is present in this area and is represented by three A-Level monitoring wells. Groundwater samples have been taken from these wells semi-annually or annually for metals (total and dissolved) since 2001.

Ten (10) samples were taken from Monitoring Wells PL2-443A, PL2-420A, and PL2-425A. Table 3.2 is an FOD and FOE table that compares groundwater results to the lowest of state and federal chronic water quality criteria for the protection of aquatic organisms. PCBs and SVOCs were not detected in these wells in 2007; and have not been monitored for them since. Groundwater results presented in Table 3.2 show that no metals were detected at concentrations exceeding the lowest applicable criteria for protection of aquatic organisms. Reporting limits for cadmium are in excess of the lowest applicable criteria for all samples. Because soils in the area were not contaminated with cadmium, the reporting limits were considered adequate to eliminate cadmium as a concern in groundwater in the area.

Protection of Sediment Quality

Results from the complete Shoreline Monitoring Network were evaluated in the 2011 CMS. Existing concentrations from the wells in this area were found to be protective of sediment quality (Table 3.3).

3.1.4 Stormwater

As part of the redevelopment of Plant 2, stormwater south of the 2-10 Building to the southern property line is undergoing a major system-wide upgrade over the next few years. The stormwater will be collected in three large basins, conveyed to new lined stormwater swales, treated/filtered, and discharged through new outfalls into the Lower Duwamish Waterway. This new system will replace all historical stormwater outfalls in the 2-41 Building complex area. This area will be served by the new northern and central basins.

The new outfalls have been designed to discharge between -9 and -10 feet MLLW, a depth that places the discharge outside of the Southern Habitat Project. Performance monitoring in accordance with the RCRA monitoring program and the NPDES permit will accompany all

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system upgrades, and the results will be used to confirm and optimize the source control upgrades. Additionally, sediment monitoring, including monitoring in front of stormwater outfalls will be conducted for the next 10 years to confirm that the stormwater releases from Plant 2 are protective of sediment quality.

3.2 THE SOUTHWEST BANK PROJECT

The Southwest Bank Corrective Measure consists of the removal of a historical overbank deposit of debris containing metals and PCBs. It excavates the bank back to approximately its location in the 1930s. The bank is then further contoured to create a habitat project. It extends from the 2-49 Building to just north of the 2-66 Sheetpile where the slope required to support the sheetpile is too steep for use in the habitat project.

3.2.1 Soil Quality After Excavation

The Southwest Bank Project Area and associated analytical data is shown on Figure 1c1

Adequate analytical data exists to perform an environmental assessment for the Southwest Bank with the exception of remaining data gap where the Southwest Bank extended beneath the 2-49 Building. This area includes the PL2-036A/AR well pair, the Outfall 12/Stretch Press Pit Area, and boring SB-06633 and SB-06616. On Figure 1c it is shown as the PCB Investigation Area. Prior to demolition of the 2-49 Building in 2011, it was not possible to access this area; now that the building has been removed, the investigation is underway and will be complete in first quarter 2012. The goal is to bound the PCB contamination to ensure that cleanup within the habitat project meets the cleanup target of the SMS SQS/LAET (130 µg/kg dry weight) and that groundwater cleanup level for PCBs of non-detects at 0.02 µg/L can be met at PL2-036AR. These will be discussed further below.

, with cross sections that extend from 32+79 to 37+67. The 2-66 Sheetpile shown on cross section 37+67 is not part of the Southwest Bank Project Area. Figure 1c reflects where soil and nearshore sediment will be removed; depending on the location, the soil may be removed as part of the Southwest Bank Corrective Measure, as part of Interim Measures in the uplands to support the new stormwater swales, as part of a Toxic Substances Control Act area removal near historical Outfall 12, or to meet habitat project objectives (such as specific elevations).

Table 3.4 is an FOD and FOE table that compares constituents to SQS/LAET for the samples remaining after the proposed RCRA Corrective Measure, stormwater facilities excavation, and construction of the habitat projects. Twelve of the semi-volatile compounds that were never detected in the Building 2-41 or Southwest Bank Project Areas contain detection limits that are greater than their SMS criteria. Ten of these twelve chemicals were analyzed in hundreds of soil and sediment samples at Plant 2 and were eliminated as constituents of concern due to the infrequent detections and low concentrations. The remaining chemicals, butylbenzylphthalate and 1,2,4-trichlorobenzene, were retained for analysis in callout boxes.

1 Figure 1c contains representative cross-sections through the Southwest Bank. The full analysis that leads to the

design excavations included all data. The text discusses a number of locations that are between the cross-sections shown.

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SMS Metals

In the Southwest Bank, fill containing miscellaneous debris (“debris fill”), including glass shards and brick, was used to expand the shoreline of the site in the 1940s. This debris fill contains elevated concentrations of most SMS metals, including cadmium, chromium, copper, lead, silver, and zinc. Geologic logs in the portion of the Southwest Bank containing debris fill confirm that elevated concentrations of multiple metals are tied to the presence of debris fill, and that once native soil or sandy soil is reached, metals concentrations return to levels in compliance with SMS criteria. The Southwest Bank Corrective Measure involves not only removing soil and fill to the excavation limits shown on the sections, but also a requirement “in the field” to remove visible debris should it extend beyond these limits. Because of its nature, it has been easy to visibly distinguish from the underlying sands.

There are several isolated metals exceedances in the Southwest Bank Project Area between cross sections 32+79 and 36+48 that warrant further discussion; they include the following:

• Cadmium exceeds SQS/LAET at PL2-015BR on cross section 35+08. At location PL2-015BR, cadmium exceeds SQS/LAET at a depth of 5 feet bgs. Cadmium meets the criteria at a depth of 10 feet bgs at this location. The excavation in this area extends 8 feet bgs in this area. However, this location falls within the boundaries of the excavation being completed in 2011 and 2012 for stormwater facilities upgrades (indicated on Figure 1c by the grey shaded area labeled 2011–2012 Facility Upgrades for Stormwater Excavation to 11 ft bgs). As indicated on the figure, the excavation will be completed to 11 feet bgs, which will be sufficient to remove cadmium contamination in excess of LAET. Several feet of clean backfill will cover exposed sediment after the completion of the excavation. These actions are presumed to be protective of habitat quality.

• Cadmium exceeds CSL/2LAET at 2-66-DP-11 on cross section 36+48. Cadmium meets SMS criteria at depths of 1 and 5 feet bgs at this location; however, cadmium exceeds the CSL/2LAET at a depth of 10 feet bgs at location 2-66-DP-11. No deeper samples at this location are available. Nearby samples SB-06635 (approximately 20 feet southwest of 2-66-DP-11) and SB-06634 show that metals at the same elevations are less than SQS/LAET criteria, indicating that the cadmium exceedance is limited in both vertical and horizontal extent and will be removed by the planned excavation.

In addition to the isolated metals exceedances described above, metals exceedances in areas known to contain debris fill are present beginning on cross section 36+48. Locations with metals contamination characteristic of debris fill are:

• PL2-013A on cross section 36+48 (arsenic, cadmium, copper, chromium, lead, mercury, silver, and zinc exceed SQS/LAET or CSL/2LAET at multiple depths)

• SB-06641, SB-06624, and PL2C-2-60Y-F-DP-S on cross section 36+95 (cadmium copper, chromium, silver, lead, and zinc exceed SQS/LAET or CSL/2LAET at multiple depths)

• SB-06644 on cross section 37+37 (cadmium, copper, chromium, lead, silver, and zinc exceed SQS/LAET or 2LAET)

Debris fill contamination is believed to be bounded vertically throughout this area, except on cross section 36+95 from PL2C-2-60Y-F-DP-2 shoreward. This area is approximately where the

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1930s shoreline had a small embayment-like feature that was approximately 20 by 40 ft in extent; the debris fill appears to be deeper here than in the surrounding areas. The proposed excavation has been designed to remove known metals contamination associated with the current understanding of the location of debris fill in the Southwest Bank. Additionally, all visible debris fill will be removed as part of the Southwest Bank Project. As has been previously discussed, metals contamination tends to be closely associated with the presence of debris fill, and once sandy soils have been reached, metals concentrations are typically less than SMS criteria.

After the completion of the excavation and removal of all visible debris fill, the Southwest Bank will be covered with a minimum of 2 feet of clean fill. These actions are presumed to be protective of habitat quality.

Polychlorinated Biphenyls (PCBs)

As seen in the Building 2-41 Project Area, PCB contamination in the Southwest Bank Project Area is generally greater at the surface, with diminishing PCB concentrations at progressively deeper sample intervals. However, there are several areas within the Southwest Bank Project Areas where pockets of high PCB concentrations are surrounded by lower concentrations at both deeper and shallower depths. The proposed excavation is designed to remove PCB contamination in excess of SQS/LAET criteria regardless of the pattern of contamination observed. Locations with PCB contamination that exceeds SQS/LAET criteria at the bottom of the sampled interval are:

• Outfall 12 Area: SD-04402, SD-04904, SD-DUW94, SD-DUW99 in the vicinity of Historical Outfall 12 on cross sections 33+34 and 33+60. A detailed removal action is planned for this area as part of the Corrective Measure that uses all available data to excavate below the PCB contamination. Final concentrations in this area after the excavation will be less than the SMS criteria. The entire Outfall 12 Area will be covered by at least 2 feet of clean backfill after the completion of the excavation. The excavation action previously described, in combination with the addition of clean fill, are deemed sufficient to remove PCB contamination in excess of SQS/LAET and to protect habitat quality.

• PCB Investigation Area: SD-04901, SD-04903, and SD-04920 on cross section 33+87 and SB-04914 on cross section 34+52 and SB-04916 on cross section 35+08. The on-going PCB investigation beneath the 2-49 building and adjacent to Wells PL2-036A and PL2-036AR will define the extent of PCB contamination in this area in time for final design. Removal of contamination to levels less than the SQS/LAET will be performed within habitat project based on the new data.

• SB-04916 on cross section 35+08 was sampled for Total PCBs at a depth of 4 feet bgs. The PCB concentration in this sample exceeds 2LAET, at a concentration of 1,880 µg/kg. The proposed excavation in the vicinity of SB-04914 extends to at least 11 feet bgs, 7 feet below the sampled depth that exceeds SMS criteria. Afterwards, the area will be covered with at least 2 feet of clean fill. These actions are deemed sufficiently protective of habitat quality.

• SB-06633 and SB-06616 on cross section 35+93; at location SB-06633, PCB concentrations decrease with increasing depth bgs, from a concentration of 1,600 µg/kg at 8 feet bgs to a concentration of 440 µg/kg at 15 feet bgs. The proposed excavation shown on the cross section in this area is approximately 15 feet

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deep, potentially leaving some contamination greater than SMS criteria behind. Additional PCB data will be collected from 15 to 25 feet bgs in this area as part of the proposed PCB Investigation in early 2012. This additional data will be used to supplement existing data and to confirm the proposed excavation depth is sufficient. This area will be covered with nearly 7 feet of clean fill after completion of the DSOA excavation. At location SB-06616, the PCB concentration at 12 feet bgs is 590 µg/kg. The proposed excavation will remove sediment to a depth of approximately 16 feet bgs at this location. The cut surface will be covered with approximately 7 feet of clean fill after completion of the excavation. These actions are presumed to be protective of habitat quality.

Semivolatile Organic Compounds

Similar to the Building 2-41 Project Area, SVOCs were detected infrequently and at low concentrations in the Southwest Bank Project Area. The only SVOC detection exceeding SMS criteria occurs at a depth of 0.3 foot at location SD-04904 on cross section 33+60. This sample exceeds SQS/LAET for butylbenzyl phthalate but the detected concentration does not exceed CSL/2LAET. Deeper sample intervals were not analyzed for SVOCs. The proposed excavation is approximately 7 feet bgs in this area, which should be sufficient to remove butylbenzyl phthalate contamination. The area will then be covered by 2 feet of clean fill. These actions are considered protective of habitat quality.

3.2.2 Fill Quality

Fill quality criteria will be determined in The Southwest Bank Project Area in the same way that fill quality was determined for the Building 2–122 Project. The reader is referred to Section 2.2 for a discussion of fill quality for use at Plant 2.

3.2.3 Southwest Bank Groundwater Results

The characteristics of the aquifer described in Section 1.3 with respect to the Northern Project are the same as they are for the Southern Project. The Shoreline Monitoring Well Network described in Section 3.1.3 monitors the quality of groundwater in the Southwest Bank Project Area in addition to the Building 2-41 Project Area. A series of groundwater wells were constructed in the debris fill along the Southwest Bank and were found to contain elevated concentrations metals, and in the case of PL2-036A, PCBs. The source of the groundwater contamination was found to be the debris fill. As part of the Focused CMS for the Southwest Bank, new wells were installed upgradient of the debris fill to represent groundwater quality that would discharge through the Southwest Bank after the debris fill was removed. It is these wells that form the Shoreline Monitoring Well Network in the Southwest Bank Area. Both the wells in the contaminated fill and the new shoreline monitoring wells have been monitored regularly for VOCs and metals. As noted in Section 3.1.3, the shoreline wells were analyzed for SVOCs and PCBs in 2007. At that time it was found that both PL2-036A and its upgradient replacement Well PL2-036AR contained PCBs. Both wells continue to be monitored semi-annually for PCBs.

Protection of Aquatic Species

Tables 3.5 and 3.6 are FOD and FOE tables for metals and PCBs in A- and B-Level groundwater monitoring wells, respectively, in the vicinity of the Southwest Bank Project. These

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tables compare groundwater concentrations to the lowest of the chronic exposure criteria to protect aquatic organisms, as discussed in Section 1.3.

Three of the wells in the Shoreline Monitoring Well Network were completed in contaminated fill in the Southwest Bank and have elevated concentrations of metals and/or PCBs and have been excluded from groundwater results presented in Tables 3.5 and 3.6 and discussed throughout this section. These locations are PL2-013A, PL2-015A, and PL2-036A. The approved Southwest Bank Corrective Measure, which will be constructed with the DSOA Corrective Measure, will remove the debris, cut back the bank, and remove these wells and surrounding aquifer material and groundwater. Therefore, these three wells were not included in analysis completed for Appendix H of the CMS and are not relevant to groundwater quality in the habitat project. Data from replacement Wells PL2-013AR, PL2-015AR, and PL2-036AR, installed at the approximate top of the proposed bank cutback, have been used to represent groundwater quality for water flowing through the bank and sediment following excavation of the Southwest Bank.

Metals in A-Level Wells

Sixteen (16) samples in the A-Level of the aquifer were analyzed for both total and dissolved metals at the following five locations: PL2-013AR, PL2-015AR, PL2-030A, PL2-036AR, and PL2-607A. Groundwater concentrations were found to be protective of aquatic species, except at PL2-036AR.

As shown in Table 3.5, two metals, copper and zinc, were detected at concentrations exceeding the lowest applicable criteria for the protection of aquatic organisms from chronic exposure.

• Copper was detected in excess of the criterion in two samples, both from location PL2-036AR, with a maximum detected value of 4.8 µg/L. These are less than the background copper concentration of 8.0 µg/L and are considered to be acceptable.

• Zinc was detected in excess of the criterion in one sample, at a concentration of 430 µg/L. Zinc was detected in four out of 16 samples, all from location PL2-036AR. Detected concentrations range from 10 µg/L to 430 µg/L. This location is within the PCB Investigation Area and is known to contain both PCBs and metals. Additional excavation is planned in this area to remove PCBs (footprint to be defined in the first quarter of 2012) and metals in the top 11 feet bgs. This work is expected to bring soil concentrations into compliance with SQS/LAET and groundwater concentrations into compliance with the lowest of the chronic ambient water quality requirements.

In addition to detected exceedances of criteria protective of aquatic organisms for both copper and zinc, non-detect results for cadmium exceed the lowest applicable criteria. Cadmium is a soil constituent of concern in the area and is expected to be removed by the Corrective Measure. The cadmium detection limit is within the range of AWQC considered relevant for the Lower Duwamish Waterway.

Metals in B-Level Wells

Ten (10) samples from three wells (PL2-015B, PL2-043B, and PL2-044B) were collected in the B-Level of the aquifer in the vicinity of the Southwest Bank Project and analyzed for metals (Table 3.6). Metals were detected infrequently in the B-Level of the aquifer, and generally at

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concentrations less than the lowest water quality criteria for the protection of aquatic organisms through chronic exposure.

Two metals, chromium and copper, were detected at concentrations that equal or exceed the lowest applicable criteria for the protection of aquatic organisms. Chromium was detected in one sample at a concentration of 10 µg/L; this concentration is equivalent to the lowest water quality criterion for chromium.

Copper was detected in 3 out of 10 samples, at concentrations ranging between 3 and 23 µg/L; the copper groundwater background in the Lower Duwamish Valley is 8 µg/L. While the copper detection at 23 µg/L exceeds the lowest of the chronic criteria and background, the average (which is more relevant for assessing chronic effects) remains less than the criteria, indicating that groundwater quality is protective of the aquatic species.

Reporting limits in the B-Level for several metals are periodically over the lower criteria; the reporting limits are within the range of AWQC considered relevant for the Lower Duwamish Waterway. Boeing continues to work with USEPA to identify laboratory methods that are able to reach the low reporting limits for the naturally brackish to saline samples from the B-Level shoreline wells.

PCBs in A-Level Wells

PCBs were not detected in shoreline monitoring wells in the Southwest Bank, except for the PL2-036A and PL2-036AR pair. As discussed above, contamination associated with PL2-036A and PL2-036AR will be addressed by the Corrective Measure.

Protection of Sediment Quality

Results from the complete Shoreline Monitoring Network were evaluated in the 2011 CMS. Concentrations from the wells in this area were found to be protective of sediment quality (Tables 3.7 and 3.8). A single isolated zinc concentration (one well in 2010) is present at a concentration of concern, but only if the concentration remained at this level for several decades. The average concentrations for zinc at this location and across the Southwest Bank are protective of sediment quality.

3.2.4 Stormwater

As part of the redevelopment of Plant 2, stormwater south of the 2-10 Building to the southern property line is undergoing a major system-wide upgrade over the next few years. The stormwater will be collected in three large basins, conveyed to new lined stormwater swales, treated/filtered, and discharged through new outfalls into the Lower Duwamish Waterway. The new outfalls have been designed to discharge between -9 and -10 feet MLLW, a depth that places the discharge outside of the Southern Habitat Project. Outfall Z, which is located at the southern end of Plant 2, will also be reconfigured to discharge at -10 feet MLLW and will no longer act as a primary basin outfall at Plant 2 but will continue to discharge stormwater from East Marginal Way. Performance monitoring in accordance with the RCRA monitoring program and the NPDES permit will accompany all system upgrades, and the results will be used to confirm and optimize the source control upgrades.

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4.0 Conclusions

4.1 NORTHERN PROJECT

Soil in the vicinity of the Building 2–122 Project generally meets SQS/LAET. Small pockets of contamination, including zinc and copper contamination at NA-DP-01, are bounded laterally by adjacent samples and vertically by samples at deeper depths, and will be removed by the excavation. Therefore, excavation work in the Building 2–122 Project is driven by the desired final grade rather than the removal of contamination. The new habitat surface will be covered by two feet of clean fill from sites which meet SMS SQS/LAET. The fill will not reintroduce contamination at levels that would pose a threat to future habitat quality.

Recontamination of the sediments and bank areas in the Building 2–122 Project by groundwater is unlikely. Detected groundwater concentrations are less than concentrations that were previously demonstrated to be protective of the sediment surface and are also less than the lowest water quality criteria for the protection of aquatic organisms through chronic exposure.

Additionally, in light of the work undertaken to improve the stormwater system and remove contaminant sources from the North Area, stormwater is not expected to be a source of recontamination to the sediments or to aquatic organisms in the vicinity of the habitat project. Long term monitoring over the next 10 years will be used to verify this.

4.2 SOUTHERN PROJECT

4.2.1 The Building 2-41 Project

There are relatively few soil and sediment concentrations in excess of SMS SQS/LAET standards in the vicinity of the Building 2-41 Project. Metals and PCBs represent the majority of contaminated samples in this area, and are bounded both laterally and vertically. Historical sampling activities and site operations indicate that samples with metals and PCB exceedances near the bottom of the sampled depth interval are typically bounded vertically, even if other samples are not available at the same location to demonstrate this. Select locations with unbounded PCB exceedances will be excavated to remove all or most of the known PCB contamination, and then covered with 8–10 feet of clean backfill. These actions are considered protective of habitat quality. Boeing will use fill which will not reintroduce contamination at levels that would pose a threat to future habitat quality.

Groundwater results from groundwater monitoring wells in the vicinity of the Building 2-41 Project indicate that detected groundwater concentrations do not pose a threat to sediment recontamination or to aquatic organisms from the chronic exposure pathway.

In light of the work undertaken to improve the stormwater system and remove contaminant sources from the South Area of Plant 2, stormwater is not expected to be a source of recontamination to the sediments in the habitat of the Building 2-41 Project or to aquatic organisms. All existing outfalls in this area are being replaced with new deep water outfalls to avoid discharging groundwater into the habitat project areas.

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4.2.2 The Southwest Bank Project

Soil and sediment concentrations are frequently in excess of SMS SQS/LAET standards in the vicinity of the Southwest Bank Project. However, this contamination is well bounded and will be removed as part of RCRA corrective measures, interim measures, or facility upgrades such as construction of the new stormwater system. Additional ongoing investigations and site activity to remove obstructions are being completed to characterize the nature and extent of contamination when contaminant concentrations are not well bounded. Outside of these defined excavation boundaries, metals-containing debris fill present in the Southwest Bank will be removed by the excavation contractor, even if observed debris fill extends beyond the planned excavation depth. Post-excavation, the habitat surface will be covered by a minimum of two feet of clean fill. Boeing will use fill that will not reintroduce contamination at levels that would pose a threat to future habitat quality.

After removal of the Southwest Bank debris fill and PCB contamination near and beneath Building 2-49, groundwater in the Southwest Bank (as measured in wells upgradient of the planned excavations) will be protective of both aquatic species and sediment quality.

In light of the work undertaken to improve the stormwater system and remove contaminant sources from the South Area of Plant 2, stormwater is not expected to be a significant source of recontamination to the sediments in the habitat of the Southwest Bank or to aquatic organisms. All existing outfalls in this area are being replaced with new deep water outfalls to avoid discharging groundwater into the habitat project areas. Long term monitoring over the next 10 years will be used to verify this.

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5.0 References

Allard, B. 1995. Trace Elements in Natural Waters. pp. 151–176. ed. Aalbu, B. and E. Steinnes. Boca Raton: CRC Press.

AMEC Geomatrix, Inc. and Floyd|Snider (AMEC and Floyd|Snider). 2011. Duwamish Sediment Other Area and Southwest Bank Corrective Measure Alternatives Study, Volume 1. Prepared for The Boeing Company. Seattle/Tukwila, Washington. March.

Environmental Partners, Inc. and Golder Associates, Inc. (EPI and Golder). 2009. Uplands Corrective Measures Study Volume VIIb: North Area Data Gap Investigation Report Part 1 of 2. Prepared for The Boeing Company. October.

Hem, J.D. 1989. Study and Interpretation of the Chemical Characteristics of Natural Water, 3rd Edition. U.S. Geological Survey Water Supply Paper 2254. U.S. Washington D.C.: Government Printing Office. p. 263.

Salomons, W. and U. Förstner. 1984. Metals in the Hydrocycle. New York: Springer-Verlag p. 349.

Shacklette, H.T. and J.G. Boerngen. 1984. Element Concentrations in Soils and Other Surficial Materials of the Conterminous United States. U.S. Geological Survey Professional Paper 1270. Washington, D.C.: U.S. Government Printing Office. p. 105.

Sposito, G. 1983. “The chemical forms of trace metals in soils.” pp. 123–170 in Applied Environmental Geochemistry, ed. Thornton, I. New York: Academic Press.

Thornton, I. 1983. “Geochemistry Applied to Agriculture.” pp. 231–266 in Applied Environmental Geochemistry. ed.Thornton, I. London: Academic Press.

U.S. Environmental Protection Agency (USEPA). 2011. Letter to Mr. William Ernst and Mr. Michael Gleason, The Boeing Company, from Mr. Shawn Blocker, USEPA Region 10, re: Final Decision and Response to Comments for Boeing Plant 2 Sediments, Duwamish Sediment Other Area and Southwest Bank, Boeing Plant 2, Seattle/Tukwila, Washington, Resource Conservation and Recovery Act (RCRA) Docket No. 1092-01-22-3008(h) EPA ID No. WAD 00925 6819. 8 May.

FINAL

Boeing Plant 2


Tables

Table 2.1Washington Sediment Management Standards

Boeing Plant 2

ChemicalSMS SQS

(dry weight)SMS CSL

(dry weight) UnitsSMS LAET

(dry weight)SMS 2LAET(dry weight) Units

Arsenic 57 93 mg/kg dw 57 93 mg/kg dw Cadmium 5.1 6.7 mg/kg dw 5.1 6.7 mg/kg dw Chromium 260 270 mg/kg dw 260 270 mg/kg dw Copper 390 390 mg/kg dw 390 390 mg/kg dw Lead 450 530 mg/kg dw 450 530 mg/kg dw Mercury 0.41 0.59 mg/kg dw 0.41 0.59 mg/kg dw Silver 6.1 6.1 mg/kg dw 6.1 6.1 mg/kg dw Zinc 410 960 mg/kg dw 410 960 mg/kg dw

Semivolatile Organic Compounds Ionizable Organic Compounds

Phenol 420 1,200 µg/kg dw 420 1,200 µg/kg dw2-Methylphenol 63 63 µg/kg dw 63 63 µg/kg dw4-Methylphenol 670 670 µg/kg dw 670 670 µg/kg dw2,4-Dimethylphenol 29 29 µg/kg dw 29 29 µg/kg dwPentachlorophenol 360 690 µg/kg dw 360 690 µg/kg dwBenzyl alcohol 57 73 µg/kg dw 57 73 µg/kg dwBenzoic acid 650 650 µg/kg dw 650 650 µg/kg dw

CAS Number Chemical

SMS SQS (organic carbon-

normalized)

SMS CSL(organic carbon-

normalized) UnitsSMS LAET

(dry weight)SMS 2LAET(dry weight) Units

Semivolatile Organic Compounds Polycyclic Aromatic Hydrocarbons

Total LPAH 1 370 780 mg/kg OC 5,200 5,200 µg/kg dwNaphthalene 99 170 mg/kg OC 2,100 2,100 µg/kg dwAcenaphthylene 66 66 mg/kg OC 1,300 1,300 µg/kg dwAcenaphthene 16 57 mg/kg OC 500 500 µg/kg dwFluorene 23 79 mg/kg OC 540 540 µg/kg dwPhenanthrene 100 480 mg/kg OC 1,500 1,500 µg/kg dwAnthracene 220 1,200 mg/kg OC 960 960 µg/kg dw2-Methylnaphthalene 38 64 mg/kg OC 670 670 µg/kg dw

Total HPAH 2 960 5,300 mg/kg OC 12,000 17,000 µg/kg dwFluoranthene 160 1,200 mg/kg OC 1,700 2,500 µg/kg dwPyrene 1,000 1,400 mg/kg OC 2,600 3,300 µg/kg dwBenzo(a)anthracene 110 270 mg/kg OC 1,300 1,600 µg/kg dwChrysene 110 460 mg/kg OC 1,400 2,800 µg/kg dwTotal benzofluoranthenes 3 230 450 mg/kg OC 3,200 3,600 µg/kg dw

Benzo(b)fluoranthene 4 No criterion No criterion No criterion No criterionBenzo(k)fluoranthene 4 No criterion No criterion No criterion No criterion

Benzo(a)pyrene 99 210 mg/kg OC 1,600 1,600 µg/kg dwIndeno(1,2,3-cd)pyrene 34 88 mg/kg OC 600 690 µg/kg dwDibenz(a,h)anthracene 12 33 mg/kg OC 230 230 µg/kg dwBenzo(g,h,i)perylene 31 78 mg/kg OC 670 720 µg/kg dw

Chlorinated Benzenes1,2-Dichlorobenzene 2.3 2.3 mg/kg OC 35 50 µg/kg dw1,4-Dichlorobenzene 3.1 9.0 mg/kg OC 110 110 µg/kg dw1,2,4-Trichlorobenzene 0.81 1.8 mg/kg OC 31 51 µg/kg dwHexachlorobenzene 0.38 2.3 mg/kg OC 22 70 µg/kg dw

Phthalate EstersDimethylphthalate 53 53 mg/kg OC 71 160 µg/kg dwDiethylphthalate 61 110 mg/kg OC 200 120 µg/kg dwDi-n-butylphthalate 220 1,700 mg/kg OC 1,400 5,100 µg/kg dwButylbenzylphthalate 4.9 64 mg/kg OC 63 900 µg/kg dwbis(2-Ethylhexyl)phthalate 47 78 mg/kg OC 1,300 3,100 µg/kg dwDi-n-octylphthalate 58 4,500 mg/kg OC 6,200 6,200 µg/kg dw

MiscellaneousDibenzofuran 15 58 mg/kg OC 540 540 µg/kg dwHexachlorobutadiene 3.9 6.2 mg/kg OC 11 120 µg/kg dwN-Nitrosodiphenylamine 11 11 mg/kg OC 28 40 µg/kg dw

Polychlorinated Biphenyls Total PCBs 4 12 65 mg/kg OC 130 1,000 µg/kg dw

Notes:1

2

34

Abbreviations:CAS Chemical abstract numberCSL Cleanup Screening Level

2LAET Second Lowest Apparent Effects ThresholdHPAH High molecular weight polycyclic aromatic hydrocarbonLAET Lowest Apparent Effects ThresholdLPAH Low molecular weight polycyclic aromatic hydrocarbon

mg/kg dw milligram per kilogram dry weightmg/kg OC milligram per kilogram of organic carbon

PCB Polychlorinated biphenylSMS Sediment Management StandardsSQS Sediment Quality Standards

µg/kg dw micrograms per kilogram dry weight

fluoranthene, pyrene, benz(a)anthracene, chrysene, total benzofluoranthenes, benzo(a)pyrene, indeno(1,2,3)pyrene, dibenz(a,h)anthracene, and benzo(g,h,i)perylene. The HPAH criterion is not the sum of criteria values for the individual HPAH compounds listed.The total benzofluoranthenes criteria are compared to the sums of the concentrations of the b, j, and k isomers of benzofluoranthene.There are no criteria for benzo(b)fluoranthene or benzo(k)fluoranthene or for individual PCB Aroclors.

1336-36-3

CAS Number

The total LPAH criterion represents the sum of the following low molecular weight polynuclear aromatic compounds:naphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, and anthracene. 2-Methylnaphthalene is not included in the LPAH definition. The LPAH criterion is not the sum of criteria values for the individual LPAH compounds listed.The total HPAH criterion represents the sum of the following high molecular weight polynuclear aromatic compounds:

117-81-7117-84-0

132-64-987-68-386-30-6

118-74-1

131-11-384-66-284-74-285-68-7

95-50-1106-46-7120-82-1

207-08-950-32-8193-39-553-70-3191-24-2

206-44-0129-00-056-55-3218-01-9

205-99-2

83-32-986-73-785-01-8120-12-791-57-6

87-86-5100-51-665-85-0

91-20-3208-96-8

Constituents for Which the SMS SQS is Expressed as Carbon Normalized

7440-66-6

108-95-295-48-7106-44-5105-67-9

7440-50-87439-92-17439-97-67440-22-4

Constituents for Which the SMS SQS Is Expressed as Dry Weight

Metals7440-38-27440-43-97440-47-3

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December 20, 2011 FINAL Page 1 of 1Environmental Conditions Report

Table 2.1

Table 2.2Northern Project—Summary of Soil Analytical Results Remaining After Excavation in the Building 2-122 Project Area1

Boeing Plant 2

UnitsNumber of

Results

SMS SQS/LAET2

(dry weight equivalents)

Number of Non-detects

Percent Non-detect

Minimum Non-detect

Value

Maximum Non-detect

Value

Number of Non-detect Results that

Exceed Criteria

Percent of Non-detect Results that

Exceed CriteriaCompounds Not Detected

mg/kg 18 5.1 18 100% 0.2 0.5mg/kg 13 6.1 13 100% 0.3 0.5

µg/kg 7 130 7 100% 32 230 5 71%Semivolatile Organic Compounds

µg/kg 12 31 12 100% 4.2 8.4 -- --µg/kg 12 35 12 100% 0.8 1.7 -- --µg/kg 12 110 12 100% 0.8 1.7 -- --µg/kg 7 29 7 100% 59 64 7 100%µg/kg 7 63 7 100% 59 64 1 14%µg/kg 7 670 7 100% 59 64 -- --µg/kg 11 500 11 100% 4.6 65 -- --µg/kg 7 650 7 100% 590 640 -- --µg/kg 7 57 7 100% 59 64 7 100%µg/kg 7 1,300 7 100% 59 64 -- --µg/kg 7 63 7 100% 59 64 1 14%

µg/kg 9 540 9 100% 4.6 43 -- --µg/kg 7 71 7 100% 59 64 -- --µg/kg 7 1,400 7 100% 59 64 -- --µg/kg 11 540 11 100% 4.6 65 -- --µg/kg 7 22 7 100% 59 64 7 100%µg/kg 12 11 12 100% 4.2 8.4 -- --µg/kg 7 28 7 100% 59 64 7 100%µg/kg 7 360 7 100% 300 320 -- --µg/kg 7 420 7 100% 59 64 -- --

UnitsNumber of

Results

SMS SQS/LAET2

(dry weight equivalents)

Number of Detections

Percent Detected

Minimum Detected

Value

Maximum Detected

Value

Location of Maximum

DetectDate of

Maximum Detect

Depth of Maximum

Detect

Number of Detected

Results that Exceed Criteria

Number of Non-detect Results that

Exceed Criteria

Percent of Results that

Exceed CriteriaCompounds Detected

mg/kg 18 57 8 44% 2 11 NA-DP-37 9/9/2008 9–10 ft -- -- --mg/kg 18 260 18 100% 10 31 NA-DP-37 9/9/2008 0–1 ft -- -- --mg/kg 18 390 18 100% 8 29 NA-DP-02 9/4/2008 15–16 ft -- -- --mg/kg 18 450 10 56% 3 27 NA-DP-37 9/9/2008 9–10 ft -- -- --mg/kg 18 0.41 5 28% 0.05 0.11 NA-DP-06 9/4/2008 9–10 ft -- -- --mg/kg 18 410 18 100% 25 85 NA-DP-06 9/4/2008 9–10 ft -- -- --

Semivolatile Organic Compoundsµg/kg 11 670 1 9% 11 11 NA-DP-38 9/4/2008 4–5 ft -- -- --µg/kg 11 1,300 2 18% 4.8 6.4 NA-DP-38 9/4/2008 4–5 ft -- -- --µg/kg 11 960 1 9% 7.8 7.8 NA-DP-38 9/4/2008 4–5 ft -- -- --µg/kg 11 1,300 3 27% 10 58 NA-DP-38 9/4/2008 4–5 ft -- -- --

2-MethylnaphthaleneAcenaphthyleneAnthraceneBenzo(a)anthracene

Zinc

PentachlorophenolPhenol

Constituent

MetalsArsenicChromiumCopperLeadMercury

Hexachlorobenzene This constituent has not been carried forward for analysis3.HexachlorobutadieneN-Nitrosodiphenylamine This constituent has not been carried forward for analysis3.

DimethylphthalateDi-n-ButylphthalateFluorene

bis(2-Ethylhexyl)phthalateButylbenzylphthalate Samples with non-detect exceedances of this compound

were flagged grey in Figure 1b.Dibenzofuran

AcenaphtheneBenzoic AcidBenzyl Alcohol This constituent has not been carried forward for analysis3.

2,4-Dimethylphenol This constituent has not been carried forward for analysis3.2-Methylphenol This constituent has not been carried forward for analysis3.4-Methylphenol

1,4-Dichlorobenzene

SilverPolychlorinated BiphenylsTotal PCBs Refer to text for discussion on impact of elevated detection limit.

1,2,4-Trichlorobenzene1,2-Dichlorobenzene

Cadmium

Constituent Comments

Metals

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